ML20091R947
| ML20091R947 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/08/1984 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091R938 | List: |
| References | |
| NUDOCS 8406150358 | |
| Download: ML20091R947 (3) | |
Text
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= sc AIR and WATER W
Pollution Patrol m g""q* g,p BROAD AXE, PA.
U.S. Nuclear Regulatory Commission..;.. >
Washington, D.C. 20555 U CMf '
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 N (Limerick Generating Station and 50-353 g Units 1 and 2 MOTION TO REOPEN RE-CONSIDERATION ON AWPP VI-I Following the oral argument re the AWPP Contention VI-I, on May 31, 1984 in Philadelphia, I feel, as in the Byron decision, that there exists a legitimate uncertainty regarding improperly dispositioned construction defects, in particular f
welding together with apparent falsified inspection records, as well as question-able quality assurance practices related to safety related hangers.
For example in the May 21, 1984 letter to PECO from NRC Richard Starostecki, writiing on the combined Inspection Report 50-352/83-19: 50-358/83-07, see Response to Appendix A, Violation 2 where it states as follows:
10 CFR 50, Appendix B, Criterion X requires the estab-lishment of a program that assures that examinations, measurments, or tests of materials or products processed be performed for each work operation where necessary to assure quality.
Section 17.2A.10 of the Final Safety Analysis Report and Volume I, Section 10 of the Limerick Generating Stat-ion Quality Assurance Plan establish this program.
Contrary to-the above, the program established for engineering and quality i.nspection of pipe support hangers failed to assure the quality of two safety-related hangers in that, as of November 7, 1983, hangers VRR-IRS-HHA-1, for the reactor ciruelation system suction piping were inadequately designed and installed 'apa he inadequacies were not ic.enti-i d
l fled during the engineering and quality inspections which had been completed.
The Response by PECO is as follows:
The interferences identified by the Inspector did not' 8406150358 840608 f P -
PDR ADOCK 05000352 Q*-
O PDR s
j AIR and WATER W
Pollution Patrol BROAD AXE, PA.
(2)
Motion To Reopen Re-consideration Ga AWPP VI-l continued:
develop until af ter Field Engineering and QC, accept-ance of HHB-1 and Field Engineering release for pre-ops of HHA-1.
These interferneces developed as a result of the vibration caused by the recire pump op-eration. However, subsequent to the interferences developing Field Engineering performed, rework on hanger HHB-1 which QC inspected.
The rework was lim-ited and did not involve the interfering members of the support.
The interferences were not identified because of the apparently limited inspection of the reworked hanger.
The Inspector identified interferences have been re-solved by implementing an optign which was included in an FDDR prior to the interference being identified.
The option was not used during-initial installation be-cause the Field Engineers did not foresee the develop-ment of the interferences.
To determine the extent of this condition QC completed inspections of the 24 GE designed recirculation and main steam hangers. These inspections identified sev-e eral nonconformances', the majority of which result from the lack of installation tolerances.
Investigation into the cause of these nonconformances is not complete. There-fore, a follow-up response to this violation will be made by 3/31/84.
That response is absolute proof bf the statements AWPP (Romano) made during the VI-I hearings.namely, the Quality Assurance personnel and program is and has be'en' abysmally incompetent. That pattern seriously threatens an accident at Lim-erick unless many rechecks are mandated.
The Applicant must know that there is only one absolute test as to whether a weld is 100% inspected as to its quality. That inspection is by destructive test-ingp While it is impracticle to "do that kind of testing generally, I fault the Applicant's program for.not doing destructive testing on those welds done in the I
test welds,made by prospective employee welders. Also, thousands of welds were
g AIR and WATER Pollution Patrol BROAD AXE, PA.
(3)
Motion To Re-open re-consideration on AWPP-VI-1: continued:
disposition'ed "use as is", "because it will support the weight", and thousands more on the basis of inbred " engineering analysis".
Therefore, AWPP (Romano) moves the Board require a random sampling of the welds dispositioned as above, including inaccessible welds in 76-06-01 which Mr. Boyer could not fully reconcil-liate.
Without such destructive corrobatory statistical analysis, the Board is de-pending on the " judgement" of Mr. Corcoran found wanting even as construction is y
completed.
Respectfully submitted,
& WATE O
TION PATROL r[
o
, Chairman 61 Forest Ave.
Ambler, Pa. 19002 9
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