ML20009B703

First Round of Interrogatories Directed to Dekalb Area Alliance for Responsible Energy & Sinnissippi Alliance for Environ.Certificate of Svc Encl.Related Correspondence

ML20009B703
Person / Time
Site:	Byron
Issue date:	07/08/1981
From:	Bielawski A, Murphy P COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
References
NUDOCS 8107170043
Download: ML20009B703 (6)

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ZI M D CC C CPONDENCE

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UNITED STATES OF AMERICA v5 NUCLEAR REGULATORY COMMISSION .b

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1. - JUL 1 G 1981 =- n COMMONWEALTH EDISON COMPANY'S -

FIRST ROUND OF INTERROGATORIES .

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Pursuant to 10 CFR S 2.740b Commonwealth Edison Company (Edison) requests the DeKalb Area Alliance for Responsible Energy (DAARE) and the Sinnissippi Alliance for the Environment (SAFE) to answer separately and fully in writing, under oath or affirmation, each of the following Interrogatories within 14 days of service.

INSTRUCTIONS AND DEFINITIONS

1. As used in these Interrogatories, whenever appropriate, the singular form of a word shall be interpreted l as plural and the masculine gender shall be deemed to include j '

the feminine.

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[ 2. As used in these Interrogatories, the term "and,"

i as well as "or," shall be construed either disjunctively or conjunctively as necessary to bring within the scope of these gSo3

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Interrogatories any information which might otherwise be con-l strued to be outside their scope.

3. As used in these Interrogatories, the term

" person" includes, without limiting the generality of its 8107170043 810708 PDR ADOCK 05000454 -

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meaning, every natural person, corporate entity, partnership, association, governmental _ body or agency.

4. As used in these Interrogatories, the term

" identification" of a person or entity includes stating his, her, or its full name, his or her most recent home address and telephone number, his, her, or its most recent known business address and telephone number, his or her present position, and his, her, or its connection or association with any party to this proceeding.

5. If any of the information contained in the answers to these Interrogatories is not within the personal knowledge of the person signing the Interrogatory, so state and identify each person, document and communication on which he relies for the information contained in answers not solely based on his personal knowledge.

6. If you cannot answer any portion of the following Interrogatories in full, after exercising diligence to secure the information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portions.

.. If you claim privilege with respect to any inforr ' ' m. s hich is requested by these Interrogatories, spscify the privilege claimed, the communication and/or answer as to which that claim is made, the parties to the communication, the tr!.ic discussed in the communication and the basis for your claim.

INTERROGATORIES

1. With respect to each Contention advanced by DAARE and SAFE which has been admitted by the Atomic Safety and Licensing Board in the above-captioned proceeding, list the following:

a. A concise statement of the facts supporting each contention together with references to the specific sources and documents and portions thereof which have been or will be relied upon to establish such facts;

b. the identity of each person expected to be called as a witness at the hearing;

c. the subject matter on which the witness is expected to testify;

d. the substance of the witness's testimony.

2. With respect to each witness identified in the League's response to Interrogatory 1 above, identify each document which the witness will rely upon in whole or in part in the preparation of his testimony or in the development of his position.

3. With respect to each witness identified in the League's response to Interrogatory 1 above, identify the witness's qualifications to testify on the subject matter on which the witness will testify.

• 4 . Identify all persons who participated in the preparation of the answers, or any portion thereof, to these Interrogatories.

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ISHAM, LINCOLN & BEALE

[('~Cdvhsww Paul M. Murphy'~j/'/'

Paul M. Murphy , j f

Alan Paul Bielawski j ' -

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Suite 4200 One First Natlonal Plaza 3 -

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Chicago, Illinois 60603 / Alan Paul Bi'elawski 312/558-7500 Attorneys for Commonwealth Edison Company

CERTIFICATE OF SERVICE The undersigned, one of the attorneys for the Commonwealth Edison Company, certifies that on this date he filed two copies (plus the original) of the attached pleading with the Secretary of the Nuclear Regulatory _ Commission and served a copy of same on each of the persons at the addresses shown on the attached service list by United States mail, postage prepaid.

DATE: ' July 8, 1981 -' , /

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Alan PY'Bielawski

COMMONWEALTH EDISON COMPANY - Byron Station

, Docket Nos. 50-454 and 50-455 Marshall E. Miller, Esq., Chairman Dr. A. Dixon Callihan Atomic Safety and Licensing Board Union Carbide Corporation Panel P.O. Box Y U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Dr. Richard F. Cole Myron Karman, Esq.

Atomic.Safee, and Licensing Board Office of the Executive Legal Panel Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Richard J. Goddard, Esq. Atomic Safety and Licensing Appeal Office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory Comraission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Board Secretary Panel Attn: Chief, Docketing and '

U.S. Nuclear Regulatory Commission Service Section Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Chief Hearing Counsel Ms.. Betty Johnson Office of the Executive Legal 1907 Stratford Lane Director Rockford, Illinois 61107 U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 l

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O Dr. Bruce von Zellen Kenneth F. Levin, Esq.

Department of Biological Sciences Beatty, Levin, Holland, Basofit; Northern Illinois University & Sarsany.  !

DeKalb, Illinois 60115 ll South LaSalle Street Suite 2200 Chicago, Illinois 60603 Dr. Axel Meyer Department of Physics.

Northern Illinois University DeKalb, Illinois 60115 Mr. Charles E. Morris Executive Director Rockford Register Star 99 East State Street Rockford, Illinois 61105 Ms. Both L. Galbreath 734 Parkview '

Rockford, Illinois 61107 Myron M. Cherry,, Esq.

Cherry, Flynn &'Kanter One IBM Plaza Room 4501 Chicago,. Illinois 60611  ;