ML20138J277

First Request for Production of Document to Nrc.Documents Should Reflect Identity of Comstock QC Inspector or Employee Who Complained to NRC About Alleged Harassment. Certificate of Svc Encl.Related Correspondence

ML20138J277
Person / Time
Site:	Braidwood
Issue date:	12/12/1985
From:	Kezelis E COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#485-498 OL, NUDOCS 8512170475
Download: ML20138J277 (6)

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a__EugEO CORRESF0NcENCE December 12, 1985

't UNITED STATES OF AMERICA D%;hg O

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENG4GgSOS$DSU N In the Matter.of: ) .

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COMMONWEALTH EDISON COMPANY ) CFFCO" DCLR '

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) Docket Nos. 5bMCH-456 0 l-.

(Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )

APPLICANT'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF Pursuant to 10 C.F.R. 52.744, Applicant Commonwealth Edison Company hereby requests that the NRC Staff make available for inspection and copying the documents requested below at a mutually agreeable time and place.

Instructions

1. As used herein, " document" means and includes correspondence, notes, memoranda, reports, written records and summaries of oral communications, statements and any other writing of any kind, whether in draft or final form.

2. If the NRC Staff considers any document requested herein to be privileged, then its response below must include a list of the document (s) withheld from pro-duction, and must identify the following for each: author, title, date, general subject matter, addressee (s) , and the ground (s) upon which each such document is withheld as privileged.

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DOCUMENTS TO BE PRODUCED 1.

All documents reflecting the identity of each Comstock QC Inspector or other employee who has complained to the NRC about alleged harassment and intimidation lar Comstock supervisors, including but not limited to the 24 QC Inspectors who allegedly complained to the NRC on March 29, 1985.

2.

All documents relating or referring to each instance of alleged harassment and intimidation of any Comstock QC Inspector or other employee either carried out or participated in by comstock supervisors, including but not' limited to Irv DeWald, Larry Seese, Bob Seltmann, R.M.

Saklak, Bob Marino, John Walters, Ken Worthington and Daryl Landers.

3. All documents reflecting or relating to the substance or. subject matter (s) of complaints to the NRC by the Comstock QC Inspectors or other employees referred to in Request No. 1 above.

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4. All documents reflecting or relating to any NRC investigation (s) of the complaints referred to in Request No. 3 above.

5. All documents reflecting or relating to any resolution (s) of the complaints referred to in Request No. 3 above.

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'E 6.

All documents reflecting or relating to any alleged quality or safety concerns expressed by any Comstock QC Inspector or other-employee to the NRC.

7.

All documents reflecting or relating to any NRC investigation (s) of the alleged quality or safety-concerns referred to in Request No. 6 above.

8.

All documents reflecting or relating to any resolution (s) of the alleged quality or safety concerns referred to in Request No. 6 above.

9.

To the extent not already produced in re-sponse to the foregoing requests, please produce (A) all documents. reflecting or: referring to any complaints of alleged harassment and intimidation made by the following

. individuals to the NRC:

(1) John D. Seeders (2) Rick Snyder (3) R.D. Hunter (4) Herschel Stout (5) Dan Holley-

-(6) Tim Stewart (7) Worley Puckett (B) all' documents reflecting or relating ' to the substance or subject matter (s) of their complaints to the NRC; (C) all documents reflecting or relating to any NRC investigation (s) of their complaints; (D)'all documents reflecting or re- .

lating to any resolution (s) of their complaints; (E) all

documents reflecting or relating to any alleged quality or safety concerns expressed by any of them to the NRC; (F) all documents reflecting or relating to any NRC investigation (s) of their alleged quality or safety concerns; and (G) all documents reflecting or relating _ to any resolution (s) of their alleged quality or safety concerns.

Submitted by:

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/s/ (tM One of the K$torneyf for Applicany COMMONWEALTH EDISON COMPANY Michael I. Miller, Esq.

Elena Z. Kezelis, Esq.

ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 Dated ' December 12, 1985

i RELATED CORRE.SPONDEN,Cg i

DeWEl UNITED STATES OF AMERICA , 'J W'EU NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING k A b

' In the Matter of: )

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COMMONWEALTH EDISON COMPANY ) 00ChETfR HCH

) Docket Nos. 50-456 (Braidwood Nuclear Power )

Station, Units 1 and 2) )

50-457 CERTIFICATE OF SERVICE I, Elena Z.

Kezelis, one of the attorneys for Commonwealth Edison Company, certi~yf that copies of the Applicant's First Request For Production Of Documents To The NRC Staff have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 12th day of December,~

1985.

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$< L Elen Z. K z lis ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 DATED: December 12, 1985

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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 Commission Office of the Secretary Washington, DC 20555 Washington, DC 20555 Ms. Bridget Little Rorem Dr. Richard F. Cole 117 North Linden Street l Administrative Law Judge P.O. Box 208 I Atomic Safety and Licensing Essex, IL 60935 I

Board United States Nuclear Regulatory Commission Robert Guild Washington, DC 20555 Douglass W. Cassel, Jr.

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 1 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 Nuclear. Regulatory Appeal Board Panel Commission United States Nuclear Regulatory 7920 Norfolk Avenue

. Commission Washington, DC Phillips Building 20555 Bethesda, MD 20014

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