ML20053B885
| ML20053B885 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/24/1982 |
| From: | Bernabei L HARMON & WEISS, HOURIHAN, P. |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8206010316 | |
| Download: ML20053B885 (3) | |
Text
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weLLIAM S. JOR D AN, Ill LCC L. BISHOP Or COUNSCL DI ANC CURRAN L.THOM AS GALLOWAY LYN N C B E RN ASCI LUCIA S. ORTH May 24, 1982 Dr. Nuzio Palladino Chairman Nuclear Regulatory Commission
'.'Jashingt on,
D.C.
20555 Ret Docket Numbers STN 50-528 STN 50-529 STN 50-530
Dear Dr. Palladino:
I am writing to respond to the May 11, 1982, letter of Arizona Public Service Company Vice President Thomas Woods in which Mr. Woods requested and NRC investigation of Inter-venor Patricia Lee Hourihan's allegations about deficiencies in the electrical systems at Palo Verde.
As attorney for Ms. Hourihan. I am today submitting a motion to the Licensing Board for leave to file new contentions concerning serious deficiencies in the electrical work related to the safety systems at Palo Verde, and falsi-fication of reports on this electrical work.
We seek also an order from the Board protecting from disclosure the identity of the worker who has sworn to a detailed affidavit about these deficiencies vitally affecting the plants' safety.
Ms. Hourihan did not believe it appropriate to raise these issues in the licenLing proceeding before she had an opportunity to protect this man, who has already re-ceived a death threat on his life, and before she could at least partially substantiate the very serious, safety violations he alleged.
After obtaining an affidavit from the worker and con-sulting with other experts about the soundness of his charges, Ms. Hourihan, through the normal channels of the licensing proceeding, moved that the Licensing Board admit new con-tentions and order an independent investigation of these Dso3 8206 01031 g S h jo
HARMON 8e WEISS page two allegations.
Ms. Hourihan is not using these serious allegations as a " delaying tactic."
Quite to the contrary, she wishes to protect the safety of the worker, who has turned to her (and not to APS) in the hope of seeing his charges brought before and carefully examined by the Licensing Board.
As explained in Intervenor's Motion for Leave to File New Contentions, the worker had previously been rebuffed by both the NRC inspector on-site and the NRC Las Vegas office.
On several occasions he asked APS supervisors to remedy deficiencies in the electrical systems and to stop falsifi-cation of records.
He was told not to worry because the quality assurance inspectors would catch the problems.
Because some of the records on electrical work were falsi-fied, however, the quality assurance program cannot possibly detect all these deficiencies.
In addition, Vice President E.E. Van Brunt's office showed little interest in the worker's complaints.
Moreover, it is Intervenor and not APS who is most concerned about protection of this man's life.
He has said in his affidavit that he and other workers fear being blackballed from work at all nuclear plants if they are identified as troublemakers.
In addition, after a death threat he fears further harassment of himself and his family if his identity becomes public.
Because of the lack of response from APS and the NRC the worker spoke to Ms. Hourihan about his concerns about the safety of the plant.
Ironically APS seems more concerned with finding out the man's identity and the specifics of the charges than with ensuring open litigation of the safety issues before the Licensing Board.
In their attempt to rush these licensing hearings to completion, for example, Joint Applicants, including APS, have opposed Intervenor's attempts to address serious issues about the adequacy of their water supply for safe operation and shutdown of Palo Verde.
If now Joint Applicants are truly interested in a constructive airing of these allegations about deficiencies in the electrical systems and falsification of records, I would expect they too will support Intervenor's Motion to Add New Contentions and Request for an Independent Investigation.
Sincerely yours,
!/
We L
e Bernabei
II ARMON & WEISS Dr. Palladino Page 3 May 24, 1982 cci Governor Bruce Babbitt Robert M. Lazo, Esq.
Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Richard F. Cole Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Dixon Callahan Union Carbide Corporation P.O. Box Y Oak Ridge. Tennessee 37830 Lee Scott Dewey, Esq.
Office of Executive Legal Director U.S. Regulatory Commission Rand L. Greenfield, Esq.
Assistant Attorney General P.O. Drawer 1508 Santa Fe, New Mexico 87504 Arthur C. Gehr, Esq.
Charles Bischoff, Esq.
Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 Honorable Barry Goldwater Honorable Dennis DeConcini Honorable John J. Rhodes Honorable Eldon Rudd Honorable Bob Stump Eonorable Morris K. Udall Dr. Harold Denton Arizona Corporation Commission Bud Tims. Chairman Diane McCarthy, Commissioner Jim Weeks, Commissioner Tim Barrow, Executive Secretary