ML20128F499
| ML20128F499 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/02/1985 |
| From: | Guild R GUILD, R., ROREM, B. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20128F497 | List: |
| References | |
| OL, NUDOCS 8507080260 | |
| Download: ML20128F499 (2) | |
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UShAC 7/2/85 l
UNITED STATES OF AMERICA
'E JL -5 N0 :54 NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD fo ET NG r
SE I SRANCH In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket No. 50-456
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50-457 (Braidwood Nuclear Power
)
Station, Units 1 and 2)
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INTERVENORS' MOTION TO REQUIRE NRC STAFF ANSWERS TO INTERROGATORIES Pursuant to 10 CFR Scotion 2.720(h)(2)(11), Intervenors Bridget Rorem, et al.,
("Intervonors"), by and through their undersigned counsel, horewith file the attnehod Rorem, Et,A_1,.,
Quality Assuranco Interrogatories and Requests to Produce, First Set, with the Licensing Board which are norved on the Applicant and NRC Staff, including the Executive Director for Operations.
Intervonors request that the NRC Staff voluntarily answer the interrogatories and nerve upon Intervenora copies of the documents of which production in sought.
Intervenoro' counsel understanda that the NRC Staff in prepared to ronpond voluntarily without compulalon by the Board.
If such voluntary responnon by the NRC Staff are refused, Intervenora move for nn order dirooting the Staff to answer on the grounda that annworn to thoso interrogatories are necessary to a proper decialon in thin proceeding and that, nnowers to these interrogatorien, in part, are not renconably obtainable from any other nourco.
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F.
WHEREFORE, Intervenors respectfully request that the NRC Starr voluntarily respond to this discovery or that the Board direct the NRC Staff to respond as herein sought, and that the Board grant such further relief as is just and reasonable.
l July 2, 1985 Respectfully submitted, Douglass W. Cassel, Jr.
Robert Guild Timothy W. Wright, III Attorneys for Intervenor Bridget Rorem, et al.
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By:
Robert'duild Douglass W. Cassel, Jr.
Robert Guild Timothy W. Wright, III 109 North Dearborii Suite 1300 Illinois 60602 Chicago $41-5570 (312) 2
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