ML20055B112

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Motion for Extension of Time Until 820717 to File Response to NRC 820607 Motion for Summary Disposition.Affidavits Being Prepared by Witnesses Located in Pittsburgh,Pa. Certificate of Svc Encl
ML20055B112
Person / Time
Site: Byron  Constellation icon.png
Issue date: 07/15/1982
From: Gallo J
COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8207200371
Download: ML20055B112 (4)


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, DOLMETED UNITED STATES OF AMERICA UiMC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BO b O' 9 !D 00 r- _

Y;.. ::, -c ~, v In the Matter of ) " iu

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) Docket No. 50-454 -

COMMONWEALTH EDISON COMPANY ) 50-455

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(Byron Station, Units 1 and 2) )

MOTION FOR A TIME EXTENSION Commonwealth Edison Company (" Applicant") hereby moves the Atomic Safety and Licensing Board to enter an order granting a time extension until noon Monday, July 17, 1982, within which to file Applicant's response to the NRC Staff's June 7, 1982 motion for summary disposition. In support of the motion, Applicant states:

1. Applicant intends to file a response to the NRC Staff's motion for summary disposition with respect to only one sub-issue of DAARE/ SAFE Contention 9, namely 9.c concerning the integrity of steam generator tubes. Applicants did not file for summary disposition on this issue and its views j should be considered by the Licensing Board.

l Affidavits concerning Contention 9.c are under preparation with witnesses from Westinghouse Electric Corporation located in Pittsburgh, t

! Pennsy lvania. This effort is incomplete and counsel l

8207200371 820715 PDR ADOCK 05000454 .

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p needs the entire working day tomorrow to attempt to complete his consultation with the witnesses.

2. Applicant will deliver its response to the Licensing l Board by messenger prior to noon on Monday, July 19, 1982. Service on the balance of the service list will be effected by mail. In view of the fact that a time extension has been granted to permit DAARE/ SAFE to file its response by Express Mail on Monday, June 19, no prejudice will accrue to any party by the grant of Applicant's motion.
3. DAARE/ SAFE has no objection to the motion. Counsel for the NRC Staff advises he has no objection provided the grant of the motion does not cause the Licensing Board to delay its ruling on this matter beyond July 22, 1982.

For good cause shown, Applicant's motion should be granted.

Respectfully Submitted, k-b Jos6ph Gallo One of the Attorneys for COMMONWEALTH EDISON COMPANY ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.

Suite 840 Washington, D.C. 20036 (202) 833-9730

J' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket No. 50-454

) 50-455 (Byron Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of MOTION FOR A TIME EXTENSION were served on Judge's Margulies and Cole by hand-delivery and on all persons listed below by deposit in the United States mail, first-class postage prepaid, this 15th day of July, 1982.

Morton B. Margulies, Esq. Atomic Safety and Licensing Administrative Judge and Chairman Board Panel Atomic Safety and Licensing U. S. Nuclear Regulatory Board Panel Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety and Licensing Appeal Board Panel Dr. Richard F. Cole U. S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D. C. 20555 Board Panel U. S. Nuclear Regulatory Chief, Docketing and Service Commission Section Washington, D. C. 20555 Office of the Secretary U. S. Nuclear Regulatory Dr. A. Dixon Callihan Commission Administrative Judge Washington, D. C. 20555 Atomic Safety and Licensing Board Panel Steven C. Goldberg, Esq.

U. S. Nuclear Regulatory Mitzi A. Young, Esq.

Commission Office of the Executive c/o Union Carbide Corporation Legal Director P. O. Box Y U. S. Nuclear Regulatory Cak Ridge, TN 37830 Commission Washington, D. C. 20555

e Chief Hearing Counsel Ms. Diane Chavez Office of the Executive SAFE Legal Director 602 Oak Street, Apt. 4 U. S. Nuclear Regulatory Rockford, IL 61104 Commission Washington, D. C. 20555 Dr. Bruce von Zellen Department of Biological Myron M. Cherry, Esq. Sciences Cherry, Flynn & Kanter Northern Illinois University Suite 3700 DeKalb, IL 60115 Three First National Plaza Chicago, Illinois 60602 Ms. Betty Johnson 1907 Stratford Lane Rockford, IL 61107

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