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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
[Table view] Category:PLEADINGS
MONTHYEARML20053E6851982-06-0404 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 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 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 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 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 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 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 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 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 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 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 ML20010C1591981-08-11011 August 1981 Third Application for Order Requiring NRC to Answer Porter County Chapter Intervenor'S Third Set of Interrogatories. Related Correspondence ML20010C3261981-08-11011 August 1981 Third Application to ASLB for Order Requiring Attendance & Testimony at Deposition of Lg Hulman,Lm Bykowski & Wf Lovelace.Exceptional Circumstances Exist.Related Correspondence ML20010B3941981-08-10010 August 1981 Response in Opposition to State of Il Refusal to Produce Designated Agent for Deposition.Util Does Not Object to Rescheduling of Deposition.Certificate of Svc Encl.Related Correspondence ML20010B2961981-08-10010 August 1981 Motion to Compel NRC Answers to Porter County Chapter Intervenors' First Set of Interrogatories.Nrc Answers Re Interrogatories 8(f)(ii)(iii) & 9(d) & (F) Were Deficient. Related Correspondence ML20010B2951981-08-10010 August 1981 Second Motion to Compel Further NRC Response & Production of Documents Per Porter County Chapter Intervenors' Second Request.Nrc Should Be Ordered to Provide Definitive Response.Related Correspondence ML20010B2901981-08-10010 August 1981 Showing of General Relevance Supporting Subpoena Applications.Persons to Be Deposed Have Knowledge Directly & Immediately Relevant to Proceeding Issues.Related Correspondence ML20010B2921981-08-10010 August 1981 Motion to Extend 810930 Deadline for Taking Depositions. Compliance May Not Be Possible.Schedule Imposes Unreasonable Burden on All Parties.Related Correspondence ML20010B1321981-08-0707 August 1981 Response Opposing Porter County Chapter Intervenors' 810731 Motion for Leave to Initiate Further Discovery.No Good Cause Shown.Certificate of Svc Encl.Related Correspondence ML20010B2871981-08-0606 August 1981 Motion for Protective Order Providing That Util Requested Deposition Not Be Taken as Scheduled.Job Responsibilities Prevent H Read 810812 Deposition ML20010B3021981-08-0505 August 1981 Response in Opposition to Util 810721 Motion to Compel Answers to Second Set of Interrogatories.Motion Is Filled W/Vituperative Rhetoric,Snide Comments & Personal Attacks on Intervenors.Certificate of Svc Encl ML20009H4681981-07-31031 July 1981 Second Request for Order Requiring NRC to Answer Porter County Chapter Intervenors Second Set of Interrogatories. Answers Relate to Matters Solely within NRC Knowledge. Certificate of Svc Encl.Related Correspondence ML20009H4951981-07-31031 July 1981 Motion for Leave to Initiate Further Discovery to Follow Up on Interrogatories & Various Documents.Related Correspondence ML20009G9841981-07-30030 July 1981 Response Opposing State of Il 810713 Motion for Extension of Time.State of Il Excuses Are Insufficient & Should Not Be Allowed to Dictate Pace of Proceeding.Certificate of Svc Encl.Related Correspondence ML20009G8241981-07-27027 July 1981 Response Opposing State of Il 810713 Motion for Extension of Time.Counsel Needs to Consult W/Other Personnel to Answer Interrogatories Is Usual & Does Not Justify Delayed Responses ML20009G8301981-07-27027 July 1981 Renewed Motion for Protective Order Re Purcell Deposition & Withdrawal of Motion for Protective Order Re Dunn & Ricca Depositions.No Justification Offered for Late Deposition ML20009F2161981-07-24024 July 1981 Answer to State of Il 810717 Motion for Clarification of Order & Porter County Chapter Intervenors' 810722 Motion for Clarification or Reconsideration of Order.Aslb 810710 Order Is Not Ambiguous.No Clarification Needed ML20009F2181981-07-24024 July 1981 Renewed Motion for Protective Order Providing That Petersen,Hiple & Kulawinski Depositions May Not Be Taken on Dates Specified.No Justification Offered.Aslb Established Final Date for Depositions.Certificate of Svc Encl ML20009G8201981-07-23023 July 1981 Response Opposing Util 810708 Motion for Protective Order That Ah Petersen,Fg Hiple & Kulawinski Depositions Not Be Taken After 810731.Util Motion Seeking 810731 as Date Closing Discovery Was Denied.Certificate of Svc Encl ML20009E3051981-07-23023 July 1981 Response Opposing Porter County Chapter Intervenors' 810710 Motion for Extension of Time to File Answers or Objections to Third Set of Interrogatories.Motion Is Attempt to Delay Completion of Discovery.W/Certificate of Svc ML20009E6521981-07-22022 July 1981 Motion for Clarification or Reconsideration of 810710 Orders.Svc of Subpoenas & Notices of Deposition & Taking of Depositions Cannot Reasonably Be Accomplished by Ordered 810828 Date.Certificate of Svc Encl ML20009E0921981-07-21021 July 1981 Motion to Compel Answers to 810423 Second Sets of Interrogatories Directed to Porter County Chapter Intervenors,Concerned Citizens Against Bailly Nuclear Site & Others.Certificate of Svc Encl ML20009E2131981-07-20020 July 1981 Statement Adopting in Entirety Porter County Chapter Intervenors 810609 Application for Order Requiring O Thompson Attendance & Testimony at Deposition 1982-06-04
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Text
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lf Nlg UNITED STATES OF AMERICA 28 /g .
- l NUCLEAR REGULATORY COMMISSION D~ 0$-$
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .f* .l
?
As . "
/ 1.,,, s In the Matter of )
)
NORTHERN INDIANA PUBLIC ) Docket No. 50-367 SERVICE COMPANY ) (Construction Permit Extension)
)
(Bailly Generating )
Station, Nuclear-1) )
PORTER COUNTY CHAPTER INTERVENORS' FIRST REQUEST TO NIPSCO FOR PRODUCTION OF DOCUMENTS Porter County Chapter of the Izaak Walton League of America, Concerned Citizens Against the Bailly Nuclear Site, Businessmen for the Public Interest, Inc. , James E. Newman and Mildred Warner (" Porter County Chapter Intervenors") by their attorneys , pursuant to 10 C. F. R. 52.741, hereby reques t that Northern Indiana Public Service Company ("NIPSCO") produce ,
for inspection and copying on September 26, 1980 at 10:00 A.M.
at the offices of Business and Professional People for the l
Public Interest, Suite 1300, 109 N.
Dearborn,
Chicago, Illinois 60602, the documents described herein.
i
! The term " document" means any writing or recording of any kind, however produced or reproduced, including but not limited to letters, telegrams , memoranda, reports , studies ,
tape recordings, computer printouts, photographs, calendar and O S D6 i 800828o gg .
S 'f/
. 1 diary entries , minutes , pamphlets , notes , charts , tabulations ,
and records of meetings, conferences and telephone or other conversations or meetings , which are in the actual or constructive possession, custody or control of NIPSCO. A described document includes all other documents which are attached to or relate to such document. The term "NIPSC0" includes Northern Indiana Public Service Company, its agents , employees , representatives , subsidiaries ,
consultants, contractors or subcontractors. The term "Sailly" refers to the Bailly Generating Station, Nuclear 1. The term "NRC" includes the United States Nuclear Regulatory Commission, its staff, members, attorneys, employees, consultants, divisions or subdivisions , contractors and subcontractors.
- 1. All documents which were consulted, referred to, or relied upon by Eugene M. Shorb or any other person in the preparation of the letter dated February 7,1979 from NIPSCO by E. M. Shorb to Harold R. Denton (hereinafter the " February 7 letter") .
- 2. All documents which tend to prove or disprove, or upon which the assertion is based that "because of a variety of delays beyond NIPSCO's control, NIPSCO has been able to achieve only the equivalent of approximately 14 months of construction" as asserted in the February 7 letter.
- 3. All documents showing, referring to, or giving reasons why " construction was not resumed until after the Supreme Court finally denied petitions for certiorari on Nover:her 8,1976" as asserted in the February 7 letter.
- 4. All documents showing or referring to the date after November 8, 1976 when NIPSCO did resume construction of the Bailly plant, and the reasons why it did not do so earlier.
s
. - - - . - _ _ . - . . - - . ~ . - . . . - _
l 5.
All documents which tend to prove or disprove that at or about the time of November 8,1976, "two months were required for remobilization of contractors" as asserted in the February 7 leeter.
6.
All contracts, subcontracts and agreements between NIPSCO and any contractor, subcontractor or supplier for any component, part or materials for, or labor pertaining to, the construction and operation of the Bailly plant.
7.
All documents pertaining to the installation of the slurry wall as described in the February 7 letter including all documents showing why plans for said slurry wall were no t included in earlier construction plans or schedule.
8.
All documents upon which the assumption is based in the February 7 letter that pile placement would be resumed not later than March 1, 1979.
9.
All documents which tend to prove or disprove that as of March 1,1979 there would have been an aggregate delay in construction of approximately 44 months , as asserted in the
- February 7 letter.
10.
All documents which contain or tend to show the reasons and the bases for the assertion, in the February 7 letter, that
" lengthier construction periods are required because, of the additional engineering effort necessary to complete final design l
and corresponding construction work," including but not limited to "more numerous and more detailed regulatory guides."
11.
All documents which identify the regulatory guides referred to in the February 7 letter.
l !
-. .. .-. - . - - - - .. . . . . . - . - - - ~ . . - . . . , _
I
- 12. All documents which tend to prove or disprove, and all documents relied upon to form the conclusion that the reasons stated in the February 7 letter constiture " good cause" for the requested extension of the latest completion date of the Bailly facility.
- 13. All documents which tend to prove or disprove, or relied upon to form the conclusion, that the requested amendment has "no safety or environmental significance" as asserted in the February 7 letter.
- 14. All prior drafts of, and notes and memoranda made in connection with the drafting of the February 7 letter.
- 15. All documents which were consulted, referred to, or relieduponbyEugeneM.Shorboranyotherpe-}onintheprepara-tion of the letter dated August 31, 1979 from NIPSCO by E. M. Shorb to Harold R. Denton (hereinafter the " August 31 letter").
- 16. All documents upon which the assumption is based in the August 31 letter that the NRC would complete its review of the foundation pilings proposal by October 1,1979.
- 17. All documents upon which the assertion is based in the August 31 letter that delay resulting from the NRC review of the
- pile foundation proposal would be greater than seven months , including l
but not limited to the reasons of remobilization of contractors and the impact of winter weather on driving activities.
- 18. All documents which reflect, describe or show any
" indications that NRC reviews arising from the Three Mile Island incident will extend the schedule of all plants under construction" as asserted in the August 31 letter.
l
19 . All documents which reflect or support, or upon which ,
the assertion is based that " delays have apparently. . . occurred with respect to Bailly N-1, in that memb,ers of the NRC Staff have extended the period for their review of the piles because they -
had to undertake generic reviews arising from TMI" as asserted in the August 31 letter.
- 20. All documents referring to, reflecting or otherwise relating to all " additional informacion" referred to in the first sentence of the sixth paragraph of the August 31 letter.
- 21. All documents upon which the assertion is based in the August 31 letter that 74 months from the commencement of concrete placement is a " reasonable estimate" of the time required to complete construction of the Bailly plant.
- 22. All documents upon which the assertion is based that "9 months would be required to reach concrete placement after the NRC concurs in resumption of pile placement" as stated in the
! August 31 letter.
- 23. All documents relied upon in forming the conclusion that "approximately 15 months should be added to the requested extension to provide for uncertainties" as asserted in the Aug'7 :
31 letter.
- 24. All documents which tend to prove or disprove or upe".
which the assertion is based that December 1,1987 is a " prudent i
projected completion date" for the requested Bailly facility permit l
amendment as asserted in the. August 31 letter.
- 25. All prior drsF:s of, and notes and memoranda made in connection with, the drafting of the August 31 letter.
- 26. All documents which describe or relate or refer te
or which evidence the reasons why construction of the Bailly plant was not completed by September 1,1979.
- 28. All documents which identiff ' persons or organizations who have possession, custody or control, or have knowledge of the existence of any of the documents described in paragraphs 1 through 27 of this request.
- 29. All documents which identify persons who have knowledge of the matters contained in or referred to in the February 7 letter and the August 31 letter.
DATED: August 21, 1980 Robert J. Vollen Jane M. Whicher Edward W. Osann, Jr.
Robert L. Graham
)
By -
' Robert J . 'Vollen Attorneys for Porter County Chapter Intervenors Robert J. Vollen Jane M. Whicher 109 N. Dearborn Chicago, IL 60602 (312) 641-5570 Edward W. Osann, Jr.
One IBM Plaza Suite 4600 Chicago, IL 60611 (312) 822-9666
Robert L. Graham One IBM Plaza 44th Floor Chicago, IL 60611 (312) 222-9350 -
CERTIFICATE OF SERVICE I hereby certify that I served copies of the foregoing Porter County Chapter Intervenors' Firs t Request t; NIPSCO
! for Production of Documents on all persons on the attached
, Service List, by causing them to be deposited in the U. S.
l mail on August 21, 1980, first class postage prepaid.
I l
I Robert J. jpilen i
? ,. .__ ._ . . - . . _ - - . .
SERVICE LIST Herbert Grossman, Esq. , Chairman George and Anna Grabowski Atomic Safety and Licensing 7413 W. 136th Lane Board Panel Ceda_r. Lake, Indiana 46303 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George Schultz 110 California St.
Dr. Richard F. Cole Michigan City, Indiana 46360 Atomic Safety and Licensing Board Panel Richard L. Robbins, Esq.
U.S. Nuclear Regulatory Commission Lake Michigan Federation Washington, D.C. 20555 53 W. Jackson Blvd.
Chicago, IL 60604 Mr. Glenn O. Bright Atomic Safety and Licensing Mr. Mike Olszanski Board Panel Mr. Clifford Mezo U.S. Nuclear Regulatory Commission Local 1010 Washington, D.C. 20555 United Steelworkers of America 3703 Euclid Ave.
Maurice Axelrad, Esq. East Chicago, Indiana 46312 Kathleen H. Shea, Esq. .
Lowenstein, Newman, Reis, Steven C. Goldberg, Esq.
Axelrad and Toll Office of the Executive 1025 Connecticut Ave., N.W. Legal Director Washington, D.C. 20036 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 William H. Eichhorn, Esq.
Eichhorn, Eichhorn & Link Susan Sekuler, Esq.
5243 Hohman Avenue Assistant Attorney General Hammond, Indiana 46320 John Van Vranken, Esq.
! Environmental Control Division Diane B. Cohn, Esq. 188 W. Randolph St. - Suite 2315 William P. Schultz, Esq. Chicago, IL 60601
" cite 700 2000 P Street, N. W. Stephen Laudig, Esq.
Washington, D.C. 20555 445 N. Pennsylvania Ave.
Indianapolis, IN 46204 Atomic Safety and Licensing Board Panel Docketing and Service Station U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C. 20a55 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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