|
---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20245L4191989-05-0404 May 1989 Graterford Inmates First Set of Interrogatories for Commonwealth of PA Dept of Corrections & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence ML20245L4941989-05-0404 May 1989 Graterford Inmates First Set of Interrogatories for Commonwealth of PA Emergency Mgt Agency & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence ML20238D1101987-12-29029 December 1987 Licensee Response to Request for Production of Documents by Air & Water Pollution Patrol Dtd 871207.* List of Available Requested Documents Provided.W/Certificate of Svc.Related Correspondence ML20238D0771987-12-29029 December 1987 Licensee Objections to Request for Production of Documents by Air & Water Pollution Patrol & Motion for Protective Order.* Request Re Records of False Activation of Monitor Alarms Requires Extensive Research.Certificate of Svc Encl ML20096E4661984-08-31031 August 1984 Supplemental Response to Applicant 840625 Discovery Request & Interrogatories Re Admitted Offsite Emergency Planning Contentions.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20096B4071984-08-30030 August 1984 Answer to Applicant First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20094C3131984-08-0303 August 1984 Revised Answer to Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions ML20094A6791984-08-0101 August 1984 First Set of Interrogatories & Request for Production of Documents to City of Philadelphia Re Offsite Emergency Planning Contentions City-18 & City-19.Certificate of Svc Encl.Related Correspondence ML20094C2121984-07-31031 July 1984 Answer to Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions (Discovery 35). Certificate of Svc Encl ML20094E5921984-07-23023 July 1984 Amended Answers to Util First Set of Interrogatories Re Offsite Emergency Planning Contention Lea/Foe 24.Certificate of Svc Encl ML20090D9621984-07-16016 July 1984 Response to Limerick Ecology Action Second Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Related Correspondence ML20093D4071984-07-11011 July 1984 Response to Limerick Ecology Action First Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20090A7091984-07-10010 July 1984 Objections to Limerick Ecology Action First & Second Sets of Interrogatories on Offsite Emergency Planning Contentions. Related Correspondence ML20090A7211984-07-0909 July 1984 Answer to First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Util & Certificate of Svc Encl.Related Correspondence ML20092P7691984-07-0303 July 1984 Second Set of Interrogatories & Request for Production of Documents to State of PA Emergency Mgt Agency on Admitted Offsite Emergency Planning Contentions.Related Correspondence ML20151K0601984-06-25025 June 1984 First Set of Interrogatories & Requests for Production of Documents to Limerick Ecology Action & Friends of the Earth Re Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20092P7761984-06-25025 June 1984 Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Certificate of Svc Encl. Related Correspondence ML20092K7191984-06-22022 June 1984 First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Certificate of Svc Encl. Related Correspondence ML20092J7561984-06-21021 June 1984 First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Notice of Appearance for M Mulligan & Svc List Encl.Related Correspondence ML20091K1841984-06-0101 June 1984 Answer Opposing Friends of the Earth 840518 Motion for Admission of New Late Contentions Re Applicant 840509 Motion for Expedited Partial Initial Decision & Issuance of Low Power License.Certificate of Svc Encl ML20091K1771984-06-0101 June 1984 Answer Opposing Del-Aware 840517 Proposed Late Contentions Re Applicant 840509 Motion for Expedited Partial Initial Decision & Issuance of Low Power License.Contentions Should Be Denied & Action Taken Against Del-Aware ML20084D9241984-04-27027 April 1984 Response to First Set of Interrogatories on Severe Accidents.Related Correspondence ML20088A4251984-04-0909 April 1984 First Set of Interrogatories & Request for Production of Documents to Limerick Ecology Action Re Severe Accident Contentions.Certificate of Svc Encl.Related Correspondence ML20088A4231984-04-0909 April 1984 First Set of Interrogatories & Request for Production of Documents to City of Philadelphia Re Severe Accident Contentions.Related Correspondence ML20087F2071984-03-12012 March 1984 Responses to Util Interrogatories on Contention I-42. Certificate of Svc Encl.Related Correspondence ML20086U0501984-03-0202 March 1984 Response Opposing Air & Water Pollution Patrol 840221 Request for Extension of Discovery Period for Contention VI-1.Certificate of Svc Encl.Related Correspondence ML20086U3431984-03-0202 March 1984 Response to Air & Water Pollution Patrol Motion to Compel Discovery.Applicant Denies That Answer to Interrogatory Evasive.Related Correspondence ML20080T9501984-02-27027 February 1984 Answers City of Philadelphia Interrogatories on Sys Interaction Contention.Certificate of Svc Encl.Related Correspondence ML20080R9931984-02-21021 February 1984 Answers to City of Philadelphia Interrogatories (Discovery 27).Certificate of Svc Encl ML20080N7201984-02-10010 February 1984 Motion to Compel Answers to Listed Interrogatories ML20080E8571984-02-0606 February 1984 Responds to Applicant First Set of Interrogatories Re Contention I-42.Certificate of Svc Encl.Related Correspondence ML20080E8031984-02-0606 February 1984 Interrogatories & Request for Production of Documents of City of Piladelphia to Util Re Sys Interaction.W/Certificate of Svc.Related Correspondence ML20080C5911984-02-0303 February 1984 Interrogatories 14-21 Re Environ Qualification ML20080C5961984-02-0303 February 1984 Interrogatories 22-30 Re Environ Qualification ML20080B8761984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-41.Certificate of Svc Encl ML20080B8301984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-41 ML20080B8201984-02-0303 February 1984 Second Set of Interrogatories & Request for Production of Documents on Contention I-42 ML20080B8081984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-42 ML20080A4501984-02-0202 February 1984 First Set of Interrogatories & Request for Production of Documents Re Limerick Ecology Action Onsite Emergency Planning Contentions.Certificate of Svc Encl ML20080B9231984-02-0101 February 1984 Answers to Twelfth Set of Interrogatories on Qa/Welding Contention (Discovery 24).Certificate of Svc Encl ML20080B9121984-02-0101 February 1984 Answers to Eleventh Set of Interrogatories on Qa/Welding Contention (Discovery 23) ML20080B8911984-02-0101 February 1984 Answers to Tenth Set of Interrogatories on Qa/Welding Contention (Discovery 25) ML20080A6251984-02-0101 February 1984 Answer to Applicant Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Related Correspondence ML20079S2721984-01-25025 January 1984 Answer to Sixth Set of Interrogatories on Qa/Welding Contention ML20079S2901984-01-25025 January 1984 Answer to Seventh Set of Interrogatories Re Qa/Welding Contention.Certificate of Svc Encl ML20079S2851984-01-25025 January 1984 Answer to Seventh Set of Interrogatories Re Qa/Welding Contention ML20079J4541984-01-20020 January 1984 Preliminary Set of Initial Interrogatories & Request for Production of Documents Re Onsite Emergency Planning Contentions.Certificate of Svc Encl ML20086J9981984-01-14014 January 1984 Twelfth Interrogatory Re Contention VI-1 (Qa/Qc).Documents, Logs & Repts on All safety-related Welds Requested ML20086J9921984-01-14014 January 1984 Eleventh Interrogatory Re Contention VI-1 (Qa/Qc).Details Pertinent to safety-related Pipe Failures Due to Freeze Induced Bursts Requested ML20079F2101984-01-13013 January 1984 Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Certificate of Svc Encl 1989-05-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 ML20151L3671997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Orders That SA Blacklock Prohibited from Engaging in Activities Licensed by NRC for 5 Yrs from Date of Order ML20203H6891997-06-0202 June 1997 Transcript of 970602 Enforcement Conference in King of Prussia,Pa ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals. ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20062C6561990-10-22022 October 1990 Affidavit Requesting Withholding of Summary Rept on Evaluation of Recirculation Nozzle to Safe End Weld Indication & Proposed Disposition to Permit Unit 1 Cycle 4 Operation, from Public Disclosure,Per 10CFR2.790 ML20246J4521989-08-30030 August 1989 Memorandum & Order (Terminating Proceeding).* Terminates Proceeding Per Settlement Agreement Between Limerick Ecology Action,Inc & Licensee.W/Certificate of Svc.Served on 890831 ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246F0121989-08-25025 August 1989 Memorandum & Order CLI-89-17.* Staff Authorizes Issuance of Full Power License to Licensee to Operate Unit 2 After Requisite Safety Findings Under 10CFR50.57 Completed. W/Certificate of Svc ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20246C0271989-08-18018 August 1989 Notice of Appointment of Adjudicatory Employee.* Informs That D Nash Appointed as Commission Adjudicatory Employee to Advise Commission on Issues in Proceeding.W/Certificate of Svc.Served on 890818 ML20246B7721989-08-17017 August 1989 Correction of Memorandum & Order of 890815.* Advises That Refs to 49CFR2.730(c) on Page 1 & 49CFR2.710 & 49CFR2.711 on Page 2 Should Be Corrected to Read as 10CFR2.730(c),2.710 & 2.711,respectively.W/Certificate of Svc.Served on 890818 ML20246D7411989-08-17017 August 1989 Transcript of 890817 Meeting in Rockville,Md Re Discussion of Full Power OL for Facility.Pp 1-58.Supporting Documentation Encl ML20246B7571989-08-16016 August 1989 Order Responding to Limerick Ecology Action Motion for Reconsideration.* Denies Motion to Reconsider,Stay,Suspend or Revoke 890707 Order on Basis That Order Appropriate.W/ Certificate of Svc.Served on 890816.Re-served on 890818 ML20246B7751989-08-16016 August 1989 Memorandum & Order.* Denies Rl Anthony 890623 Request for Hearing for Intervention in Remand Proceeding & for Stay of Low Power Authorization.W/Certificate of Svc.Served on 890816 ML20246B7931989-08-15015 August 1989 Memorandum & Order (Request for Expedited Answer).* Denies Licensee 890811 Request for Expedited Answer from NRC & Limerick Ecology Action on Basis That Request Lacks Good Cause.W/Certificate of Svc.Served on 890816 ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H5991989-08-11011 August 1989 Memorandum & Order (Terminating Proceeding).* Dismisses Graterford Inmates Contention Re Adequacy of Training for Drivers Responsible for Evacuating Graterford & Terminates Proceeding.Certificate of Svc Encl.Served on 890814 ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20245F7341989-08-0909 August 1989 NRC Staff Response to Commission Memorandum & Order of 890807.* Advises That NRC Will Provide Comments on Limerick Ecology Action 890814 Filing Prior to Commission Meeting Scheduled for 890817.W/Certificate of Svc ML20245F7291989-08-0808 August 1989 Affidavit.* Discusses Costs Incurred While Plant Inoperable. Allowance for Funds Used During Const,Security,Maint & Operational Costs Considered Proper for Calculating Costs for Delay ML20248D9241989-08-0707 August 1989 Memorandum & Order.* Extends Limerick Ecology Action Response Deadline to 890814 to Respond to Five Questions Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890807 ML20248D7871989-08-0303 August 1989 Correction for NRC Staff Response to Commission Questions.* Forwards Corrected Page 5 to NRC Response to Questions Filed on 890802,deleting Phrase by Nearly Factor 2.5 in Next to Last Line.W/Certificate of Svc ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20248D5391989-08-0202 August 1989 Affidavit of MT Masnik.* Advises That Author Prepared Response to Question 3 ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D6451989-08-0202 August 1989 Affidavit.* Advises That Author Read Responses to Request for Comments by NRC & Knows Contents.W/Certificate of Svc ML20248D4721989-08-0202 August 1989 NRC Staff Response to Commission Questions.* Provides Info for Use in Commission Effectiveness Review of Plant Full Power Operation,Per Commission 890726 Memorandum & Order. Supporting Affidavits Encl ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20245J1321989-07-27027 July 1989 Transcript of 890727 Meeting in Rockville,Md Re Facility Severe Accident Mitigation Issues.Pp 1-130.Supporting Info Encl ML20247N3261989-07-26026 July 1989 Transcript of 890726 Affirmation/Discussion & Vote in Rockville,Md on SECY-89-220 Re Order Requesting Info from Parties for Immediate Effectiveness Review of Full Power Authorization for Limerick Unit 2.Pp 1-4 ML20248D7331989-07-24024 July 1989 Second Rept of Parties & Request for Dismissal of Graterford Inmates Contention & Termination of Proceeding.* Requests Board to Enter Order to Terminate Proceeding Based on Parties Agreeing to Dismissal of Remaining Contention ML20247Q4621989-07-23023 July 1989 Response of Intervenor Rl Anthony to Answer of Philadelphia Electric Co (PECO) to Request for Hearing on PECO Application for Low Power Operation of Unit 2 & Stay of Any Operation in Keeping W/Us Circuit Court Remand Of....* ML20247B7261989-07-20020 July 1989 Notice of Appointment of Adjudicatory Employee.* Advises That H Vandermole Appointed to Advise Commission on Issues in Proceeding Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890720 ML20247B3821989-07-18018 July 1989 Memorandum & Order.* Orders That Severe Accident Mitigation Alternatives,Per Nepa,To Be Considered Include Containment Heat Removal,Core Residue Capture & Venting.Certificate of Encl.Served on 890719 ML20247B7641989-07-13013 July 1989 Motion of Intervenor,Limerick Ecology Action Inc,To Reconsider/Stay/Suspend/Revoke Order Authorizing Issuance of Low Power OL for Limerick 2.* Consideration of Accident Mitigation Alternatives Imperative.Certificate of Svc Encl 1997-08-05
[Table view] |
Text
,, , -
s . z.z RE' J TD w;,g;;,3, g,wu, ..
py vt ED
,=
tr.
UNITED STATES OF AMERICA
,8,, y F._.a, -9 m1 :05 h
NUCLEAR REGULATORY COMMISSION m BEFORE THE ATOMIC SAFETY AND LICENSING BOARD : - "
'C.......a* SEi SRANCH h.7 In the Matter of .
m PHILADELPHIA ELECTRIC COMPANY :
' Docket Nos. 50-352 E I"'
50-353 (Limerick Generating Station, :
Units 1 and 2) :
ft LEA'S ANSWERS TO APPLICANT'S FIRST SET OF INTER- b ROGATORIES RELATING TO CONTENTION I-42. -
$3
- Limerick Ecology Action hereby responds to Applicant's -
Jan. 10, 1984 First Set of Interrogatories and Request for Pro- 7. . .
duction of Documents on Contention I-42., pursuant to the NRC ((
Rules of Practice and Procedures, 10 CFR 2. 74 0 (b) and the Board's [.I Order of Oct. 28, 1983. Please note that LEA was informed by Ni Applicant's counsel that LEA was not expected to respond to a
~
similar (but shorter) " Initial Interrogatory" Request dated e.;
Jan. 9, 1984, due to the fact that Applicant's First Set of :: -
Interrogatories covers the same material (per conversation with !
Mark Wetterhahn, 2/3/84). All answers have been prepared by Phyllis -
- itzer, President of LEA, a full-time voluntecr.
INTERROGATORIES M
E'r 1). State whether or not LEA intends to present any expert witnesses on Contention I-42.
ANSWER: At the present time, LEA has no plans to present. expert Ir testimony on I-42. A
- 2. State whether or not LEA intends to present any facutal witnesses Y on the subject matter at issue in. Contention I-42.
ANSWER: At the present time, LEA has no plans to present any factual {
witnesses on the subject matter at issue in Contention I-42. ..,
- 3. Identify by titic, author publisher, and date'or issue, all docu-N 7-ments that LEA relies unon as a basis ~for Contention I-42, or that LEA intends to use in presenting its' direct case or in cross- 5 examining'other witnesses on Contention I-42, and identify g 8402100178 840206 i' 1 PDR ADOCK 05000352 "
G . . . . _ , - ._
PDR
all documents to which LEA intends to refer to in conducting cross.. examination of other witnesses who may testify in connec-tion with any such contention.
ANSWER: LEA is relying upon the documents listed as the " Basis" for {
this contention as discussed in its filings on Respecification I of Contention I-42, dated 7/11/83, 8/9/83, and any subsequent '
_ material provided to LEA by the Applicant.
T
- 4. To the extent that your answer to any interrogatory is based upon one or more documents, (a) identify each such document on which your answer is based; (b) identify the specific information in such document upon which you rely; (c) explain how the information provides a basis for your answer.
ANSWER: See discussion under " Basis" section of LEA's filings on I-42, dated 7/11/83 and 8/9/ST as referemced above, Applicant's responses to City Interrogatories dated 2/3/84 may provide additional information.
- 5. To the extent that your answer is based upon any study, calculation, research or analysis, (a) describe the nature of the study, calculation, research or analysis and identify any documents which discuss or describe the study, calculation, research or analysis; (b) identify the per- .
son (s) or entity (ies) who performed the study, calculation, research or analysis; (c) describe in detail the information which was the subject of the study, calculation, research or analysis; (d) describe the results of such study, calcu-lation, research or analysis; (e) explain how such study, calculation, research or analysis provides a basis for your answer.
ANSWER: Not applicable.
-se
1 answer is based upon
- 6. To the extent that your 1 correspondence or other conversations, consultations or communications with one or more individuals or entities, (b) state please identify each such individual or entity; the educational and professional background of each su h 3
individual, including occupation and institutional affil-iations; (c) describe the nature of each communication, including time and context, and describe the information (e) explain received from each such individual or entity; how such information provides a bacis for your answer.
~ '-
ANSWER: Not applicable.
- 7. To the extent that intervenor possesses information or documents expressing facts or opinions which are relevant to the specific interrogatories below, but which do not support intervenor's position or which have not otherwise been fully provided in the answers thereto, please provide such information and documente.
ANSWER: Not applicabic.
Specify each system, component or part or tne
, 8.
asserts is Limerick Generating Station which intervenor meaning of 10 C.F.R.
safety" within the "important to which has not been included' in Appendix B of the 550.49(b) As Environmental Qualification Report ("EQR") for Limerick.
w- , _ _ _
to ecch such component or part, (a) describe in detail the component or parts and their exact location at the Limerick Generating Station; (b) identify the manufacturer, if known; I (c) identify whether the component or part is asserted to be l 1
3 within the category "important to safety" because of its inclusion within 10 C.F.R. S50.49b (1) (2) or (3), describing in detail the reason for classification in one or more of these categories; (d) describe in detail the alleged "impor-tant to safety" function which the component or part will perform; (e) state the basis which the intervenor used in concluding that another system, component or part, or combination thereof, which is being qualified or which is not within a harsh environment cannot perform the function instead of the subject part or component; (f) state the basis, if any, upon which intervenor asserts that environ-mental qualification of such component or part will not or could not be performed prior to fuel loading for Limerick Unit 1 or 2, as appropriate; (d) the exact event or events for which intervenor asserts that the equipment must - be qualified, the time or times after the initiation of the most critical event during which the part or component is asserted to be necessary to operate, and the exact environ-mental conditions which the component or part would experi-ence.
ANSWER: Intervenors position is that PECO has not complied with the new expended EQ rule, nor even attempted to conduct a thorough review of both safety-related and non-safety-related equipment to determine which equipment falls into category (b) (2) of the EQ Rule (10 CFR 50.49), since either might contain non safety related components, the failure of which could prevent the satisfactory accomplishment of safety functions.
LEA is unabic to provide a more detailed response until it receives answers to City Interrogatories on I-42 dated 2/3/84.
- .$h g 9.
=%
"""" Identify any and all components or parts listed in
- m Appendix B of the EQR which intervenor asserts will not be environmentally qualified by
.jjj the time of fuel loading for
... 2.9 each unit, giving the basis M for such conclusion and stating 35t when intervenor believes such part or equipment will be y
...a qualified, giving the basis for such conclusion or estimate ,
ANSWER: LEA is Ap'plicant*s receiving unable to respond to this Interrogatory without on I-42, dated 2/3/84 answers It is to City Interrogatories also possible that LEA will not be able to provide a throuogh question until it has had an opportunityanswer to to this cross-exa-mine PECO's witnesses on this contention.
. 10. With regard to each of the following parts, compo-nents, or systems which intervenor alleges should be includ -
ed in the equipment qualification program, (1) feedwater control; (2) emergency lighting and communications systems; (3) plant process computer system; (4) computer scftware:
(a) identify the exact systems, part or component involved, with reference to the description P&I.D.'s, contained in the FSAR or if possible; (b) identify the location or lo-cations of the systems, parts or components at the Limerick Generating Station; (c) identify the conditions, e.g. LOCA .
or HELB; which intervenor asserts require that these systems be qualified; (d) identify the operations that such equip-ment would have to perform for such conditions and the time frame in which these actions are required; (e) identify the harsh environment that such equipment, part or component would experience; (f) state intervenor's understanding of systems, equipment, parts or components which can perform
' functions equivalent to those identified above and which are either being qualified or are not located in a harsh en-
- 12. ,
As to each component or part for which intervenor ,
asserts that an' Equipment Qualification Review Record
("EQRR") has not been provided in Applicant's Environmental Qualification Report for Limerick, (a) specify each part or a component allegedly omitted; (b) identify the exact location of such component or part; (c) identify the manufacturer, if known; (d) state the basis upon which intervenor relies to assert that such part or component should have been included in en EQRR.
ANSWER: LEA cannot respond until it is provided with answers to City Interrogatories on I-42, dated 2/3/84. Further-more. LEA's concerns relate to the scope of search made by the Applicant to determine (b) ( 2) "important- ,
to safety" equipment. LEA believes that it is the Appli-cant's responsibility to make a showing that its EQ pro-gram meets the new requirements of the 1/31/83 new EQ Rule.
- 13. As to each part or component for which intervenor asserts that the EQRR specifies a qualified life of less than 40 years, (a) specify the part or component; (b) identify the manu.facturer, if known; (c) the corrective action which intervenor asserts should be.taken by Applicant to correct the alleged deficiency, the basis upon which the' means for identification of such items by Applicant as .
discussed on page 8.2 of the Environmental Qualification Report is insufficient to meet NRC requirements.
ANSWER: LEA's position is that no action is identified to correct noted deficiencies where life of qualified equipment does not equal the 40 year plant life. 1 (See EQRRs, pp. 8,32-35) LEA intends to cross-exa-mine Applicant's witnesses to determine whether or not NRC requirements have been satisfied. l
- 14. State intervenor's basis for the assertion that the key switch in the control room for the standby liquid control system is in a harsh environment and thus subject to _.
~
COMMElf7S SUBMITTED ONLY TO APPLICANT'S COUNSEL f
h i:
k i
l t
9 l a.
t ik 6
m b
L 5
5 5
l3 h
LEA has relied soley upon documentr. nrovided by the Applicant. [
h a
I hereby affirm that the above answers are true and correct to the g best of my knowledge. 5
6.'
LE ' resident !
E h
y
?
E t
j f
. g~
L k
CERTIFICATE OF SERVICE
[{
'M FD -9 AM :06 5 I hereby certify that LEA's E Responses to Applicant's _First {
Set of Interrogatories relating to Contention I-42 havf,been- g g served upon the following by first class mail, p o s t a g p#"p sgjg ' '
on Feb. 6, 1984. {
i=
E 5
m
=
k)
Lawrence Brenner, Chairman (2)
Ann P. Hodgdon, Esq. k Administrative Judge Office of the Executive Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission ET il Commission Washington, DC 20555
=
Washington, DC 20555 Benjamin Vogler, Esq. a Dr. Richard F. Cole 6 Administrative Judge Office of the Executive Legal Director e U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory kashington, DC 20555 E Commission ,=
Washington, DC 20555 Troy B. Conner, Jr., Esq.
[7 Dr. Peter A. Morris Conner and Wetterhahn 2:
1747 Pennsylvania Ave., NW 5 Administrative Judge Washington, DC 20006 U.S. Nuclear Regulatory- l@
Commission Philadelphia Electric Company Washington, DC 20555 Attn: Edward G. Bauer, Jr.
is Docketing and Service Section VP and General Counsel y 2301 Market St. =
Office of the Secretary Phila., PA 19101 U.S. Nuclear Regulatory 5 Commission Thomas Gerusky, Director M Washington, DC 20555 Bureau of Radiation Protection, DER Ti EL 5th fl, Fulton Bank Bldg. E Atomic Safety and Third and Locust Sts.
Licensing Board Panel Harrisburg, PA 17120 E U.S. Nuclear Regulatory g Commission Spence W. Perry, Esq. y Washington, DC 20555 gg Associate General Counsel =
Atomic Safety and FEMA Room 840 -
b EE Licensing Appeal Panel 500 C St., SW EE U.S. Nuclear Rerulatory Washington,.DC 20472 Commission =.
~ ' ~
==
Washington, DC 20555 Zori Ferkin, Esq. Ms Governor's Energy Council GE P.O. Box 8010 1625 Front St. {}=
=
mm Harrisburg, PA 17105 E, j?:?
.g-
Jay M. Gutierrez, Esq. Robert Sugarman, Esq.
U.S. Nuclear Regulatory Commission Sugarman and Denworth Region 1 Suite 510 l 631 Park Ave. North American Building l King of Prussia, PA 19406 121 S. Broad St.
Phila., PA 19107 Director, PEMA Basement, Transportation David Wersan, Esq.
and Safety Building Assistant Consumer Advocate Harrisburg, PA 17120 Office of the Consumer Advocate 1425 Strawberry Square Angus Love, Esq./Myggggy Aid)
C Harrisburg, PA 17120 107 East Main St Norristown, PA 19401 Gregory C. Minor Robert Anthony MHB Technical Associates 103 Vernon Lane 1723 Hamilton Ave.
Moyla'n, PA 19065 San Jose, CA. 95125 Martha W. Bush, Esq.
Kathryn S. Lewis, Esq.
Solicitor's Office City of Philadelphia Municipal Services Building Phila., PA 19107 -
Steven Hershey, Esq.
community Legal Services 5219 Chestnut St.
Phila., PA 19139 Marvin I. Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.
Ambler, PA 19002 Joseph H. White,III 15 Ardmore Ave.
Ardmore, PA 19003 February 6. 19A4 9485 W PHYLLIS {1TZER V m, 7 _ _ , ,,.. _ .