ML20055B689
| ML20055B689 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/21/1982 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20055B686 | List: |
| References | |
| NUDOCS 8207220635 | |
| Download: ML20055B689 (6) | |
Text
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o 00LKETED USt&^
'82 3L 2 IOi UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION er < r Before the Atomic Safety and Licensing Board In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
NOTICE OF TAKING DEPOSITIONS TO:
G. Kenneth Young John Phillipi Norman Forkelson Jack Miller and all other individuals identified below c/o Robert J.
Sugarman, Esq.
Sugarman & Denworth Suite 510 North American Building 121 South Broad Street Philadelphia, Pennsylvania 19107 This notice, as authorized by 10 C.F.R. 52.740a in circumstances where, as here, names and addresses of persons
[
[
to be examined are not known, is directed to the persons who t
comprise the class of individuals described below.
The l
persons to be examined are as follows:
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i 8207220635 820721 PDR ADOCK 05000352 O
G. Kenneth Young John Phillippi Norman Forkelson Jack Miller and Each individual identified in response to Interrogatory.14 of Applicant's First
~
Set of Interrogatories and Request for Production of Documents to Del-Aware, Unlimited, Inc.,
served upon Del-Aware on July 21, 1982.
The persons identified above are hereby
- notified, pursuant to 10 C.F.R.
S2.740a, that Philadelphia Electric Company, by and through its counsel, will take the oral depositions of those identified above commencing on Tuesday, August 9,
1982 from 9:00 a.m.
until 5:00 p.m.,-
and continuing each day thereafter, except
- Sunday, until completed.
All depositions are presently scheduled to be taken at the Holiday Inn Center
- City, 18th and Market
- Streets, Philadelphia, Pennsylvania.
The depositions will be-taken before an officer authorized to administer oaths by the laws of Pennsylvania, to wit, Kenneth Russell or Mickey Dinter, Area Wide Federal Reporting, 1315 Walnut
- Street, Philadelphia, Pennsylvania.
The examination will relate to the three contentions granted by the Atomic Safety and Licensing Board to Del-Aware in the captioned proceeding as stated at page 87 of the "Special Prehearing Conference Order," dated June 1,
1982.
These contentions are as follows:
Contentions V-15 and V-16a (in part) - The intake will be relocated such that it will have significant adverse
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impact on American shad and short-nosed sturgeon.
The relocation will adversely affect a major fish resource and i
boating and recreation area due to draw-down of the pool.
Contention V-16a - Noise effects and constant dredging maintenance connected with operations of the intake and its associated pump station will adversely affect the peace and tranquility of the Point Pleasant proposed historic district.
Contention V-16b - Seepage of water and toxics from Bradshaw Reservoir will cause a
risk of groundwater contamination and hydraulic saturation.
The deposition of each deponent will be taken with regard to the following:
1.
His or her interest in this proceeding and the facts relating thereto; 2.
His or her knowledge of the admitted contentions and the supporting basis and other facts relating thereto; 3.
The subject matter on which each prospective witness for Del-Aware is expected to testify, his or her educational and professional qualifications to give expert opinion testimony, and the substance of his or her testimony; 4.
The educational, professional, and any other relevant qualifications of any proposed interrogator, spokesman, or representative for Del-Aware in the evidentiary hearing (other than an attorney appearing as such), and the subject matter and the substance of what he or she plans to elicit; 5.
The subject matter and substance of any other direct or cross-examination evidence, including
- exhibits, which Del-Aware plans to adduce or elicit in this proceeding; and 6.
The names and identities, addresses, educational, professional, and other relevant qualifications of all other individuals from whom Del-Aware has or will obtain information, expert opinion, facts or other matters.
Each deponent should bring to the deposition session the whole of all documents and other material pertinent to the foregoing upon which he or she relies in whole or in
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o part, and should be prepared to designate specific portions of documents or other material upon which he or she relies.
By mutual agreement between counsel for Philadelphia Electric Company and for Del-Aware Unlimited, Inc.
the tender of witness fees has been waived.
'l CONNER & WETTERHAHN, P.C.
- 2. '
Tro Conner, Jr.
Counsel for the Applicant 1747-Pennsylvania Avenue, N.W.
Washington, D.C.
20006 (202)833-3500 July 21, 1982
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
Certificate of Service I hereby certify that copies of " Applicant's First Set of Interrogatories and Request for Production of Documents to Del-Aware, Unlimited, Inc." and " Notice of Taking Deposition," in the captioned matter have been served upon the following by deposit in the United States mail this 21st day of July, 1982.
Judge Lawrence Brenner (2)
Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Stephen H.
Lewis, Esq.
Judge Richard F.
Cole Ann P.
Hodgden, Esq.
Atomic Safety and Licensing Elaine I. Chan, Esq.
Board Counsel for NRC Staff U.S.
Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Judge Peter A. Morris Washington, D.C.
20555 Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S.
Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Panel Philadelphia Electric Company U.S. Nuclear Regulatory ATTN:
Edward G.
Bauer, Jr.
Commission Vice President &
Washington, D.C.
20555 General Counsel 2301 Market Street Philadelphia, PA 19101
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Mr. Frank R. Romano Walter W.
Cohen, Esq.
61 Forest Avenue Consumer Advocate Office of Ambler, Pennsylvania 19002 Attorney General 1425 Strawberry Square Mr. Robert L. Anthony Harrisburg, PA 17120 103 Vernon Lane Moylan, Pennsylvania 19065 W. Wilson Goode Managing Director Mr. Marvin I.
Lewis City of Philadelphia 6504 Bradford Terrace Philadelphia, PA Philadelphia, PA 19149 Steven P.
Hershey, Esq.
Judith A.
Dorsey, Esq.
Community Legal 1315 Walnut Street Services, Inc.
Suite 1632 Law Center Philadelphia, PA 19107 North Central Beury Bldg.
3701 North Broad Street Charles W.
Elliott, Esq.
Philadelphia, PA 19140 123 N.
5th Street Suite 101 Donald S.
Bronstein, Esq.
Allentown, PA 18102 1425 Walnut Street Philadelphia, PA 19102 Mr. Alan J. Nogee 3700 Chestnut Street Mr. Joseph H. White, III Philadelphia, PA 19104 11 South Merion Avenue Bryn Mawr, PA 19010 Robert W.
Adler, Esq.
Assistant Counsel Dr. Judith H. Johnsrud Commonwealth of Pennsylvania Co-Director, ECNP DER 433 Orlando Avenue 505 Executive House State College, PA 16801 P.O.
Box 2357 Harrisburg, PA 17120 Robert J.
Sugarman, Esq.
Sugarman & Denworth Thomas Gerusky, Director Suite 510 Bureau of Radiation North American Building Protection 121 South Broad Street Department of Environmental Philadelphia, PA 19107 Resources 5th Floor, Fulton Bank Bldg.
James M.
Neill, Esq.
Third and Locust Streets Box 511 Harrisburg, PA 17120 Dublin, PA 18917 Director Pennsylvania Emergency Management Agency Basement, Transportation and Safety Building Harrisburg, PA 17120 f
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- Hand Delivered Rdbert M.
Rader Counsel for the Applicant
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