ML20039D833

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Motion for Leave to File Motion to Compel Answers to Second Set of Interrogatories & Request for Production of Documents.Circumstances Prevented Motion from Being Filed on 811230.Affidavit & Certificate of Svc Encl
ML20039D833
Person / Time
Site: Clinton Constellation icon.png
Issue date: 12/31/1981
From: Willman P
ILLINOIS, STATE OF
To:
NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8201060235
Download: ML20039D833 (6)


Text

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UNITED STATES OF AMERICA- DOLKETED NUCLEAR REGULATORY COMMISSION w;$ac

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ILLINOIS POWER COMPANY, ) ERANCH-SOYLAND POWER COOPERATIVE, INC. ) Docket No. 50-461 OL and WESTERN ILLINOIS POWER )

COOPERATIVE, INC. O CD-

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) ( 4 (Operating License for Clinton )

Power Station, Unit 1) ) 9 NECEIVED ILLINOIS' MOTION FOR E JAN 5 1982> ~- -

' PERMISSION TO FILE g."EuEmYa INSTANTER E%

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% o The State of. Illinois _(Illinois) , by its attorney, TYRONE C. FAHNER, Attorney General of the. State of Illinois, moves the Board for permission to file instanter Illinois' Motion To: Compel Answers To Its Second Set'Of Interrogatories And Request For Production Of Documents To Applicants. In support of this motion Illinois states as follows:

1.- On December 15, 1981 Applicants, Illinois Power Company, Soyland Power Company, and Western Illinois Power Cooperative, Inc. '(IP), served on~ Illinois by mail a response to Illinois' second round discovery requests.

2. Illinois did not receive IP's response in the Attorney General's Chicago office until December 21, 1981.
3. Philip L. Willman, one of the Assistant Attorneys General assigned to represent Illinois in this proceeding, was away from the Chicago office from December 22 through December 27, 1981.
4. Pursuant to the NRC Rules of Practice and Procedure-Illinois' motion to compel had to be served by mail by December 8201060235 811231 PDR ADOCK 05000461 I26#

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30, 1981.

5. Illinois is unable to serve by mail its motion to compel until December 31, 1981 because of the circumstances described above.
6. Illinois has served by mail on December 31 its motion to compel, under separate cover from the Attorney General's Springfield office.

WHEREFORE, for the foregoing reasons Illinois respectfully requests' permission to file -instanter its Motion To compel Answers To Its Second Set Of Interrogatories And Request For Production Of. Documents To Applicants.

Respectfully Submitted.

b. ( &-

Philip / L. Willman' Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite-2315 Chicago, Illinois 60601 (312) 793-2491 DATED: December 31, 1981

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AFFIDAVIT 1 i

-I,' PHILIP L. WILLMAN, being duly sworn uoon oath,: depose _

. an'd state:.

~

1. ~I am oneof.the Assistant Attorneys General assigned to  ;

represent ~the. State of Illinois in Illinois Power Comoany, et al.

(Operating License for Clinton Power Station, Unit 1), 50-461 OL' .

i 2. I have read Illinois' Motion For: Permission To File

' Instanter, and I believe it to be-true' and-accurate to.the best of_my recollection.-

FURTHER AFFIANT SAYETH NOT.

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. ' L. (a / W PHILIP L. WILLMAN

' SUBSCRIBED-'AND SWORN TO,BEFORE~ME THIS 31st DAY OF DECEMBER, 1981.-

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NOTARY PUBLIC

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UNITED STATES CF A.'iERICA NUCLEAR REGULATORY COT"IISSION

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ILLINOIS POWER COMPANY, ) "l SOYLAND POWER COOPERATIVE, INC.)

and WESTER'i ILLINOIS POWER )

. COOPERATIVE, INC. )

) Docket Nos. 50-461 OL (Operating Licenses for Clinton) 50-462 OL Power Station, Units 1 and 2) )

NOTICE TO: Hugh K. Clark,'Esq., Chairman '

P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A.Ferguson School of Engineering Mcward University 2300 Sixth Street, N .' W .

Washington, D.C. 20059 Dr. Oscar H. Paris Automic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard J. Goddard Office of the Execucive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555

.e.

Peter V. Fazio, Jr.

Schiff, Hardin, & Waite 7200 Sears Tower '

233 South Wacker Drive Chicago, Illinois 60606 Prairie Alliance s P.O. Box 2424 Station A Champaign, Illinois 61820 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atcmic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washingten, D.C. 20555

PLEASE TAKE NOTICE-that today~I have caused to be

- filed with the Secretary, United States Nuclear, Regulatory _Com-t mission, Washington, D.C. 20555, Attention: Chief, Docketing

.and Service Section, one original and two conformed copies of Illinois' Motion For' Permission To File Instanter. A copy of this. doc' ment u is attached and served upon you.

l Respectfully submitted, l.

TYRONE~C. FAHNER Attorney General

! State of_ Illinois By:-

W PHILIP L. WILLMAN l Assistant Attorney General Environmental. Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601.

l (312) 793-2491 DATED: December 31,.1981 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIVE, INC. ) Docket No. 50-461 OL and WESTERN ILLINOIS POWER )

)

(Operating License for Clinton )

Power Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that I served copies of Illinois' Motion For Permission To File Instanter on the persons listed on the attached Notice by causing them to be deposited in the United States mail, first class, postage prepaid, on this 31st day of December, 1981.

' 4. lsk PHILIP L. WILLMAN