ML20052A362
| ML20052A362 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/21/1982 |
| From: | Bielawski A, Bielawski A COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-OL, NUDOCS 8204280262 | |
| Download: ML20052A362 (5) | |
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UNITED STATES OF AMERICA B2,qpg73 g,dd nK NUCLEAR REGULATORY COMMISSION g
N BEFORE THE ATOMIC SAFETY AND LICENSING APPE L 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
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(Byron Nuclear Power Station, )
Units 1 & 2)
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MOTION FOR EXTENSION OF TIME Commonwealth Edison Company (Edison), by its attorneys, respectfully requests that the Atomic Safety and Licensing Appeal Board extend the period, up to April 29, 1982, within which Edison may file its brief in response to the Rockford League of Women Voters (League) "Brief In Support of Exceptions To Orders Dated October 27, 1981 and January 27, 1982."
In support of its Motion, Edison states the following:
1.
On March 8, 1982 the Appeal Board granted the League's unopposed request to extend the time within which to file its brief, up to March 23, 1982.
2.
Under the Commission's Rules of Practice, Edison's reply brief is required to be served by mail no later than April 22, 1982.
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... 3.
Much of the effort associated with research-ing the legal issues raised by the League's appeal and preparing Edison's brief is completed.
However, during the same time period.this brief was being prepared, counsel assigned to this appeal were required to devote substantial time and effort to other pressing matters.
These matters include, among others, the preparation and filing of a brief in conjunction with Edison's pending request before~the Illinois Commerce Commission for interim rate relief, and ongoing settlement negotiations in an action between Edison, the United States of America and the State of Illinois pending'in the Federal District Court for the Northern District of Illinois.
As a result, additional time is re-quired to adequately brief the issues raised in this appeal.
4.
If the extension is granted, counsel for Edison represents that Edison's brief will be served on all parties and the Appeal Poard by expedited mail or messenger no later than August 29, 1982.
5.
Counsel for the League, Myron Cherry, Esq.
has authorized counsel for Edison to represent that the League will not oppose Edison's present motion.
Counsel for the NRC Staff, Steven Goldberg, Esq. has authorized counsel for Edison to represent that the Staff has no objection to the requested extension.
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- s. WHEREFORE, Commonwealth Edison respectfully re-quests that the Appeal Board extend the time within which to file in this appeal up to April 29,_1982.
Respectfully submitted, COMMONWEALTH EDISON COMPANY By: -
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Aphn'(P. Bielawskf One of the Attorneys for Commonwealth Edison Company Dated:
April 21, 1982 Michael I. Miller Paul M. Murphy Alan P.
Bielawski ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 (312) 558-7500
CERTIFICATE OF SERVICE 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 the same on each of the persons at the addresses shown on the attached service list in the manner indicated.
Date:
April 21, 1982
/
u Alan"P. Bielawski
SERVICE LIST COMMONWEALTH EDISON COMPANY -- Byron Station Docket Nos. 50-454 and 50-455 BY MESSENGER Myron M.
Cherry, Esq.
Chief Hearing Counsel Cherry, Flynn & Kanter Office of the Executive Three First National Plaza Legal Cirector Suite 3700 U.S. Nuclear Regulatory Commission Chicago, Illinois 60602 Washington, D.C.
20555 BY EXPRESS MAIL Dr. A.
Dixon Callihan Union Carbide Corporation Mr. Steven C.
Goldberg P.O.
Box Y Ms. Mitzi A.
Young Oak Ridge, Tennessee 37830 Office of the Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Stephen F.
Eilperin U.S. Nuclear Regulatory Commission Secretary Washington, D.C.
20555 Attn:
Chief, Docketing and Service Section Ms. Christine N.
Kohl U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Ms. Betty Johnson Dr. Reginald L. Gotchy 1907 Stratford Lane U.S. Nuclear Regulatory Commission Rockford, Illinois 61107 Washington, D.C.
20555 Ms. Diane Chavez BY FIRST CLASS MAIL SAFE 602 Oak Marshall E. Miller, Esq., Chairman Rockford, Illinois 61104 Atomic Safety and Licensing Board Panel Dr. Bruce von Zellen U.S. Nuclear Regulatory Commission Department of Biological Sciences Washington, D.C.
20555 Northern Illinois University DeKalb, Illinois 60115 Dr. Richard F.
Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555