ML20079B874

Discusses Meeting on Facility Weld Review

ML20079B874
Person / Time
Site:	Seabrook
Issue date:	06/06/1991
From:	Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP.
To:	Carr K, Curtiss J, Rogers K NRC COMMISSION (OCM)
Shared Package
ML20079B872	List: ML20079B874
References
NUDOCS 9106180091
Download: ML20079B874 (3)

Text

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. IIARMON, CURRAN, GAI.I.AGiiER & SPIQ.HFRG 2001 S STRElfl',N.W.

SUITE 430 WASillNGTON, D.C. 20009 1125 Gall M(GRI't:VY llARMON Ts u.I' HONE DIANE CL'RRAN (202) 328 3MM)

ANNI: M'lilltLRG LAX JANNL G GAU.AGilLR (202) 32H+91H jlANCA A. l. ADD

• Of Counwl ERIC R, GUT 7.I'.NVITIN dUUe 6, 1991

',ATHERINE A METI R

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

SUBJECT:

Meetino on Seabrook weld reylew

Dear Commissioners:

I have been informed today of a proposed meeting on Monday, June 10, 1991, betwoon 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 Wold Record R3 verification,"

38 weld radiographs that were "previously called into quantion" have been inspected by NRC's Nondestructive Laboratory Level III, which found that one of the welds hac' an " internal condition" that received no documented evaluation by the licensco; and that ten other wolds " exhibited film quality conditions" which "poten-tially jeopardize the ASME Code compliance." This extremely high failure rate -- over 25% -- is a matter of tyrave concern to my client, the New England Coalition on Nuclear Pollution, which is an intervonor in the Seabrook opo*cating license case.

NRC's policy st3tc.nont 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 ?omestic license or permit application (inclu.ing e an applicat. n ;or an amendment to a license or permit) wi 1 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 relates to licensing: it is a " reverification" of whether the Seabrook operating license was properly issued. Moreover, as you 9106180091 910612 PDR ADOCK 05000443 P PDF<

d IIARMON, CURRAN. GALLAGIIER & SPIELIlERG 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 weAds should also be held in public.

We ask that you take immediate action to order that the June 10th meeting be open to the parties and their representativca, 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 sijnificance that are under Congressional investigation, we ask that the meeting be tran-scribed bf a court reporter.

Thank you for your prompt attention to this matter.

Sincerely, v

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

cc: James Taylor Executive Director for Operations Seabrook service list i

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..' SEABMOOK WELD RBCORD REVERIP1 CATION As part of the Region I Seabreck weld record reverification program overview, the Mobile Nondestructive Laboratory Level III was tasked'to peiform an overview of the licensee's review program and to independendy cammine ASMB Code radiographic films for weld and film quality. The mident inspector selected 38 welds that were pmviously called into quesdon either through the licensee's review process or the congress. The NRC exam 164 tion cf these web disclosed the following:

Weld Cas 120101 P0103 demonstrated an Intemal condition that should have been' ovaluated in the radio 5raphic reviewer's sheet. The weld radiograph had been recently reviewed by the NNY (YABC) 14 vel m and pronounced acceptable. Our review determined mat there was no documentation or evaluation of the condition.

Subsequently, the licensee produced the weld process record that contain a quality  !

control inspecdon fbr v!sual internal weld examinadon. The NRC accepted the documentation ihr establishing that the condition did not represent a threat to the structural integrity of the weld. Hmvever, the issue mmains concerning the basis that the lloensee's Level m recently used to disposition'the weld as acceptable.

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1 Ten other welds exhibi;ed filn. quality conditions that included the lack of the '

, required penwirameter sensitivity, fdm artithets, procedural technique inconsistencies, and film idendfication deficiencies.which potemially jeopardlae the ASME Code compliance. One of these deficiencies was resolved before the end of the inspecdon.

%e romaladct are currendy under review by the licenses and the NRC IJvel m

! teshalsal staff. ,

The foregoing issues call into question the adequacy of the licensee's documentation process tbr recent evaluations of the weld records. Wold Cas 120101 P0103 was recently reviewed by the licensee's level !!! boca.s 9 did not contt.in the committad YABC y t ality overview.

The I4 vel m did not record his dew or observations that would provide t Wbjective  ;

evidonoe of ble asview and acceptance. l 1

Decause of the considerable number of weld radiographs reviewed by the NRC over the '

construction life of the plant and the recent sview conduced by the Independent Review Team as discussed in NURBO 1425, the extent of the film quality problems can not be determined a: this dme. The NRC Ievel Ill ;eviewer discussed his Andings with the lloonsee's technleal staff and they are performing their own assessment. The licensee has '

been infbrmed that we consider thl inue to be encompassed by the reporting agreement which would require NHY to report these deficiencies once they have determined them to be reportable,

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