ML20062D552

Motion to Compel ASLB Order Requiring NRC to Revise or Suppl Feb 1982 Ser.New Circumstances & Developments Show Licensee Financial Qualifications to Complete Const Not Sufficiently Considered

ML20062D552
Person / Time
Site:	Byron
Issue date:	08/03/1982
From:	Whicher J DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8208060133
Download: ML20062D552 (2)

Text

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UNITED STATES OF AMERICA ectKETEC t

NUCLEAR REGULATORY COMMISSION " UM BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ;a .p, -5 ?1 'G

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In the Matter of ) y;dQii; : .A .~

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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

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

MOTION OF DAARE/ SAFE TO COMPEL SUPPLEMENT TO OR REVISION OF SAFETY EVALUATION REPORT Intervenor DAARE/ SAFE, by its undersigned attorneys , hereby moves the Board to enter an order requiring the NRC staff to revise or supplement the Byron Safety Evaluation Report (SER),

issued in February 1982 and supplemented in March 1982.

The grounds for this motion are as set forth in the Petition of Rockford League of Women Voters for Waiver of or Exception to Financial Qualifications Regulations filed July 6, and Petition of DAARE/ SAFE for Waiver of or Exception I to Financial Qualifications Regulations filed July 30, 1982 and the exhibits to both petitions. See petition at p. 3: DAARE/ SAFE's Reply to Responses of Commonwealth Edison and NRC Staff to Rockford League of Women Voters' Petitions for Waiver or Exception at pp. 2-11.

The SER should be supplemented with respect to the matter of Commonwealth Edison's (CE) financial qualifications to complete construction / and safely operate and decommission

• / See DAARE/ SAFE Reply at pp. 2-4. See also, Rockford League of Women Voters v. NRC, 679 F.2d 1218 (7th Cir. 1982).

8208060133 820803 PDR ADOCK 05000454 E h G PDR n

the Byron plant. Significant new circumstances and developments, detailed in the petitions, have recently become known which show CE's financial situation has not been sufficiently considered in the SER. As such, the SER is inadequate and nust be supple-mented or revised. ,

DATED: August 3, 1982 Respectfully submitted, Douglass W. Cassel, Jr.

Jane M. Whicher by: _

sa . bU 1 ri_ h .

Attorneys for D' ARE/

A SAFE with respect to issues of financial qualifications, need for power and alternative energy sources Douglass W. Cassel, Jr.

Jane M. Whicher 109 North Dearborn Chicago, IL 60602 (312) 641-5570

. .