ML20024A118
| ML20024A118 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/21/1983 |
| From: | Chavez D, Morrison P DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20024A111 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8306150436 | |
| Download: ML20024A118 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-454 OL
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50-455 OL (Byron Nuclear Power Station, Units 1 & 2)
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MOTION TO AMEND AND CONSOLIDATE DAARE/ SAFE CONTENTION 3 AND ROCKFORD LEAGUE OF WOMEN VOTER'S CONTENTIONS 19 AND 108 DAARE/ SAFE and Rockford League of Women Voters move the Nuclear Regulatory Commission for an order amending and consolidating DAARE/ SAFE Contention 3 and Rockford League of Women Voters Contention 19 and 108, and in support thereof state as follows:
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The Amendment and Consolidation of DAARE/ SAFE Contention 3 and Rockford League of Women Voters Contentions 19 and 108 (Amendment) is stated in Exhibit Ar which is attached to and made a part of nKs o e n.
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$8 this action.
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,o 2.
The purpose of the Amendment is to limit the state-n:s:
88 ment of DAARE/ SAFE Contention 3 (Contention 3) and no Y
Rockford League of Women Voters Contentions 19 and SE ma.o 108 (Contentions 19 and 108) to the issues which:
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,t (a) are addressed in the Affidavits of David
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Turner, David Miller, J. Michael Maloney, Charles Lamb. Thomas Bowes, Gary Montel, Carl Swon, and Joel Cowen.
Said Affidavits were filed with the Nuclear Regulatory Commission and served on all parties on Monday, February 21, 1983 Said Affidavits are incorporated herein by reference as Exhibits B, C, D E, F, G, H, and I, respectively.
(b) will be addressed by the witnesses which DAARE/ SAFE intends to subpoena viz., Ruth Little, Director, Rockford Chapter, Girl Scouts of America (Camp McCormick): Robert Glazer, Director, Village of Progress, Oregon, Illinois:. Steve Walters, Chief of the Byroa Fire Department: William Dilts, l
Administrator in Charge of Emergency Services, Rockford Memorial Hospitals Jerry Brooks, Ogle County ESDA Coordinators and, Paul Sereg, Region II, ESDA Coordinator, Dixon, Illinois.
-(c) will form the basis of DAARE/ SAFE's and a
<tha Rockford League of Women Voter's cross-examination of witnesses called by other parties or by the Atomic Safety Licensing Board.
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The testimonial evidence contained in Exhibits B through I, and the testimonial evidence which will
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be presented by Feul Holn. beck -nd th-t which '.1i11
be elicited from witnesses which DAARE/ SAFE will
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subpoena concerns, in large part, certain inadequacies in the emergency plans stated in IPRA, VI, Revision 0, (Revision 0) and Evacuation Time Estimates Within the Plume Exposure Pathway Emergency Planning Zone for the Byron Nuclear Generating Station.
(Evacuation Time Estimates) 4.
The Amendment is timely filed.
Both Revision 0 and the Evacuation Time Estimates were published in late December, 1982, and were produced by Commonwealth Edison for DAARE/ SAFE in early January, 1983 These publication and production dates gave DAARE/ SAFE approximately five to six weeks to review and analyze those documents: contact their witness about the plans: secure the agreement of their witnesses to testify: and prepare the testimony.
5 DAARE/ SAFE's and the Rockford League of Women Voter's interest in adjudicating the adequacy emergency planning for the Byron Station will not be prote ted unless their motion is granted.
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6.
The Amendment will assist in the development of a 1
i sound record because it will eliminate those portions
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of Contentions 3. 19, and 108 which will not be addressed by DAARE/ SAFE's witnessess because it will state the issues about' emergency preparedness with greater specificitys and because all of DAARE/ SAFE's l
witnesses with respect to the Amendment have now been identified.
7 The Amendment will not broaden,the issues or delay l
4-the proceedings because all of the testimony which
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DAARE/ SAFE intends to introduce is within the scope of Contentions 3, 19, and 108 as they are currently worded; and because DAARE/ SAFE is willing to attempt a compromise of the issues raised in the Amendment and in Exhibits B through I.
DAARE/ SAFE will also promptly disclose any information about its case which is otherwise subject to discovery and will make,its witnesses available for deposition.
Wherefore, DAARE/ SAFE and the Rockford League of Women Voters respectfully ask the Nuclear Regulatory Commission to issue an order amending and consolidating DAARE/ SAFE Contention 3 and
.rford League of Women Voter's Contentions 19 and 108 as stated in Exhibit A.
By Diane Chavez, DAARE/ SAFE Representative and i
By3Y i ed%w Pat Mo M iso'n, League of Women Voters of Rockford Representative February 21, 1983 O
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