ML20087J486

Motion to Require Further Depositions Re Contention VI-I Concerning 760601 Broomstick Deficient Welding Affair

ML20087J486
Person / Time
Site:	Limerick
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: ML20087J465 ML20087J476 ML20087J486
References
NUDOCS 8403220234
Download: ML20087J486 (2)

Text

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AIR and WATER m,a -=y l 1

Pollution Patrol March 19 lbP 422 A10:51 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, n but the NRC Quality Con-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 l

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 .

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