ML20082N907

Response to Util Motion for Reconsideration of 831121 Memorandum & Order Establishing Discovery Schedule Re Contention VI-1.Earlier Response Impossible Since Necessary Technical Rept Not Received.Date of 840206 Reasonable

ML20082N907
Person / Time
Site:	Limerick
Issue date:	12/01/1983
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8312080013
Download: ML20082N907 (2)

Text

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AIR and WATER E" P'ollution Patrol BROAD AXE, PA. Dec. 1, 18$30EC -7 RO:45 U.S. Nuclear Regulatory Commission Washington, D.C.20555 .

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BEFORE THE ATOMIC SAFETY AND LICENSING BbARERANCH In The Matter of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station and 50-353 Units 1 and 2)

ANPP RESPONDS TO APPLICANT'S MOTION FOR RECONSIDERATION OF " MEMORANDUM AND ORDER ESTABLISHING DISCOVERY SCHEDULE" re CONTENTION VI-1.

As indicated by reasons detailed in my lecter of November 14, 1983, denial of sufficinet time for Discovery involved in the overwhelmine task assigned would neither serve the safety of the public nor the com-plete information needed in the record. The Applicant must remember the task developed as a result of the 50-353-76-06 affair. That over-whelming task is evident in wording of the Board, namely; Applicant has failed to control performance of wel-ding and inspection thereof in accordance with Qua-lity Control and Quality Assurance procedures and requirements, and has failed to take proper and corrective actions when improper welding has been discovered.

While I had tried to start the overwhelming Discovery task, I was confronted with the immediate very tight schedule involved in V-4 and the Nov. 1, 15, 22, and 29 deadlines

• Each requirement was totally unfamiliar as to meanino and procedure. So that with the loss of Coun-sel Dorsey guidance, other attorneys I contacted admitted uncertainty as to exact requirements to guide me. The result was loss of time and wasted effort.

Further, inspection and Engineering Infraction reports I had mar-ked for copying at least three weeks ago have not been recieved as of this date because the copies had been delivered to the Applicant's office (I always previously picked up and paid for the copics at the ~

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L AIR and WATER Pollution Patrol BROAD AXE, PA.

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Rosponse To Applicant's Motion For Reconsideration of 11/28/83 cont.:

Xcrox Copy Center at 399 Market St.).

In checking with Mr. Cullen in charge of the Applicant's Document Room, I was told his office picked up the copies so as to expediate them to me. He said the copies had been mailed to me on Wednesday, November 23, 1983. That's 2 weeks after I requested the copies be made, and I still have not received same.

Because I have had to cut down on my reading due to eye strain and because I have not yet received the delayed copies, I had to cancel a meeting set for December 1, 1983 with Mr. Wetterhahn until I inspect more documents.

No doubt time and physical factors resulted in my missing the Nov-ember 1, 1983 filing requirement and extension of time made available by the Board. I certainly would have responded earlier had I noted it properly.

Therefore, while I tried to conform and made limited progress in the task, re VI-1, the February 6, 1984 date in your November 21, 1983 Order is fair and reasonable, and will encourage the possibility of better dealing with discovery. This,'too, will require much cooper-ation relative to supply of copies and answers to Interrogatories I have recently sent, with no response as yet.

Repsectfully yours, AIR & WATER OLLUTION PATROL O s-$-- .

Frank R. Romano, Chairmam 61 Forest Ave.

Ambler, Pa. 19002 FRR/jch and now preparation for possibly a week of hearings.

I certify the Service List has been served.

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