ML20084D952
| ML20084D952 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/25/1984 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20084D948 | List: |
| References | |
| NUDOCS 8405020019 | |
| Download: ML20084D952 (3) | |
Text
.
s AIR and WATEIF=c"S" Pollution Patrol 00c m co BROAD AXE, PA.
April 25, 1984
- E U.S. Nuclear Regulatory Commission Washington, D.C.
20555
,84 FR 30 M1 :16 BEFORE THE SAFETY AND LICENSING BOARD pg.y
.n,
' ' IQ b f.' N."
90 2R" In The Matter of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station, and 50-353 Units 1 and 2)
AWPP RESPONSE TO " APPLICANT MOTION TO STRIKE TESTIMONY OF AIR AND WATER POLLUTION PATROL CONCERNING CONTENTION VI-I" AWPP regards, as stated in its Testimony submitted April 16, 1984 that the Contention VI-I involves four aspects namely, (1) failure to properly control performance of certain welding, (2) failure to properly inspect certain welding in accordance with Quality Control and Quality Assurance procedure, (which AWPP con-siders partially results from improper samoling and auditing), (3) failure to take proper and effective corrective action when improp-er welding was discovered, because of inadequate concern for speci-fied procedure, and (4) failure to take proper preventive actions when improper welding was discovered because of breakdown in Qual-ity Assurence.
In total AWPP interprets the wording of the Board as more than just improper welding not discovered by inspectors and not dispositioned properly.
While AWPP (Romano) was not able to obtain witnesses in weld-ing itself, because of fear of reprisal or loss of jobs, Mr. Rom-ano has experience in Quality Control and Quality Assurance, and indicated such in testimony relating to Contention V-4.
AWPP states the elements of Quality Control and Quality Assur-ance are essentially simil.ar as it relates to adherence to speci-fled, tested, and proven procedure, properly detailed in 10 CFR Appendix b to insure no deviation of workmanship, performance, in-spection and corrective action...so that there is no deviation from results desired.
Applicant has deviated from procedures (see page 99 line 11 to 14 of 3/15/85 and l'00, line 6,23 deposition of Mr. Boyer and Mr. Clohecy).
Hundreds of NRC IE reports attest 8405020019 g40425 gDRADOCK 05000352 PDR
AIR and WATER N
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Pollution Patrol BROAD AXE, PA.
(2)
AWPP Response To " Applicant Motion To Strike" continued:
to the fact that the Applicant not only many times, improperly de-viated from specified procedure, but even changed procedures arbi-trarily, which Mr. Boyer states is use of " judgement".
The use of judgement in the manner in which Mr. Boyer has inferred is con-trary to Quality Control and Quality Assurence (see page 99-100 of March 15, 1984 AWPP Deposition.
Further, as an EPA approved laboratory director of an EPA app-roved laboratory, I am subject to Quality Control and Quality Con-trol regulations.
The essence of Quality Control and Quality Assur-ance, therefore, is inherent in the type of consideration in which I have 25 years experience. (See page 3 at *)
Further, Quality Assurance does involve the performance capa-bility of welders, and the Board rightfully sought persual of a dangerous situation involving welding fraud known to have been pra-cticed elsewhere.
The Applicant should seek to include the scur-tany of the Board for the safety of the public and the elimination of such criminal practice.
The Applicant should support this scru-tiny.
The Applicant states AWPP (Romano) did not file Dr. Iverson's professional qualifications.
However, AWPP did state Dr. Iverson was a Professor of Statistics at Swartbnore. College. ;Dr.;Iverson obtained his PhD in statistics fron. r etrard, was certified as an expert witness in Federal Court A 'd riainly qualified to testify on whether or not certain sam.J
,m
.f welds) and audits met the scientific standards to assure highest probability of validity in making conclusions from sample observations made, as it assures or does not assure the highest degree of public safety.
Only with scientific sampling and auditing of the weld population can the crucial aspecte involved in assuring safe constructi;n receive severo examination.
The admitted use of " judgement" by inspectors and even as Mr. Boyer stated might be~used by welders, is opposed to the principle of Quality Assurnace (see page 54, line 6 of
1 AIR and WATER Pollution Patrol BROAD AXE,PA.
(3) is opposed to the principle of stated might be used by welders, Quality Assurance (see page 54, line 6 of March 15, 1984 AWPP-App-s licant Deposition).
to testify on the validity i
Dr. Iverson, To permit an expert,
.upon which conclusion of proper workmanship of Applicant's audits done and corrective action is based, which apparantly has not been is to be honest with the real world of reactor con-at Limerick, Bechtel Corp-struction as it may affect the safety of millions.
and recent disclosure of Bechtel Corp-oration's record at Midland, Lim-oration's Korean scandal merits closer scrutiny of its work at AWPP challenges the auditing process and the Applicant's erick.
as it can auditors capability as to statistically proper methods, impinge on public safety.
The final test of proper or improper welding performance and
[
proper or improper correction of infractions fully involves samp-The numerous NRC reports that raise questions ling and auditing.
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of assurance of ultimate performance requires a severe challenge.
Such a challenge can only come from an inspection of auditing prac-jif_[
This can only be done via an tices used by Applicant and Staff.
scientific analysis of the Limerick weld sampling and M
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independent ss#
such as Dr.
auditing procedure by a qualified expert statistician, Respectfully submitted, Iverson's scrutiny can provide.
AIR & WATER POLLUTION PATROL
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- While Applicant sought to limit my experience to studies of air and for water which I submitted as pertinent qualifications in testimony (V-4), my experience is broadly across chemical analysis,
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=r5F analysis of brass and bronze and welding rod analyses for Carburetor Ice for example, the United States Navy Department.
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Service List.
We certify the above has been served on the latest E