ML12248A223

Applicant'S Second Supplemental Disclosures Pursuant to 10 C.F.R. Section 2.336; Exelon Generation Company, LLC, License Renewal for Limerick Generating Station, Units 1 and 2

ML12248A223
Person / Time
Site:	Limerick
Issue date:	09/04/2012
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 23413, 50-352-LR, 50-353-LR, ASLBP 12-916-04-LR-BD01
Download: ML12248A223 (10)

Text

Morgan. Lewis & Bockius LLP 1111 Pennsylvania Avenue. NW Washington. DC 20004 Morgan Lewis Tel: 202.739.3000 COUNSELORS AT LAW Fax: 202.739.3001 www.morganlewis.com Alex S. Polonsky Partner 202.739.5830 apolonsky@morganlewis.com September 4,2012 VIA ELECTRONIC INFORMATION EXCHANGE Anthony Z. Roisman, Esq.

National Legal Scholars Law Firm, P.C.

241 Poverty Lane, Unit 1 Lebanon, NH 03766 Maxwell Smith, Esq.

Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Second Supplemental Disclosures Pursuant to 10 C.F.R. § 2.336; Exelon Generation Company, LLC, License Renewal for Limerick Generating Station, Units 1 and 2, Docket Nos. 50-352-LR and 50-353-LR

Dear Counsel:

Pursuant to 10 C.F.R. § 2.336 and the Board's Scheduling Order dated May 7, 2012, Exelon Generation Company, LLC (Exelon) is providing the enclosed supplemental disclosures with respect to Natural Resource Defense Council (NRDC) Contention 1 as restated and admitted by the Board in LBP-12-08 on April 4, 2012.

Exelon's disclosures consist of the following

• 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, and will update Enclosure 1 when it has identified its witnesses.

• Enclosure 2 provides a description, by category and location, of the documents, data compilations, and tangible things in the possession, custody, or control of Exelon that Wilmington Philadelphia Washington New York Los Angeles San Francisco Miami Pittsburgh Princeton Chicago Palo Alto Dallas Houston Harrisburg Irvine Boston London Paris Brussels Frankfurt Beijing Tokyo

Morgan Lewis COUNSELORS AT LAW Anthony Z. Roisman, Esq.

Maxwell Smith, Esq.

September 4,2012 Page 2 may be relevant to the admitted contention, as modified by the Board's May 7, 2012 Scheduling Order. Enclosure 2 includes a revision to the log provided at Enclosure 2 in Exelon's August 1,2012 disclosure, revised as described in Exelon's August 22,2012 production.

• Enclosure 3 provides an index of documents, data compilations, or tangible things that may be relevant to the admitted contention but that contain proprietary or Sensitive Unclassified Non-Safeguards Information (SUNSI).

• Enclosure 4 provides an index of documents, data compilations, or tangible things that may be relevant to the admitted contention but that contain privileged information, as modified by the Board's May 7, 2012 Scheduling Order. Some of the materials identified on Enclosure 4 may also contain proprietary information or SUNS!.

In order to compile Enclosures 2, 3 and 4, a reasonable search was conducted of documents in Exelon's possession, custody, or control, from custodians (and central files) expected to have relevant materials. The attached affidavit attests that all relevant materials identified by this search that are required to be disclosed have been disclosed.

Exelon has been conservative in identifying documents for inclusion in Enclosures 2,3, and 4.

By identifying documents on those Enclosures, Exelon does not necessarily concede that the documents are in fact relevant or material to the admitted contention.

All documents are available through Morgan, Lewis & Bockius, LLP, located at 1111 Pennsylvania Avenue, N.W., Washington, D.C. 20004.

Sincerely, Signed in Accordance with 10 CPR. § 2.304(d)

Alex S. Polonsky Counsel for Exelon Generation Company, LLC Enclosures DB 11 70895771.1

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) ) September 4, 2012

)

CERTIFICATE OF SERVICE I hereby certify that on September 4, 2012, Exelon served a copy of its Second Supplemental Disclosures, supporting affidavit, and transmittal letter via the Electronic Information Exchange.

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/ 70895834.2 1

UNITED STATES UNITED STATES OF OF AMERICA AMERICA NUCLEAR REGULATORY NUCLEAR REGULATORY COMMISSION COMMISSION BEFORE THE BEFORE THE ATOMIC ATOMIC SAFETYSAFETY AND AND LICENSING LICENSING BOARDBOARD

))

In the In the Matter Matter of of ))

)) Docket Docket Nos.

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

))

(Limerick Generating (Limerick Generating Station, Station, Units Units 11 and and 2)

2) ))

))

AFFIDAVIT OF OF NANCY L. L. RANEK 1.

1. My name is Nancy L. Ranek. I am the Environmental Environmental Lead, License Renewal, at Exelon Generation Company, LLC ("Exelon"). (Exelon). Working with the attorneys for Exelon, I have been responsible for managing the collection of documents, data compilations, compilations, and tangible things to comply with the mandatory disclosure requirements in 10 c.F.R.

things C.F.R. §§ 2.336 and the Atomic Safety and Licensing Boards Board's Initial Scheduling Order dated May 7,2012 7, 2012 ("Scheduling (Scheduling Order)

Order") in this proceeding.

2. Exelon conducted a search of documents, data compilationscompilations,, and tangible things in its its possession, possession, custody, and control control for infonnation information relevant to the admitted contention, and in the possession, possession, custody, custody, and control of its relevant contractor organizations organizations,, as as specified in in 10 10 C.F.R.

C.F.R. §§ 2.336(a).

2.336(a). As provided provided in in 10 10 C.F.R.

C.F.R. §2.336(c),

§2.336(c), this this search search encompassed encompassed information and and documents documents reasonably reasonably available available to to Exelon Exelon and and its its relevant relevant contractor contractor organizations organizations,,

including:

including:

a.a. Both Both electronic electronic and and paper paper documents; documents; b.

b. Corporate Corporate records, records, Limerick Limerick license license renewal renewal project project files, files, and and documents documents in in the the possession possession and and control of individuals control of individuals who who have have worked worked onon the the 11

Limerick license Limerick project or renewal project license renewal matters potentially on matters or on relevant to potentially relevant to the the admitted contentions; and admitted contentions; and c.c. Documents, data Documents, compilations,, and data compilations tangible things and tangible things in possession and the possession in the and control of control of ERIN ERIN Engineering Engineering & ("ERIN") and Inc. (ERIN)

Research, Inc.

& Research, and URS URS

("URS"), which Corporation (URS),

Corporation Exelon in assisted Exelon which assisted portions of preparing portions in preparing of the the Limerick Environment Limerick Environmental al Report.

Report.

3.

3. Enclosure 11 is names, addresses, is reserved for the names, numbers of telephone numbers and telephone addresses, and of the the persons upon persons upon whose whose opinion opinion Exelon Exelon willwill base positions on its positions base its on the contention and the contention upon whom and upon whom Exelon may rely as witnesses, and a copy of the analyses and authorities authorities upon which they base base their opinions. Exelon has not yet identified witnesses for any hearing on the contention.

4. Consistent with the Boards Board's May 7, 2012 Scheduling Order, Enclosure 2 to this 7,2012 Affidavit provides an index of relevant, non-privileged, non-protected documents, data non-privileged, non-protected compilations, and tangible things that were located as a result of this search.

compilations,

5. Consistent with the Board's Boards May 7,20127, 2012 Scheduling Order, Enclosure 3 to this Affidavit provides an index of relevant documents, data compilations, compilations, and tangible things that Exelon Exelon believes are are proprietary to Exelon organizations, or Exelon or its relevant contractor organizations, or falls within the the category category ofof Sensitive Sensitive Unclassified, Non-Safeguards Information Unclassified, Non-Safeguards (SUNSI).

Information ("SUNS I").

6.

6. Consistent Consistent with with thethe Board's Boards May 7, 2012 Scheduling May 7,2012 Enclosure 44 to Order, Enclosure Scheduling Order, this to this Affidavit Affidavit provides provides an an index index ofof relevant relevant documents, documents, data compilations, and data compilations, things that tangible things and tangible that Exelon Exelon believes believes are are privileged.

privileged.

7.

7. Exelon Exelon has has been been conservative conservative inin identifying documents for identifying documents inclusion in for inclusion the in the enclosures.

enclosures. Accordingly, Accordingly, Exelon Exelon isis not not suggesting that just suggesting that listed on document isis listed because aa document just because on anan enclosure enclosure that that itit isis indeed indeed relevant relevant to to the the admitted contention.

admitted contention.

2

8. These disclosures are reasonably accurate and complete as of August 1,2012.1, 2012.

The statements made above are true to the best of my knowledge, information, infonnation, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Nancy L. Ranek /

""""~".H Generation Company, LLC Exelon

.....

License Renewal Environmental Lead 200 Exelon Way, KSAl2-EKSAI2-E Kennett Square, P PA A 19348 Phone: 610-765-5369 Email: nancy.ranek@exeloncorp.com Executed this 2L 1L day of j\ugust August 2012.

DB 1170895757.

DBl/ 70895757.11 3

August 2012 - Revised Enclosure 2: Non-Protected Log 1 of 1 DOCUMENT AUTHOR / DOCUMENT NUMBER DATE CUSTODIAN TYPE TO FILE NAME / EMAIL SUBJECT LINE Gregory Krueger 152 4/30/10 (Exelon) DOC n/a Limerick Plant Changes Impacting CDF for LR.doc 153 8/16/89 Steven Varga (NRC) PDF G.A. Hunger (PECO) Lim_SAMDA_Supplement_16aug1989.PDF 154 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 155 10/31/89 David Helwig (PECO) PDF NRC Vulnerabilities" 10CFR50.63, "Loss of All Alternating Current Powwer" 156 4/9/90 G.A. Hunger (PECO) PDF NRC Supplemental Information Station Blackout Analysis, Limerick Generating Station, 157 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" 158 9/4/91 George Beck (PECO) PDF NRC Response to NRC Concerns 10CFR50.63, "Loss of All Alternating Current" 159 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 160 7/30/92 George Beck (PECO) PDF n/a Vulnerabilities"

September 2012 Enclosure 2: Non-Protected Log 1 of 1 DOCUMENT AUTHOR / DOCUMENT NUMBER DATE CUSTODIAN TYPE TO FILE NAME / EMAIL SUBJECT LINE Philip Tarpinian 161 9/10/07 (Exelon) Excel n/a LGS PRA FASA - HRA ScopeRev1.xls Philip Tarpinian 162 7/24/12 (Exelon) Word n/a ACRS Slide 4.3 Talking Paper on PRA.docx Philip Tarpinian 163 7/31/12 (Exelon) PDF n/a LGS Draft LRA SER (ML12173A470).pdf Larry Lee Greg Krueger 9900-467 Memo GKrueger Summary of Plant 164 8/10/11 (Exelon) Word (Exelon) Improvements.docx

September 2012 Enclosure 3: Proprietary Log 1 of 1 BASIS FOR DOCUMENT AUTHOR / DOCUMENT FILE NAME / EMAIL SUBJECT PROPRIETARY NUMBER DATE CUSTODIAN TYPE TO LINE STATUS Phillip Tarpinian Official FASA Report Template, LGS Exelon Proprietary 6 10/20/2011 (Exelon) Word n/a PRA Quality Information Phillip Tarpinian Event Procedure E-10/20, Loss of Exelon Proprietary 7 4/1/2011 (Exelon) Word n/a Offsite Power, Rev. 44 Information

September 2012 Enclosure 4: Privilege Log 1 of 1 DOCUMENT AUTHOR / DOCUMENT BASIS FOR NUMBER DATE CUSTODIAN TYPE TO SUBJECT PRIVILEGE Phillip Tarpinian Materials Requested by Counsel for 33 11/3/2011 (Exelon) PDF n/a Review Attorney Work Product Phillip Tarpinian Materials Requested by Counsel for 34 4/5/2012 (Exelon) PDF n/a Review Attorney Work Product Christopher Shimer Don Vanover Discussion of Work Directed by 35 7/14/2012 (Exelon) Email (ERIN) Counsel Attorney Work Product Christopher Phillip Tarpinian Shimer Discussion of Work Directed by 36 7/16/2012 (Exelon) Email (Exelon) Counsel Attorney Work Product Phillip Tarpinian Don Vanover Discussion of Work Directed by 37 7/16/2012 (Exelon) Email (ERIN) Counsel Attorney Work Product Gregory Krueger David Helker 38 7/5/2012 (Exelon) Email (Exelon) Work Directed by Counsel Attorney Work Product