ML20010C497

First Request for Production of Documents Directed to Util

ML20010C497
Person / Time
Site:	Bailly
Issue date:	08/11/1981
From:	Rapkin A ILLINOIS, STATE OF
To:	NORTHERN INDIANA PUBLIC SERVICE CO.
Shared Package
ML20010C493	List: ML20010C492 ML20010C497 ML20010C500 ML20010C503 ML20010C507 ML20010C511
References
NUDOCS 8108200139
Download: ML20010C497 (2)

Text

7 UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 1

) ,

NORTHERN INDIANA PUBLIC )

Docxet No. 50-367 SERVICE COMPANY )

(Bailly Generating Station,

)

(Construction Permit Nuclear-1) )

Extension)

)

PEOPLE OF THE STATE OF ILLINOIS' FIRST REQUEST TO NIPSCO FOR PRO-DUCTION OF DOCUMENTS People of the State of Illinois, by its attorney, TYRONE C. FAHNER, Attorney General, State of Illinois, hereby requests that NIPSCO produce on September 4, 1981 at 9:00 A.M. at the offices of the Illinois Attorney General, 188 West Randolph, Suite 2315, Chicago, Illinois 60601, the documents described herein. This request for production of documents relates to the Staff report issued July 17, 1981 entitled: 'WRC Staff Evaluation of the Bailly Construction Permit Extension".

The term " document" means any writing or recording of any kind, however produced or reproduced, including but not limited to letters, telegrams, memoranda, reports, st'udies, tape recordings, computer printouts, photographs, calen'dar and diary. entries, minutes, pamphlets, notes, charts, tabulations and records of meetings,. conferences and telephone or other conversations or meet-ings, which are in the ac'tual or constructive possession, custody or control of NIPSCO. A described document inclues all other documents which are atta'ched to or relate to such document. The term "NIPSCO" includes Northern Indiana Public Service Company, its agents, employ-

.ees, representatives, subsidiaries, and those consultants, contrac-8108200139 810811~ .

PDR ADOCK 05000367 G PDR

p 3

tors or subcontractors over whom.NIPSCO retains control.

1. All documents relating to NIPSCO's verbal agreement to submit modifications.to its monitoring'and mitigation program, .

referred to on page 10 of-the Environmental Impact Appraisal.

2. All documents relating to any proposed modifications to NIPSCO's monitoring and -mitigation prbgram with respect to the

. Unit 3 acquifer.

3. All documents submitted to 'he Staff, other than those already of record in this proceeding, relating to any of the matters

~ discussed in the Staff's said report.

Respectfully Submitted, TYRONE C. FAHNER, Attorney Gener State of Ill' oi  ?

I By:- ,-

Anne Rapkin, 'Asslstant At.torm?7 Gen al Anne Rapkin i Mary Jo Murray Assistant Attorneys General Environmental Control Division I 188 West Randolph Street - Room 2315 Chicago, Illinois 60601 312/793-2491 1

_ _