ML20087J486

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Motion to Require Further Depositions Re Contention VI-I Concerning 760601 Broomstick Deficient Welding Affair
ML20087J486
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/19/1984
From: Romano F
AIR AND WATER POLLUTION PATROL
To: Brenner L, Cole R
Atomic Safety and Licensing Board Panel
Shared Package
ML20087J469 List:
References
NUDOCS 8403220234
Download: ML20087J486 (2)


Text

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AIR and WATER m, =y a -

Pollution Patrol lbP 22 A10:51 March 19 4

Atomic Safety & Licensing Board d;j.. L..

U.S.

Nuclear Regulatory Commission A c i_0 6 3H.u Washington, D.C.

20555 SM In The Matter Of PHILADELPHAI ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station and 50-353 Units 1 and 2)

Judges Lawrence Brenner, Peter Morris and Richard Cole AWPP MOVES BOARD REQUIRE FURTHER DEPOSITIONS RE VI-I AWPP (Romano's) primary purpose to take time off from work and incur an expensive charge for a court reporter, was to get first-hand, face-to-face clarification on ambigious nuclear in-dustry parlance as it relates to details surrounding the 76 01 "Broomsitek" deficient welding affair.

I had indicated to the Board I would want key people,such as the NRC, the Bechtel, and the Applicant's QA-QC inspectors.

It is inexcusable, therefore, that Mr. Corcoran, whom I specif-ically asked for, I feel, was kept away.

Similarly it is ironic that the NRC had their Counsel prese't, but the NRC Quality Con-n trol inspector who led the inquiry into the Broomstick affair was absent.

(

While Mr. Boyer was there with Mr. Clohecy, Mr. Clohecy con-tinued to avoid answering questions by repeatedly asking that the question be reasked.

He avoided answering directly, and as 1

a result I could not resolve the question of evasion of interrog-atories.

Altogether, therefore, the purpose and right to depose 1

was, in effect, violated.

8403220234 840319 PDR ADOCK 05000352 O

PDR

AIR and WATER Pollution Patrol BROAD AXE, PA.

(2)

AWPP Moves Board Require Further Deposition Re VI-I continued:

Further, Mr. Cleaecy, on repeated questioning answered that what welds were chosen for inspection and how many were chosen is up to his judgement.

In fact Mr. Bcyer, included a statement that even a welder might use his judgement even if specified procedure exists.

On these bases, I move that the Board require another pre hearing on the VI-I contention.

Respectfully submitted, AIR & WATERgf0LLUTION PATROL

[.); k G O Frank R.

Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 I certify the service list has been served:

Lawrence Brenner, Chair-man; Dr. Richard Cole; Dr. Peter Morris; Troy B.

Conner, Esq; Ann Hodgdon, Esq; Atomic Safety and Licensing Board; Docketing and Service Section; Atomic Safety & Licensing Appeal Panel; without enclosure to Edward G.

Bauer; Robert L.

anthony: Marvin I Lewis; Thomac Gerusky; Walter W.

Cohen; Martha Busch; Steven P.

Hershey, Esq: Phyllis Zitzer; Charles Elliott, Esq.; Nori G.

Ferkin, Esq; Angus Love, Esq. Joseph l

White III; Robert J.

Sugarman,Esq; Director PEMA; Spence W. Perry, Esq; Jay M.

Gutierrez, Esq; and James Wiggins O

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