ML20070R180
| ML20070R180 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/24/1983 |
| From: | Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8301270321 | |
| Download: ML20070R180 (32) | |
Text
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LAW OFFICES TfD GONNER & WETTERHAHN, P.C.
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January 24, 1983 (203)833 3500 CABLE ADDRESS: ATO MLAW Judge Lawrence Brenner Judge Richard F. Cole Atomic Safety and Atomic Safety and Licensing Board Licensing Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Judge Peter A. Morris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 Gentlemen:
I have been asked by coansel for the NRC Staff and counsel for Limerick Ecology Action, who is coordinating discovery matters for the intervenors, to submit the joint report on informal discovery requested by the Atomic Safety and Licensing Board in its orders of June 1 and October 20, 1982.
I am attaching letters from Ms. Dorsey dated January 17, 1983 and Ms. Hodgdon dated January 21, 1983 which state their positions regarding the Board's inquiries.
In subsequent telephone conversations, Ms. Dorsey asked that I
report the following additional items to the Licensing Board.
(1)
Marvin Lewis has stated that he has made oral requests to the Philadelphia Electric Company for certain documents which have all been provided to him.
He wishes this informal process to continue.
i i
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Judga Lt.wrenct Brenner.
Judge Richard F. Cole 3 Judge Peter;A.-Morris January 2.
4,a1983 Page 2:
(2)
Limerick Ecology Action has- ' requested documents.-
from the._
Department
.of.
Environmental Resources?of:the Commonwealth of Pennsylvania trelated to emergency planning.
The requests were for. the
" implementing procedures. for. Annex E of the Disaster Operations Plan ' of the. Commonwealth of Pennsylvania
.related to' fixed nuclear facilities.
As detailed in the letter from Robert-W.
- Adler, counsel for _the Commonwealth of Pennsylvania, to Charles _ W.
all Ellictt dated January; 18,.1983 sent to the ' service list, requests have:been fulfilled with the exception of a revised procedure which is to be sent when available.
1 In' addition to the information' provided by the intervenors
'and NRC
- Staff, the following represents Applicant's comments on the status of discovery:
'(1)
In response to the discovery requests filed by Limerick Ecology Action and the two filed by Mr.
Romano, over 150,000 pages of material is being made
.available:for inspection in Philadelphia.
.In order to
. assure that : the Board and - parties are aware of the
~
status of this effort, my letters to Ms. Dorsey and Mr.
r l
Romano are attached.
(2)
The Applicant's response to the Friends of the Earth December 17, 1982 request for documents is expected to be sent.this week..
I (3)-
Applicants do not object to the continuation of -informal discovery-for a reasonable period, but will request formal ' discovery under the Commission's-rules as necessary and appropriate.
Counsel for Limerick Ecclogy Action and Applicant have agreed that it would be premature te request formal discovery and take dispositions of Limerick Ecology Action's potential witnesses at this time.
(4)
In fulfillment of the requirement that the parties-shall
" jointly identify portions of the application - for which information had not been fully provided by the Applicant prior to the special prehearing conference for which essentially complete information is available~at the time the joint report is_ filed,"
the information in Appendix A
- hereto, I.
categorized by contentions admitted by the Licensing
- Board, is submicted by Applicant.
For a number of
'y
.-or- -, - -
..----m
Judge L;wrenco Brennor Judge Richard-F.= Cole
-Judge Peter.A. Morris January 2 __
'4, 1983
'Page 3 the.
contentions, Applicant believes that its application-for an operating license including the Final Safety Analysis Report, ' Environmental Report Operating License
- Stage, fulfills all regulatory-requirements _
without additional information.
Nevertheless,-Applicant will-submit' specific testimony as to its position - on these matters.
The indication-.
that material is complete also does not imply that the NRC Staff may not in the future ask its customary additional questions _concerning the subject material.
Sincerely, e
-Mark J. Wetterhahn Counsel ~for Philadelphia Electric Company MJW:sdd Enclosures
e APPENDIX JL
. COMPLETED-PORTIONS OF THE APPLICATION RELATED TO ADMITTED CONTENTIONS Contentions Status Contentions I-1 Applicant's Probabilistic Risk through I-32 (PRA)
Assessment is complete.
Additional information on certain of these contentions will be found in an-Environmental' Report Operating License _ revision to respond to NRC questions regarding compliance-with "NRC Interim Position on Accident Considerations Under NEPA" to' be submitted in a
March,-1983.
Item under Contention I-33E, response to-Section III.D.l.1 is complete.
Contention I-35 Complete Contention I-39 Complete Contention I-40 Complete Contention I-41A Complete
' Contention I-41B Complete Contention I-43A Complete Contention I-44 Complete Contention I-46 Complete Contention I-58 Complete E
Contention I-59 Complete Contention I-60 Complete Contention I-60A Complete Contention I-60B Complete L
4 la.
.e Contention Status Contention-I-60C Complete r
Contention I-60D
.Completo
- Contention-I-62 Complete
. Contention V-3a Complete Contention V-3b Complete.
Contention V-4
. Complete Contention V-8' Complete a
JAN 21 1983 e
~JUDrrH A. DORSEY MW OFFICES 1315. WALNUT ST SUITE 1632 PWTT.AnELPHIA. PA.19107 215 738 7200 January 17, 1983 Mark J.-Wetterhahn,-Esq.
Conner and-Wetterhahn 1747 Pennsylvania Ave., NW Washington, DC 20006 Re:
Limerick Generating Station, Docket Nos. 50-352, 50-353
Dear Mr. Wetterhahn,
Pursuant to the NRC Licensing Board's Orders of June 1 and October 20, 1982, I request that the following report be included in the joint report to the Board on informal discovery, due January 24:
Status of Informal Discovery Requests of Intervenors as of 1/17/83 Four intervenors/ consolidated intervenors have submitted informal discovery' requests to the Applicant (PECO) and/or the NRC staff.
1)
Robert Anthony (FOE) submitted a request for documents related to his contentions V-3A and V-3B on Nov. 22, to PECO.
He has not yet received a reply.
2)
Marvin Lewis submitted a request to the NRC staff on August 18, 1982, related to his contention I-62, pressurized thermal shock.
On Sept. 23, Mr. Lewis was informed by the staff that his request did not meet the guidelines for informal discovery as outlined in the Board's June 1, 1982 Order, and that his questions would be answered when formal discovery began.
Additional information has come to Mr. Lewis' attention recently that leads him to believe that informal discovery to PECO on this matter would be beneficial.
Thus Mr. Lewis requests that informal discovery continue.
to -
Wetterhahn, page 2 3)~.Mr.-Frank Romano and Mr. Marvin Lewis jointly submitted i
discovery requests (through Mr. Romano) on-Sept. 3 and Sept. 23, 1982, related to contention VI-1, quality assurance / control.
InEa letter received on January 17, 1983, PECO stated its
' intention-to.make available those documents responsive to the
-request, at a site near PECO headquarters in Philadelphia.
Since the' documents will not be available for-inspection and
~;
copying until January 19, Mr. Romano _and Mr.' Lewis request that informal discovery be per.itted to continue -- it may be that i
additional such discovery would be useful after they have had Lthe opportunity to review t..e documents thus far offered.
1 It should also be mentioned that it appears that some of intervenors' requests related to contention VI-l have been misinterpreted or misunderstood.
Further informal discovery will provide the opportunity for clarification.
o 4)
Mr. Frank _ Romano submitted requests concerning his contention V-4, on carburetor icing, on Sept. 3 and Sept. 23,
,L_
1982.
'In a letter received January 17, PECO responded as in item #3 above.
5)
On August 26, _1982, LEA submitted a discovery request on contentions I-59'and -60 to the NRC.
(These contentions relate to the setting of design basis for-Limerick, and_to the control of radioactive releases from the site, respectively.)
On January 17, 1983, the NRC. staff indicated by phone that a response;would be forthcoming.
6)
On August 26, 1982, LEA submitted to PECO a series of discovery requests related to its PRA contentions, its accident monitoring ~ contentions, and contentions I-33A and I-43.
7 By-letter received January 14, PECO responded as in item #3 l.
above.
7)
On~ December-29, 1982, LEA made a discovery request to the NRC related to PRA contentions.
LEA has been-informed that the NRC is presently-working on a response to that request.
Due to the fact that responses to various discovery requests made by intervenors are only recently beginning to arrive, I request that informal discovery continue.
-Mark and Ann:
Please let me know if you have any problems with the substance of the above.
If not, please include it along with the NRC estimated release dates for NRC review documents and PECO's status report on incomplete application sections.
Thanks.
l l-p%ncerely,0
%dtL dith A. Dorsey v
J xc: Ann Hodgdon l-
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LAW OFFICES '
GONNER Oc WETTERHAHN. P.C.
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. coszar M. runt January.20, 1983 (soa l soo-seoo CABLE ADDRESS: ATo M LAW
~ Judith A. Dorsey, Esq.
Suite 1632-1315 Walnut Street Philadelphia,~ Pennsylvania 19107 In the hatter of Philadelphia Electric Company (Limerick Generating Station, Units'l and 2)
Docket Nos. 50-352 and 50-353
Dear Ms. Dorsey:
This letter is a followup to my: letter of January 11, 1983 to you and cur-telephone conversations of January 14 and 20, 1983 regarding the status of' the Philadelphia Electric Company's response ~to your August 26, 1982 informal discovery request.
The material'being made available for your review next Week represents - 150,000 pages of material.
As you are aware,.certaili of the documents related to the Limerick i
Probabilistic Risk Assessment are proprietary to the General Electric ~ Company.
Proprietary material, including computer i
. input'andioutput, has been so-designated and segregated and will-be - made available for your inspection and duplicated for your 'use in accordance with the proprietary agreement i
which you have executed.
I have forwarded to Mr. Elliott, who I understand from you will be reviewing the documents L
being made available, an agreement regarding disclosure of l-this information to be executed and forwarded to the General Electric' Company for approval.
With regard to your request to inspect the third volume of the Design Assessment Report, while the consent of one of the owners of the information has been obtained, the other owner, KWU, has not yet responded.
I will endeavor to make this material available to you as soon as possible.
As we discussed on January 14, 1983, the Company will endeavor to make any large-size drawings' associated with the i
,+ -
Judith A.-~Dore;y, Erq.
' January 20, 1983
-Page 2 Probabilistic Risk ~ Assessment available for your inspection lshould you so' desire.
Finally, for your information, the cost to reproduce a microfiche is 300 per fiche.
'If you have any questions concerning any of these
- matters,.please let me know.
Sincerely, E Y)
Mark J.'Wetterhahn Counsel for Philadelphia Electric Company MJW:sdd 4
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LAW OFFICES CONNER 8e WETTERHAHN. P.C.
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January 11, 1983
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CABLE ADDRESS: ATOMLAW '
Mr. Frank-Romano.
Air and Water Pollution Patrol 61 Forest Avenue Ambler, Pennsylvania 19002 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353
Dear..Mr. Romano:
This letter is reply to your - September 3,
1982 and September 23, 1982 letters to Mr. Conner concerning informal discovery in the_ captioned proceeding.
In order to keep track of discovery items, we have designated your September 3 and September 23 letters " Discovery 2" and " Discovery 3,"
respectively.
All classes of documents which ' are being produced are labeled accordingly..
The documentary material responsive to your request in the Company's possession as described below will be made available for your' inspection during normal business days from - 9 :00 a.m.
to 4:30 p.m.
beginning next Wednesday at a
room near Philadelphia Electric Company's headquarters.
'Please call Edward Cullen, Esq. at 215/841-4273 to make specific arrangements at-least one day in advance in order to gain access to the documents.
Any copies that you wish made of this material as the result of your review should be marked and copies will be made at the commercial rate of approximately 70 per page.
Hard copies of microfiche will be made at a rate of approximately 350 per page.
The
.following information explains the Company's responses to your requests.
Discoverv 2 1.
Items A, B,
C, E,
F and G - Philadelphia Electric Company does not have any documentation which is responsive i
to your requests in these paragraphs.
As you are aware, there are summariets of meteorological data contained in the Final Safety Analysis Report
("FSAR")
and Environmental Report Operating License Stage
("ER-OL").
We are also providing a four volume document entitled "Micrometeorologi-l
\\.
-4 Mr.-Frank Romanc January 11, 1983 Page.2 cal Data and Analysis for the Limerick Generating Station Environmental Report Operating _ License Stage and Final Safety Analysis Report Submittals."
This document supple-ments the information in the FSAR and ER-OL and cresents summary and frequency descriptions for the following meteorological, parameters:
Wind speed and direction Atmospheric stability Ambient temperature Temperature lapse rate Precipitation Relative humidity and dew point Joint frequency distribution of the above parameters Fog at National Weather Service stations located at Philadelphia and Allentown, Pennsylvania In addition to these summaries, Philadelphia Electric Company has on magnetic tape the raw data for a ten year period, with measurements made on an hourly basis from the onsite meteorological instrumentation.
While it would be costly, the Company would be willing to provide, at your expense, either a copy of the magnetic tapes or a printout of this data.
2.
Items D and L - While the Company has conducted no studies-specific to the Limerick Generating Station responsive to these requests, it is making available to you a document entitled " Chalk Point Cooling Tower Project, Salt Loading, Modeling, and Aircraft Hazard Study" by the Applied Physics-Laboratory of The Johns Hopkins University.
3.
Item H The Company declines to respond to this paragraph as beyond the scope of the contentions and not
-designed to lead to admissible' evidence.
4.
Items I,
J and K - Documents responsive to these re. quests are being provided.
A contract for electrical service with Pottstown Municipal Airport is not being provided as being beyond the scope of the contention.
5.
Enclosure 1,
Item 1 No documents responsive to this request have been identified.
6.
Enclosure 1,
Items 2,
3, 4,
5 and 6 Documents responsive to this request are being provided.
- 7.,
Item 7 No documents responsive to this request have been identified.
However, see generally the documents produced in response to Items 2-6 above.
.~
- O Mr. Frank Romant January 11, 1983 Page 3 8.
Enclosure 1,
Items 8 and 9 The Company has not been able to determine the originator of rhe-sketch which was attached to the NRC letter to which you apparently refer.
- However, see cenerally the documents produced in response to Items 'ECT, anove.
~
9.-
Enclosure 2,
Items 1,
2 and' 3 Documents responsive to these requests are being provided.
10.
Enclosure 2,
Items 4,
5 and 6
Documents responsive. to these requests are being provided.
The Company is exploring whether and under what conditions, because of the need to preserve the individual's rights of privacy,'certain of the requested documents can be released.
- 11., Item 7 - Documents responsive to this request are being provided.
12.
Enclocure 2, Item 8 - No' documents responsive to this request have been identified.
However, see cenerally the documents prcduced in response to Items 2-6 above.
13.
Enclosure 2,
Item 9
No specific documents responsive to this request have-been identified.
- However, see cenerally the documents produced in response to Items T-"6 above.
It shoulc be noted that no safety-related welded pipe has been received from ITT Grinell Industrial Piping, Inc.
14.
Enclosure 3,
Items 1 Documents responsive to this request relating to the Limerick Generating Station will subsequently be produced for your inspection.
The ASME Code St:!ess - Report for the Limerick vessels is expected to be completed in late February at which time all documents responsive to your request will be made available for inspection.
Discovery 3 15.
Item 1 - Documents responsive to this request are being provided.
I ti.
Item 2 - See response to Item 14, above.
Sincerely, Mark J. Wetterhahn Counsel for the Applicant bec:
Eugene J. Bradley, Esq.
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I.AW OFFICES CONNER Sc. WETTERHAHN. P.C.
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January 11, 1983 lao *8 8= oaa CABLE ADDRESS: ATO M LAW Judith A. Dorsey, Esq.
1315 Walnut Street Suite 1632 Philadelphia, PA. 19107 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353
Dear Miss Dorsey:
This letter is reply to your August 26, 1982 letter to Mr. Conner concerning informal discovery in the captioned proceeding.-
In order to keep-track of discovery items, we hat a designated.your August 26 letter " Discovery
- 1. "
All classes of documents which are being produced are labeled accordingly.
The -documentary material responsive to your request in the Company's possession as described below will
- be made available for your inspection during normal business days from 9
- 00 a.m. to 4:30 p.m. beginning next Wednesday at a room -near Philadelphia Electric Company's headquarters.
Please call Edward Cullen, Esq.
at 215/841-4273 to make specific arrangements at least one - day in advance in order to gain access to the documents.
Any copies that you wish
-made of thi's material as the result of your review should be i
marked and copies will be made at the commercial rate of approximately 70 per page.
Hard copies of microfiche will l
l be made at a rate of approximately 350 per page.
The following information explains the Company *s responses to your requests.
Discoverv 1 1.
Item A.1 - As we discussed, first priority has been given to production of the input and output listing of the CRAC code.
Thi:s information is available for your inspection in microfiche form.
The remainder of the requested information is presently being segregated.
.-n.
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,' [ Judith-A. Dorca Ecquira
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January.11, 1983 Page 2 2.
Items A.2,
'A.4 Documents responsive _to this request in Applicant's possession are being provided.
As additional material is located in PRA contractor files, it will. be provided.
To the extent material within these categories -are claimed. to be proprietary, it will be
.. segregated and made vailable in accordance with the a
- Agreement Regarding Disclosure of Confidential Commercial Information executed-by you and your consultant.
4
-3.
Item A.3 Aside from the cited reference, no documents in Applicant's possession have been located which are responsive to this request.
.4.
Item B.1 - As further clarified by our discussion, the specifications, calibration
- report, acceptance test procedures, and vendor literature, as available, is being provided for the following systems:
Drywell High Range Monitor Standby Gas Treatment System
~
North Stack Broad Range Accident Monitoring System Main Steam Line Monitor
'MainLCondenser Air _ Ejector Off Gas Radiation Monitor 6.
Item C.1 The requested document is being j
provided.
- 7..
Item D.1 - As soon as approval for the form of a protective order is received from Pennsylvania Power &' Light Company and Kraftmark Union Aktiengesellschaft, I will send you a copy for execution after which the requested document will be provided.
Sincerely, O
W. s%
u l
Mark J. Wetterhahn l
Counsel for the-Applicant l
bcc:
Eugene J.
Bradley l-
. p.,'g JAN 21 igg 3 8'
o UNITED STATZs f,.,,.. - d, l' i NUCLEAR REGULATORY COMMISSION i
wAsmucron. o. c. 20sss 1, '~
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January 21, 1983 Mark J. Wetterhahn, Esq.
Conner and Wetterhahn 1747 Pennsylvania Ave., N.W.
Washington, D.C.
20006 In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Jocket Nos. 50-352 and 50-353
~
I
Dear Ml. b Carffs n,
Pursuant to the NRC Licensing Board's Orders of June 1 and October 20, 1982, the NRC Staff requests that the folicwing infomation be included in the joint report on infomal discovery to be submitted to the Board on. January 24, 1983:
Status of Informal Discovery and Current Estimated Schedule for Issuance of the Staff's Draft and Final Environmental Statements, Safety Evaluation Report and Review of Probabilistic Risk Assessment 1)
The NRC Staff has not addressed any informal discovery requests to intervenors.
2)
On January 20, 1983s the Staff filed written responses to LEA's requests for. informal discovery dated August 26, 1982, and December 29, 1982.
3)
The status of responses to intervenors' requests of the Staff other than those noted in (2) is as stated in the section of this report entitled Status of Informal Discovery Requests of Intervenors.as of 1/17/83.
4)
In view of the fact that intervenors have requested that informal discovery continue and that it has been working successfully, the Staff believes that it should continue.
l
2 5)
The current estimated schedule for issuance of.the Staff's documents is as follows:
Review of the Limerick Generating Staticn Prob 3bilistic Risk Assessment issued as a NUREG document............................ March 11, 1983 Draft Environmental Statement issued......May 1983 4
Safety Eval ua ti on Repo rt i s sued............ Augu st 1983 Final Environmental Statement issued...... 0ctober 1983.
The estimated issuance schedule for documents other than the PRA Review has not changed since the Staff previously reported to the Board regarding this matter.- The circumstances surrounding the delay.in the issuance of the PRA Review are a
set forth in the attached memoranda.
If.you believe that the information as stated above is incomplete or incorrect, please let me know. Also, in view of your offer to compile and coordinate the joint report, please feel free to make adjustments l
as necessary to suit the format of your choice.
Sincerely, M
OC Ann P. Hodgdon Counsel for NRC Staff l
Attachments: As stated cc: Judith. A. Dorsey, Esq.
I-
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UNITED STATES
~]
NUCLEAR REGULATORY COMMISSION
'~
h-E WASHINGTON. D. C. 20535 JAN ~ 2 0 1c83 MEMORANDUM-FOR:
Darrell G.- Eisenmrtr Director -
Divi' ion of Licensing s
.Themis Speis, Director
'Di' vision of Safety Technology FROM:
Al Schwencer, Chief-Licensing Branch No. 2 Divi-sion of Licens-i.ag- ~- --
Ashok Thadani; Chief Reliability and Risk Assessment Branch Division of Safety Technology
SUBJECT:
REVISED SCHEDULE FOR CONTRACTOR REPORT FOR LGS PRA
~
The Erookhaven National Laboratory, under contract TIN A-3393, is preparing a report for RRAB that' evaluates the Probabilistic Risk Assessment on the
-Limerick' Generating Station.
Brookhaven has requested an additional delay in issuing the report owing to the diversion of their resources to work on
~
the hearing support for the Indian Point plants.
The Accident Evaluation Branch.is being provided with the support because the present consequence analysis on the Indian Point plants is considered obsolete (F. Rowsome, RES, to R. Mattson, DSI, 11/30/82).
The Indian hint plant's_ consequence analysis needs updating because (a) there are new accident sequence likelihoods, (b) design and procedure changes have altered the dominant contributors, (c) errors were discovered in the
~
characte'rization of two release categories of the conventional source term, and'(d) the coupling of the emergency response model to both inte,rnal and external accident initiators has been discovered to be-important.
S e
O g
e 9
i m -
/
n
{.
The resulting delay in the Brookhaven report on the Limerick PRA is estimated to be about three weeks.
We recommer.d that the final report
- milestone be changed from February 18, 1983 to March 11, 1983.
Also, we recommend that the Limerick Board be notified concerning the delay.
)
/8&
~ -~
'Al Schwencer, Chief Licensing Branch No. 2
' ~~ ~
~
Division of Licensing p
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/
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f Ashok Thadani, Chief Reliability and Risk Assessment Branch -
Division o'f Safety Technology cc:
M. Ernst
~
- 7. Novak A. Hodgdon e
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BROOKHAVEN~ SATIONAL LABORATORY
{
QQg ASSOCIATED UNIVERSITIES, INC.
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x Upton. Long istcnd. New York 11973 (516) 282s 2435 y;
Cepcrtment of Nuefect Energy FTS 666'
- 3'l December 22, 1982
~
4 Erulappa S. Chelliah Reliability and Risk Assessment Branch Division of Safety Technology Mail Stop 216 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Erul:
Owing to the NRC need for BNL personnel to divert resources to work on other projects ir support of the Indian Point hearing, the milestones for the BNL final report on the " Review of the Limerick PRA" must change. As per discussions between R. A. 3ari (BNL) and F. Coffman (RRAB) this diversion of resources will -result 'in a forward shift of the milestone dates. As per our discussions the new milestone dates are as follows:
Submission of final draft to NRR February 4,1983 Receipt of NRC coments on final draft February 11, 1983
^
Submission of camera ready copy February 18, 1983 If you have any comments please let me know as soon as possible.
Best regards, J
) j
.UGb H
Ioannis A' apazodlou,Gro-Leader Risk Evaluation Group IAP/dm cc:
W. Kato R. Bari R. Hall W. T. Pratt A. Thadani A. Schwencer F. Coffman 4,
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NUCCEAR REGULATORY COM@lSSION
[ M 8-'$3 UNITED STATES et y-WASmGTON, D. C. 20555
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January 20, 1983 Judith A. Dorsey, Esq.
1315 Walnut Street, Suite-1632 Philadelphia, PA 19107.
In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353
Dear Ms. Dorsey:
This is in further response to Action.for informal discovery, your request on behalf of Limerick Ecology dated August 26,_1982,(attached),whichwas the subject of our telephone conversation of Monday, January 17, 1983.
The Staff is now engaged in preparing its Draft Environmental Statement (DES), which is scheduled to be issued in May,1983, and Safety Evaluation Report -(SER), scheduled for issuance in August,1983.
These documents, which will be made available to all-persons on the service list, will address the matters identified in your request for infonnal discovery.
You are no doubt aware that these matters were addressed in the FES and SER issued in connection with the Construction Permit proceeding for the Limerick station. Those documents can be found in the Local Public Document Room located in Pottstown, Pennsylvania.
Any other CP-stage documents which might relate to these matters would also be available in the LPDR at Pottstown.
Sincerely, m
W
~
Ann P. Hodgdon Counsel for NRC Staff
Attachment:
As stated cc: -See next page
, _. ~,--.-_,-.
..._m
2, f
.5 '-
, cc:
' Lawrence Brenner, Esq.
Robert L. Anthony Dr. Richard F. Cole Alan J. Nogee Peter A. Morris Charles W. Elliott, Esq.
Frank R. Romano W. Wilson Goode Edward G. Bauer, Jr.
Walter W. Cohen Troy B. Conner, Jr.,- Esq.
Robert W. Adler Mark J..Wetterhahn, Esq.
Steven P. Hershey, Esq.
Marvin I. Lewis Robert J. Sugarman, Esq.
James M. Neill, Esq.
Donald S. Bronstein, Esq.
Joseph H. White, III Atomic Safety & Licensing Board Dr. Judith H. Johs.srud Atomic Safety & Licensing Appeal Panel Thomas Gerusky Docketing and Service Section Dir. Pa. Emer. Mgmt. Agency 8
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y JUDrra A. DORSEY 1.Aw orrtcts 1315 WAI.NTJT ST., StnTE 1832 PEII.ADEI.PEIA. PA.19107 318 735.7304 August 26, 1982
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Stephen H. Lewis, Esq.
_75-T.'.
Office of the Executive Legal
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Director U.S. NRC
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Washington, DC 20555
Dear Steve,
Pursuant to the Limerick Board's order concerning informal discovery of existing documents, Limerick Ecology Action requests the following. materials:
Contentions I-59 and -60 All.NRC documents relating to any determination of " credibility" of Limerick accidents for purposes of acceptance'of design basis, or for determination.
of site acceptability under 10 CFR Part 100 (see 10 CFR 5100.ll(a), footnote 1).
I look forward to a prompt reponse to my request.
Sincerely,
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J dith d Dorsey Counsel for Limerick Ecology Action xc: Service list e
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January 20, 1983 Charles W. Elliott, Esq.
123 North Fifth Street Allentown, PA 18102 In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limericx Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353
Dear Mr. Elliott:
This is in further response to your letter of December 29, 1982 requastitig the Staff's issistance in obtaining copies of documents relating to the Staff's review of the Limerick PRA. (Letter attached)
Pursuant to our telephone conversation of January 17, 1983, copies of documents in the first category, consisting of thirteen documents identified by Central Files Accession numbers, will be placed in the Local Public Document Room at Pottstown, Pa.
The Staff has identified five documents as responsive to your request in categories 2 and 3.
Those documents are:
I (1) NUREG/CR-2934 (Sandia National Laboratories) Review and Evaluation i
oftheIndianPointProbabilisticSafetyStudy(IPPSS) l l
(2) Sandia's August 25, 1982 Letter Report on the IPPSS (3) Sandia's March 5,1982 Letter Report on the Zion Probabilistic Safety-Study l
(4)
Brookhaven's Peer Review of the IPPSS i
(5) Brookhaven's Peer Review of the Zion Probabilistic Safety Study These documents will be placed in the LPDR at Pottstown, as will a transcript of the ACRS meeting held on November 3,1982, abcut which we spoke on the telephone January 17.
That meeting concerned the Sandia review of the IPPSS and Brookhaven's review of the Limerick PRA.
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, The printouts constituting the fourth category of documents which you have requested have not yet been pulled from Brookhaven's files.
Brookhaven personnel associated with the Limerick PRA review have been engaged on a priority basis in updating the consequence analysis for the Indian Point plants.
As soon as Brookhaven personnel are available to address the matter, we will inform you of how the information you have requested in your fourth category may be made available.
Sincerely, pv OC W
Ann P. Hodgdon Counsel for NRC Staff
Attachment:
As stated cc:
Lawrence Brenner, Esq.
Robert L. Anthony Dr. Richard F. Cole Alan J. Nogee Peter A. Morris Judith A. Dorsey, Esq.
Frank R. Romano W. Wilson Goode Edward G. Bauer, Jr.
Walter W. Cohen Troy B. Conner, Jr., Esq.
Robert W. Adler Mark J. Wetterhahn, Esq.
Steven P. Hershey, Esq.
Marvin I. Lewis Robert J. Sugarman, Esq.
James M. Neill, Esq.
Donald S. Bronstein, Esq.
Joseph H. White, III Atomic Safety & Licensing Board Dr. Judith H. Johnsrud Atomic Safety & Licensing Appeal Panel Thomas Gerusky Docketing and Service Section Dir. Pa. Emer. Mgmt. Agency h
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December 29, 1982 Ann P. Hodgdon, Esquire United States Nuclear Regulatory Commission Washington, DC 20555 Re:.
Philadelphia Electric Co.
(L' merick) Docket i
Nos. 50-352,353
Dear Ann:
Pur'suant to the order of the Board concerning informal discovery of existing documents, I would appreciate your assistance in obtaining copies of the following_ documents:
(1) The following documents are apparently located in Central Files, are filed under the Limerick docket number as Category A Application /Censtruction Stage documents and correspondence and have been assigned the accession numbers on the left hand column:
Accession Number Date
-8008040023 7/29/80 8006120121 5/23/30
- 8008080565
~
7/15/80 8009230523 9/8/80 8010270176 10/2/80 8010270178 10/2/80
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8010300443 10/9/80 8011040503 10/27/80
^
8101160537-1/5/81 8101230140 1/5/81~
8103180770 3/12/81 8103300239 3/24/81 8103300262 3/24/80 The accession numbers are derived from the printout of titles of construction stage documents which the staff provided to the parties pursuant to Board order.
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Hodgdon,-Esquire December 29, 1982
.(2)
All reports from Sandia National Laboratory in its " Review of Detailed Reliability Analysis for Zion Units 1 and 2, Indian Point, Units 2 and 3, and Limerick".
(3)
All reports from Brookhaven National Laboratory pursuant to its " Review of Residual Risk for Zion Units 2 and },
Indian Point Units 2 and'3, and Limerick" (FINA-3347).
(4)
The computer printouts for each Limerick site s
specific CRAC code version run perform'd by Brookhaven National e
Laboratories, including the complete output of each ruri, including the printout of any recompilation of the CRAC version a
performed during the run, tha print back of all results, and copies of any sensitivity. studies or analyses made from any chEnges in input'for any run.
Thank you for your anticipated cooperation with.this request.
Very truly yours, CHARLES W. ELLIOTT CWE:seh xc:
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January 21, 1983 (20e i 833-3500 cAaLE ADDRESS: ATO M LAW Judith A. Dorsey, Esq.
Suite 1632 1315 Walnut Si:reet Philadelphia, Pennsylvania 19107 In the Matter of Philadelphia Electric Company (Limerick Generating Station,_ Units 1 and 2)
Docket Nos. 50-352 and 50-353-
Dear Ms. Dorsey:
As we discussed
- today, enclosed is an
" Agreement
-Regarding Disclosure of Confidential Commercial Information" relating to Volume III of the Design Assessment Report.
I would appreciate your review and execution of this agreement such that-the. report may be made available for your inspection.
Sincer
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Mark J. Wetterhahn Counsel for Philadelphia 4
Electric Company MJW:sdd Enclosure w/o enclosure
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1747 PENNSYLVANIA AVENUE. N. W.
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January 20, 1983 (sos) eco asco cAats ADomsss: AroxLAw Judit;h A. Dorsey, ' Esq. -
Suite 1632 1315 Walnut Street Philadelphia, Pennsylvania 19107 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353
Dear Ms. Dorsey:
This letter is a followup-to my letter of January 11, 1983 to you and our telephone ccnversations of January 14 and
'20, 1983 regarding the status of the Philadelphia
-Electric Company's response to your August 26, 1982 informal discovery request.
The material ~being made available for your review next week represents 150,000. pages of material.
As you are awarci cert.iin of the documents related to the Limerick Probabilistic Risk Assessment are proprietary to the General Electric Company.
Proprietary material, including computer input and output, has been so designated and segregated and
.will be made available for your inspection and duplicated for your use in. accordance with. the proprietary agreement L
which you have executed..
I have forwarded to Mr. Elliott, l
who I understand from you will be reviewing the documents I
being made available, an agreement regarding disclosure of this information to M executed and forwarded to the General
-Electric Company for approval.
l
.With regard to your request to inspect the third volume L
of the Design Assessment Report, while the consent of one of l
the owners of the information has been obtained, the other owner, KWU, has not yet responded.
I will endeavor to make this material available to you as soon as possible.
As we discussed on January 14, 1983, the Company will endeavor to make any large-size drawings associated with the
'E' ~ Judith A. Dorecy, Erq.
~Jcnuvry 20, 1983 Page 2 Probabilistic Risk Assessmant available for your. inspection l
should you so cesire.
Finally, for your information, the cost to reproduce a microfiche is 300 per fiche.
If you have. any questions concerning any of these matters, please -let me know.
Sincerely, Y
- Mark.J. Wetterhahn Counsel for Philadelphia Electric Company a
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January 24, 1983 (SOS) 833 3500 -
CABLE ADD SS: ATO M LAW Mr. Frank R. Romano 61 Forest Avenue Ambler, Pennsylvania 19002 a
In the Matter of
. Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2) s Docket Nos. 50-352 and 50-353
Dear Mr.. Romano:
As a followup to my letter to you dated January 11, 1983,-I wish to provide you the following information.
With regard to your September 3, 1982 letter, Enclosure 1,
Item 4,
Applicant has located a -number of documents responsive to the request which relate to claims made by individuals living near the Limerick site regarding quarry blasting.
These documents are being provided for your inspection.
- However, to maintain the privacy of the individuals involved
- the, names, addresses and other identifying information has been deleted.
~With regard to. Enclosure 2 of the September 3,
1982 letter, the Bechtel Power Corporation which was apparently
'the' employer of the individual involved and is custodian of
.all related records has stated that it is its policy not to release employment records except in respone to a subpoena or: other lawful process.
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Sincerely, b
Mark J. Wetterhahn Counsel for Philadelphia Electric Company l
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g' 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 IL hereby certify that copies of Applicant's Letter to the Licensing Board Regarding Informal Discovery dated a
January _24, 1983, in the captioned matter have been served
'upon the following by deposit in the United States mail this 24th day of January, 1983:
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 Ann P. Hodgdon, Esq.
Judge Richard F. Cole-Elaine I. Chan, Esq.
Atomic Safety and_ Licensing Counsel for NRC Staff
.' Board Office of the Executive U.S. Nuclear Regulatory Legal Director Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Judge Peter A. Morris Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Atomic Safety and Licensing Philadelphia Electric Company Appeal Panel ATTN:
Edward G. Bauer, Jr.
U.S. Nuclear Regulatory Vice President &
Commission
. General Counsel Washington, D.C.
20555 2301 Market Street Philadelphia, PA 19101 a
-. _ -., - - + - - - - - --,
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-Mr.f rank'R. Romano
' Walter W.' Cohen,.Esq.
F 361 Forest Avenue Consumer Advocate Office of Ambler, Pennsylvania 19002 Attorney. General.
1425 Strawberry Square Mr.' Robert L. Anthony Harrisburg, PA 17120
, Friends of,the Earth of'
'the Delaware Valley
- W. Wilson Goode P.'O. Box 186 Managing ~ Director 103.Vernon Lane City.of Philadelphia
-Moylan,-Pennsylvania 19065 Philadelphia,.P.A
- Mr. Marvin.I. Lewis Steven P.-Hershey, Esq..
6504 Bradford Terrace Community Legal Philadelphia, PA 19149 Services, Inc.
Law Center
'1315-Walnut-Street North Central Beury Bldg.
J JudithLA. Dorsey, Esq.
3701 North Broad Street
~ Suite 1632.
Philadelphia, PA' 19140 Philadelphia, PA. 19107 3
Donald:S. Bronstein, Esq.
. Charles W.LElliott, Esq.
1425 Walnut Street-123 N. 5th Street
' Philadelphia, PA 19102 Suite 101 Allentown, PA 18102 Mr. Joseph H. White, III 8 North Warner Avenue Mr.. Alan J. Nogee.
Bryn Mawr, PA 19010 3700 Chestnut Street
-Philadelphia, PA. 19104 Dr. Judith H.'Johnsrud Co-Director, ECNP 433
-Robert W. Adler, Esq.
Orlando Avenue State Assistant Counsel College, PA 16801 Commonwealth of Pennsylvania DER Robert J. Sugarman, Esq.
~
505 Executive House Sugarman & Denworth
~P.O.
Box 2357 Suite 510.
Harrisburg, PA 17120 North American Building 121 South Broad Street r
Thomas Gerusky, Director Philadelphia,-PA 19107 Bureau of Radiation
. Protection James M. Neill, Esq.
Department of Environmental Box 217 Resources Plumsteadville, PA 18949 5th Floor, Fulton Bank Bldg.
. Third and Locust Streets Director Pennsylvania Harrisburg, PA -17120 Emergency Management Agency Basement, Transportation and Safety Building Harrisburg, PA 17120 Makk J. Wetterhahn
- - - - - -.,