ML20062B082

Response to First Round of Interrogatories Re Financial Qualifications,Need for Power & Alternative Energy Sources

ML20062B082
Person / Time
Site:	Byron
Issue date:	07/30/1982
From:	Chavez D DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	COMMONWEALTH EDISON CO.
Shared Package
ML20062A998	List: ML20062A995 ML20062B011 ML20062B027 ML20062B047 ML20062B059 ML20062B067 ML20062B082 ML20062B093
References
NUDOCS 8208040312
Download: ML20062B082 (4)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION QW.F c

l BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD ',

7 7 ..

1 In the Matter of )

)

{ C0!1MONWEALTil EDISON COMPANY ) Docket Nos. 50-454 .

! ) 50-455

! (Byron Station, Units 1 and 2) )

DAARE/ SAFE'S RESPONSE TO COMMONWEALTil EDISON'S FIRST ROUND OF INTERROGATORIES TO BE ANSWERED BY DAARE AND SAFE INTRODUCTION In answer to the interrogatories submitted to DAARE/ SAFE by Commonwealth Edison on July 8, 1981, DAARE/ SAFE, by its under-s igned attorneys , submits the following with respect to its financial qualifications contention, and need for power and alternative energy source contention, submitted to the Licensing Board this same date.

FINANCIAL QUALIFICATIONS CONTENTION 1(a). This contention is based on the facts set forth in i

the Petition of Rockford League of Women Voters for Waiver of or l

l Exception to Financial Qualifications Regulations and the Exhibits thereto, filed July 6, 1982, and on the facts set forth in the

'etition of DAARE/ SAFE for Waiver of or Exception to Financial e 'ali ficat ions Regulations, filed July 30, 1982, and Exhibits t .' e r e t o . Further specific references are set for th in the conten-tion itself. In addition, DAARE/ SAFE believes addit ional relevant fjj8040312820730 C ADOCK 05000454 PDR

information and studies are presently being developed which will l

be submitted to Commonwealth Edison as soon as they become i

l available.

1(b), (c) and (d) Pending a ruling by the Board and the Commission on which of DAARE/ SAFE's contentions will be admitted, DAAPE/ SAFE has not ascertained which persons it expects to call as witnesses at the hearing. DAARE/ SAFE will provide further

( information as soon as it has determined whom it will call.

2. Although DAARE/ SAFE has not yet ascertained which witness it will call, certain documents are identified in the exhibits themselves.

3. Although DAARE/ SAFE has not yet ascertained which witness it will call, the qualifications of persons whose testimony appears in the Exhibits are contained in or attached to the respective Exhibits.

4. Counsel for DAARE/ SAFE with respect to the issues of l

financial qualifications, need for power and alternative energy

<;o urce s .

NEED FOR POWER AND ALTERNATIVE ENERGY SOURCE CONTENTION l

1(a) This contention is based on the facts set f o r t. h in the Petit ion of Rockford League of Women Voters for Waive r o f or l Exception to Need for Power and Alternative Energy Source Rerulations 1

10 CFR s S51.23(e) and 51.53(c) and the Exhibits thereto, filed

.Iuly 6, 1982, and on the facts set forth in the Petition of DAARE/ SAFE for Waiver of or Exception to Need for Power and Alternative

W.. .

Energy Source Regulations S$51.23(c) and 51.53(c), filed July 30, 1982. Further specific references are set forth in the contention itself. In addition, DAARE/ SAFE believes additional relevant information and studies are presently being developed and will be submitted to Commonwealth Edison as soon as they become available.

1(b), (c) and (d). Pending a ruling by the Board and the Commission on which of DAARE/ SAFE's contentions will be admitted, DAARE/ SAFE has not ascertained which persons it expects to call as witnesses at the hearing. DA RE/ SAFE wili provide further information as soon as it has determined whom it will call.

2. Although DAARE/ SAFE has not yet ascertained which witness it will call, certain documents are identified in the exhibit themselves.

3. Although DAARE/ SAFE has not yet ascertained which witness

.r will call, the qualifications of persons whose testimony appears in the Exhibits are contained in or attached to the respective Exhibits.

l

4. Counsel for DAARE/ SAFE with respect to the issues of financial qualifications , need for power and alternative energy sources.

1, Diane Chavez , state that I have reviewed the foregoing l

interrogatory answers and they are true and correct to the best of my knowledge and belief; that I am authorized to sign these

C c . . . - interrogatory answers on behalf of DAARE/ SAFE; and that I have a 'horized Jane M. Whicher to sign this document on my behalf.

DATED: July 30, 1982

\M 1M W- .

k Diane Chavez h Fo r Se rvi ce :

Douglass W. Cassel, Jr.

Jane M. Whicher 109 North Dearborn Chicago, IL 60602 (312) 641-5570

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