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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20245L4191989-05-0404 May 1989 Graterford Inmates First Set of Interrogatories for Commonwealth of PA Dept of Corrections & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence ML20245L4941989-05-0404 May 1989 Graterford Inmates First Set of Interrogatories for Commonwealth of PA Emergency Mgt Agency & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence ML20238D1101987-12-29029 December 1987 Licensee Response to Request for Production of Documents by Air & Water Pollution Patrol Dtd 871207.* List of Available Requested Documents Provided.W/Certificate of Svc.Related Correspondence ML20238D0771987-12-29029 December 1987 Licensee Objections to Request for Production of Documents by Air & Water Pollution Patrol & Motion for Protective Order.* Request Re Records of False Activation of Monitor Alarms Requires Extensive Research.Certificate of Svc Encl ML20096E4661984-08-31031 August 1984 Supplemental Response to Applicant 840625 Discovery Request & Interrogatories Re Admitted Offsite Emergency Planning Contentions.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20096B4071984-08-30030 August 1984 Answer to Applicant First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20094C3131984-08-0303 August 1984 Revised Answer to Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions ML20094A6791984-08-0101 August 1984 First Set of Interrogatories & Request for Production of Documents to City of Philadelphia Re Offsite Emergency Planning Contentions City-18 & City-19.Certificate of Svc Encl.Related Correspondence ML20094C2121984-07-31031 July 1984 Answer to Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions (Discovery 35). Certificate of Svc Encl ML20094E5921984-07-23023 July 1984 Amended Answers to Util First Set of Interrogatories Re Offsite Emergency Planning Contention Lea/Foe 24.Certificate of Svc Encl ML20090D9621984-07-16016 July 1984 Response to Limerick Ecology Action Second Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Related Correspondence ML20093D4071984-07-11011 July 1984 Response to Limerick Ecology Action First Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20090A7091984-07-10010 July 1984 Objections to Limerick Ecology Action First & Second Sets of Interrogatories on Offsite Emergency Planning Contentions. Related Correspondence ML20090A7211984-07-0909 July 1984 Answer to First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Util & Certificate of Svc Encl.Related Correspondence ML20092P7691984-07-0303 July 1984 Second Set of Interrogatories & Request for Production of Documents to State of PA Emergency Mgt Agency on Admitted Offsite Emergency Planning Contentions.Related Correspondence ML20151K0601984-06-25025 June 1984 First Set of Interrogatories & Requests for Production of Documents to Limerick Ecology Action & Friends of the Earth Re Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20092P7761984-06-25025 June 1984 Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Certificate of Svc Encl. Related Correspondence ML20092K7191984-06-22022 June 1984 First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Certificate of Svc Encl. Related Correspondence ML20092J7561984-06-21021 June 1984 First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Notice of Appearance for M Mulligan & Svc List Encl.Related Correspondence ML20091K1841984-06-0101 June 1984 Answer Opposing Friends of the Earth 840518 Motion for Admission of New Late Contentions Re Applicant 840509 Motion for Expedited Partial Initial Decision & Issuance of Low Power License.Certificate of Svc Encl ML20091K1771984-06-0101 June 1984 Answer Opposing Del-Aware 840517 Proposed Late Contentions Re Applicant 840509 Motion for Expedited Partial Initial Decision & Issuance of Low Power License.Contentions Should Be Denied & Action Taken Against Del-Aware ML20084D9241984-04-27027 April 1984 Response to First Set of Interrogatories on Severe Accidents.Related Correspondence ML20088A4251984-04-0909 April 1984 First Set of Interrogatories & Request for Production of Documents to Limerick Ecology Action Re Severe Accident Contentions.Certificate of Svc Encl.Related Correspondence ML20088A4231984-04-0909 April 1984 First Set of Interrogatories & Request for Production of Documents to City of Philadelphia Re Severe Accident Contentions.Related Correspondence ML20087F2071984-03-12012 March 1984 Responses to Util Interrogatories on Contention I-42. Certificate of Svc Encl.Related Correspondence ML20086U0501984-03-0202 March 1984 Response Opposing Air & Water Pollution Patrol 840221 Request for Extension of Discovery Period for Contention VI-1.Certificate of Svc Encl.Related Correspondence ML20086U3431984-03-0202 March 1984 Response to Air & Water Pollution Patrol Motion to Compel Discovery.Applicant Denies That Answer to Interrogatory Evasive.Related Correspondence ML20080T9501984-02-27027 February 1984 Answers City of Philadelphia Interrogatories on Sys Interaction Contention.Certificate of Svc Encl.Related Correspondence ML20080R9931984-02-21021 February 1984 Answers to City of Philadelphia Interrogatories (Discovery 27).Certificate of Svc Encl ML20080N7201984-02-10010 February 1984 Motion to Compel Answers to Listed Interrogatories ML20080E8571984-02-0606 February 1984 Responds to Applicant First Set of Interrogatories Re Contention I-42.Certificate of Svc Encl.Related Correspondence ML20080E8031984-02-0606 February 1984 Interrogatories & Request for Production of Documents of City of Piladelphia to Util Re Sys Interaction.W/Certificate of Svc.Related Correspondence ML20080C5911984-02-0303 February 1984 Interrogatories 14-21 Re Environ Qualification ML20080C5961984-02-0303 February 1984 Interrogatories 22-30 Re Environ Qualification ML20080B8761984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-41.Certificate of Svc Encl ML20080B8301984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-41 ML20080B8201984-02-0303 February 1984 Second Set of Interrogatories & Request for Production of Documents on Contention I-42 ML20080B8081984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-42 ML20080A4501984-02-0202 February 1984 First Set of Interrogatories & Request for Production of Documents Re Limerick Ecology Action Onsite Emergency Planning Contentions.Certificate of Svc Encl ML20080B9231984-02-0101 February 1984 Answers to Twelfth Set of Interrogatories on Qa/Welding Contention (Discovery 24).Certificate of Svc Encl ML20080B9121984-02-0101 February 1984 Answers to Eleventh Set of Interrogatories on Qa/Welding Contention (Discovery 23) ML20080B8911984-02-0101 February 1984 Answers to Tenth Set of Interrogatories on Qa/Welding Contention (Discovery 25) ML20080A6251984-02-0101 February 1984 Answer to Applicant Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Related Correspondence ML20079S2721984-01-25025 January 1984 Answer to Sixth Set of Interrogatories on Qa/Welding Contention ML20079S2901984-01-25025 January 1984 Answer to Seventh Set of Interrogatories Re Qa/Welding Contention.Certificate of Svc Encl ML20079S2851984-01-25025 January 1984 Answer to Seventh Set of Interrogatories Re Qa/Welding Contention ML20079J4541984-01-20020 January 1984 Preliminary Set of Initial Interrogatories & Request for Production of Documents Re Onsite Emergency Planning Contentions.Certificate of Svc Encl ML20086J9981984-01-14014 January 1984 Twelfth Interrogatory Re Contention VI-1 (Qa/Qc).Documents, Logs & Repts on All safety-related Welds Requested ML20086J9921984-01-14014 January 1984 Eleventh Interrogatory Re Contention VI-1 (Qa/Qc).Details Pertinent to safety-related Pipe Failures Due to Freeze Induced Bursts Requested ML20079F2101984-01-13013 January 1984 Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Certificate of Svc Encl 1989-05-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20247L8591998-05-19019 May 1998 Confirmatory Order Modifying Licenses Effective Immediately Re Thermo-Lag 330-1 Fire Barrier Sys ML20203A1701998-01-30030 January 1998 Exemption from Requirements of 10CFR70.24 for Limerick Generating Station,Unit 1 ML20151L3671997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Orders That SA Blacklock Prohibited from Engaging in Activities Licensed by NRC for 5 Yrs from Date of Order ML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 ML20203H6891997-06-0202 June 1997 Transcript of 970602 Enforcement Conference in King of Prussia,Pa ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20080D8351994-12-22022 December 1994 Exemption from Certain Requirements of 10CFR50,App J Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors Allowing Continuation of Plant Operation within 24 Month Cycle ML20078K1441994-11-0909 November 1994 Exemtion Granted from Requirements of 10CFR73.55(d)(5) Re Returning of Picture Badges Upon Exit from Protected Area Such That Individuals Authorized Unescorted Access Into Protected Area Can Take Badges Offsite ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20062C6561990-10-22022 October 1990 Affidavit Requesting Withholding of Summary Rept on Evaluation of Recirculation Nozzle to Safe End Weld Indication & Proposed Disposition to Permit Unit 1 Cycle 4 Operation, from Public Disclosure,Per 10CFR2.790 ML20006D3821990-02-0606 February 1990 Comment on Proposed Rule 10CFR2 Re Policy & Procedures for Enforcement Actions;Policy Statement.Util Uncertain as to Whether Changes Necessary ML20246J4521989-08-30030 August 1989 Memorandum & Order (Terminating Proceeding).* Terminates Proceeding Per Settlement Agreement Between Limerick Ecology Action,Inc & Licensee.W/Certificate of Svc.Served on 890831 ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246F0121989-08-25025 August 1989 Memorandum & Order CLI-89-17.* Staff Authorizes Issuance of Full Power License to Licensee to Operate Unit 2 After Requisite Safety Findings Under 10CFR50.57 Completed. W/Certificate of Svc ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl ML20246E8351989-08-24024 August 1989 Second Supplemental Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission & Memorandum & Order of 890807.* W/Certificate of Svc ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20246C0271989-08-18018 August 1989 Notice of Appointment of Adjudicatory Employee.* Informs That D Nash Appointed as Commission Adjudicatory Employee to Advise Commission on Issues in Proceeding.W/Certificate of Svc.Served on 890818 ML20246B7721989-08-17017 August 1989 Correction of Memorandum & Order of 890815.* Advises That Refs to 49CFR2.730(c) on Page 1 & 49CFR2.710 & 49CFR2.711 on Page 2 Should Be Corrected to Read as 10CFR2.730(c),2.710 & 2.711,respectively.W/Certificate of Svc.Served on 890818 ML20246D7411989-08-17017 August 1989 Transcript of 890817 Meeting in Rockville,Md Re Discussion of Full Power OL for Facility.Pp 1-58.Supporting Documentation Encl ML20246B7751989-08-16016 August 1989 Memorandum & Order.* Denies Rl Anthony 890623 Request for Hearing for Intervention in Remand Proceeding & for Stay of Low Power Authorization.W/Certificate of Svc.Served on 890816 ML20246B7571989-08-16016 August 1989 Order Responding to Limerick Ecology Action Motion for Reconsideration.* Denies Motion to Reconsider,Stay,Suspend or Revoke 890707 Order on Basis That Order Appropriate.W/ Certificate of Svc.Served on 890816.Re-served on 890818 ML20246B7931989-08-15015 August 1989 Memorandum & Order (Request for Expedited Answer).* Denies Licensee 890811 Request for Expedited Answer from NRC & Limerick Ecology Action on Basis That Request Lacks Good Cause.W/Certificate of Svc.Served on 890816 ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H5991989-08-11011 August 1989 Memorandum & Order (Terminating Proceeding).* Dismisses Graterford Inmates Contention Re Adequacy of Training for Drivers Responsible for Evacuating Graterford & Terminates Proceeding.Certificate of Svc Encl.Served on 890814 ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7341989-08-0909 August 1989 NRC Staff Response to Commission Memorandum & Order of 890807.* Advises That NRC Will Provide Comments on Limerick Ecology Action 890814 Filing Prior to Commission Meeting Scheduled for 890817.W/Certificate of Svc ML20245F7291989-08-0808 August 1989 Affidavit.* Discusses Costs Incurred While Plant Inoperable. Allowance for Funds Used During Const,Security,Maint & Operational Costs Considered Proper for Calculating Costs for Delay ML20248D9241989-08-0707 August 1989 Memorandum & Order.* Extends Limerick Ecology Action Response Deadline to 890814 to Respond to Five Questions Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890807 ML20248D7871989-08-0303 August 1989 Correction for NRC Staff Response to Commission Questions.* Forwards Corrected Page 5 to NRC Response to Questions Filed on 890802,deleting Phrase by Nearly Factor 2.5 in Next to Last Line.W/Certificate of Svc ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20248D5391989-08-0202 August 1989 Affidavit of MT Masnik.* Advises That Author Prepared Response to Question 3 ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 ML20248D4721989-08-0202 August 1989 NRC Staff Response to Commission Questions.* Provides Info for Use in Commission Effectiveness Review of Plant Full Power Operation,Per Commission 890726 Memorandum & Order. Supporting Affidavits Encl ML20248D6451989-08-0202 August 1989 Affidavit.* Advises That Author Read Responses to Request for Comments by NRC & Knows Contents.W/Certificate of Svc ML20245J1321989-07-27027 July 1989 Transcript of 890727 Meeting in Rockville,Md Re Facility Severe Accident Mitigation Issues.Pp 1-130.Supporting Info Encl 1998-05-19
[Table view] |
Text
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mm> mmm>s==
AIR and WATER fl#fdEo Pollution ' Patrol si sg>
. BROAD AXE, PA.
Ni *01 Sept. 3, 1982 Cfr/cg Troy B.
Conner, Jr., Esq.
CEET Gh$AEIA g
Conner and Wetterhahn 6.
"E4NCH f
1747 Pennsylvanla Ave., NLJ gg;gp,C %M Washington, DC 20006 PROD. 3,, UTIL GC-
Dear Mr. Conne r:
Pursuant to the Limerick Board's order concerning informal discovery of existing documents, Air and Water Pollution Patrol requests the following re Weather Modification (carburetor ice)
--Contention V-4 Applicant asserts there will be "little or no effect" on weather modification as it relates to carburetor ice' danger to aircraft resulting from the release of 35 million gallons of water (as vapor) per day, and which may accumulate in the imme-diate Limerick reactor-Pottstown area, ordinarily, and more par-ticularly when natural stagnant conditions exist.
In particu-
- lar,
(
(A)
Provide documentation relating to P.E. "s studies j
which took into consideration how mang? or less days in j
the past 10 years the dew point was 5 i
than the air temperature.
h (B)
Show documentation that demonstrate that P.E.
took into consideration. (re added moisture build up or accumulation possible from the ' cooling tow-ers) the number of days within the 'past t'en years that fog existed in the Pottstown-Limerick area making ground level visibility less than one mile;.
less than mile; less than % mile; less than 500 ft.; less than 300 ft.
(C)
Provide documentation that PE's studies included the number of days within the past ten years that the cloud ceiling was 1,000 ft'. or less, and the visibility in the Pottstown-Limerick area (as a measure of accumulated moisture 'in the ait) was 4 miles; 3\\ miles'; 3 miles.-
(D)
Provide existing studies that indicate no potential for carburetor ice formation or other adverse eff-ects on aircraft from accumulation of 35 million gallons per day of moisture from the Limerick tow-ers under stagnant naturally saturated conditions present 2 3, 4, days or more in a row from r bru-e ary throug,h April and from September through Nov-ember.
8209130140 820903 PDR ADOCK 05000352 o
l l
T)S O 3 i
AIR and WATER P'ollution Patrol BROAD AXE, PA.
(2)
Letter to Troy B. Conner re: informal discovery of existing doc-uments--Contention U-4....contd.
(E)
Provide existing studies that the Applicant has made to insure there will be no adverse effects (as it relates to accumulated moisture) which could increase potential for carburetor ice, as referenced on gps 15, 17, 14, and 25 in " Aerology Series No.
1, Ice Formation on Aircraf t" Bureau of Aeronautics, U.S. Navy". (Pages enclosed)
(F)
Provide documentation and/or studies that in dia cate how many days during 1981 (1) the dew point was reached within 1,3,5,7. 10 miles of the Limerick reactor and (2) the dew point was within 1,3,5,7 degrees F of the air temperature in the Limerick area.and (3) please provide documentation to show grams of moisture per liter of air on days (a) when dew point was Qithin 1, 3, 5 degrees F of air temperature and (b) on days when air is stagnant and saturated, how much moisture is added per liter in a volume of air 1,000 fe.et high and 1 mile square with tower water vapor releases accumula ting 1,2,3,4,5 and 6 days.
(4) Please provide tables and data used.from which (1), (2), and (3a) and(3b) above were determined.
(G)
Provide documentation to show (a) values you received on studies to show how of ten plume h61ght with south east winds would be 1,000 feet or under at 2,3,4,7 miles from the Limerick towers.
(b) number of days north north west (NNW) wind blows directly toward Perkiomen Airport traff-ic pattern, approximately 6 miles from site, when plume cannot evaporate and layers 600 to 1000 feet above the ground as per LGS EROL.
(H)
Provide documentation on studies P.E. has done to show there would be no " chimney" effect, namely, there would be no rising hot air from the towers to cause descending air currents to create wind shear in the Pottstown-Limerick area to augment carburetor ice danger.
c' AIR and WATER Pollution LPatrol BROAD AXE, PA.
(3)
Letter to Troy B.
Conner re: informal discovery of existing doc-umen ts--Con ten tion V-4.... contd-(Il Also provide all correspondence by P.E. or any agency, group, or individual representing P.E.,
with Perkiomenville Airport and Pottstown Munici-pal Airport or any of the two airports owners, representatives, (legal, financial or otherwise) from 1974 to the present, regarding potential eff ects of the Limerick plant on operation and use of the airports.
(J)
Further, provide copies of contracts, agreements, leases or arraingements P.E. has made with oper-ators or owners of Pottstown-Limerick, Limerick Municipal, and Perkiomenville airports.
(K)
Provide documentation on purchase by P.E. of the Pottstown-Limerick Airport, amount of purchase and correspondence with PhilaElatric. Board of Directors and former owners of the Pottstown-Lim-erick Airport relative to reason for purchase.
Respectfully submitted, R
pno--AWPP Encl.osure; 11).
Interogatories re Blasting. (VI-1)
(21 Interogatori.es re Welding Infractions (VI-1).
(.3)_ Interogatories re Neutron Fluxes, e t c. (VI-1)_
l l
(L)
Re LGS EROL 5.1. 4. 3.1 (p 5.1-24) per table 5. ll, Quote :
l
" The main point to be drawn from table is that on days when plume does not evaporate while rising, it will level off at an elev-ation several hundred meters above ground, and in most cases augment an alregdgggxh45hngo lagg deck.
When the Limerick winter mo,rning c
plumes docum8nced b_y Kfamer et al (Ref. 5.1-41 of LGS EROL) a slight preferance' for lower rises is noted at Limerick". (Underlineing by
- v. Romano) Please provide documentation that the above indication of ceiling under 1000 f t.
with moisture content, augmente d by plumes from Limerick, that there will be no adverse affect on aircraft, including high potential for engine failure with possible fatal con-l sequences, due to carburetor ice caused by the Limerick operation.
I certify that service list was served by first class mail this date.
AIR and WATER Pollution Patrol BROAD AXE, PA.
Sept. 3, 1982 Troy B. Conner, Jr. Esq.--re: Docket No 352-353 (Contention VI-1) 6 Enclosure #1 Interogatories re: Quarry Blasting.
(1)
Provide all documents and correspondence with Trap Rock Quarry Co,.,. be tween Jan 1, 1970 and Dec.,3I',
1976 re operation of quarry adjacent to Limerick reactor site, in particular as it relates to blast-ing activity at quarry.
(2)
Provide all correspondence and reports from Bech-tel Corporation and Dames and Moore relating to fractures beneath the reactor site.
(3)
Provide documents used to conclude that the sub-rock integrity was more than just adequate, with-out a doubt.
(4)
Provide documents, reports, letters etc. showing effects of quarry blasting, and blasting by App-licant, on homes adj acent to the quarry and re-actor site.
(5)
Provide documents and/or information that Appli-cant and Trap Rock Quarry co-ordinated blasting times with concrete placement times so as not to a f fect setting of recently placed. concrete.
[
i (6)
Provide documents to show seismic effect of quarry l
blasting on geology of the Limerick site over the past 50 years, 20, years, and in particular during 1970-1-2-3-4-5-6.
(7)
Provide documents or reports Applicant used to -
demonstrate concussion effect of blasting could not be transmitted to reactor location because of rock configuration.
e (8)
Provide document's'on tests which prove (sketches
[
not wanted) the Limerick reactor coundations are stratigrophically lower than the Trap Rock Quarry.
i (9)
Provide records which show the exact da t e, and the geologist (s) who first made the above finding (8)...
and written nrocedure used to establish the conclu-sion without' a doub t.
v AIR and WATER Pollution Patrol BROAD AXE, PA.
Sept. 3, 1982 Tro'y B.
Conner, Jr., Esq.--Re: Docket No 352-353 (Sontention VI=ll Enclosure #2 Interogatories on Welding Infractions:
(1)
Provide all correspondence from the Nuclear Reg-ulatory Commission to Applicant and contractor, and sub-contractor including Bechtel Corporation and vice versa regarding infractions in welding procedures during construction of the Limerick reactor facility from 1974 to present.
(2)
Provide all documents or reports on infractions found in tool use recording and records.
(3)
Provide all documents on infractions of "use as is" rule as it relates to welding and associated activities, in particular, with the Unit I reac-tor core and containment drywell wall.-
(41 As it relates' to infractions identified during site insnection of Oct. 16, 19-22., 1976 reported to Acolicant's Vincent Boyhr in letter of Nov. 10 19.76.(Report No. 50-Y53 / 76l0.6)_ please provide job work record of, inspector who accented the deficient welds,. including name of employer, length of ' time employed at Lim-e rick, and qualifications to inspect wel'as.
. (.5 )
Further', provide ' record indicating date separated from position as in s pector, also provide employment ~ records inclu-ding -unemployment compensation record, if any...and record to show inspector no longer is employed by same ' contractor.
(6)
Vin cent Boyer's letter, Res'ponse 1(b), discusses one in s pe c tor.
Provide record of licensee ~ inspector, and disposition of his negligence.
(7)
Provide record of all welds accepted by inspector who accented welds at elevation 253, colums 23G and M, and provide record showing percentage 'of welds inspected by inspector in. (6) above that were reinspected.
(8)
Please nrovide following documentation.re 76-06-01; QCIR-0-201-N-1-8; c-41A-515-3; QCIR-0-204-W-1-2; C-41A-657-3;PI-A-Lh and 0-201-U-1-8.
(9) Please provide 4ocuments,.dealivery slips, etc. showing shipmen'ts involved with. welded pipe worked on ~ or receive'd from assoc-isated Piping & Engineer'ing and with records of amounts, and, rec ~or/or ITT Grinell Industrial Pining ds; where 'in the Limerick reactor fac-ilityjall pipe' referred to above was or~is to be used.(Re Doctored radiographs on welds from abovel.
s AIR and WATER Pollution Patrol BROAD AXE, PA.
Sept. 3, 1982 f
Troy B. Conner, Jr., Esq. --Docket No 352-353 (Contention VI-1) h Enclosure #3 Interogatories re: Neutron Fluxes (1)
Provide documentation on studies re thermd shock vs neutron fluxes at reactor pressure temperature boundry of BWRs equivilent tb Limerick.
Give data including name of reactor, rating in KW or MR, in-strumentation, time span and data gathering, and any other recorded information. -
(2)
Provide record of study of neutron fluxes at the wall of the BWRs such as Limerick prior to oper-ation.
If available give date calculated, results, name of software program, name of hardware that sof tware program was run on, comparison to meas-ures data, justifications for discrepancies be-tween measured and calculated data if any.
(3)
Provide studies done,. if any, on geometires and materials that fluxes would have to penetrate between fuel and wall before flux could irradiate wall.
(4)
Provide record, dates and individual (s) responsi-ble for original calculations or data gathering in all the above answers.
(5)
Provide record of " test cunons" irradiated and tested in BURS, including kocation where -cupons were placed during irradiation and name, location, rating in MN of reactor.
t I
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