ML20136C507

Answer in Support of Bn Farms 790322 Petition to Intervene. Parties Have Negotiated Relevant Contentions But Efforts Should Continue to Sharpen Issues.Certificate of Svc Encl

ML20136C507
Person / Time
Site:	Braidwood
Issue date:	08/20/1979
From:	Karman M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 7909260056
Download: ML20136C507 (4)

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kids UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 8/20/79

, g BEFORE THE ATOMIC SAFETY AtlD LICEllSIfiG BOARD In the Matter of ) 3

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) Docket Nos. 50-456 COMMONWEALTH EDISON COMPANY -

) 50-457

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(Braidwood Station, Units 1 and 2) )

.L]Ord$f i ANSWER OF NRC STAFF TO AMENDED PETITION OF B0B NEINER FARMS, INC. ET AL The petitioners herein have submitted an amended petition for leave to intervene in accordance with the order of this Board, dated March 22, 1979. The Staff, Applicant and petitioner have met on several occasions to negotiate contentions which would be relevant to the Braidwood prcceeding. The Staff, Applicant and petitioner have met on several occasions in Illinois to negotiate contentions which would be relevant to the Braidwood proceeding.

The Staff is of the view that petitioners have filed a petition which has included within it the bases for one or more contentions which should be admitted as issues

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in the proceeding. Example of such contentions are Contention 1 - transmission lines; Conta tion 3 - emergency plans; Contention 6 - chemical and radiological discharges; Contention 7 - recreational facilities; Contention 9 - Farm data; Contention 10 - radiation exposure; Contention 11 - dike failure: There are other contentions which may be admissible in the proceeding, but at the present time are.too vague and non-specific to allow proper response to them.

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.The Staff urges the Board that at the special prehearing conference to be held in Joliet, Illinois on August 23, 1979, Bob fleiner Farms Inc. et al be admitted as intervenors in this proceeding. In light of the cooperative effort by all parties to sharpen the issues, it is suggested that the Board authorize

! the parties to continue such efforts so that within an agreed to period of time a further amended set of contentions can be submitted. This procedure will expedite discovery and prevent undue delay in the processing of this litigation.

Respectfully submittep,

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'*tAmmq i Myrorf Karman ,

Coudsel for NRC Staff 4

Dated at Bethesda, Maryland this 20th day of August, 1979.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0l'a'IISSION

. 1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

In the Matter of )

) Docket Nos. 50-456

, COMMONWEALTH EDISON COMPANY ) 50-457

)

(Braidwood Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " ANSWER OF NRC STAFF TO AMENDED PETITION OF B0B NEINER-FARMS, INC. ET AL", in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory' Commission's internal mail system, this 20th day of August,1979:

• Marshall E. Miller, Esq., Chaircan

• Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4

Washington, D.C. 20555 *

.* Atomic Safety and Licensing Dr. A. Dixon Callihan Appeal. Board Panel -

Union Carbide Corporation , U.S. Nuclear Regulatory Commission P. O. Box Y . Washington, D.C. 20555 Oak Ridge, Tennessee 37830 .

• Docketing and Service Section Dr. Richard F. Cole Office of the Secretary of the Atomic Safety and Licensing Board Panel Co'mmission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555- Washington, D.C. 20555 Paul M. Murphy Esq. Ms. Bridget Little Rorem .

Isham, Lincoln,& Beale Braidwood Area Co-ordinator One First National Plaza Bailly Alliance-Illinois Chicago, Illinois 60603 Braidwood, Illinois 60408

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. i C. Allen Bock, Esq.

P. O. Box 342 Urbana, Illinois 61801 Thomas J. Gordon, Esq.

WAALER, EVAtl5 & GORDON 2503 S. Neil Champaign, Illinois 61820 Ns. Marty Westerman Route 1, Box 279 St. Anne, Illinois 60964 Wa /J, J..

/ Richard J/G6ddard Counsel {orNRCStaff b

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