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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20058M0361993-04-12012 April 1993 Partial Response to FOIA Request for Documents.Forwards Records in App L Which Are Being Withheld Partially for Listed Reasons,(Ref FOIA Exemptions 5) IR 05000367/19870211987-09-29029 September 1987 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-367/87-21 & 50-370/87-21 ML20235M4251987-07-13013 July 1987 Partial Response to FOIA Request for Documents Re Acrs. Forwards Documents for Categories One & Three of FOIA Request.Review of 21 Addl ACRS Documents Continuing ML20234E4571987-06-23023 June 1987 Partial Response to FOIA Request for 771026 Minutes of ACRS Subcommittee on Fluid/Hydraulic Dynamic Effects Meeting in Portland,Or & Addl ACRS Documentation.Documents Identified on App H & Addl ACRS Documents Encl ML20212H6601987-01-20020 January 1987 Final Response to FOIA Request.App F Documents Re Marviken II Project Encl & Available in PDR ML20140F3691986-01-14014 January 1986 Further Response to FOIA Request for Several Categories of Documents Re Pressure Suppression Containment.Fsar & SER for Limerick Only Documentation Re 4x4 Tests.Encl Apps D-G Documents Responsive to Item 4 Also Available in PDR ML20138H0481985-12-0606 December 1985 Responds to FOIA Request for SECY-85-152 & Commission 850523 Order.Forwards App Documents.Commission Order & Attachment 1 to Secy Placed in Pdr.Portions of SECY-85-152 Being Withheld (Ref FOIA Exemption 5) ML20138Q8301985-12-0303 December 1985 Further Response to FOIA Request for Records Re Voluntary or Required Redress of Sites Where Const Was Terminated, Including Crbr & Legal Analysis.Forwards App E Documents.App D & E Documents Available in Pdr.Photographs Also Available ML20095G7811984-08-22022 August 1984 Requests Response Re Resolution of 820604 Application for Fees & Expenses Under Equal Access to Justice Act.Payment Clearly Authorized by 5USC504(d)(1).No Issue Exists to Commission Granting Petition.Related Correspondence ML20084P3501984-03-14014 March 1984 Requests Response to Encl W & V Smelser 840210 Inquiry Into NRC Attitude Toward Utils.Concerns Include Marble Hill & Bailly Cancellation,Withdrawal of Util Application for Zimmer & Denial of License for Byron Facility ML20080R2831984-02-22022 February 1984 Requests Ruling on 820604 Application for Award of Attys Fees Under Equal Access to Justice Act in Light of Comptroller General 830929 Ruling.Related Correspondence ML20078F9881983-10-0505 October 1983 Requests Status Rept on Author Fee Petition ML20077N5691983-09-0909 September 1983 Requests Status Rept of Application for Award of Fees & Expenses Under Equal Access to Justice Act (Filed 15 Months Ago).Matter Delayed Well Beyond Reasonable Time for No Apparent Reason ML20072D6841983-06-0909 June 1983 Requests Status of Business & Prof People for Public Interest 820604 Application for Fees Under Equal Access to Justice Act ML20066H7941982-11-17017 November 1982 Forwards Final Rept on Completion of Site Restoration Program,Per ASLB 820506 Order ML20027D6631982-11-0202 November 1982 Forwards Notice of Final Insp to Be Conducted on 821116 Following Completion of Site Restoration Work,Per 820506 Order Terminating Proceedings on Extension of CPPR-104 ML20065H5221982-10-0101 October 1982 Forwards Notice of Site Insp to Be Conducted on 821018 in Conjunction W/Ongoing Restoration Work,Per ASLB 820506 Order Terminating Proceedings on Application for CP Extension ML20063L1511982-09-0101 September 1982 Forwards Second Rept on Progress of Site Restoration Plan, Per ASLB 820506 Order ML20058J5371982-08-0606 August 1982 Requests Comptroller General Opinion Re Availability of Funds to Pay Awards by Us Agency to Intervenors Under Equal Access to Justice Act (Eaja).Eaja Conflicts W/Nrc FY82 Appropriations Act ML20054L9191982-07-0606 July 1982 Informs That No Questions Eliminated Re Existence of ASLB to Rule on Application for Award of Fees & Expenses Since 820624 Notice of ASLB Reconstitution Issued ML20054K9751982-06-25025 June 1982 Forwards Evaluation of First Quarterly Rept Re Progress on Site Restoration.Util Made Reasonable Progress in Restoring Site.Evaluation Forwarded to Parties Per ASLB 820506 Order ML20054G5791982-06-18018 June 1982 Advises That NRC Will File No Response to Business & Prof People for Public Interest 820604 Application for Award of Fees Until Commission Secretary Renders Advice on Procedure to Be Followed & Schedule Established ML20053D2381982-06-0101 June 1982 Forwards Quarterly Progress Rept Re Site Restoration Plan, Per 820506 Order ML20053E5851982-06-0101 June 1982 Forwards Util Rept on Site Restoration Plan as of 820601 ML20052C6031982-04-29029 April 1982 Advises That Util Will Not File Objections &/Or Requested Mods to ASLB 820412 Memorandum & Order.Certificate of Svc Encl ML20050B5621982-03-30030 March 1982 Responds to NRC 820304 Ltr Re Natl Park Svc 811223 Ltr Commenting on Util Proposed Restoration Plan for Excavation Site.Procedures to Be Undertaken by Util for Sealing & Capping of Wells Adequately Address Concerns ML20049J5861982-03-11011 March 1982 Requests Status Rept on Util Implementation of Revised Restoration Plan ML20039D6151981-12-23023 December 1981 Comments on Facility Site Restoration Plan,In Response to NRC 811120 Ltr.Monitoring Wells Outside Excavation Necessary for Future Monitoring Should Not Be Capped ML20039A8461981-12-15015 December 1981 Comments on Facility Site.Site Endangers Safety of Wildlife & Welfare of Public ML20038B1611981-11-19019 November 1981 Forwards Revised Rept on Resolution of All Const Activities Undertaken at Bailly Site. Rept Incorporates NRC & Porter County Chapter Intervenor Comments ML20010G1211981-08-20020 August 1981 Forwards Spring 1981 Quarterly Rept,Bailly Nuclear-1 Site Encompassing Apr-June 1981. Contains Analyses & Interpretations of Data for Terrestrial & Aquatic Monitoring Efforts ML20010D1901981-08-17017 August 1981 Ack Receipt of 810813 Ltr Requesting Rescheduling of Osann Deposition.Lists Available Dates for Rescheduling.Related Correspondence ML20010B8491981-08-12012 August 1981 Forwards Well Charts for 810729-0805,Bailly Wells W/O Recorders,Pond Levels,Pneumatic Pressure Transducers,Water Meter Readings,Usgs Wells,Chart Recorder Calibr Results for 810805 & Rainfall Data for 810601-0731 ML20010B4131981-08-0606 August 1981 Responds to Rj Vollen 810803 Ltr Re 810731 Press Releases on Util Financial Repts.Qualified Audit Rept Will Be Available on or Before 810831.Press Release Encl ML19247E6511981-08-0404 August 1981 Continues Correspondence Re Const Dewatering & CP Extension for Facility.Requests Latest Info on CP Renewal Hearing, Including Official Orders Issued Since 800807 Order,Current List of Intervenors & All Interrogatories & Depositions ML20010B1271981-08-0303 August 1981 Forwards Well Charts for 810722-29 & Bailly Wells W/O Recorders,Pond Levels,Pneumatic Pressure Transducers,Water Meter Readings & USGS Wells for 810729 ML20009G9301981-07-31031 July 1981 Opposes Licensing of Facilities ML20009H4181981-07-31031 July 1981 Ack Receipt of Two 810724 Ltrs.Requests Addl Documents Responsive to Porter County Chapter Intervenors 810519 Second Request & 810609 Third Request for Production of Documents.Related Correspondence ML20009H4201981-07-31031 July 1981 Confirms That Rj Bohn Deposition Will Continue on 810814 & AP Severance Depositon Will Commence on 810821,per 810730 Telcon.Related Correspondence ML20009G3661981-07-29029 July 1981 Forwards Well Charts for 810715-22 & Bailly Wells W/O Recorders,Pond Levels,Pneumatic Pressure Transducers,Water Meter Readings & USGS Wells for 810722 ML20009G9751981-07-28028 July 1981 Opposes Licensing of Facilities ML20009E1881981-07-23023 July 1981 Forwards Well Charts for 810708-15 & Bailly Wells W/O Recorders,Pond Levels,Pneumatic Pressure Transducers,Water Meter Readings & USGS Wells for 810715 ML20009E0931981-07-21021 July 1981 Forwards Bohn Deposition Exhibit 2.W/o Encl ML20009E2121981-07-21021 July 1981 Forwards Proposed Agreement Per ASLB 810522 Memorandum & Order Granting Protective Order to Ge,For Review & Reply. Relevant Documents Available for Insp ML20009D4501981-07-21021 July 1981 Opposes Licensing of Facilities ML20009C0581981-07-15015 July 1981 Forwards Well Charts for 810701-08 & Bailly Wells W/O Recorders,Pond Levels,Pneumatic Pressure Transducers,Water Meter Readings & USGS Wells for 810708.Pen Off Paper for Well 14 ML20009B1701981-07-10010 July 1981 Package of Two Ltrs Opposing Licensing of Facilities ML20009B2171981-07-10010 July 1981 Responds to Generic Ltr 81-01, Qualification of Insp Exam & Testing & Audit Personnel. Util Commits to Comply W/Regulatory Positions Contained in Reg Guides 1.58 & 1.146 ML20009B7871981-07-0808 July 1981 Requests That ASLB Withhold State of Il 810623 Requested Subpoenas Until General Relevance of Testimony Demonstrated ML20009A9921981-07-0808 July 1981 Forwards Well Charts for 810624-0701 & Bailly Wells W/O Recorders,Pond Levels,Pneumatic Pressure Transducers,Water Meter Readings & USGS Wells for 810701 1993-04-12
[Table view] Category:EXTERNAL CORRESPONDENCE
MONTHYEARML20049J5861982-03-11011 March 1982 Requests Status Rept on Util Implementation of Revised Restoration Plan ML20010D1901981-08-17017 August 1981 Ack Receipt of 810813 Ltr Requesting Rescheduling of Osann Deposition.Lists Available Dates for Rescheduling.Related Correspondence ML20010B4131981-08-0606 August 1981 Responds to Rj Vollen 810803 Ltr Re 810731 Press Releases on Util Financial Repts.Qualified Audit Rept Will Be Available on or Before 810831.Press Release Encl ML20009H4201981-07-31031 July 1981 Confirms That Rj Bohn Deposition Will Continue on 810814 & AP Severance Depositon Will Commence on 810821,per 810730 Telcon.Related Correspondence ML20009E2121981-07-21021 July 1981 Forwards Proposed Agreement Per ASLB 810522 Memorandum & Order Granting Protective Order to Ge,For Review & Reply. Relevant Documents Available for Insp ML20009E0931981-07-21021 July 1981 Forwards Bohn Deposition Exhibit 2.W/o Encl ML20009B7951981-07-0808 July 1981 Ack Receipt of Ah Petersen,Fg Hiple & CR Kulawinski 810629 Notice of Depositions.Util Pending Motion Suggests Depositions Not Be Scheduled After 810731.Earlier Date Requested ML20008G1091981-06-24024 June 1981 Ack Receipt of Wh Eichhorn 810623 Response to Porter County Chapter Intervenors' 810615 Request for Documents Filed W/ NRC Per Generic Ltr 81-23.Requests Documents When & If Available.Related Correspondence ML20004F7691981-06-15015 June 1981 Requests That Any Repts from Facility Submitted to NRC Per Generic Ltr 81-23 Also Be Submitted to Porter County Chapter Intervenors.Related Correspondence ML20004F6351981-06-15015 June 1981 Informs That Wh Eichhorn Furnished Copy of Answers of People of State of Il to Licensee Second Set of Interrogatories. Requests Correction of Svc List Used by Il.Certificate of Svc Encl.Related Correspondence ML20004C6491981-05-29029 May 1981 Forwards Northern in Public Svc Co Latest Cost Estimate & Documents in Supplementary Response to Item 6(a) of Third Request for Production of Documents.Requests Prompt Return of Documents.Related Correspondence.W/O Encl ML19346A0531981-05-28028 May 1981 Poses Addl Questions Re Const Permit Extension to Obtain Info Omitted from First Set of Interrogatories.First Set of Answers Were Not Sufficiently Detailed.Related Correspondence ML20004B7021981-05-19019 May 1981 Responds to 810428 Ltr Re Motion to Compel Answers to Porter County Chapter Intervenors' First Set of Interrogatories to Util.Ltr Is Not Proper Substitute for Answer to Interrogatory ML19345H5851981-05-0707 May 1981 Ack Receipt of 810505 Ltr Demanding Documents.Documents Requested Will Be Delivered During Week of 810511.Two Documents Beyond Discovery Scope,One Proprietary Document & One Other Document Removed.Related Correspondence ML20008G1201981-05-0505 May 1981 Requests Prompt Delivery of Documents Per Porter County Chapter Intervenors Second & Third Requests to Produce Directed to Util ML20003J3781981-04-28028 April 1981 Discusses Concerns Re Util Answers to Porter County Chapter Intervenors' First Set of Interrogatories.Prefers Settling Differences W/O ASLB Ruling ML20126H9761981-04-10010 April 1981 Forwards Util 810410 First Set of Interrogatories Re Dewatering Effects on Lakeshore,Expert Witnesses to Be Called & Documents to Be Introduced Into Evidence or Used in cross-examination.Related Correspondence ML20126H9441981-04-10010 April 1981 Forwards Util 810410 First Set of Interrogatories Re Dewatering Effects on Lakeshore,Expert Witnesses to Be Called & Documents to Be Introduced Into Evidence or Used in cross-examination.Related Correspondence ML19345G8861981-04-0808 April 1981 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 ML19347D9601981-04-0303 April 1981 Ack Receipt of 810325 Ltr.Requests to Be Informed of Possibility of Documents from Second Request & Quantity of Addl Info to Be Produced ML19345G5301981-03-25025 March 1981 Responds to 810313 Ltr Re Documents Identified in First & Second Requests for Production of Documents Per ASLB 801120 Order.Documents Tending to Prove or Disprove Any Assertion Not to Be Produced.Related Correspondence ML20003E2071981-03-13013 March 1981 Requests Production by 810406 of CP Extension Documents Requested in ASLB 801120 Discovery Order ML20003E2451981-03-13013 March 1981 Submits Formal Request That Listed Documents Be Produced on or Before 810406,per ASLB 801120 Order Re Discovery ML19347D2341981-02-18018 February 1981 Forwards Response to Util 801208 Ltr Re Site Groundwater Analysis.D'Appolonia Consulting Engineers Rept Criticizing USGS Contains Only Repetition of Known & Ack Methodology Limitations.Internal Doi Memos Encl ML19351G2761981-02-12012 February 1981 Forwards Sargent & Lundy 781030 Rept, Hydrogeologic Evaluation of Const Dewatering,Bailly Generating Station, Nuclear 1. Other Requested Documents Have Already Been Produced.Certificate of Svc Encl.W/O Rept ML20126E7471981-02-0505 February 1981 Ack Receipt of Re Comments on Dewatering Rept. Panel Completed Work.No Plans Made to Reconvene Group. Studies of Cowles Bog & Wetlands & Effects of Dewatering on Lakeshore Will Continue.Certificate of Svc Encl ML19344B3241980-08-12012 August 1980 Informs That Council Has Reviewed 800527 Ltr Re Application of NEPA Future Decisions Concerning Facility.Council Concludes That NRC Should Prepare & Circulate Suppl to EIS on CP Prior to Rendering Decision ML19309A5141980-03-21021 March 1980 Forwards Three Sargent & Lundy Repts & 780413,790629 & 0814 Ltrs,Re H-pile Foundations in Response to NRC Request.W/O Encl ML19322E7941980-02-29029 February 1980 Responds to Eichhorn 800227 Ltr.Arrangements Will Be Made Re Pick Up of Applicant Responses to Supplemental Petitions at Convenient Time.Certificate of Svc Encl 1982-03-11
[Table view] Category:EXTERNAL LETTERS ROUTED TO NRC
MONTHYEARML20049J5861982-03-11011 March 1982 Requests Status Rept on Util Implementation of Revised Restoration Plan ML20010D1901981-08-17017 August 1981 Ack Receipt of 810813 Ltr Requesting Rescheduling of Osann Deposition.Lists Available Dates for Rescheduling.Related Correspondence ML20010B4131981-08-0606 August 1981 Responds to Rj Vollen 810803 Ltr Re 810731 Press Releases on Util Financial Repts.Qualified Audit Rept Will Be Available on or Before 810831.Press Release Encl ML20009H4201981-07-31031 July 1981 Confirms That Rj Bohn Deposition Will Continue on 810814 & AP Severance Depositon Will Commence on 810821,per 810730 Telcon.Related Correspondence ML20009E2121981-07-21021 July 1981 Forwards Proposed Agreement Per ASLB 810522 Memorandum & Order Granting Protective Order to Ge,For Review & Reply. Relevant Documents Available for Insp ML20009E0931981-07-21021 July 1981 Forwards Bohn Deposition Exhibit 2.W/o Encl ML20009B7951981-07-0808 July 1981 Ack Receipt of Ah Petersen,Fg Hiple & CR Kulawinski 810629 Notice of Depositions.Util Pending Motion Suggests Depositions Not Be Scheduled After 810731.Earlier Date Requested ML20008G1091981-06-24024 June 1981 Ack Receipt of Wh Eichhorn 810623 Response to Porter County Chapter Intervenors' 810615 Request for Documents Filed W/ NRC Per Generic Ltr 81-23.Requests Documents When & If Available.Related Correspondence ML20004F7691981-06-15015 June 1981 Requests That Any Repts from Facility Submitted to NRC Per Generic Ltr 81-23 Also Be Submitted to Porter County Chapter Intervenors.Related Correspondence ML20004F6351981-06-15015 June 1981 Informs That Wh Eichhorn Furnished Copy of Answers of People of State of Il to Licensee Second Set of Interrogatories. Requests Correction of Svc List Used by Il.Certificate of Svc Encl.Related Correspondence ML20004C6491981-05-29029 May 1981 Forwards Northern in Public Svc Co Latest Cost Estimate & Documents in Supplementary Response to Item 6(a) of Third Request for Production of Documents.Requests Prompt Return of Documents.Related Correspondence.W/O Encl ML19346A0531981-05-28028 May 1981 Poses Addl Questions Re Const Permit Extension to Obtain Info Omitted from First Set of Interrogatories.First Set of Answers Were Not Sufficiently Detailed.Related Correspondence ML20004B7021981-05-19019 May 1981 Responds to 810428 Ltr Re Motion to Compel Answers to Porter County Chapter Intervenors' First Set of Interrogatories to Util.Ltr Is Not Proper Substitute for Answer to Interrogatory ML19345H5851981-05-0707 May 1981 Ack Receipt of 810505 Ltr Demanding Documents.Documents Requested Will Be Delivered During Week of 810511.Two Documents Beyond Discovery Scope,One Proprietary Document & One Other Document Removed.Related Correspondence ML20008G1201981-05-0505 May 1981 Requests Prompt Delivery of Documents Per Porter County Chapter Intervenors Second & Third Requests to Produce Directed to Util ML20003J3781981-04-28028 April 1981 Discusses Concerns Re Util Answers to Porter County Chapter Intervenors' First Set of Interrogatories.Prefers Settling Differences W/O ASLB Ruling ML20126H9761981-04-10010 April 1981 Forwards Util 810410 First Set of Interrogatories Re Dewatering Effects on Lakeshore,Expert Witnesses to Be Called & Documents to Be Introduced Into Evidence or Used in cross-examination.Related Correspondence ML20126H9441981-04-10010 April 1981 Forwards Util 810410 First Set of Interrogatories Re Dewatering Effects on Lakeshore,Expert Witnesses to Be Called & Documents to Be Introduced Into Evidence or Used in cross-examination.Related Correspondence ML19345G8861981-04-0808 April 1981 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 ML19347D9601981-04-0303 April 1981 Ack Receipt of 810325 Ltr.Requests to Be Informed of Possibility of Documents from Second Request & Quantity of Addl Info to Be Produced ML19345G5301981-03-25025 March 1981 Responds to 810313 Ltr Re Documents Identified in First & Second Requests for Production of Documents Per ASLB 801120 Order.Documents Tending to Prove or Disprove Any Assertion Not to Be Produced.Related Correspondence ML20003E2071981-03-13013 March 1981 Requests Production by 810406 of CP Extension Documents Requested in ASLB 801120 Discovery Order ML20003E2451981-03-13013 March 1981 Submits Formal Request That Listed Documents Be Produced on or Before 810406,per ASLB 801120 Order Re Discovery ML19347D2341981-02-18018 February 1981 Forwards Response to Util 801208 Ltr Re Site Groundwater Analysis.D'Appolonia Consulting Engineers Rept Criticizing USGS Contains Only Repetition of Known & Ack Methodology Limitations.Internal Doi Memos Encl ML19351G2761981-02-12012 February 1981 Forwards Sargent & Lundy 781030 Rept, Hydrogeologic Evaluation of Const Dewatering,Bailly Generating Station, Nuclear 1. Other Requested Documents Have Already Been Produced.Certificate of Svc Encl.W/O Rept ML20126E7471981-02-0505 February 1981 Ack Receipt of Re Comments on Dewatering Rept. Panel Completed Work.No Plans Made to Reconvene Group. Studies of Cowles Bog & Wetlands & Effects of Dewatering on Lakeshore Will Continue.Certificate of Svc Encl ML19344B3241980-08-12012 August 1980 Informs That Council Has Reviewed 800527 Ltr Re Application of NEPA Future Decisions Concerning Facility.Council Concludes That NRC Should Prepare & Circulate Suppl to EIS on CP Prior to Rendering Decision ML19309A5141980-03-21021 March 1980 Forwards Three Sargent & Lundy Repts & 780413,790629 & 0814 Ltrs,Re H-pile Foundations in Response to NRC Request.W/O Encl ML19322E7941980-02-29029 February 1980 Responds to Eichhorn 800227 Ltr.Arrangements Will Be Made Re Pick Up of Applicant Responses to Supplemental Petitions at Convenient Time.Certificate of Svc Encl 1982-03-11
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Mr. Mike Olszanski i b.
Chair, Environmental Committee '\3 C; -
C United Steelworkers of America \d --
C, Local 1010 '
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3703 Euclid Avenue East Chicago, Indiana 46312 s4 jII D)..Q d? R N 4 Re: In the Matter of Northern Indiana Public Service Company (Bailly Generating Station, Nuclear 1)
Docket No. 50-367 Q
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(Construction Permit Extension) \
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Dear Mr. Olszanski:
I am in receipt of " United Steelworkers of America, Local 1010's Response to Northern Indiana Public Service Company's First Set of Interrogatories" dated April 29, 1981.
Among the purposes of " discovery" is to enable one party to understand clearly what another party is alleging and the facts upon which the allegations are based. With such knowledge, issues can be narrowed and preparation for hearing is facilitated.
In order to accomplish these goals, we posed NIPSCO's First Set of Interrogatories to Local 1010. The answers which were fur-nished over your signature as Local 1010's representative are, in our view, not sufficiently detailed and explicit to satisfy the purposes of discovery. We therefore pose these additional questions in order to obtain information which should have been furnished in response to the First Set.
For example, we asked whether Local 1010 contends that dewatering which has occurred since 1974 has affected the Lakeshore. (Inter-rogatory I.l.) We asked Local 1010 to " identify and describe in detail the specific effects" if it contends that dewatering since 1974 has affected the Lakeshore. (Interrogatory I.2.)
The April 29 Response replies that dewatering since 1974 has had a negative effect on the Lakeshore. However, in our view, the answer to Interrogatory I.2. fails to identify and describe in detail the specific effects" caused by dewatering. For g example, the answer does not specify the dimensions of the o O
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ElCHHORN, ElCHHORN & LINK ,
Mr. Mike Olszanski Page 2 May 28, 1981
- " lowering of the water table" which it alleges nave occurred.
l How much lower is the water table? Where has the lowering occurred? When did it occur? Nor does the response specify the details of the " consequent changes in average soil moisture content" to which it refers. What is " average soil moisture content"? How has it been changed by dewatering since 1974?
The same answer alleges that dewatering "affects many species of plant, animal and marine life." Please name the species of plant life, animal life, and marine life which have been affected and describe the effects which Local 1010 alleges have occurred.
The answer states that " subtle changes in the total ecology of the Dunes, especially wetlands can already be noted by observa-tion." Please identify the " subtle changes" to which the answer refers. Please provide details regarding the " observation"--
who has observed what, where, and when.
We also asked Local 1010 to identify and describe in detail any incremental effects which it contends will occur as a result of dewatering during an extended period of construction.
(Interrogatory I.3.) The answer appears to be non-responsive.
We note first that the question does not ask Local 1010'"to predict future effects with a high degree of accuracy." To what " kind of animal . . . life" does the answer refer? To what " kin of . . . plant . . . life" does the answer refer?
To what " kind of . . . marine life" does the answer refer?
Please identify and describe in detail the " change" which will occur in each form of " life." Please define the word " irreversibly" as used in the Response to Interrogatory I.3. Please define the term " total ecological system of the Dunes" as used in the Response to Interrogatory I.3.
Interrogatory I.4. asked Local 1010 to specify the geographical area within which it alleges the effects will occur. We request greater specificity than is provided in the Response of April 29.
That is, will the effects occur at every part of the Lakeshore?
If not, in which parts, and at what distance from the excavation for Bailly N-l? Please specify the location of the " adjoining natural areas" to which the answer refers.
Local 1010's answer to Interrogatory I.S. is apparently not responsive. The interrogatory asked, in effect, that Local 1010 state how long it contends will be needed for each effect to appear. Is it your position that those time periods are coterminous with the length of time allegedly required "to ruin the ecology of the Dunes wetlands or adjoining areas"?
Speculation as to the length of time periods is not required
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. s ElCHHORN, EXCHHORN & LINK -
Mr. Mike Olszanski Page 3 May 28, 1981 and, if Local 1010's representatives do not know the answer to the Intarrogatory, they may, of course, respond accordingly.
Please note that Interrogatories III.l. and 2. inquire about all consultations, whether " formal" (as that term is used in the response to Interrogatory III.2.) or otherwise.
I would remind you as representative of Local 1010 that there is a continuing obligation to supplement Local 1010's responses to questions regarding the identity and location of persons having knowledge of discoverable matters and the identity of persons expected to be called as witnesses. (10 C.F.R.
S 2. 740 (e) (1) . ) NRC regulations also require amendment of a prior response as specified in 10 C.F.R. S 2.740 (e) (2) if additional information is obtained.
Finally, the Response which you signed and served on April 29 does not comply with the requirement of NRC regulations that answers to interrogatories be filed "under oath or affirmation."
(10 C.F.R. S 2. 740b (b) . ) Would you please refile the answers to NIPSCO's First Set of Interrogatories under oath or affirma-tion. Would you also respond to the additional interrogatories posed in this letter in writing under oath,or affirmation.
Yours very truly, EICHHORN, EICHHORN & LINK l
By:
William H. Eidhhorn WHE/dgg cc: Herbert Grossman, Esquire, Chairman Dr. Robert L. Holton Dr. J. Venn Leeds Docketing and Service Section l Howard K. Shapar, Esquire i Stephen H. Lewis, Esquire l Susan Sekuler, Esquire Robert J. Vollen, Esquire Edward W. Osann, Jr., Esquire Robert L. Graham, Esquire Mr. George Grabowski & Ms. Anna Grabowski
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