ML20077J092
| ML20077J092 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/25/1983 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20077J090 | List: |
| References | |
| NUDOCS 8308120242 | |
| Download: ML20077J092 (2) | |
Text
AIR and WATER 5p Pollution Patrol BROAD AXE, PA.
Hay 25,198383 AUS 11 P2:25 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Lawrence Brenner, Chairman
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Vashington, D.C.20555 SRANCH In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 Lawrence Brenner, Chairren; Dr. Richard F. Cole; and Dr. Peter A. Morris Gentlemen:
This letter is being submitted in response to letter of May Mark J. Wetterhahn, Counsel for the Applicant re:IE Report No.50-353/76-06 20, 1983 from want to state at the start that I
do not at all, quoting Mr. Wetterhahn's letter:the documents submitted to me by Mr. Wetterhahn
" demonstrate that all suspect velds, rather than those which were merely accessible, were re-inspected."
The third paragraph of Mr. Wetterhah..'s May 20 letter referring to Finding report No N-093, inter alia, and NCR report 1980 has to do with the velds which were found deficient by the NRC inspector after they were certified acceptable by the inspector of the Applicant and Rechtel's inspector.
Nouhere does the report made accessible and, thirdly, re-inspected completely, as inferre In Mr. Wetterhahn's fourth paragraph he discusses Finding Report N-093 which he writes, quote:" requires a re-inspection of all other accessible velds inspec ted by the inspector who accepted the deficient velds referred to in NRC I&E R port No. 50-353/76-06'.'
it does not solve the question of inaccessible welds (emphasis by Roma e-control Nos. C-63-20 and C-63-21 dated Jan.Mr. Wetterhahn's fifth paragrap 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 H, Inspection report C 63 20 and C-63-21 above refer en " control room, reactor building Unit'2, elevation 257 tn 264"respectively. elevation 269 and 289, Area 8 headed " Failure to weld structural Steel per AUS Code" mentions elevation 283 Ar a Further, 76-06-01 13 and clevation 253, colums F and H at wall 23 c
Because of confusion, Applicant must supply the name of the Rechtel and Applicant's inspectors, ber of welds and locations can he proven accessible or inaccessible together with in-Applicant For the icity, and t!.cn refer to uelds which were, nuote:"possiblyto provide statnents j
i ticular Bechtel nuality Control Inspector involved" indicates uncertaintinspected by the par-nullifying specificity.
(emphasis by Ronano).
y totally the names of the inspectors in the " broomstick" incidentIt is important also for the record that
- 06) with work records at the time of the incident, (50-353/76-to the present. These were not made available to me.
Further, as it relates to the sixth paragraph, reference to Bechtel Field In-snection Report Control *lo.C-61-22 dated April 4, 8300120242 G30005 1477 (Applicant means April 5, 1977?)
PDR ADOCK 05000352 O
AIR and WATER Pollution Patrol BROAD AXE:, PA.
May 25, 1983 (2) the report, at 6, indicated quo : " Type of Inspectior.... Visual". Certainly a visual inspection cannot inspec concrete. imbedded or otherwise non-visible welds.
Further, the inspection was, quote:"of installed structural steel, beams, and col-umns to determine its accessibility for inspection." Nowhere is shown that 7
report C-63-22 reports on accessible or inaccessible welds caused y 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" defici nt welds incident, it seems, because of the s 3 nspection of welds by the inspectors involvedy iousness of the in-cident, that should have been made immediatedly after the incident.
Paragraph seven of ?fr. Wetterhahn's letter again refers to Report C-63-22 together with related items in the suenary of Page 8 of 8, mention is made of,
" the particular Ouality Control Inspector..." In actuality, however, there cuote:
were two inspectors who were involved in falsely 0.K.ing deficient velds in the 50-353/76-06 incident.
It ie #for the Applicant also to explain why the serious question of repeated failure to perform velding as per specified At!S code on Oct.
16, 19-22, 1976 s allowed to remain unre-inspected as to accessibility until July 1977. g g f y -fS Rf pich g.,cpgf?s.es uen obw snest.d e.wKi' ' 'S t
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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 welds.
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 NC3-2710 explains how, in spite of being inhedded in concrete, the welds are declared acceptabic...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 weld was non-existent..." It seens the inaccessbile welds were declared, capriciously and unilaterally, acceptable on the convient and unscientific declaration that welds that cannot be re-inspected because they cannot be made accessible are, therefore, acceptable. Public safety d :mands Philadelphia Electric to categorically prove its statement (2nd Paragraph of !!r. Wetterhahn's
?tay 20 1cteer), nuote: "...that all suspect welds, rather than those which were merely accessible, vere reinspected."
P.E. must also prove that all u ids, acc-J essible and unaccessible were not just inspected but were acceptabl e Sincerely, ANPP Frank R. Ronano, Chairman First class mail service to:
Richard F. Cole, Peter 'forris, Atomic Sefety & Licensing Appeal Panel; Rocketing and Service Section; Ann P. Ilodgdon, Elaine I. Chan; Atomic Safety & T.icensing Board Panel, Phila. Electric, Ent> C.
Rauer; Roht. L. Anthony; !!srvin f.ewis; Judith Dorsey; Charles EJliott; Alan J. :Togec; Thomas Y. Au; Thomas l'hite III; Judith Johnsrud; Roht. Sugarman; James N. Neill; Director PEftA; Trob n. Conner,Jr.;
- ! ark J.lletterhahn.
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