ML20062F710

Corrected Page 16 to Applicant Objections to Interrogatories & Request for Production of Documents,Correcting Inadvertent Transposition of Text from Another Page

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: ML20062F695 ML20062F710
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 PDR