ML20077E145
| ML20077E145 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/25/1983 |
| From: | Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Romano F ROMANO, F. |
| References | |
| NUDOCS 8307280147 | |
| Download: ML20077E145 (2) | |
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July 25, 1983
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M O ABLE ADDRESS: ATO M LAW 1
Mr. Frank Romano 61 Forest Avenue Ambler, Pennsylvania 19002
't In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 i
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Dear Mr. Romano:
This letter will memorialize the two matters that we discussed on July 22, 1983.
Your June 21, 1983 response to Applicant's interrogatories which were received by you on June 6,
1983 listed in response to Item AI-2 a number of publications regarding carburetor icing.
By this letter, I am requesting that you provide a copy of all pages of such documents in accordance with your letter.
You stated that you will deliver the originals to a commercial copier and will notify me as to their location and completion date for pickup by Philadelphia Electric Company.
In
- addition, we discussed certain specific points l
regarding your July 12, 1983 second round of interrogatories on Contention V-4.
As required by the Atomic Safety and Licensing Board's Memorandum and Order Confirming Schedules Established During Prehearing Conference (May 16, 1983), we discussed whether a
reasonable accommodation could be reached regarding interrogatories which the Applicant considered objectionable in whole or in part.
I stated that in the Applicant's view interrogatories p, q (in part) and u which related to wind shear were beyond the scope of the l
admitted contention and that it was my preliminary recommendation that the Applicant not respond.
You stated that you considered wind shear to be a hazard in the I
vicinity of the Limerick Station.
It was my view, as I expressed to you, that this was irrelevant to the scope of the admitted contention.
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PDR ADOCK 05000352 3
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Mr. Frank Romano July 25, 1983 Page 2 We also discussed the fact that a
number of the interrogatories which were similar to questions asked during the informal discovery process would require significant research, computer programming and/or runs or calculations and that under the Commission rules I did not believe that the Applicant was required to do the extensive research necessary to respond to your questions.
As I
noted previously to you, the raw data involving meteorological measurements and some related printouts are available for your inspection.
If you are merely asking whether such studies have been performed by Applicant, this information will appear in the response.
You stated that you viewed the fact that these particu-lar calculations were not done to be a
deficiency in Applicant's presentation regarding carburetor icing.
You may attempt to show at an evidentiary hearing or in reply to a motion for summary disposition that this is a deficiency in the evidentiary presentation.
In these circumstances, I therefore believe that it is impossible to reach resolution of our differences regarding your discovery request.
Sincerely, Jl Mark J. Wetterhahn l
Counsel for the Applicant MJW:sdd cc:
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