ML20077G221

Requests That NRC Take Action to Order That 910610 Meeting Be Open to Parties & Representatives & All Seabrook Parties Be Informed of Exact Time & Location of Meeting

ML20077G221
Person / Time
Site:	Seabrook
Issue date:	06/06/1991
From:	Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Carr K, Curtiss J, Rogers K NRC COMMISSION (OCM)
References
CON-#291-11830 OL, NUDOCS 9106250072
Download: ML20077G221 (3)

Text

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7 CD & UT!L FAC.N'Y

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EUG10N, CUlulAN, GALLAGIIER & SPIELBERG 2001 E STREET, N.W. . M a:

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WASHINGTON, D.C. 20009 1125 GAIL McGREEVY HARMON '91 J5 -6 P 4 Zl m EpHoxE DLANE CURRAN (202) 328-3500 ANNE SPIE13 ERG FAX =

JtWNE G. GAllAGHER (202) 328-6918 ,

JESSICA A. LADD' Of Counsel:

ERIC R. GUTZENSTUN June 6, 1991 KATHERINE A. MEYER

' Admitted only in Massachusetts Kenneth M. Carr, Chairman Kenneth C. Rogers James R. Curtiss Forrest J. Remick U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Meetina o:1 Seabrook weld review

Dear Commissioners:

I have been informed today of a proposed meeting on Monday, June 10, 1991, between the Nuclear Regulatory Commission Staff's Region I office and New Hampshire Yankee, to discuss significant new information regarding the quality of safety welds at the Seabrook nuclear power plant. According to the attached NRC Staff document, entitled "Seabrook Weld Record Reverification,"

38 weld radiographs that were "previously called into question" have been inspected by NRC's Nondestructive Laboratory Level III, which found that one of the welds had an " internal condition" that received no documented evaluation by the licensee; and that .

ten other welds " exhibited film quality conditions" which "poten-tially jeopardize the ASME Code compliance." This extremely high failure rate -- over 25% -- is a matter of grave concern to my client, the New England Coalition on Nuclear Pollution, which is j an intervenor in the Seabrook operating license case.

NRC's policy statement for technical review of domestic license applications provides that "All meetings conducted by the NRC technical staff as part of its review of a particular domestic l license or permit application (including an application for an 7 amendment to a license or permit) will be open to attendance by all parties." 43 Fed. Reg. 28,058 (June 28, 1978). According to Gordon Edison, the NRC's Project Manager for Seabrook, however, the NRC Staff intends to close its June 10th meeting to the pub-lic, on the ground that it involves " enforcement" issues. To the contrary, by its own terms, the Seabrook weld review process t relates to licensing: it is a " reverification" of whether the Seabrook operating license was properly issued. Moreover, as you 9106250072 910606 PDR #IJOCK 05000443 G PDR )S ep $-

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IIAR510N, CURRAN, GAI.LAGIIER & SPIELBERG NRC Commissioners June 6, 1991 Page 2 know, the operating license case has not been closed, and is still pending before you.

The Staff's decision to close the June 10th meeting is flatly inconsistent with the NRC's policy for holding open licensing meetings. As it has with all other licensing meetings regarding Seabrook, the Staff should be required to conduct the meeting publicly. All future meetings regarding the Seabrook welds should also be held in public.

We ask that you take immediate action to order that the June loth meeting be open to the parties and their representatives, and that all of the seabrook parties be informed of the exact time and place of the meeting. In addition, because the meeting con-corns matters of serious safety significance that are under Congressional investigation, we ask that the meeting be tran-scribed by a court reporter.

Thank you for your prompt attention to this matter.

Sincerely, Diane Curran Counsel to New England Coalition on Nuclear Pollution Encl.

cc: James Taylor Executive Director for Operations Seabrook service list

1 5BABROOK WELD RECORD REVERIFICATION As part of the Region 1 Seabrook weld record reverification program overview, the Mobile Nondestructive Laboratory Level III was tankai'to perform an overview of the licensee's revisw program and to independendy examine ASMB Code radiographic films for weld and film quality no resident inspector sc!ceted 38 wsids that were previously called into question either through the licensee's review process or the congress. The NRC examination cf these welds disclosed the following:

Weld CBs 120101 P0103 demonstrated an internal condition that should have been' evaluated in the radiographlo reviewer's sheet. The weld radiograph had been recently reviewed by the NHY (YAEC) Level III and pronounced noc6ptable. Our review determined that there was no documentation or evaluation of the condition.

Subsequendy, the licensee produced the weld process record that contain a quality control inspect!on for visual internal weld examination. The NRC accepted the documentation for establishing that the conditloc did not represent a threat to the structural integrity of the weld. However, the issue remains concerning the basis that the licensee's Level III recently used to dispostdon the wold as Acceptable. .j 1

Ten other welds exhibited film quality conditions that included the lack of the t required penetrameter moitivity, fdm artifacts, procedural technique inconsistencies, and film identification d:ficiencies which po:ent! ally jeopardise the ASME Code compilance. One of these deficiencies was resolved before the end of the inspection.

The remalader are currently under review by the licensee and the NRC 1Avel !!!

technical staff.

The foregolag issues call into question the adequacy of the licensee's documentation procou for recent evaluations of the weld records. Weld CBS 120101 F0103 was recently reviewed by the lloonsee's Level !!I because it did not contain the committed YAEC quality overview.

He Level III did not record his review or observations that would provide the objective ,

evidence of his review and recef.noe.  ;

Decause of the considerable number of weld radiographs reviewed by the NRC over the construction life of the plant and the recent review conducted by the Ind*p=Mt Review Team as dis.W. in NURBO 1425, the extent of the film quality problems can not be determined at this time. The NRC !.evel Ill reviewer discuned his findings with the

!!oeneoo's technical staff and they are performing their own asacssmcat. no licensee has been Informed that we consider this issue to be encompassed by the reporting agreement which would require NHY to report these deficiencies once they have determined them to be  !

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