ML12248A223
| 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 Tel: 202.739.3000 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 Morgan Lewis COUNSELORS AT LAW 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
- 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.
- 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
Anthony Z. Roisman, Esq.
Maxwell Smith, Esq.
September 4,2012 Page 2 Morgan Lewis COUNSELORS AT LAW 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.
- 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).
- 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
1 DB1/ 70895834.2 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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September 4, 2012
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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
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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EXELON GENERATION COMPANY, LLC
)
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(Limerick Generating Station, Units 1 and 2)
)
)
Docket Nos.
50-352-LR 50-353-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 infonnation 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
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
)
)
)
)
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EXELON GENERATION COMPANY, LLC (Limerick Generating Station, Units 1 and 2)
Docket Nos.
50-352-LR 50-353-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 Board's 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. 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 provides 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).
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.
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.
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 Board's 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 Board's May 7,2012 Scheduling Order, Enclosure 3 to this Affidavit provides 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 ("SUNS I").
- 6.
Consistent with the Board's 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.
- 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.
2
8.
These disclosures are reasonably accurate and complete as of August 1, 2012.
The statements made above are true to the best of my knowledge, infonnation, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Nancy L. Ranek /
Exelon Generation Company, LLC License Renewal Environmental Lead 200 Exelon Way, KSAI2-E Kennett Square, PA 19348 Phone: 610-765-5369 Email: nancy.ranek@exeloncorp.com Executed this 1L day of j\\ugust 2012.
DBl/ 70895757.1 3
- 8.
These disclosures are reasonably accurate and complete as of August 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.
Executed this 2L day of August 2012.
DB 1170895757. 1
..... """"~".H Generation Company, LLC License Renewal Environmental Lead 200 Exelon Way, KSAl2-E Kennett Square, P A 19348 Phone: 610-765-5369 Email: nancy.ranek@exeloncorp.com 3
August 2012 - Revised : Non-Protected Log 1 of 1 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO FILE NAME / EMAIL SUBJECT LINE 152 4/30/10 Gregory Krueger (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" 155 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" 156 4/9/90 G.A. Hunger (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current Powwer" Supplemental Information 157 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) 158 9/4/91 George Beck (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current" Response to NRC Concerns 159 2/4/92 George Beck (PECO)
PDF NRC 10CFR50.63, "Loss of All Alternating Current" Response to NRC Concerns 160 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"
September 2012 : Non-Protected Log 1 of 1 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO FILE NAME / EMAIL SUBJECT LINE 161 9/10/07 Philip Tarpinian (Exelon)
Excel n/a LGS PRA FASA - HRA ScopeRev1.xls 162 7/24/12 Philip Tarpinian (Exelon)
Word n/a ACRS Slide 4.3 Talking Paper on PRA.docx 163 7/31/12 Philip Tarpinian (Exelon)
PDF n/a LGS Draft LRA SER (ML12173A470).pdf 164 8/10/11 Larry Lee (Exelon)
Word Greg Krueger (Exelon) 9900-467 Memo GKrueger Summary of Plant Improvements.docx
September 2012 : Proprietary Log 1 of 1 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO FILE NAME / EMAIL SUBJECT LINE BASIS FOR PROPRIETARY STATUS 6
10/20/2011 Phillip Tarpinian (Exelon)
Word n/a Official FASA Report Template, LGS PRA Quality Exelon Proprietary Information 7
4/1/2011 Phillip Tarpinian (Exelon)
Word n/a Event Procedure E-10/20, Loss of Offsite Power, Rev. 44 Exelon Proprietary Information
September 2012 : Privilege Log 1 of 1 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO SUBJECT BASIS FOR PRIVILEGE 33 11/3/2011 Phillip Tarpinian (Exelon)
PDF n/a Materials Requested by Counsel for Review Attorney Work Product 34 4/5/2012 Phillip Tarpinian (Exelon)
PDF n/a Materials Requested by Counsel for Review Attorney Work Product 35 7/14/2012 Christopher Shimer (Exelon)
Email Don Vanover (ERIN)
Discussion of Work Directed by Counsel Attorney Work Product 36 7/16/2012 Phillip Tarpinian (Exelon)
Email Christopher Shimer (Exelon)
Discussion of Work Directed by Counsel Attorney Work Product 37 7/16/2012 Phillip Tarpinian (Exelon)
Email Don Vanover (ERIN)
Discussion of Work Directed by Counsel Attorney Work Product 38 7/5/2012 Gregory Krueger (Exelon)
Email David Helker (Exelon)
Work Directed by Counsel Attorney Work Product