ML20116C964

Second Set of Interrogatories to Intervenors Bl Rorem & Appleseed Alliance Re Emergency Planning Issues.Certificate of Svc Encl.Related Correspondence

ML20116C964
Person / Time
Site:	Braidwood
Issue date:	04/25/1985
From:	Copeland V COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	APPLESEED, ROREM, B.
References
CON-#285-712 OL, NUDOCS 8504290230
Download: ML20116C964 (5)

Text

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DOCKETED l USNEC l UNITED STATES OF ATRICA l

NUCLEAR REGUIRIORY CCNMISSIN BEEVRE THE A'IOMIC SAFETY AND LICENSING BOARD 85 APR 26 A10:51 CFFiCE 0r SECStTA a.

00ChEi!NG & SEpvict In the Matter Of: )

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CCet!ONWEALTH EDISCN CCMPANY )

) Docket Nos. 50-4560L (Braidwood Nuclear Power ) 50-4576L Station, Units 1 and 2) )

INTERROGA'IORIES 'IO INTERVENCR BRIDGET LI'ITLE ROREM AND APPLESEED ALLIANCE - SET II l

i Applicant, Cannonwealth Edison Canpany, hereby serves upon Intervenor Bridget Little Rorem and Appleseed Alliance this second set of written interrogatories pursuant to 10 C.F.R. S 2.740b. Each interroga-tory should be answered separately and fully in writing, under oath or affirmation, within 14 days after service.

19. In your April 17 response to our Interrogatory (page 2, subpara-graph "a") you refer to " informational brochures." Please f provide the titles of the brochures and the names of the nuclear plants covered by such brochures. Please designate by page nurber and paragraph and sentence the material in such brochures that " relies too heavily on the unlikelihood of any radiological em rgency."

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20. Your April 17 response (page 3) to Interrogatory 3 states:

Intervenor believes that emergency plans for cther Comonwealth Edison nuclear plants have relied too heavily upon (a) the unlikelihood of any radiological emergency requiring a large-scale evacuation, (b) the availability of appro-priate transportation vehicles, (c) optimum weather conditions during any emergency evacu-ation, and (d) that the public within 10 miles of these plcnts has more knowledge of proper re-sponse to emergency situations than has been provided by Camenwealth Edison's brochures.

Please identify the Edison nuclear plant emergency plans referred to in the above response. Please identify by page references those passages of such plans that rely too heavily on the unlikelihood of any radiological emergency requiring a large scale evacuation, the availability of appropriate transportation vehicles, optimum weather conditions during any emergency evacuation, and that the public within 10 miles of these plants has more knowledge of proper response to emergency situations than has been provided by comonwealth Edison's brochures.

21. Your response to Interrogatory 10 does not identify the specific hospitals referred to in your Contention 1. Please provide this information. If the answer is "none," so state.

22. Please identify the schools, kindergartens, nursery schools, licensed and unlicenced day care facilities referred to in your Fesponse to Interrogatory 11.

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23. Kho sponsors the classes and field trips referred to in your Response to Interrogatory ll? hhere are these sponsors located?

Submitted by: i t

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Victor G. Copelefid i One of the Attorneys for Ccrimonwealth Edison Carpany Dated: April 25, 1985 Joseph Gallo, Esq.

Victor G. Copeland, Esq.

Isham, Lincoln & Beale i 1120 Connecticut Avenue, N.W.

Suite 840 s

Washington, D.C. 20036 i (202) 833-9730 Rebecca J. Lauer, Esq.

Isham, Lincoln & Beale Three First National Plaza Chicago, IL. 60602 (312) 558-7500 I

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COLKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 85 @R 26 N0 51 A

BEFORE THE ATOMIC SAFETY AND LICENSING BOA [Cf[yg[;

g BRANCH In the Matter of )

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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Nuclear Power Station )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the INTERROGATORIES TO INTERVENOR BRIDGET LITTLE ROREM AND APPLESEED ALLIANCE - SET II were served on the persons listed below by deposit in the United States mail, first-class postage prepaid, this 2JC day of April, 1985.

Lawrence Brenner, Esq. Chairman C. Allen Bock, Esq.

Administrative Law Judge P.O. Box 342 Atomic Safety and Licensing Board Urbana, IL 61801 U.S. Nuclear Regulatory Commiasion Washington, D.C. 20555

. Dr. A. Dixon Callihan Atomic Safety and Administrative Law Judge Licensing Board Panel 102 Oak Lane U.S. Nuclear Regulatory Oak Ridge, TN 37830 Commission Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and Administrative Law Judge Licensing Appeal Board Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 1 Commission Washington, D.C. 20555 Ms. Bridget Little Rorem 117 North Linden Street P.O. Box 208 Essex, IL. 60935

Myron Karman, Esquire Docketing and Service Section Elaine I. Chan, Esquire Office of the Secretary Office of General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Douglass W. Cassel, Jr., Esquire Lorraine Creek Timothy W. Wright, III, Esquire Route 1 BPI Box 182 109 North

Dearborn Street Manteno,

Illinois 60950 Suite 1300 Chicago, Illinois 60602 Charles Jones, Director Illinois Emergency Services and Disaster Agency 110 East Adams Springfield, IL 62705 YW Victor G. Copelind One of the Attorneys for Commonwealth Edison Company 1

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