ML20080S078
| ML20080S078 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/14/1983 |
| From: | Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080S084 | List: |
| References | |
| NUDOCS 8310180234 | |
| Download: ML20080S078 (3) | |
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00CMETED USNRC UNITED STATES OF AMERICA 13 OCT 17 P3:26 NUCLEAR REGULATORY COMMISSION CFFICE OF sicggggy.
00CMETING & SEftylcf' Before the Atomic Safety and Licensing Board BRANCH In the Matter of
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Philadelphia Electric Company
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Docket Nos. 50-352
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50-353 (Limerick Generating Station,
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Units 1 and 2)
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APPLICANT'S ANSWER TO THE OCTOBER 2, 1983 PLEADING OF AIR AND WATER POLLUTION PATROL On October 2, 1983, the Air and Water Pollution Patrol
("AWPP"), an intervenor in the captioned proceeding, submit-ted an untitled motion.
The relief requested is that affidavits from Applicant's management be required to show that welders who performed specific welding tasks "had passed their apprenticeship and had passed qualification tests for that type of circular weld and for that type of l
l steel and for that type of welding rod used. "
AWPP also f
moved that " tests involving the Limerick reactor that were done by Radiation Management Corporation ("RMC") at the time Applicant's President was Chairman of the RMC board and Applicant was part owner of RMC be redone by an independent testing facility.
Applicant opposes these requests as being unsupported and without basis.
Initially, this Board has not acted on the pending motion of AWPP to reconsider the denial of Contention VI-l DR 0
0 00 g
related to quality assurance.
Thus it is premature to file motions on this matter.
If AWPP is intending to submit these matters as new contentions, it has failed to fulfill the requirements of 10 C.F.R.
S2.714, particularly with regard to addressing the criteria regarding lateness.
With regard to the first request, AWPP points to no specific reason for the requested affidavit.
AWPP brings forth no reasons why these welds or the welders should be singled out for this extraordinary treatment.
The existence of an IE Information Notice does not in any way indicate l
that a problem exists at the Limerick site.
In the absence of specific informa. tion that a deficiency may exist, it is
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up to the NRC's Office of Inspection and Enforcement to generally oversee the construction of the
- facility, including necessary audits of welding operations.
In the j
absence of even a specific allegation of impropriety related l
l to the specific welds, this portion of the motion should be l
denied.1/
With respect to the motion that the tests performed by RMC be redone by an independent testing facility, AWPP has not specified what tests were performed by RMC or that it l
has any independent evidence that a specific deficiency 1/
AWPP states that the matter of the containment welds is somehow related to the failure of Applicant to identify l
all welds inspected by a particular inspector which j
matter is before the Licensing Board.
The nature of the relationship is not discussed.
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exists in. any such tests..
Certainly it points to no NRC regulatilon which would require that an independent testing
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facility perform all tests at a nuclear power facility.
The requested relief should be denied.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Mark J. Wetterhahn Counsel for Philadelphia Electric Company October 14, 1983 o
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