ML20076F215
| ML20076F215 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/25/1983 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8306010464 | |
| Download: ML20076F215 (2) | |
Text
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DOCKETED AIR and WATER
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W Pollution Patrol 33 m 33 en33 BROAD AXE,PA.
!!ay 25, 1983 Atomic Safety and Licensing Board
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U.S;.Nticlear Regulatory Commission I
Lawrence Brenner, Chairman Washington, D.C.20555 In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 Lawrence Brenner, Chairman; Dr. Richard F. Cole; and Dr. Peter A. Morris Gentlemen:
This letter is being submitted in response to letter of May 20, 1983 from
!! ark J. Wetterhahn, Counsel for the Applicant re:IE Report No.50-353/76-06.
I want to state at the start that the documents submitted to me by Mr. Uetterhahn, do not at all, quoting Mr. Wetterhahn's letter: " demonstrate that all suspect velds, rather than those which were merely accessible, were re-inspected."
The third paragraph of Mr. Wetterhahn's May 20 letter referring to Finding report No N-093, inter alia, and NCR report 1980 has to do with the welds which were found deficient by the NRC inspector after they were certified acceptable by the inspector of the Applicant and Bechtel's inspector. Nowhere does the report explain how and when the inaccessible welds were discovered first and, secondly, ciade accessibic and, thirdly, re-inspected conpletely, as inferred.
In Mr. Wetterhahn's fourth paragraph he discusses Finding Report N-093 which he writes, quote:" requires a re-inspection of nll other accessible welds inspec-ted by the inspector who accepted the deficient welds referred to in NRC I&E Re-port No. 50-353/76-06'.' Since report N-093 has only to do with " accessible" welds, it does not solve the question of inaccessible welds (emphasis by Romano),
Mr. Wetterhahn's fifth paragraph discusses Bechtel Field Inspection Report control Nos. C-63-20 and C-63-21 dated Jan. 17, 1977 (attachment 7).
Whereas per Appendix A, Notice of Violation under A, Report No.50-353-76/06, it is stated the deficient welds were at elevation 253, celumns 23G and 11 Inspection report C / 20 and C-63-21 above refer to " control room, elevation 269 and 289, Area 8; and reactor building Unit 2, elevation 257 to 264"respectively.
Further, 76-06-01 headed " Failure to weld structural Steel per AUS Code" mentions elevation 283. Area 13 and elevation 253, colums F and H at wall 23.
Because of confusion, Applicant must supply the name of the Bachtel and Applicant's inspectors, together with in-spection records with their signatures and dates before specific and precise num-ber of welds and locations can he proven accessible or inaccessible. For the Applicant to provide statnents in the fifth paragraph alledged to actuate specif-icity, and then refer to ucids which were, nuote:"possibly inspected by the par-ticular Bechtel nuality Control Inspector involved" indicates uncertainty totally nullifying specificity. (emphasis by Ronano).
It is important also for the complete record that the names of the inspectors in the "broonstick" incident (50-353/76-
- 06) with work records at the time of the incident, to the present. These were not made available to me.
Further, as it relates to the sixth paragraph, reference to Bechtel Field In-spection Report Control '!o C-63-22 dated April 4, M77 (Applicant means April 5, 1977?)
8306010464 830525 PDR ADOCK 05000353 0
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/o-AIR and WATER Pollution Patrol BROAD AXE, PA.
May 25, 1983 (2) the report, at 6, indicated quote: " Type of Inspection... Visual". Certainly a visual inspection cannot inspect concrete imbedded or otherwise non-visible welds.
Further, the inspection was, quote:"of installed structural steel, beams, and col-umns to determine its acce.;sibility for inspection." Nowhere is it shown that report C-63-22 reports on accessible or inaccessible welds caused by scaffolding or otherwise.
I ask applicant to supply date that scaffording was removed in that specific area. Since inspection of 4/5/77 is six months after the " broom-stick" deficient welds incident, it seems, because of the seriousness of the in-cident, that inspection of welds by the inspectors involved should have been made immediatedly after the incident.
Paragraph seven of ?ir. Metterhahn's letter again refers to Report C-63-22 together with related items in the summary of Page 8 of 8, mention is made of, quote: " the particular Quality Control Inspector..." In actuality, however, there were two inspecto'rs who were involved in falsely 0.K.ing deficient welds in the 50-353/76-06 incident.
It 19 "for the Applicant also to explain why the serious question of repeated failure to perform welding as per specified AUS code on Oct.
16, 19-22, 1976 was allowed to remain unre-inspected as to accessibility until July 1977.
As it relates to eighth paragraph, Field Inspection Reports Nos. C-63-30,31, 32, and C-41A-493, do not provide proof of inspection of inaccessible velds.
In fact those reports prove inaccessible welds,as stated, cannot receive a full in-spection because of being inhedded in concrete. Neverthe-less the Applicant states NCR-2710 explains how, in spite of being inhedded in concrete, the welds are declarcd acceptable...but does not providd the manner by which the unsubstan-tiated conclusion that welds were acceptable on the basis that, quote:"
..."the embedded portion of the veld was non-existent..." It scens the inaccessbile velds were declared, capriciously and unilaterally, acceptable on the convient and unscientific declaration that welds that cannot he re-inspected because they cannot be made accessible are, therefore, acceptable. Public safety demands Philadelphia Electric to categorically prove its statement (2nd Paragraph of Mr. Wetterhahn's
!!ay 20 letter), quote: "...that all suspect welds, rather than those which were merely accessible, vere reinspected."
P.E. must also prove that all welds, acc-essible and unaccessible were not just inspected but were acceptable.
Sincerely, AlTPP Frank R. Romano, Chairman First class mail service to: Richard F. Cole, Peter !! orris, Atomic Sefety & Licensing Appeal Pancl; Bocketing and Service Section; Ann P. llodgdon, Elaine I, Chan; Atomic Safety & Licensing Board Panel, Phila. Electric, EDW G. Bauer; Roht. L. Anthony; tiarvin Lewis; Judith Dorsey; Charles Elliott; Alan J. Mogee; Thomas Y. Au; Thomas Phite III; Judith Johnsrud; Roht. Sugarman; James N. Neill; Director pef tA; Trob B. Conner,Jr. ;
!! ark J.Wetterhahn.
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