ML20069M219
| ML20069M219 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/18/1982 |
| From: | Cassel D BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES, DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SAFE ENERGY FOR NEW HAVEN |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20069M223 | List: |
| References | |
| NUDOCS 8211230486 | |
| Download: ML20069M219 (2) | |
Text
11/18/82
- If; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKETED BEFORE T!!E ATOMIC SAFETY AND LICENSING BOARD USNFC In the Matter of
)
82 NOV 22 #0:51
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COMMONWEALTil EDISON COMPANY
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Docket Nos. 50-454 ;pgggggAg,
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50e455 h; 2. SERVic'E (Bryon Station, Units 1 and 2)
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ii?ANCH MOTION TO DIRECT NRC STAFF TO COMMENCE SPECIAL INSPECTION DAARE/ SAFE, by its undersigned coun.sel, moves the Board to direct the NRC staff to commence its special inspection of DAARE/
1 SAFE's allegations of unsafe QA/QC practices at Byron.
In support of this motion, DAARE/ SAFE states as follows :
1.
On September 23, 1982, DAARE/FAFE moved the Board to reconsider its summary disposition of DAARE/ SAFE's contention number one relating to QA/QC at Byron.
DAARE/ SAFE's motion was based in part on affidavits of three former employees of contractors at Bryon, including a QA/QC Inspector and a QA auditor.
2.
On October 12, 1982, in its response to DAARE/ SAFE's motion, the NRC staff represented that it would commence "immediately" a special inspection of the allegations of DAARE/ SAFE's affiants, which it expected to complete "by December 1, 1982."
(Response at 7.)
3.
As detailed in the attached letter of this date from the a f fi ants ' counsel to the NRC staff, the special inspection has yet to commence in carnest.
8211230486 821118
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4.
The s taf f's foot-dragging on this special inspection prejudices DAARE/ SAFE's ability to prepare its case, especially since the Board has yet to rule on DAARE/ SAFE's pending, fully briefed September 23, 1982 motion to reconsider.
UllEREFORE, DAARE/ SAFE moves the Board to direct the NRC staff immediately to commence the special inspection and to complete it at the earliest reasonable date.
Novembe r 18 1982 Respectfully submitted, Douglass W. Cassel, Jr.
Jane !!. Whicher Attorneys for DAARE/ SAFE with respect to issues concerning quality assurance / quality control by:
d h-DouglasE W. Cassel, Jr.
I For Service:
Douglass W. Cassel, Jr.
Jane M. Whicher l
109 North Dearborn Suite 1300 Chicago, IL 60604 (312) 641-5570 i
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