ML20080N720

Motion to Compel Answers to Listed Interrogatories

ML20080N720
Person / Time
Site:	Limerick
Issue date:	02/10/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20080N684	List: ML20080N681 ML20080N693 ML20080N704 ML20080N720
References
NUDOCS 8402220327
Download: ML20080N720 (2)

Text

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AIR and WATER W Pollution Patrol

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BROAD AXE, PA.

Feb. 10, 19g g g g U.S. Nuclear Regulatory Commission

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Atomic Safety and Licensing Board ..

Washington, D.C.20555 U"'4'Qf.[U

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In the Matter of PHILADELPHIA ELECTRIC COMPANY -Docket No. 50-352 (Limerick Generating Station ~

and 50-353 Units 1 and 2)

Judge Lawrence Brenner, Chairman, Dr. Richard F. Cole, Dr. Peter A. Morris Gentlemen:

AWPP asks the Board to compel Applicant to answer interrogatories primarily answered with evasion:

Re AWPP 8th set of Interrogatories:

Re interrogatory #1--AWPP asked where the welds are so as to verify that number of welds radiographed are still available. Interr-ogatory #1 did not ask reinspection of such welds.

Re interrogatory #3,4,6,10 and 11 relate to statistics of sampling.

Applicant evaded answer.

Re AWPP 10th Set of Interrogatories:

Interrogatory 2A:

Why were Bechtel records in error? Why the change from 350 to 709?

Interrogatory 2B:

Why state "some additional deficiencies may be present"?

Why are the records not complete?

Interrogatory 2C:

Applicant states " associated affidavits were cent with Oct. 4, 1983 report...only one usual affidavit, Mr. Boyer's, was sent.

Re AWPP 12th set of Interrogatories:

Interrogatory #2:

Reference to reports does not answer who, specifically, signed off deficiencies.

8402220327 840210 PDR O ADOCK 05000352 PDR

o AIR and WATER Pollution Patrol BROAD AXE, PA.

(2)

AWPP request to Compel continued:

Interrogatory #7a:

Applicant avoids the question requiring number values.

Interrogatory #7b Applicant avoids the question.

Interrogatory #7c:

Applicant avoids the question.

Interrogatory #7d:

Applicant avoids the question.

Interrogatory #7e:

Applicant avoids the question.

Interrotatory #7g:

Applicant avoids the question.

Interrogatory #7h:

Applicant avoids the question.

Interrogatory #7i:

Would not supply affidavit.

Interrogatory #7k:

Whht about discharge of inspectior I am required to keep confidential?

Very truly yours, AIR ,ATER TI ATROL ou Frann- ? R ano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 i

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