ML20053A510
| ML20053A510 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/20/1982 |
| From: | Bielawski A COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20053A511 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8205260165 | |
| Download: ML20053A510 (2) | |
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4 UNITED STATES OF AMERICA U
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING; BOARD [O :]4 1
4 In The Matter of
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CO!1MONWEALTH 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 LEAVE TO FILE INSTANTER Commonwealth Edison Company respectfully requests that the Licensing Board grant it leave to file the attached
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motion instanter.
In support of its motion, Edison states 1
the following:
1.
On April 15, 1982, DAARE/ SAFE filed a list of revised contentions, presumably pursuant to the Board's Scheduling Order which authorized the filing of contentions 4
based on new information contained in the SSER.
2.
Edison filed an answer and motion to dismiss l
DAARE/ SAFE's contentions generally asserting that DAARE/ SAFE failed to demonstrate that its revised contentions were in fact based on new information, which was not previously available at the time DAARE/ SAFE's original contentions were due.
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4 3.
On May 8, 1982 DAARE/ SAFE filed a reply to
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Edison's answer and motion in which it attempts to demon-strate that its contentions are based on "new" information and that it was justified, for other reasons, in not having filed its contentions at an earlier date.
4.
In view of the fact that these arguments were presented for the first time in DAARE/ SAFE's May 8th motion, Edison requests an opportunity to respond to these i
arguments.
WHEREFORE, Commonwealth Edison Company requests 4
that the Licensing Board grant it leave to file instanter the attached response to DAARE/ SAFE's motion.
Respectfully submitted, u
ks
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hian'P. BhbFhwski, One of the Attcrneys for Commonwealth Edison Company Michael I. Miller Paul M. Murphy ISHAM, LINCOLN & BEALE Three First National Plaza Chicago, Illinois 60602 (312) 558-7500 1
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