ML20076J109

From kanterella
Jump to navigation Jump to search
Affidavit of DC Thomas Supporting Extension Until 830628 to File Proposed Findings of Fact & Conclusions of Law Re Contentions 22 & 9(c).Time Needed Due to Heavy Trial & Teaching Schedule.Certificate of Svc Encl
ML20076J109
Person / Time
Site: Byron  Constellation icon.png
Issue date: 06/14/1983
From: Thomas D
AFFILIATION NOT ASSIGNED, DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:
Shared Package
ML20076J082 List:
References
NUDOCS 8306200331
Download: ML20076J109 (3)


Text

,

AFFIDAVIT DAVID C. THOMAS, being first duly sworn on oath, deposes and states as follows:

1.

YOUR AFFIANT is the attorney of record for Intervenor Rockford League of Women Voters and Daare/ Safe regarding Contentions 22 and 9 (c) respectively.

(

2.

On May 31, 1983, Your Affiant filed proposed findings and conclusions regarding the seismology issues.

3.

Contemporaneous 1y herewith Your Affiant is filing pro-4 posed findings and conclusions regarding ALARA.

4.

During the period of time since the hearings in this proceeding closed, in addition to the activity set forth above, Your Affiant has also been required to grade approximately 80 criminal procedure examinations, as well as maintain a heavy trial and teaching schedule.

5.

Although Your Affiant has worked diligently on the steam generator issue, which encompasses the testimony of more than 15 witnesses and consumed two full weeks of the hearing, Your Affiant has been unable to complete the findings and conclusions on this issue.

6.

This request is made in good faith and not for the purposes of delay.

FURTHER AFFIANT SAYETH NOT.

8306200331 830614 gDRADOCK05000 l

DAVlD C. THOMAS l

STATE OF ILLINOIS

)SS COUNTY OF COOK

)

SUBSCRIBED and SHORN to before me this 14th day of/ June, 1983.

e NOTARI h'

a

1 hl pos'd esnG

'A UNITED STATES OF AMERICA 4

NUCLEAR REGULATORY COMMISSION g ggS3 >

'O

$1'/,$.s.6 s w-U#*

\\

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD q,

I?a ^ ' ~

In the Matter of

)

) Docket Nos.

50-454 OL COMMONWEALTH EDISON COMPANY

)

50-455 OL

)

(Byron Nuclear Power Station,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE The undersigned, attorney for Intervenor Rockford

~ League of Women Voters, certifies.that he filed the original and two copies of the attached "INTERVENOR ROCKFORD LEAGUE OF WOMEN VOTERS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW REGARDING ALARA AND STEAM GENERATOR TUBE INTEGRITY", along with Motion for Extention of Time on the Steam Generator issue and an attached with the Secretary of the Nuclear, Regulatory Commission Affidavit, on the 14th day of June, 1983 &

served a copy of the same on each of the persons at the addresses shown on the attached service list.

Service on the Secretary and all parties, unless otherwise indicated, as made by deposit in the U.S. Mail, first-class postage on the

prepaid, day of June, 1983.

15th DAVID C. THOMAS Attorney for the Rockford League of Women Voters DAVID C.

THOMAS I

77 S. Wacker Dr.

Chicago, IL 60606 (312) 567-5050 L.

SERVICE LIST COMMONWEALTH EDISON COMPANY -- Byron Station Docket Nos. 50-454 and 50-455 Mr. Ivan W. Smith Ndchael Miller, Esq.

Administrative Judge and Chaire.an Isham, Lincoln & Beale Atomic Safety and Licensing Board Panel One First National Plaza Room 428 East West / West Towers Bldg.

42nd Floor 4 350 East West Highway Chicago, IL 60603 Bethesda, MD 20114 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Chief Hearing Counsel Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dr. A Dixon Callihan Union Carbide Corporation P.O. Box Y Oak Ridge, Tennessee 37830 Mr. Steven C.

Goldberg Ms. Mitzi A. Young Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Secretary i

Attn :

Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission j

Washington, D.C.

20555 Ms. Diane Chavez SAFE 326 N. Avon St.

(

Rockford, IL 61103 Dr. Bruce von Zellen l

Department of Biological Sciences Northern Illinois University DeKalb, IL 60115 Joseph Gallo, Esq.

Isham, Lincoln & Beale Suite 840 1120 Connecticut Ave., N.W.

Washington, D.C.

20036 Douglass W.

Cassel, Jr.

Jane whicher BPI Suite 1300 109 N. Dearborn Chicago, IL 60602