ML20058C005
| ML20058C005 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/22/1982 |
| From: | Chavez D, Whicher J DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE), VOLLEN, R.J. & WHICHER, J.M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8207260223 | |
| Download: ML20058C005 (3) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CKETE0 USNFC ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges :
Morton B. Margulies, Chairman s Jbt 23 P1 Dr. Richard F. Cole Dr. Dixon Callihan opncE CF :EtRQ cc;Eitw & SEFJJ In the Matter of
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Commonwealth Edison Conpany
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Docket Nos. STN 50-454 OL
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STN 50-455 OL (Byron Station, Units 1 and 2) )
MOTION TO REVISE HEARING SCHEDULE DAARE/ SAFE, by its undersigned representatives, moves the Board to revise the schedule for the hearing on the Byron operating license and to set the hearing to begin not sooner than mid-November, 1982.
In support of its motion, DAARE/ SAFE states as follows:
1.
DAARE/ SAFE has recently retained the undersigned counsel, who are filing their appearances herewith, to represent l't on issues of financial qualifications, need for power and alter-native energy sources.
2.
Based on significant new evidence which has become available only within the last month, DAARE/ SAFE, by its new counsel, will file within the week petitions for waiver of or exception to the new NRC regulations which exclude the issues of financial qualifications, need for power and alternative energy.
sources from operating license hearingu.
DAARE/ SAFE's petitions will include information in addition to and more recent than that contained in the similar petitions filed July 6 by the Rochford League of Women Voters.
More time than is allowed for in the a
8207260223 820722 PDR ADOCK 05000454 0
PDR ygy
present hearing schedule will be needed for answers, the Board's certification to the Commission, and a Commission ruling on DAARE/ SAFE 's petitions, as well as for receipt of significant additional evidence which DAARE/ SAFE expects to become available within approximately 45 days.
3.
Simultaneously with its petitions DAARE/ SAFE will file contentions on these issues, answers to Commonwealth Edison's interrogatories with respect to these issues, and motions seeking appropriate revisions of or supplements to the Byron FES and SER.
Time will then be needed for answers, rulings, and for the NRC staff to revise the FES and SER.
4.
DAARE/ SAFE also needs additional time to prepare its case on its other contentions, particularly since it has not yet been advised as to which of such contentions will be disposed of summarily, and which not.
DAARE/ SAFE also plans to file,a response to Commonwealth Edison's response to the NRC staff Motion for Summary Disposition on Contention 9(c).
5.
A single hearing on all DAARE/ SAFE's contentions would be more efficient and more economical for all concerned.
Since a proper hearing on DAARE/ SAFE's new contentions could not possibly begin in August, the hearing on all DAARE/ SAFE's contentions should be held at a later date.
6.
Likewise, a single hearing on DAARE/ SAFE's contentions and any contentions by Rockford League of Women Voters which relate to the same issues would be more efficient and economical.
Since the League's hearing cannot begin in August, and since it i
N has not yet been determined which contentions of either party will be litigated, the hearing on DAARE/ SAFE's contentio'ns should not go forward in August.
Moreover, while DAARE/ SAFE cannot be ready before mid-November, the League may not be ready until a later date, in which event the joint hearing should not be set until such later date.
7.
A mid-November hearing date, / the earliest date by which DAARE/ SAFE could be properly prepared, will neither prejudice any party nor jeopardize the operation of Byron I, the fuel load-ing date for which is currently scheduled to be not sooner than late August, 1983.
DATED:
July 22, 1982 Respectfully submitted, Douglass W. Cassel Jane M. Whicher D.
By:
A Jane M. Whicher Attorneys for DAARE/ SAFE with respect to issues of financial qualifications, need for power j
and alternative energy sources l
Douglass W. Cassel, Jr.
h bM Jane M. Whicher M
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109 North Dearborn Diane Chavez Chicago, IL 60602 i
Representative of DAARE/ SAFE with (312) 641-5570 respect to all other issues Diane Chavez 608 Rome Avenue Rockford, IL 61107 (815) 962-7373
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Dates for matters preliminary to the start;ing date of the hearing e. g., for the dates for filing pre-filed testimony, should also be moved back accordingly.
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