ML20083G293

Initial Interrogatories & Request for Production of Documents on Contention I-42.Response by 840203 Requested. Certificate of Svc Encl

ML20083G293
Person / Time
Site:	Limerick
Issue date:	01/09/1984
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	LIMERICK ECOLOGY ACTION, INC.
References
NUDOCS 8401110238
Download: ML20083G293 (6)

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, UNITED STATES OF AMERICA 84 JD 10 A10:26 NUCLEAR REGULATORY COMMISSION -

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Before the Atomic Safety and Licensing : Board In the Matter of \ )

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Philadelphia Elcctric Company ) Docket Nos. 50-352 1 ) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

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-APPLICANT'S INITIAL INTERROGATORIES AND REQUEST FOR PRODUC'1 ION OF DOCUMENTS TO LIMERICK ECOLOGY ACTION ON CONTENTION I-42

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Pursuant tc t,he Rules of Practice of the Nuclear Regulatory Commission ("NRC"), 10 C.F.R. 52.740b, and the Atomic Safety and Licensing Board's Memorandum and Order Establishing Discoveryg Schedule (November 21, 1983),

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

(" LEA") to be answered ful)y, in writing, under oath, and to be served on Applicant on or before February 3, 1?84.

Additionally, pursuant to 10 C.F.R. S2.741, Applicant requests that i LEA prodt:ce for inspection and copying (or s

provide copies of) the documents requested below.

These ' requests are preliminary in nature in order to ascertain the identity of those deponents who may be ex-aminad by / Applicants. Further interrogatories and document requests will be made subsequently as to specific con-t ntions. ,

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PDR ADOCK 05000352

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j' g Interrogatories

1. State whether you intend to present any expert witnesses on the subject matter at issue in Contention I-42.

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 sub-stance 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) sub-ject (s) .

2. State whether you intend to present any fact .

witnesses on the subject matter at issue in Contention I-42.

If'so, identify each such fact witness and further state-ta) 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 Contention I-42 or that you intend to use (by way of reference or evidentiary proffer) in presenting your direct case on Contention I-42 and all documents to which you intend to refer in conducting cross-examination of other Mitnesses who may- testify in connection with this contention..

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Document Request Please attach to your answer (s) to the interrogatories listed above a copy of all documents identified therein, 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.

p ,i s . c a s s w L i & A Mark J. Wetterhahn Counsel for the Applicant January 9, 1984 -

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\ b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Initial Interrogatories and Request for Production of Documents to Intervenor Limerick Ecology Action on Contention I-42" dated January 9, 1984 in the captioned matter, have been served upon the following by deposit in the United States mail this 9th 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.

2 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

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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.

1N O . Box.761 City of Philadelphia L762 Queen Street Municipal Services Bldg.

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

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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

8) i 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

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b Robert M.

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