ML20062B067

Response to First Request for Production of Documents Re Financial Qualifications,Need for Power & Alternative Energy Sources

ML20062B067
Person / Time
Site:	Byron
Issue date:	07/30/1982
From:	Whicher J DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20062A998	List: ML20062A995 ML20062B011 ML20062B027 ML20062B047 ML20062B059 ML20062B067 ML20062B082 ML20062B093
References
NUDOCS 8208040308
Download: ML20062B067 (2)

Text

7 b-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION D00qrEn Uwc BEFORE THE ATOMIC- SAFETY AND LICENSING BOARD Y AGO ~3 .pi_n y v

In the Matter of ) . .

) C .i rm f, s COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 MM6

) 50-455 (Byron Station, Units 1 and 2) )

DAARE/ SAFE RESPONSE TO NRC STAFF FIRST REQUEST FOR THE PRODUCTION OF DOCUMENTS In response to the NRC staff's first request to DAARE/ SAFE for the production of documents, DAARE/ SAFE submits the following with respect to the issues of financial qualifications, need for power and alternative energy sources.

Category 2 DAARE/ SAFE does not yet know which witnesses it will call-on the foregoing issues, pending decision by the Board and the Commission on which of DAARE/ SAFE's contentions will be admitted.

However, DAARE/ SAFE expects to rely on all documents attached as Exhibits to the following petitions: Petition of Rockford League of Homen Voters for Waiver of or Exception to Financial Qualifi-cations Regulations ; Petition of DAARE/ SAFE for Waiver of or Exception to Financial Qualifications Regulations; and Petition of Rockford League of Women Voters for Waiver of or Exception to Need for Power and Alternative Energy Source Regulations 10 CFR S$51.23(e) and 51.53(c); and all studies and documents referenced 820so40308 820730 PDR ADOCK 05000454 0 PDR

, r.

2 in the above Petitions and in the Petition of DAARE/ SAFE for.

Waiver of or Exception to Need for Power and Alternative Energy Source Regulations 10 CFR SS51.23(c) and Sl.53(c) which are now i in the process of being developed. DAARE/ SAFE further states 1

that copies of all prescatly available documents have been served 1

on the staff, (or in the case of the FES and SER were generated by the staff), and that copies of all other documents will be

[ served as they become available.

l DATED: July 30, 1982 Respectfully submitted,

} Douglass W. Cassel, Jr.

I Jane M. Whicher by: _-

• 5m . U , -

! \

! Jane M. Whicher Attorneys for DAARE/ SAFE with respect to issues of financial qualifications, need for power i

and alternative encry,y sourcen i

Douglass W. Cassel, Jr.

Jane M. Whicher 3

[09 North Dearborn f Ch i ca y,o , IL 60602 t

(312) 641-5570 I

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