ML20138J059

Provides First Request for Production of Documents on Contention Re Supervisors Employed by Electrical Contractor Allegedly Harassed & Intimidated QC Inspectors & Other Employees.Svc List Encl.Related Correspondence

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 CORRESPoncgh COUNSELORS ATLAW D6LKEIED i

. THREE FWtSTNATIONAL PLA2A cacAso.aumoisessee 1

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85 DEC 16. All:12 oca g @ ~- i December 12, 1985 WFICI F SE3N '

• • • • %EEE "

DOCKETmG A SERViD BRANCH Mr. William Dirks Executive Director of Operations United States Nuclear Regulatory Commission 1 1717 "H" Street.

Washington, DC 20555 Re: i COMMONWEALTH EDISON COMPANY --

(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. l As reflected in Applicant's First Request, the l documents sought relate to an admitted contention in the proceeding before the ASLB that supervisors employed by Applicant's electrical contractor allegedly harassed and intimidated their QC inspectors and other' employees. In-the NRC Staff with similar discovery requests and Staf 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.

a statement Similarly, to someone.at the deponent-testified Region III. that he had made gation of that individual's allegations has been The NRC's investi-closed.

Accordingly, we-believe we are entitled'to all such docu-ments sought in our enclosed First Request. 1

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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 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 j intervenors alleging regarding the identities of the individuals harassment.

, that the documents we obtain from the NRC Staff and theWe are, of co information the terms ofthey that contain Order. will be treated in accordance with Very truly yours, ,,

)

w & 2 W ena Z. Kezelis /

One of the Attorneys for Applicant {

i' Commonwealth Edison Company 1 EZK:hmw Enc.

cc:

See attached Service List I

I

l 0

),

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 Administrative Law Judge P.O. Box 208 Essex, IL 60935 Atomic Safety and Licensing Board United States Nuclear Regulatory Robert Guild Commission

' Washington, DC Douglass W. Cassel, Jr.

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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