ML20080B820

Second Set of Interrogatories & Request for Production of Documents on Contention I-42

ML20080B820
Person / Time
Site:	Limerick
Issue date:	02/03/1984
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	LIMERICK ECOLOGY ACTION, INC.
Shared Package
ML20080B812	List: ML20080B808 ML20080B820 ML20080B830 ML20080B876
References
NUDOCS 8402070287
Download: ML20080B820 (2)

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C0CMETED UWRC

'84 FEB -6 All :37 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,-, --

Before the Atomic Safety and Licensing Board 3

In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR LIMERICK ECOLOGY ACTION ON CONTENTION I-42 r

Pursuant to the Rules of Practice of- the Nuclear Regblatory Commission ("NRC"), 10 C.F.R. 52.740(b),

Philadelphia Electric Company (" Applicant") hereby propounds the following interrogatory to Limerick Ecology Action

(" LEA") to be answered fully in writing, under oath, in accordance with the definitions 'and instructions previously contained in Applicant's First Set of Interrogatories and Request for Production of Documents to Intervenor Limerick Ecology Action on Contention I-42 dated January 10, 1984 <

(" Applicant's First Set of Interrogatories").

Additionally, pursuar.t to 10 C.F.R. 52.741, Applicant requests that intervenors produce for inspection and copying (or provide copies of) those documents designated by intervenor in its answer below in accordance with the definitions, instructions and requests contained in Applicant's First Set of Interrogatories.

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Interrogatory Pler') update all answers by LEA to interrogatories and requests for documents previously propounded in Applicant's First Set of Interrogatories. Such answer shall include all responsive information available up to and including the date of your response. In providing your response, please use the same numeration as used for the original interrogatory and answer. Specifically include consideration in your responses of the Environmental Equipment Report, as amended and revised on January 16, 1984 by Letter of Mr. John S. Kemper to Mr. A. Schwencer.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn Counsel for Applicant February 3, 1984

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