ML20077J535

First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20077J535
Person / Time
Site:	Limerick
Issue date:	08/12/1983
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	LIMERICK ECOLOGY ACTION, INC.
References
NUDOCS 8308160497
Download: ML20077J535 (9)

Text

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] '83 AUG 15 A10:47 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 0FFICE OF SECRETAP.,

j Before-the Atomic Safety and Licen((bh N r V I p In the Matter of ) ,

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2hiladelphia Electric Company ) Docket Nos. 50-352 L )

50-353 (Limerick Generating Station, )

2 Units 1 and 2) )

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! ' APPLICANT'S FIRST SET OF INTERROGATORIES

!. AND REQUEST FOR PRODUCTION OF DOCUMENTS i TO LIMERICK ECOLOGY ACTION Pursuant to the Rules of Practice of the Nuclear f Regulatory Commission ("NRC"), 10 C.F.R. 52.740b, and the f Atomic Safety and Licensing Board's Second Special Prehearing Conference Order (July 26, 1983), Philadelphia-Electric Company (" Applicant") hereby propounds the following interrogatories to Limerick Ecology Action (" LEA")

f- to be answered fully in writing, under oath, in accordance

! with the-definitions and instructions below.

Additionally, pursuant to 10 C.F.R. 52.741, Applicant requests that intervenors produce for inspection and copying (or provide ' copies of) those documents designated by intervenors in their respective-answers below.

I Definitions and Instructions

! 1, 'For each. interrogatory, please state the full name, work address,-and title or position of each person providing information for the answer to the interrogatory.

2. The following definitions shall apply:

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a. "Intervenor" shall refer to LEA or any officer, member, employee or consultant thereof.

b. " Document" shall mean any written, printed, typed or other graphic matter of any kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of intervenor, or its officials, employees, or agents; it shall also mean all copies or drafts of documents by whatsoever means made.

c. "Date" shall mean the exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the event's relationship to other events in the relevant context of the interrogatory).

d. "NRC" or " Commission" shall mean either the Atomic Energy Commission or the Nuclear Regulatory Commission, as appropriate, including its regulatory staff and adjudicatory boards, as indicated by the context of the interrogatory.

e. "Specify", when referring to a proceeding before the Nuclear Regulatory Commission, means that the answer shall ' set forth the proceeding, applicant, docket number,.

relevant date, and any other descriptive information appropriate to the request.

f. "Specify" or " identify", when referring to an individual, corporation, or other entity, means that the answer shall set forth the name, present or last known work address, and, if a corporation or other entity, its principle place of business or, if an individual, his or her title or titles and employer. Once an individual corporation or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation or other entity to state merely his, her or its name.

3. These interrogatories request all knowledge and information in intervenor's possession and/or knowledge and information in the possession of intervenor's agents, representatives, consultants, and, unless privileged, attorneys.

Interrogatories

1. State whether you intend to present any expert witnesses on the subject matter at issue in Contentions I-8 or I-15. If so, identify each such expert witness and further state (a) his professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the L _______ _ __

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expert is expected to testify; (d) the grounds for each opinion. Identify by court, agency, or other body, each proceeding in which such individual rendered testimony on this (these) subject (s).

2. Identify by title, author, publisher and date of issuance or publication, all documents that you rely upon as a basis for your contentions or that you intend to use (by way of reference or evidentidry proffer) in presenting your

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direct case on Contentions I-8 or I-15 and all documents to which you intend to refer id conducting cross-examination of other witnesses who may testify in connection with any such contention (s) .

3. To the extent that your answer to any interrogatory is based upon one or more documents, (a) identify each such document on which your answer is based; (b) identify the specific information in such document upon which you rely; (c) explain how such information provides a basis for your answer.

4. To the extent that your answer is based upon any study, calculation, research or analysis, (a) describe tne nature of the study, calculation, research or analysis and identify any documents which discuss or describe the study, calculation, research or analysis; (b) identify the person (s) or entity (ies) who performed the study, calculation, research or analysir (c) describe in detail the information which was the subject of the study, calculation, research or analysis; (d) describe the results

of such study, calculation, research or analysis; (e) explain how such study, calculation, research or analysis provides a basis for your answer.

5. To the extent that your answer is based upon conversations, consultations, correspondence or other communications with one or more individuals or entities, (a) identify each such individual or entity; (b) state the educational and professional background of each such individual, including occupation and institutional affiliations; (c) describe the nature of each communication, including time and context, and describe the information received from each such individual or entity; (e) explain how such information provides a basis for your answer.

Contention I-8

6. Specify all applicable NRC regulations, General Design Criteria or other regulatory requirements or guidance, or portions thereof, pertaining to loss of offsite power (" LOOP") events which intervenor asserts are applicable to Limerick.,

7. Specify each section of the Limerick Final Safety Analysis Report ("FSAR"), Probabilistic Risk Assessment, or Severe Accident Risk Assessment or other correspondence with the NRC, including Applicant's response to Staff questions, which intervenor asserts may be relevant to consideration of LOOP events and specify, to the extent applicable, any failure to meet the regulatory requirements set forth in response to Interrogatory 6.

8. Specify each initiating event which intervenor asserts would lead to a LOOP event at Limerick and, as applicable, specify the compensating measure which intervenor asserts is required at Limerick such that the Station is designed to withstand the LOOP event.

9. Identify all LOOP events at nuclear or other power plants upon which you rely for statistical or other data in support of this contention and provide the date of the event, a description of the facility, number of offsite lines available, duration of the LOOP and its cause.

10. Describe any studies, including assumptions, methodology and results regarding the reliability of the offsite power system for Limerick, or of the PJM interconnection which you have conducted or reviewed in connection with this contention, whether or not supportive of your position.

Contention I-15

11. Specify all applicable NRC regulations, General Design Criteria or other regulatory requirements or guidance, or portions thereof pertaining to leakage past closed main steam isolation valves which intervenor asserts are applicable to Limerick.

12. Specify each section of the Limerick FSAR, including Applicant's response to Staff questions, which intervenor asserts may be relevant to consideration of

' leakage past closed main steam isolation valves and specify,

to the extent applicable, any failure to meet the regulatory requirements set forth in response to Interrogatory 11.

13. Specify all facts upon which intervenor relies to assert that leakage past closed main steam isolation valves would be a problem for Limerick in meeting any NRC regulatory requirements or guidance.

14. Specify the compensating measures intervenor asserts should be taken in response to any problems identified in Interrogatory 13 above, including the factual basis for such assertion.

CONNER & WETTERHAHN, P.C

/ -

Mark J. Wetterhahn Counsel for the Applicant August 12, 1983 1

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 SERVICZ I hereby certify that copies of " Applicant's First Set of Interrogatories and Request for Production of Docurents to Limerick Ecology Action," dated August 12, 1983, in the captioned matter have been served upon the following by deposit in the United States mail this 12th day of August, 1983:

Judge Law'rence 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 Con. mission 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

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Mr. Frank R. Romano David Wersan, Esq. Consumer 61 Forest Avenue Assistant Advocate Ambler, Pennsylvania 19002 Office of Consumer Advocate 1425 Strawberry Square Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth of the Delaware Valley Steven P. Hershey, Esq.

P. O. Box 186 Community Legal 103 Vernon Lane Services, Inc.

Moylan, Pennsylvania 19065 Law Center North Central Beury Bldg.

Mr. Marvin I. Lewis 3701 North Broad Street 6504 Bradford Terrace Philadelphia, PA 19140 Philadelphia, PA 19149 Angus Love, Esq.

Judith A. Dorsey, Esq. 101 East Main Street 1315 Walnut Street Norristown, PA 19401 Suite 1632 Philadelphia, PA 19107 Mr. Joseph H. White, III 8 North Warner Avenue Charles W. Elliott, Esq. Bryn Mawr, PA 19010 Brose and Postwistilo 1101 Building ~ Robert J. Sugarman, Esq.

lith & Northampton Streets Sugarman & Denworth Suite Easton, PA 18042 510 North American Building 121 South Broad Street Jacqueline I. Ruttenberg Philadelphia, PA 19107 Keysteon Alliance 3700 Chestnut Street Director, Pennsylvania Philadelphia, PA 19104 Emergency Management Agency Basement, Transportation Thomas Y. Au, Esq. and Safety Building Assistant Counsel Harrisburg, PA 17120 Commonwealth of Pennsylvania DER Martha W. Bush, Esq.

505 Executive House P.O. Box Kathryn S. Lewis, Esq.

2357 Harrisburg, PA 17120 City of Philadelphia Municipal Services Bldg.

Thomas Gerusky, Director 15th and JFK Blvd.

Bureau of Radiation Philadelphia, PA 19107 Protection Department of Environmental Spence W. Perry, Esq.

Resources Associate General Counsel 5th Floor, Fulton Bank Bldg. Federal Emergency Third and Locust Streets Management Agency Harrisburg, PA 17120 500 C Street, S.W., Rm. 840 Washington, DC 20472 1

MatR J. Wetterhahn w -,

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