ML20137J125

Affidavit of Ld Butterfield Re Respiratory Protection. Statement Re Use of Handkerchief Deleted from Emergency Planning Brochures Due to Technical Inappropriateness. Certificate of Svc Encl.Related Correspondence

ML20137J125
Person / Time
Site:	Braidwood
Issue date:	01/10/1986
From:	Butterfield L COMMONWEALTH EDISON CO.
To:
Shared Package
ML20137J117	List: ML20137J114 ML20137J125
References
OL, NUDOCS 8601220260
Download: ML20137J125 (15)

Text

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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 4

(Braidwood Station, Units 1 and 2) )

AFFIDAVIT OF LAWRENCE D. BUTTERFIELD, JR.

(Concerning Respiratory Protection)

I I, Lawrence D. Butterfield, Jr., being first duly

sworn, hereby depose and state:

1. I am employed by Commonwealth Edison Company (" CECO")

4 as Manager of the Nuclear Services Technical Department.

4 I have been employed by CECO in that position since June 1984. As Manager of the Nuclear Services Technical Department, I am responsible, among other things, for the Emergency Planning Section. That Section is responsible for the development, maintenance and modification of the Company's on-site emergency l plans for its nuclear power plants, and for the development i

of plans and schedules for the emergency planning drills with State and local government agencies. The Section also t works with State and local agencies to develop, modify and implement their emergency plans. The Emergency Planning Section's activiti !nclude day-to-day contact with state and local officials as well as individuals residing in the

! plume exposure pathway Emergency Planning Zones ("EPZ")

surrounding the company's nuclear power reactors.

4 8601220260 860121 i PDR ADOCK 05000456 o pm i

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2. I have been involved in emergency planning for nuclear power plans for at least the last six years. The Company's employees are trained for and perform special assignments in the event of an emergency at a nuclear power plant. I have received training for various positions, including Technical Support Manager, Engineering Director, and Intelligence Director. I have also participated in at least one drill / exercise a year for about the last six years, and I have been a controller at other exercises.

3. I have been with Commonwealth Edison about nineteen years. During that time, I have had assignments at Dresden Station as Administrative Assistant to the Superintendent, a Supervisor of Engineering Analysis in the Nuclear Fuel Services Department, an Engineer in the Nuclear Licensing Department, and a Section Engineer in the Station Nuclear Engineering Department. I have a Bachelor's Degree in Electrical Engineering and a Master's Degree in Nuclear Engineering, both from the University of Florida. I am also a Registered Professional Engineer in the State of Illinois.

4. The purpose of this Affidavit is to address a question raised by the Atomic Safety and Licensing Board during the emergency planning hearings held in October 1985.

During those hearings, it was noted that previous emergency planning brochures prepared by CECO for certain of its other nuclear power plants had contained the following statement:

If you must go outside, place a handkerchief or a protective mask over your nose and mouth. 1/

This statement was deleted from the brochure for the Braidwood Station. In light of this deletion, the Board requested CECO to provide information explaining "...why this particular provision was deleted from the current brochure when it appeared in the company's prior brochures." (Tr. at 562.) 2/

5. The respiratory protection statement quoted above first appeared in the emergency brochure issued for the Dresden nuclear power station in 1981. The language was subsequently included in the 1982 and 1983 revisions of that brochure, and was also included in the brochures for the Zion nuclear power station during the same time period.

In the fall of 1983, CECO distributed a reformatted brochure for Byron Station which, for the first time, deleted the respiratory protection statement. Neither the Byron brochure, nor the Braidwood brochure ever contained the above quoted statement. At the present time, none of the current CECO emergency planning brochures contain that statement. ,

i 1/ A copy of a previous version of the emergency brochure i

for the Zion Station is attached.

2/ Transcript citations are to the transcript of the emergency i planning hearings held in this proceeding on October 29, 1985. ,

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6. During the preparation of the Byron brochure in f 1983, CECO decided to eliminate the respiratory protection language from the brochures for a number of reasons. First, i

j placing a handkerchief or other covering over the mouth and nose is a meaningful precaution only in a small number of accident scenarios involving offsite particulate releases.

It provides no protection in the event of gaseous releases 1

resulting from a nuclear power plant accident. Second, the use of a handkerchief or other hand-held mask would provide only minimal protection even where particulates are released. During an emergency, it is highly unlikely i

i that persons, including children, responding to a shelter-in-place or evacuation announcement would be able continuously to hold a covering over their noses and mouths while taking other required protective actions. Third, attempting to hold a covering over the face during an evacuation could

hinder or impair a person's ability to take other necessary 1

actions, such as driving a car, or leading small children.

1 J

Finally, such an instruction might create a false sense

of security and could result in persons within the EPZ taking 4

) unnecessary risks or delaying evacuation.

7. On balance, CECO believes that the better practice is to give specific instructions regarding respiratory protection at the time of the accident. If particulates were released, j

I

offsite authorities could issue instructions at that time regarding the use of face coverings. Generally, however, evacuation would most likely be ordered prior to any radioactive release, thus eliminating the need for any such instructions.

8. At the time CECO decided to delete the respiratory protection statement in the fall of 1983, CECO's Emergency Planning Section was aware that the NRC Staff, in connection with the emergency brochure for Big Rock Point Plant, had concerns similar to those of CECO regarding respiratory protection. In that brochure, the Licensing Board had ordered the insertion of the following instruction:

"[i]f you are asked to evacuate, first put on a dust mask or breathe through a damp handkerchief to filter out any dust in the air."

Consumers Power Company, (Big Rock Point Plant), LBP-82-60, 16 NRC 540 (1982). Subsequently, NRC Region III ordered the deletion of the statement as technically inappropriate for reasons similar to those of Ceco. The Board was advised of the deletion on October 22, 1982. On September 25, 1984 the Licensing Board explained the NRC Staff's technical basis for the deletion:

Normally evacuation would be ordered as a precautionary measure some time before an actual release of radioactive material might occur. Wearing a dust l mask or holding a handkerchief over the nose would, Staff believes, tend to delay evacuation and might interfere with driving and create a safety hazard.

Respiratory protective measures should

be utilized only upon the specific direction o1 offsite authorities at the time of an accident; such directions would be issued if radiciodines or particulate material is released, and normally sheltering, rather than evacuation, would be ordered in that situation.

Based on these factors, the Board agreed that the provision had been properly deleted from the emergency brochure.

Consumers Power Company, (Big Rock Point Plant), LBP-84-38, 20 NRC 1019, 1024 (1984).

9. During the hearings held in October 1985, in this proceeding, Mr. Gorden Wenger, Emergency Planning Specialist, Technological Hazards Branch, Federal Emergency Management Agency (" FEMA") testified that the respiratory protection statement was not required to be included in the emergency brochure for Braidwood for reasons similar to those noted earlier as well as those approved by the Licensing Board in Big Rock Point Pl. ant. (Tr. at 539, 553-561.) Mr. Wenger concluded that the emergency information brochure was adequate nd met FEMA requirements. (Tr. at 552-553.) Recently, FEMA issued a " Policy Statement on Respiratory Protection" concurred in by the NRC Staff, in response to the Board's questions in this proceeding. In its Policy Statement, FEMA noted that the inclusion of specific language regarding respiratory protection is not mandated by NUREG-0654/ FEMA Rep. 1, Rev. 1, Section G.l.c., and that the exclusion of such language would not render a brochuro inadequate. Although,

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i as a general matter, FEMA recommends that brochures contain some language on respiratory protection, FEMA also recognizes that such language might be inconsistent with the policy i

I of local jurisdictions and thus should not be included in

! the brochures. '

'. i Protective actions information included 2

in the brochure, like all the information t in the brochure, is required to be a i 3

reflection of the public policy for i j protective actions. A jurisdiction might feel that a particular action is not acceptable. Thus requiring information within the brochure on protective actions j not intended for general use might confuse rather than inform.

1 i In the case of Braidwood, the State of Illinois has concluded I

that inclusion of instructions on respiratory protection, as a routine procedure, would tend to confuse rather than f inform the public. Instead, the State would prefer to provide instructions on respiratory protection to the extent needed, at the time conditions resulting from an emergency warranted such instructions.

10. I have been authorized to state that the Illinois I

Department of Nuclear Safety agrees with CECO's position

! regarding respiratory protection as set forth in paragraphs 6-9 l of this affidavit.

~.

l Lawlence D. Butierfield, Jr.

Subscribed and Sworn to before me this / M day of t

--M4J4A/)

i 1986.

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! m . s.- s - i j Aletatjy Pubp6 My Commission expires Mr [+ / 9A9

I I Zion Ctation l l

1 WhatTo Do  ;

In Case Of A Nuclear Station Emergency l l

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Shad ==- M ; 3 Protectiese la the event of an accident at a nucle.ar generating st.s-The purpne of this b mLlet is to tell you what to do in -

tion invoising a potentially dangeroin release of radia-case of a nuclear generating stathm emergency, although tion, the Illinois Pl.in few Radkilogical Accidents mill go unch an emergency n a sery scrnote pandbahty. But be- inno operation immediately.

cause it omld happen. we hase to be prepared. I or that When it doew it triggers a coordinated effort on the reaum, we think stiimportant that you not only under* part of the Ilknois Emergency Senices and Disnter stand the pl.an but also raduthm and how it alTects u'

. Agency. Commonwealth Ednon, the lilinois Depart-all. ment is Nuclear Safety, the Nuclear Regulatory Com-First. raduthm inimpl> cnergy which travels in the miwion the state of Wisconsin. other state agenciew form of particles av bundles called wases One kind gocal governments emergency workers the Amencan

cooks suir f =wl in micromase osens Another is the Red Crow and the Salvatkm Army. These groups hase i

s. ray. A thud, the radio w.ne. carries umnd. Yet a only one goal-to protect the public.

fourth,a wase is higher energy transmits TV picture'

! But radiatkm isn't just man-made. Iti a natural phe- That means no one shotdd be confused or misin-formed. The minute any emergency is declared the nomenon. too. all around uw all the time. It comes from Emergency Bro.edcast Splem uill also go into elTect.

the um the stars the soil beneath twar feet the air we breathe. the water we drink, the foisi we cat. the stone, All radio and televidon stathms in the area will continu-ally upd.ite the situathm and proside people w.th infor-beick or wissien walls that shcher uw een the potas- m.dion am how to protect themselses and their f.smilies num and cailwm in smr own IwwheC Special attention has been paid to the needs and cim-

{ To measure the amoimt of radiathm a person receises. cerns (4 peopic lising within a 10-mile radius of nuclear a unit called milhrem is used. In the northern llhnon power pl.ints in lilinois After a thorough study, the Nu-j area natural background r.eduthm results in an annual clear Regulatory Commiwion set 10 miles as the masi-

, radutam dine of lull millerem. Someone standing at a mum distance which ctmid require shelter tw evacuati(m miclear plant bsmndary for a year would receise an estra during an accident. This 10-mde radius is called the

, e r milbrem. An s-r. ) m.ny espine the atTected part of Emenyency Planning Zone and people within the ione the tw=ly to 75 millirem or more. will hase drens to notify them of an emergency.1he

To be sure, radation can be dangertms Hut that de- plant and emergency personnel within the 10-mile radius pends on the amtmnt we acceise. As you can see from practice the plan perieshcally.

{ the preceding p.aragraphs we're all espined to low

! lesels of raduskm escry day of our hses But because i

w e can't sec st. feel it, smell it, hear it or Iaste it iti W0nst To Do Asad Winese To Do it

! can to fear it. And panic can i e the mint penadse You'll be warned in sescral wayw just as you would be l d.inger in the cent of a nuclear stathm emergency- during a tornado alert: oser the radas telesision or Studies which tracLed people espsned to far mewe public-addrew system. by siren. oen by word of muuth.

4 r.aliathm than peopic norm.dly receise in the nswthern The signal for areas hasing sirens is a three to five min-Ilhnon area h. se Ismnd no eseew leukemia other can- . ute steady tone w hich means take shelter and turn on

, .;crw or genetic dam.sge due to low- les el raduthm. your r.nlan or telesson. i.ocal radio statkms are listed I his plan is deugned to present people from bemF. on page II.

esposed to I. :ge amoients of radutmn if a sesums acci- J If you didn't hear it on the radio or TV. though, be dent actiully occursed. Sheltering. or in estreme casc%

sure to tuin on one or the other as uwm as you can and esaceuthm windJ be recommended as needed to keep then stay tuned. Thefte your best umrces of reikible, r.aluthm esgsnure to the general public well below the up-to-the-minute infoimathm and instructiorn (trallic re-limits for nuclear plant uosLess of 5.t106) millirem- portw shelt er locations evacuation disections etc.L

% has all thn means is that we shouldn't p.inic at the fint warrung of a nuclear staskm accident. We shtudd Comrmmwealth Edium will Leep the medu up to date

( on the plant status and the Illinois Fmergency Services t.ike piecantams howeser sust as we wondd during a and Disnier Agency and the Wisconsin Disision of toin.edo. Os. in the c.nc of a chemical spill, w hen it\ Emergency Gosernment will update the medk: on rec-1 often necewas) to cwicuate an asca. ommended actions for the general public.

Iake un nung osher things ue lise wiih radiathm can I 14 Nos call Ihe pohce or sherilT or fine dep.uiment or be harmful. Hut tocated with cmthm and common sense. 5 anyone else unlew iti abudutely necewas y tand Ihen i 4 it needn't i e l~rightening. '

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liait Scar call to ame minute if you caxi. The pNme Do not try entering the evacualism area fa r any reaum lines hase to be kept open for use by emergency perum- whatun c:. If youie been asked to evacuate. do not nel. hoitate or waste time tr)ing to take all Simr pawsewions Finally. ie pimd piomptly to allinstructions. If you're with you. Instead:

asked to take shelter ind mis and remain there, do it quickly. Do not cacuate. If you're asked to evacuate 1. Gather Sour family together. If Simr children are in the area. get Samt family together pack quickly lsee "

scNiol and the schel is in an evacuation tone, do checklisti, plan your route, and leas e as wxm as pensi- not try to pick them up. They will be transported out ble. i of the. area to a safe location where you may go to get

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them. The same applies for nursing home residents Stayistg lendoors: "Sitelter-les-Place" and hospital patients.

A shelter-in-place annamncement means stay indiers' 2. Pack only cwential items (see checklist im page 9).

or get indiers. This is the miwt hkely protectise ae-tion. Esacuation is much lew hLely and in many cases 3. Turn off gas, electricity and water to the same extent alTords lew protection than shelter-in-place. If you're as if you wcre leasing for a week.

imiside at the time shelter is secommended. head for home immediatel) or. in a pinch. for.any place that'll 4. l.ock the windows and dixws.

take Soul. Wheiner you end up. shoirgh tesen if yois are in a cars. take the following precautions to reduce the 5. Don't get on Ihe road with a car in poor running risk of radatism espinute. condition or that has a nearly empty gas tank. Car-piel with a neighbor or call yimr hical Emergency

1. Make sure the diers and uindows are shut and Sessices Coordinator on the phone number listed on tightly sealed. page 11.

2. Turn otT the combustion heating or cieling system if 6. Keep Sour pets indimrs unlew Sim have a place to go it's beinging air in hom the outside (if instincted to other than the designated Relocation Centers. Relo-

do un. curion Centers will not accept pets. If you do hase a

, place to take them, bring them along. Hut then, se-

3. llc a radio or teloision and mose to the b.nement member to take leashes dishes carriers, etc., and a if im S hase one. II not, stay awa) from the doors and supply of pet fixxi.

wmdoww i

7. If you have lisestock, shelter them. And,if powible.

4. Keep escrylwly -including pets-inside. stay calm. make pianisions for feeding and watering them.

and time into a local radio or teloision station for Simed feed should be used if powible. As umn as Im ther instr uctions it% safe. Sim'll be permitted to return and case for l then..

5. Refer to pages its and 11 in this NmLles for infornu-tion on naciulion nmies and Primary Relocation l 8. Know w heie you're going . . . w hich direction is safe.

Communities in your asea in case instructions ase = 1.'ch soutes aie open. whese you can sit p for Ihe changed to "esacuation7 mght, etc.

! 6. If you aie not uinhin the take-shelter area, tio not 9. Don't sush. You' e a los move hkely to get hurt that

entes it. When it is safe to re-enter the area. you will way than you are by the selease of radiation.

be inloe med.

7. If you must go outside place a hanalketchief or a psotectise nusk ener Simr nine and mimth. I imit  ;

Som time outsitie as much as powible.

fi 7 . .

WWords To The VWises Preparing For Emergencies Since you may hase to lease Sour home on shoot notice for any one of a number of accidents including nuclear. %isconsin Division of Emergency Gmernment flinhng and chemical spills. you can do some things 4802 Sheboygan Asenue now to make things easier later. Ilere are famr sensible bladison %isconsin $3702 wap to prepare yinuself for any emergency.

For local protectise plans. contact your city or county

1. Collect your important paren and store them in a ,

Emergency Services Coordinator as listed on page 11.

wife place. 'Ihey should all be together so that you can take them u nh Sou.if you want without wasting if you are disabled, or without any means of transpor-time searching for them. tation. or know of someone who needs special help.

contact your city or county Emergency Senices Coor-

2. Set aside anoiher place for emergency gear such as dinator in advance.

Ilashlight estra batteries, estra sets of car keys.

Fint Aid kit fire estinguisher, and other items that WWhat You May WWent To Take Besides

>ou may want quickly. Your Loved Ones

3. Alake a list of things you'll need to take with you. These are only general suggestions for any evacuation.

and make sure you alwan hase~ them on hand. They obviously don't apply to everyone. Shelters in host towns will provide food and bedding.

4. Keep your car in gewi running order with an adequate supply of fuel. Clothing A. Enough seasonal clothing for one wce';

For The Disabled Medical Supplies Special prmisions will be made to piovide care and A. First Aid kit transpostation for all the disabled. It is impiutant that H. Prescription medicines and prescriptions sim let your needs be known. so contact in advance your city or coimiy Emeigency Senices Coordinator as Personal items hsted at the back of this brochure. A. Soap and towels H. Shaving articles For More Information On: C. Toothpaste and toothbrushes Nuclear Power D. Sanitary supplies Supenisor of Public AITairs. Commonwealth Edison E. Required papers (auto registration and credit cards)

Company. P.O. Hos 767. Chicago. Illinon Nm90 Children And Infants Radiation .

A. Disposable diapers and powder Radiation llo I.ine. Argonne National I.aboratories H. Hottles etoll freep. lilinois 8tNk942 9440 C. Ahlk/ formula Outside !!!inois 8tN1/32313M .

Other Supplies State Protection Action Plans A.1-lashlight Ilhnois Emergency Senices and Disaster Agency H. Candles / matches Pubhc Infos mation Otlice C. Portable radio /batleries 110 East Adams Street D. Plastic or paper b.igs Spiingfiehl. lilinois 62706 E. Iland tools tror car repairs)

M

. . 9

i 10-WIiie Emergency Planning Zone o DesPlaines via U.S. Route 45 South, or Interstate 294 N: #

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,,@ """"" South to U.S. Route I4 West.

[ e Pa:L Ridge via U.S. Route 45 South,or Interstate 294 Id , jf South to U.S. Route 14 East.

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• Elk Grove Village via U.S. Route 45 South, or r agoc , c oo,, l Is.eth .

/,(,,,,,,,( p,,3,,, Interstate 294 South to Illinois Route 72 West.

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• Buffalo Grove via U.S. Route 45 South to Illinois 5.=mu==*=

Route 83 South, or Interstate 94 South to Illinois c is h Route 22 West to Illinois Route M3 South.-

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• Wheeling via U.S. Route 45 South to Illinois Route 6N West,or Illinois Route 43 South to Illinois Route 6H gggg, l ..w ScONSIN l, I

IL LIN OIS o n=istires> He te, Wuloconsin

[ ' 5 L . co.ne[-

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I e Whitewater via Wisconsin Routes 50 and 142 West to u.S. Route 12 Wesi.

Zion Lake Mic % an

y ,~ Primary Emergency Information Radio Stations

41 3 y m amiss. 1 WM AQ-670- A M ce=* M i WX l.C-102.3-F M

\ j, Wl.1 P-1050- A M

• • \ J Emergency Services Coordinators 5 m aes QT  %

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. The disabled and those requiring transportation for an evacuation should contact in advance their Emergency Services Coordinator listed below.

k j Director or Deputy Director 25

\ . 6 caev assem chacase Kenosha County Emergency Gosernment I

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• 8'"'L*h" Court flouse. Room I Kenosha, Wis. 53140 o, oM i 414/656-6595 Relocation Communities And Directions Assistant County Administrator The lisllow mg communities are likely io serse as host I.ake County Courthouse shelter areas m the esent of an evacuation request. 'li, Waukegan. Ill. 600M5 plan your soute. trasel to one of the roads shown on the 312/6H9-6603 map. use the nup to get to one of the m.ijor highways, and follow the disections below to the host shelter aseas.

Aikhtional or alleinale communities and routes may be utili/cd. depenthng on weather and road conditions.

Specilie emespency infos mation about what to take.

w hat schication centers will be open, and how to get these will be baudeast as infos mation becomes asailable by the radio stations that are listed on page ll.

litenois e Mclienr>/Woodstock via lilinois Route 131 South to ll

. In Ilhnois Route 120 West.

l l

-O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l )

l In the Matter of ) Docket Nos. 50-456-OL ,

l ) 50-457-OL .

I COMMONWEALTH EDISON COMPANY )

) '

(Braidwood Station, Units 1 and 2) ) l l )

t CERTIFICATE OF SERVICE I hereby certify that copies of the attached COMMONWEALTH EDISON'S RESPONSE TO THE BOARD"S QUESTIONS REGARDING RESPIRATORY PROTECTION were served on the persons listed below by deposit in the United States mail, first-class postage prepaid, unless otherwise indicated, this 21st day of January, 1986.

l Herbert Grossnian, Esquire Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary U.S. Nuclear Regulatory Washington, D.C. 20555 Commission (3 copies)

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

Essex, IL 60935

Stuart Treby, Esquire William Little, Director Elaine I. Chan, Esquire Braidwood Project Office of the Executive Region III Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 799 Roosevelt Road Washington, D.C. 20555 Glen Ellyn, IL 60137 Robert Guild, Esquire Jan Stevens Douglass W. Cassel, Jr., Esquire U.S. Nuclear Regulatory Timothy W. Wright, III, Esquire Commission BPI 7920 Norfolk Avenue 109 North Dearborn Street Phillips Building Suite 1300 Bethesda, MD 20814 Chicago, Illinois 60602 Joseph Gallo, Esquire Charles Jones, Director Isham, Lincoln & Beale Illinois Emergency Services 1120 Connecticut Avenue, N.W.

and Disaster Agency Suite 840 110 East Adams Washington, D.C. 20036 Springfield, IL 62705 Elena Z. Kezelis, Esquire Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, Illinois 60602

/ '

Edgar //

Ge6fge[theAttoYneysfor One of COMMONWEALTH EDISON COMPANY Dated: January 21, 1986

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