ML20065M478

Reply to Amended First Request for Production of Documents. Proof of Svc Encl.Related Correspondence

ML20065M478
Person / Time
Site:	Byron
Issue date:	10/15/1982
From:	Rose B CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8210210278
Download: ML20065M478 (3)

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~ '= OXKETED USNPC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 OCT 20 A11:56 In the Matter of ) (

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) ERANCH COMMONWEALTII EDISON CO., ) Docket Nos. STN

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Byron Station ) 50-454 and 50-455

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(Units No. I and No. 2) ) Operating License REPLY OF TIIE ROCKFORD LEAGUE OF WOMEN VOTERS TO TIIE NUCLEAR REGULATORY COMMISSION STAFF'S AMENDED FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Intervenor Rockford League of Women Voters (" League"), pursuant to 10 C.F.R. Sec. 2.741, herewith submits its reply to the Nuclear Regulatory Commission Staff's Amended First Request for Production of Documents.

CATEGORYI See the League's response to Interrogatories 3(a), 3(b) 'and 3(d) to Commonwealth Edison Co.'s (" CECO') Amended Second Round of Interrogatories.

As noted in the League's answer to Interrogatory 3(d), all the relevant documents i either have been previously furnished to the Staff or "are in the public domain.

CATEGORY 2 See the League's response to Interrogatory 9(a) of CECO's Amended Second Round of Interrogatories. All relevant documents have either previously been furnished to the Staff or are in the public domain.

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1 C ATEGORY 3 Cee the League's response 'to Interrogatory 18(b) and 18(d) of CECO's Amended Second Round of Interrogatories. As stated in the answer to 18(d),

these documents have either been furnished to the Staff or are in the public domain.

CATEGORY 4 A. The League has not yet determined who it will call as a witness at the hearing or to submit an Affidavit. Consequently, it is unclear what precise testimony will be offered, and therefore the League is unable to state with any particularity what documents may be relevant to our witnesses' testimony and Affidavits. It is likely that the League's witnesses may rely on any or all of the documents already identified in the League's responses to both rounds of interrogatories from CECO and the Staff's own interrogatories.

B. The same considerations as stated in subpart A above also apply to subpart B. At such time as the League is able to more specifically indicate what documents will be used as exhibits or for purposes of cross-examination, that information will be supplied to the Staff in a timely fashion.

ROCKFORD LEAGUE OF WOMEN VOTERS By m,-  %

One of Their Attorneys Myron M. Cherry, p.e. c Peter Flynn, p.e.

CHERRY & FLYNN Three First National Pleza Suite 3700 .

Chicago, Illinois 60602 (312) 372-2100

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PROOF OF SERVICE I certify that a copy of the foregoing Reply of the Rockford League of Women Voters to The Nuclear Regulatory Commission Staff's Amended First Request for Production of Documents was served upon all parties of record herein, postage prepaid and properly addressed, this 15th day of October,1982.

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