ML20203P872
| ML20203P872 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/06/1986 |
| From: | Edgar G COMMONWEALTH EDISON CO., NEWMAN & HOLTZINGER |
| To: | |
| References | |
| CON-#286-079, CON-#286-79 OL, NUDOCS 8605080280 | |
| Download: ML20203P872 (22) | |
Text
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j' gin'(0 B.F UNITED STATES OF AMERICA , ; J7 NUCLEAR REGULATORY COMMISSION ,
2 ;;f ATOMIC SAFETY AND LICENSING BOARD ,.
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In the Matter of ) Docket Nos. 50-456-OL
<) 50-457-OL COMMONWEALTH EDISON COMPANY )
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(Braidwood Station, Units 1 and 2) )
)
COMMONWEALTH EDISON'S REPLY TO INTERVENOR'S PROPOSED FINDINGS ON EMERGENCY PLANNING Pursuant to 10 C.F.R. S 2.754, Commonwealth Edison Company (" Ceco" or " Applicant") hereby files its Reply to Intervenor's Proposed Findings on Emergency Planning.
INTRODUCTION On April 25, 1986, Intervenor submitted to the Board twelve proposed findings addressed solely to Contention 1(a)
(pre-accident public information) and Offer of Proof Issue 2. l_/
For the most part, Intervenor attempts to support these findings, not on the basis of the record evidence, but rather on specula-tive, conclusory and unsupportable statements and arguments made for the first time on brief. Moreover, Intervenor's findings are 1_/ Intervenor has evidently abandoned Contention 1(a) Offer of Proof Issues 3, 4 and 6 and Contention 1(b) by failing to file proposed findings of fact and conclusions of law on those issues. On April 25, and April 29, 1986, CECO and the NRC Staff moved to dismiss these contentions pursuant to 10 C.F.R. S 2.754.
8605080280 860506 PDR ADOCK 05000456 G PDR S, o,n
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premised on erroneous and improper legal standards which run
'directly. contrary to the' legal standards established by applicable Commission regulations and case law. Accordingly, for the reasons which follow, CECO _ respectfully requests that Intervenor's.
proposed findings be rejected in their entirety. 2/
I. INTERVENOR'S PROPOSED FINDINGS REGARDING CONTENTION lla) (PRE-ACCIDENT PUBLIC INFORMATION)
Intervenor's Proposed Findina 1
- 1. The only method by which the public within the Emergency Planning Zone will learn how they will be notified and what.their initial actions should be in the event of a radiological. emergency.
originating at the station is the booklet entitled " Emergency Information --
Braidwood."
In her. discussion of this finding, Intervenor fails to cite any record evidence supporting the statement that the Braidwood Emergency-Booklet is the "only" method of disseminating pre-accident-public information. Although the Booklet is, as
'noted in the testimony of Mr. Butterfield, the principal method of
~
providing the public with'. pre-accident information, (AW Butter-
' field ff. TR 465B at 7), the emergency plan for Braidwood includes a number of additional means for providing pre-accident informa- ,
. tion . - First, the Illinois Plan for Radiological Accidents
!("IPRA").also requires annual press briefings, the designation of ;
a media spokesperson and systematic rumor control. AW Butterfield-2/ Intervenor's-Proposed Findings 4, 9 and 11 are largely duplicative of: CECO's proposed findings 28, and 71-74. CECO requests that its findings, which include citations to the record, be adopted by the Board.
r Suppl. ff. TR 465B at 3, 5-6; SW Wenger ff. TR 518 at 7. In addition, the Illinois Emergency Services and Disaster Agency
("IESDA") has conducted extensive training and orientation programs for various organized groups within the 10-mile plume exposure emergency planning zone ("EPZ") including interested citizens groups. (A Exh. 2 ff. TR 690 at 44-47) Thus, the Booklet is, as noted in CECO's Proposed Findings, the principal, but not the only, means of providing pre-accident public information.
In her discussion of Proposed Finding 1, Intervenor correctly notes that Applicant has offered to provide signs to recreational areas but claims that "the exact wording of the signs was given by neither Miss Fairow nor Mr. Butterfield". 3/
Intervenor also complains that the signs will not state that the recreational area is within the Braidwood EPZ. 4/
Contrary to Intervenor's claim, the language to be contained on the signs was provided in the direct testimony of Mr. Butterfield. In his testimony Mr. Butterfield stated that "the sign will contain the following information in substantially the following language:"
If you hear a siren continuing for 3 minutes or more, please tune to radio stations 1340 AM or 96.7 FM for instructions.
3/ Intervenor's Proposed Findings at 3.
4/ Intervenor has not proposed any findings regarding the signs.
In her requested relief, however, Intervenor asks that Applicant " develop and present a specific message to be used on the signs including information about why the signs and siren system exist."
l
T AW Butterfield ff. TR 465B at 14.
As to Intervenor's complaint that the signs do not state that the recreational area is within the Braidwood EPZ, the record evidence conclusively establishes that such a statement would be inappropriate. As Mr. Butterfield testified, the signs will be used to alert persons to other emergencies such as tornadoes or flooding and thus a statement that the area is in the Braidwood EPZ would not serve any useful purpose. AW Butterfield TR 735-739. It would not hasten responses to an emergency. AW Butterfield TR 738-39. In addition, in those areas with electronic sirens, the information on the signs would be supplemented by verbal messages in the event of an emergency. AW Butterfield TR 736. Finally, all of the recreational areas will be furnished with a supply of the Braidwood Information Booklet which provides detailed information on the possibility of a radiological emergency and the me,ans of notification of the public
, in the event of an emergency. A Exh 2 ff. TR 690 at 60. Thus, there is'no need for additional information on the signs.
. In summary, Intervenor's Proposed Finding 1 is not sup-ported by the record evidence in this proceeding and should be rejected.
Intervenor's Procosed Findino 2
- 2. Applicant's public information program assumes that the adult population is able to read.
There is no record evidence to support this finding. In discussing this finding, Intervenor merely notes that no atudies were performed of the number of illiterates in the EPZ. 5/
Although no such studies have been undertaken (AW Butterfield TR 466), the Braidwood Emergency Booklet specifically requests that the contents of the Booklet be shared with other members of the household. A Exh. 1 at 1; AW Butterfield TR 482. The Booklet also requests that employers advise their employees of the information in the Booklet. A Exh. 1 at 1. Finally, the material in the Booklet is presented in a simple and readable format (AW Butterfield TR 490), which ensures that it is understandable to persons with limited reading skills.
As to the visually impaired, Mr. Butterfield noted that the Booklet provides a form to be filled out by anyone with any type of impairment in order to provide advance notification to the State and facilitate assistance to these persons in the event of an emergency. AW Butterfield TR 477-78. Mr. Butterfield also testified that family, friends or neighbors can be expected to assist the visually impaired in reading the Booklet and filling 5/ Based on this testimony, Intervenor discusses her personal opinion that persons who are illiterate or suffer visual impairments may be too embarrassed to make their disabilities known. Intervenor's Proposed Findings at 4-5. There is, of course, no record evidence to support Intervenor's opinion.
out the form.- AW Butterfield TR 478, 483. And, as noted earlier, the Booklet itself requests that its contents be shared with other members of the same household. A Exh 1 at 1.
'The Federal Emergency Management Agency (" FEMA") has reviewed the pre-accident public information program for Braidwood and found that it meets the requirements'of NUREG 0654/ FEMA-Rep.
1, Rev.~1. .SW Wenger.ff. TR 515 at 9. The record evidence-in this proceeding fully supports that conclusion. Intervenor's Proposed Finding 2 is contrary to the record and should be rejected by the Board. 6/
Intervenor's Proposed Findino 3
- 3. The booklet entitled " Emergency Information - Braidwood" does not address the nature of the danger of a radioloaical accident.
Ignoring the clear and unambiguous language in the Braidwood Emergency Booklet which explains what radiation is as well as the potential danger it poses to the public, (A Exh 1 at SS 7 and'8), Intervenor claims that because the Booklet informs the public that accidents resulting in the release of radiation are unlikely, "those statements need to be balanced with a short 6/ In her requested relief regarding Proposed Finding 2, Intervenor requests that CECO develop video presentations, slideshows or radio information programs to provide pre-accident information to the visually impaired or illiterate.
It is difficult to understand how the visually impaired would
-benefit by either video presentations or slideshows. It is similarly difficult to understand how CECO or the State could
_ identify or notify either the illiterate or visually impaired of such programs since,'as Intervenor suggests, such people will not "make their inabilities known." Intervenor's Proposed Findings at 4-5. In any event, neither NUREG-0654-nor 10 C.F.R. S 50.47 require CECO to develop such programs.
description of how radiation adversely affects the body and what the possible consequences of nuclear accidents might be." 7/
Contrary to Intervenor's claim, the Braidwood Emergency Booklet does precisely that.
Section 7 of the Booklet describes in simple, under-standable language how a nuclear power plant works and pointedly notes that were an accident to occur, radioactive materials would escape to the environment.
Section 8 of the Booklet describes, again in simple understandable language, the effects of radiation. This Section explains background radiation and notes that low levels of radia-tion produce no identifiable health effects. This statement is balanced with the cautionary note that " scientists believe that any amount of radiation, no matter how small, carries some risk."
A Exh 1 at S 8. The next paragraph of Section 8 explains that radiation doses of over 20,000 millirem received within a day produce identifiable effects in the body. The paragraph also explains that very large doses (over 100,000 millirem) received over a day's time may be directly harmful or even deadly. The Section goes on to explain that radiation levels are constantly monitored at the plant and if an accident were to occur, in most instances there would be no excessive radiation. The section concludes, however, with the statement that:
if the accident were serious, and could expose members of the public to 1,000 millirem or more of radiation, state plans call for protection of the public by taking shelter indoors or by evacuation . . . .
7/ Intervenor's Proposed Findings at 6.
In short, Sections 7 and 8 provide a fair and balanced discussion of radiation.
Although Sections 7 and 8 of the Booklet were not the subject of any testimony offered by Intervenor, expert testimony was offered by both the NRC Staff and CECO regarding these sections. Both Mr. Butterfield of CECO and Mr. Wenger of FEMA described these two sections and concluded that the information met the requirements of NUREG 0654. AW Butterfield ff. TR 465B at 8, 9; SW Wenger ff. TR 515 at 3. Under these circumstances, Intervenor's claim that the Booklet is somehow deficient with regard to educational information regarding radiation is wholly without merit and Intervenor's Proposed Finding 3 should be rejected.
Intervenor's Proposed Findinos 4-7
- 4. Applicant has committed to modify the language of the booklet in its next issuance to include the following language as the last full paragraph of Section 8:
If a nuclear plant accident were ever to occur, teams of specially-trained personnel would be sent to get even more detailed radiation readings all around the plant. In most cases, there would be no exces-sive radiation. If the accident were serious, and could expose members of the public to 1000 millirem or more of radiation, state plans call for protection of the public by taking shelter indoors or by evacuation. The most probable form of radiation which could be found beyond the plant boundaries would be contained in a cloud or plume. This cloud would move in the prevailing wind direction and would
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dictate the areas for potential shelter or evacuation recommenda-tions.
- 5. The additional information as stated in Finding 4 does not resolve the plume issue, because the information concerning the radioactive plume is significant enough to deserve a separate paragraph.
- 6. The additional information as stated in Finding 4 does not resolve the plume issue, because no possible physical characteristics or lack of characteristics of the radioactive plume are given.
- 7. The additional information as stated in Finding 4 does not resolve the plume issue because such information should be keyed back to earlier passages or sections which are affected by it.
During the hearings held on March 11-12, 1986, Mr. Butterfield testified that the Braidwood Emergency Booklet would be amended to include language describing the radioactive plume. Specifically, Mr. Butterfield testified that the new language. describing the plur) would be added to the last full paragraph of Section 8. AW Butterfield TR 1026-1027. For her part, Intervenor chose not to question Mr. Butterfield regarding the insertion of this language and now requests the Board in Proposed Finding 5 to substitute her extra-record opinion as to the appropriate location of this language for that of Mr. Butterfield. 8/ Mr. Butterfield's opinion was never ,
challenged by Intervenor or contradicted by any other witness.
Accordingly, it should be upheld by the Board and Intervenor's Proposed Finding 5 rejected.
8/ Indeed, Intervenor makes no attempt to justify Finding 5 on the basis of the record. Rather, Intervenor's basis for this change is that "Intervenor feels" that Mr. Butterfield's insertion of the language in Section 8 is inappropriate.
Intervenor's Proposed Findings at 9.
_ 10 _
In her Proposed Finding 6, Intervenor suggests that additional language should be included in the Braidwood Emergency Booklet to describe the physical appearance of the radioactive plume. Although the plume language in Section 8 was never the subject of any cross-examination by Intervenor, nor the subject of 4
any expert testimony offered by Intervenor, Intervenor nonetheless requests that the language be changed because, in her view, the
-language "may" be confusing to the public. Intervenor bases this opinion on the fact that radiation is described in the Booklet as invisible, silent, tasteless and odorless, while no physical description is-given of the radioactive plume or cloud.
Even the most cursory review of Section 8 demonstrates that Section 8, including the plume language, is written in a clear and understandable fashion. The section describes the physical characteristics of radiation and makes no distinction between radiation in general and radiation moving in a plume. It is difficult to understand how any confusion could result.
The language describing the radioactive plume was sponsored by a qualified expert responsible for the drafting and preparation of the Braidwood Emergency Booklet. Intervenor's extra-record opinions concerning the appropriate language to be included-in the Booklet are entitled to no weight by this Board.
Intervenor's Proposed Finding 6 should be rejected.
In Proposed Finding 7, Intervenor argues that the language describing the radioactive plume should be " keyed back to earlier passages or sections which are affected by it." Specifi-
. r-.-, _mm.~_,. .- , . . _ . _ , _ _ , - - . _ . . - . . . - . . . _ , , , , , _ - . ,
cally, Intervenor argues that the plume language should be cross-referenced in Section 4 of the Booklet. Section 4 of the Booklet describes the principal evacuation routes but notes that:
Other routes than those above may be given on the radio, depending on environmental conditions. 9/
Intervenor proposes that the plume language be cross-referenced after this sentence because, in Intervenor's opinion, the reader may not understand that weather conditions would dictate the direction of the plume. As in the case of Intervenor's other suggested changes to the Booklet, this matter was never the subject of cross-examination nor the subject of expert testimony offered by Intervenor.
No worthwhile purpose would be served by cross-referencing the description of the radioactive plume in Section 4.
Indeed, such cross-referencing would likely create confusion. The phrase " weather conditions" refers to far more than simply the prevailing wind direction carrying the plume, but also refers to conditions, such as snow, rain and hail, that may affect evacua-tion routes. By specifically cross-referencing the plume language, the reader would be misled into believing that the phrase simply referred to the movement of the plume. 10/
9/ The phrase " environmental conditions" will, in future editions of the Booklet, be changed to " weather conditions."
AW Butterfield TR 484.
10/ There is very little cross-referencing in the Booklet, presumably to ensure that each Section is read in full before going to the next or succeeding Sections.
l Intervenor again provides the, Board with her opinion !
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that, without cross-referencing, the reader "may respond to t
' weather conditions' as he already understands the term and not follow the instructions given on the radio as to evacuation".
There is no record evidence to support'this opinion. In any event, Mr. Wenger testified that although language regarding the plume might be helpful, it was not necessary. Mr. Wenger also testified as follows:
The instructions given to the public would be classified as emergency instructions. If someone says to move a direction because of a problem, I don't think I would question to ask what the problem may be. I think it is necessary that people take,lthat action.
There is going to be pre-information announced. Therefore, when it is given to evacuate by certain routes,from an area, the area you should go, I don't know if plume pathway, or radioactive plume, has that much significance. You are telling people: Move.
As the foregoing demonstrates, cross-referencing of the plume language would be counter-productive, would tend to confuse the reader, and would not assist the public in the event of a take shelter or evacuation instruction. 11/ Intervenor's Proposed Finding 7 should, therefore, be rejected.
11/ The plume language added by Mr. Butterfield does specifically note that the plume would travel in the direction of the prevailing wind and would dictate the areas to be sheltered or evacuated.
Intervenor's Procosed Findino 8
- 8. In Section 1 of the emergency information booklet, bullet 4, the first sentence should read "You will be given informa-tion and instructions." rather than "You will be given information and instruction if there is a real call for concern."
Intervenor contends that the phrase "if there is a real call for concern" is misleading because as indicated by Mr. Wenger's testimony, if an accident were to occur, the sirens would sound and information would be given in all cases.
SW Wenger TR 535. Intervenor concludes from this that the phrase "if there is a call for concern" is unnecessary in Section 1 and misleading.
Contrary to Intervenor's assertions, in the context of Section 1, the phrase is both necessary and pertinent. The second paragraph of Section 1 notes that the sirens will be tested each month but advises the reader to assume an emergency exists. In order to determine if an emergency does exist, the reader is told to listen to one of the two EBS stations. Finally, the reader is advised that if there is a real call for concern, (i.e., the sirens sounded because of an emergency rather than merely a test) information and instructions will be given. It is also possible, of course, that no information or instructions will be given because the sirens were simply being tested, or were actuated spuriously.
Read in the proper context, the phrase "if there is a call for concern" is entirely appropriate and necessary.
Intervenor's suggested change would seriously alter the meaning of
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the entire Section and would create a source of confusion in those cases where the siren is tested or spuriously actuated and no information or instructions are forthcoming.
Intervenor's Proposed Findina 9 12/
- 9. Applicant's means of distribution of the emergency preparedness booklet (Emergency Information-Braidwood) is deficient in that it does not cover all possible residents of the Emergency Planning Zone.
As an initial matter, CECO is not required to devise a
" "means of distribution cohering "all possible residents of the Emergency Planning Zone." Rather, 10 C.F.R. S 50.47(b) and NUREG-0654 require CECO to have a reasonable planning basis for
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its methods of distributing pre-accident information to the public. As the Atomic Safety and Licensing Board found in Long Island Lichtino Comoany, (Shoreham Nuclear Power Station) LBP 12, 23 NRC 644, 653 (1985):
The Commission's regulations do not require that extreme or unreasonable emergency planning measures be taken. EER E29thern California Edison Co. (San Quofri Nuclear Generating Station, Units 2 and 3),'CLI 10, 17 NRC 528 (1983). The planning standards of 10 C.F.R. S 50.47(b) and NUREG-0654 provide a reasonable planning basis rather than absolute planning requirements. .
This Board does not have to find that all individuals are covered by the plan under all circumstances.
12/ Intervenor has numbered two proposed findings with the number 9. In order to eliminate confusion, we have 0 renumbered Intervenor's second Proposed Finding 9 as 9A.
__ ___m__ _ _ _ _ _ _ _ . _ _ _ _
CECO's method of distribution clearly meets this standard.
The Braidwood Emergency Booklet will be mailed to all CECO customers within the EPZ. 13/ A complete mailing list of CECO's customer in the EPZ will be developed from its Customer ,
Information System. ("CIS"). A Booklet will be mailed to every address on the list developed from CIS. The list will be updated for each subsequent mail distribution. AW Butterfield ff. TR 465B ,
l at 12. Where a particular person's billing address is different than the residence address, a copy of the Booklet will be mailed to both the billing address and the residence address.
AW Butterfield TR 480, 498-499.
After extensive cross-examination of Mr. Butterfield, Intervenor established one possible scenario in which a person living within the EPZ micht not receive a copy of the Booklet.
l This scenario assumes that an owner (1) leaves the EPZ, (2) allows someone to use his residence, (3) continues to pay the electric bill, (4) has the same billing and service address, (5) has all
- mail forwarded and (6) presumably takes all copies of the Booklet he already possesses out of the residence. AW Butterfield TR 512-513. In response to this possibility, Mr. Butterfield acknowledged that the person would not receive a Booklet but explained that, in such a case, it would be impossible for CECO to know that a guest was living in the residence. AW Butterfield 13/ CECO is the only utility providing electricity within the EPZ, with the-exception of the Joliet Arsenal. AW Butterfield TR 510.
TR 512-513. More importantly, Mr. Butterfield testified that it would be the obligation of the owner to inform his guest of the Booklet. AW Butterfield TR 514.
Proposed Finding 9 also ignores the fact that mailing of the Booklet is only one means of distribution used by CECO. The Booklet will also be distributed at area hotels, motels, recrea-tional areas, schools, industries, health care and nursing
! facilities, public libraries, local ESDA offices and local utility offices. A Exh 3, Ch. 8. Thus, in addition to direct mailing, there are a variety of locations at which a guest in the situation described above could, and likely would, obtain a copy of the Booklet.
In light of the speculative nature of the scenario upon 1
which Intervenor bases Proposed Finding 9, the improper legal standard upon which the finding is premised, and the fact that l alternative distribution measures have already been planned, Intervenor's Proposed Finding 9 should be rejected.
l II. Intervenor's Contention 1(a) and Offer of Proof Issue 2 Intervenor's Proposed Findinos 9A-12 9A. Section 3 of the booklet entitled
" Emergency Information -- Braidwood",
bullet 2 states:
GATHER THE PEOPLE in your home TOGETHER. If you have children or
. others at schools, hospitals, overnight campground or nursing homes, DO NOT try to pick them up.
These facilities will be following their own evacuation procedures, and you would probably miss connections.
STAY TUNED to one of the radio stations listed earlier for informa-
tion on where persons are being moved. Students, patients and nursing home residents will be accompanied'by Staff to relocation centers. Their needs, including medical needs, will be provided for until they are reunited with their families..
- 10. The information provided in the booklet is not sufficient to deter individuals responsible for school children or persons at recreational areas from attempting to pick them up.
- 11. The information provided in the shelter and evacuation recommendation messages reads, "All school children, nursing home residents and hospital patients are being attended to by trained personnel. There is no need to go there to pick anyone up." (IPRA Vol. 1, Ch. 2)
- 12. The information provided in the shelter and evacuation recommendation messages is not sufficient-to deter individuals responsible for school children or persons at recreational areas from attempting to pick them up.
In these four proposed findings, Intervenor claims that the language in the Booklet and in-the pre-scripted EBS messages are insufficient "to deter individuals responsible for school children or persons at recreational areas from attempting to pick them up." Intervenor's Proposed Finding at 13. There is no record evidence to support this finding. On this basis alone it should be rejected.
If the inquiry is extended beyond Intervenor's mere assertion of insufficiency, it is necessary to consider the purpose of the language in question. The primary concern in .
attempting to deter parents or others from going to schools or recreational areas is increased traffic congestion. AW Fairow TR
l 854-855. Thus, the EBS messages as well as the Booklet advise parents that their children are being well taken care of, and that the children will be taken to a particular congregate care center, and pointedly caution that parents or others should not attempt to pick them up. 14/ A Exh. 2 at S3; A Exh 2 ff. TR 690 at 17, 18,
- 20. CECO's witnesses testified that the language in the Booklet should deter people from going to either recreational areas or schools and thus discourage unnecessary traffic. A Exh 2 ff.
TR 690 at 20. Nevertheless, Ms. Fairow acknowledged that where a child could be evacuated more quickly by a parent than by a bus, it might be expected that some parents would go to the schools or recreational areas. A.W. Fairow TR 851, 1016.
Based on Ms. Fairow's acknowledgement, Intervenor contends that the scripts and Booklet are deficient presumably because there is no absolute assurance that a parent will not go to recreational areas or schools. Neither CECO nor the State are required,to provide absolute assurance that every possible contingency is addressed. Instead, they are required to provide a reasonable planning basis to deal with contingencies such as traffic congestion at schools or recreational areas. Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3) CLI-83-10, 17 NRC 528, 533 (1983); Lona Islands Lichtino Company, suora at 653.
14/ There is no basis for concern with parents or others outside the affected areas. Traffic and access control points will prevent such persons from entering the affected areas. A Exh 2 ff., TR 690 at 68, 70; AW Fairow TR 852.
In this case, the IPRA clearly provides such a basis.
The State has developed a structured, flexible organization comprised of EOCs at the municipal and county levels of government to deal with problems like traffic congestion. If parents or others within the affected areas ignore the Booklet and pre-scripted messages and do go to schools or recreational areas creating traffic congestion, the school principal or recreational area supervisor would call the municipal EOC for assistance.
Representatives of the local sheriff and police departments are stationed at the municipal and county EOCs and an officer would be sent to the particular school or recreational area to render assistance. E,c., A Exh 2 ff. TR 690 at 98, 105.
The record evidence clearly establishes that the language in the pre-scripted messages and Booklets should provide a reasonable deterrent against parents or others going to schools or recreational areas. To the extent that the messages and Booklet might be ignored, and traffic congestion is created, assistance in dealing with traffic congestion would be given by the municipal or ccunty EOCs. Intervenor's Proposed Findings 9A-12 are contrary to the record evidence and should be rejected.
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CONCLUSION For the foregoing reasons, CECO respectfully requests that all of Intervenor's proposed findings be rejected in their entirety.
Respectfully submitted, l
, (,
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'/ .
George'L. Edgar s#
Thomas A. Schmutz Donald J. Silverman j Newman & Holtzinger, P.C.
l 1615 L Street, N.W.
! Washington, D.C. 20036 Attorneys for Commonwealth Edison Company
( Date: May 6, 1986
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of ) Docket Nos. 50-456-OL
) 50-457-OL COMMONWEALTH EDISON COMPANY )
)
(Braidwood Station, Units 1 and 2) )
)
CERTIFICATE OF SERVICE
.I hereby certify that copies of the attached Commonwealth Edison's_ Reply to Intervenor's Proposed Findings On Emergency Planning were served on the persons listed below by deposit in the United States mail, first-class postage prepaid, unless otherwise indicated, this 6th day of May, 1986.
- Herbert Grossman, 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
o 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 i Robert Guild, Esquire
- Janice A. Stevens Douglass W. Cassel, Jr., Esquire (For Addressee Only)
Timothy W. Wright, III, Esquire U.S. Nuclear Regulatory BPI Commission
-109 North Dearborn Street 7920 Norfolk Avenue
-Suite 1300 Phillips Building Chicago, Illinois 60602 Bethesda, MD 20814 Charles Jones, Director
- Joseph Gallo, Esquire Illinois Emergency Services Isham, Lincoln & Beale and Disaster Agency 1150 Connecticut Avenue, N.W.
110 East Adams Suite 1100 Springfield, IL 62705 Washington, D.C. 20036 Elena Z. Kezelis, Esquire Isham, Lincoln & Beale l Three First National Plaza l Suite 5200 Chicago, Illinois 60602
.7 /
~
_Y George g Edgar'
( One of the Attorneys for i
Commonwealth Edison Company Dated: May 6, 1986 Hand Deliver
- Federal Express i
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