ML20212R691

Intervenor Motion for Extension of Time.* Extension Until 870203 Requested for Filing Proposed Findings & Brief Due to Extraordinary Bulk of Record.Certificate of Svc Encl

ML20212R691
Person / Time
Site:	Braidwood
Issue date:	01/23/1987
From:	Guild R BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES, ROREM, B.
To:	Atomic Safety and Licensing Board Panel
References
CON-#187-2339 OL, NUDOCS 8702030047
Download: ML20212R691 (4)

Text

' 235 Ef7 DOLMETEp

. unc January 23, 1987

'87 JAN 28 A 8 :21 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 6 Ff r. ,

60CN in ( ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD **

In the Matter of: )

)

COMMONWEALTH EDISON COMPANY ) Docket No. 50-4560L,

) 50-457 (Braidwood Nuclear Station, )

Units 1 and 2) )

INTERVENORS' MOTION FOR EXTENSION OF TIME

1. Intervenors Bridget Little Rorem, gt al., by their undersigned counsel, move for extension of time for the filing of their Proposed Findings and Brief in this proceeding, as provided for in Section 2.711 and 2.754 of the Commission's Rules of 1

Practice. Intervenors seek an extension of eight (8) days for these filings f rom January 26 until February 3,1987. We consent to a like extension of the time for the filings of the Staff and Applicant in Reply.

2. Intervenors require' this limited enlargement of the period for filing because of the extraordinary bulk of this record, consisting of over 18,000 pages of testimony and hundreds of exhibits, the complexity of the factual issues in the proceeding and confounding developments since the close of the record. Since the original filing dates were established, Applicant has found itself unable to serve portions of its findings in advance of January 5, 1987, as it had anticipated; i

and has sought an extension of the page limitations originally l

l imposed. Further, a considerable amount of attorney time has 8702030047 B70123 1 DR ADOCK 0500 6

been required by Intervenors in order to solve unexpected technical problems with the system for computerized access to the hearing record available to the Board and parties. Despite Intervenors' diligence, these factors have necessitated this request for a limited extension of time.

3. The Board Chairman heard this Motion orally, presented by Intervenors' counsel in a conference call this date, January 23, 1987. Applicant's counsel was heard in opposition.

Representatives of the NRC Staff were unavailable. The Chairman advised counsel that the Motion for extention would be granted with subsequent filing dates extended by eight (8) days as well, and directed counsel for Intervenors to submit this written filing.

4. WHEREFORE, good cause having been shown, Intervenors respectfully request the Board to order an extension of time until February 3, 1987, for the filing of Intervenors' Brief and Findings in this proceeding.

Robert Guild /

One of the Attorneys for Intervenors Rorem, et al.

Robert Guild Business and Professional People for the Public Interest

. 109 North

Dearborn,

1. 1300 Chicago, IL 60602 (312) 641-5570 2

4 UNITED STATES OF AMERICA hkIf NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD eg JM 28 A8:21 In the Matter of: )

) LFf u '

Docket No. 50-456 80ut 4,,,L/ , . J, COMMONWEALTH EDISON COMPANY )

) 50-457 (Braidwood Nuclear Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that I have served copies of Intervenors' Motion for Extension of Time on all parties to this proceeding as shown on the attached Service List by having said copies placed in envelopes, properly addressed and postaged (First Class), and deposited in the U.S. mail at 109 North

Dearborn,

Chicago, Illinois, on this 23rd day of January, 1987.

I a I ,

Onelof the A'!torhiys~f5r~iht5rvinors Bridget Little Rorem, et al, l

l

[

t

. *

• 50-456 50-457' SERVICE LIST Herbert Grossman, Esq. Ms. Bridget Little Rorem Chairman 117 North Linden Street Administrative Law Judge P.O. Box 208 Atomic Safety and Licensing Essex, IL. 60935 Board United States Nuclear Regulatory Charles Jones, Director Commission Illinois Emergency Services Washington, D.C. 20555 and Disaster Agency 110 East Adams Dr. Richard F. Cole Springfield, IL. 62705 Administrative Law Judge Atomic Safety and Licensing William Little, Director Board Braidwood Project United States Nuclear Regulatory Region III Commission United States Nuclear Regulatory Washington, D.C. 20555 Commission 799 Roosevelt Road Dr. A. Dixon Callihan , Glen Ellyn, IL. 60137 Administrative Law Judge 1911 Parkview Street Ms. Janice A. Stevens Huntington, Wes t Virginia 25701 United States Nuclear Regulatory Commission Stuart Treby, Esq. 7920 Norfolk Avenue Elaine E. Chan, Esq. Bethesda, MD. 20014 Office of the Executive Legal Director George L. Edgar, Esq.

United States Nuclear Regulatory Thomas A. Schmutz, Esq Commission 1615 "L" Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20036 Atomic Safety and Licensing Gregory Berry, Esq.

Appeal Board Panel NRC Staff Counsel United States Nuclear Regulatory U.S. Nuclear Regulatory

, Commission Commission i Washington, D.C. 20555 7335 Old Georgetown Road Bethesda, MD. 20014 Robert Guild 413 Pall Mall Joseph Gallo, Esq.

Columbia, S. Carolina 29201 Isham, Lincoln & Beale 1120 Connecticut Av., N.W.

Docketing & Service Section Washington, D.C. 20036

, Office of the Secretary i U.S. Nuclear Regulatory Commission Michael I. Miller, Esq.

Washington, D.C. 20555 Peter Thornton, Esq.

Isham, Lincoln & Beale Three First National Plaza j Chicago, Illinois 60602 1

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