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Category:INTERVENTION PETITIONS
MONTHYEARML20009H4981981-07-31031 July 1981 Sixth Request for Production of Documents Directed to Util. Related Correspondence ML20003H7441981-04-24024 April 1981 Motion to Intervene as Respondent in Proceeding.Certificate of Svc Encl.Related Correspondence ML20008D9361980-10-22022 October 1980 Corrections to State of Il Reply Re NRC & Util Responses on Newly Filed Contentions ML19347C1861980-10-10010 October 1980 Response in Opposition to Util 800828 Response to Porter County Chapter Revised Contentions.Contentions Raise Issues Re Delay.Contentions R-I 1 Through R-I 9 & R-I 13 Should Be Admitted.Certificate of Svc Encl ML19337A3771980-06-0505 June 1980 Petition to Intervene & Request for Hearing Submitted on Behalf of City of Gary,In,United Steelworkers of America Local 6787,Bailly Alliance,Save the Dunes Council & Critical Mass Energy Project ML19309H5851980-04-14014 April 1980 Response to Various Filings.States No Objection to State of Il & Intervenors Grabowski Participation as Parties.All Other Petitioners Failed to Establish Right to Participate Re Contention,Interest & Standing.Certificate of Svc Encl ML19309G0141980-04-0202 April 1980 Second Suppl to Petition to Intervene.Contends That Psychological Stress Is within NEPA Zone of Interest.Urges That Hearing Be Held to Consider Totality of Circumstances. Certificate of Svc Encl ML19305E1431980-03-28028 March 1980 Motion for Addl Time to File Contentions & First Suppl to Intervention Petition in CP Extension Proceeding.Dewatering Info Should Be Reconsidered at 5-yr Interval.Affidavit, Motion & Certificate of Svc Encl ML19309F6011980-03-26026 March 1980 Supplemental Statement Re Standing.Contends That Members of United Steel Workers of America Local 1010 Are Users of in Dunes Natl Lakeshore in Which Site Dewatering Will Take Place Due to Const.W/Affidavit & Certificate of Svc ML19354C2991980-03-0707 March 1980 Response in Opposition to G Schultz,A & G Grabowski,State of Il,City of Gary & Porter County Chapter Supplemented Petitions to Intervene Filed in Response to ASLB 800207 Order.Urges Denial of Hearing Requests.W/Certificate of Svc ML19296D7891980-02-27027 February 1980 Suppl to 800223 Petition to Intervene.New Developments Since Original CP Granted Give Cuase for Hearing to Update CP ML19337A3801980-02-26026 February 1980 Response,Submitted on Behalf of City of Gary,In,United Steelworkers of America Local 6787,Bailly Alliance,Save the Dunes Council & Critical Mass Energy Project,To NRC & Util Opposition to Petition to Intervene.Draft Affidavits Encl ML19309A7661980-02-26026 February 1980 Reply in Opposition to NRC & Northern in Public Svc Commission Responses to Petition to Intervene Re CP Extension.Supporting Affidavits & Certificate of Svc Encl ML19309A7601980-02-26026 February 1980 Contention by City of Gary,In,United Steelworkers of America,Bailly Alliance,Save the Dunes Council & Critical Mass Energy Project.Questions Whether Realistic Evacuation & Emergency Plans May Be Implemented Adequately ML20126B9961980-02-25025 February 1980 Amended Petition to Intervene Opposing Extension of Facility Cp.Nrc & Util Must Consider Safety Issues Before Facility Reaches OL Stage.Nrc Is Unlikely to Deny OL for Safety Reasons After Money Has Been Spent on Const of Facility ML19305E1951979-02-27027 February 1979 Request for Hearing Re CP Amend Extending Completion to 850901.Certificate of Svc Encl ML19305E1831976-11-24024 November 1976 Requests to Institute Proceeding & to Suspend or Revoke Cp. Urges Admittance of Porter County Chapter of Izaak Walton League of America,Concerned Citizens Against Bailly Nuclear Site,Et Al,As Parties.W/Certificate of Svc & Documentation 1981-07-31
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20009H4981981-07-31031 July 1981 Sixth Request for Production of Documents Directed to Util. Related Correspondence ML20003H7441981-04-24024 April 1981 Motion to Intervene as Respondent in Proceeding.Certificate of Svc Encl.Related Correspondence ML20008D9361980-10-22022 October 1980 Corrections to State of Il Reply Re NRC & Util Responses on Newly Filed Contentions ML19347C1861980-10-10010 October 1980 Response in Opposition to Util 800828 Response to Porter County Chapter Revised Contentions.Contentions Raise Issues Re Delay.Contentions R-I 1 Through R-I 9 & R-I 13 Should Be Admitted.Certificate of Svc Encl ML19337A3771980-06-0505 June 1980 Petition to Intervene & Request for Hearing Submitted on Behalf of City of Gary,In,United Steelworkers of America Local 6787,Bailly Alliance,Save the Dunes Council & Critical Mass Energy Project ML19309H5851980-04-14014 April 1980 Response to Various Filings.States No Objection to State of Il & Intervenors Grabowski Participation as Parties.All Other Petitioners Failed to Establish Right to Participate Re Contention,Interest & Standing.Certificate of Svc Encl ML19309G0141980-04-0202 April 1980 Second Suppl to Petition to Intervene.Contends That Psychological Stress Is within NEPA Zone of Interest.Urges That Hearing Be Held to Consider Totality of Circumstances. Certificate of Svc Encl ML19305E1431980-03-28028 March 1980 Motion for Addl Time to File Contentions & First Suppl to Intervention Petition in CP Extension Proceeding.Dewatering Info Should Be Reconsidered at 5-yr Interval.Affidavit, Motion & Certificate of Svc Encl ML19309F6011980-03-26026 March 1980 Supplemental Statement Re Standing.Contends That Members of United Steel Workers of America Local 1010 Are Users of in Dunes Natl Lakeshore in Which Site Dewatering Will Take Place Due to Const.W/Affidavit & Certificate of Svc ML19354C2991980-03-0707 March 1980 Response in Opposition to G Schultz,A & G Grabowski,State of Il,City of Gary & Porter County Chapter Supplemented Petitions to Intervene Filed in Response to ASLB 800207 Order.Urges Denial of Hearing Requests.W/Certificate of Svc ML19296D7891980-02-27027 February 1980 Suppl to 800223 Petition to Intervene.New Developments Since Original CP Granted Give Cuase for Hearing to Update CP ML19337A3801980-02-26026 February 1980 Response,Submitted on Behalf of City of Gary,In,United Steelworkers of America Local 6787,Bailly Alliance,Save the Dunes Council & Critical Mass Energy Project,To NRC & Util Opposition to Petition to Intervene.Draft Affidavits Encl ML19309A7661980-02-26026 February 1980 Reply in Opposition to NRC & Northern in Public Svc Commission Responses to Petition to Intervene Re CP Extension.Supporting Affidavits & Certificate of Svc Encl ML19309A7601980-02-26026 February 1980 Contention by City of Gary,In,United Steelworkers of America,Bailly Alliance,Save the Dunes Council & Critical Mass Energy Project.Questions Whether Realistic Evacuation & Emergency Plans May Be Implemented Adequately ML20126B9961980-02-25025 February 1980 Amended Petition to Intervene Opposing Extension of Facility Cp.Nrc & Util Must Consider Safety Issues Before Facility Reaches OL Stage.Nrc Is Unlikely to Deny OL for Safety Reasons After Money Has Been Spent on Const of Facility ML19305E1951979-02-27027 February 1979 Request for Hearing Re CP Amend Extending Completion to 850901.Certificate of Svc Encl ML19305E1831976-11-24024 November 1976 Requests to Institute Proceeding & to Suspend or Revoke Cp. Urges Admittance of Porter County Chapter of Izaak Walton League of America,Concerned Citizens Against Bailly Nuclear Site,Et Al,As Parties.W/Certificate of Svc & Documentation 1981-07-31
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20126M8141985-05-23023 May 1985 Order Denying Business & Prof People for Public Interest Application for Atty Fees Under Equal Access to Justice Act. Commission FY82 Appropriation Act Prohibited Funding of Intervenors.Served on 850523 ML20058J0861982-08-0606 August 1982 Order Holding Intervenor Business & Prof People for Public Interest Request for Award of Atty Fees & Expenses Under Equal Access to Justice Act Until Question of Availability of Funds Solved.Nrc Will Seek Comptroller General Opinion ML20054J0811982-06-18018 June 1982 Notice of ASLB Reconstitution.H Grossman,Chairman & K Mccollom & Rl Holton,Members ML20054F9471982-06-0707 June 1982 Memorandum Supporting Business & Prof People for Public Interest Application for Award of Atty Fees & Expenses ML20053E6801982-06-0404 June 1982 Application for Award of Fees & Expenses Under Equal Access to Justice Act.Fees Requested for Svcs Re Proceedings on Proposed Amend to CP to Extend Completion Date & Proposed Amend to Allow Foundation of Short Pilings ML20053E6821982-06-0404 June 1982 Affidavit of Rj Vollen Re Costs & Legal Svcs Provided ML20053E6831982-06-0404 June 1982 Affidavit of Jm Vollen Re Costs & Legal Svcs Provided ML20053E6851982-06-0404 June 1982 Memorandum of Law Supporting Application for Award of Fees & Expenses Under Equal Access to Justice Act.Proceedings Pending on Effective Date of Act,Party Prevailed & Amount of Fees & Expenses Compensable.Certificate of Svc Encl ML20053E6841982-06-0303 June 1982 Affidavit of Rl Graham Re Reasonable & Customary Charges of Attys ML20052C7281982-04-29029 April 1982 Answer Objecting to & Proposing Mods to ASLB 820412 Memorandum & Order.Objects to Proposed Order Calling for Immediate Termination of Proceedings.No Assurance Util Will Comply If Proceedings Terminated.W/Certificate of Svc ML20050A5201982-03-29029 March 1982 Response Opposing Porter County Chapter Intervenors 820323 Pleading.No Legal Authority Shown for Intervenor Attempt to Exercise NRC Responsibility for Monitoring Compliance W/Aslb Orders.Certificate of Svc Encl ML20049K0791982-03-23023 March 1982 Motion for Leave to Take Limited Discovery.Suppls Position Re Timing of Termination of Proceeding.Util Refusal to Supply Intervenors W/Info Re Compliance W/Aslb 820129 Order Illustrates Need for Jurisdiction.W/Certificate of Svc ML20049K0821982-03-23023 March 1982 First Interrogatory Re Site Restoration ML20069B8901982-03-0101 March 1982 Response Opposing Util 820210 Motion for Reconsideration of 820129 Order.No Legal Basis Presented for Util Argument That ASLB Exceeded Jurisdiction.Certificate of Svc Encl ML20041A4721982-02-16016 February 1982 Motion for Reconsideration of ASLB 820129 Order Requiring Implementation of Revised Plan.Aslb Course Falls Short of ASLB Responsibility to Issue Timely Rulings,Is Unfair to Util & Exceeds ASLB Authority.Certificate of Svc Encl ML20040C7011982-01-25025 January 1982 Responses Opposing Porter County Chapter Intervenors 820108 Motion for Order Imposing Condition of Withdrawal.Nrc Unauthorized to Require Applicant to Pay Intervenors' Fees & Expenses.Certificate of Svc Encl ML20039G0811982-01-0808 January 1982 Motion for Order Imposing Condition Upon Withdrawal of Util Application.Expenses Incurred by Intervenor Were Substantial & Info Developed in Discovery Cast Doubt on Merits of Util Application.Certificate of Svc Encl ML20039C2601981-12-22022 December 1981 Response Opposing Porter County Chapter Intervenors 811209 Motion to Compel Util to Implement Revised Plan for Restoration.Util Will Act When Termination Order Issued, Weather Permitting.Certificate of Svc Encl ML20062L9641981-12-0909 December 1981 Motion to Compel Util to Implement Revised Plan for Site Restoration.No Valid Reason Exists for Further Delay. Certificate of Svc Encl ML20011A2391981-10-0101 October 1981 Motion for Order Directing Util to Submit Plans to ASLB Re Site Excavation.Excavation Should Be Filled W/Matl Comparable to Removed Matl to Preclude Possibility of Harm to Natl Lakeshore.Certificate of Svc Encl ML20010G5041981-09-10010 September 1981 Response Supporting Util 810826 Motion to Terminate Proceeding.Termination Should Be W/Prejudice to Assure Finality of Util Decision & That Issues Raised Need Not Be Litigated ML20010E0331981-08-25025 August 1981 Response in Opposition to Porter County Chapter Intervenors 810817 Motion to Extend Time for Reply to Util Fourth Set of Interrogatories.Also Submits Motion to Compel Response. Related Correspondence ML20010E0321981-08-25025 August 1981 Motion to Compel Appearance of Ew Osann & Read for Deposition Re Facts Upon Which State of Il Has Based Contentions.Porter County & State of Il Are Attempting to Delay Completion of Proceeding.Related Correspondence ML20010E0171981-08-25025 August 1981 Renewed Motion for Protective Order Providing Hiple & Kulawinski Not Be Required to Appear for Depositions on 810915 & 22,respectively.Refusal to Reschedule Unwarranted. W/Ltrs & Certificate of Svc.Related Correspondence ML20010E0341981-08-25025 August 1981 Response in Opposition to State of Il 810820 Motion for Extension of Time to Respond to Util Fourth Set of Interrogatories.Requests That Order Be Issued to Compel Response.Related Correspondence ML20010D2381981-08-18018 August 1981 Response in Opposition to State of Il 810813 Motion to File Application for Discovery & Interrogatories Instanter & for Protective Order. General Allegations Insufficient to Extend Deadline.Certificate of Svc Encl.Related Correspondence ML20010D2291981-08-18018 August 1981 Motion to Compel Answers to 810622 Third Set of Interrogatories Directed to Porter County Chapter,Concerned Citizens Against Bailly Nuclear Site,Businessmen for Public Interest,Et Al.Related Correspondence ML20010D1201981-08-18018 August 1981 Response to Porter County Chapter Intervenors' Third Set of Interrogatories.Related Correspondence ML20010D1191981-08-18018 August 1981 Objections to Porter County Chapter Intervenors' Third Set of Interrogatories 9,10,11 & 42.Requests Protective Order Providing That No Further Response to Interrogatory 42 Is Required.Related Correspondence ML20010D1181981-08-18018 August 1981 Response to People of State of Il Second Set of Interrogatories.Related Correspondence ML20010D2441981-08-18018 August 1981 Objection to State of Il Second Set of Interrogatories, Interrogatories 12(c),13(b) & 13 (C).Matters Already Reviewed in Original CP Proceeding & Irrelevent to Instant Proceeding.Related Correspondence ML20010D2341981-08-18018 August 1981 Request for Motion to Compel Response to 810622 Third Set of Interrogatories Directed to State of Il.Answers Were Nonresponsive.Related Correspondence ML20010C8961981-08-17017 August 1981 Motion for Extension of Time Until 810910 to File Answers or Objections to Util 810730 Fourth Set of Interrogatories. More Time Needed for Adequate Preparation.No Party Will Be Prejudiced by Extension.Certificate of Svc Encl ML20010C8231981-08-17017 August 1981 Response Opposing Porter County Chapter Intervenors' 810810 Motion for Extension of Time to Take Depositions.Intervenors Had Ample Opportunity for Discovery.Board Should Not Allow Delaying Tactics ML20010C8251981-08-17017 August 1981 Response Opposing State of Il 810811 Motion for Extension of Time to Take Depositions.Hardships Under Discovery Schedule Are self-imposed ML20010C5031981-08-14014 August 1981 Second Application for Order Requiring Attendance & Testimony at State of Il Noticed Depositions of Lm Bykoski & Lg Hulman.Exceptional Circumstances Exist & Listed Personnel Should Be Required to Appear ML20010C5881981-08-13013 August 1981 Motion for Leave to File Application for Discovery Re NRC Documents,First Set of Interrogatories Directed to NRC & Third Set of Interrogatories Directed to Util.Discovery Could Not Be Completed by 810811.Related Correspondence ML20010C5911981-08-13013 August 1981 First Set of Interrogatories Directed to NRC ML20010C5921981-08-13013 August 1981 First Set of Interrogatories Directed to Util.Certificate of Svc Encl ML20010C5901981-08-13013 August 1981 Application for Discovery Directed to NRC Re NRC Staff Evaluation of Bailly CP Extension Request. ML20010C5181981-08-13013 August 1981 Motion for Protective Order That Ew Osann Deposition Not Be Taken on 810820.Osann Will Be Unavailable for Util Deposition Due to Other Business Commitments.Good Cause exists.W/810813 Ltr to Util Law Firm & Certificate of Svc ML20010B2941981-08-12012 August 1981 Renewed Application for Subpoenas Directed to Rf Brissette, s Dobrijevic & Personnel at Sargent & Lundy,Ground/Water Technology,Inc & Dames & Moore.Related Correspondence ML20010C4971981-08-11011 August 1981 First Request for Production of Documents Directed to Util ML20010C5111981-08-11011 August 1981 Motion for Extension of Time for Taking Depositions.Supports Porter County Chapter Intervenors' 810810 Motion for Extension of Deadline Until 810803.Schedule Places Burden on Parties W/O Benifit to Anyone.Certificate of Svc Encl ML20010C2821981-08-11011 August 1981 Conditional Withdrawal of Motions for Protective Orders Re Hiple & Kulawinski Depositions.If Depositions Rescheduled for Suggested Dates,Util Will Withdraw Objections. Certificate of Svc Encl ML20010C2621981-08-11011 August 1981 Amend to Porter County Chapter Intervenors' 810717 Notice of Deposition of MD Lynch,Adding Addl Subjs to Deposition. Related Correspondence ML20010C2391981-08-11011 August 1981 Fifth Set of Interrogatories Directed to Util.Related Correspondence ML20010C1591981-08-11011 August 1981 Third Application for Order Requiring NRC to Answer Porter County Chapter Intervenor'S Third Set of Interrogatories. Related Correspondence ML20010C1531981-08-11011 August 1981 Third Set of Interrogatories Directed to Nrc.Related Correspondence ML20010C5071981-08-11011 August 1981 Amended 810720 Notice of MD Lynch Deposition,Including Listed Matters for Exam 1985-05-23
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800.4300133 8
UNITED STATES OF AMERICA fES NUCLEAR REGULATORY COMMISSION March 26, 1980 IN THE MATTER.0F: )
)
NORTHERN INDIANA PUBLIC ) DOCKET No. 50-367 SERVICE COMPANY (Bailly )
Generating Station, )
Nuclear-1) )
SUPPLEMENTAL STATEMENT TO ATOMIC SAFETY AND LICENSING BOARD PREHEARING CONCERNING STANDING.
United Steelworkers of America Local 1010 seeks standing to intervene in proceedings on NIPSCO'S construction permit extension for Bailly Nuclear One as a matter of rightu. Ourscon-tention 10-B of " Petition to Deny Permit" contends that further construction of Bailly will harm the Indiana Dunes National Lakeshore Park of which many of ou'r Memb ers 'are us ers . Further, without the construction. permit extension the Bailly plant, which will adversely affect our Members, cannot be built.
Local 1010 additionally seeks standing as a matter of dis-cretion because our participation will assist in developing a more complete record. Local 1010 has previously petitioned the Nuclear Regulatory Commission requesting public hearing on NIPSCO'S proposed change in the foundation of Bailly Neclear One.
Local 1010's 19,000 Members are reside in a broad area of two
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states and their interests are such that they cannot adequately be represented by any other party to the proceedings.
@ Respectfully Submitted, w
iM &1 -
1 APR I% t Joe Frantz, Secretary gy C n I93D> 7, Enviromental Committee n,
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DCCKETES b USNRO g: APR 2E80> I
. UNITED STATES OF AMERICA ' '
, . NUCLEAR REGULATORY COMMISSION 9 Officeof theSe Dghgq g ggg 7 Sanch BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 E u
In The Matter of )
NORTHERN INDIANA PUBLIC DOCKET No. 50-367 SERVICE COMPANY ) (Construction Permit (Bailly Generating Station, Extension)
Nuclear 1)
AFFIDAVIT OF JOE FRANTZ Joe Frantz declares and states.as:follows:
- 1. I reside at 535 Miami Place in the City of Gary, Indiana. My residence is located approximately 8 miles from the proposed site of the Bailly Generating Station, Nuclear.l.
- 2. I am secretary bf the Environmental Committee of the United Steelworkers of America, Local Union 1010, which is seeking to intervene in this construction permit extension proceeding.
- 3. Local 1010 represents approximately 19,000 Employees of the Indiana Harbor Works'of Inland Steel Campany, which is approximately. 15' miles from the proposed site of Bailly Nuclear One.
The general Membership of Local 1010 voted in 1976 to oppose , i construction of a nuclear generating station at the Bailly site.
The general Membership of Local 1010 voted 1979 to, authorize the Local Union to oppose the application of Northern Indiana Public Service Company for a construction permit extension for l t
i Etilly Nuclear 1, and to petition The Nuclear R~.egul'ator Commis- l sion f o r a hearing on the construction permit' extension in our behalf. -
4.I and many other members of Loc 51 1010 are users of the Indiana Dunes National Lakeshore. The continued construc-tion o f Bailly Nuclear One will cause further site-dewatering which harms the, interests of our members as users of the park.
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- 5. The continued construction of Bailly Nuclear One threatens the, health and jobs of members fo Local 1010. If Bailly Nuclear:One is built and operated, the possibility *of an accident threatens our health and j obs. This risk is aggravated by the lack of viable evacuation plans for the high-ly populated areas surrounding the site. If the ' plant is built and not operated, the utility rate increases necessary to finance both an idle generating station and emergency. sources of power will j eopardize our ability to purchase the power necessary to protect our health and our families'. It will also j eopardize our jobs because steelmills depend upon adequate supplies of
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electricity at reasonable rates.
- 6. Unless NIPSCO can demonstrate the ability to proceed with construction of Bailly Nuclear One with'out harming the-Indiana Dunes National Lakeshore, and unless NIPSCO can prove ability to protect the j obs and safety and health of our members in the event of a nuclear accident, the construction permit ex-tension should be denied. -
l
. . -In.accoraance wi.th 28 U.S.C. S 1746, I !
declare under penalty of perjury that the foregoing is true and correct.
Executed on f//Lu 4 26 , /ff'O .
b M. VKda$
JQfFRANTZ G 4 .
9
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e UNITED STATES OF AMERICA e
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NUCLEAR REGULATORY COMMISSION 2 APR 4 offiarofas2 IN THE MATTER OF: ) Sbdut g NORTHERN INDIANA PUBLIC ) DOCKET No. 50-367 4 SERVUCE COMPANY (Bailly ) N g j, Generating Station, )
Nuclear-I ) -
CERTIFICATE OF SERVICE l
I hereby certify that I have served copies of the SUPPLEMENTAL STATEMENT TO ATOMIC SAFETY AND LICENSING BOARD PREHEARING AND AFFADAVIT OF JOE FRANTZ, upon each of the following persons by deposit in the United States mail, first class postage prepaid, this 27th day of March, 1980.
Herbert Grossman, Chairman Diane Cohn Atomic Licensing and Safety Board Suite 700 U.S. Nuclear Regulatory Commission 2000 P Street N.W.
Washington, D.C. 20555 Washington, D.C. 20036 Katheeen Shea Mr. Glenn Bright 1025 Connectibut Ave. N.W. ,
Atomic Safety & Licensing Board Washington, D.C. 20036 U.S. NuclearRegulatoryCommissf Washington, D.C. 20555 Dr. Richard Cole Atomic Safety & Licensing Board Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissi Washington, D.C. 20555 Washington, D.C. 20555 William H. Eichorn, Esq. . Robert J. Vollen Eichorm, Morrow & Eichorn Business & Professional People l
. 5243 Hohman Ave. For The Public Interest i Hammond, Indiana 46320 109 N.
Dearborn' St. Suite-1300 ,
Chicago, Illinois 60611 ;
Do eting and Service Section ou 1 he NRC Staff U.S. Nuclear Regulatory Commission Secretary of the Commission
, Washington, D.C. 20555 U.S. Nuclear Regulatory Commiss Robert L. Graham Washington, D.C. 20555 Jenner & Block Dean Hansell One IBM Plaza-Suite 4300 Assistant Attorney General Chicago, Illinois 4 188 W. Randolph St.
Richard L. Robbins Chicago, Illinois 60601 Lake Mich. Fed.
53 W. Jakeson Blvd.
Chicago, Illinois 60604
,