ML20086U050
| ML20086U050 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/02/1984 |
| From: | Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | AIR AND WATER POLLUTION PATROL |
| References | |
| NUDOCS 8403070142 | |
| Download: ML20086U050 (7) | |
Text
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itEUdED CoimESPONDENCE 9,VETED vdec Idle -6 p7l,.g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.MThfkhg, Before the Atomic Safety and Licensing Board JAtlc4
~In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353
-(Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S RESPONSE TO AWPP REQUEST FOR
. EXTENSION OF DISCOVERY PERIOD FOR CONTENTION VI-l By letter dated February 21, 1984, but not received by Applicant's counsel until February 27, 1984, Air and Water Pollution Patrol ("AWPP"), an intervenor in this proceeding, requested that the period for discovery granted by the Board on Contention VI-1 be extended for some indefinite period.1!
Applicant opposes the relief requested as being totally unjustified and unsupported.2_/
This appears to be another one of a series of dilatory pleadings which would delay AWPP's required respecification of Contention VI-1.
1/
Inasmuch as the period for discovery on this contention closed on January 16, 1984, the request is properly one to reopen discovery.
Furthermore, as pointed out in previous filings, the Board has prohibited requests for affirmative relief in the form of letters.
2/
This matter was discussed with Mr. Romano and the NRC Staff on March 2,
1984.
Another attempt at an explanation of welding inspection logs was made by Applicant's counsel.
Mr. Romano stated he still wished to pursue the request.
8403070142'840302 PDR ADOCK 05000352 O
t'.
Initially, this request is late without any explana-tion.
As admitted by AWPP, the responses in question date back to December 28, 1983 leaving a period of almost two 4
months in which the intervenor could have sought additional information or any inspection records, whether complete or in process, via discovery or requested timely relief from the Atomic Safety and Licensing Board
(" Licensing Board" or
" Board").
In addition to being late, this request lacks merit.1#
Applicant's answer to the subject interrogatory is complete and responsive.
It does not support the requested relief.
Some background is necessary to understand the context of the answer.
In inspecting welds, Applicant uses a aystem of weld inspection plans.
Each plan covers one or more welds, usually of the same commodity, e.g.,
structural or hanger welds, in specific locations or by system.
As each weld inspection plan is prepared, it is assigned a number in the appropriate log in order to track it in accordance with the quality assurance program.
It was these logs which were made available for Mr. Romano, representative of AWPP, to examine.
3/
The subject of this interrogatory was one of the matters specifically discussed in the meeting between Mr.
Romano, representative of AWPP, and Applicant's technical representatives in December 1983.
-j '
The close-out entry in the log is not made until the very last weld covered by the plan has been inspected.
Merely because an inspection record has been open for a
- number of years does not necessarily mean that welds which were made some years ago have not been inspected.
For example, usual practice for pipe welds is to inspect them shortly after they have been performed.
Thus, the fact that an inspection plan may remain open may mean that one or more
- welds, because of construction scheduling, has not been completed and thus the corresponding inspection has also not been accomplished.
In some cases, welds which have been performed sometime ago may not yet have been inspected, however, this fact lends no support for the requested relief.
For example, the welds on a hanger may not be inspected until the entire hanger has been completed and no more changes are contem-plated.. An inspection done at that time would be as valid as one'done immedic.tely after the weld was completed.
AWPP implies that an uninspected weld might be made inaccessible.
This possibility is remote and would be protected against by
.the provision of appropriate hold points in subsequent con-struction.
In any event, if the inspection could not be accomplished, a nonconformance report for proper disposition would have to be prepared.
Thus, the requested relief is completely without merit.
AWPP has failed to give any support for the proposition that required inspections will not have been done by fuel t
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loading.
The purpose of the logs is to assure that this is accomplished.
I For the foregoing reasons the requested relief should be denied.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Mark J. Wetterhahn Counsel for the Applicant March'2, 1984 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and'2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Response to' AWPP Request for Extension of Discovery Period for Contention VI-1" dated March 2,
- 1984, in the captioned matter have been served upon the following by deposit in the
^
United States mail this 2nd day of March, 1984:
-Lawrence Brenner, Esq. (2)
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Docket..tng and Service Section
.Dr. Richard F. Cole Office of the Secretary Atomic Safety and-U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Ann P. Hodgdon, Esq.
Counsel for NRC Staff Office Dr. Peter A. Morris of the Executive Atomic Safety and Legal Director
. Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
4 q I
l Atomic Safety and Licensing Steven P. Hershey, Esq.
' Board Panel Community Legal U.S. Nuclear Regulatory Services, Inc.
Commission Law Center West North Washington, D.C.
-20555 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN:
Edward G. Bauer, Jr.
Angus Love, Esq.
Vice President &
107 East Main Street General Counsel Norristown, PA 19401 2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 61 Forest Avenue Ambler,. Pennsylvania 19002 Robert J. Sugarman, Esq.
Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of.
121 South Broad Street the Delaware Valley Philadelphia, PA 19107 106 Vernon' Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I.. Lewis Basement, Transportation 6504'Bradford Terrace and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120
. Phyllis.Zitzer, Esq.
Martha W. Bush, Esq.
Limerick Ecology Action Kathryn S. Lewis, Esq.
P.O. Box 761 City of. Philadelphia 762-Queen Street Municipal Services Bldg.
Pottstown, PA 19464 15th and JFK Blvd.
Philadelphia, PA 19107 Charles W. Elliott, Esq.
Brose and Postwistilo Spence W. Perry, Esq.
1101 Building lith &
Associate General Counsel Northampton. Streets Federal Emergency
'Easton, PA 18042 Management Agency 500 C Street, S.W., Rm. 840 Zori G. Ferkin, Esq.
Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director Governor's Energy Council Bureau of Radiation 1625 N. Front Street Protection Harrisburg, PA 17102 Department of Environmental Resources 5th Floor, Fulton Bank Bldg.
Third and Locust Streets Harrisburg, PA 17120
'** Federal Express - Saturday Delivery
.J- -
a Jay M. Gutierrez, Esq.
U.S. Nuclear Regulatory Commission
.. Region I-631 Park Avenue King of Prussia, PA 19406 James Wiggins Senior-Resident Inspector U.S.. Nuclear Regulatory c
Commission
.P.O.
Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Direccor'
' Department of Emergency Services 14 East Biddle Street.
West Chester, PA. 19380 Marr J.-Wetterhahn
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