ML20235A804

Air & Water Pollution Patrol (Romano) Reaction to Licensee time-defaulted Response for Production of Documents as Ordered by NRC Administrative judges,871120.* Requests That Util Be Reprimanded for Defaulting on 871120 Order

ML20235A804
Person / Time
Site:	Limerick
Issue date:	01/05/1988
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Cole R, Ferguson G, Wolfe S Atomic Safety and Licensing Board Panel
References
CON-#188-5292 OLA, NUDOCS 8801130043
Download: ML20235A804 (2)

Text

3nw t

AIR and WATER mn W

Pollution Patrol BROAD AXE, PA.

'88 JAN 11 P2:17 Jan 5, 1988 U.S. Nuclear Regulatory Commission

{0 Washington, D.C..20555 i

I[

BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Administrative Judges Honorable Sheldon Wolfe, Chairman Dr. Richard F. Cole Dr. George Ferguson In The Matter Of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Unit 1)

(Docket No. 50-352-OLA (TS Iodine)

AWPP (ROMANO) REACTION TO LICENSEE'S TIME-DEFAULTED RESPONSE FOR PRODUCTION OF DOCUMENTS AS ORDERED BY NRC ADMINISTRATIVE JUDGES, NOVEMBER 20, 1987 Previous to the Licensce's default on the NRC Adminis-trative Judges' Order of November 20, 1987 to provide AWPP's Discovery requests, dated December 7, 1987, AWPP (Romano) asked for an extension to permit completion of Discovery which could not be completed by December 22, 1987 because Licensee defaulted on the November 20, 1987 Administrative.

Order!.to-comply-with Discovery.

AWPP now asks that the Licensee be made show cause why it did not honor the Administrative Order re Discovery and to show cuase why the Licensee should not be denied the A-mmendemnt re Iodine Spike reporting on Recirculating Cooling Water Radioactive Iodine Concentration at Limerick 1.

Further complicating the situation, on January 3, 1988 AWPP received material dated December 29, 1987, purportedly answering our Discovery requests, which material we aliege mostly avoided our questiv.'s, and again asked for a Protective t.

Order.

Therefore, AhPP asks that the January 11, 1988 dead-line to answer Licensee's 9mumiry Disposition be extended u.itil a decision is made on Licensee's default of the Novem-i ber Order.

8801130043 880105

{DR ADOCK 05000352 PDR 1A pb

1

.c AIR and WATER

{

Pollution Patrel BROAD AXE, PA.

AWPP'S REACTION TO LICENSEE'S TIME-DEFAULTED RESPONSE cont.

l It is evident that the Licensee did not honor the November 20, 1987 Memorandum and Order and has since asked that AWPP be denied Discovery.

AWPP asks that Licensee be made to honor the Memorandum and Order.

AWPP asks that Licensee's repeat request to refuse Discovery be denied.

AWPP asks that Licensee be reprimanded for defaulting on Order of November 20, 1987.and denied Ammendment request-ed by Licensee.

Respectfully submitted, AI

& WA R,P9LLUTION PARTOL Fra R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 FRR/jch We certify the above has been served on the latest Service List where applicable.

_.--_-m__mm_

_. -