ML20080R737

Motion for Extension of Discovery Period Re Contention VI-1.Records Needed on Logs & Welds Involved W/Broomstick Issue.Related Correspondence

ML20080R737
Person / Time
Site:	Limerick
Issue date:	02/21/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel
References
NUDOCS 8402280393
Download: ML20080R737 (2)

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"3NDENQ AIR and WATER Pollution Patrol F BROAD AXE, PA. Feb. g ,

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,,7 7 . _

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ORANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station 50-353 Units 1 and 2)

Judge Lawrence Brenner, Chairman; Dr. Peter Morris; Dr. Richard Cole Gentlemen:

AWPP (Romano) 4th Request re Interrogatories concerning Con-tention VI-l dated Dec. 5, 1983, in particular the first interrog-atory, asked completion dates for approximately fifty log numbers.

The Applicant answered, "there is no completion date on certain inspection log entries because the inspection activities required for items included in the scope of that inspection record had not been completed at the time the log was made available. Inspection planning and the scoping of the inspection records started early in the project and is a continuing process. The work is performed in the sequence prescribed by construction schedules, and the final inspections are performed after the work is completed. The comple-tion date is entered after the final inspections that are within the scope of the inspection record are completed". ,

AWPP asserts that most of these log numbers for which we asked completion dates go back to 1976 and 1977. If the completion date is entered after the final inspection (as Applicant stated), and none is shown as of the Applicant's Interrogatory response date of Dec. 28, 1983, it must be presumed the inspections have not yet been done.

Therefore, AWPP requests extension of Discovery period in order to get complete records on those logs and welds involved which occured principally just previous to the time Inspector Ferretti was involved with the IE 76-06-01 " broomstick" affair.

8402280393 840221 PDR ADOCK 05000352 A/

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AIR and WATER W Pollution Patrol BROAD AXE,PA.

(2)

Letter re 4th Interrogatory " completion dates" continued.

The request is made also because the procedure to inspect welds years after they were done means reports on improperly done welds are not now available as it affects Contention VI-1.

Further, AWPP requests whether any listed welds are now inaccessible, in order to continue the search.

Respectfully submitted AIR & WATER POLLUTION PATROL f

_> q<x:;4 3(3 m FraB1C R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 FRR/jch i

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