ML20087M490

Response to Applicant Motion to Delete Specific Instances in Support of Contention VI-I Advanced by Air & Water Pollution Patrol as Unrelated to Welding or welding-related QA Activities

ML20087M490
Person / Time
Site:	Limerick
Issue date:	03/24/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20087M489	List: ML20087M488 ML20087M490
References
NUDOCS 8403290397
Download: ML20087M490 (11)

Text

.

AIR and WATER gygo Pollution Patrol .

BROAD AXE,PA. '84 MAR 29 A11:13 March 24, 1984 U.S. Nuclear Regulatory ommiss'ioh~

L :"

Before the Atomic Safety and Licensing Board In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station and 50-353

' Units 1 and 2)

AWPP'S RESPONSE TO APPLICANT'S MOTION TO' DELETE SPECIFIC INSTANCES IN SUPPORT OF CONTENTION VI-I ADVANCED BY AIR AND WATER POLLUTION PATROL AS UNRELATED TO WELDING OR WELDING RELATED QUALITY ASSURANCE ACTIVITIES Applicant states that the Board In its Order Confirming Miscellaneous Oral Record Rulings (March 15, 1984), the Atom-ic Safety and Licensing Board confirmed its ruling made at the prehearing conference (Tr. 8326-27) that Applicant and NEC Staff may move by March 20, 1984 that one or more of AWPP's listed examples do not relate to welding or welding related quality assuranc'e, activities."

AWPP's representative sta'tes he possibly did not under -

stand such oral ruling, nor was he given an opportuinty to see transcript relating thereto.

This ia evidenced by the fact that in an AWPP telephone call on March 19, 1984 to Mr. Cullen, who supervises the Doc-g ument Room at Philadelphia Electric, Mr. Wetterhahn came to nno

@@' the phone and surprised me with the need to discuss the weld-

?8 mn 0

ing information examples AWPP ubmitted re VI-I contention. I 3

gg informed Mr. Wetterhahn that I was occupied with work schedule oo

$@ and did not have time to discuss my contention. No mention was om go g made that "as required by that order, the NRC Staff, AWPP and Applicant have a.ttempted to discuss the pertinence to welding 1

Q AIR and WATER

' ' Pollution Patrol BROAD AXE, PA.

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AWPP's Response to Applicant's Motion to Delete continued:'

and welding inspection of the specified items discussed below, but have been unable to do so.2/" At footnote 2/ it states " Staff coun-sel attempted unsuccessfully to contact Mr. Romano on Saturday, March 17, 1984. Applicant's counsel spoke with Mr.' Romano on Mon-day, March 19, 1984. Mr. Romano stated that he wanted to cooperate but could not discuss it on that date because of other things he had to do."

At the.very late date of Saturday, March 17, 1984 Staff tried-to reach me while I was away -- and only by accident did I inad-vertently talk to Mr. Wetterhahn on March 19, and learned a discuss-ion was to be held prior to the March 20, 1984 dead line. It is' obvious that neither NRC nor Applicant, with all their staff; were espically concerned about the Board's order to discuss the pertin-ence of specified items AWPP submitted. I received the Applicant's (Wetterhahn) " Motion to Delete" certain specific items the next day.

This meant any discussion that I would have held with Mr. Wetterhahn could havn been after he had already written his " Motion to Delete".

I move the Board advise Mr. Wetterhahn to not mischaracterize AWPP's effort to comply with the Board.

Further, as I stated, the instances I submitted were NRC I&E Reports describing examples of pertinent welding and QC items.

There are hundreds more examples many buried in welding logs which Mr. Wetterhehn's evasivness, as we previously described, kept AWPP from discovering. Also it must be noted that my examples start with 1

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AWPP's Response to Applicant's Motion to Delete continued:

AWPP page number 138 and many numbers skipped in between 138 and 260. I expect to include all unsubmitted incidents, not just ex-amples already submitted. This is necessary because those unsub-mitted incidents are necessary.to support my VI-I c6ntention.

We did not at all include: items in the " REPORT REGARDING THE INVOLVEMENT OF PHILADELPHIA ELECTRIC COMPANY MANAGEMENT IN ASSUR-ING THE QUALITY OF WELDING AT LIMERICK GENERATING STATION." We cer-tainly intend to include such infractions noted.

As it related to Applicants page 2 item 1, re AWPP 141 (page 2 of Appendix A to IE Report 352/77-02) statement that "nowhere on page AWPP 141 or AWPP 144 is there any indication whatsoever that the deficienty relates to welding"_. AWPP cites the Applicant's own statement under 1 that spent fuel. pool liner was contaminated "with slag iron residu'e from a thermal. metal cutting. process". Inasmuch as welding was taking place, the Applicant must verify that the metal deposits were not from careless dropping of molten metal from welding rods.

Further on AWPP designated page 141 the Applicant was required "upon receipt from Project Engineering of an acceptable Quality Assur ance Manual (and changes thereto) it is forwarded to Document Con-trol for logging..." But " contrary to the above, on March 8, 1977 1

the latest approved amendments (Nos. 3 and 4) to Testing and In- l spection Procedure 3.20.A.1 were not entered in two controlled vol-umes of the Peabody Testing Quality Assurance Plan at separate on-l l

t AIR and WATER  :

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AWPP's Response to Applicant's Motion to Delete continued:

site locations." This again illustrates Applicant's lack of control.

Re AWPP 144 (IE Report 352/77-02, page 8, item 1) Applicant cor-roborates the arbitrairy and unilateral use of their " judgement"

.which the NRC properly characterizes as " narrow vie'w" and as "not being consistent with the obvious intent of the specification in the related PSAR commitments, and the governing criteria of 10 CFR 50, Appendix B". Further , on page 144 under 77-02-03 is another.vio-lation indicating carelessness by the Applicant of QA/QC control that could directly or indirectly involve welding.

Re AWPP 210 page 1 of Appendex A to IE Report 352/80-12)Appli-cant further indictes itself as not taking QC/QA seriously by answer-ing at item 3, page 4 of its " Move to Delete" when it states discov-ery of "one individual,who was employed as a QC inspector performing receipt inspections without being properly certified as a qualified inspector to perform such function", cannot relate to welding. Re-ceipt and imporper inspection of material that might be used directly or indirectly in welding can affect welding quality and subsequent performance of the weld.

Re Applicant 4, page 4 of Applicant's " Motion to Delete" at AWPP 242 (page 1, of Appendex A to IE Report 352/81-01 and AWPP 245 (IE Report 352/81/01, pages 4 and 5) which report relates to an ASME Nuclear Class I pipe weld, the Applicant states "the liquid pene-trant test indications on components which were involved were in i

l l

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• Pollution Patrol BROAD AXE,PA.

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AWPP's Response to Applicant's Motion to Delete continued:

the base metal and unrelated to welding". Again the Applicant's OA program was accidently found as violating specified procedures on apparant arbitrary re-use of its own judgement.

Further, Applicant page 4 item 4 talks of "non-destructive indications found on the surface of,an ASME valve body casting.

Thus, this matter does not involve welding, but only indications on

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the valve body itself". But as per p.,5 of IE Report 352/81-01, the inspector noted "These indications were found while testing the pipe to valve weld"...not specificall;y on the surface of the valve

...but'on the base metal, namely, "on'the Nuclear Class I pipe weld DLA-107-1/16 FW II".

Further, Applicant improperly rationalizes that the weld was O.K. even though the weld had been performed adjacent.to base metal

?

which was found rejectable by liquid penetrant indications which however, the Applicant's.0C did not. properly follow up. ,

As to AWPP page (260A) page 1 of 7.ppendix A to IE Report 352/

83-19 item l') discussed on page 5 of Applicant's " Motion to Delete",

Applicant states the Notice of Violation refers to (Applicant's)

" failure to provide cleanliness control following disassembly of a feed water system containment isolation valve". The Applicant then states "There is no stated relationship to welding or welding related quality assurance".

AWPP (Romano) states that welds made in an unclean area, and

AIR and WATER Pollution Patrol BROAD AXE, PA.

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AWPP's Respomse To Applicant's Motion To Delete continued:

welds to be made to re-assemble the feedwater system isolation valve could be affected by rust or other corr 9sion effects because clean-liness controls were ignored.

As to AWPP 260A, 352/83-19, item 2, the infrac' tion involves a deficiency, namely, the failure of the program established for eng-ineering and quality inspection of pipe support safetp d sted hang-ers. Not only were the welds improperly designed and installed, but the inadequacies were not identified during the inspections. This specifically demonstrates failure to perform welding properly, and failure of Quality Control.

The Applicant refers to an attachment 1 to their pleading, which we did not receive.

As it relates to AWPP 260B (page 2 of Appendix A to IE Report 352/83-19 (item 7 of Applicant's " Motion to Delete") Applicant's statement is prima facia admission that specified procedure follow-ing a deficiency was violat'ed. Such skirting of required proper

! follow-up indicates, to gether with many such previous examples which Applicant feels were not important; less than complete l

respect for Quality Assurance.

l l Applicant's point 8, page 6 of their "Motiore to Delete" refer-ring to AWPP p.260C (Cover letter to IE Report 352/83-19), Applicant states, "This cover letter relates to an NRC concern over perceived weakness in the Quality Assurance and Quality control programs ap-plied to systems for which construction has been essentially com-

AIR and WATER W Pollution Patrol BROAD AXE,PA.

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AWPP's Response to Applicant's Motion to Delete continued:

pleted and which are then turned over to the startup organization for testing".

The Jan 10, 1984 cover letter, and the fact that it is going on to 8 years since the " Broomstick affair", with the hundreds of NRC IE reported welding infractions to Jan. 1984 sums up the inade-quacies of the Nuclear Industry's Quality Control and, therefore, Quality Assurance and, therefore, safety of the public in a probable nuclear accident at Limerick.

AWPP (Romano) sees more than " perceived weaknesses", AWPP sees that less-than harsh disciplining of the Applicant when infractions were found, has been taken advantage of by the Applicant. As a re-sult, the NRC is deeply concerned in finding infractions even as construction is being completed and ready for turnover to the start-up organization.

As it related to Applicant's point 9 on page 6 of " Motion to Delete", identified as AWPP 180B (NRC #'13 6 6 ) , Applicant states "this non?conformance report relates to a 'non-Q' item as stated in block 19 of the NCR". The Applicant further states "there is no l

l reason for the Board to consider this matter since the Contention is l related only to safety related welding".

l AWPP (Romano) states that 180B was used as an example (and will l submit many more) of the rationalizing away of improperly performed welds.

O AIR and WATER N Pollution Patrol BROAD AXE, PA.

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AWPP's Response To Applicant's Motion to Delete continued:

Further, as per Oct. 28, 1983 Memorandum and Order Confirming Rulings Made At Prehearing Conference, , contention was reworded by the Board as follows:

" Applicant has failed to control performance of welding and inspection thereof in accordance with Quality Con-trol and Quality Assurance procedures and requirements, and has failed to take proper and effective' corrective and preventive actions when improper welding has been discovered".

Failure to follow any specified procedure on welding, and j failure to adequately perform Quality Control and Quality Assurance and proper follow-up reveals a characteristic of improper perfor-mance and concern for performance irrespective of the item being performed... safety or non-safety related.

[ Further corrobor,ating AWPP's contention that Applicant failed in too many aspects of control of welding including inspection and qualification of welders, is their own report of Philadelphia Elect-ric Compan'y management on their involvement in welding quality at i

Limerick. This report was also ordered by the Board on Oct. 28, 1983.

Primarily, the classical example was the " Broomstick Affair" l

where laxity in welder qualification, inspection including falsifi-j cation of records, statements that all welds inspected by an inspec-tor who O.K'd welds found so severely non-conforming as to indicate they were not at all inspected (re 76-06-01), and finaly repeated statements by the Applicant to the NRC Atomic Safety and Licensing Board that all welds, accessible, and inaccesible were reinspected

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AWPP's Response To Applicant's Motion To Delete continued:

with the ultimate admission that such statements were not true.

On page 37-38 in " Applicant's Q.C. Involvement Report", it is admitted that the Applicant's audits could stand improvement in various areas. But Applicant does not reveal those areas so that AWPP could follow up on location', type and number of welds involved.

In the second paragraph on page 37, the Applicant speaking of welding audits states, "The lack of identification of such areas in an undertaking as large as the Limerick project would raise questions regarding the effectiveness of the Audits". (AWPP underlines, and concurs). Applicant continues:"The same audit (Applicant's) process that has identified such (welding) problems has also been used to verify that they (welding problems) have been satisfactorily resol-ved' . AWPP states that the admitted inability of the Applicant's audit process to effectively identify preldem welding areas cannot, at the same time, as the Applicant states, be used to verify such problems have been satisfactorily resolved.

1 Further, on page 37,in spite of the Applicant's description of its three level redundancy rs inspections, the fact that there was

" poor quality welding in the safety-related HVAC systems and compon-ents...", AWPP, in questioning how such poor cuality welding can be l

l admitted, sees it as proof the three level QA, QC has resulted in i

, 1 admitted poor welding, nevertheless. 1 Further, it was the responsibility to check and know the QA/QC l

AIR and WATER W Pollution Patrol BROAD AXE, PA.

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AWPP's Response To Applicant's Motion To Delete continued:

program of subcontractors met specifications. The Applicant admits locking the barn after the horse is stolen. In the case of a nuc-lear reactor this could be tragic. -

Page 38 shows Applicant, very late # finding that, " subcontract-ors did not'have enough inspectors to handle the work load and those it had were not performing at an adequate level". The Applicant states "this situation was remedied through increasing manpower and intensive training". That may have taken care of the manpower and training which should have previously been part of specified require-ments, but what about the inferior welds and inspections?

Further, on page 40 the " piping and welding QC affair" came to light. AWPP states that while Applicant tries to rationalize the careless cucurrences, no better example of QC auditing fou]-up could l ever be manufactured on purpose.

AWPP and the Board deserve a full review of the "HVAC Affair" and the" piping and V61 ding QC Af f air"which seems to be another

" Broomstick Affair". AWPP moves the Board require affidavits on all pertinent phases of the HVAC and $iping and'Yelding QC affair. That is, the Applicant is to indicate number of welds involved, how.many l

l were accessible, how many inaccessible, and that all have been re-solved properly.

AIR and WATER

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W Pollution Patrol BROAD AXE,PA.

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AWPP's Res onse To Applicant's Motion To Delete continued:

The Applicant on page 37 and page 38, and inparticular page 40, gives a litany of faulty workmanship and faulty inspections in its report as to how Applicant assures proper performan'ce of welding.

Its report does not at all' assure there has been quality welding at Limerick.

Respectfully submitted, Air & Water P lution Patrol

.[ e.. Z Frank R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 FRR/jch I

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