ML20077J091

Requests Reconsideration of ASLB 830726 Order Denying Contention VI-I Re Qa.Aslb Order Compromises Right to Due Process

ML20077J091
Person / Time
Site:	Limerick
Issue date:	08/05/1983
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel
Shared Package
ML20077J090	List: ML20077J089 ML20077J091 ML20077J092 ML20077J093 ML20077J096
References
NUDOCS 8308120241
Download: ML20077J091 (1)

Text

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AIR and WATER occxtT_to USNRu Pollution Patrol BROAD AXE, PA. *hE*hg g98P2 :25 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comnission CFFIt N.3,N e k.

Washington, D.C.20555 00CNU g gy Laurence Brenner, Esq., Pcter A. Morris, and Richard F. Cole In the Matter of PHIIADELPHIA ELECTRIC COMPANY (Linerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50-353

Dear Administrative Judges:

Even though I do not have the icgalese er.perience nor the legal staff the Applicant enjoys, I do have justification in stating that (re Board's statements O re Contention VI-I) that the 2nd Special Prehearing Conference Order of July

$ 26, 1983 ic totally unfair.

Further, I believe the Board's decision apparantly comproniscs ny right to E due process, in having prenaturely, albeit tentatively, rejected ny Quality Assurance u Contention.

E E The basis for the rejection, as the Board states, is on the unsubstantiated y assertions by the Applicant's Counsel, re inspection of all welds, accessible and

inaccessibic.

5 E

Further the Board in such rejection states I did not provide "better specificity E and basis " and also suggests I nou ask for nore tine in that regard. I did not e so ask, because in enclosure 2 of my Sept. 3, 1982 letter enclosed (as supported E by enclosued letters of May lo and 25, 1983, I asked specific questions of the Applicant, the answers to which I uould use to provide "better specificity and E basis". The Applicant did not provide the ansvers that dealt specifically uith proof that all ucids, accessible and inaccessible inspected by the inspector in-t! volved in IE report Mo.60-353-76/06 7_

e Contrary to Board's statenent,(page 38 of July 26 order) quote: "nothing in

.h AITP's Letter to Board of 'tay 25, 1083, responding to Applicant's Counsel's letter E of "ay 20, 1983, renedies the fatal absence of basis for believing the Applicant 5 limited its follou-up action to accessibic ucids", the "ay 25, 1083 letter specif- l itally, points out the deficiencies in Applicant's reports, one by one, chich purported to substantiate all uelds were inspected and not all AL'S Code requirements. I

_5 Further the Board states "A"PP is not alleginr that any particular defect still exists". Intervenor did not allene, he specifically stated the shoching revelations b of repeated infractions in uelding, false records of insnected nelds, inproperly

nixed concrete, inproperly placed concrete (see Ir Report No. 50-353/76-00(10/13/76) y still cy.ists at Lincrich to result in hinh potential for accident.

1 And the same effort to hide nony sinitar and repeated infractions by Applicant i and contractors inspectors, nore than constitute a nattern of carclessness upon which J. I ask the P,oard to reconsider such contention.

9300 g0 2 PDR Franh 9. "onano, Chairnan gDR Air 6 Unter Pollution Patrol