ML20138J059
| ML20138J059 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/12/1985 |
| From: | Kezelis E COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| CON-#485-497 OL, NUDOCS 8512170424 | |
| Download: ML20138J059 (3) | |
Text
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491 I,
- ISHAM, LINCOLN & BEALEWED CORRESPoncg COUNSELORS ATLAW D6LKEIED
. THREE FWtSTNATIONAL PLA2A cacAso.aumoisessee 1
7 85 DEC 16. All:12 oca g @ ~-
December 12, 1985
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WFICI F SE3N '
DOCKETmG A SERViD BRANCH Mr. William Dirks Executive Director of Operations United States Nuclear Regulatory 1
Commission 1717 "H" Street.
Washington, DC 20555 COMMONWEALTH EDISON COMPANY --
Re:
(Braidwood Station, Units 1 and
)
2), Docket Nos. 50-456, 50-4570L_
Dear Mr. Dirks:
i In accordance with the provisions of 10 C.F.R.
S2.744, I am herewith serving you with Applicant's First
' Request for Production of Documents to.the NRC Staff.
As reflected in Applicant's First Request, documents sought relate to an admitted contention in the the proceeding before the ASLB that supervisors employed by Applicant's electrical contractor allegedly harassed and intimidated their QC inspectors and other' employees.
the NRC Staff with similar discovery requests and Staf In-apparently complied voluntarily.
i We have good cause to believe that Staff has in its possession the documents Applicant seeks; for example during the course of the deposition last week of one of the individuals alleging harassment within the scope of the admitted contention, Mr. L. G. McGregor (who was present at the deposition) indicated that he-was reviewing his notes from an interview he.had conducted of the individual being deposed.
Similarly, the deponent-testified that he had made a statement to someone.at Region III.
The NRC's investi-gation of that individual's allegations has been closed.
Accordingly, we-believe we are entitled'to all such docu-ments sought in our enclosed First Request.
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Mr. William Dirks December 12, 1985 Page Two sought by AIn sum, it is self-evident that the documents contention,pplicant's Request are relevant to the harassment that the documents are necessary to a proper
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decision in the licensing proceeding, and that the documents are not obtainable from any other sources.
For your additional information, the Licensing Board entered a Prctective Order on December 6, 1985 which provides for confidential treatment of information from intervenors regarding the identities of the individuals j
alleging harassment.
that the documents we obtain from the NRC Staff and theWe are, of co information they contain will be treated in accordance with the terms of that Order.
Very truly yours,
)
2 W w
ena Z. Kezelis
/
One of the Attorneys for Applicant
{
Commonwealth Edison Company i'
EZK:hmw 1
Enc.
See attached Service List cc:
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),
SERVICE LIST Herbert Grossman, Esq.
Chairman Mr. William L. Clements Administrative Law Judge Chief, Docketing and Services Atomic Safety and Licensing United States Nuclear Regulatory Board Commission United States Nuclear Regulatory Office of the Secretary Commission Washington, DC 20555-Washington, DC 20555 Ms. Bridget Little Rorem Dr. Richard F. Cole 117 North Linden Street P.O. Box 208 Administrative Law Judge Atomic Safety and Licensing Essex, IL 60935 Board United States Nuclear Regulatory Commission Robert Guild Douglass W.
Cassel, Jr.
' Washington, DC 20555 Timothy W. Wright, III BPI Dr. A. Dixon Callihan 109 North Dearborn Street Administrative Law Judge Suite 1300 102 Oak Lane Chicago, IL 60602 Oak Ridge, TN. 37830 Charles Jones, Director Stuart Treby, Esq.
Illinois Emergency Services Elaine I..Chan, Esq.
and Disaster Agency Office of the Executive Legal 110 East Adams Director Springfield, IL 62705 United States Nuclear Regulatory Commission Washington, DC 20555 William Little, Director Braidwood Project Region III Atomic Safety and Licensing United States Nuclear Regulatory Board Panel Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, IL 60137 Washington, DC 20555
'Jan Stevens Atomic Safety and Licensing United States Nucl' ear Regulatory Appeal Board Panel Commission United States Nuclear Regulatory 7920 Norfolk Avenue Commission Phillips Building Washington, DC 20555 Bethesda, MD 20014
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