ML19253B298

From kanterella
Jump to navigation Jump to search
Answer to Bl Rorem 790807 Amended Petition Submitting Contentions Negotiated Among Petitioner,Applicant & Nrc. Contentions Should Be Admitted as Issues in Controversy. Certificate of Svc Encl
ML19253B298
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 08/15/1979
From: Murphy P
COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:
References
NUDOCS 7910100677
Download: ML19253B298 (5)


Text

., y m gj4.,

y s

,,,f.

[Ih

,(Q

~

UNITED STATES OF AMERICA e

NUCLEAR REGULATORY COMMISSION

)

In the Matter of

)

)

COMMONWEALTH EDISON COMPANY

)

Docket Nos. 50-456

)

50-457 (Braidwood Nuclear Power Station,

)

Units 1 and 2)

)

)

ANSWER OF COMMONWEALTH EDISON COMPANY TO AMENDED PETITION OF BRIDGET LITTLE ROREM, ET AL.

Commonwealth Edison Company

(" Applicant") submits the following in answer to the Amended Petition of Bridget Little Rorem, et al., dated August 7, 1979.

1.

Pa.-ties Bridget Little Rorem, et al., have requested that the Bailly Alliance-Illinois be dropped as a party to this proceeding and that Appleseed be admitted as a party.

Upon receipt of the petition, counsel for Applicant contacted Ms. Rorem for additional details on this request.

Ms. Rorem represented that Appleseed is, in essence, a successor organization to the local chapter of Bailly Alliance-Illinois and that the membership of Appleseed consists primarily of those members of Bailly Alliance-Illinois who reside or work within 30 miles of the Braidwood nuclear station and which were referenced in Ms. Rorem's original petition dated January 11, 1979.

Ms. Rorem also represented that all of 1124 277 677 7910100 G

4 the individual petitioners joining in her petition are associated with Appleseed.

Based on these representations from Ms. Rorem, Applicant believes that it would be appro-priate to substitute Appleseed for the Bailly Alliance-Illinois as a party to this proceeding.

Ms. Rorem has informed Applicant that she will act as spokesperson for Appleseed and the individual petitioners, that the petitioners will act as a consolidated party and that 3ervice on the petitioners should be made on her.

2.

Contentions The contentions submitted in the Rorem petition are the result of negotiations between Ms. Rorem, Applicant and the NRC Staff.

Applicant believes that these contentions should be admitted as issues in controversy in this proceed-ing.

Respectfully submitted,

,.Q

{

ONIi.?',-l?%wb Paul M.

Murphy.. '

nATED:

August 10, 1979 One of the Attorneys,p/

for Commonwealth Edison Company ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 (312)558-7500 1124 278 CERTIFICATE OF SERVICE The undersigned, one of the attorneys for Common-wealth Edison Company, certifies that on this date he filed 20 copies (plus the original) of the attached pleading with the Secretary of the Nuclear Regulatory Commission and served a copy of same on each of the persons at the addresses shown on the attached service list by United States mail, postage prepaid.

3

[l DATE:

August 10, 1979

/

s 1/

f%

I 3 %6 ',//, 1 Mgh Paul M.

Murphy 8

N e

i124 2/9

COMMONWEALTH EDISON COMPANY - Braidwood Station Docket Nos.50-456 and 50-457 Marshall E. Miller, Esq., Chairman Dr. A. Dixon Callihan Atomic Safety and Licensing Board Union Carbide Corporation Panel P.O. Box Y U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.

20555 Dr. Richard F.

Cole Myron Karman, Esq.

Atomic Safety and Licensing Board Office of the Executive Legal Panel Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Richard J, Goddard, Esq.

Atomic Safety and Licensing appeal Office of the Executive Legal Board Danel Director U.S. Nuclear Regulatory Commis3 ion U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Atomic Safety and Licensing Board Secretary Panel Attn:

Chief, Docketing and U.S. Nuclear Regulatory Commission Service Section Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Chief Hearing Counsel C. Allen Bock, Esq.

Office of the Executive Legal P.O. Box 342 Director Urbana, Illinois 61801 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 1124 280

Thomas J.

Gordon, Esq.

Ms. Bridget Little Rorem Waaler, Evans & Gordon 117 North Linden Street 2503 South Neil Essex, Illinois 60935 Champaign, Illinois 61820 Paul M. Murphy, Esq.

Michael I. Miller, Esq.

Isham, Lincoln & Beale Isham, Lincoln & Beale One First National Plaza One First National Plaza Suite 4200 Suite 4200 Chicago, Illinois 60603 Chicago, Illinois 60603 Mr. Cordell Reed Commonwealth Edison Company P.O. Box 767 Chicago, Illinois 60690 I124 281