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Category:INTERVENTION PETITIONS
MONTHYEARML20199E2221986-03-21021 March 1986 Response to Bl Rorem 860124 Motion to Compel Discovery for Third Set of QA Interrogatories & Request to Produce.Motion Should Be Denied & Protective Order to Interrogatories Granted.Certificate of Svc Encl.Related Correspondence ML20138A3291986-03-0505 March 1986 Application for Subpoena to Require Presence & Testimony of D Dvorak on 860311 in Joliet,Il.Related Correspondence ML20138A1521986-03-0505 March 1986 Response to NRC 860218 Filing,Supporting Applicant Motion for Summary Disposition.Applicant Motion Should Be Denied. W/Certificate of Svc ML20137F2711986-01-11011 January 1986 Petition of Bl Rorem Et Al for Leave to Intervene & Request for Hearing.Hearing on QA Issues Commences on 860520. Certificate of Svc Encl ML20138P7321985-12-20020 December 1985 Response to Rorem QA Contentions 3.C,5,6.F,6.G,6.I,9.A (partial),9.C,9.D,10.F,12.E,12.F,12.J,13.B & 14.B ML20132B2621985-07-18018 July 1985 Response in Opposition to Util Motion for Directed Certification.Motion Considered Interlocutory Appeal of ASLB 850621 Memorandum & Order Admitting Rorem Amended QA Contention.Certificate of Svc Encl ML20129K1001985-06-18018 June 1985 Response Re Documents & Names of Potential Witnesses Concerning Emergency Planning Contention.Certificate of Svc Encl ML20094H5371984-08-0909 August 1984 Response to Neiner Farms 840705 Status Rept Re Contention 4 Concerning Transport of Hazardous Matl Near Facility. Intervenor Offers No New Substantial Info.Contention 4 Should Be Dismissed ML20090A6881984-07-0505 July 1984 Status of Contention & Proposed Revs & Amends.Certificate of Svc Encl 1986-03-05
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20199E2221986-03-21021 March 1986 Response to Bl Rorem 860124 Motion to Compel Discovery for Third Set of QA Interrogatories & Request to Produce.Motion Should Be Denied & Protective Order to Interrogatories Granted.Certificate of Svc Encl.Related Correspondence ML20138A3291986-03-0505 March 1986 Application for Subpoena to Require Presence & Testimony of D Dvorak on 860311 in Joliet,Il.Related Correspondence ML20138A1521986-03-0505 March 1986 Response to NRC 860218 Filing,Supporting Applicant Motion for Summary Disposition.Applicant Motion Should Be Denied. W/Certificate of Svc ML20137F2711986-01-11011 January 1986 Petition of Bl Rorem Et Al for Leave to Intervene & Request for Hearing.Hearing on QA Issues Commences on 860520. Certificate of Svc Encl ML20138P7321985-12-20020 December 1985 Response to Rorem QA Contentions 3.C,5,6.F,6.G,6.I,9.A (partial),9.C,9.D,10.F,12.E,12.F,12.J,13.B & 14.B ML20132B2621985-07-18018 July 1985 Response in Opposition to Util Motion for Directed Certification.Motion Considered Interlocutory Appeal of ASLB 850621 Memorandum & Order Admitting Rorem Amended QA Contention.Certificate of Svc Encl ML20129K1001985-06-18018 June 1985 Response Re Documents & Names of Potential Witnesses Concerning Emergency Planning Contention.Certificate of Svc Encl ML20094H5371984-08-0909 August 1984 Response to Neiner Farms 840705 Status Rept Re Contention 4 Concerning Transport of Hazardous Matl Near Facility. Intervenor Offers No New Substantial Info.Contention 4 Should Be Dismissed ML20090A6881984-07-0505 July 1984 Status of Contention & Proposed Revs & Amends.Certificate of Svc Encl 1986-03-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20149H0301997-06-19019 June 1997 Comment Opposing Proposed Generic Communications Re Control Rod Insertion Problems ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20204G3081988-10-19019 October 1988 Order Imposing Civil Monetary Penalty in Amount of $50,000, Per 880506 Notice of Violation from Insp on 880301-17 ML20154K0301988-05-20020 May 1988 Transcript of 880520 Dicussion/Possible Vote in Rockville,Md Re Full Power OL for Facility.Pp 1-70.Related Info Encl ML20148G2161988-03-25025 March 1988 Decision.* Affirms Concluding Partial Initial Decision, LBP-87-14,25 NRC 461.Served on 880325 ML20149D8231988-02-0101 February 1988 Notice of Withdrawal.* Withdraws Appearance as Atty for Util in Proceeding,Effective 880201.Certificate of Svc Encl ML20236A8341987-10-21021 October 1987 Transcript of 871021 Proceedings in Bethesda,Md.Pp 1-100 ML20235K8741987-09-30030 September 1987 Notice of Oral Argument.* Oral Argument on Pending Appeal of Intervenors Bridget Little Rorem from Board 870519 Concluding Partial Initial Decision in Proceeding Will Be Heard on 871021.Served on 871002 ML20235H7121987-09-25025 September 1987 Memorandum & Order.* Intervenor Appeal from ASLB Rejection of late-filed Contention Dismissed & LBP-87-19 & LBP-87-22 Vacated on Grounds of Mootness Due to Util Withdrawing Amend Application.Served on 870928 ML20237L7461987-09-0303 September 1987 Order.* Oral Argument on Pending Appeal of Intervenors Bl Rorem Et Al from Licensing Board 870519 Concluding Partial Initial Decision in OL Proceeding Will Be Heard on 871021 in NRC Public Hearing Room.Served on 870903 ML20237L7721987-09-0101 September 1987 Reconstitution of Aslab.* Notice That Aslab Has Been Reconstituted for OL Proceeding.Board Will Consist of as Rosenthal,Wr Johnson & Ha Wilber.Served on 870902 ML20237L6931987-08-28028 August 1987 Decision.* Review of Licensing Board 870513 & 0706 Partial Initial Decisions Revealed No Error Necessitating Corrective Action.Result Reached by Licensing Board Re Decision LBP-87-13 Affirmed.Served on 870831 ML20237K0361987-08-11011 August 1987 NRC Staff Brief in Support of LBP-87-14.* Certificate of Svc Encl ML20236P1101987-07-31031 July 1987 Brief of Comm Ed.* Brief Filed Re Appeal by Bridget Little Rorem,Et Al from ASLB 870519 Concluding Partial Initial Decision.Appeal Shoud Be Denied & Decision Affirmed. Certificate of Svc Encl ML20236N9791987-07-31031 July 1987 NRC Staff Response to Aslab Order of 870721.* NRC Supports Deferral of Briefing of Intervenors Appeal Until Applicant Affirmation Re Withdrawal of License Amend Application Received.Bc Hunsader Encl.W/Certificate of Svc ML20236N8851987-07-31031 July 1987 Response to Intervenors Request for Deferral of Further Appellate Proceedings.* Forwards Util to NRC Withdrawing License Amend Applications Re Ownership.Pending Appeal Should Be Dismissed.Certificate of Svc Encl ML20235Y8711987-07-23023 July 1987 Appeal from Licensing Board Denial of Motion to Reopen Record.* Intervenors Rorem Appeal from Decision of Licensing Board of 870706 Denying Rorem Motion to Reopen Record for Purpose of Admitting Late Contention.W/Certificate of Svc ML20235Y9081987-07-21021 July 1987 Order.* Date for Filing Briefs Re Intervenor Appeal of Board 870706 Memorandum & Order Denying Motion for Reconsideration & Motion to Admit late-filed Contention Postponed Until Further Order by Board.Served on 870722 ML20234D0521987-07-0202 July 1987 Motion to Reopen Record to Admit late-filed Contention on Financial Qualifications.* Record Should Be Reopened Since Rule Barring case-by-case Financial Qualification Adjudication Not Applicable ML20235D6761987-07-0202 July 1987 Order.* Intervenors 870623 Motion That ASLB Reconsider 870610 Memorandum & Order Denying 870506 Motion to Reopen Record & 870701 Motion to Admit late-filed Contention Denied.Motion in Alternative Dismissed.Served on 870707 ML20234D0961987-07-0101 July 1987 Affidavit of DW Cassel.* Affidavit Re Intervenors Rorem,Et Al Motion to Reopen Record to Admit Late Filed Contention on Financial Qualification.Related Info Encl.W/Certificate of Svc & Svc List ML20216J8821987-07-0101 July 1987 Motion in Alternative Before Appeal Board.* Intervenors Hold That Jurisdiction Over 870701 Motion to Reopen Record to Admit Late Filed Contention on Financial Qualifications Remains W/Aslb.W/Svc List & Certificate of Svc ML20234D0361987-07-0101 July 1987 Opening Brief of intervenors-appellants Bridget Little Rorem,Et Al.* Board Majority Committed Errors of Fact & Law That Compel Reversal of 870519 Concluding Partial Initial Decision.Certificate of Svc Encl CLI-87-07, Order CLI-87-07.* ASLB Concluding Partial Initial Decision, Resolving All Contested Issues & Authorizing NRR to Issue Ol,Reviewed by Commission & Effective Immediately.Separate Views of Commissioner Asselstine Encl.Served on 8707011987-06-30030 June 1987 Order CLI-87-07.* ASLB Concluding Partial Initial Decision, Resolving All Contested Issues & Authorizing NRR to Issue Ol,Reviewed by Commission & Effective Immediately.Separate Views of Commissioner Asselstine Encl.Served on 870701 ML20235A7271987-06-30030 June 1987 Transcript of 870630 Discussion/Possible Vote in Washington, DC Re Full Power OL for Facility.Pp 1-70.Supporting Documentation Encl ML20216D1941987-06-22022 June 1987 Order.* Amend to 861107 Protective Order Which Resolved Dispute Between ASLB & Commission Ofc of Investigation Over Disclosure of Certain Investigatory Matls.Certificate of Svc Encl.Served on 870623 ML20215J8891987-06-19019 June 1987 Applicant Texas Utils Electric Co Petition for Directed Certification of Licensing Board Order of 870312.* Brief Supports Granting Petition to Vacate ASLB 870312 Order. Supporting Documentation & Certificate of Svc Encl ML20215D9241987-06-15015 June 1987 Memorandum on Licensing Board Jurisdiction.* Jurisdiction Over Intervenors 870506 Motion Retained Until Further Action of Licensing Board Due to Util 870528 Filing of Application for Amend to Ol.Served on 870616 ML20214W9601987-06-12012 June 1987 Transcript of 870612 Telcon in Washington,Dc.Pp 18,585- 18,596 ML20214W5031987-06-10010 June 1987 Memorandum & Order (Denying Intervenors Motion to Admit late-filed Contentions on Financial Qualifications).* Rorem, Et Al 870506 Motion Re Financial Qualifications of New co- Licensees Denied for Want of Jurisdiction.Served on 870611 ML20214W5491987-06-0909 June 1987 Notice of Reconstitution of Board.* Iw Smith,Chairman & Rf Cole & AD Callihan,Members.Served on 870610 ML20214W4911987-06-0909 June 1987 Order.* ASLB 870513 Partial Initial Decision Addressing Emergency Planning Issues Will Be Reviewed Sua Sponte & Will Not Be Deemed Final Until Further Order.No Appeal from Decision Received ML20214P0811987-06-0101 June 1987 Notice of Appeal.* Intervenor Bl Rorem,By Attys & in Accordance w/10CFR2.762,appeal ASLB 870519 Concluding Partial Initial Decision Re Plant Which Served on Parties on 870521.Notice of Appearance & Certificate of Svc Encl ML20214N0521987-05-28028 May 1987 Affidavit of Mj Wallace.* Affidavit of Mj Wallace Re Startup & Initial Criticality of Unit 1.W/Certificate of Svc ML20214N0471987-05-28028 May 1987 Affidavit of Jc Bukovski.* Affidavit of Jc Bukovski Re Delay in Startup,Testing & Commercial Operation of Unit 1 ML20214N0421987-05-28028 May 1987 Commonwealth Edison Co Comments to Commission on Immediate Effectiveness Issues.* Forwards Affidavits of Mj Wallace & Jc Bukovski.Requests Opportunity to Be Heard If Commission Contemplates Such Stay ML20214N4321987-05-26026 May 1987 NRC Staff Response to Motion to Admit late-filed Contention on Financial Qualifications.* Board Must Deny Motion to Admit late-filed Contention & Deny Request to Certify Question of Waiver to Commission.W/Certificate of Svc ML20214N3901987-05-22022 May 1987 Amend to Concluding Partial Initial Decision.* Amends 870519 Concluding Initial Decision to Delete Limited Authorization Granted NRR to Issue License for Low Power Testing,Due to Issuance of LBP-87-13 on 870513.Served on 870526 ML20214N0631987-05-19019 May 1987 Errata Correction.* Requests Pen & Ink Corrections to Minority Decision Pages Forwarded as Corrected Pages to Errata .Pages 73,74 & 75 Should Be Numbered as Pages 72,73 & 74,respectively.Served on 870529 ML20214N0851987-05-19019 May 1987 Errata.* Forwards Corrected Pages to Minority Opinion, Matters of Dissent.Served on 870528 ML20214G5141987-05-19019 May 1987 Response to Intervenor Motion Seeking to Reopen Record for Admission of New Contention.* Intervenor Filed Motion, Motion to Admit Late Filed Contention on Financial Qualifications. Affidavit & Certificate of Svc Encl ML20214N3431987-05-19019 May 1987 Errata to Concluding Partial Initial Decision (Ol).* Minor Editoral Corrections Listed.Served on 870528 ML20214G5921987-05-19019 May 1987 Concluding Partial Initial Decision (Ol).* Due to Violation Re Discouragement to Document Any Major Deficiency That Could Result in Lengthy Delay in Production,Civil Penalty Should Be Imposed on Comstock & Util.Served on 870521 ML20214G8701987-05-18018 May 1987 Notice of Reconstitution of Aslab.Gj Edles Chairman & WR Johnson & CN Kohl Members.Served on 870520 ML20213F9971987-05-13013 May 1987 Partial Initial Decision on Emergency Planning Issues.* ASLB Resolves All Outstanding Issues Re Offsite Emergency Favorably to Applicant Subj to Certain Info Being Included in Next Emergency Info Booklet.Served on 870514 ML20215K9991987-05-0606 May 1987 Motion to Admit late-filed Contention on Financial Qualifications.* Contention Based on Util 870406 Filing Re New Ownership & Financing for Facility.Affidavit & Certificate of Svc Encl ML20214F1991987-04-22022 April 1987 Applicant Exhibit A-188,consisting of Admitting Exhibit.Util Re General Ofc Records Audit,Lk Comstock Engineering Co,Inc 830110 Memo Re Audit Responses & 821101 General Insp Rept Re Torque Wrench Test Record Encl 1999-03-02
[Table view] |
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'[7d9 July 18, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EKED BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD S
In the Matter of: )
N 22 Ali:03 r
y Da p' COMMONWEALTH EDISON COMPANY ) B f ERv#ff
) Docket Nos. 50 6bb (Braidwood Nuclear Power ) 50 457 o L_,
- Station, Units 1 and 2) )
RESPONSE OF INTERVENORS BRIDGET LITTLE ROREM, ET AL. .
IN OPPOSITION TO COMMONWEALTH EDISON COMPANY'S MOTION FOR DIRECTED CERTIFICATION i
Interv'enors Bridget Little Rorem, et al., by their under-signed counsel, hereby respond in opposition to Applicant Commonwealth Edison Company's July 8,1985, Motion For Directed Certification.
Applicant's Motion For Directed Certification should be denied. In substance, Applicant seeks merely to challenge by impermissible interlocutory appeal the Licensing Board's June 21, 1985, Memorandum and Order Admitting Rorem et al. Amended Qua:ity Assurance Contention. Such an interlocutory appeal - from an order admitting a contention - is barred by 10 CFR $$2.714(a) and 2.730(f).
?!oreover, to the limited extent that Applicant's Motion seeks any relief other than its effort to oust an admitted ,
contention, the Motion is neither timely nor supported by grounds sufficient to warrant directed certification.
I 8507230555 850718 gDR ADOCK 05000456 PDR
In'its Motion at page 1, Applicant characterizes the pur-ported subject of directed certification as "the procedures adopted by the Atomic Safety and Licensing Board in this proceed-ing that led to the admission of the quality assurance contention of Intervenors Bridget Little Rorem, e t a l ." While Applicant disclaims any interest in the Licensing Board's " basis and speci-ficity" or late-filing-factor " balancing" decisions leading to the admission of Intervenors' QA contention, the true target of Applicant's attack appears in its requested relief which sweeps broadly to include "vacat[ing] the order of June 21, 1985 [ admit-ting Intervenors' amended QA contention] and instruct [ing] the' Licensing Board to dismiss Intervenors' amended quality assurance contention." Motion at p. 2.
As expressly provided by Commission Rules of Practice, 10 CFR $2.714(a), , interlocutory appeals from Licensing Board decisions admitting or excluding contentions are permissible only under the limited circumstances, not present here, where the decision could have the effect of entirely excluding the inter-venor from the proceeding. See, South Carolina Electric & Gas Company (Virgil C. Summer Nuclear Station, Unit 1), ALAB-642, 13 NRC 881, 884 FN. 3 (1981); Houston Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1), ALAB-585, 11 NRC 469, 470 (1980); Gulf States Utilities Company (River Bend Station, Units 1 and 2), ALAB-329, 3 NRC 607, 610 (1976) ("As we have previously held, Section 2.714a excepts from the general prohibition against interlocutory appeal only those orders which are directly concerned with the grant or denial of status as an 4
2
i nter ven or." Id.) A challenge limited to the admission or exclusion of some but not all contentions, such as that attempted by Applicant here, is impermissible. Even in a case where, ,
unlike here, the appeal is " meritorious," it is nonetheless
" premature, i .e . , its assertion to us must await the rendition of an inicial decision." River Bend, supra, 3 NRC at 611. As noted in Virgil C. Summer, supra, no appeal by Intervenors from the Licensing Board's June 21, 1985, decision rejecting aspects of Intervenors' quality assurance claims could be prosecuted at this time. Intervenors must await the rendition of the Licensing Board's initial decision to press any interlocutory complaints we may have. This prohibition against interlocutory appeals applies with equal force to bar Edison's complaints here.
What, then, remains of Edison's request for the extraordinary device of directed certification? Excluding the impermissible subject of contention admissibility, Applicant has left only the much narrower question regarding the propriety of the Licensing Board's April 17, 1985, Special Prehearing Conference Order per-mitting Intervenors to depose the NRC Region III Administrator, James G. Keppler. At that time, the Board authorized Intervenors to take Mr. Keppler's deposition in order to identify the
" serious quality assurance questions at Braidwood" to which he had alluded in earlier sworn testimony. April 17, 1985, order at
- p. 36.
The Board explained why it saw such a device as necessary under these unusual circumstances:
3
The Board's own concern with the QA/QC matters here, together with the importance of Mr.
Keppler's testimony and the position he holds at the NRC, and the apparent lack of other means available to Intervenors to more specifically explain this portion of their proposed conten-tion, encourages us to view Mr. Keppler's deposition as imperative if an important part of Intervenors' QA/QC allegations are to be adequately composed and addressed.
April 17 Order at 38-39 The ruling, then, setting forth the procedure from which Edison only now see!<s appellate review, was issued April 17, 1985. Intervenors (and the NRC Staff and Applicant) took Mr.
Keppler's deposition May 20, 1985. Indeed, Applicant fully participated in the Keppler deposition, which was reconvened on May 24, 1985, in order that Applicant could question Mr. Keppler in detail regarding his knowledge of QA problems at Braidwood.
Although Applicant had previously moved for reconsideration of the April 17 Order, and in its motion had asked the Licensing Board, in the event it ruled against Applicant, to refer its ruling to the Commission, Applicant made no effort to bring its objection to the deposition before the Appeal Board during the month-long period between issuance of the April 17 Order and the May 20 deposition. It was during this period that effective relief was available to-prevent the deposition of which Applicant now purportedly complains. Yet Applicant proceeded to partici-pate in the deposition, even though the Licensing Board had informed Applicant, in a conference call ten days prior to the deposition, that the Board did not intend to rule on Applicant's request for reconsideration until after the deposition.
4
- -e Before pressing any appellate complaint whatever, Applicant chose not only to await the results of the deposition in which it hac ga'ticipated fully but, further, to await both the subsequent subm'ission of Intervenors' amended quality assurance contention and, finally, the Licensing Board's June 21, 1985, Order admit-ting the amended contention. Applicant simply chose to bide its time until it knew of the Licensing Board's ultimate decision on contention admissibility. Finally, not until an additional 17 days later did Applicant file its appellate motion supposedly to avert the Licensing Board from its " collision course" with the Commission regulations it ostensibly had long since transgressed.
Motion at p. 7.
In sum, to the extent Applicant seeks interlocutory review of the May 20-24 deposition rather than of the admission of Intervenors' Q.^. contention, Applicant's Motion is untimely in the extreme and should not be entertained.
Even if Applicant had timely sought relief on a matter permitted to be the subject of interlocutory appeal, its Motion fails to satisfy the traditional stringent standards for direct-ing certification set out in Public Service Company of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-405, 5 NRC 1190 (1977), Motion, p. 7 Applicant claims no legally cognizable irreparable harm from the Board's deposition ruling, and argues only weakly that the Board's ruling so departs "from the normal course" as to pervasively affect the basic structure of the proceeding. Motion at p. 14.
Applicant's principal argument is rather that the extra-5
ordinary ~ device it invokes and relief it seeks is necessary "to settle a legal point of general applicability" in order to pro-vide guidance for other Boards in future cases. Motion at p. 8.
Such a claim is pure hyperbole.
Wisely, this Appeal Board has eschewed the rendering of
" essentially advisory" opinions, particularly on narrowly fact-dependent issues which are not of " demonstrably recurring importance." Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-743,18 NRC 387, 390 FN. 3 (1983).
The unique and special factual circumstances which prompted the Licensing Board action complained of here provide far too narrow a foundation for general policy guidance to be applied in recurring circumstances.
Since the Keppler deposition complained of by Applicant has already been taken, an opinion on its propriety would be only
" essentially advisory" in character. Moreover, subsequent procedural developments in this very case underscore the unlikelihood of these unusual facts possessing " demonstrably recurring importance." On two later occasions this same Licensing Board has rejected requests by Intervenors for further use of the deposition device to obtain factual information needed to further specify our QA contention. As described in Intervenors' May - 24, 1985, Motion To Admit Amended QA Contention, pp. 13-14, Intervenors sought and were refused Board permission to depose other NRC Staff persons who were knowledgeable about Braidwood QA problems. Again, on July 11, 1985, in an on-the-record telephone conference call Intervenors sought the 6 I i
m opportunity to take the deposition of an NRC Staff member on Lhe subject of QC inspector harassment in order to further specify a portion of our QA contention now pending before the Board. This request was likewise refused by the Board, which reiterated the unique circumstances under which it had permitted the earlier Keppler deposition. .
The circumstances underlying the April 17 Order are clearly so narrow that they are demonstrably unlikely to recur even in this particular case, let alone affording a sufficient basis for an extraordinary decision by this Appeal Board to enunciate guidance of general and recurring importance.
CONCLUSION For the foregoing reasons, Intervenors Bridget Little Rorem, et al., respectfully request that Commonwealth Edison Company's Motion For Directed Certification be denied.
July 18, 1985 Respectfully submitted, Robert Guild Douglass W. Cassel, Jr.
Attorneys for Intervenors Rorem, et al.
/
ouglass W. Cassel, Jr.
Robert Guild s
/ (
Timothy W. Wright, III /'By: Robert Guild (/
109 North Dearborn Suite 1300 Chicago, Illinois 60602 (312) 641-5570 7
l l
- _r a 4
- 7/18/85 UNITED STATES OF AMERICA, NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket No. 50 456
) 50-457 (Braidwood Nuclear Power )
Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that I have served copies of Response of Intervenors Bridget Little Rorem, et al. In Opposition To Co.3monwealth Edison Company's Motion For Directed Certification on all parties to this proceeding as listed 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, 60602, this 18th day of J ul y , 198 5.
M k
~
l l
i l
l i
. .# . *y.
BRAIDWOOD SERVICE LIST Gary J. Edles, Chairman Michael I. Miller, Esq.
and Administrative Judge Peter Thornton, Esq.
Atomic Safety and Licensing Isham, Lincoln & Beale Appeal Board Three First National ~ Plaza U.S. Nuclear Regulatory Commission Chicago, Illinois 60602 Washington D.C. 20555 Docketing & Service Section Thomas S. Moore Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board Washington D.C. 20555 U.S. Nuclear Regulatory Commission ,
Washington D.C. '20555 Rebecca J. Lauer, Esq.
Isham, Lincoln & Beale Dr. Reginald L. Gotchy Three First National Plaza Administrative Judge Chicago, Illinois 60602 Atomic Safety and Licensing Appeal Board .
Bridget Little Rorem U.S.-Nuclear Regulatory Commission 117 North Linden Street Washington D.C. -20555 Essex, Illinois 60935 Lawrence Brenner, Esq. C. Allen Bock, Esq.
Chairman and Administrative Judge P.O. Box 342 Atomic Safety and Licensing Board Urbana,' Illinois 61801 U.S. Nuclear Regulatory Commission Washington D.C. '20555 Thomas J. Gordon, Esq.
Waller, Evans & Gordon Dr. Richard F. Cole 2503 South Neil Administrative Judge Champaign, Illinois 61820 Atomic Safety and Licensing Board
- U.S. Nuclear Regulatory Commission Lorraine Creek Washington D.C. 20555 Route 1, Box 182 Manteno, Illinois 60950 Dr. A. Dixon Callihan Administrative Judge Region III 102 Oak Lane Office of Inspection &
Oak Ridge, Tennessee 37830 Enforcement U.S. Nuclear Regulatory Elaine Chan, Esq. Commission NRC Staff Counsel 799 Roosevelt Road U.S. Nuclear Regulatory Commission Glen Ellyn, Illinois 60137 7335 Old Georgetown Road Bethesda, Macyland 20014 Atomic Safety and Licensing Board Panel Joseph Gallo, Esq. U.S. Nuclear Regulatory Isham Lincoln & Beale Commission 1120 Connecticut Avenue N.W. Washington D.C. 20555 Suite 840 Washington D.C. 20036 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington D.C. 20555 1