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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
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07/21/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PHILADELPHIA ELECTRIC COMPANY ) Docket No. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
NRC STAFF'S FIRST ROUND DISCOVERY REQUESTS OF DEL-AWARE Pursuant to 10 C.F.R. 5 2.740b of the Commission Regulations and the Atomic Safety and Licensing Boards Order (Approving Schedule Proposed by Staff and Del-Aware) (July 13,1982), the NRC Staff requests that Del- - .
Aware answer the interrogatories set forth below. Each interrogatory shall be answered separately and fully, in writing and under oath or affirmation, and the answers shall be signed by the person (s) making them.. In addition, pursuant to 10 C.F.R. Q 2.741, the NRC Staff requests that Del-Aware make available for Staff inspection and copying (or provide copies of), those documents designated by Del-Aware in it; answers.1/
The responses to these interrogatories should be supplemented if any new information arises with respect to the matters identified in
-1/ If a document was prepared by the NRC Staff or its consultants, or was submitted by the Applicant in connection with the captioned matter, the date of its preparation by the Staff or its submittal to the Staff should be identified but a copy need not be made available by Del-Aware.
DESIGNATED ORIGINAIl Corttric$ z y ,
8207230140 820721 PDR ADOCK 05000352 O PDR .
__________________________-_____-__J
e -D
> - * ' 'e 2- ' ~
10 C.F.R. 5 2.740(e)(1)-(2).2/
General Interrogatories _/3 G-1 State whether you intend to present any expert witnesses on the subject matter at issue in:
a) Contention V-15 o) Contention V-16a c) Contention V-16b .
If so, provide the names, addresses (residence and business), and professional qualifications of those persons you expect to call as expert witnesses, state the subject matter on which'the expert is expected to testify, state the substance of the facts and opir. ions.
to which the expert 7, expected to testify and provide a summary of the grounds.for each opinion.
i 2/ These provisions state:
(1) A party is under a duty seasonably to supplement his response with respect to any' question directly addressed to (1) the identity and location of persons having knowledge of discoverable matters, and (ii) the identity of each person expected to be called as an expert witness at the hearing, the subject matter on which he is expected to testify, and the sub,tance of his testimony.
(2) A party is under a duty seasonably to amend a prior response if he obtains information upon the basis of which (i) he knows that the response was incorrect when made, or (ii) he knows that the response though correct when made is no longer true and the circumstances are such that a failure to amend the response is in substance a knowing concealment.
3_/ These interrogatories should be answered separately with respect to each contention.
s -
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G-2 Identify by' title, author, date of issuance or publication, and issuer or publisher, all documents that you intend to use (refer to or offer in evidence) in presenting your direct case on the contentions listed in Interrogatory G-1 and all documents that you intend to refer to in conducting your cross-examination of witnesses for other parties who may testify in connection with any admitted contention, and make available those documents for Staff inspection and copying (or provide copies of them).
Specific Interrogatories Contention V-15 and V-16a (in part)
S-1 Identify and describe the adverse impact you assert will occur to the American shad and shortnose sturgeon as a result of the relocation of the Point Pleasant intake.
S-2 Specify and describe in detail all the physical and biological factors associated with the relocation of the intake that would result in the adverse impact identified in your response to Interrogatory S-1.
S-3 Provide any available information on the distribution, abundance, and life stages of American shad and shortnose sturgeon that inhabit l
or migrate through the stretch of the Delwaware River in the vicinity of the proposed Point Pleasant Pumping intake.
l l
V l
l
' ~'
- 4' S-4 Describe the " pool" which you assert will be drawn down by the operation of the intake and its associated pump station.
S-5 Identify and describe the major fish resource that would be adversely affected by drawdown of this pool. Indicate with particularity what biotic and abiotic factors are responsible for 3
this adve se effect and how they contribute to adversely affecting this fish resource. -
S-6 Indicate and describe the exact seasonal range of river surface elevation draw-down alleged to be caused by the placement and operation of the Pt. Pleasant intake structure. Indicate each basis for alleging that this drawdown will adversely affect fish resources, boating and recreation.
Contention V-16a S-7 Provide the basis for the assertion that "constart dredging maintenance" will be necessary at the Point Pleasant intake.
! S-8 Identify and describe any noise associated with operations of the intake and its associated pump station.
S-9 Identify and describe in detail how the noise identified in 'your response to Interrogatory S-7 will adverse affect the peace and tranquility of the Point Pleasant proposed historic district.
1 m
-52 S-10 a) Identify the specific areas that you assert are sensitive to the noise identified in your response to Interrogatory S-8.
b) Mark the sensitive areas identified in Interrogatory S-10a on a map of the Point Pleasant vicinity.
c) Explain why each particular area was identified as sensitive to noise.
Contention V-16b S-11 Identify and describe in detail the basis for the contention that toxics will exist in the Bradshaw Reservoir in sufficient concentrations to contaminate groundwater supplies.
S-12 Specifically identify which toxic materials will be present in the proposed Bradshaw Reservoir upon its filling.
S-13 Provide the basis for the assertion that water in the Bradshaw Reservoir will be able to escape by seepage into area groundwater.
S-14 Set forth your definition of and criteria for contamination of groundwater.
S-15 Identify and describe in detail the basis for your contention that there will be sufficient seepage from Bradshaw Reservoir to result in contamination of groundwaters.
i
. . a S-16 Set forth your definition of hydraulic saturation. a) Do you consider hydraulic saturation a risk comparable to groundwater contamination? b) If so, explain why, and how it compares.
i S-17a) Identify and describe in detail any studies regarding Bradshaw Reservoir upon which your contention is based. b) If studies are identified, discuss how the data and/or conclusions in these studies support your contention.
Respectfully submitted, n
Elaine I. Chan -
Counsel for NRC Staff Dated at Bethesda, Maryland this 21st day of. July 1982 l
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UNITED STATES OF AtiERICA
-. NUCLEAR REGULATORY COMt11SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352
) 50-353
)
(Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATEhF SERVICE ar I hereby certify that copie's _of "NRC STAFF'S FIRST ROUND DISCOVERY REQUESTS OF '
DEL-AWARE" in the above captioned proceeding have been served on the followin.g by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, by double asterisk through special mail service, this 21st day of July 1982:
Lawrence Brenner, Esq., Chairman
- lir. Edward G. Bauer, Jr.
i Administrative Judge Vice President & General Counsel l
U.S. Nuclear Regulatory Commission Philadelphia Electric Company
, Washington, D.C. 20555 2301 tiarket Street l
Philadelphia, PA 19101 Dr. Richard F. Cole
- Administrative Judge Troy B. Conner, Jr., Esq.
- U.S. Nuclear Regulatory Commission Mark J. Wetterhahn, Esq.
Washington, D.C. 20555 Conner and Wetterhahn 1747 Pennsylvania Avenue, N.W. '
Dr. Peter A. liorris* Washington, D.C. 20006 Administrative Judge U.S. Nuclear Regulatory Commission Mr. tiarvin I. Lewis Washington, D.C. 20555 6504 Bradford Terrace Philadelphia, PA 19149 Mr. Frank R. Romano Air and Water Pollution Patrol James M. Neill, Esq. .
61 Forest Avenue Associate Counsel for Del-Aware Ambler, PA 19002 Box 511 Judith'A. Dorsey, Esq.
Limerick Ecology Action Joseph H. White.III l 1315 Walnut Street, Suite 1632 11 South tierion Avenue l Philadelphia, PA 19107 Bryn fiawr, PA 19010
'O O ** *m
'9'8 O v Q _'e avsm = Mm r_me n e rs
.c Environmental Power Coalition on Nuclear Walter W. Cohen Dr. Judith H. Johnsrud, Co-Director Consumer Advocate 433 Orlahdo Avenue Office of Attorney General State College, PA 16801 1425 Strawberry Square Harrisburg, PA 17120
' Thomas Gerusky, Director Bureau of Radiation Protection Robert W. Adler Dept. of Environmental Resources Assistant Counsel 5th Floor, Fulton. Bank Building
. Commonwealth of Pennsylvania, DER Third and Locust Streets 505 Executive House Harrisburg, PA 17120 P. O. Box 2357-Harrisburg, PA 17120 Director Pennsylvania Emergency Management Steven P. Hershey, Esq.
Agency Law Center North Central -
Beury Building Basement, Transportation & Safety Building 3701 North Broad Street Harrisburg, PA 17120 Philadelphia, PA 19140 John Shniper Meeting House Law Building-& Gallery **Sugarman and Denworth Mennonite Church Road,- Suite 510 Schuylkill Road (Route 724) North American Building Spring City, PA 19475 121 South Broad Street Philadelphia, PA 19107 Robert L. Anthony Friends of the Earth of the Donald S. Bronstein, Esq.
Delaware Valley The National Lawyers Guild 103 Vernon Lane, Box 186 Third Floor Moylan, PA 19065 1425 Walnut Street Philadelphia, PA~ 19102 Alan J. Nogee The Keystone Alliance Atomic Safety & Licensing Board
- 3700 Chestnut Street U.S. Nuclear Regulatory Commission Philadelphia, PA 19104 Washington, D.C. 20555 W. Wilson Goode Atomic Safety & Licensing Apoeal Managing Director Panel
- City of Philadelphia U.S. Nuclear Regulatory Comission
. Philadelphia, PA 19107 Washington, D.C. 20555 William A. Lochstet Secretary
- 119 E. Aaron Drive U.S. Nuclear Regulatory Commission State College, PA 16801 ATTN:
Chief, Docketing & Service Br.
Washington, D.C. 20555 Charles W. Elliott, Esq.
123 N. 5th Street, Suite 101 ,
Allentown, PA 18102 g
Counsel for NRC Staff
. . __. _.._. __ _