ML20081F602

Outlines Steps to Be Taken in Response to ASLB Direction at 831017 & 18 Prehearing Conferences Re Discovery 14 on Welding Issue.Certificate of Svc Encl.Related Correspondence

ML20081F602
Person / Time
Site:	Limerick
Issue date:	11/01/1983
From:	Wetterhahn M CONNER & WETTERHAHN
To:	Romano F AIR AND WATER POLLUTION PATROL
References
NUDOCS 8311030146
Download: ML20081F602 (7)

Text

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GONNER 8e WETTERHAHNI.NE.G.

1747 PENNSYLVANIA AVENUE. N. W.

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33n:ce GABLE ADDRESS: ATOM LAW Mr. Frank R. Romano Chairman Air and Water Pollution Patrol 61 Forest Avenue Ambler, Pennsylvania 19002 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50-353

Dear Mr. Romano:

This letter outlines the steps which Philadelphia Electric Company (" Company") is taking to respond to the Atomic Safety and Licensing Board's direction at the pre-hearing conference of October 17 and 18, 1983 (Tr. 4913-16) regarding discovery related to the " welding" issue. For convenience, this matter has been designated Discovery 14.

As you must recognize, there are many thousands of records relating to welding and inspection of welding at the Limerick site; the Company will work with you to identify and obtain the specific information that you wish to review.

As detailed below, the specific documents identified by the Licensing Board are being made available immediately for your review. In addition, the Company and Bechtel Power Corporation quality asaurance audits relating to welding are also being made available. Documents relating to the 1983 reevaluation of welding deficiencies identified in NRC Inspection Report 50-353, 76/06, Item 1, are being provided, as well as documents related to welder qualifications for the ' specific containment liner welds identified in the second paragraph of your October 2, 1983 letter to the Chairman of the Licensing Board.

To help your understanding of the quality control inspection records of safety related welding performed at the Limerick site, the Company is providing a description of the Bechtel Quality Control Records filing system, which discusses how particular records are retrievable and a description of the welding inspection records prepared by the major subcontractors, including a description of their 8311030146 831101 'l PDR ADOCK 05000352 O PDR /

. Mr. Frank R. Romano Nav;mber 1, 1983 Page 2 work scope. A list of other subcontractors which are in possession of welding related records and their scope of work is also enclosed. As discussed below, a number of quality control and quality assurance related logs are also being provided.

While we will endeavor to make any information you request available in . Philadelphia for your inspection in accordance with past practice, if your requests are volumi-nous or if documents, which, in accordance with NRC requirements, may not be removed from the site and which are not easily reproducible are requested, it may be necessary for you to examine the material at the Limerick site.

The Company is making the following documents related to your contention on welding quality assurance immediately

.available at its document room:

(1)- NRC Inspection Reports and Philadelphia Electric Company correspondence to the NRC Staff related to these Inspection Reports (Discovery 14, Item 1) ;

(2) Philadelphia Electric Company and Bechtel Power Corporation quality assurance audits related to welding (Discovery 14, Item 2);

(3) A description of the welding records kept by the major contractor and subcontractors on the Limerick facility--General Electric Installation and Service, Bechtel Engineering, Schneider, and CBI (Discovery 14, Item 3);

(4) A list of other subcontractors which performed safety related welding or inspection and a brief description of their scope of work (Discovery 14, Item 4);

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(5) Quality Control and Quality Assurance Logs (Dis-covery 14, Item 5);

(a) Bechtel Inspection Record Logs by Architec-tural/ Civil Drawings; l (b) Bechtel Inspection Record Logs by Electrical Drawings; l (c) Bechtel Inspection Record Logs by P&ID

( Drawings;

Mr. Frenk R. Romano 1Novsabar 1, 1983 Page 3 (d) Bechtel Inspection Record Logs by Specifica-tion / Subcontract No.;

(e) _ Nonconformance Report' Logs; (f) Subcontractor Engineering Approved Package .

Log; (g) 'PECO QA Surveillance Check Report Logs; (h)_ List of Bechtel QA Monitorings related to Welding; (6) Documents related to welder qualifications relat-

'ing -to the specific liner containment welds identified in the second paragraph of your October 2, 1983 letter to the Licensing Board (Discovery 14, Item 6); and (7) Documents related to the.1983 reevaluation of the welding deficiencies identified in NRC Inspection I Report 50-353, 76/06, Item 1 (Discovery 14, Item 7).

-In accordance with past procedure, this documentary material will be made available for your inspection during normal  !

business days from 9:00 a.m. to 4:30 p.m. at a room near Philadelphia Electric Company's headquarters. Please call Edward Cullen, Esq. at ' 215/841-4273 to make specific ar-rangements. at least one day in advance in order to gain access to the documents. As in the past, any copies that -

you wish made of this material as the result of your review should be marked and copies will be made at the commercial rate of approximately 7C per' page. Hard copies of micro-fiche will be made at a rate . of approximately the cost of 35C per page. The cost of copying drawings will vary with their size.

In' closing, I would request that after you have had an opportunity to review the information being made available, you-give me a call if you wish to meet in the Philadelphia area with me and appropriate technical personnel in order to help you in.your, understanding of the material provided, to

.further explain the record keeping system, and to assist you in specifying additional documents you may wish to inspect.

Of ' course, this should not be interpreted as a blanket commitment to reorganize records or do significant research to obtain information on your behalf. If you'wish to review

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Mr. Frank R. Romano Nsv&mber 1, 1983 Page 4 .

additional material, please be as specific as possible in identifying that material .

Sincerely, 4 -

Mark J. Wetterhahn Counsel for the Applicant MJW/dlf f

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION _

In-the. Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1.and 2) )

CERTIFICATE OF SERVICE I hereby- certify that: copies of " letter to Frank R.

Romano from Counsel for the Applicant," dated November 1,

-1983, in the captioned matter have been served upon the following by deposit in the United States mail this 1st day of November, 1983:

Christine N. Kohl, Chairman

• Judge Richard F. Cole

. Atomic Safety and Licensing Atomic Safety and Licensing AppealEBoard Board U.S. Nuclear Regulatory .U.S.. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Gary J. Edles

• Judge Peter A. Morris Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear-Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Reginald L. Gotchy Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel

. Appeal-Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section

• Judge Lawrence Brenner (2) Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Board' Commission U.S.' Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• Hand Delivery

• Ann P. Hodgdon, Esq. David Wersan, Esq. Consumer Counsel for NRC Staff Office Assistant Advocate of the Executive Office of Consumer Advocate Legal Director 1425 Strawberry Square U.S. Nuclear Regulatory Harrisburg, PA 17120 Commission Washington, D.C. 20555 Steven P. Hershey, Esq.

Community Legal.

Atomic Safety and Licensing Services, Inc.

Board Panel Law Center West North U.S. Nuclear Regulatory 5219 Chestnut Street Commission Philadelphia, PA 19139 Washington, D.C. 20555 Angus Love Esq. 101 East Philadelphia Electric Company Main Street Norristown, PA ATTN: Edward G. Bauer, Jr. 19401 Vice President &

General Counsel Mr. Joseph H. White, III 2301 Market Street 15 Ardmore Avenue Philadelphia, PA 19101 Ardmore, PA 19003

• • Mr. Frank R. Romano Robert J. Sugarman, Esq.

61 Forest Avenue Sugarman & Denworth Suite Ambler, Pennsylvania 19002 510 North American Building 121 South Broad Street Mr. Robert L. Anthony Philadelphia, PA 19107 Friends of the Earth of the Delaware Valley Director, Pennsylvania 106 Vernon Lane, Box 186 Emergency Management Agency Moylan, Pennsylvania 19065 Basement, Transportation and Safety Building Mr. Marvin I. Lewis Harrisburg, PA 17120 6504 Bradford Terrace Philadelphia, PA 19149 Martha W. Bush, Esq.

Kathryn S. Lewis, Esq.

Judith A. Dorsey, Esq. City of Philadelphia 1315 Walnut Street Municipal Services Bldg.

Suite 1632 15th and JFK Blvd.

Philadelphia, PA 19107 Philadelphia, PA 19107 Charles W. Elliott, Esq. Spence W. Perry, Esq.

Brose and Postwistilo Associate General Counsel 1101 Building Federal Emergency lith & Northampton Streets Management Agency Easton, PA 18042 500 C Street, S.W., Rm. 840 Washington, DC 20472 Jacqueline I. Ruttenberg Keysteon Alliance 3700 Chestnut Street Philadelphia, PA 19104

• Hand Delivery

' ** Federal Express

O . ,

Thomas Y. Au, Esq.

Assistant Counsel Commonwealth of Pennsylvania DER 505 Executive House P.O. Box 2357 Harrisburg, PA 17120 Thomas Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources 5th Floor, Fulton Bank Bldg.

Third and Locust Streets Harrisburg, PA 17120 Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Zori G. Ferkin Commonwealth of Pennsylvania Governor's Energy Council P.O. Box 8010 1625 N. Front Street Harrisburg, PA 17105 Mark J(/YeWerhahn

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