ML20084D980
| ML20084D980 | |
| 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 8405020031 | |
| Download: ML20084D980 (6) | |
Text
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RE1.ATED COms?T1DENik.
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AIR and WATER Pollution Patrol
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BROAD AXE, PA.
April 25, 1984 U.S. Nuclear Regulatory Commission g APR 30 Washington, D.C.
20555 Ay,.16 BEFORE THE SAFETY AND LICENSING BOARD L, i -
CC $[. -lE. O.
i,y$$ d'"W 50 In The Matter of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352' (Limerick Generating Station, and 50-353
- Jnits 1 and 2)
AWPP RESPONSE TO " STAFF 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 Qulaity Assurance procedure, (which AWPP considers partially results from improper sampling and auditing),
(3) failure to take proper and effective corrective action when improper welding was discovered, because of inadequate concern for specified procedure, and (4) failure to take proper preven-tive actions when improper welding was discovered because of breakdown in Quality Assurance.
In total AWPP interprets the wording of the Board as more than just improper welding not dis-covered by inspectors and not dispositioned properly.
While AWPP (Romano) was not able to obtain witnesses in welding itself, because of fear of reprisal or loss of jobs, Mr.
Romano has experience in Quality Control and Qaulity Assurance, and indicated such in testimony relating to Contention V-4.
AWPP states the elements of Quality Control and Quality Assurance are essentially similar at, it relates to adherence to specified, tested, and proven procedure, properly detailed in 10 CFR Appendix b to insure no deviation of workmanship, perfor-mance, inspection and corrective action...so that there is no deviation from results desired.
Applicant has deviated from
& 100 line 6 23 procedures (see page 99 line 11 to 14 of 3/15/84 depo,ition o,f s
4 Mr. Boyer and Mr. Clohacey).
Hundreds of NRC IE reports attest 8405020031 840425 PDR ADOCK 05000352 G
AIR and WATER Pollution Patrol BROAD E,PA.
AWPP Response To " Staff Motion To Strike" continued:
to the fact that the Applicant not only many times, improperly deviated from specified procedure, but even changed procedures arbitrarily, which Mr. Boyer states is use of " judgement".
The use of judgement in the manner in which Mr. Boyer has inferred is contrary to Quality Control and Quality Assurance. (See page 99-100 of March 15, 1984 AWPP Deposition.
Further, as an EPA approved laboratory director of an EPA approved laboratory,I am subject to Quality Control and Quality Control regulations.
The essence of Quality Control and Quality Assurance, theg fore, is inherent in the type of consideration in which I have years of experience 4.(See page 3 at *)
Further, Quality Assurance does involve the performance cap-ability of welders, and the Board rightfully sought persual of a dangerous situation involving welding fraud known to have been practiced eleswhere.
The Staff should seek to include the scru-tiny of the Board for the safety of the public and the elimin-ation of such criminal practice.
The Staff should support this scrutiny.
The Staff states AWPP (Romano) did not file Dr. Iverson's professional qualifications.
However, AWPP did state Dr. Iver-son was a Professor of Statistics at Swarthmore College.
Dr.
Iverson obtained his PhD in statistics from Harvard, was certi-fied as a expert witness in Federal Court and certainly quali-fies to testify on whether or not certain camplings (of welds) and audits met the scientific standards to assure highest prob-ability of validity in making conclusions from sample observa-tions 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 aspects involved in a-
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ssuring safe construction receive severe examination.
The ad-mitted use of " judgement" by inspectors and even as Mr. Boyer
- a:
AIR and WATER Pollution Patrol BROAD AXE,PA.
(3)
March 15, 1984 AWPP-Applicant Deposition).
To permit an expert, Dr. Iverson, to testify on the validity of Applicant's audits upon which conclusion of proper workmanship and corrective action is based, which apparantly has not been done at Limerick, is to be honest with the real world of reactor con-struction as it may affect the safety of millions.
Bechtel Corp-oration's record at Midland, and recent disclosure of Bechtel Corp-oration's Korean scandal merits closer scritiny of its work at Lim-erick.
AWPP challenges the auditing process and the Applicant's auditors capability as to statistically proper methods, as it can impinge on public safety.
The final test of proper or improper welding performance and proper or improper correction of infractions fully involves samp-ling and auditing.
The numerous NRC reports that raise questions of assurance of ultimate performance requires a severe challenge.
Such a challenge can only come from an inspection of auditing prac-tices used by Applicant and Staff.
This can only be donc via an independent scientific analysis of the Limerick weld sampling and auditing procedure by a qualified expert statistician, such as Dr.
Iverson's scrutiny can provide.
Respectfully submitted, cAI
& WAT R LLUTION PATROL FRR/jch R. Romin57" Chairman
- While Stai.' sought to limit my experience to studies of air and water which I submitted as pertinent qualifiactions in testimony for Carburetor Ice (V-4), my experience is broadly across chemical analysis, for example, analysis of brass and bronze and welding rod analyses for the United States Navy Department.
We certify the above has been served on the latest Service List.
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54 1
this same welder could have, as he had, taken 2
liberty to modify procedures, could have on many 3
other occasions taken liberty and did improper 4
welding?
5 MR. DOYER:
Your statement was that it G
was an improper procedure.
In the welder.'.p_yiew
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7 it was appropriate and proper.
There was no 8
specific procedure which said that he could not use
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that type of access to the weld., "" J.
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, v c r.r Y c J. A aci n a,...nyk.)"iph 10 MR. ROMANO:
Well, I thought We went 11 through this, did we not, that the extension had to 12 be designed and manufactured so as to enable him to 13 do the weld properly?
14 And then, you know -- and then --
15 MR. BOYER:
In his opinion, he was using 16 a suitable extension.
17 MR. ROMANO:
We're back again to whether 18 an individual welder can determine through his own 19 opinion rather than specify procedure what he will en do.
21 And I think again -- I say says something 22 about quality assurance -- is the big key situation 23 that we're discussing.
24 MR. BOYER:
That's right.
It was detected ARl A.Wil)! I I l)I R.\\L Kl l'OK 11N(i INC
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1 Do you do or do the inspectors do random 2
sampling or do they do sampling based on statistical 3
scientific procedure?
l MR. WETTERHAN:
I think that is confusing.
5 Are you talking about inspectors or auditors?
ii MR. ROMANO:
Well, do inspectors make 7
audits and in those audits take samples, do they randomly take samples or do they use scientific 8
statistical procedures to be sure that they have 9
10 proper representation of the welding population?
11 MR. CLOHECY:
As auditors performing our 12 audits, we have done both.
We have used judgment 13 and we have used standards.
It depends on the la situation.
IS MR. ROMANO:
Where would you use judgment lii and on what basis do you use judgment?
17 MR. CLOHECY's I would apprt ciate it you I8 would be a little more specific in your question.
19 MR. ROMANO:
You said you used judgment 20 at times in how many samples you take.
21 MR. CLOHECY:
Yes, I answered this question 22 MR. ROMANO:
And I asked you when do you 23 use -- on what basis do you use judgment?
24 MR. CLORECY:
Okay.
We answered a similar
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100
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1 and related question in one of your earlier 2
interrogatories.
1 3
MR. ROMANO:
No.
Just tell me now.
4 What basis do you use when you make a 3
decision you're going to use your judgment on this?
6 MR. CLOHECY:
It's the judgment of the I'
auditor and the auditor's field branch head as to 8
what sample size or what items should be audited.
9 MR. ROMO:
What basis do you use for 10 when you're going to do that?
II MR. CLOHECY:
It's the judgment of a 12 j
qualified auditor.
I3 MR. ROMANO:
In other words, he can make 14 that judgment any time he wants without, you know,
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15 qualification, without checking it with anyone else?
16 MR. CLOHECY:
It's approved by supervision.
II MR. ROMANO:
Why isn' t a statistical 18 procedure used rather than random judgment by an 19 individual?
20 MR. CLOHECY:
We have used statistical 21 procedures.
22 MR. ROMANO:
Why isn't it always used?
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2.1 MR. CLOHECY:
It's no.t felt necessary.
21 MR. ROMANO:
That's your opinion, isn't it?
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