ML12275A081
| ML12275A081 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/01/2012 |
| 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 23538, 50-352-LR, 50-353-LR, ASLBP 12-916-04-LR-BD01 | |
| Download: ML12275A081 (7) | |
Text
Morgan Lewis Morgan. Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 COUNSELORS AT LAW Tel: 202.739.3000 Fax: 202.739.3001 www.morganlewis.com Alex S. Polonsky Partner 202.739.5830 apolonsky@morganlewis.com October 1,2012 VIA ELECTRONIC INFORMATION EXCHANGE Anthony Z. Roisman, Esq.
National Legal Scholars Law Firm, P.C.
241 Poverty Lane, Unit 1 Lebah.on, NH 03766 Maxwell Smith, Esq.
Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Third 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 Revised Scheduling Order dated September 4, 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.
October 1, 2012 Page 2 may be relevant to the admitted contention, as modified by the Board's September 4, 2012 Revised Scheduling Order.
- Enclosure 3 is reserved for 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). Exelon has no such documents to disclose this month.
- Enclosure 4 is reserved for 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 September 4,2012 Revised Scheduling Order. Some of the materials identified on Enclosure 4 may also contain proprietary information or SUNSI.
Exelon has no documents appropriate for Enclosure 4 to disclose this month.
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 CP.R. § 2. 304 (d)
Alex S. Polonsky Counsel for Exelon Generation Company, LLC Enclosures DB 11 71183040.1
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) ) October 1, 2012
)
CERTIFICATE OF SERVICE I hereby certify that on October 1, 2012, Exelon served a copy of its Third 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/ 71183029.1 1
UNITED UNITED STATES STATES OF OF AMERICA AMERICA NUCLEAR REGULATORY NUCLEAR REGULATORY COMMISSION COMMISSION BEFORE BEFORE THE THE ATOMIC ATOMIC SAFETY SAFETY ANDAND LICENSING LICENSING BOARD BOARD
))
In the Matter of In of ))
)) Docket Nos.
Docket Nos. 50-352-LR 50-352-LR GENERATION COMPANY, EXELON GENERATION COMPANY, LLC )) 50-353-LR
))
Generating Station, (Limerick Generating Station, Units 11 and 2) ))
)
AFFIDAVIT OF NANCY L. RANEK 1.
- 1. Environmental Lead, License Renewal, at My name is Nancy L. Ranek. I am the Environmental (Exelon). Working with the attorneys for Exelon, I have Exelon Generation Company, LLC ("Exelon").
compilations, and tangible been responsible for managing the collection of documents, data compilations, things to comply with the mandatory disclosure requirements in 10 c.F.R.C.F.R. §§ 2.336 and the Boards Revised Scheduling Order dated September 4,2012 Atomic Safety and Licensing Board's 4, 2012 (Revised Scheduling Order")
("Revised Order) in this proceeding.
- 2. Exelon conducted a search of documents, data compilations compilations,, and tangible things in its possession, custody, and control for information infonnation relevant to the admitted contention, and in the possession, custody, and control of its relevant contractor organizations organizations,, as specified in 10 C.F.R. § 2.336(a).
c.F.R. § 2.3 36(a). As provided in 10 C.F.R.
c.F.R. §2.336(c), this search encompassed information and documents reasonably available to Exelon and its relevant contractor organizations organizations,,
including:
- a. Both Both electronic and paper paper documents;
- b. Corporate Corporate records, Limerick license renewal project project files, and documents in in the possession and control control of of individuals individuals who have have worked on on the 11
Limerick license Limerick project or renewal project license renewal on matters potentially or on relevant to the potentially relevant the admitted contentions; admitted contentions; and and
- c. Documents, data compilations, possession and compilations, and tangible things in the possession
("ERIN") and URS control of ERIN Engineering & Research, Inc. (ERIN) control
("URS"), which assisted Exelon in Corporation (URS), in preparing portions of preparing portions of the Limerick Environmental Report.
3.
- 3. Enclosure 11 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. Board's Revised Scheduling Order, Enclosure 2 to this Consistent with the Boards 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 Boards Revised 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 ("SUNS (SUNSI).I"). Exelon has no such documents to disclose this month.
- 6. Consistent with the the Board's Boards Revised Scheduling Enclosure 4 to this Scheduling Order, Enclosure Affidavit is reserved for an index of relevant documents, documents, data compilations, and tangible things that that Exelon Exelon believes are are privileged. Exelon has no such such documents to this month.
to disclose this month.
22
- 7. conservative in identifying documents for inclusion in the Exelon has been conservative enclosures. Accordingly, Exelon is not suggesting that just because a document is listed on an an enclosure that it is indeed relevant to the admitted contention.
- 8. 1, 2012.
These disclosures are reasonably accurate and complete as of September 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.
'4cX~
)Le&f J4JL anekl Nancy L. .anek Exelon Generation Company, LLC License Renewal Environmental Lead KSA/2-E 200 Exelon Way, KSN2-E Kennett Square, P PAA 19348 Phone: 610-765-5369 Email: nancy.ranek@exeloncorp.com 28
_
th Executed this 28 th day of September 2012.
DB 1/71183131.1 DBII71183J31.1 33
October 2012 Enclosure 2: Non-Protected Log 1 of 1 DOCUMENT AUTHOR / DOCUMENT NUMBER DATE CUSTODIAN TYPE TO FILE NAME / EMAIL SUBJECT LINE Philip Tarpinian Perspectives on SAMAs for US Plant LR [w 165 8/2/12 (Exelon) PDF n/a SAMDA ref].pdf Michael Gallagher (Exelon), Nancy Ranek (Exelon),
Albert Fulvio Christopher Wilson (Exelon), Jeff Gabor (Exelon) / Jeff Gabor (ERIN), Gregory 166 8/22/12 (ERIN) Email Krueger (Exelon) "SECY" 167 8/22/12 Jeff Gabor (ERIN) PDF n/a Secy-12-0110.pdf