ML20009H021

Motion to Compel Discovery by Rockford League of Women Voters.Applicant Directed Interrogatories to League on 810727.No Answers or Objections Received.Certificate of Svc Encl.Related Correspondence

ML20009H021
Person / Time
Site:	Byron
Issue date:	07/30/1981
From:	Murphy P COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	NRC COMMISSION (OCM)
References
NUDOCS 8108050365
Download: ML20009H021 (8)

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UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION -i . s 06 ,, sod -  :

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In the Matter of ) py\S '

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) 50-455 (Byron Nuclear Power Station, )

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MOTION OF COMMONWEALTH EDISON COMPANY S 1981 > {;d TO COMPEL DISCOVERY BY Z /suG .

THE ROCKFORD LEAGUE OF WOMEN VOTERS B# .,6 '/

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~ "g,",  ;'a N Commonwealth Edison Company (" Applicant") move j F

. a> w the Board, pursuant to 10 CFR S2.740 (f) (1) , to issue an order directing the Rockford League of Women Voters (the

" League") to answer forthwith Applicant's interrogatories directed to the League. In support of this Motion, Appli-cant states as follows:

1. By Memorandum and Order, dated December 19, 1980, this i Board opened discovery on all admitted contentions of the League.

l 2. On July 8, 1981, Applicant directed four interrogatories to the League (copies of which are attached hereto) i which, pursuant to 10 CFR S2.740b(b), the League was i required to answe: not later than July 27, 1981, includ-ing five days for mailing.

l 3. As of this date, tne League has neither answered nor i

objected to said interrogatories.

j 8108050365 810730 PDR ADOCK 05000 pgp$ 7 G $# 7 t

WHEREFORE, Commonwealth Edison Company respect-i fully requests the 3oard to enter an order compelling the i League to respond to Ccmmonwealth Edison Company's First 4

Round of Interrogatories in the manner required by the Commission's Rules of Practice.

DATED: July 30, 1981 j ne spectfully submitted, Ih l

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0 lb . llDAA Paul M. Murphy' ~/

One of the Attorneys for Applic nt Commonwealth Edison Company i

Michael I. Miller, Esq.

Paul M. Murphy, Esq.

Alan P. Bielawski, Esq.

ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200

Chicago, Illinois 60603

(312)558-7500 4

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Dated: 7-8-81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

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In the Matter of ) .

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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) 50-455 i (Byron Nuclear Power Station, )

Units 1 and 2) )

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COMMONWEALTH EDISON COMPANY'S FIRST ROUND OF INTERROGATORIES TO BE ANSWERED BY THE ROCKFORD LEAGUE OF WOMEN VOTERS 4

Pursuant to 10 CPR S 2.740b Commonwealth Edison Company (Edison) requests the Rockford League of Woman Voters (League) to answer separately and fully in writing, under oath or affirmation, each of the following Interrogatories within 14 days of service.

INSTRUCTIONS AND DEFINITIONS

1. As used in these Interrogatories, whenever appropriate, the singular form of a word shall be interpreted as plural and the masculine gender shall be deemed to include the femini,ne.

2. As used in these Interrogatories, the term .

"and," as well as "or," shall be construed either disjunctively or conjunctively as necessary to bring within the scope of these Interrogatories any information which might otherwise be construed to be outside their scope, i

3. As used in these Interrogatories, the term

" person- includes, without limiting the generality of its D4 i'& O F

? L.d D. 76C45 _ _ _ _ _ _ _ _ _ _ _ . _ _ _ , _ . . _ . . . . - . . _ . . _ _ , _ _ _ _ _ . _ _ . _ _ _ _ - _ . , _ . , . _ _ _ _ _

i I meaning, every natural person, corporate entity, partnership, 1

l association, governmental body or agency.

4. As used in these Interrogatories, the term

" identification" of a person or entity includes stating his,

! her, or its full name, his or her most recent home' address 4

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and telephone number, his, her, or its most recent known business address and telephone number, his or her present I position, and his, her, or its connection or association

. with any party to this proceeding.

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! 5. If any of the information contained in the answers to these Interrogatories is not within the personal j knowledge of the person signing the Interrogatory, so state

, and identify each person, document and communication on which he relies for the information contained in answers not solely based on his personal knowledge, f 6. If you cannot answer any portion of the following 1

Interrogatories in full, after exercising diligence to f secure the information to do so, so state and answer to the extent possible, specifying your inability to answer tne l remainder and stating whatever information or knowledge you have concerning the unanswered portions.

7. If you claim privilege with respect to any i information which is regoested by these Interrogatories, f

specify the privilege claimed, the communication and/or answer as to which that claim is made, the parties to the l

communication, the topic discussed in the communication and l the basis for your claim.

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INTERROCATORIES

1. With respect to each Contention advanced by the League which has been admitted by the Atomic Safety and Licensing Board in the above-captioned proceeding, list the followiny:

a. A concise statement of the facts supnorting each Contention together with references to the specific sources and documents and portions thereof which have been or will be relied upon to establish such facts;

b. the identity of each person expected to be called as a witness at the hearing;

c. the subject matter on which tne witness is expected to testify;

d. the substance of :he witness's testimony.

2. With respect to each witness identified in the League's response to Interrogatory 1 above, identify each document which the witness will rely upon in whole or in part in the preparation of his testimony or in the development of his position.

3. With respect to each witness identified in the League's response to Interrogatory 1 above, identify the witness's qualifications to testify on the subject matter on which the witness will testify.

4 Identify all persons who participated in the preparation of the answers, or any portion thereof, to these Interrogatories. q

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I S IIA M , LINCOLN & BEALE \ /

Paul M. Murphy i

/ 'I Alan Paul Bielawski Paul M. Murphy, , /

Suite 4200 '

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One First National Plaza p/- -

,/j Chicago, Illinois 60603 -

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312/558-7500 j/ / Alan Paul'Bielawski Attorneys for Commonwealth Edison Company

CERTIFICATE OF SERVICE l The undersigned, one of the attorneys for Common-wealth Edison Company, certifies that on this date he filed two copies (plus the original) of the attached pleading with the Secretary of the Nuclear Regulatory Commission and

! served a copy of same on each of the persons at the addresses shown on the attached service list by United States mail, postage prepaid.

i DATE: July 30, 1981 l

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Paul M. Murphy

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,, ,. Dockst Nos. 50-454 and 50-455-Marshall E. Miller, Esq., Chairman Dr. A. Dixon Callihan Atomic Safety and Licensing Board Union Carbide Corporation Panel P.O. Box Y U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 r

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l Dr. Richard F. Cole Myron Karman, Esq.

Atomic Safety and Licensing Board Office of the Executive Legal Panel Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Richard J. Goddard, Esq. Atomic Safety and Licensing Appeal 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

l Atomic Safety and Licensing Board Secretary Panel Attn: C' lie f , Docketing an,d U.S. Nuclear Regulatory Commission 9arvice Section l Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

l Chief Hearing Counsel Ms.. Betty Johnson Office of the Executive Legal 1907 Stratford Lane Director Rockford, Illinois 61107 U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 i

Dr. Bruce von Zellen Ms. Beth L. Galbreath Department of Biological Sciences 734 Parkview Northern Illinois University Rockford, Illinois 61107 DeKalb, Illinois 60115 Paul M. Murphy, Esq. Michael I. Miller, Esq.

Isham, Lincoln & Beale Isham, Lincoln & Beale One First National Plaza One First National Plaza Suite 4200 Suite 4200 Chicago, Illinois 60603 Chicago, Illinois 60603 i

Mr. Cordell Reed Myron M. Cherry, Esq.

. Commonwealth Edison Company Cherry, Flynn & Kanter P.O. Box 767 One IBM Plaza Chicago, Illinois 60690 Room 4501 Chicago, Illinois 60611

Dr. Axel Meyer Kenneth F. Levin, Esq.

Department of Physics Beatty, Levin, Holland, Basofin j Northern Illinois University & Sarsany l DeKalb, Illinois 60115 11 South LaSalle Street Suite 2200 Chicago, Illinois 60603 I

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i Mr. Charles E. Morris i Executive Director l Rockford Register Star 99 East State Street Rockford, Illinois 61105 l

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