ML17341B634
| ML17341B634 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/29/1981 |
| From: | Fitzgibbons R COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8107080274 | |
| Download: ML17341B634 (4) | |
Text
ISHAM, LINCOLN & BEALE COUNSELORS AT LAW ONE FIRST NATIONALPLAZA FORTY SECOND FLOOR CHICAGO, ILLINOIS BOBO3 TELEPHONE 312 5S8 TSOO TELEX: 2 5288
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June 29 UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of COMMONWEALTH EDISON COMPANY (Quad Cities Station, Units 2 and 3)
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Docket Nos ~50-254-
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(Spent Fuel Pool Modification)
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Dear Pdministrative Judges:
On June 26,
- 1981, counsel for Commonwealth Edison Company and Iowa-Illinois Gas and Electric Company (NLicenseesN),
met with representatives of the.Quad-City Alliance for Safe Energy and Survival
(,NQASESN), Citizens For Safe Energy
("CSEN) and Older Americans for Elderly Rights
(,"OAERN) in the offices of OAER in Rock Island, Illinois.
Counsel for the NRC Staff was unable to attend.
Based on information supplied at this meeting, Licensees wi'thdraw their objections
.as to QASES's and CSE's standing and authority to intervene in this proceeding.
Counsel for Licensees also discussed with the representatives of QASES and CSE,the aspects raised in these two organizations'espective petitions for leave to intervene.
Negotiations are continuing and it appears likely that Licensees will be able to stipulate as to the acceptability of at least some of the contentions filed by both QASES'nd CSE.
Nevertheless, it is also apparent that we will not be able to agree on all contentions and therefore Licensees request a, special prehearing conference at the Board's convenience in order for the Licensing Board to rule on contested contentions pursuant to 10 CFR 52.751a.
It is Licensees'nderstanding that QASES and CSE oppose the scheduling of the special prehearing conference until sometime after Licensees'omplete application is filed.
This is unacceptable to Licensees.
Revising Licensees'pplication is a continuous process and postponing the special prehearing conference until after the complete and revised
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application is filed will not only unduly delay the commencement of discovery, but would contravene 10 CFR 52.75la.
- Moreover, postponement is unnecessary as any new information disclosed in subsequent revisions of Licensees'pplication would con-stitute "good cause" pursuant to 10 CFR 52.714(b) for filing late contentions related to such new information.
Finally, the representative of OAER, Mr. John Smith, exhibited a marked reluctance to deal with Licensees'ounsel at the meeting held in Rock Island on June 26, 1981.
Mr. Smith was not interested in discussing either the organizational background of OAER or the aspects raised on this organization's behalf.
- Indeed, Mr. Smith stated that he would communicate directly only with the NRC and would not supply any information to Licensees absent an NRC instruction to do so.
Licensees are concerned that implicit in Mr. Smith's statements is a refusal to.comply with the Commission's regulations. with respect to the serving of pleadings and other written communications on all parties to this proceeding.
Accordingly, Licensees request, that in the order designating the time and place of the special prehearing conference, the Licensing Board instruct all parties to comply with the service requirements set forth in the Commission's regulations.
Respectfully submitted,
- Robert, G.
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, Jr.
One of the Attorneys for Licensees RGF:jp cc:
Service List
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