ML20054M254
| ML20054M254 | |
| Person / Time | |
|---|---|
| Site: | Byron |
| Issue date: | 07/03/1982 |
| From: | Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ALAB-678, ISSUANCES-OL, NUDOCS 8207120173 | |
| Download: ML20054M254 (2) | |
Text
.L =.
n
- t Ci' u..C UNITED STATES OF AMERIC A NUCLEAR REGULATORY COMMISSION
.g,,
_g, 1 r4 ATOMIC SAFETY AND LICENSING BOARD
///
,-r
- v..
.t In the Matter of
)
~
)
COMMONWEALTil EDISON COMPANY
)
Docket Nos. 50-454 OL
)
50-455 OL (Byron Nuclear Power Station,
)
Units 1 and 2)
)
)
RESPONSE TO MOTION FOR PROTECTIVE ORDER FILED BY COMMONWEALTH EDISON COMPANY AND REPLY TO NUCLEAR REGULATORY COMMISSION AND COMMONWEALTII EDISON OBJECTION TO INTERROGATORIES AND IN SUPPORT OF LEAOUE'S MOTION FOR SANCTIONS
'Ihe Rockford League of Women Voters (" League *'), by their attorneys, duly filed Interrogatories in accordance with the Rules of Practice.
The Appeal Board in ALAB-678 did not (and could not) restrict the League's right to discovery and other necessary preparation.
The position of the Staff and Commonwealth Edison are inappropriate and their objections should be overruled and the League's discovery enforced.
Respectfully submitted, Myron M. Cherry, p.c.
RC ORD LEAGUE OF WOM N VOTERS Peter Flynn, p.c.
j; CHERRY & FLYNN ffO E
Three First National Plaza By:
// 4M/
/" /[ h Suite 3700 On f its Attorneys Chicago, Illinois 60602 l
(312) 37 2-2100 K o!hhoh PDR 38 C Z
.4 3
CCLlQiD u%w
.p"
,rl p Fl '.04 PROOF OF SERVICE g;
- ~.;.
n~ -
si, I certify that the foregoing Motion was served upon the Sec~retary of the Atomic Safety and Licensing Board, counsel for the U. S. Nuclear Regulatory i
i Commission Staff, counsel for Commonwealth Edison Co. and the Secretary-Docketing Section of the U. S. Nuclear Regulatory Commission by mail, postage j
prepaid and properly addressed, this 3rd day of July,1982.
O i
2 m
b*
6 i
/
I 9
b 8
8 s
l l
l l
h a
q