ML12214A467
| ML12214A467 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/01/2012 |
| From: | Polonsky A Exelon Generation Co, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | Roisman A, Matthew Smith National Legal Scholars Law Firm, PC, NRC/OGC |
| SECY RAS | |
| References | |
| RAS 23151, 50-352-LR, 50-353-LR, ASLBP 12-916-04-LR-BD01 | |
| Download: ML12214A467 (10) | |
Text
)In the Matter of))EXELON GENERATION COMPANY, LLC))(Limerick Generating Station, Units 1 and 2)))Docket Nos.50-352-LR 50-35 3-LR AFFIDAVIT OF NANCY L.RANEK 1.My name is Nancy L.Ranek.I am the Environmental Lead, License Renewal, at Exelon Generation Company, LLC ("Exelon").
Working with the attorneysforExelon, I have been responsible for managing the collection of documents, data compilations, and tangible things to complywiththe mandatory disclosure requirements in 10 C.F.R.§2.336 and the Atomic Safety and Licensing Board's Initial Scheduling Order dated May 7, 2012 ("Scheduling Order")in this proceeding.
2.Exelon conducted a search of documents, data compilations, and tangible things in its possession custody, and control for information relevant to the admitted contention, and in the possession, custody, and control of its relevant contractor organizations, as specified in 10 C.F.R.§2.336(a).As provided in 10 C.F.R.§2.336(c), this search encompassed information and documents reasonably available to Exelon and its relevant contractor organizations, including:
a.Both electronic and paper documents; b.Corporate records, Limerick license renewal project files, and documents in the possession and control of individuals who have worked on the UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR])1 Limerick license renewal projectoron matters potentially relevant to the admitted contentions; and c.Documents, data compilations, and tangible things in the possession and control ofERINEngineering
&Research, Inc.("ERIN")and URS Corporation
("URS"), which assisted Exelon in preparing portions of the Limerick Environmental Report.3.Enclosure 1 is reserved for the names, addresses, and telephone numbers of the persons upon whose opinion Exelonwillbase its positions on the contention and upon whom Exelon may rely as witnesses, and a copy of the analyses and authorities upon which they base their opinions.Exelon has not yet identified witnesses for any hearing on the contention.
4.Consistent with the Board's May 7, 2012 Scheduling Order, Enclosure 2 to this Affidavit provides an index of relevant, non-privileged, non-protected documents, data compilations, and tangible things thatwerelocated as a result ofthissearch.
5.Consistent with theBoard'sMay 7, 2012 Scheduling Order, Enclosure 3 to this Affidavit is reserved for an index of relevant documents, data compilations, and tangible things that Exelon believes are proprietary to Exelon or its relevant contractor organizations, or falls within the category of Sensitive Unclassified, Non-Safeguards Information
("SUNSI").
There are no such documents in this round of disclosures.
6.Consistent with the Board's May 7, 2012 Scheduling Order, Enclosure 4 to this Affidavit provides an index of relevant documents, data compilations, and tangible things that Exelon believes are privileged.
2 7.Exelon has been conservative in identifying documents for inclusion in the enclosures.
Accordingly, Exelon is not suggesting that just because a document is listedonan enclosure that it is indeed relevant to the admitted contention.
8.These disclosures are reasonably accurate and complete as of July 1, 2012.The statements made above are true to the best of my knowledge, information, and belief.I declare under penalty of perjury that the foregoing is true and correct.)Iai c./f/YLdCJ Nany L.R/inek/Exelon Generation Company, LLC License Renewal Environmental Lead 200 Exelon Way, KSAI2-E Kennett Square, PA 19348 Phone: 6l0765-5369 Email: nancy.ranek@exeloncorp.com Executed this 2.1 day of.u.1 cJ2012.DR 1/70520361.1 3