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 & 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 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 Morgan Lewis COUNSELORS AT LAW 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
- 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.
October 1, 2012 Page 2 Morgan Lewis COUNSELORS AT LAW may be relevant to the admitted contention, as modified by the Board's September 4, 2012 Revised Scheduling Order.
- 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.
- 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. 3 04 (d)
Alex S. Polonsky Counsel for Exelon Generation Company, LLC Enclosures DB 11 71183040.1
1 DB1/ 71183029.1 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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October 1, 2012
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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
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)
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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 Revised Scheduling Order dated September 4, 2012 (Revised 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. § 2.3 36(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 Docket Nos.
50-352-LR 50-353-LR 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 Revised Scheduling Order dated September 4,2012
("Revised 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 Revised 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 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 (SUNSI). Exelon has no such documents to disclose this month.
6.
Consistent with the Boards Revised Scheduling Order, Enclosure 4 to this Affidavit is reserved for an index of relevant documents, data compilations, and tangible things that Exelon believes are privileged. Exelon has no such documents to disclose this month.
2 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 Revised 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 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 I"). Exelon has no such documents to disclose this month.
- 6.
Consistent with the Board's Revised Scheduling Order, Enclosure 4 to this Affidavit is reserved for an index of relevant documents, data compilations, and tangible things that Exelon believes are privileged. Exelon has no such documents to disclose this month.
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 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.
)Le&fJ4JL Nancy L..anek Exelon Generation Company, LLC License Renewal Environmental Lead 200 Exelon Way, KSA/2-E Kennett Square, PA 19348 Phone: 610-765-5369 Email: nancy.ranek@exeloncorp.com Executed this _
28 th day of September 2012.
DB 1/71183131.1 3
- 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 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~
Nancy L. anekl Exelon Generation Company, LLC License Renewal Environmental Lead 200 Exelon Way, KSN2-E Kennett Square, P A 19348 Phone: 610-765-5369 Email: nancy.ranek@exeloncorp.com Executed this 28th day of September 2012.
DBII71183J31.1 3
October 2012 : Non-Protected Log 1 of 1 DOCUMENT NUMBER DATE AUTHOR /
CUSTODIAN DOCUMENT TYPE TO FILE NAME / EMAIL SUBJECT LINE 165 8/2/12 Philip Tarpinian (Exelon)
PDF n/a Perspectives on SAMAs for US Plant LR [w SAMDA ref].pdf 166 8/22/12 Christopher Wilson (Exelon) / Jeff Gabor (ERIN)
Email Michael Gallagher (Exelon), Nancy Ranek (Exelon),
Albert Fulvio (Exelon), Jeff Gabor (ERIN), Gregory Krueger (Exelon)
"SECY" 167 8/22/12 Jeff Gabor (ERIN)
PDF n/a Secy-12-0110.pdf