ML20069M219

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Motion to Direct NRC to Commence Special Insp Immediately of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Allegations of Unsafe Qa/Qc Practices at Plant
ML20069M219
Person / Time
Site: Byron  Constellation icon.png
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

  • If; UNITED STATES OF AMERICA 11/18/82 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 ) Docket Nos. 50-454 ;pgggggAg,

) 50e455 h; 2. SERVic'E' (Bryon Station, Units 1 and 2) ) 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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