ML19345G886

Responds to 810403 Ltr Requesting Addl Info Re Production of Documents.All Documents Produced in Response to Paragraphs 9,10 & 11 Available for Insp.Page Count of Documents to Be Produced Not Available.Related Correspondence

ML19345G886
Person / Time
Site:	Bailly
Issue date:	04/08/1981
From:	Eichhorn W EICHHORN, EICHHORN & LINK
To:	Whicher J AFFILIATION NOT ASSIGNED
References
NUDOCS 8104220635
Download: ML19345G886 (2)

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EBCHHORN, ElCHHORN & L. INK rococa ca ,. csenmon=,se. ATToutvs At W wetteam a.cicw=oam saas e.oMwam avcNuc

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Ms. Jane M. Whicher c/o BPI g "' $h fQ 109 North Dearborn Street N Suite 1300 L ., ) Y~d #, >p Chicago, Illinois 60602 - *'

4 Re: In the Matter of Northeu.g g t?

..iu.tana Public Service Ccmpany (Bailly Generating Station, Nuclear 1),

Docket No. 50-367 (Construction Permit Extension)

Dear Ms. Whicher:

We have your letter of April 3 seeking additional information f regarding production of documents.

The November 20, 1980 order required NIPSCO to produce documents requested under paragraphs 9, 10 and 11 of PCCIs' second request for production of documents, but limited "the documents to be produced under the three requests to those which relate to the delay in construction." In view of your assertions that matters other than those identified by NIPSCO contributed to the delay in constru'ction and to avoid further controversy regarding discovery, we have produced additional documents within the subject areas referred to in paragraphs 9, 10 and 11 of PCCIs' second request. However, as you know, it is our view that no documents limited to those subject areas can be said to " relate

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to the delay in construction." As I advised in my letter of March 25, 1981, all documents produced in response to PCCIs' second request are now available for your inspection and copying at the offices.of NIPSCO's Nuclear Staff.

You have also asked for a page count of the documents we "will be producing". I assume you are referring to the additional documents produced in response to paragraphs 9, 10 and 11 of PCCIs' second request following the Board's order of November 20, 1980. The gathering of those documents began following the Board's November 20 order and has continued until just recently.

At the same time we have been updating document production requested s

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EICHHORN, ElCHHORN & LINK Ms. Jane M. Whicher Page 2 April 8, 1981 by the other paragraphs of PCCIs' second request. No count of documents was made as they were assembled and documents are not segregated by request number. I am therefore unable to respond to your question regarding the number of pages produced.

In any event all documents requested by PCCIs' second request for production of documents are now and have been for some time available for your inspection and copying at the offices of NIPSCO's Nuclear Staff. I would appreciate your prompt advice as to whether and when you would like to inspect them.

Yours very truly, EICHHORN, EICHHORN & LINK

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By:

William H. Eidhhorn WHE/dgg cc: Herbert Grossman, Esquire, Chairman

( Dr. Robert L. Holton Dr. J. Venn Leeds Docketing and Service Section Howard K. Shapar, Esquire Steven C. Goldberg, Esquire Susan Sekuler, Esquire Edward W. Osann, Jr., Esquire Mr. Mike Olszanski & Mr. Clifford Mezo Mr. George Grabowski & Ms. Anna Grabowski e

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