ML20079J454

Preliminary Set of Initial Interrogatories & Request for Production of Documents Re Onsite Emergency Planning Contentions.Certificate of Svc Encl

ML20079J454
Person / Time
Site:	Limerick
Issue date:	01/20/1984
From:	Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	LIMERICK ECOLOGY ACTION, INC.
References
NUDOCS 8401240322
Download: ML20079J454 (6)

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USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION N JAN 23 P12:32 Before the Atomic Safety and Licensing. Board.

w In the Matter of

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Philadelphia Electric Company

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Docket Nos. 50-352

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50-353 (Limerick Generating Station,

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Units 1 and 2)

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APPLICANT'S PRELIMINARY SET OF INITIAL INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LIMERICK ECOLOGY ACTION REGARDING ONSITE EMERGENCY PLANNING CONTENTIONS Pursuant to the Rules of Practice of the Nuclear Regulatory Commission ("NRC"), 10 C.F.R.

S2.740 (b), and the Atomic Safety and Licensing Board's Memorandum and Order Establishing Discovery Schedule (November 21, 1983)

(slip op, at 2),

Philadelphia Electric Company

(" Applicant")

hereby propounds the following preliminary interrogatories te Limerick Ecology Action

(" LEA" or "intervenor")

to be answered fully in writing, under oath, and to be served on Applicant on or before February 14, 1984.

As used herein, "intervenor's onsite emergency planning contentions" refers to the contentions submitted by LEA to the Atomic Safety and Licensing Board by letter dated November 14, 1983.

Additionally, pursuant to 10 C.F.R.

S2.741, Applicant requests that intervenors produce for inspection and copying (or provide copies of) the documents requested below.

8401240322 840120 PDR ADOCK 05000352

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O l 6 These requests are preliminary in nature in order to ascertain the identity of those deponents who will be examined by Applicant in accordance with the Licensing Board's Memorandum and Order.

Further interrogatories and document requests will be made subsequently as to specific contentions.

Interrogatories 1.

State whether you intend to present any expert witnesses on the subject matter at issue in intervenor's onsite emergency planning contentions.

If so, identify each such expert witness and further state (a) his professional qualifications; (b) the subject matter c'n which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) the grounds for each opinion; (e) the expert's business and residential addresses.

Identify by court, agency, or other

body, each proceeding in which such individual rendered testimony on this (these) subject (s).

2.

State whether you intend to present any fact witnesses on the subject matter at issue in intervenor's onsite emergency planning contentions.

If so, identify each such fact witness and further state (a) his business and residential addresses; (b) the subject matter on which the witness is expected to testify; (c) the substance of the factual testimony which the witness is expected to offer.

3.

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 evidentiary proffer) in presenting your direct case on intervenor's onsite emergency planning contentions and all documents to which you intend to refer in conducting cross-examination of other witnesses who may testify in connection with any such contentions.

4.

Whether or not such individual is designated as a witness, identify each person (including, but not limited to, each public official) intervenor has contacted with respect to its onsite emergency planning contentions and specify in detail all deficiencies, if any, which such individual asserts to exist in Applicant's onsite emergency plans.

Document Request Please attach to your answer (s) to the interrogatories listed above a copy of all documents identified in the answers above, or upon which you otherwise intend to rely in the presentation of your direct case or in the cross-examination of other witnesses.

Alternatively, state that all such documents will be produced at a reasonable time and place to be agreed upon by the Applicant for inspection and copying.

CONNER & WETTERHAHN, P.C.

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Troy B~.

Conner, Jr.

Counsel for the Applicant January 20, 1984

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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Philadelphia Electric Company

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Docket Nos. 50-352

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50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE I

hereby certify that copies of

" Applicant's Preliminary Set of Initial Interrogatories and Request for Production of Documents to Limerick Ecology Action Regarding Onsite Emergency Planning Contentions," dated January 20, 1984 in the captioned matter, have been served upon the following by deposit in the United States mail this 20th day of January, 1984:

Lawrence Brenner, Esq. (2)

Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Docketing and Service Section Dr. Richard F. Cole Atomic Office of the Secretary Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Ann P.

Hodgdon, Esq.

Counsel for NRC Staff Dr. Peter A. Morris Atomic Office of the Executive Safety and Licensing Legal Director Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555

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Atomic Safety and Licensing Steven P.

Hershey, Esq.

Board Panel Community Legal U.S. Nuclear Regulatory Services, Inc.

Commission Law Center West North Washington, D.C.

20555 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN:

Edward G. Bauer, Jr.

Angus Love, Esq. 101 East Vice President &

Main Street Norristown, PA General Counsel 19401 2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 61 Forest Avenue Ambler, Pennsylvania 19002 Robert J.

Sugarman, Esq.

Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street the Delaware Valley Philadelphia, PA 19107 106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I.

Lewis Basement, Transportation 6504 Bradford Terrace and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer, Esq.

Martha W.

Bush, Esq.

Limerick Ecology Action Kathryn S.

Lewis, Esq.

P.O.

Box 761 City of Philadelphia 762 Queen Street Municipal Services Bldg.

Pottstown, PA 19464 15th and JFK Divd.

Philadelphia, PA 19107 Charles W.

Elliott, Esq.

Brose and Postwistilo Spence W.

Perry, Esq.

1101 Building lith &

Associate General Counsel Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W.,

Rm. 840 Zori G.

Ferkin, Esq.

Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director Governor's Energy Council Bureau of Radiation 1625 N. Front Street Protection Harrisburg, PA 17102 Department of Environmental Resources 5th Floor, Fulton Bank Bldg.

Third and Locust Streets Harrisburg, PA 17120 l

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Jay M.

Gutierrez, Esq.

U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O.

Bcx 47 Sanatoga, PA 19464 Mark ~3. Wetterhahn s

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