ML12214A467
| ML12214A467 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/01/2012 |
| From: | Polonsky A Exelon Generation Co, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | Roisman A, Matthew Smith National Legal Scholars Law Firm, PC, NRC/OGC |
| SECY RAS | |
| References | |
| RAS 23151, 50-352-LR, 50-353-LR, ASLBP 12-916-04-LR-BD01 | |
| Download: ML12214A467 (10) | |
Text
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-352-LR EXELON GENERATION COMPANY, LLC
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50-353-LR
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(Limerick Generating Station, Units 1 and 2)
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August 1, 2012
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CERTIFICATE OF SERVICE I hereby certify that on August 1, 2012, Exelon served a copy of its first Supplemental Disclosures, supporting affidavit, and transmittal letter on the following recipients via the Electronic Information Exchange:
Administrative Judge William J. Froehlich, Chair Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: William.Froehlich@nrc.gov Administrative Judge Dr. William E. Kastenberg Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: William.Kastenberg@nrc.gov Administrative Judge Michael F. Kennedy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Michael.Kennedy@nrc.gov Office of the Secretary U.S. Nuclear Regulatory Commission Rulemakings and Adjudications Staff Washington, DC 20555-0001 E-mail: HearingDocket@nrc.gov Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Mail Stop: O-16C1 Washington, DC 20555-0001 E-mail: OCAAMail@nrc.gov Matthew Flyntz Law Clerk Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: Matthew.Flyntz@nrc.gov
2 DB1/ 70520358.1 Natural Resources Defense Council (NRDC) 1152 15th St., N.W.
Washington, D.C. 20005 Geoffrey H. Fettus, Senior Project Attorney E-mail: GFettus@nrdc.org National Legal Scholars Law Firm, P.C.
241 Poverty Lane, Unit 1 Lebanon, NH 03766 Anthony Z. Roisman, Managing Partner E-mail: ARoisman@nationallegalscholars.com Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop O-15D21 Washington, DC 20555-0001 OGCMailCenter@nrc.gov Catherine Kanatas Catherine.Kanatas@nrc.gov Brian Newell Brian.Newell@nrc.gov Maxwell Smith Maxwell.Smith@nrc.gov Mary Spencer Mary.Spencer@nrc.gov Ed Williamson Edward.Williamson@nrc.gov Signed (electronically) by Anna V. Jones Anna Vinson Jones Morgan, Lewis & Bockius LLP 1111 Pennsylvania Ave., NW Washington, DC 20004 Phone: (202) 739-5881 Fax: (202) 739-3001 E-mail: Anna.Jones@morganlewis.com Counsel for Exelon
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In the Matter of
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EXELON GENERATION COMPANY, LLC
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(Limerick Generating Station, Units 1 and 2)
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Docket Nos.
50-352-LR 50-35 3-LR AFFIDAVIT OF NANCY L. RANEK 1.
My name is Nancy L. Ranek. I am the Environmental Lead, License Renewal, at Exelon Generation Company, LLC (Exelon). Working with the attorneys for Exelon, I have been responsible for managing the collection of documents, data compilations, and tangible things to comply with the mandatory disclosure requirements in 10 C.F.R. § 2.336 and the Atomic Safety and Licensing Boards Initial Scheduling Order dated May 7, 2012 (Scheduling Order) in this proceeding.
2.
Exelon conducted a search of documents, data compilations, and tangible things in its possession custody, and control for information relevant to the admitted contention, and in the possession, custody, and control of its relevant contractor organizations, as specified in 10 C.F.R. § 2.336(a). As provided in 10 C.F.R. §2.336(c), this search encompassed information and documents reasonably available to Exelon and its relevant contractor organizations, including:
a.
Both electronic and paper documents; b.
Corporate records, Limerick license renewal project files, and documents in the possession and control of individuals who have worked on the UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR])
1
Limerick license renewal project or on matters potentially relevant to the admitted contentions; and c.
Documents, data compilations, and tangible things in the possession and control of ERIN Engineering & Research, Inc. (ERIN) and URS Corporation (URS), which assisted Exelon in preparing portions of the Limerick Environmental Report.
- 3. is reserved for the names, addresses, and telephone numbers of the persons upon whose opinion Exelon will base its positions on the contention and upon whom Exelon may rely as witnesses, and a copy of the analyses and authorities upon which they base their opinions. Exelon has not yet identified witnesses for any hearing on the contention.
4.
Consistent with the Boards May 7, 2012 Scheduling Order, Enclosure 2 to this Affidavit provides an index of relevant, non-privileged, non-protected documents, data compilations, and tangible things that were located as a result of this search.
5.
Consistent with the Boards May 7, 2012 Scheduling Order, Enclosure 3 to this Affidavit is reserved for an index of relevant documents, data compilations, and tangible things that Exelon believes are proprietary to Exelon or its relevant contractor organizations, or falls within the category of Sensitive Unclassified, Non-Safeguards Information (SUNSI). There are no such documents in this round of disclosures.
6.
Consistent with the Boards May 7, 2012 Scheduling Order, Enclosure 4 to this Affidavit provides an index of relevant documents, data compilations, and tangible things that Exelon believes are privileged.
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7.
Exelon has been conservative in identifying documents for inclusion in the enclosures. Accordingly, Exelon is not suggesting that just because a document is listed on an enclosure that it is indeed relevant to the admitted contention.
8.
These disclosures are reasonably accurate and complete as of July 1, 2012.
The statements made above are true to the best of my knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
)Iaic. /f/YLdCJ Nany L. R/inek /
Exelon Generation Company, LLC License Renewal Environmental Lead 200 Exelon Way, KSAI2-E Kennett Square, PA 19348 Phone: 6l0765-5369 Email: nancy.ranek@exeloncorp.com Executed this 2.1 day of.u.
1 cJ2012.
DR 1/70520361.1 3
August 2012 : Non-Protected Log 1 of 1 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO FILE NAME / EMAIL SUBJECT LINE 152 4/20/12 Gregory Krueger (Exelon)
Email Kathleen Turner (BSC)
RE: Limerick: Data Status Update 153 4/30/10 Gregory Krueger (Exelon)
DOC n/a Limerick Plant Changes Impacting CDF for LR.doc 154 8/16/89 Steven Varga (NRC)
PDF G.A. Hunger (PECO)
Lim_SAMDA_Supplement_16aug1989.PDF 155 4/17/89 G.A. Hunger (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current Powwer" 156 10/31/89 David Helwig (PECO)
PDF NRC Response to NRC Generic Letter 88-20, "Individual Plant Response to NRC Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities" 157 4/9/90 G.A. Hunger (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current Powwer" Supplemental Information 158 6/3/91 Richard Clark (NRC)
PDF George Beck (PECO)
Station Blackout Analysis, Limerick Generating Station, Units 1 and 2 (TAC Nos. 68561 and 68562) 159 9/4/91 George Beck (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current" Response to NRC Concerns 160 2/4/92 George Beck (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current" Response to NRC Concerns 161 7/30/92 George Beck (PECO)
PDF n/a Response to NRC Generic Letter 88-20, "Individual Plant Response to NRC Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities"
August 2012 : Privilege Log 1 of 2 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO SUBJECT BASIS FOR PRIVILEGE 20 4/17/2012 Gregory Krueger (Exelon)
Email Nancy Ranek (Exelon)
Discussion of Work Directed by Counsel Attorney Work Product 21 6/4/2012 Gareth Parry (ERIN)
Email Gregory Krueger (Exelon) Discussion of Work Directed by Counsel Attorney Work Product 22 6/11/2012 Don Vanover (ERIN)
Email Philip Tarpinian (Exelon)
Discussion of Work Directed by Counsel Attorney Work Product 23 6/20/2012 Gregory Krueger (Exelon)
Email Don Vanover (ERIN)
Discussion of Work Directed by Counsel Attorney Work Product 24 6/20/2012 Richard Dudley (NRC)
PDF n/a Materials Supporting Work Directed by Counsel Attorney Work Product 25 4/6/2012 Philip Tarpinian (Exelon)
Email Nancy Ranek (Exelon)
Discussion of Work Directed by Counsel and Transmittal of Supporting Documents Attorney Work Product 26 4/6/2012 Philip Tarpinian (Exelon)
PDF n/a Materials Supporting Work Directed by Counsel Attorney Work Product 27 4/6/2012 Philip Tarpinian (Exelon)
PDF n/a Materials Supporting Work Directed by Counsel Attorney Work Product 28 5/30/2012 Philip Tarpinian (Exelon)
Email Nancy Ranek (Exelon)
Work Directed by Counsel Attorney Work Product
August 2012 : Privilege Log 2 of 2 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO SUBJECT BASIS FOR PRIVILEGE 29 5/30/2012 Philip Tarpinian (Exelon)
Spreadsheet n/a Work Directed by Counsel Attorney Work Product 30 6/12/2012 Philip Tarpinian (Exelon)
Email Don Vanover (ERIN)
Work Directed by Counsel Attorney Work Product 31 6/13/2012 Don Vanover (ERIN)
Email Don Macleod (ERIN)
Work Directed by Counsel Attorney Work Product 32 6/11/2012 Don Vanover (ERIN)
Email Philip Tarpinian (Exelon)
Work Directed by Counsel Attorney Work Product