ML20033B319
| ML20033B319 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/28/1981 |
| From: | Flynn P CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20033B283 | List: |
| References | |
| 80-0760, 80-760, NUDOCS 8112010226 | |
| Download: ML20033B319 (10) | |
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EXHIBIT 20 CDCKETED uw:
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SDGE T ILUNDIS
'11 nY 24 P3:46 ILuNOIS CXMEIG CCPNISSICN f
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PDCIGt:RD IFRIE T WCEEN 90IERS
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80-0760
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CCMTIMEAMH EISW COMPANY
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Application to Halt (bnstructicm
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of Byron Nuclear Power Station
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IkluaWGOPN 'IO CDMN2EAUlff EISCN GNPANY
'ID:
Paul M. Murphy, Eag.
Isham, Lincoln s nanla One First Naticmal Plaza
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Suite 4200 Chicago, Illinois 60603 Pursuant to the Public Utilities Act, the Rules of Practice of the Illinois CuuAw Comnission and the ruling of the Hearing Examiner in the above cause on the u Jst. of <Hwvery, Cuuu =:lth Eclison m is hereby requested to answer the follwing Intarogatories i
within 28 days of the date hereof:
l.
With regard to the itats listed in NUREG-0660, 'Elable B.2 (Exhibit C to the Affidavit of Messrs. Hubbard and Minor in this
< anaa), please state with par +3 ilarity:
i (a) Which items have already been iT== tad for Byron 1
(providing in each instance the date of implenentation, the
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projected cost of inplementaticm, and the actasal cost of
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inplementation);
y (b) Whid itens are currently planned or sc W ilad for l
future inplementaticm at Byron (providing in each case the scheduled inplementation date and the projected cost of I
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inglenentation);
(c) mich itens have been granted an wi,d.icn fcc Byron (providing in each case the date sud exasptica was granted, the spacifir-terms of the exenption, and the identity of each authority and each person within that authority l
resis1=ihle for granting the wi,4.icm); and
.i (d) Which itens are asserted by C- =lth Filiarvt t
Ostpany, and/or ccmaidared by the Pv-laar Regulatory th=i==4rm
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or its Staff, to be inappli: ship to Byron (pcoviding in each q
l instance the asserted reascos for ncmappliemhility);
4 And identify with pat +ir 1 arity'ench doctanent, as defined in Exhibit A 1
1 hereto, which da M ha=, records, or refers or relates to any portion of your answer tu this questicm or upon which you have relied in pr= raring i
such answer.
l 2.
With regard to each its mentioned in your answer to i
l Interrogatory 1(a), state with par +4r _i1=rity all costs===rv inted with its inplementation, separately stating and dam rihing design costs, saterial costs, labor costs, and QA-QC costs; and identify with partioilarity l
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0 ce refers or relates to ary porticm of your answer to this questian or
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upon dtids you have relied in preparing stxf1 answer.
t Please state Cum.4..=lth Bliscm Orpany's current estinCc.c 3.
of the total cost of inplernenting at Byron all NURDG-0060 itess applicable to' Byron, and dawibe in detail each factor on W11ch that estinate is g
based; and identify with par +4m1=rity each 6=mt, as dafid in 5'vhihit A hereto, Wiich describes, records, or refers az relates to any porticn of y.n answer to this question or upon Wtids you have relied in preparing sxh answer.
Does the estimate given in response to Interrogatory 3 4.
represent an increase or decrease frcan any prior estimates by Cwmm =lth If 5H4=m Ctmpany or the Nacisv Regulatory Cxmnission or the NIC Staff?
the answer is in the affirmative, please daar riba in full each sudi prior
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estimate, stating by whcan that estimate was nade, deacrihing each fact:or on whidt it was based, and identifying each reason why the estinate was changed; and identify with particularity each h=mt, as defined in Exhibit A hereto, which daaerihaa, records, or refers or relates to any portion of your answer to tnis questicn or upon Milch you have reliad in preparing such answer.
With regard to the items spMfiad in your answer to 5.
Interrogatories 1(a) and 1(b), please state whether the planned scharble If your for implementation of any such item was changed at any time.
answer is in the affirmative, plamaa describe, with regard to each sudi itan, how the schedule changed and describe with par +1mlarity each reason for the sdiedule change; and identify with particularity each 6=mt, as defined in Exhibit A hereto, whidt i?cribes, records, or 3_
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refers or relates to any porticn of your answer to this question or upon s.
I idtid you have relied in preparing such answer.
6.
What is Cwma =lth mi== Ompany's current estinte of th.: total cost to inpleoent at Byrtm the enviramental qmlificaticn -
Please h % in swi-and requirenents defined in NURDG-0588?
detail lxw that estimate as made and each factor span idlich it is haani; and ihr*4fy with par +imlarity each docunent, as defined in Whihit A hereto, whis describes, records, or refers or relates to any portion of your answer to this questien or upon whicit you have relied in preparing i
such answer.
Does the estimate given in response to Inteuw i. cry 6 e
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represent an increase or decrease fra any prior estimates by omraonwealth i
U Edison Ompany or the Neler Regulatory winsimi or & E MU the answer is in the affirative, P ease hibe in full M d W l
estimate, stating by whom that estinate was nede, describing each factor en which it was based, and identifying each rea. con dty the estimate us i
5 a fi w in changed; and identify with par +im1=rity each document, as Exhibit A hereto, which describes, records, or refers or relates to any porticn of your answer to this questicri or upon which you have relied in i
preparing such answer.
What is G.mmamith Miel Ompany's currait estimated 8.
date of ocupletion of the NURDG-0588 enviu -utal qualification s%-
Please describe in detail each and requirements with regard to Byron.
factor on which that estimate is based; and identify with par +4m1=rity each docunent, as defined in Exhibit A hereto, dtich Wham, records, j
t or refers or relates to ag portim of your answer to this question or
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span Wtich you have relied in preparing such answer.
9.
Has the estimated date given in your answer to In atory 6 ever been rescheduled from a different estimated date? If your answer to this Interrogatory is in the affimative, plaam state end sudi,
different estimated date, and <% rribe with partie'larity the factors whidi were utili-M in arriving at that estimate and each reascm Wry the estimate was W; and identify with particularity each document, as j
Minari in Pvbihit A hereto, Wrich describes, records, or refers a relates to any portion of your answer to this questial or upon drich you have.
relied in preparing such answer.
- 10. With regard to the new generic safety issues identifiM in l
NUREG-0705, please state whethr r Cumn =lth Mien Wny has analyzed I
or estimated the inpact of any such issue on:
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(a) the cost of Byron, or (b). the Byron otrrpletion date.
If your answer to any part of this Interrogatory is in the affiznative, please state with par *imlarity, with regard to each such issue, what I
i Oxrmriwealth FAIann QXtpany estinntes the cost inpact of that issue CD i
Byron to be, what Edison estinates the irpat.t of that issue to be on the Byron cartpletion date, and the factors considered by Miarrt in arriving at each such estimate; and idmtify with partimladty each %=M, i
as defined in Exhibit A hereto, Wildi theribes, recr)rds, or refers or relates to any porticn of your answer to this question or upon Wtida you I
have relied in preparing such answer.
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- 11. Has Lau ::=1th Bliscri Q:mpany wrv14fiM the Byrm design to otmply with the new postWaarit monitoring requirment as _ defined F
in NBC Regulatory G.lide 1.97, Revisicri 2?
(a) If your answer is in the affirmative, describe with particularity each such wrvlification or change and, with regard to each stch nodification or dange, state the actual or estimted cost, design, matarial, labar, and QA-QC incurred in inplementing the nrvlification'or change; and identify with par +4m3 arity end 1
h==nt, as defined in Exhibit A hereto, which MM, rhJs, or refers or relates to any portion of your answer to this question or upon which you have relied in preparing such answer; and 1
(b) If your answer is negative, p1==a state delar Otmmonwealth Edison G.m@Tf has analyzed or estimated the cost T mting the required wrvlifications or
,f and/or schedule of 4 i
changes to the Byron design, and, if so, hibe with par +4m1=rity each such analysis or estimate and each factor considered by Gau calth Blison Oz:pany in that analysis or estinate; and identify with par +4m>1=rity each h=mt, as defined in Exhibit A hereto, which describes, records, or refers or relates to any portion of your answer to this question or up>l1dlid1 you have relied in preparing s d1 answer.
- 12. With~ regard to the prepared testiacriy of Byrm Ime, Jr.
and Ibbert J. Schultz subnitted in July 1980 in Illinoic Cxxmmroe f
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h4==icn Docket No. 78-0646, and the Exhibits to that testinony, i
please state whether there have been any changes in:
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(a) the Byron moguction budget as reflected in that testinmy; f
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--1th' Minen 0:npany's overall - Lrden (b) budget as reflected in that testinony; (c) the projected schedule for empletion of Byron as reflected in that testinmy; (d) the projected schedule for w Euctica expenditures on Byrm reflected in that testinony;
.e) Ozmonwealth einen Ompany's credit standirg, as
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reflected in that testinony; the " cash m 0 +len" reflected in that testinony; (f) or G.mu =1th mi== Ompany's "Financias '--hilihy" (g) as reflected in that testinony.
If your answer to any pa.t of this qt=*im is in the affimative, please r
describe with par +4m1=rity each sudh change and the reasons for each such change; and identify with par +im1=rity each h==rit, as defined in Exhibit A he$eto, ditch describes, rwds, or refers or relates to any portion of your answer to'this questian or tecm daich you have relied in pra,= ring such answer.
- 13. mat is G.
ealth Blison Gawry's r _, d. estimate of:
(a) the current cost to caplete constructicm of Byron 3
(including, and specifying, all cost itens Bdison ocmsiders for 1
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budgeting purposes); and
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(b) the total cost of construction of the Byron plant (including, and specifying, all cost iterts Edison cxmsideA 'for
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budgeting purposes)?
I Please h a -ib in detail each factor on whidi each sudi estimate is hw, and identify with parHm1=Hty each document, as defined in Exhibit A hereto, which describes, records, or refera or relates to any porticn of your answer to this question or igon which you have relied in preparing such answer.
DMED: August 28, 1981 BOCKFORD TNE CF NCPEN VOIERS P
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One of Their Att )rneys i
MTron M. Cherry Peter Flynn OERRY & FLDN One IBM Plaza, Suite 4501 011cago, T11inois 60611 (312) 565-1177 5
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PRXr M SERVIG P
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I certify that the abtwe and foregoing Intuwgadies were hand-delivered to the addressee stated therein, at the address therein I
given, by messenger, this 28th day of Awfust,1981.
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[L EXHIBIT A I
'Jhe term "doctanents" shall mean and include all written, graphic, or. recorded materials of any nature whatever, including (but not limited i
to) letters,
=t g4=..e,==sorda,- notes, telegrams, diaries, desk calendars, circulars, charts, papers, tape or other sound recordings, ledgers, Wiles, worksheets, contracts, films, transcripts, agreements, licenses, - Ja of telephone or personal cxztversaticms, microfilm, books, news' releases, newspapers, erim, advertisenents, MMicals, bulletins, panphlets, statements, notices, reports, he, rules, regulations, directives, teletype messages, minutes of meetings, inter-office ocumunicatims, accounting worksheets, finarv-in1 statments, W, books of account, bills, wWen, bank checks, per==1=,
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s opactuses, offers, ceders, receipts, working papers, appointment books, c
time sheets, logs, p.YWiads, drawings, shvHam, forecasts, projections, punch cards, ccmputer print-out sheets, and any other data W1=tions frcan which informaticm can be obtained.
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S3'JE & ILLINOIS g
l ILLINOIS C3NEKZ CDMISSICN
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RO3 ERD IEAGUE: T WOMEN VOIERS
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80-0760
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COMNWEAL'IH EDISCN 03PANY
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i hpplication to Balt Constructicn
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of Byrcn Niclaar Power Station
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NorICE OF IEPOSITICN AIO j
REQUEST MR PRCDUCTICN CF DOCDENIS j [o
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Paul M. Murphy, Esq.
Isham, Lincoln & Beale i
One First National Plaza Suite 4200 Chicago, Illinois 60603 e
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Pursuant to the Public Utilities Act, the Rules of Pra.t. ice 4
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of the Illinois comnerce omsnission and the ruling of the n ring j
E:asniner in the above cause on the ocnduct of discovery, you are hereby notified that the depositicms of the persons naned below will be takeet on the dates at the times indicated for each person below, for the purp3ses of discovery, before a notary p&lic, in and for the Cbunty I
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of Cook, State of Illinois, r.t Duite 4501, One IIH Plaza, Chicago, Illinois 60611, qxx1 interrogatories to be propounded to said witm-l arally:
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Deponent Time Date I
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John C. Bukovski 9:00 A.M.
Septerter 23, 1981 2.
James D. Dereas 9:00 A.M.
Septs &er 24, 1981 3.
Byrcm Ise, Jr.
9:00 A.M.
Seyba h 25, 1981
'Jhis is a request upon you to produce said Messrs. Bukovski, Deress, and Iae at the times and place =IeIf4M above. Each of the above h mitions i
will be conducted frcan day to day until conpleted. In the event any
% 4 tion s not capleted prior to the time rM1M for a svmading f.
depositicm, the st< mad %g deposition will ccmnence 4w=diately upon the capletion of the prMasanr deposition.
You are also hereby requested to produce for inspecticm and
- 60603, copying, at Suite 4200, One First National Plaza, Chicago, Illinois l
on September 11, 1981, the following doctamnts (dafining the term
" document" as specified cm Exhibit A hereto, incorporated herein by j
reference):
1.
All doctanents (other than the uhrd-Minor Affidavit) cited or referenced or relied tgxm in the " Affidavit of John C. Bakovski,"
l attached as Exhibit B to the laswundan fi1M by GAmmAswr:lth Blison orpany in this prtmad%g under date of r-
- +r 19, 1980, including f
l without limitaticm engineering economic studies, testinony sponsored by Mr. Bukovski, studies peu fs.M by the T114nois Oxmerce Ommission Staff, waste di=Imal studies referred to at page 4 of the Bukovski Affidavit, Awaminsicning analyses and estimates referred to at pages i
4 and 5 of the Bukovski Affidavit, Nx1 "shrHan perfomed in Ibcket No.
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78-0646" as referred to at page 5 of the Bukovsk3 Affidavit.
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All other documents in the po==aamion of Mr. Bukovski or Gm
=.lth Mim Ompany whicit relate to the capital,axpendi and/or expense analysis mentioned in the first full paragraph at page 2 of Mr.
Bukovski's Affidavit; the assertions made in the second sentence of the t
i==14ately following paragr=nh of Mr. Bukovski's Affidavit; the asserticos i
nede in the 3rd through 8th, 12th through 17th, and 18th through 25th lines j
on page 3 of the Bukovski Affidavit; the assertions made in the 2nd through 15th lines of page 4 of the Bukovski Affidavit; and the assertions nede in the 1st through 7th, 8th through 13th, and 18th through 26th lines on page 5 of the Bukovski Affidavit.
- 3. All h=mts (other than the Rh@ Minor Affidavit and the Byron FSAR) cited or referenced or reliM tpon in the " Affidavit of James D. Deress," attached as Exhibit C to the N--e+= fi1M by k'
Gm
=1th Mien Coupany in this g-Mng under date of Deosser 19, 1980, inchaing without limitation eccocanic, safety, budgetary, and other analyses vam.m.Tdng A1WS events, economic, safety, hrigetary and other analyses concerning equipment gnalifications, 4x--ats evidencing or relating to the " Byron Fmp.mu" menticmed at line 21 of page 6 of the Deress Affidavit; any and all NRC or IEC Staff responses to our cxmments on that " Byron Progran;" sonnic, safety, budgetary, and other analyses relating to the " design mea.mmes" referenced at line 6 of page 8 of the Deress Affidavit; eccxunic, safety, budgetary, and other analyses relating to fire protection, including without limitation all of the analyses referred to in lines 23 throujh 26 of page 9 and 1 ihw==h 22 of page 10 1
i of the Deress Affidavit; all usnic, safety, budgetary, and other analyses ocncerning systens interaction, irebaing without limitatirm
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the " Westinghouse investigation" referred to at line 24 of page 10 of the L
Deress Affidavit and the Report and IE Informaticn Notice ref to at line 3 of page 11 of the Deress Affidavit; and also including without limitaticn the "evaluaticms" and reviews referred to at lines 4 and 5 of I
J page 11 of the Deress Affidavit; all econmic, safety, budgetary, and 1
l other analyses relating to 'Ihree Mile Island issues, including without$
limitaticn analyses relating to the Byron budget increase and/or " budget
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consideraticn" referred to at lines 22 and 25 en page 11 of the Deress Affidavit; the testimcny and exhibits referred to at line 4 of page 12 of the Deress Affidavit; any and all ecmmic, safety, budgetary, and other analyses of the issues and/or the proposed rulerraking Wharl in lines 3 throtxJh 18 at page 13 of the Deress Affidavit; the "Probabi-listic Risk Assessment Study" referred to at.line 20 of page 13 of the Deress Affidavit, in-1dng without limitation the " analysis" referred to in the following line thereof; and the " preliminary results" referred to in line 4 on page 14 of the Deress Affidavit.
4.
All other h=mts in the possession of Mr. Dartws or Chmenwealth Ediscn Otmpany W11ch relate to the assertions made in the 16th through 19th lines of page 2 of the Deress Affidavit, the 3rd through lith and 18th through 22nd lines on page 6 of the Deress Affidavit; the 1st through 16th lines on page 7 of the Deress Affidavit; the 6th through 23rd lines on page 8 of the Deress Affidavit; the 5th through 15th and 17th through 18th lines on page 9 of the Deress Affidavit; the 2nd through 22nd lines on page 10 of the Deress Affidavit; the 4th through 7th, 9th through 13th, and 21st through 24th lines en page 11 of the Deress Affidavit; the loth through 12th lines on lage 12 of the
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Deress Affidavit; and/or the 4th through 6th and 15th through 18th lines I
cm page 14 of the Deress Affidavit.
5.
All documents recording, reflecting, or referring or xv.lating to:
(a) 'Jhe status of inplenentatics at Byron of the itsas listed in Table B.2 of NUREG-0660 (Exhbit C to the phrd-Minor Affidavit) im1sditx3 items Waidt have already been T -ted, ditch are p1==rl for future inplanentation, 1
i W11d1 have been granted an exmpticm, or idhidi are cana4& red to be nampplicable; and all doctztents recording, estinating, analyzing, or referring or relating to the cost (imiiding design, lahnr, material, and OPWC efforrs) of ingleroentation at Byron of any such itern; (b) All subnittals to tie NBC by Wtit Mi arri W_ny relating to the resolution of 'IMI safety 4a=== (4 eliding without limitaticn NURED-0660 issues) at Byron, and all fn-1 or nonfn=1 NBC or NBC Staff respcmses or inquiries in must.icn therewith; (c) All subnittals to the NRC by 0----#
th Miarvt 02tpany 1
regarding envirmnental qua14 fir-aticn issues as defined in NUREG-l 0588, with regard to Byron, and all fonnal or rurfa-1 NRC or NRC Staff responses or inquiries in muAi. ion therewithi (d) All economic, safety, %', and other analyses
-or estinates of the inpect av 'or app 14r =hi14ty of new generic i
~ safety issues identified in MTREG-0705 with regard to Byrcm,
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including the inpact of sudt i==== cm the Byron ecmpletion
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schedule and the inpact of sudt !==== on the cost of Byron, as well as all subnittals by Otzmcstalth Mf =vt Conpany to h NRC relating thereto and all NRC or NRC Staff asponses or inquiries pcrtaining to av such =4=1=Ims; (e) All documents pertaining to aq prrlifications of the Byron design to atmply with the current post-accident nonitoring requirenents defined in Pwjulatory Guide 1.97, Revision 2, im1 Ming without limitation doceents defining and <barribing any changes j
inplernented or to be im1==nted and docments recording or estimating or r=farring or relating to the cost (in::luding design, naterial, labor, and QA-G: costs) concerning all sudt d.anges.
6.
All dortznents recording, rWhing, :?a.?.yzing, or referring or relating to the estinated cost of cxmstruction of the Byron plant:
(a) As estimated by the NRC or the NRC Staff at any time or times between January 1,1978 and the date of your response to this request; 7
(b) As estimated by Otzmonwealth Edison Coupany at'any time or times between January 1,1978 and the date of your response to this request; (c) As estimated by any other person or entity at any time or times between Jantury 1,1978 and the date of your response to this request.
7.
Cw.u_=lth miisan Otmpany's cmstruction budget, both
~as p4M3 and as & and including any and all five year or longer am
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term projections, for the years 1979, 'Juu,1981, arx1 (if available) 1982; and all subsidiary occunentaticm used in or==4a.a part y such pW or actual budgets pertaining to the Byron plant.
8.
All h=mts describing, recording, estimating, or otherwise referring or relating to the status and/cr cost of emergency P anning naasures for Byron, at the utility, cwty, and state levels, l
as well as any and all m4=4==4 cms to the NFC and any and all responses or inquiries by the NRC or IEC Staff relating thereto.
~ 9,. All cbetments recording, describing, estinating, or referring or relating to any specific actions taken by Carmorwealth Edison Ocupany to reduce the chance for steam generator tube failure at Byrtm, including hmmts concernirs the cost (actual or estimated) of any strh acticns and the cost (actual or estimated) of eWancing
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a steam generator tube failum at Byrtm.
- 10. All h= ants analyzing, estimating, describing, or otherwise referring or relating to the date at which (asstuning r<wnal fuel di=-harge cycles) the accumiated storage at Byron as presently Planned will preclude full core d4=-harge capability, and/or actions planned by Ormonwealth Miano Ctmpany to handle Byron spent fuel beyond that date.
You are further notified that, pursuant to the Ruling of the Bearing h=minar made in the above cause cm July 22, 1981, anyobjections 7-9
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to the above request nust be ande in writing within five days of delivery of this 14equest to your office.
t Dk3D: August 28, 1981 IIOCU WD y CF WCNEN 902ERS l
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i one of S mir a6ttornefs I
Myron M. Cherry Peter Flynn OERRY & FLYNN One IBM Plaza, Suite 4501 Chicago, Illinois 60611 (312) 565-1177 b'
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j shall sean ard include all written, graphic, a
the tem %==nta or recorded matad=1= of ary nature idiatever, including (but not limited l
tn) letters, u -gd.is, e
- nda, notes, telegrams, diaries, desk l
calendars, circulars, charts, papers, tape or other sound z-Mimps, i
i ledgers, scMlam, worksheets, md.,..;ts, films, he+ Ipts, agreenents, i
- licenses, m
4a of talmphtme or Waal conversations, hf41=,
books, naus, releases, newspapers, magazines, advertisements, periodimls, bulletim, panphists, statanents, notices, %s, r as, zulas,
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regulatims, directi% talatype=====7=, mimtes of meetings, inter-office ocurunications, accounting =w+=heets, financial statements, h=1=, books of account, hills, vouchers, bank checks, pe==1=,
==, offers, ceders, receipts, working papers, c4a+==nt books, nac+r+w-time sheets, logs,1 ute 1-d., drawings, studies, forecasts, projections, 4
pmch cards, ocmputer print-cit sheets, and sny other data milaticms from which infomation can be obtained.
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I certify that the above and fcregoirxJ Notice of Deposition j
and Request for Production of Dtcwents were hand-delivered to the addraa== stated therein, at the address therein given, by===xjer, this 28th day of August,1981.
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