ML20092B726

Answer Opposing Air & Water Pollution Patrol (Awpp) 840608 Motion to Reopen Reconsideration Re Contention VI-1.AWPP Basis for Motion Relies on Util Which Fails to Support Requested Relief

ML20092B726
Person / Time
Site:	Limerick
Issue date:	06/18/1984
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20092B717	List: ML20092B713 ML20092B726 ML20092B734 ML20092B750 ML20092B755
References
NUDOCS 8406200346
Download: ML20092B726 (3)

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UNITED STATES OF AMERICA 84 JUN 20 A!0:24 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Boards;.n6.

E NC4 In the Matter of )

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Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S ANSWER TO AWPP'S JUNE 8, 1984 MOTION RELATING TO CONTENTION VI-l On June 8, 1984, Air and Water Pollution Patrol filed a document entitled " Motion to Reopen Re-consideration on AWPP-VI-1." The motion relies principally on a May 21, 1984 letter to Philadelphia Electric Company from NRC Region I.

The letter acknowledges receipt and attaches copies of letters dated February 17 and March 26, 1984 from Applicant in response to a letter dated January 10, 1984 transmitting an NRC Inspection Report.

T1.e May 21, 1984 letter, including its attachments, fails to support the requested relief. Of primary impor-tance is the fact that the quoted. material on pages 1 and 2 of AWPP motion is directly related to a matter which AWPP has previously attempted to raise in support of Contention VI-1. The document, which AWPP previously designated "AWPP 260A," is the Notice of Violation which Applicant's letter dated February 17, 1984 is addressing and which it partially quotes. In its " Memorandum and Order Ruling on Applicant's i

8406200346 840618 PDR 0 ADOCK 05000352 PDR ~'

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Motion to Strike Specific Instances Advanced by AWPP in Support of Contention VI-1" (April 2, 1984) (slip op, at 4),

the Atomic Safety and Licensing Board ruled that the in-stances described in AWPP 260A hav'e nothing to do with the quality of welding or welding related quality assurance. In any event, AWPP fails to demonstrate how anything in the May 21, 1984 letter supports the relief requested.

AWPP asserts that Applicant should have done destruc-l tive testing "on those welds done in the test welds made by prospective employee welders." / No technical justification is given for this assertion. AWPP fails to show how Appli-

cant has in any way failed to comply with applicable regu-l l

1ations, codes and standards regarding welding or qualifica-tion of welders. The . remainder of the statements in the pleading are mere generalizations and repetitious of argu-ments previously made by AWPP.

In sum, whether treated as a motion to reopen the record or to reconsider the Board's ruling on the merits, AWPP has not addressed the legal standards for either nor l

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AWPP Motion at 2.-

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has it demonstrated that it is entitled to whatever relief

it is seeking. For these reasons, AWPP's motion should be

, denied.

l Respectfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn Counsel for the Applicant June 18, 1984 i

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