ML20197H689

Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20197H689
Person / Time
Site:	Byron
Issue date:	06/14/1984
From:	Becker B COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES, DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY
References
NUDOCS 8406190147
Download: ML20197H689 (5)

Text

57/ 5

[ RELATED CORRESPONDENCE g. -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 'g4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '33 7 ,. na u .

k .-1

> [i,}/C )[C,'

In the Matter of: ) ' UN

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) 50-455 (Byron Nuclear Station, )

Units 1 and 2) )

COMMONWEALTH ED1 SON CO!iPANY'S SECOND SET OF INTERROGATORIES TO INTERVENORS AND REQUEST FOR PRODUCTION OF RELATED DOCUMENTS For the purpose of these interrogatories, the term "Intervenors" includes all agents and representatives of the Intervenors, including counsel. If you claim that any of the requested information or documents are protected from disclosure because of privilege, please identify the privilege claimed and delineate the communication to which the privilege in claimed to apply.

1. Please identify all communications, written and oral, between Intervenors and the NRC Staff, during the period August 1, 1983, to date, pertaining to the Byron 82-05-19 reinspection program, Hatfield Electric Company, Hunter Corporation, Pittsubrgh Testing Laboratory, the recertification of inspectors subsequent to the Staff's issuance of 82-05-19, Systems Control Corporation, and Sargent & Lundy.

For each communication, identify:

a) date, time and place; ,

k O

j 950

b) each person involved, and his or her employer and position; and c) topics discussed.

Please produce all documents which refer to or relate to each of the communications identified above. ,

2. Please identify all communications, 4ritten and oral, between Intervenors and current and past employees of Commonwealth Edison Company, Sargent & Lundy, Hatfield Electric Company, Hunter Corporation, Pittsburgh Testing Laboratory, Systems Control Corporation, Blount Brothers Corporation, Johnson Controls, Inc., Nuclear Installation Services Company, Powers-Azco-Pope, Peabody Testing Laboratories, and Reliable Sheet Metal, during the period August 1, 1983, to date.

For each communication, identify:

a) date, time and place; b) each person involved, and his or her employer and position; and c) topics discussed.

Please produce all documents which refer to or relate to each of the communications identified above.

COMMONiJEALTH EDISON COMPANY By: '

M( ) dk Bruce D. Becker One of Its Attorneys i

Isham, Lincoln & Beale .

Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500

l CERTIFICATE OF SERVICE '

.- t P

The undersigned, one of the attorneys for Common-wealth Edison Company, certifies that on this date he filed i

two copies (plus the original) of the attached pleading with i the Secretary of the Nuclear Regulatory Commission and

. served a copy of the same on each of the persons at the 4

addresses shown on the attached service list in the manner  !

-indicated.

i r

i Date: 6 // ff

< M0t# l '

X. /d_

I l-I l

i f

u. -

Dr. A..Dixon Callihan 6 Judge Ivan W. Smith, Chairman Union Carbide Corporation Atomic Safety and Licensing Board P.O. Box Y U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Conmission

. Washington, D.C. 20555 Mr. Richard J. Rawson Dr. Richard F. . Cole Ms. Mitzi A. Young Atomic Safety and Licensing Office of the Executive Legal Board Panel Director U.S.-Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington', D.C. 20555 Washington, D.C. 20555 1

Atomic Safety and Licensing

, Ms. Patricia Morrison Appeal Board Panel '

5568 Thunderidge Drive U.S. Nuclear Regulatory Commission Rockford, Illinois 61107 Washington, D.C. 20555 -

P i

~

Atomic Safety and Licensing Secretary Board Panel Attn: Chief, Docketing and U.S. Nuclear Regulatory Commission Service Section Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. ~20555 Chief Hearing' Counsel Ms. Betty Johnson Office of the Executive 1907 Stratford Lane Legal Director Rockford, Illinois 61107 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

r-

Ms. Diane Chavez ,

SAFE 326 North Avon Street Rockford, Illinois 61103

Joseph Gallo, Esq.

Isham, Lincoln & Beale

' Suite 840 1120 Connecticut Ave. NW Washington, D.C. 20036 i

Dr. Bruce von Zellen Department of Biological Sciences Northern Illinois University DeKalb, Illinois 60115 Douglass W. Cassel, Jr.

Jane Whicher BPI

-Suite 1300-109-North Dearborn '

Chicago,-_ Illinois 60602-i i

l Mr. David Thomas 77 South'Wacker

-Chicago,'IL 60621 *

,- , ,, - , , , . , , -, . , - . . , - . - - . . , . . . , , - -