ML20058E233
| ML20058E233 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/23/1982 |
| From: | Sugarman R DEL-AWARE UNLIMITED, INC. |
| To: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| ISSUANCES-OL, NUDOCS 8207280103 | |
| Download: ML20058E233 (8) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.N ' M BEFORE THE ATOMIC SAFETY AND LICENSING B M
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In the matter of Ort"!CE OF SECRE
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Docket Nos.
560Q52JyOL SEP,vn
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PHILADELPHIA ELECTRIC COMPANY
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50-3534iiCH
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(Limerick Generating Station
)
Units 1 and 2)
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REQUEST FOR PRODUCTION OF DOCUMENTS OF DEL-AWARE UNLIMITED, INC.
Pursuant to the Order of the Atomic Safety and Licensi dated June 1,
1982, and the Letter Order dated July 14, 1982, and pursuant to the rules of the Nuclear Regulatory Commission published at 10 C.F. R. S 2.741, Del-AWARE Unlimited, Inc.
(" Del-AWARE") hereby requests that the following documents be produced by Ph Electric Company
("PECo"),
Applicant in the above-captioned proceedings, for inspection and/or copying by Del-AWARE at a ti place and in a manner to be agreed upon by PECo and D l me and s
e -AWARE DEFINITIONS As used in these Interrogatorids the following words shall the following meanings:
1
" Person" means any individual, corporation, association, council or similar organization' partnership, 2
" Technical Consultant" means a person or entity who has rendered advice or assistance to the Pennsylvania Department of 8207280103 820723 PDR ADOCK 05000352 g
PDR,
y
o,
g Environmental Resources
(" DER")
on the basis of that person or entity's expertise.
3.
" Document" includes any
- written, recorded or graphic material, however produced or reproduced, including, but not limited to:
the original or any copy of
- books, records,
- reports, correspondence, memoranda, notes, written communications, telegrams and cables, notes of oral or telephonic communications,
- diaries, schedules, calendars, graphs, charts, contracts, agreements, releases, appraisals, valuations, estimates, projections, work paper s, opinions,
- studies, analyses, summaries,
- booklets, circulars, bulletins, instructions, minutes or notes of meetings, resolutions, photographs, tabulations, questionnaires,
- tapes, surveys,
- messages, tables,
- drawings, sketches, financial statements, as well as any.other tangible things on which information is recorded in writing or sound or magnetically or in any other manner and includin underlying or preparatory material.
g supporting, 4.
" Identify" when used in reference to a natural person s
, means to state in the answer in each instance his/her full name, present or last known business address, occupation (including name of present employer) and position, if known.
5.
" Identify" when used in re'ference to a non-natural person means to set forth a description of the entity, identify its principal place of business, its officers, directors, limited partners,general partners, board or council members, 4
if any i
6
" Identify" when used in reference to a writing or document, means to state in the answer in each instance, (i) the date, type of M
4
document (e.g.,
- letter, memorandum, etc.),
- author, address, -all recipients, title and filing or identifying number, and (ii) the present or last known location and custodian of the document and all copies.
7.
"You" or "yours" means
- PECo, its
- servants, agents, representatives, and employees or anyone acting on its behalf.
8.
" Environmental Report" means The Environmental Report on the Neshaminy Water Supply
- System, prepared by the Neshaminy Water Resources Authority, Doylestown, Pennsylvania (February 1979) and/or the Environmental Report, Bradshaw Reservoir, Transmission Main, East Branch Perkiomen, and Perkiomen
- Creeks, prepared by Philadelphia Electric Company (July 1979).
9.
" Delaware River Basin Commission Level B Study" means a study a
by that name prepared by the Delaware River Basin Commission.
INCORPORATION BY REFERENCE s
This Request for Production of Documents incorporates by reference the Interrogatories of Del-AWARE Unlimited, Inc. Addressed to Applicant which were served this day on PECo and the other parties to this proceeding, and filed with the Secretary of the Nuclear Regulatory Commission and the Atomic Safety Licensing Board, pursuant to 10 C. F.*R.
$2.74 0 (b).
As used in the following Request for Production of Documents, the term " Interrogatory No.
shall mean the designated Interrogatory set forth in the above-described Interrogatories..
o DOCUMENTS REQUESTED TO BE PRODUCED 1.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 1 (a) -(i), or which PECo referred to or relied on in responding to such Interrogatory.
2.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 2 (a) -(d), or which PECo referred to or relied on in responding to such Interrogatory.
3.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No.
3, or which PECo referred to or relied on in res-ponding to such Interrogatory.
4.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 4 (a)-(e), on which PECo referred to or relied on in responding to such Interrogatory.
5.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 5 (a)-(f), or which PECo referred to or relied on in responding to each Interrogatory.
l 4 l.
i 6.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 6 (a) - (f), or which PECo referred to or relied on in responding to such Interrogatory.
7.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 7 (a) - (b), or which PECo referred to or relied on in a
responding to such Interrogatory.
i 8.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 8 (a)-(b), or which PECo referred to or relied on in responding to such Interrogatory.
9.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No.
9, or which PECo referred to or relied on in res-ponding to such Interrogatory.
10.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 10, or which PECo referred ' to or relied on in res-ponding to such Interrogatory..
t 11.
Any and all docoments which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 11, or which PECo referred to or relied on in res-ponding to such Interrogatory.
12.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 12, or which PECo referred to or relied on in res-ponding to such Interrogatory.
13.
Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 13, or which PECo referred to or relied on in res-
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ponding to such Interrogatory.
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14, Any and all documents which refer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 14 (a) - (b), or which PECo referred to or relied on in responding to such Interrogatory.
15.
Any and all documents which r'efer or relate to, discuss, de-scribe, record or contain the information requested in Inter-rogatory No. 15, or which PECo referred to or relied on in res-ponding to such Interrogatory.
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and all documents which refer or relate to, discuss, de-f
%e, record or contain the information requested in Inter-i i
tory No. 16, or which PECo referred to or relied on in res-ing to such Interrogatory.
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and all documents which refer or relate to, discuss, de-i he,. record or contain the information requested in Inter-t i
lory No. 17 (a) - (b), or which PECo referred to or relied on psponding to such Interrogatory.
and all documents which refer or relate to, discuss, de-g ke, record or contain the information requested in Inter-i j
ory No. 18, or which PECo referred to or relied on in res-ng to such Interrogatory.
I Bnd all documents which refer or relate to, discuss, de-
- e, record or contain the information requested in Inter-I.
(ory No. 19, or which PECo referred to or relied on in res-
- ng to such Interrogatory.
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I hnd all documents which r'efer or relate to, discuss, de-record or contain the information requested in Inter-ry No. 20, or which PECo referred to or rel'ied on in res-hgtosuchInterrogatory.
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CERTIFICATE OF _ SERVICE 12 it 73 RU I hereby certify that 7 have served copies of the forh foregoing Request of Del-Aware Unlimited, Inc.
BRANCH of Documents by hand delivering or mailing the same to the following persons:
Lawrence Brenner, Esq., Chairman Administrative Judge-U.
S.
Nuclear Regulatory Commission Washington, DC 20555 Dr. Richard F. Cole Administrative Judge U.
S.
Nuclear Regulatory Commission Washington, DC 20555 t
Dr. Peter A. Morris Administrative Judge U.
S. Nuclear Regulatory Commission Washington, DC 20555 s
Stephen H. Lewis, Esquire Counsel for NRC Staff i
U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Edward G.
Bauer, Jr.
i Vice President & General Counsel Philadelphia Electric Company 2301 Market Street Philadelnhia, PA 19101 Troy B. Conner, Jr., Esquire Mark J. Wetterhahn, Esquire Conner and Wetterhahn 1747 Pennsylvania Avenue Washington, DC 20006 Secretary U.S. Nuclear Regulatory Commission ATTN:
Chief, Docketing p Service r.
Washington, DC 20555
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Robert J.
Sugarmana s
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