ML20032E072
| ML20032E072 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/11/1981 |
| From: | Bielawski A CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Chavez D SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| References | |
| ISSUANCES-OL, NUDOCS 8111190595 | |
| Download: ML20032E072 (2) | |
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o n Ms. Diane Chavez J
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Dear Ms. Chavez:
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[h The purpose of this letter is to summarize our understanding of DAARE/ SAFE's position regarding Commonwealth Edison Company's first round of interrogatories directed to DAARE/ SAFE dated July 8, 1981, and to state our views regarding DAARE/ SAFE's position.
These matters were discussed by representatives of Commonwealth Edison Company and DAARE/ SAFE at a meeting held in Rockford, Illinois on November 5, 1981.
At the November 5th meeting, DAARE/ SAFE stated that it had in its possession approximately one file drawer of documents, and that it would not be in a position to answer Commonwealth Edison's first round of interrogatories until after it had an opportunity to review those documents.
DAARE/ SAFE also stated that it would take anywhere from six to eight weeks to complete the process of reviewing these documents and responding to Edison's interrogatories.
In view of the fact that Edison's interrogatories were served approximately four months ago, and DAARE and SAFE have been instructed by the Licensing Board on two separate occasions to respond promptly to Edison's interrogatories, the additional delay contemplated by DAARE/ SAFE is unacceptable to Edison.
i We will therefore continue to maintain our position, as presented in our filings with the Licensing Board, that DAARE/ SAFE should appropriately be dismissed from this proceeding for its failure to comply with the Board's orders relative to Edison's outstanding interrogatories.
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following statements are intended only to inform DAARE/ SAFE of our views concerning DAARE/ SAFE's proposals in the event the Licensing Board denies Edison's request that DAARE/ SAFE be dismissed from this proceeding.
DAARE/ SAFE stated that it needs an additional six to eight weeks to respond to Edison's interrogatories because it must review documents in its possession which it claims are relevant to its contentions.
During this same time 911119G595 011111 9
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a Ms. Chavez Page Two November 11, 1981 period, DAARE/ SAFE intends to begin the process of reviewing the very substantial number of documents which will be provided by Edison in response to DAARE/SAFF'a interrogatories directed to Edison.
In view of the fact ths OARE/ SAFE's interrogatories were served on Edison nearly. ur months after Edison served its interrogatories on DAAL3/ SAFE, we believe DAARE/ SAFE should first complete its review of documents in its possession in order.to answer Edison's outstanding interrogatories prior to reviewing information to be provided to DAARE/ SAFE by Edison.
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It is our understanding that DAARE/ SAFE has agreed to provide Edison access to documents in DAARE/ SAFE's possession which DAARE/ SAFE believes are relevant to the issues raised in its contentions.
We would expect that these documents be provided promptly so that Edison's right to adequately prepare its case in this proceeding is not further prejudiced.
The discussion above represents our understanding of the positions articulated by the parties with respect to the interrogatories in question.
If your recollection differs from ours, please so inform us as early as possible.
Sin erepy
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w A an P. g el wdki One of t-ttorneys for Commonwealth Edison Company APB/gi cc:
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