ML20082H964

Suppl to 830808 Response to Rl Anthony & Friends of the Earth First Set of Interrogatories on Pipeline Contention

ML20082H964
Person / Time
Site:	Limerick
Issue date:	11/28/1983
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	AIR AND WATER POLLUTION PATROL, FRIENDS OF THE EARTH
Shared Package
ML20082H879	List: ML20082H876 ML20082H916 ML20082H937 ML20082H964 ML20082H985 ML20082J024
References
NUDOCS 8312010336
Download: ML20082H964 (2)

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Interrogatory No. 12 Did any drilling or excavation on the site or PECo. property strike or uncover the pipe?

Supplemental Answer On June 22, 1983, Bechtel Power Corporation's sub-contractor (Conduit and Foundations, Inc.) uncovered approximately 15 feet of the ARCO pipeline in order to install the supplemental water supply pipeline for Limerick.

The water pipeline is located approximately 12 feet below the ARCO pipeline.

ARCO was informed of the excavation prior to the start of excavation. An ARCO representative was present at all times when work being done involved the ARCO Pipeline. The ARCO pipeline was re-covered in mid-September,1983 to a minimum depth of 4 feet. ,

The Company's August 8,1983 answer to Interrogatory 12 was based upon a review of records of construction activity at the Limerick site.

Since the work on the water supply pipeline was in progress at the time the answer was being prepared, the records reviewed had not yet been updated to reflect this activity.

Participants in Preparation of Supplemental Answer Neal Cody

. Construction Engineer Philadelphia Electric Company 2301 Market Street N2-2 Philadelphia, PA 19101 John M. Stipcevich 4 Senior Supervising Designer - Engineering Design Div.

Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 ,

9312010336 031128 PDR ADOCK 05000352 .

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COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF PHILADELPHIA  :

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V. S. Boyer, being first sworn, deposes and states:

That he is Senior Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Applicant's Supplemental Answer to Intervenors R. L. Anthony and F0E Interrogatory No. 12 and.knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

'SenidT'71cePresynt Subscribed and sworn to before me this 3 3 day of M , 1983.

& L A40 Notary Public PATRICIA D. tCHoL1:

Notary Pu%c. Phila:!elphis. Philadelphia Co.

My f-~ Empires Fetuuary 10, 1986

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