ML20033B841
| ML20033B841 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/25/1981 |
| From: | Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | Cole R, Alicia Dixon, Mark Miller Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8112020331 | |
| Download: ML20033B841 (2) | |
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November 25, 1981
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- lam CH Dr. A. Dixon Callihan Marshall E.
Miller, Esq., Chairr.aan Administrative Judge Union Carbide Corporation Administrative Judge Atomic Safety & Licensing Board Panel P.O. Box Y U.S. Nuclear Regulatory Co nmission Oak Ridge, Tennessee 37830 Washington, D. C.
20555 Dr. Richard F. Cole
[@' / gb Administrative Judge Atomic Safety &. Licensing Board Panel U.S. Nuclear Regulatoff Commission g
Washington, D. C.
20555
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2 In the Matter of L-COMMONWEALTH EDISON COMPANY D g#W (Byron Station, Units 1 and 2)
Docket Nos. 50-454, 50-455) _
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Dear Administrative Judges:
We have received Commonwealth Edison's " Oppo Petition for Reconsideration.
Rules of Practice we are not permitted a reply.
However, for the sake cf fairness, we deem it necessary to inform h
Board that the factual allegations in the Petition for Recons Edison concerning events purportedly occurring in 1979 and early 1 incredible and irrelevant.
bizarre only irrelavant to the narrow issues before the Board, they are in fac (counsel for the League recalls Mr. Miller asserting, in the course f t did not a settlement which we considered a bribe, that the League's ef or s h t it matter anyway since the Commission always gave Commonwealth Ediso for that r e a. Son ?).
wanted -- should he Board.now hold for the' Ler.gueAdd i
(hardly submitted affidavits incorporating these irrelevant and bizarre allegat ons ptom a surprise given their lack of neutrality) is no more and no less than a sym i h the of the overall disagreement among counsel in a discovery dispute as to w League called the Board's attention earlier on seeking a board su t
t conference among counsel to resolve discovery disputes and get this-im hearing on track.
We inform the' Board that if the League had an opportunity to rep i d by the League would file counter-affidavits contesting all the matters ra seW 03 h
st, Commonwealth Edison's opposition papers.
not simply adopt Commonwealth. Edison's allegations as it has done in t d
and we respectfully offer a reminder that this he f
iil Ig parties happen to like each other.
8112020331 811125 PDR ADOCK 05000454 PDR G
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e Messrs. Miller, Callihan and Cole November 25, 1981 Page Two In sum Commonwealth Edison, realizing the difficult position it has placed itself in by its obdurate behavior, is simply trying to avoid the main thrust of the Board's decision of October 27, 1981 which we have demonstrated is insupportable in law and fact.
We respectfully urge the Board to grant our Petition for Reconsideration and then supervise a much needed and long delayed discovery conference among counsel so that the importLnt aspects of this hearing (including the League's important task of challenging the Byron plant in accordance with its contentions) move forward promptly.
Respectfully, Myron herry MMC /dm cc: Service Lis*
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