ML20033B314
| ML20033B314 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/22/1980 |
| From: | Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | Mark Miller Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20033B283 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112010220 | |
| Download: ML20033B314 (4) | |
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EXHIBIT 17 gf
- Grrecto C H E R RY, FLY N N & K A N T E R oNEseu plaza CHICAGO. ILLINOIS S06ll vettonout 4
- uv::oM m. cNtony PETER FLYN N 13tti SG S.t:77 ARNOLD KANTER f
February 22, 1980 1
Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board Panel 4
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United States Nucilear Regulatory Commission Washington, D. C.
20555 j.
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Re:
Commonwalth Edison Company (Byron i
Nuclear Pcwer Station, Units.1 and 2)
Dht. Nos. 50-454 and 50-455
Dear Chairman Miller:
j As the Board has been informed on previous occasions, j
I have had discussions with the League of Women Voters of Rockford l
and have finally wo'rked out the details of my representation.
l Under this date I have filed an Appearance on behalf of the League f
and have served everyone concerned.
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Under date of February 13, 1980, Commonwealth Edison i
filed its " Motion for a Ruling on the Admissibility of Contentions l
of the League of Women Voters of Rockford."
i l
Today I talked with Mr. Paul Murphy representing commonwealth Edison and explained to him that I would be shortly j
filing revised contentions and that I was filing my Appearance l
today.
In Ilew of that, I requested Mr. Murphy to withdraw his Motion based upon my representation that our revised contentions 1
will be filed shortly.
I i
Mr. Murphy advised me to represent to you that Commonwealth Edison is agreeable to entering and continuing l
Commonwealth Edison's Motion until March 10, 1980, on or before i
which date I will file and serve upon all of the parties the League's revised contentions.
Thereafter, if advisable, the i
parties will negotiate and inform the Board.
Mr. Myron Karman
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of the NRC has also agreed to this procedure.
On March 10 or shortly thereafter Mr. Murphy will advise the Hearing Chairman whether, in view of the filing"of the revised contentions, it is any longer necessary to consider Commonwealth Edison's Motion at all or in its present form.
I have also agreed with Mr. Murphy (and have secured Mr. Karman's agreement as well) that if I do not Yile revised t
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1 Mrrchall E Millcr, Ecq.
February 12, 1980 Page Two I
contentions on or before March loth, I will at that time file an answer to Commonwealth Ediso1's Motion dated February 13, 1980.
The parties have asked that the Board treat this letter as a stipulation reflecting the above.
Res'3ectfullyM, h $u v
I Myro 'M. Cherry Coun 1 for the Lea ue of Women Voters of Rockfor O
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Service List O
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EXHIBIT 17 La orricco CH E R DtY, FLY N N & K A NT E R ONE SSN PMIA TettpsoN c CHICAGO. ILLINots SoSil MvDCN M. CHERRY 13121 5 6 5 - s t 77 a -
FETE 2 rLYNN
.t ACCCLD MANTER a
February 22, 1980 Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D. C.
20555 Re:
Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2)
Dkt. Nos. 50-454 and 50-4 55
Dear Chairman Miller:
As the Board has been informed on previous occasions, I have had discussions with the League of Women Voters of Rockford and have finally wo'rked out the details of my representation.
j Under this date I have filed an Appearance on behalf of the League i
and have served everyone concerned.
' Under date of February 13, 1980, Commonwealth Edison filed its " Motion for a Ruling on the Admissibility of Contentions i
of the League of Women Voters of Rockford."
Today I talked with Mr. Paul Murphy representing Commonwealth Edison and explained to him that I would be shortly filing revised contentions and that I was filing my Appearance In view of that, I requested Mr. Murphy to withdraw his today.
l Motion based upon my representation that our revised contentions will be filed shortly.
Mr. Murphy advised me to represent to you that l
Commonwealth Edison is agreeable to entering and continuing Commonwealth Edison's Motion until March 10, 1980, on or before which date I will file and serve upon all of the parties the l
League's revised contentions.
Thereafter, if advisable, the parties will negotiate and inform the Board.
Mr. Myron Karman of the NRC has also agreed to this procedure.
On March 10 or shortly thereafter Mr. Murphy will advise the Hearing Chairman whether, in view;of the filing of the revised contentions, it is any longer necessary to consider i
Commonwealth Edison's Motion at all or in its present form.
I have also agreed with Mr. Murphy (and have secured Mr. Karman's agreement as well) that if I do not file revised i
I Marshall E. Miller, Esq.
February 22, 1980 Page Two
.1 contentions on or before March 10th, I will at that time file an answer to Commonwealth Edison's Motion dated February 12, 1980.
I The parties have asked that the Board treat this letter as a stipulation reflecting the above.
ResSectfully, f
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vv u
o Myro M. Cherry Coun el for the Lea ue of Women Voters of Rockfor e
MMC /dn 4
Serv' ice List 4
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EXHIBIT'18 D0LKETED T3N.E
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C H E R R Y & F LY N N t
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81 NOV 24 P3:46 i
CHICAG O. lLLINOls 60611 1
l' J SECRETt.RY
,J;m_:,ING & SERVICE 4
isian ses-""
BRANCH j
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'Fetruary 21,19C i
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Marshall E. Miller, Esq., 01aiman i
Atomic Safety and Li nsing Board Panel U. S. Nuclear Regulatory Omnissian j
washington, D. C.
20555 4
l Re: In the Matter of Cw-.--;:=lth Diisan Oztpany j
(Byron Nuclear Power Station, Units 1 and 2),
Docket Nos. 50-454 and 50-455 l
Dear Chairman Miller:
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comonwealth Miann requested an tu-----3 extension of time within which to file a Petiticn for Reconsideration.
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'Ibe undersigned hereby requests until March 23, 1981, within which to respond. Below we set forth the reasons for this request and
- d. of G--
- -lth Edison's counsel to this request.
the im===
Cw=4 =lth Miam's Petiticn for Reconsideration was received j
at the office of the undersigned ocnnsel for the Ibckford Imague of wznen Voters on February 14, 1981. At the time of receipt of this dev'=mnt I was in Ios Angeles, California (and had been since the first of February) taking dwitions in a case pending in the thited States District' court i
for the Northern District of T114 min. I returned to my office 'Ilmraday,
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February 19, and 4==diately began working on papers in mum; tion with a j
preliminary injunction motion to be heard in the Illinois State Court sometime during the and of the week of February 23 or the beginning of l
the week of March 2.
l In addition, beginning February 23 for at least five days I j
1 will be involved in Chicago, Illinois, in a continuation of the depositions
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in connecticn with the matter that required agr presence in Ics Angeles.
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'Ibe two renaining lawyers in my office have been involved in all of the aforesaid matters and will continue to be so occupied over the j
next two weeks.
Pbr that reason, I iw ilully request until March 23, 1981, to respond to Ocmenwealth Einert's Febtuary 13, 1981 Petition for Recensideration.
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Marshall E. Miller, Esq., Chairman February 21, 1981 Page 'IWo t
I am authorized to state that Paul M2rphy, counsel for otmnonwealth FAiW, has agreed to this requested extension of time within which to answer, and has authorized me to transmit his agreement to the Board via this letter.
Mr. Mirphy and I will prepare a stipulaticm for entry by the Board if such a procedure is desned necessary. However, I respectfully call to the Board's attention 10 C.F.R. 5 2.718(f) drich permits the presiding officer to act upon this g -+%rni request given the agreement of all parties.
C ms g ully,
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W f Co for the of W:xTn Voters, Ibckford, T11ino*
MC/dn oc: Paul M. MIrphy, Esq.
Kenneth F. Ievin, Esq.
Atomic Safety and Licensing Board Panel Secretary, Docketing ard Service Section Dr. Richard F. Cole Dr. A. Dixon 2114han r
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