ML20080L086
| ML20080L086 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/14/1984 |
| From: | Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| References | |
| NUDOCS 8402160238 | |
| Download: ML20080L086 (5) | |
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'84 FE 15 All:13 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BRANCH Before the Atomic Safety and Licensing Board In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S TRANSMITTAL OF ADDITIONAL MATERIAL RELATING TO CONTENTIONS V-3a AND V-3b On February 3, 1984, Applicant served " Transmittal of Testimony of Applicant Relating to the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation Resulting from the Ruptures of the ARCO and Columbia Gas Transmission Pipelines and Request to Set Schedule"
(" Testimony").
In conjunction with this testimony, Applicant is hereby transmitting the following material:
1.
For completeness, copies of all figures to the testimony are being sent to those on the service list not
. involved with litigation of this contention.
The Licensing Board, NRC Staff, Friends of the Earth and the Commonwealth of Pennsylvania had previously been served.
Difficulty in reproduction of certain figures had prevented inclusion of this material with the testimony.
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2.
Copies cf a revised Figure 3 to the Testimony are being transmitted to the service list.
This revision corrects the figure designation and shows the postulated line of centroids of detonation on the base drawing of Applicant's Exhibit 7.
It depicts the identical information regarding the Columbia Gas Transmission line explosion as the one it replaces.
3.
Copies of general references regarding the subject matter of structural evaluation not specifically referenced in the Testimony are being made available for inspection in Philadelphia.
This material has been designated " Discovery 29" for reference.
In addition, a complete copy of the manual entitled
" Structures to Resist the Effects of Accidental Explosions," parts of which were provided to the Board and interested parties, will be made available for review upon request.
In accordance with past practice, this material will be made available for inspection during normal business days from 9:00 a.m.
to 4:30 p.m.
at a room near Philadelphia Electric Company's headquarters.
Any party desiring access to the documents should call Edward Cullen, Esq. at 215/841-4273 to make specific arrangements at least one day in advance.
Any copies of this material should be marked and will be made at the commercial rate.
Copies of this material are being sent to the Licensing Board.
4.
By telephone call of February 7,
- 1984, Mr.
- Anthony, representative of FOE, requested copies of all structural "as built" drawings for safety related I
structures.
While he could give absolutely no assurance that he has obtained the services of an expert who can understand the requested material or will do so, current design drawings are being made available for examination.
Since these drawings contain confidential and proprietary information, arrangements will have to be made for the protection of this information if copies are requested.
5.
Similarly, copies of calculations supporting the testimony are being made available for inspection.
A complete set of sample calculations for the spray pond pumphouse is being forwarded to the Licensing Board, Mr.
Anthony, the NRC Staff and the Commonwealth of Pennsylvania.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Mark J. Wetterhahn Counsel for the Applicant February 14, 1984
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerich Generating Station,
)
Units 1 and 2)
)
i CERTIFICATE OF SERVICE I
hereby certify that copies of
" Applicant's Transmittal of Additional Material Relating to Contentions V -3 a and V-3b" dated February 14, 1984 in the captioned matter, have been served upon the following by deposit in the United States mail this 14th day of February, 1984:
_ Lawrence Brenner, Esq. (2)
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory O'.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing and Service Section Dr. Richard F. Cole Office of the Secretary
' Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Ann P. Hodgdon, Esq.
Counsel for NRC Staff Office Dr. Peter A.. Morris of the Executive Atomic Safety and Legal Director Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Hand Delivery
1
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)
u- -
l Atomic Safety and Licensing Steven P. Hershey, Esq.
' Board Panel Community Legal r
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.
Vice President &
107 East Main Street General Counsel Norristown, PA 19401 2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 bl Forest Avenue Ambler, Pennsylvania 19002 Robert J. Sugarman, Esq.
Sugarman & Denworth Suite 14r. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street the Delaware Valley Philadelphia, PA 19107 I
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 Eldg.
Pottstown, PA 19464 15th and JFK Blvd.
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 Federal Express
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. Box 47 Sanatoga, PA 19464 Di.
Mark (/J. Wetterhahn
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