ML20062F710
| ML20062F710 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/27/1982 |
| From: | CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | FRIENDS OF THE EARTH |
| Shared Package | |
| ML20062F697 | List: |
| References | |
| NUDOCS 8208120118 | |
| Download: ML20062F710 (1) | |
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Interrogatory 21:
This interrogatory asks Applicant to describe the extent to which data in the NWRA Environmental Report relating to its application before the DRBC was considered in preparing Applicant's Environmental Report.
Applicant objects to this interrogatory insofar as it goes beyond the three admitted contentions and addresses impacts beyond the Point Pleasant Pumping Station and Bradshaw Reservoir.
Applicant will review its files to determine if any data within the scope of the three admitted contentions contained in the NWRA Environmental Report were considered in preparing Applicant's Environmental Report.
Conclusion For the reasons discussed more fully above, the Board t
should sustain Applicant's objections and enter a protective order that the objectionable interrogatories need not be answered and that related documents need not be produced.
The Board should also proscribe further inquiry into the same irrelevant areas during the taking of depositions.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Troy B.
Conner, Jr.
Mark J. Wetterhahn Robert M. Rader Suite 1050 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 202/833-3500 Counsel for the Applicant July 27, 1982 8208120118 820809 PDR ADOCK 05000352 G