ML19309C305

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Motion for Order Setting 800418 for Applicant & 800425 for NRC to Respond to Rockford League of Women Voters Revised Contentions.Time Is Needed to Perform Preliminary Evaluation Re Possible Stipulation.Certificate of Svc Encl
ML19309C305
Person / Time
Site: Byron  Constellation icon.png
Issue date: 03/20/1980
From: Murphy P
COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8004080428
Download: ML19309C305 (4)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) 50-455 (Byron Nuclear Power Station, )

Units 1 and 2) )

)

MOTION FOR AN ORDER SETTING THE TIME TO RESPOND TO THE REVISED CONTENTIONS OF THE ROCKFORD LEAGUE OF WOMEN VOTERS Commonwealth Edison Company (" Applicant") respect-fully moves the Atomic Safety and Licensing Board to enter y

an order setting April 18, 1980, as the date on which Appli-cant's written response to the Revised Contentions of Inter-venor, Rockford League of Women Voters (the " League"), may be filed. As grounds for this Motion, Applicant states as follows: -

1. On March 10, 1980, the League filed a ll3-page document containing 146 " Revised Contentions." The Revised Con-tentions assert a large number of safety and environ-mental issues which may or may not be applicable to the _

Byron Station.

2. The sheer bulk-of the Revised Contentions precludes Applicant from filing its response by March 25, 1980, the date on which Applicant had agreed to respond before it had seen the Revised Contentions.
3. Counsel for the League and counsel for the NRC Staff have informed counsel for Applicant that they are agree-8004080

o .

able to Applicant's filing its response to the Revised Contentions on April 18, 1980. The NRC Staff has stated that it desires to file its response on April 25, 1980, one week after Applicant's response.

4. The parties have also discussed the possibility of stipulating to some of'the Revised Contentions. Both the Applicant and the NRC Staff will need time to per-form a preliminary evaluation of the Revised Contentions 4 to determine whether such a stipulation is possible.

WIIEREFORE , Commonwealth Edison Company respectfully moves the Licensing Board for entry of an order setting April 18, 1980, as the date for filing Applicant's response to the League's Revised Contentions, and April 25, 1980, as the date for filing the NRC Staff's response.

DATED: March 20, 1980 Respectfully subm tted, 1 Md dhb Paul M. Murphy / /

Attorney for Applicant Commonwealth Edison Company I S ilA M , LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 (312)S58-7500 m

Li

UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION

)

In the Matter of )

)

, COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) 50-455 (Byron Nuclear Power Station, )

Units 1 and 2) )

)

CERTIFICATE OF SERVICE I, Paul M. Murphy, one of the attorneys for Commonwealth Edison Company, certify that copies of " Motion For An Order Setting The Time To Respond To The Revised Con-tentions Of The Rockford League Of Women Voters" have been served in the above-captioned matter on the following by United States mail, postage prepaid, this 20th day of March, 1980:

Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C. 20555 Dr. A. Dixon Callihan Union Carbide Corporation P.O. Box Y Oak Ridge, Tennessee 37830 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel United States Nuclear-Regulatory Commission Washington, D.C. 20555

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Myron Karman, Esq.

Office of the Executive Legal Director United States Nuclear Regulatory Commission Wasnington, D.C. 20555 Richard J. Goddard, Esq.

Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington,.D.C. 20555 Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington,.D.C. 20555 .

Atomic Safety and Licensing Appeal Board Panel United States Nuclear Regulatory Commission Washington, D.C. 20555 Secretary Attn: Chief, Docketing and Service Section United States Nuclear Regulatory Commission Washington, D.C. 20555 Chief Hearing Counsel Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Betty Johnson 1907 Stratford Lane Rockford, Illinois 61107 Ms. Beth L. Galbreath 734 Parkview Rockford, Illinois 61107 Dr. Julianne Mahler Center for Governmental Studies Northern Illincis University DeKalb, Illinois 60115 Dr. Bruce von 7 ellen Department of 111ological Sciences Northern Illinois University DeKalb, Illinois 60115 Myron M. Cherry, Esq.

Cherry, Flynn & Kanter One IBM Plaza Room 4501 Chicago, Illinois 60611 Kenneth F. Levin, Esq.

Beatty, Levin, Holland, Basofin & Sarsany 11 South LaSalle Street Suite 2200 Chicago, Illinois 60603 DATED: March 20, 1980

. A40 Paul M. Murphy

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