ML20132B248

Forwards Motion Opposing Admission of Intimidation & Harassment Issues,In Response to 850712 Motion to Admit Claims of Intimidation & Harassment of Comstock QC Inspectors.Certificate of Svc Encl

ML20132B248
Person / Time
Site:	Braidwood
Issue date:	07/18/1985
From:	Thornton P ISHAM, LINCOLN & BEALE
To:	Brenner L, Callihan A, Cole R Atomic Safety and Licensing Board Panel
Shared Package
ML20132B254	List: ML20132B248 ML20132B256
References
CON-#385-876 OL, NUDOCS 8507230549
Download: ML20132B248 (4)

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, ISHAM, LINCOLN & BE4tEKETED

. COUNSELORS AT LAW Ubh5C p

THREE FIRSTNATIONAL Pf hj CHICAGO. iLLihotS 60w TELEPHONE 312 558 7500

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• WASHIN GTON OFFICE lER1ruEON"EE '''''

WILUAM G BEALE. 1885 1923 t r: " = ~ & ~ "' ' " 'sI S o " *

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July 18, 1985 VIA FEDERAL EXPRESS Lawrence Brenner, Esq., Chairman Dr. Richard F. Cole Administrative Law Judge Administrative Law Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory ' U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. A. Dixon Callihan Administrative Law Judge 102 Oak Lane Oak Ridge, TN 37830 Re: In the Matter of Commonwealth Edison Company (Braidwood Nuclear Power Station, Units 1 and 2 Docket Nos. 50-456 and 50-457) O/

Gentlemen:

I am enclosing Commonwealth Edison Company's Opposition to Admission of Intimidation and Harassment Issues. This constitutes Applicant's response to the Motion to Admit Claims of Intimidation and Harassment of Comstock Quality Control (QC) Inspectors and Motion for Protective Order of Intervenors' Rorem et al., dated July 12, 1985.

Under the Licensing Board's Order of June 21, 1985, Applicant was required to respond by a received date of July 19, 1985.

Intervenors subsequently filed a " Supplement" to their motions. This document was received by Mr. Miller of our office yesterday, July 17, 1985. I received a copy of it this morning. Mr. Gallo did not receive a copy from Intervenors, but he received one by telecopy from me today.

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I 8507230549 850718 PDR

• ADOCK 05000456 Ds03

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p U July.18, 1985 Page Two Mr. Gallo and-I have been responsible for preparing ~ Applicant's response to-Intervenors' motions. We have not as yet had time to evaluate Intervenors' later document. We vill do so promptly. The Applicant's response enclosed herewith, however, is limited to Intervenors' motions of July 12, 1985.

Very truly yours, ISHAM, LINCOLN & BEALE BY Peter Thornton Attorneys for COMMONWEALTH EDISON COMPANY PT:ljn Enclosures cc: All Parties s

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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) Docket Nos. 50-456 COMMONWEALTH EDISON COMPANY ) 50-457

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(Braidwood Nuclear Power )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of APPLICANT'S OPPOSITION TO ADMISSION OF INTIMIDATION AND HARASSMENT ISSUES were served on the persons listed below and identified with an asterisk by Federal Express, except that Mr. Cassel will be served by hand delivery the following day, and the remaining persons listed below by depositing same in the United States mail, first-class postage prepaid, this 18th day of July , 1985.

Lawrence Brenner, Esq. j{ Myron Karman, Esq.

yd( Chairman Elaine I. Chan, Esq.

Administrative Law Judge Office of the Executive Legal Atomic Safety and Licensing Director Board United States Nuclear Regulatory United States Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing i Dr. Richard F. Cole Board Panel Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, DC 20555 United States Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Board Panel United States Nuclear Regulatory Dr. A. Dixon Callihan Commission q{AdministrativeLawJudge Washington, DC 20555 102 Oak Lane Oak Ridge, TN 37830 c.

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=4 Robert Guild Mr. William L. Clements Douglass W. Cassel, Jr.

Chief, Docketing and Services Timothy W. Wright, III United States Nuclear Regulatory BPI Commission 109 North Dearborn Street Office of the Secretary Suite 1300 Washington, DC 20555 Chicago, IL 60602 C. Allen Bock, Esq. Ms. Lorraine Creek P.O. Box 342 Route 1 Urbana, IL 61801 Box 182 Manteno, IL 60950 Ms. Bridget Little Rorem 117 North Linden Street Charles Jones, Director P.O. Box 208 Illinois Emergency Services Essex, IL 60935 and Disaster Agency 110 East Adams

• Springfield, IL 62705 PETER THORNTON One of the Attorneys for COMMONWEALTH EDISON COMPANY Joseph Gallo Victor G. Copeland ISHAM, LINCOLM & BEALE 1120 Connecticut Avenue, N.W.

Suite 840 Washington, D.C. 20036 (202) 833-9730 Peter Thornton Rebecca J. Lauer i ISHAM, LINCOLN & BEALE Three First National Plaza Chicago, Illinois 60602 (312) 558-7500  !

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