ML20091D688

Confirms 840521 & 24 Conversations Re Scope of Reopened Hearing & Util Response to Intervenor Discovery Requests. Util Takes Listed Positions Re Intervenor Discovery.Related Correspondence

ML20091D688
Person / Time
Site:	Byron
Issue date:	05/29/1984
From:	Mark Miller COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Whicher J BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES, WHICHER, J.M.
References
OL, NUDOCS 8405310434
Download: ML20091D688 (2)

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BRAT 4CH 202 833 9730 May 29, 1984 Ms. Jane M. Whicher Business and Professional People for the Public Interest 109 North Dearborn Street Suite 1300 Chicago, Illinois 60602 Re: Commonwealth Edison Company (Byron Nuclear Station, Units 1 and 2)

Docket Nos. 50-454 and 50-455 0 L

Dear Jane:

Confirming our conversations on May 21 and May 24 ,

regarding both the scope of the reopened hearing and Commonwealth Edison Company's response to intervenors' discovery requests, Commonwealth Edison Company takes the following positions with respect to intervenors' discovery.

1. Commonwealth Edison Company will produce documents responsive to paragraphs 1 through 16 and paragraphs 37 and 38 insofar as those two paragraphs seek documents referred to in responding to interrrogatories 2, 8, 9, 11 and 12. Documents withheld on ground; of privilege will be identified and the basis for the privilege stated. You agreed to withdraw intervenors request paragraph 17 on my representation that there is no construction assessment program applicable to Byron. Similarly you agreed to drop paragraphs 33 through 36 after you have had an opportunity to informally review the l 8405310434 840529 PDR ADOCK 05000454 PDR g (

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,. Ms. Jane M. Whicher i May 29, 1984 Page 2 status of this issue at Byron. We stated that we would object to paragraphs 18 through 32 of the document request as well as the balance of paragraphs 37 and 38. As with

. objections to certain interrogatories, it seems appropriate to await rulings by-the Licensing Board on the scope of the reopened hearing before filing formal objections. If the Licensing Board wishes t'o hear evidence on any of the subjects comprised within the document requests and interrogatories to which we now object, we will, of course, reconsider our position.' Some documents responsive to paragraphs 1-7, 9, 11-13 and 15 are available today for your inspection and copying at our offices. About two file drawers of documents are now available,.

Commonwealth Edison Company will answer interrogatories 1 through 12 and 24 insofar as information responsive to the interrogatories is not privileged. Interrogatories 20 through 23 and 25 may be withdrawn by you on the same basis as applic-able to paragraphs 33 through 36 of the request to produce documents. While our time for filing answers or objections to interrogatories technically expired on May 24, you agreed to an informal extension of that date. Our present intention is to file answers to the interrogatories on June 4.

Sincerely, 4/

s; . . . , s MIM:es Michael I. Miller t cc Service List

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