ML12214A467

Exelon'S First Supplemental Disclosures

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

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-352-LR EXELON GENERATION COMPANY, LLC ) 50-353-LR

)

(Limerick Generating Station, Units 1 and 2) ) August 1, 2012

)

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 Office of the Secretary William J. Froehlich, Chair U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: HearingDocket@nrc.gov E-mail: William.Froehlich@nrc.gov Administrative Judge Office of Commission Appellate Adjudication Dr. William E. Kastenberg U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Mail Stop: O-16C1 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: OCAAMail@nrc.gov E-mail: William.Kastenberg@nrc.gov Administrative Judge Matthew Flyntz Michael F. Kennedy Law Clerk Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: Michael.Kennedy@nrc.gov E-mail: Matthew.Flyntz@nrc.gov 1

Natural Resources Defense Council (NRDC) Office of the General Counsel 1152 15th St., N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20005 Mail Stop O-15D21 Geoffrey H. Fettus, Senior Project Attorney Washington, DC 20555-0001 E-mail: GFettus@nrdc.org OGCMailCenter@nrc.gov Catherine Kanatas Catherine.Kanatas@nrc.gov National Legal Scholars Law Firm, P.C. Brian Newell 241 Poverty Lane, Unit 1 Brian.Newell@nrc.gov Lebanon, NH 03766 Maxwell Smith Anthony Z. Roisman, Managing Partner Maxwell.Smith@nrc.gov E-mail: ARoisman@nationallegalscholars.com 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 DB1/ 70520358.1 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR])

)

In the Matter of )

) Docket Nos. 50-352-LR EXELON GENERATION COMPANY, LLC ) 50-35 3-LR

)

(Limerick Generating Station, Units 1 and 2) )

)

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 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. Enclosure 1 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.

2

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.

)Iai c. /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.

cJ2012.

1 DR 1/70520361.1 3

August 2012 Enclosure 2: Non-Protected Log 1 of 1 DOCUMENT AUTHOR / DOCUMENT NUMBER DATE CUSTODIAN TYPE TO FILE NAME / EMAIL SUBJECT LINE Gregory Krueger 152 4/20/12 (Exelon) Email Kathleen Turner (BSC) RE: Limerick: Data Status Update Gregory Krueger 153 4/30/10 (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" Response to NRC Generic Letter 88-20, "Individual Plant Response to NRC Generic Letter 88-20, Individual Plant Examination for Severe Accident 156 10/31/89 David Helwig (PECO) PDF NRC Vulnerabilities" 10CFR50.63, "Loss of All Alternating Current Powwer" 157 4/9/90 G.A. Hunger (PECO) PDF NRC Supplemental Information Station Blackout Analysis, Limerick Generating Station, 158 6/3/91 Richard Clark (NRC) PDF George Beck (PECO) Units 1 and 2 (TAC Nos. 68561 and 68562) 10CFR50.63, "Loss of All Alternating Current" 159 9/4/91 George Beck (PECO) PDF NRC Response to NRC Concerns 10CFR50.63, "Loss of All Alternating Current" 160 2/4/92 George Beck (PECO) PDF NRC Response to NRC Concerns Response to NRC Generic Letter 88-20, "Individual Plant Response to NRC Generic Letter 88-20, Individual Plant Examination for Severe Accident 161 7/30/92 George Beck (PECO) PDF n/a Vulnerabilities"

August 2012 Enclosure 4: Privilege Log 1 of 2 DOCUMENT AUTHOR / DOCUMENT BASIS FOR NUMBER DATE CUSTODIAN TYPE TO SUBJECT PRIVILEGE Gregory Krueger 20 4/17/2012 (Exelon) Email Nancy Ranek (Exelon) Discussion of Work Directed by Counsel Attorney Work Product Gareth Parry 21 6/4/2012 (ERIN) Email Gregory Krueger (Exelon) Discussion of Work Directed by Counsel Attorney Work Product Don Vanover 22 6/11/2012 (ERIN) Email Philip Tarpinian (Exelon) Discussion of Work Directed by Counsel Attorney Work Product Gregory Krueger 23 6/20/2012 (Exelon) Email Don Vanover (ERIN) Discussion of Work Directed by Counsel Attorney Work Product Richard Dudley Materials Supporting Work Directed by 24 6/20/2012 (NRC) PDF n/a Counsel Attorney Work Product Discussion of Work Directed by Counsel Philip Tarpinian and Transmittal of Supporting 25 4/6/2012 (Exelon) Email Nancy Ranek (Exelon) Documents Attorney Work Product Philip Tarpinian Materials Supporting Work Directed by 26 4/6/2012 (Exelon) PDF n/a Counsel Attorney Work Product Philip Tarpinian Materials Supporting Work Directed by 27 4/6/2012 (Exelon) PDF n/a Counsel Attorney Work Product Philip Tarpinian 28 5/30/2012 (Exelon) Email Nancy Ranek (Exelon) Work Directed by Counsel Attorney Work Product

August 2012 Enclosure 4: Privilege Log 2 of 2 DOCUMENT AUTHOR / DOCUMENT BASIS FOR NUMBER DATE CUSTODIAN TYPE TO SUBJECT PRIVILEGE Philip Tarpinian 29 5/30/2012 (Exelon) Spreadsheet n/a Work Directed by Counsel Attorney Work Product Philip Tarpinian 30 6/12/2012 (Exelon) Email Don Vanover (ERIN) Work Directed by Counsel Attorney Work Product Don Vanover 31 6/13/2012 (ERIN) Email Don Macleod (ERIN) Work Directed by Counsel Attorney Work Product Don Vanover 32 6/11/2012 (ERIN) Email Philip Tarpinian (Exelon) Work Directed by Counsel Attorney Work Product