ML20096H259
| ML20096H259 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/06/1984 |
| From: | Rader R CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Mulligan M LIMERICK ECOLOGY ACTION, INC. |
| References | |
| OL, NUDOCS 8409110312 | |
| Download: ML20096H259 (2) | |
Text
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, gj GoNNER 6e WETTERHAHN, P.G.
1747 PENNSYLVANIA AVENUE. N. W.
M A n E J. wEttEm H ANN WAS HINGTON. D. C. 20000 GCSENT M. R ADER IMORID M.. OLSON ACC MOORE.JR.*
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Miss Maureen Mulligan
^84 SEP 10 P3HUD DELIVERY IN Limerick Ecology Action WASHINGTON, D.C.
P.O. Box 761
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762 Queen Street Pottstown,.PA 19464 SunCH In the Matter of Philadelphia Electric Company (Limerich Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 O(
Dear Miss Mulligan:
This will' confirm our conversation yesterday regarding your letter dated August 31, 1984, providing LEA's supple-mentary answers to Applicant's interrogatories.
The answers and documents provided in your. August 31 supplementation, as well as those - provided with your letter dated August 13, 1984, in large part respond to the points made by Applicant in its Motion to compel, filed August 2, 1984.
Accordingly, I-would be willing to withdraw the motion once LEA has completed its responses to the discovery requested by Applicant as discussed below.
First, in your letter and supplementary responses dated
. August 6, 1984, LEA indicated that it would file specific answers to Interrogatories 9, 17, 25, 27, 39 and 43 (incor-rectly cited as 45) "as soon as possible, and.
'. no later than August 31" (letter dated August 6, 1984 at p. 4).
Your most recently filed answers respond to Interrogatory 27, but none of the other interrogatories within this particular group, which requests LEA to specify any change in the offsite emergency plans and/or implementing procedures which it asserts to be = necessary in order to assure adequate planning for the ' subject of each particular interrogatory.
See Applicant's Motion to Compel at p.
6.
Applicant re-quests that LEA meet'its commitment to answer these inter-rogatories by furnishing answers no later than September 12, 1984.
Second, your-August 31 answers discuss LEA's consid-eration of Dr. Erikson as a:possible witness, but no other individuals.
Your earlier answers filed on August 6, 1984 state that LEA considers it "very likely that we would 8409110312 840906
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y o*H Mics Maurcen.; Mulligan Sspt:mbar 6.,
1984-V xPage 2;
- present? ! school ; officials 7as witnesses," and. states that
" individual teachers,;. bus ' drivers or union representatives would: be presented asf witnesses.". LEA also stated that it is;"likely that.we would present witnesses who are in charge of: day' care / pre-schoo1~ centers and summer camps, unless:they 4
are satisfied with planning 'for ~the children-they are responsible _ for," -including school officials from the Camp iHill Village. School and cCamp Hill Special' ' School.
LEA'
'further stated that it' was.considering a request to park
. officials at Valley Forge and Marsh Creek State Park-to testify.
Finally, LEA indicated that it may present wit-inesses "from various gas station and towing service owners along L evacuation. routes,- as well~ as those responsible for snow removal at the. municipal level" (letter dated August 6, 1984-at p.
1-2).
Applicant again ~ requests that all iden-tified: witnesses ? be. designated,- subject to further supple-mentation ofJLEA's witness list, no later than September 12,
?l984.
Third,.and finally, you indicate on the final page of LEA's August ~-31 supplementary; answers'that "there are other issues that'I stated that I.would attempt to. address in.this filing, but due to-time ~ constraints,.these enswers provide
. all.'information presently ;known to -LEA that I am awareJof."
This.-statement is. ~ ambiguous and
!apparently.:.self-contradictory.. Thus, it is unclear _whether. LEA has provided full a'nswers to.each-of the interrogatories'it has answered.-
If'so, please. confirm.
If'not, complete answers should be J
provided_by' September 12,-1984.
Applicant understands, as a separate matter, ' that LEA will be updating its --answers and i
~ providing-.further documents in accordance with its responsibilities under; the Commission's Rules of Practice
'and the; instructions'in Applicant's' discovery request to'do so.
.-If,
'for whatever reason, LEA is. unwilling to meet its
' discovery. obligations as outlined above, Applicant will necessarily have'no recourse ~but to resort'to its Motion-to Compel, which has been pending since August 2, 1984.
Sincerely, s
Robert M. Rader Counsel:for the Applicant-
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