ML20132D930
| ML20132D930 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/05/1984 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-627 OL, NUDOCS 8509300336 | |
| Download: ML20132D930 (107) | |
Text
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627 7 843466 AIR and WATER WJ P0llUt'05 POffol 1
March 5, 1984 ' f /are /
de t - -
(_[Dd* g g
BROAD AXE, PA.
U.S. Nuclear Regulatory Commission g
Atomic Safety and Licensing Board.85 Smbrud SPu rd'y
'fp fhe75at@e N f PHILADELPHIA ELECTRIC COMPANY (Limerick Generatin g ',
station Units 1 and 2)
Docket Nos-50-352 and 50-353dC'
/_
=
Judge Lawrence Brenner, Chairman; Dr. Peter Morris; D, hard cc Gentkemes:
'g A
D Chronology of pertinent examples of infraction r OffbS6qgg % h
?C improper control or performance of welding and/or f D 'uq1 sS!Sitalte O
proper action when welding infractions have been dis e
6 9/76 IE Report 76-06-01 AWPP-138 Finding report #093-Contradiction on elevat-ion of deficient beam (257' vs 253')
AWPP -13 S NCR #1980 AWPP-139B Samples of NCR's demonstrating rou, tine "use as is".
3/77 AWPP-140 Applicant's lack of control of performance 3/77 AWPP-141 Lack of Applicant control.
3/77 F P-14 2/43 Applicant failure to control performance.
3/77 AWPP-144 (77.02-01)
Applicant arbitrarily interperts rules and ignores interpretation of speci-fications.
3/77 AWPP-152 (50-352/77-02)
Example of Applicant's failure to control performance of welding.
5/76 AWPP-155 (50-352/78-03;78/04 letter from Bruce Grier)
Example of fa'ilure to take proper and correc-tive action.
6/78 AWPP-156 (50-352/78-03) Notice of Violation 5/10/78--
Improper action followed by improper corrective action by Applicant.
8/78 AWPP-156 (50-352/78-04) Notice of Violation dated 6/16/78 Applicant failed to take proper and effective corrective action.
12/78 AWPP-176 (60-353/78-08)
Failure of Applicant to con-trol performance resulting in inability to in-8509300336 840305 PDR ADOCK 05000352
AIR and WATER W
Pollution Patrol BROAD AXE, PA.
(2)
I Chronolog'y continued:
spect welds.
12/78-1/79 AWPP-180 (50-353/78-08)
Under response to item of non-compliance (response to Appenxis A) Applicant's answer ignores the seriousness of infraction.
If welds can no longer be performed discussion of correction at final routine inspection is an apparent excuse to cover lack of control and lack of corrective action after improper weld-ing has been discovered.
12/78-1/79 AWPP180b NCR 1366 demonstrates routine "use as is" follow up--as it might relate to AWPP 180.
4/79 AWPP-181" Letter to P.E.
from Robt. Carlson re inspection 50-352/78-12 Letter shows total lack of control and failure to control performance and an effort to avoid proper corrective action after improper welding has been performed /
7/79 AWFP-186 See Infraction and Engrieering change.
7/79 AWPP-187 Infraction detailed that could result in damage from stress to subsequent cracking.
This is care-less contempt for safety proceedure.It is again a failure to control performance by Licensee.
And if, as it seems, no further action was taken it shows Applicant did not take proper corrective action after deficiency is found.
7/79(ref)
AWPP-189 (50-352/79-07-02) See underlined statements.
Under (1) it appears Applicant arbitrarily makes decsisions on rules without specific description.
Under (2) There is an indication of incomplete control by Licensee.
Under (3) An indication is shown VIA acceptance of weld joint by Q.C. engineer on 4/9/79 that only certain welding activity is checked.
There could be nany such undiscovered deficient welds
AIR and WATER Pollution Patrol BROAD AXE, PA.
(3)
Chronology continued:
to cause subsequent problems.
7/79 AWPP-190 (ref 50-352/79-07-05) Under (4) there is more evidence of lack of control of performance with welding on the critical liner of the reactor Core.
AWPP-194 Discussion weld performance 10/79.
Again improper 10/79 Applicant control of welding performance.
- Further, Applicant's Q.A. engineers issued p285 finding re-port on the day the NRC inspector found work not in conformance with required perocedure.
The Applicant appears to try to cover up its non-con-trol of performance by a late copy-cat finding report AFTER the Applicant was notified of in-correct proce dure occuring because of Licensee's lack of control of performance.
204 Referring to unresolved item (352/79-11-02) licen-10/79 AWPP see's memo dated 1/23/80 demonstrates improper follow up by Applicant after a deficiency is dis-s covered.
AWPP-210 Further deficiency relative to Applicant's pri-6/80 mary responsibility to control all activities.
6 (?) /80 AWPP-235 Under(3) it is shown there is improper inspection proceedure by Applicant found by NRC inspector::
Osimilar to 76-06-01.
AWPP 236 See underlining, indicates Applicant's failure to app 8-9 (?) /80 (
vntrol puformance and Q.C..
Licensee is arbi-I trarily ignoring required " hold point".
AWPP-237 re above under response to item of non-compliance-B 11/80 Applicant's inadequate control VIA Q.C. and Q.A.
is shown.
AWPP-242 See underlining --improper follow-up on infract-1/81 ion and improper action after deficiency is found.
a AIR and WATER Pollution Patrol BROAD AIE, PA.
(4)
Chronology' continued:
1 2/81 AWPP-243 See underlining on welding defieiency.
j 2/81 AWPP-244 Under 352/81-01-02 -Violation of specified pro-(re above ref1-cedure as underlined.
?/81 AWPP-246 e 50-352/81-05; 06 see underlined--refering to k
welding inadequacies disovered but not properly s
corrected.
- Further, improper welding accepted byLicenseeon2{6/80 g
pg g
6[w f*i d
-$f44 9
PP-260 re.'E8 ice f
olation inpsection df 1/11-29/82
?/8 a
under A and B severd violation of welding procedure by Applicant.
11/83 AWPP260A Notice of Violation re inspection of 10/17 and 11/30/83.
Under (1) evidence of continued lack of control of performance responsibility of Applicant.
Under (2) Again svidence of carless performance and failure to properly identify infractions.
?/81 AUPP-247 Same reference as AWPP 246 see underlining under Violation B.
11/83 AWPP 260B Under 3 of above reference demonstrated Applicant's non-conformance as it relates to reporting.
1/84 AWPP 260C Relating to 12/83 meeting of P.E. and Bechtel Power with resident inspectors concerning evident weak-ness in O.A. and O.C. programs involving completed construction.
This item shows PECO's Q.C. and Q.A.
programs, almost 8 years after the infamous " broom-stick affair" is deficient to the point of threat-ening accidents during operation.
Respectfully submitted Airsp Water P lution Patrol
-94 i,
FraW( R.
omano, Chairman 61 Forest Ave.
Ambler, Pa. 19002 FRR/jch
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Citi 1 e, 3
- }.5 Rtv't.5/75 FINDING REPORT d,..
Limerick Units 1 8 2
,, t,pt: O aueit Osuivaitta:t a XRX NRC
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,,ative assesses:
O aca coastefi'r actisa acc's.
Bechtel Power Corp.
E Item of Noncompliance esist semisastee 4 atraernets C.K. Soppet - Project Manager
- i. ISSUED TO.
a) AWS p1,.1.71;and 72 4 74 Bechtel Power Corporation editions
,.0RGANIZATION T. Alton - K. Bishop UEC101N3 i.THOSE CONTACTED s.in CFs So, aPPENDis B CRiftRia p, g, [,*,y, Q*l[
3., FINDING <sst nun strantuct senittuat sntets as arousato:
Two welds from the beam to the clip on beams 232B7 and 23289 in unit 3 on Elev. 257_were both incomplete and unacceptab'le and were made with the ald' '
of a broom stick handle attached to the stinger"to reach the joint to be.
. welded; which is contrary to AWS se,ction 3.1.2.
Furthir, inspection surveillance records' indicated that these, beam connections were inspected.
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n,0lSCUSS10N tust no atrintn:t aanitiowat snitts as assuists)
Bechtel issued NCR No.1980 identifying the non-conforming condition.
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A* Both Inspector 10/27/76
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,,033 IDENilFire saar fifLE Batt empte essa ICINTirit0 A. Teller - TLC mat TITLE s4T 2@9w-%_ S!te QAE 10/29/76 P.L. Sauk PLE*6234 issuto et
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. nun.u.u.n dORRECTIVEACTIONTAKEN' TOR 101.VEFINDING llll,".l"lllll'ie.. ins:
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Issuance of NCR 1980 to ac' knowledge the nonconforming condition and to acquire dispositioning to correct same.
2.
A Reinspection of all other work performed by the particular inspector who accepted the welds in question was accomplished
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CORRECTIVE ACTION TAhEN TO PREVENT RECURRENCE t'"'"""""'
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A training class was held 10-25-76 for re-indoctrination and re-orientation in the various aspects of acceptance of completed work, reviewing or inspection criteria and ultimate responsibilities for weld inspections with all personnel in attendance from both the QC and field welding groups.
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License No. CPPR-106 0
7 i
APPENDIX A NOTICE OF VIOLATION Bssed on the results of an NRC inspection conducted on March 8-11, 1977, it appears that certain of your activities were not conducted in full compliance with conditions of ycur Facility License CPPR-106 as in-dicated below.
Items A and B are categorized as Infractions and Item C is categorized as a Deficiency.
A.
Criterion V of Appendix B of 10 CFR 50 states, in part, that:
"Act-ivities affecting quality shall be prescribed by documented instruct-ions, procedures, or drawings, of a type appropriate to the cig-cumstances and shall be accomplished in accordance with these
--O j
instructions, procedures, or drawings." The Limerick PSAR Appendix D.1 and D.4, including Answer to Question #17, describes the application.
D[T) of this criterion and others to site subcontractors and vendors. Bechte drawing C-236. Rev. 6, establishes 3/16-inch as fillet weld size for niding carbon steel stiffeners to stainless steel liner plate of the spent fuel pool structure. Subcontractor procedure CVT-01, Rev. 0, establishes visual inspection requirements for such welding, " Fillet welds shall be of the specified size with full throat and legs of uniform size."
Contrary to the above, on March 11, 1977, fillet welds at several locations on the liner plate were less than the specified 3/16-inch J'.C j size and hcd less than full throat. The weld <nea 3daubsenuant
'l cutlity ineneHan had not been accomoirshego_p.qqqhe with ap-sl' d.
special processes, and the program for inspection of liner / stiffener IIratb'e dr_twings and procedures. The measures established to control welding, which were established to comply with Criteria IX and X of
,. rd Appendix B of 10 CFR 50 J
B.
Criterion XIII of Appendix Ei of 10 CFR 50 states, in part, that:
Measures shall be established to control the handling... and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration." The Limerick PSAR, paragraph D.4.9 states, in part, that:
" Vendors
' /W e.-
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2 shall have written instruction to govern the handling... and
. preservation of the items under contract so as to prevent degra-detion of quality..." The 8echtel Technical Specification 8031-C-45 for the Spent Fuel Pool Liner requires, in paragraphs 7, 9,14 and 16, that:
"The application of heat to.. '. austenitic stain-less steel is not permitted... (and) Iron contamination of stainless steel shall be prevented... Handling... procedures shall include measures to protect liners surfaces... from damage."
Contrary to the above, on March 8,1977, the following conditions J
,p.axisted during field erection of the Spent Fuel Pool Liner:
(1) 1,,f Stainless steel exterior surfaces had been contaminated with the
') area /ironresiduefromathermalmetalcuttin slag process. Several
[g/00 l
s exhibited large accumulations of fired s ag/ iron deposits which indicate that the base metal was subjected to uncontrolled elevated temperatures and iron contamination. This condition had not been prevented by control measures. (2) Stainless steel interior h"eb g surfaces had been contaminated by an unidentified residue which had 4
apparently been deposited in the presence of high heat which had l
/
burned a sheeting material in contact with the steel at several gr in locations and of several square feet area. This condition had not g [ y'A k.
riterion V of Appendix B of 10 CFR 50 requires, in part, that:
" Activities affecting quality shall be... accomplished in accordance with these... procedures."
The Limerick FSAR, Appendix D, paragraph D.1 states, in part, that:
"(Philadelphia Electric) is responsible for coordinating the (Quality Assurance) program to assure that all necessary control require-ments and procedures are followed..."
Bechtel Job Rule G-5 for p-Q Design Document Control, paragraph 4.2.3.4, directs that "Upon receipt from Project Engineering of an acceptable Quality Assurance
/)
Manual (and changes thereto) it is forwarded to Document Control i
't7 for 1ogging...*
ments (y to the above, on March 'J.1977, the latest approved amend Contrar l
Nos. 3 and 4) to Testing and Inspection Procedure 3.20.A.1 j
i were not entered in two controlled volumes of the Peabody Testing Quality Assurance Plan at separate on-site locations.
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6 a.
Infractions 7 01 :
Failure to Assure that Specification Requirements are Accomplisnee Relative to Minimum Size of Fillet Welds on Carbon
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Steel Stiffener Attachments to the Stainless Steel Liner Plate of the Scent Fuel Pool The inspector viewed the spent fuel pool liner structure being erected on a concrete pad south of the reactor building.
On each of four sides of the liner structure, segments of the' h-ON fillet welds on various vertical stiffeners appeared marginal when viewed from a distance.
The inspector obtained a fillet
'[
weld gage from the licensee quality assuranc.e representative and measured the weld size at several locations (e.g. #45 A15)
(
which appeared suspect. At least one location on each side of h
the liner assembly did not meet the 3/16-inch criteria shown ghf M
on the design drawing C-236.
This is contrary to the visual V#
MOV inspection criteria of part 5.6 of PDM procedure CVT-01 which Q
/
requires " Fillet welds shall be of the specified size with
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full tnroat and legs of uniform size."
The existence of the above condition required that the responsible [
My
/pr M 4Y welder did nnt adhn-
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the soecifc d weld size recoirement e
X In n=Wo mine the w k, and the cua'ity intrecTor d'd not adhere to specified inspiction requirements.
This 1: contrary to criteria V, relative to implement:. tion of criteria IX and X of Appendix B of 10 CFR 50, which require accomplishment and inspectier. of welding to assure adherence to specifications and procedures.
The inspector examined the following documents relative to the above:
Bechtel Drawing #C-236, Rev. 0 PDM Welding Specification WS-17 FDM Procedure CVT-01, Rev. 0 77-02-02:
Failure to Prevent Damage and Deterioration of the boent Fuel Deo) Liner Oj7 f
The inspector observed that the stainless steel exterior surfaces of the spent fuel pool liner assembly had been exposed to the
$,l 00 molten slag / iron material resulting from a carbon steel thermal cutting process.
This was evidenet:d by the spray patterns of p/.'
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Therefore, the SFPL material was not handled in accordance with work instructions as directed by 10 CFR 50 Appendix 5 Criterion XIII, which states, in part, that:
" Measures shall be established to control the handling... and preservation of material... in accordance. with work... instructions lg&dM to prevent damage er. deterioration."
The licensee stated that the statement in the Bechtel Specification gv F[M '
g, 8031-C-45, paragraph 14 pertaining to the prevention of iron contamination of stainless steel is only applicable to the h
final cleaning aspects and coes not apply to the fabrication / instal-i lation activities.
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Tha inenacter etated that such a narrow view of that unecifd cation D
reTuirement g not recogntze uni other simnar provisions < n L[
the speclficatioUnd implementing procedures, and wat not p
consistent with the obvinne intan* of the ses"4'4"='4an, the reTated PSAR commitments, and the governing criteria of 10 CFR 50 Appendix B.
b.
Deficiencies 77-02-03:
Failure to Distribute the Peabody Testinc Quality Assuranc Plan (OAP) in Accorcance witn Job Instructions During a review of the licensen site 0A
_ office ensv (39 _
gg
- 5) of the 1:eabedy Testinc OlP, the inspector noted certain inconsistencies in the amendment numbering sequence to one of i
I a
the procedures.
Further investigation of the Bechtel's Master P
Copy (39-02-1) revealed di'fertnt are+aate than these in conv 39-02-5m The Becntel Fielu Drawing Control Reg' ster indicated that amendment No. 2 was the latest approved amendment.
The inspector examined the subcontract Field Engineer's and the on site Peabody Testing Quality Centrol Group)'s copies of i
the QAP (copies 35-02-4 and 3g-02-8 respectively and verified that amendment Nc. 4 was the latest approved edition.
Those manuals controlled by Bechtel had not received the lates,t amendments (Nos. 3 and 4) due to a failure to fully implement distribution instructions. -
Bechtel Job Rule G-5 for Design Document Control, paragraph 4.2.3.4, directs that "upon receipt from Project Engineering of an acceptable Quality Assurance Manual (and changes thereto) it is forwarded to Document Control for logging and control l
' number assignment."
In this instance, Engineering / Trocurement had received the amendments but had not forwarded them to Document Control for logging in a timely manner.
A 8echtel
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g m-1 F.e:nonse to Apandix 1 - Hetice of Violation Infreetion:
j 4.
Criterion V of Appendi.t B of 10 CFP. 50 states, in part, thata
" Activities affecting quality shall be instructions, procedures, or drawings, prescribed by documented of a type appropriate to the circur. stances and chall be accocplished in accordance with these instructions, procedures, or drawings." Tne I,inerick P61R Appendix D.1 and D.4, including Answar to Question #17, describes the application of this critation and others to site I
subcontractors and vendors.
Bechtel drawing C-236, Rev. 6, establishan 3/16-inch as fillet veld mise for volding carbon i
steel otiffeners to stainless steel' liner plate of the spent fuoi pool ntructure.
Subcontractor procedure CVT-01, Bev. O, establishes vicual inspection requiracants for such ws1 ding, "Finet velde shall be of the spesified size with full throat 4
and legs of unifor= sica."
A** P Contra.ry to the chove, on March 11, 1977, finet vside at g 140 several locations on the 'lir.or plate wars less the the specified 3/16-inch nine ud had less the run throat.
The vel h e4 g
pubencuent outlitv itNweetion had not basa secocpl. sand in accord-an=a w2tn sopiicEoie drastre sad proeecures.
Ice usamurea p
establach60 to cast.roA specia.1 processes, and the e-errs = for I
h
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inspection of lir.er/stiffenor welding, which were estab12shed y
1,a cor. ply wsth Urlteria II 'and I of Appa-m B of 10 CFA 50,
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6 were not effectively inplacented.
.5DONR68 1 non-co'nfornsnee report issued to prcride e rrective action for the condition identified s.bove has resulted in ne followings l
1.
Corrective St'ns..
/
An cospisted velas have been rainspe'etod at the site to assure that their si:o is in accordanos with drawing req irer_snts. Any undersiced walds have been repairsi s.nd reinspected.
2.
Action to nravent reeu renes.
l 2he vendor Plant ed Tield Superintendents have been reinstructo1 to asnure that velda utist drawing requirecents.
Tne Plant and Sit' Q.1. Departennte brav baen reinstructed in the drawing requiranent-j j
and vin verity bo;:plsanco with the requirements dying the visaal:
inspeetion of the volds.
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...fgJ G 2 0 1978 AU6 2 4 IHI g,4, gggygg Docket No. 50-352
}3'.E; Gu At 124. (352['lS 09 Philadelphia Electric Company A )f.04)
IF Attention:
Mr. V. S. Boyer YLLE.'. Goal-7.*2.(ggt Vice President Engineering and Research 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
Inspections 50-352/78-03and50-352/78-04 This refers to your letter dated June 12 in response to our letter dated May 10, and your letter dated July 20 in response to our igetterdatedJune 16, 1978.
The inforcation presented in your letters in response to the Notices of violation issued L this office coes not fully meet the requirements A
of Section 2.701 of the NRC's " Rules of Practice," Part 2, Title 10.
- hf['/
Pursuant to these requirements, you are d [ Code of Federal Reculations.
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- requested to submit tc tnis office within ten (10) days of your r v < 'S d
d,lI*/
f mentioned Notices of Violation which includes: (1) corrective steps f
@d'Q which have been taken by you and the results achieved; (2) corrective ge 0 steps which will be taken to avoid further items of noncompliance; and d.4'
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(3) the date when full compliance will be achieved.
The enclosure to this letter is provided to assist you in your under-standing of our areas of concern.
Should you have any questions con-cerning these items, we will be pleased to discuss them with you.
Sincerely,
/
9 I'1 *f f,1A
- Boyce H. Grier Director Enclosure,:
Areas of Concern
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ENCLOSURE AREAS OF CONCERN M
A.
Notice of Violation dated May 10, 1978 5o-557./'1803 E
g This item of noncompliance concerned one instance of failure to G
fully implement the requirements of Liquid Penetrant Test Procedure IPPT-340-39-02, Revision 0.
Namely, liquid penetrant ' test indica-tions in excess of the acceptance standards were observed by subcon-tractor test personnel when pipe weld No. HBC-183-1-FW-8 was tested nd accepted on April 2, 1978; however, it was not verified whether or not actual defects were present.
Our bases for the. above finding included the following:
(1) on April 6 an NRC inspector observed that the develeeine eowder had not been removed from the weld after it was tested en Apri' 2 and t rre L., y re m e-test indications wnien__were in excess of the 9
accec'Ance st M a*ds, (2) on April 7 the weld was retestec Dy a qiialified examiner from the licensee's constructor in the presence
~
of an NRC inspector and both eM e*ved indicath -e 4e evenst of the accectance standards, Inc (3) recorcs or other evidence were Dot arcilable indicatine it had been ve m 1*' Nt the W icatTons did esem 1 coal cerectsj pgr tg age { tg wegn -
e b.{t,h1fPECO'sresponsetothisaccarentitemofnoncomplia g
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limited to actions which attested to the quality of the particular
-4 C
c weld.
Further corrective actions are required to assure that; Ip M,,f (1) subcontractor test personnel are properly implementing df pfd thetestingprocedurewithrespecttotheprocessinf2hotherprevious f
indications which exceed acceptance standards, and I
p 1 g < Yg, liquid penetrant test indications which exceeded acceptance standards were not accepted without taking suitable actions to verify whether 1i "the indications represented actual defects.
B.
Notice of Violatien dated June 16, 1978 50- 5 67./'18 M t
Pt This item of noncompliance concerned one instance of failure to h
control deviations from quality standards for Class I seismic is structures.
Namely, Bechtel Drawing No. C-875, Revision 6, was hj, approved and issued to implement modifications to radial beams y
inside the containment structure even though this drawing contained instructions which were contrary to requirements of the AWS D1.1 q
Structural Welding Code, an applicable quality standard.
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' [ f ur bas'es for the above findings included the following:
- 1) the aforementioned Bechtel drawing specifies the use of a w(elding procedure applicable to prequalified weld joints although N*
the weld joints called out on the drawing do not meet all of the
/
requirements of Section 2 of the AWS D1.1 code for prequalified ih(/
joints, and (2) the drawing permitted the use of fillers in a I
manner contrary to requirements of Section 2 of the AWS D1.1 code.
The designs of the weld joints were significantly different from that specified for AWS prequalified weld joints.
Differences
)
r included shape and type of weld joint and weld size, e.g., weld sizes specified for fillers for Beam Nos. 24, 25 and 29 were less than that required for BTC-P4 welds by paragraph 2.10.3 of the applicable AWS code.
PECO's response to this apparent item of noncompliance indicated l
that clarifying revisions had been made to drawings, but stated that code requirements were met.
Futther correctiu actions Et recuired to assure that (1) the requirements of AWS D1.1 have been met in the performance of the modifications, and (2) suitable measures are provided and implemented to control deviations from
- J 4ty standards during the design process.
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YfY kY oW ga er "fi3j mg 3/$y APPENDIX A
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NOTICEOFVIOLATiON e-
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N Pniladelphia Electric Company Docket No. 50-352 This refers to the inspection conducted by a representative of the v
Region I (Philadelphia) office at the Limerick Generating Station Unit 1
Limerick, Pennsylvania, of activities authorized by NRC License No.
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CPPR-106.
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During this inspection, conducted on December 26-29, 1978, and January Q
2,1979, the following apparent item of noncompliance was identified:
10 CFR 50, Appendix B Criterion V, states, in.part, that:
" Activities T
affecting quality shall be prescribed by documented instructions.
-j procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings."
k T1e Limerick PSAR, Appendix D. Quality Assurance Program, Paragraph D.6.4, states, in part, that:
"(Bechtel) quality control engineers
... are responsible for preparing inspection plans in accordance s
with the Field Inspection Manual, (and) Performing Quality Control inspections."
Bechtel Project Special Provisions Procedure G-6.1 v@h '
states in Section 3.1.5 that "an Inspection Point (I) in' the Quality Control Instruction (QCI) is a mandatory inspection point beyond which work shall not proceed past the point where the designated q
activity is no longer inspectable".
I Contrary to the above, on December 2.1978, the weldine of a two rna c 10e 3c07,,,, i e c e p 5 K. t e n.12 9. Jf_'y had DedcErded U
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bev0nc IPe EM Pt b are some of the /esicnt.ted mancatory insoections
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(Closed) Unresolved (352/78-03-05):
Bechtel Job Rule JR-E-1 was completely revised (Revision 9, issued July 26, 1978) based upon IEEE Standard 43-1974 requirements.
A memo was issued by Bechtel, dated August 7,1978, listing (motors that are to be meggered in accordance with the Job Rule E-1, Revision 9), in, lieu of the vendors instructions.
The GE supplied motors for the core spray, PJiR and reactor recirculation pumps were on this list.
This item is considered resolved.
(Closed) Unresolved (352/78-02-02):
Bechtel Drawing C-637 was revised (Revision 8) to state which " Guides" listed on the drawing are mandatory and will require prior engineering approval for deviation.
Bechtel issued a checklist (No.15) which lists the C-637 Orawing mandatory inspection criteria.
The project QC instruc-tions for concrete preplacement (8031/C-1.20. Revision 10) were revised to incorporate checklist No.15.
The inspector reviewed PECO Surveillance Report No. G-19 which detailed the search that PECO had perfdrmed to ascertain that for the 1.imerick Units no other design " Guideline" document existed.
This item is considered resolved.
l 9.
Safe:v Related Picine Installation (Unit 1) a.
The inspector observed welding of safety related piping at various stages of weld completion to determine if regulatory requirements and PSAR cemittments are adhered to.
The following weld joints in various stages of completion were inspected.
HBB-127-1/7-M57 FSK-EBB-129-3/9-No. 51 Noitemsofnoncompljancewereidentified.
I The inspector reviewed the weld history cards and outlity b.
control inspection reports for the above weld joints.
For weld joint FSX-ESB-129-3/9-No. 51 (the welding of a two inch 1
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11 Aipple to the pipe spool) the inspector observed that there f
were three (prior to. welding) inspection hold points listed on Quality Control Inspection Report No. M55 which were not
. signed off as acceptable.
These inspection hold points were
' as follows:
(1) Activity #2.2 - verification of materials, (2) Activity #2.3 - inspection for cleanliness and surface defects, and (3)
The authorized code inspector's hold point for activity 2.3.
Further investigation indicated that neither the authorized code inspector nor the Bechtel QC engineer were notified prior to the welding of the 2" nipple to pipe spool that construction was ready for them to perform their respective inspections.
The work had proceeded beyond the point where it was not feasible to adaquately perform the cleanliness and surface defect inspections (activity 2.3) as described in QC inspec-tion (No. 8031/P-1.10).
The licensee was infonned that this was contrary to the requirements of the Project Special Pro-visions Procedure G-6.1, Revision 1, and Appendix B, Criterion p g, V of 10 CFR 50.
NV44 12-02)uan.gsg.rs.ts.estes.m.gaagy (3sans-Tr.isJ 10.
PreserviceInsoection(pST) Activities (Unit 1) 5 The licensee has contracted Nuclear Energy Services, Inc. (hE5) to perform the PSI examinations required by Section XI of the ASME Boiler and Pressure Vessel Code.
The ultrasonic examination of piping welds is governed by Appendix III of Section XI, 1974 Edition, Winter 1975 Addenda as modified by Paragraph 1WA-2232 of the Sumer 1976 Addenda.
The inspector observed NDE in progress, reviewed NDE data and interviewed personnel with resoect to the data end observations.
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ATTACHMENT I
'PESPONSE TO APPENDIX A fls.
S C $ 'T W A Item of. Noncompliance
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s criterion N Itates, inYart,[that:
qualityshallbeprescribedbydocumente[p,[
" Activities affecting instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings."
The Limerick PSAR, Appendix D, Quality Assurance Program, Para-graph D.6.4, states, in part, that:
"(Bechtel) quality control engineers... are responsible for preparing inspection plans in accordance with the Field Inspection Manual, (and) Performing Quality Control Inspections."
Bechtel Project Special Provisions Procedure C-6.1 states in Section 3.1.5 that "an Inspection Point (I) in the Quality Control Instruction (QCI) is a mandatory inspectic point beyond which work shall not proceed past the point where the designated activity is no longer inspectable".
Contrary to the above, on December 2, 1978, the velding of a two inch nipple onto pipe spool piece FSK-IBB-129-3/9 had proceeded beyond the' point where some of the designated mandatory inspections could not be performed.
. g* R e s p o n s e to Item of Noncompliance W.oI b
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The required inspections have been performed and documented.
A_ review of other open inspection plans indicates that - tto other g u P',,,,
if In any event,d Quality Centrni nnid eeints have been bypassec.
- g the start fqd hgif peines are missed they are identified prior to
%,5 final inspections as a matter of routine, since in-process inspections are reviewed for eeenteraness prior to the start of g %fA f final i n s o c e t i cus.s In order to avoid further items of noncom-b J
,wh / pliance, the Tield Staff Engineering and Area Supervision were g
, l' /ri-instructedat a meeting on January 2, 1979, on their quality l related responsibilities concerning hold points.
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4 it :a requested that this item of noncompliance be reclassifind t[i as an unresolved item since the Quality Control Instructions on 0 * #g e?'
Ethe timerick project designed to identify missed inspections are
, b or hold pdints.
We do not consider it appropriate to identify pt of,/ this a s an item of noncompliance since reviews of the in-process
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F inspections and final inspections which follow would have L
identitled the condition.
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APfi 2. G79 KINC OF PRUSSI A. P.NNSY gV ANI A 19408 e
81f.Clivi.0 6 95 M Docket flo. 50-352
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!L,I Philadelphia Electric Company ATTil:
I4r. V. S. Boyer Vice President 2301' l'a r 5
W.E*. Q
\\-2-2 (352[98-12 )
h Philadelphia, PA 19101 Gentlemen:
Subject:
Inspection 50-352/78-12 This refers to your letter dated liarch 2,1979, in response to our i,
letter dated January 31, 1979.
Thank you for informing us of the corrective and preventive act'ons documented in the response portion of your letter.
These actions will be exatined during a subsequent inspection of your licensed program.
Your letter requested that this item of noncompliance be reclassified as an unresolved item since the Quality Control Instructions on the Limerick project are designed to identify missed inspections or hold points.
You indicated that subsequent reviews would have identified the condition.
he Office of Inspection and Enforcement Inspection Report 50-352/78-12
_s noted in Paragraph 9 that the missed inspection hold points included Yj adequatelybecauseofworkwhic(hnadproceecec.
some inspection requirements w ich were no longer feasible to nerfonn 5ubsequent ioentification by yode orna**m could~noFadEfuaW c'Bmpensate for the oricinal em4" inn of <*en insnections.
We also no;e_5 net consent had not be*a "4ean eithe-Fe the enda 2 '*horized insoecf6r_or by thalechtel OC insnector tn Biva the dniena*FM hnTH mMnts.
Therefore, reclassification of_the
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Ete fef noncompliance would not be appropriate.
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Sincerely.
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- Robert T. Carlson, Chief
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' 4 hg, Reactor Construction and Engineering f'
Support Branch vy,y/y w.o
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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 This refers to the inspection conducted by a representativ'e of the Region I (Philadelphia) office at the Limerick Generating Station Unit 1. Limerick, Pennsylvania, of activities authorized by NRC License No. CPPR-106.
During this inspection, conducted on July 5, 6, and 9,1979, the following apparent items of noncompliance were identified:
2 1
A.
Appendix B of 10 CFR 50, Criterion V, states, in part:
" Activities affecting quality... shall be accomplished in accordance with these instructions, procedures or drawings."
The Limerick PSAR, Appendix D. Quality Assurance Program Paragraph D.6.4, states, in part, that:
"Bechtel Construction Department... is responsible for construction of the plant to approved engineering specifications, drawings, and procedures..."
Bechtel Power Corporation Project Special Provision Procedure G-6.1, Revision
%R.
2 states in Section 4.4, " Engineering changes which effect completed work that requires further construction, shall have a new inspection recort g, g initiated by construction QC.
The new inspection record is developed to cover the inspection of the work required to accomplish the engineering I
change."
Contrary to the above, as of July 6,1979, a Field Design Change Notice No.
5 to Design Drawing :-292 effected the completed anw ;C accepted weld. joint on a pipe restraint, identified as PR-9.
A new inspection record was not developed to cover the inspection of the work required to accomplish the l
engineering change..As a result, the work required by the engineering change was not accomplished on PR-9._
This item is an infraction.
E.
Appendix B of 1d CFR 50, Criterion V, states, in part:
" Activities affecting quality... shall be accomplished in accordance with these instructions, j
procedures or drawings."
l The Limerick PSAR, Appendix D. Quality Assurance Program, Paragraph D.6.4, V. R.
states, in part, thet:
"Bechtel Construction Department... is responsible for construction of the plant to approved engineering specifications.
g drawings, and procedures..."
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APPD; DIX A 2
i Bechtel Primary Containment Specification C2 (Revision 9), Section 10.1.14, applies to temporary brackets among other things, and states that:
" Preheat at 2000F minimum shall be applied to all carbon steel seac:s whose thickness exceeds 1-1/4" regardless of at:bient temperature."
N'l(D$
Contrary to the above, as of July 6,1979, temporary brackets were welded at several locations on the liner plate, where the plate thickness was 1-1/2 inches, and no preheat was applied.
l This item is an infracti n. -
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I Primary Steam and Feedwater Pioing Restraints a.
The inspector inspected pipe restraint weld joints in various stages l
of completion. The restraints inspected were identified as PR-9, PR-42, PR-47. PR-12 PR-43. PR-11, and PR-44. The following items were l
found during this inspection:
(1)
A backing bar is used when welding the two circumferential pieces l
of a restraint t6gether.
The inspector notes that the backing bar is attached to the restraint by various amounts of weld, since there are no requirements for the amount of weld to be used.
There are instances where the backing bar is either tack welded F. R.
on both eeges, or one edge is weldee to the restreint. yhe inspector also could not find in various documents any acceptance p/'t criteria for what is the allowable gap between the backing bar N.lgc i
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and restraint.
The inspector questioned the QC engineer what he used for an acceptance criteria.
He stated that his critaria gg8 WA1 "ticht against the restraint." The infpktbr Wfo'rinefthe -
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I licensee Inis is considered unresolved pending review of their evaluation of this situation ( m m.nt n>("
f'kWi The inspector also noted during his inspection of the pipe restraints l
7
g (2) that the restraints supplied by Chicago Bridge and Iron had a i
t cope or access hole where the horizontal and vertical weld joints
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coincide.
This was apparently done to assure that a full penetra-The Mississippi Valley Company supplied J+'
tion weld is obtained. restraints do not have an access hole at the we N - IGG Jf therefore, it is questionable that the required full penetration k
-weld can be obtained. The lirantaa etetM +b+
th4t 4+== will be l
The inspector infonned the licensee this item is pN M valuatad.
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considered unresolved pending review of their evaluation (352/79-i U
07-03).
(3)
During the inspection of completed restraint, identified as PR-9 the inspector noted that the tacking bar was welded on one edge i
only and was warped. The completed weld joint (horizontal) was pb approximately 1/4 of an inch misaligned.
The weld doint was ccepted by QC encineer on April 9. 1979.
A review of Drawing C-g.' N 292.' Revision 8, indicated that a Field Change Request No. C-g 5542F was issued on April 9,1979 to provide for fitup tolerances 4
for restraints.
This request was approved as Field Design Change
!l 8 No. 5 and it requires that when there is a misalignment (1/2"
- h. MQ maximum) the backing bar is to be removed after one side of weld ot.. C(pb i joint has been welded and a six to one taper shall be provided at M
the weld joint where the backing bar was.
This was not done.
M(g M This is contrary to the Limerick Procedure PSP-G-6.1. Revision 2,
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5 E. k' which requires a new inspection for additional work to be accom-N-l(oS p11shed to completed work due to an engineering change. The licensee was infomed that this was an item of noncompliance (352/79-07-04).
(4)
During the above inspection of restraints, the inspector also noted that temporary brackets (used for construction aids) were welded to the containment to temporarily support or align piping.
The inspector asked to see documentation for these temporary welds to determine if they were being controlled. Theinsnector7 found that these welds were treated as nonsafety related. thefe. fort F. R.
cuality. gatrol_was not involved and weld historv in'ntmatian was a
Q not docyme.nted.
Several of the welds were made on liner menetra #
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tions (penetratior).s X9A and X9B), which were 1-1/2 inches thick.
u A erefore, requiring a minimum preheat of 2000T. The licensea was v4 y,IAg /(
informad n t tM:p enntrary to the raq"4*e-nt!
- Rechtel e
Spacification E-6 which recuire that waldina of *emporary attach-J. d',
ments be contro11arL(use of qualified welders and procedures, f
preheat, and nondestructive examination of liner after removal of temporary attachment.), and that this is an item of'noncomoliancu (352/79-07-05).
5.
Reactor Ccolant Pressure Boundary - RevDT'ltetords (Unit 1)
A review of two pipe spool Quality Assurance Document packages was performed to verify compliance with Specification P-312, the ASME III Code, and Regulatory Requirements.
The following pipe spool document packages were reviewed:
Pipe Scool Size Nuclear Class Material DCA-105-1-3 20" 1
304 Stainless Steel DCA-105-1-4 20" 1
304 Stainless Steel The documents reviewed consisted of the material test reports, shop fabrica-tion and inspection records.
No items of noncompliance were identified.
6.
Unresolved Items Unresolved items are matters about which more infomation is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Three unresolved items disclosed during this inspection are.
discussed in Paragraphs 3 and 4.
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Reviewed QC inspection re,7 ort (QCIR-M41-821-G001-2-1) for this
)
weld joint I
Verified that weldor was preparly qualified I
Verified preheat and interpass temperatures were controlled in i
accordance with procedure (PI-AT-LH/CVN). requirements Verified that quality control inspection and authorized inspec-tor hold points were adhered to No items of noncompliance were identified for the above inspection.
During the above inspection the inspector noted that the opposite weld joint end prep (WA3) had to be modified (mitered) in the field for align-ment purposes.
The inspector during his plant tour observed the final stages of machining of the weld end prep on October 16, 1979.
During the investigation of the various documents involved in this modification, the
.J g;, v (/ October inspector determined that the documents were issued after the_ machining I
bas practin1.ly_.Komp.1,ete.
The Bechtel re-worn not.ca P-7zT was 1ssued ori 16, 1979.
The General Electric (supplier of pipe spool piece) l l
/d issued the field deviation disposition request on October 16, 1975.
The in,spector informAd_.1hs ],1c.ensee that this_was cWary to the a F
<aaei-b j [t j MgaQo@A2513, which requires G.E. approv'aToriw4o_re-worMpg.
The 7'
o E"that one oT'their QA engineers also uncevered this ud
- (J g license finding report (number.f,-23,5, dated October 16, 1979).
r informed the licensee that this item is considered l
utwesuiveo pending review by an NRC. inspector of the corrective action taken assure that the requirements of procedures, specifications and instruc-tions will be adhered to for safety related activitie.s inside the contain-M ment.
(352/79-11-01).
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- Also during the above inspection the inspector noticed a non-conformance (NCR) tag (#3795) on a reactor recirculation restraint 4' Qgh located at azimuth 90* and elevation 278'.
The tag stated that f
g p ~ ([p'p to biological shield).
there was a crack in the fillet weld (attachment weld for restraint g.
The inspector reviewed the NCR report which p
.was validated October 12, 1979 and held discussions with Bechtel welding angineer and the piping foreman to determine the cause for 4
the crack.
It was both of their opinions that it was caused by 8/[
improper sequencing of the weld.
The inspector. reviewed the weldor's y/
qualification and found that he was properly qualified on October 3, C
1979, for this welding.
It appears that this was his first production
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The i ector infermed the licensee that the aws n1 1 g
ISection 3.4_re u1res that the contractor shalf cevelop weldinc 9
hI sequencesjish.contrwHistoWer
--d Sc. r is the licensee's
/
gpinion that the_crac_ king of weld _was not due to _sequencine of the I
y wiidin~d3Tthey,ars sys?">+ M ":
~~'c=
nne 11censee also '
stated that the engineering disposition for the NCR (sixty days from pf issue) will state the cause and corrective action.
The inspector v'
also stated that he is concerned, that since the welds for attaching j
j
[
restraints to the biological shield wall do not receive any non-y destructive examinations other than a visual (no magnification) that i
there may be g1Act,_g.r,acks not detectable by the amh d p This.
j+[
( item is unresolved pending review by the NRC inspector the licensee's corrective actions (352/79-1102).
Observed postweld heat treatment (PWHT) of feedwater weld joint
)
c.
(DLA-107-1-7 to DLA-107-1-1 at FW #50), to determine that require-ments of Bechtel Job Rule G-33 Revision 6 and ASME Code are adhered to.
The following activities were inspected:
Verified recorder (W361) was in calibration Observed placing of thermocouples, installation of heaters and wrapping of insulation blankets i
Observed portions of heat up rates holding temperatures and cooldown rates Reviewed various types of documentation (workorder, QC records, recorder chart etc.) associated with this PWHT 1
No items of noncompliance were identified.
d.
The inspector reviewed welder training records for the past three months and complied a list of weldors who are welding safety related items where only a visual examination is required.
Two reactor recirculation restraints were randomly selected where the welds attaching the restraints to shield wall were made in accordance with i
Bechtel drawing C-956 Revision 2 requirements and accepted by quality control.
The restraints were at location azimuth 105' and 135' on the shield wall and welds were accepted by QC on October 17, 1979 and November 1, 1979, respectively.
No weld defects were noted (inspector used 5x magnification), however, the inspector noted that the restraint at the 135' azimuth the vertical welds were ground while at 105* it was not.
The inspector questioned the Bechtel QC engineer what was the maximum reinforcement allowed by AWSD1.1 code and used for acceptance.
He replied that one-eighth was the require-ment.
The code appears to be unclear and the licensee and Bechtal are to evaluate what maximum reinforcement is allowed for this particular joint configuration.
This item is unresolved pending t
i review of code and design requirements (352/79-11-03).
6 y/T) ) /
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11
@-63
[ y. 2. T) 14fD 9.
Crackino of Welds in Reactor Recirculation Pipe Restraints (Unit 1)
The inspector reviewed nonconformance report (NCR) No. 4018 which involved the cracking of weld joints during the welding of a reactor 0 and elevation 278.
recirculation pipe restraint, located at azimuth 0 This restraint was being welded to an embed in the biological shield and this is the second restraint that has cracked during welding (see unresolved item in inspection Report 352/79-11). The licensee was informed that the NCR did not evaluate the possible cause for the cracking and that the NRC inspector is concerned that the final welds on these particular type of restraints do not receive a non-destructive examination (liquid penetrant or magnetic particle exam-ination).
This item is considered unresolved pending review of licensee's evaluation as to the cause of cracking and their decision on perfonning NDE other than visual for these restraints (352/80-03-011 10.
Licensee Action on Previous Insoection Findings
{0 pen) unresolved item (352/79-11-02):
the inspector reviewed the status of the licensee's evaluation of the cause as of the cracking of pipe restraint weld. The following memoranda or letters were 4
viewed:
. Licensee QA organization's memo dated Oct. 22, 1979 to their engineering division requesting they evaluate that liquid penetrant 4
(LP) or magnetic particle (MP) examination be performed on
/
reactor recirculation restraint based upon the complex welding and h[p/
J h cracking of welds.
S
((
V(,Licen.s, ele M emo A ted Jan f
71 14Rn concluded that LP or MP is not -
7e'qEred due to cracHnc caused by improper weld ~ sequencing.
r On Feb. 19, 1980 the licensee's QA organization issued a memo to i
Do h I,M.A,'
their engineering division to re-evaluate the need for LP or MP of i.
the completed restraint weld joints due to another reactor
\\.
recirculati.on restraint cracking, whereby the proper weld sequence was used.
p Bechtel letter dated Nov. 8,1979 evaluating the cause of cracking.
The conclusion drawn was improper weld sequencing.
Bechtel field memo, dated 10/29/79 was an evaluation as to cause of weld cracking.
The conclusion drawn was improper weld sequencing was used by the weldor.
This item is considered still open pending review of the licensee's engineering reply to their QA organization's memo dated Feb. 19, 1980.
Wfh eO I
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4 APPENDIX A i
NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 g,.in This refers to the inspecticn conducted by rep.esentatives of the Region I
{?hiladephia) office and the Senior Resident Inspector at the Limerick 1
- enerating Station, Unit 1, Limerick, Pennsylvania of activities authorized oy HRC License No. CPPR-106.
Durin0 this inspection conducted on June 16,1980 - June 27,1980, the following apparent items of noncompliance wer_e identified.
j Appendix B' of 10 CFR 50, Criterion V, states in part:
" Activities n.
affecting quality shall be prescribed by documented instructions, 4 'e procedures, or drawings and shall be accomplished in accordance:
these instructions, procedures or drawings, pW l
[The Limerick PSAR, Appendix D. Quality Assurance Program, paragraph "The subcontracter shall have written procedures y &) 0 D.4.3.2 states in part:for control of the required testing and inspection programs pf i c,{# ~
item under contract.
These procedures shall cover all nondesctructive F
, tes ti ng...".
- 6.==
Schneider Inc. procedure PPM 5.1 Revisicn 0 requires that Quality Control inspection personnel have experience and training and be g
certified as qualified prior to performing inspections.
Contrary to the above, on June 18,1980 an individual who worked for Schneider Inc. as a QC inspector performed receipt inspections without peing properly certified as a qualified inspector.
This item is a deficiency.
B.
Appendix B of 10 CFR 50, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings."
.. L..
The Limerick PSAR, Appendix D. Quality Assurance Program, paragraph D.4.8 states, in part:
"The subcontractor shall have instructions governing the control of measurements.
These instructions shall include, as appropriate, calibration to standards and accuracy requirements...;
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2.
Plant Tours (Unit Nos.1 and 2)
The' inspector routinely toured the facility and outlying areas inspecting He observed pipe welding, installed structural steel and i
1 ongoing work.
]
I equipment supports, electrical and instrumentation. installed equipment and quality control activities.
i During the observation of main steam line pipe welding activities, the i
inspector examined a naarby rigid strut main steam line support, EBB-102-H15. He noted that the structural beam supporting the rigid strut had This copes and welding undercut which do not meet AISC and AWS codes.
beam and similar beams are located in the Turbine Building which is not a However, the main steam line is seismic j
seismic category I structure. The PSAR acknowledges that the Turbine category I at this location.
Building is not seismically designed and that the main steam line and its supports will be attachtd to this structure. The facility "Q-List",
which designates equipment important to safety, implies that the sub, ject beams are safety related and that the boundary of the "Q-List" is the weld These beams are not currently i
attaching the beam to the building steel.This matter is considered unresolved p designated as "Q-Listed".
detennination that these beams are part of the pipe support and "Q-Listed".
(80-20-04) 3.
Licensee Action on Previous Insoection Findinos (Closed) Noncompliance (352/77-12-01 and 353/77-12-01)
(0 pen) Unresolved Item (352/77-12-02)
Nonconfonning field welds (77-12-01) andshopwelds(77-12-02)onthe "r.
RHR heat exchanger supports. Reference IE Report 352/78-05.
0 W-
/Thelicenseerespondedtotheitemofnoncomplianceonthefieldweldsby:
[
a.
Re-inspecting all field welds.
Re-insp utina a samale of walds previously accepted by the quality
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% b.
contro'ITnspectors inv571Fe6..
e L
j
-p g,h-V Holding training classes for quality control welding inspectors.
c.
3 2970, 2971, 2972 and
/
The inspector reviewed Nonconformance Reports Nos.
2973 which documented the re-inspection of the RHR heat exchanger supports 9
/
[ and the disposition of those identified _as.. unacceptab b
N the Field Inspection Reports Nos. C63-24, 40, 41, 42, 43, 46 and 47 q
which document the sample re-inspection of the quality control inspectors 13
,--.--...,------.,._-.,-..---,-,.._-.,,-.-Q--,..-.-,.---
t Nuclear Weld Joint System
' Class Status
- ECC-106-1/1-FW62 Reactor Water C1sanup III F&I EBB-106-1/8-FW4 Main Steam By-pass II FAI GBC-101-14-WO58 Main Steam Relief III F
II FAR j
HCB-107-1/2-FW61 1.iquid Rad Waste I
I BWR-PD-1 REC-1/4 WA3 Reactor Recirculation
- F-Fit-up; I-Intermediate weld passes; R-Root pass During the observation of welding activities on weld joint BWR-PD-1 REC-1/4 WA3, the inspector noted that the weld groove preparation on the pipe elbo was being ground approximately 3/16" into the base material and around th circumference approximately 49".
Further investigation disclosed that no written authorization existed for this alteration to the weld groove.
E'n General Electric Specification 22A2284 Revision 2 " Field Erection of W
Piping Butt Joint End
, Reactor Recirculation Piping", paragraph 4.7.1.
N, g
Preparation, requires that, "... Existing piping butt joint end preparation shall not be remachined, filed, ground or otherwise changed wit V
approval of General Electric".accordance with applicable specificati
/
52/80-20-01).
{
MCFR50, Appendi tagI
\\ Jhe 4aspector..noted that the McensaaJa.s anda.A Jignif.fcan
, pipe welding.faspection.aragram in that.sertain inspect o
y
(
"Jipid.potat".
This tack welds, and alignment are no longer performed on a 1001 basis.
change is reflected in Sechtel Quality Assurance Manual - ASME Section "f)
Division 1. WD-1, paragraph 7.4.
A note permits the Lead Welding Quality r
l Control Engineer to determine if these attributes are checked on aIn
" surveillance" or " inspection" basis.
hold point beyond which work may not proceed and surveillance meaning The surveillances are made at may proceed without the check being made.
the option of the inspector.
k y
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(+ 8
Item of Moncomoliance -E Infraction Appendix B, of 10CTR50, Criterion V, states in part:
" Activities affecting quality...shall be accomplished in accordance with those instructions, procedures or drawings...".
The Limerick PSAR, Appendix D. Quality Assurance Program, paragraph D.6.4 states, in part, that:
"Bechtel Construction Department...
is responsible for construction of the plant to approved engineering specifications, drawings and procedures...".
Limerick Proj ect Standard for Visual Examination Acceptance Criturin for Welded structures, 8031-G-20, paragraph 4.1.6.1 states, in part, "... undercut not exceeding 1/32" may be accepted...".
Contrary to the foregoing, on November 14, 1980, 10 _azaaa_.o f
/3f'ind[pThwere_oysegvedonthe feedwater (ejeu~t~~si(cieTing 1
s i
restraint N pIcted on drawl O !f36, Revision 3.
J pe
Response
The subject feedwater pipe restaint was inspected by Bechtel Power
..M i Corporation inspectors subsequent to'the NRC ddentification of the deficiencies.
Additional deficiencies identified were recorded
_h,3*#
Bechtel Power Corpo, ration Nonconformance Report for engineering f(
on a evaluation.
As a result of this inspection, further inspections aru required in order to perform an engineering evaluation of the conditions.
The additional inspections and engineering evaluation i
&b will be completed by May 1981 and rework, if required, will be n
g ompleted by July 1, 1981.
To prevent recurrence, the manufacturer sent a representative to the site to observe the conditions first hand.
In addition to this, a Philadelphia Electric Company audit of the vendor involved to check on the effectiveness of his welding inspection program will be conducted during the 3rd week of January 1981.
Sheet 2 of 2 3:
2 37 W
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APPENDIX A-M NOTICE'0F VIOLATION L"
Docket No. 50
- Philadelphia Electric Company Philadel'hia, Pennsylvania 19101 p
L1 cense No. CPPR-106 As a result of the inspection conducted on January 5-30, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the followins violations were identified:
10 CFR 50, Appendix B, Criterion XVI, states, "... conditions adverse to qua11ty, such as...nonconfonnances, are promptly identified...that the A.
cause of the condition is determined'and corrective action taken to pre-clude repetition... and the corrective action taken'shall be documented and reported to appropriate levels of management.".
The Limerick PSAR, Appendix D, paragraph D.4.12, states, in part, that:
...The program shall provide input for the initiation of corrective action y g' and follow-up as appropriate.".
r.
Project Special Provisions Notice 'SF/ PSP G-3.1., Revision 3, paragraph
-Uk 3.1.5, states. "If a deficiency to the code requirements are identified within the code boundary of an ASME ttem, it shall be controlled by the use -
of nonconfonnance reports.".
=
Contrary.to_the.foregoin_3,_.pn_Jarmacy 15 19E the NRCDpector dinov grouch observation anl document review that rejecta'bleJondestructive lesting indications iaFe~Identif3iuTET3fspositioned_pn.ln.. process R
~
~
Notices instead of Nonconformance Reports as.requirsd Specifically, an ~
"ASME Nuclear ClhTTpipe~ weld',7LA-107-17FW 11, was liquid penetrant tested and rejectable linear indications were identified, "outside the i
areas of interest " (the adjacent base material). The indications were dispositioned on In-process Rework Notice No. W 655.
This is a Severity Level V Violation (Supplement II).
V 10 CFR 50, Appendix B, Criterion V, states, in p procedures, or drawings.".
The Limerick PSAR, Appendix D, paragraph 6.4, states, in part, that, "B Y. k.
Construction Department...is responsible for construction of the plant to approved engineering specifications...".
pgg Bechtel Specification for Fonning, Placing. Fin concrete shall be repaired as soon as practicable but no later than after forms removal.".
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2 APPEllD1X A Contrary to the above, on January 15, 1981, a concrete imperfection w served on approximate elevation 279', in Reactor Building No.1, in the West slab construction joint RS-P-1-4, measuring approximately 2" deep b The Quality Control. Inspection Record No. C-140-1" high by l' in length.
RS-P-1-4, executed on October 10, 1977, did not record this condition.
1 This is a Severity Level V Violation (Supplement II).
10 CFR 50, Appendix D, Criterion IX, states, in part, that, "... Welding...
(is) controlled...in accordance with applicable codes, standards, sp C.
cations...".
The Limerick PSAR, Appendix 0, paragraph D.6.
7, Q.
plant to approved engineering specifications..."'.
Welding Procedure Specification 'PI-A-LH'(Sheet), Revision 0, requ welding be performed in accordance with the General Welding S p MQ The GWS, in paragraph 5.1 and Table GSW - Structural - 1.
requires that for E7018 electrodes and material thickness in exce Structural.
0 F.
through' 2 ", the welding preheat be maintained at 150 J,Dntrary,lec,the 3 ove on.JanuaryN{ 81b.weljing to b
21 Q431-4. consisting ~of a 5/8 te related e trical_JupportsDJeld dWn6tlave Jelded 'to a str.ucturALbtam fjan_,geJreateri than 11thl'cTC 5
^
pieheat a'pElied to a temperature To.1500 F.
This is a Severity Level V Violation (Supplement II).
Pursuant to the provisions of 2.201, Philadelph (1) the cor-Notice, a written statement or explanation in reply, including (:2) corrective rective steps which have been taken and the results achieved; steps which will be taken to avoid further' violations; and (3) the dat l
full compliance will be achievad. Under the aut oath or affimation.
FEB 2 71991 g
M[
_ IIdbert T. Carlson, Chief Dated
?
Reactor Construction and Engineering Support Branch
.N 5
.g
4 The following observations were made during the tours:
% A concrete defect was observed at elevation 283', in the WestT I
F.R-concrete slab No. RS-P-1-4.
p., g g,
.~ joint of the slab to. wall and measured approximately-2" deep by A review of the Quality Control Inspection in height by l' in length. Record No. C-140-RS-P-1-4 disclosed i
Paragraph 2.2.b been ccznpleted and had not identified the defect.
The of the QCIR states that, " Surfaces inspected for major defects".
failure to identify and evaluate the aforementioned defect is contrary to the requirements of 10CFR 50, Appendix 8. Criterion V, and an item of noncomoliance.
(352/81-01-01)
Observation of electrician welders making cable tray and conduit hange support attachments to building structural steel disclosed that they
- 7. Q.
---)>
The weld, were be.ing made without the required preheat being applied.
M" N R-431-4, was being made to the flange of a W36x300 structural beam o The prescribed welding procedure specification, the reactor building.
P1-A-LH (Sheet), Revision O. requires that welding be perfomed in General Welding Standard, GWS-Structural. The accordance with standard GWS-Structural further imposes preheat requirements for the i
welding of structural components in Section 5.0 and table GWS-It requires that, for materials in excess of 1 "
Structural-1.
through 2h", a preheat of 150 F be applied before welding and main 0
The inspector felt the weld inrnediately after the welder
- throughout.
completed a weld and observed that the metal was only wam to the to The welder acknowledged that preheat was not I
not unccrnfortable.Tha failure _to._ preheat structural steel base mater ule in 1dpand h R-employed.
,Lc cor d an ce Sith..requ i reme nt s lsTjont7aM_MD130.~(35
~
i Criterion IX, and an item of noncomoliance.
i 1
While touring the reactor pressure vessel (RPV), it was noted that chemically treated lumber and a trash bag were being sto recirculation loop nozzle.
Supervisory personnel were unable to confim if these materials are l
acceptable for use inside the RPV. The material control document, ASM-1, dated August 3,1979, titled, " Approved Site Material for Sup of Reactor Pressure Vessel Internals Installation", does not specific It does specify certain types of address the fire retardent wood.However, at the time of this inspec plastics for use.
This matter is acceptability of these materials was indeteminate. c I
these materials.
(352/81-0,1-03)
He The inspector examined welding on the RPV l
Further inspection revealed that the shrouc procedure (W)-1/1-05-1L, lifting device is not conside scope of quality control inspection.
the lifting device is not safety related, it is employed to place t Both of these items are safety related and evt shroud in the vessel.
precaution should be taken to preclude construction damage to R"fP
.wy
= -
1 5
i The licensee took action to provide preheat for subsequent welds.
i The inspector witnessed parts of the nondestructive tests performed on the lifting device.
He also made selected visual and dimensional examinations of the device and verified they confomed to drawing No. LM 005/1.
this matter at this time.
The inspector noted that workmen were grinding on a valve body to Y.R'
+
These indications were remove liquid penetrant test indications.
HCC-101-6/12 FW 7, and Q -Q found while testing the pipe to valve weld.
The repairs were documented on Peabody Testing Report PST-PT-7420.
being carried out under an In Process Rework Notice (IPRN), No. W The valves are ASME Code valves and should not have rejectable indica Furthermore, if defects are noted in when they' arrive in the field.
It this type of equipment, a Nonconfomance Report should be written.
was detemined that these valves are'not "Q" listed and nomally beyor:
However, the practice of dispositioning the purview of the liRC.
potentially hamful defects in ASME Code press tigation.
A revicw of the IPRN log revealed that other similar, safety r components have been dispositioned using IPRN's.
W655, dispositioned 2 rejectable linear liquid penetrant test indica "outside the area of interest" (i.e., the base metal) on the nuclear Class I pipe weld DLA-107-1/16 FW 11.
The Project Special Provisions Notice, SF/PSPG-3.1, Revision 3,
" Control of Nonconfoming Items", paragraph 3.1.5, requires that, "If a deficiency to the code requirements is identified within the code boundary of an ASME item, it shall be controlled by the use o The failure to disposition nonconforming nonconformance reports".
conditions on ASME III Code base materials in accorda foregoing Project Special Provision is contrary to 10 CFR 50 Criterion V and an item of noncompliance.
(352/81-01-04)
Licensee Action on previous Insoection Findinos 3.
Storage' requirements for (Closed) Unresolved Item (352/79-11-05)Two aspects of generator s emergency diesel generators.
(1) The en'ergizing adequately addressed in the storage instructions:of windings.
A review of the electrical quality control the generators is being accomplished.The meggering records were verified fc is printed out each test period. emergency diesel gener 0 mr
7 _
g ;st?
ATTACRMENT I
{V b
RESPONSE TO APPENDIX A
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A Violation -A3p 10 CFR 50, Appendix B, Criterion XVI, states, in part, that:
" Measures shall be established to assure that conditions adverse to quality....
~
are promptly identified and corrected."
The Limerick PSAR, paragraph D.4.12, states, in part:
"The program shal provide input for the initiation of corrective action and followup as l
appropriate."
The Limerick Quality Assurance Plan, Volume 1, Appendix S, " Procedure fe; l
Processing Field Initiated Tinding Reports", paragraph S-5.1.7, states:
i "The Responsible Organization shall take or have corrective action taken....".
nromeri, carrected:
Contrary to the above, veldins inadequacies were not NU*f3. issued on November 1, 1979 for corrf in tAa t T.ield Lin,d,in.3_Lepo.r];
f1E'e action on an NRC finding which resultDE su sne January 11, 1950 for noncompliance with fire damper welding forwarding of a citation requirements, was impr_operly closed out by the architect-engineer and that closure was ace _epted by the licensee on February 6.
1980.
Closure; l
was based on contractor rework or zars camper installations to assure TCR-C6351 requirenent compliance with the approved Tield Change Request for alternate, interic welding of fire damper exterior velds which do nii and upon f uture fire damper installatio:
meet accessibility requirements in accordance with TCRC6351 or an alternate acceptable method.
NRC j
inspection in April 1981 disclosed that fire protection dampers-TPD-202 TPD-201-31, and TPD-202-44 had exterior welds without sufficient access for inspection.
Severity Level IV Violation (Supplement II.D.1) applicable to This is a CFPK-106. ~
i Resoonse to Violation l
Corrective actions taken by the Licensee to ensure that identified Ite: '
recur were:
of Noncompliance will be completely corrected and vill not l
1.
A caview was perf ormed on the Licensee responses since 1979 to NRCl future Items of Noncompliance.
Any response which committed to actions was followed up to ensure that the actions were satisfactc, accomplished.
2.
Philadelphia Electric Companv Tinding Report N-173 was initally based on a c ommitment by the HVAC Subcontractor to closed out dampers.
reinspection of all previously installed fire a result of NRC perform a In the future, all finding reports generated as l
resolutions will not be Items of Noncompliance with acceptableactions have been satisfactorily l
closed out until the corrective accomplished and verified.
I 1
50-352/81-4
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4 ovaun assuanact File No.:
.'d h 8 kg R.A. Mulford E. C. McCabe NRC "1* * "
TO Name Organization Name Organization 5/20/81 9tho==
337g ngg
SUBJECT:
PIOO Response to Ins. Report Nos. 50-352/80-21 & 50-353/80-19 wherein PECO requeste'd NRC to reconsider violation resulting from QC doing suweillances on veld fitup. Dese surveillances are done on randon basis rather than utilizing a statistically based saspling method.
N'N Y A e N hmf> bf (N.sgl{F. A.) tsW DISCUSSION
SUMMARY
(Commitmencs, Problems, Agreements, Etc.)
9,,7,
ECM:
We have prepared a draft of a letter which disagrees with PECO's response.
Eowever, we believe it would be desirable to discuss this matter before any letters a.:e written.
?JX/EN: We agree. Could you describe your position on PICO's response.
ECM:
Yes, it is the NRC's position that:
1)
The PSAR App. D paragraph h.3 2 requires a 100% veld fitup inspection.
2)
Feedback to appropriate management must be provided on fitup problems.
3)
Verification on rework must he obtained.
b)
Proper fitup cannot be verified without 100% inspection.
i 5)
Radiography does not always show nismatch of P P*.
6)
Pe=it holders in Reg. I currently perfom 100% fitup inspectics (based on recollections of personnel at Reg. I).
'7) verfifiention by osmp1'ing is acceptable if performed under cuicwco of Rec. Guide 1.28 or ANSI 45 2.
8) his 100% fitup was included in program proviously accepted by iUtc but was cha=ged without NRC's concurrence. (Note: D:Lis apparently refers to Bechtel BQAM which was revised abet,t 4 yeah
. Wt=c i
100%r.quirement).
- RECEIVED
- o infer that addl*tIonal i
Also, the NRC could interpret your response hif 2 4 pq '
inspection impedes the progress of the work.
I assure you the PEC'0/3echtel do not believe tha OMoES$%fggspe k ERW:
work, and we had no intention to convey such an m 4 rence to the NB&.
I will contact responsible people and tentativelf,.__l%4 f c M%a meegtt Reg. I Eeadquarters to discuss this matter. I vili- =
I a mutually agreeable date.
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evaur, assvaamcc Limerick Generating Station FOR us No.
PECO Response to Ins. Report Nos. 50-352/80-21 &
SUBJECT 50-353/80-19 5/20/81 3M.ET N0.
2 0F S
ogg NOTE:
Subsequent phone calls involving 3echtel, EtC and 3echtel personnel deter =Imed that meeting villbeheldduzir.gtheweekof6/15(either6/16, 6/17,or6/18). Era win notify nC or exact date within next few days.
.y COFT TO:
J. S. Ie=per R. A. Mulfo."
I. C. Iistne:
G. R. Eutt/Iocal File Project File J. M. Corcoran E. C ossen (Bechtel)
- 1. E. Zoms.
M-tones esv. 7ns N-27 an.
_ _. =.
In addition to the above actions, the HVAC Subcontractor has inspected all 148 installed trap door fire dampers to determine if the welds were accessible for inspection.
Any velds found to be inaccessible for inspection vere fixed in accordance with the option allowed by Drawing C1616.
Eleven (ll)'of the inaccessible welds were determined, due to size limitations and existing interference problems, to be neither accessible for inspection nor fixable per the allowed option of Drawing C-616.
These eleven were evaluated and dispositioned as acceptable "use-as-is" by Bechtel Project Engineering since they will meet the actual design requirements.
t The corrective actions taken by the EVAC Subcontractor to prevent recurrence were:
- 1) Quality Control Inspectors have had training cours in the requirements of AWS DI.1 and Specification G-20, 2)
A special training session was held for the Quality Control Inspectors regarding the actions to be taken when, and if, welds or other attributes cannot be adequately inspected because of accessibility, and 3) the Site Inspection Procedure, PPM-5.3 was revised to include a requirement in the in-process inspection plan for checking welds for accessibility for inspection.
The above actions taken by the BVAC Subcontractor were completed by June 24, 1981.
B Violation 10 CPR 50, Appendix B, criterion V, requires in part that:
" Activities af f ecting quality shall be... accomplished in accordance with these instructions, procedures, or drawings."
"Bechte$
The Limerick PSAR, Appendix D, paragraph 6.4, states in part:
Construction Department is responsible for construction of the approved engineering specifications plant to Bechtel specification 8031-C-41A, paragraph 4.4, states in part:
"All welding shall be in accordance with the " Structural Welding Code,"
AW!
DI.1....".
The " Structural Welding Code", AWS DI.1, requires in paragraph 3.6.4:
"For buildings.... undercut shall not be more than 0.01 inches deep when its direction is transverse to primary tensile stress in.the part that is undercut, nor more than 1/32 inches for all other situations.
Contrary to the above, on April 22, 1981, welding undercut in excess o 1/32 inches was observed on the North Reactor Building Exhaust S t ack.1-velds on beam members 22D2 and 24D4R.
This is a severity Level V Violation (Supplement II), applicable to CPPK-106 and CPPR-107.
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50-352/81; La satici
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APPENDIX A NOTICE OF VIOLATION Docket No. 50-352 Philadelphia Electric Company License No. CPPR-106 Limerick Generating Station, Unit 1 4
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e During the January 11-29,1982 Jnspection, and in accordance with the Interim Tnforcement Policy, 45FR66754 (October 7,1980), the following violations were identified:
10 CFR 50.55a requires that Class 1 valves comply with the ASME Draft Code A.
for Pumps and Valves (DCPV), which specifies in Section 314.1.6 that repair welding procedures be qualified in accordance with ASME Code Section IX.
ASME Code Section IX, Paragraph V-6 requires welding procedure regualifi-cation if there is a cTa'F'geln7e" heat 1:reattepeTatse'.7e repair welding procedure', QAP-490,7ated l'!ay 7,1971, and'Procedurflualification
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Record QAP-490, dated October 26, 1971, limit post-weld heat treatment tem-11000-13000 (Fahrenheit).
Further, DCPV Section 314 specifies peratures to that rtqndestructive tests must be perfomed after any heat treatment.
I Contrary to the above, from December 20, 1971 to February 12, 1972 Class 1 Main Steam Isolation Valve B21F022D, Serial No. 3-683, was repair welded, radiographed, and_ post-weld heat treated / tempered at 13400F. '
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Thisis,aSeverityLevel_IVViolationJSypplementII).
10 CFR 50 Appendix 8 Criterion V requires that activities affecting quality B.
Project Special Provision Notice '
be perfomed in accordance with procedures.
PSP G-6.1, Revision 3. Paragraph 3.1.5, specifies that inspection hold points are mandatofy and work shall not proceed to a point where work is no longer inspectable.
Quality Control Instruction H-2.00, Paragraph 2.4.a.1, requires that minimum preheat and interpass temperatures be verified for l
full penetration groove welds,as a hold point inspection.
i Contrary to the above, reviews on January 21, 1982, disclosed that the pre-heat and interpass temperature hnld J oint inspections for full enetrfd20 gr.cova welds..)_ij'ted on Quality Control' irs)ectien1tecof6T -1 had not tLeen performed, aiidT6Twe7s tiadle~ ento ~mpTeTe6thout them, This is a Severity Level VI Violation (Supplement II).
i Pursuant to 10 CFR 2.201, Philadelphia Electric Company is hereby required to sub-mit to this office, within 30 days of the date of this Notice, a written reply, sec including:
(1) the corrective steps which have been taken and the results achie 1
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Philadelphia Electric Company Docket No. 50-352 2.*! O y' g ' {Limerick Generating Station, Unit 1 License No. CPPR-106 V
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y' 4 i As a result of the inspection conducted between October 17 and November 30, 1983, i.
and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C) pub-
@I N lished in the Federal Register Notice (47 FR 9987) dated March 9, 1982, the fol-lowing violations were identified:
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10 CFR 50, Appendix B, Criterion V requires that activities affecting qual
,f ity be prescribed by appropriate procedures and accomplished in accordance 6Q y with these procedures.
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Bechtel Power Company Job Rule M-21 is the procedure established to provide
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b direction to construction personnel regarding cleanliness controls on sys-tems which have been turned-over to the licensee's Startup organization.
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%Q,6 Contrary to_the at ove,, as of Novantb.er 30. 19.83. Job Ru_le M-11_had not been t
hy N.. '.
@fctNeb.jmp1emented as.evf dencadJay_1ht.laj.lureJJraxjde..wi+^1t S.1,.ean1j ness,contr.ols fol.lowingjia.a.}se!! y_of a feedwatet._3y.st,e.m gonta_inment i j bl
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4 isolation valve HV41-1F010A.
The valve body was open, the internal surfaces
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of the valva and its attehedJiping were eggsad to the..ssotain=aat _
,,ssament, and Buding,.nter of un7etermined quality had accumulated in the vh
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10 CFR 50, Appendix B, Criterion X requires the establishment of a program s
that assures that examinations, measurements, or tests of material or pro-M ducts processed be performed for each work operation where necessary to assure quality.
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Section 17.2A.10 of the Final Safety Analysis Report and Volume 1, Section
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10 of the Limerick Generating Station Quality Assurance Plan establish this j
program.
Contrary to the above, the program established for engineering and quality inspection of pipe support hangers failed to assure the quality of two
/ safety-relatedhangersinthat,asofNovember7,1983,hangersVRR-IRS-
$ HHA-1 and HHB-1, for the reactor recirculation system suction piping, were inadequately designed and installed, and the inadequacies were not identi-j fied d eing the engineering and quality inspect, ion's which had been completed.
This is a Severity Level IV Violation (Supple / ment II).
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3.
10 CFR 50, Appendix B, Criterion V requires that activities affecting qual-ity~ bit prescribed by documented procedures and accomplished in accordance with the established procedures.
Project procedure PSP-G-3.1 specifies nonconformance reporting requirements and permits only one nonconforming condition to be reported in each noncon-formance report (NCR)
Contrary to the above, the project procedure for NCR reporting was not fol-lowed in that, as of November 30, 1983, NCR 6507 was revised to include additional nonconformances.
This is a Severity Level V Violation (Supplement II).
Pursu.nt to 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office, within 30 days of the date of the letter transmitting i
this Notice, a written reply including:
(1) corrective steps taken and the re-sults achieved; (2) the corrective steps taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending your response time.
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ICING OF PRUSSIA PENNSYLVANIA 19406 i}
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Docket Nos. 50-352; 50-353 i
Philadelphia Electric Company h
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ATTN: Mr. John S. Kemper h
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Vice President i
Engineering and Research 1
i 2301 Market Street Philadelphia, Pennsylvania 19101 lb y
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Gentlemen:
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Subject:
Combined Inspection 50-352/83-19; 50-353/83-07 l-and J. T. Wiggins on October 17 - November 30, 1983 at the Limerick Generating This refers to the routine resident safety inspection by Messrs. S. K. Chaudhary Station, Limerick, Pennsylvania. The inspection consisted of document reviews, interviews, and observation of activities, and the results have been discussed with Messrs. G. M. Leitch and J. M. Corcoran of your staff.
pendix A and categorized Apparent violations of NRC requirements are cited in Ap(47 FR 9987), March 9,198 under the NRC Enforcement Policy,10 CFR 2 Appendix C A reply is required and should be prepared in accordance with Appendix A.
It is exempt from the Office of Managenent and Budget's clearance procedures under the i
Paperwork Reduction Act of 1980, PL 96-511.
fin a December 2,1983 meeting with senior Philadelphia Electric and Bechtel Power l
1 representatives onsite, the resident inspectors expressed NRC's concern over apparent:
weaknessas la4ha Quality ><=anca and ^"=*y caatrol Engrams, applied to sysr. ems for which construction has been essentially completed and which are then turned-I over to your Startup organization for tescing. Because the violations specified 3
in Items 1 and 2 of the enclosed Notice appear to result from these weaknesses, j
you are requested to incorporate in your reply to the Notice, those progransnatic corrective actions to be implemented to strengthen your controls over turvied-over i
Lsystems.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by i
telephone, within ten days of the date of this letter and submit written application to withhold infortnation contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
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JAN 101984 Philadelphia Electric Company 2
Your cooper.ation is appreciated.
Sincerely,
~7 M.
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s-Richard W. Starostecki, Director Division of Project and Resident Enelosures :
Programs 1.
Appendix A, Notice of Violation 2.
NRC Region I Combined Report 50-352/83-19; 50-353/83-07 cc w/ encl:
V. S. Boyer Senior Vice President, Nuclear Power Troy B. Conner, Jr.. Esquire Eugene J. Bradley, Esquire Limerick Hearing Service List Public Document Room (PDR) local Public Document Room (LPOR) (NSIC)
Nuclear Safety Information Center NRC Resident Inspector Comonwealth of Pennsylvania
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gd Here are facts backed by official documentation to prove there has been an apparant fraud by Philadelphia Electric (P.E.) involv-ing crucial, safety related welding infractions at the Limerick nuclear reactor.
On November 10, 1976, reacting to an unannounced Nuclear Reg-ulatory Commission (NRC) inspection report, Mr. Robert Carlson, of the NRC, wrote a letter (item 1) to P.E. Vice-President for Eng-ineering and Research, Mr. Vincent Boyer.
In that letter, Mr. Carl-son notified Mr. Boyer of serious violations in mandatory construc-tion procedures involving welding infractions in the on-going con-struction at the Limerick reactor.
(See Inspection Report No. 50-353/76-06 (item 2), and in partucular " Notice of Violation", Appen-dix A, Part A (item 3) of Mr. Carlson's letter.
As discussed under Part A, the most glaring example of repeat-ed welding violations had to do with the welding of safety-related items by non-qualified welders, using unapproved methods in contempt of specified procedures.
In this most glaring example, detailed on Page 5 of " Summary of Findings" under 76-06-01 (item 4), inspectors were recording as 0.K. improperly performed welds.
On learning of these repeated vio-lations from workmen, the N1C inspector, over the objection of Phila-delphia Electric, demanded an immediate inspection of questioned welds, and found them to be grossly deficient...but recorded as 0.K.
(described in item 5 above).
On Decemb'er 15, 1976, Vincent Boyer responded to Mr..Carlson's November 19 notice of violations, by writing to Mr. James P.O. O'R-eilley, Director, NRC Office of Inspection and Enforcement, at Reg -
ion 1, King of Prussia, Pa. (item 5).
Mr. Boyer wrote, "the inspec-tor involved is no longer employed by the contractor and a reinspec-tion of all other work performed by him has been accomplished where accessible". (see p 1 & 2 of attachment 1 of Mr. Boyer's Dec. 15, 1976 letter (item 6) (underlining mine).
The Air & Water Pollution Patrol, a Pennsylvania incorporated environmental group is intervening before the NRC Atomic Safety and Licensing Board contending a high potential for accident exists at Limerick.
This situation exists because P.E.'s Vice-President Boyer should have requirred inspection of all welds, both accessible and inaccessible, which now, at great risk, are embedded in concrete, l
and are no longer accessible for inspection.
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(2) 50-353--Welding--76-06-01 (cont.)
And now,seven years later, in order to counter our contention, P.E.
has suddenly changed its story.
Mark Wetterhahn, P.E.'s coun-sel, in correspondence of April 27, 1983 (item 7), responding to questioning by the Licensing Board relating to the possible impact of safety at Limerick, emphatically stated, "all welds inspected by the particular inspector, not only accessible welds were re-examined" (underlining by P.E.).
(See p. 43 & 46)
Apparantly to further remove any doubts caused by our insistent contention, a follow-up letter of May 20 (item 8) from P.E.'s Counsel to the licensing Board, contained various work records, in particular Finding Report No. N 093 (ltem 9), that was stated to be sent as ab-solute proof that all welds... accessible as well as inaccessible welds were inspected (see p.2 of May 20 letter, lines 7,8,9,10, 11).
(Report No. N093 does not even discuss inaccessible welds.)
In an order dated July 26, 1983, the Atomic Safety and Licensing Board, in spite of ordering that Air & Water Pollution Patrol's wel-ding contention be thrown out, requested affadavits from Philadelphia Electric to affirm their emphatic statements contined in their April 27 letter that "all welds...not only where accessible were re-exam-ined"
(* item 10)
Unable to substantiate, via affidavit, information which had pre-viously and repeatedly been submitted as fact, Philadelphia Electric, through its Counsel Mark Wetterhahn's letter to the Atomic Safety and Licensing Board, dated August 19, 1983 (item 11) wrote:
In the course of preparing to respond to*
the Atomic Safety and Licensing Board's request contained in its Second Special Prehearing ord-er (LPB-83-39) dated July 26, 1983, at 38-39 for an affidavit to verify the statements contained in Counsel's May 20, 1983 letter to the Licen-sing Board, it was learned that all inspections performed by the subiect quality control inspector had not been identified and, therefore, not re-in-spected as previously believed. (underlining AWPP's)
As a result of Philadelphia Electric Counsel's August 10, 1983 letter above,.snd the Air & Water Pollution Patrol's request for re-consideration of its Quality Assurance Contention, identified as AWPP VI-1, the Atomic Safety and Licensing Board reversed its posi-tionthrough its October 28, 1983 "Memorandun and Order Confirming Rulings Made At Prehearing Conference".(item 12)
a4, AIR and WATER Pollution Patrol BROAD E,PA.
50-353--Welding--76-06-01 (cont. )
As can be seen on p5 of.that order, our Quality Assurance Con-tention was only " partially admitted" thus eliminating an extremely serious known concrete defect (item 13) in the drywell wall surround-ing the primary containment enclosing the reactor core.
The partial contention, after eliminating concrete and other re-lated infractions, however, was more than just a contention.
It was a proven fact, as we made known to the Atomic Safety and Licensing Board, that (as the contention reads)" Applicant has failed to con-trol performance of welding and performance there-of in accordance with Quality Control and Quality Assurance procedures and. require-ments, and has failed to take proper and corrective and pre.ventive actions when improper welding has been discovered". Items 14 & 15 is a confused attempt, via " engineering analysis " to cover one such failure.
Just as at Zimmer, Air & Water Pollution Patrol has hundreds of doc,umented infractions of specified procedures in concrete work and safety related welding.
Just as at Zimmen it is already known there have been slip-shod inspections of safety related work.
Just as at Zimmer, it is already known there tuve been falsifi-cation of records.
Just as at Zimmer, workmen have anonymously reported. completed and inspected as O.K work which was later shown to be improperly done.
Just as at Zimmer, there was deliberate sabotage.
Just as at Zimmer, so-called qualified workers were found to be performing improper welds and performing welding procedures for which they were not qualified.
And just as at Zimmer, the Contractor, the Applicant, and in-spectros by-passed safety codes and standards, ignored their own quality assurance program, and then covered up flagrant violations, through false statements.
And just as the Nuclear Regulatory Commission was part of the whole sorid Zimmer indictment of the nuclear establishment, that same Nuclear Regulatory Commission, during much the same time was meting out gentle responses to infractions at Limerick.
And this same federal agency, while watching Zimmer and Phila-
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AIR and WATER Pollution Patrol BROAD AXE, PA.
(4) 50-3 5 3--Welding--76-06-01 (cont. )
delphia Electric (as stated in the Inquirer, Jan. 24, 1984) repeat-edly refused to insist, on safe nuclear standards even when workers and others submitted evidence of contempt for specified procedures in safety related construction work.
(We may have a Limerick work-er who might testify to this).
While Philadelphia Electric has, as ordered by the Atomic Safety and Licensing Board, placed all discovery documents we re-quested at 2300 Market St. in Philadelphia, the time alloted to Air and Water Pollution Patrol to ferret out all the details was totally insufficient, so that we could not fully search out the welding affair.
We have repeatedly pleaded with the Atomic Safety and Licen-sing Board (one motion for extended time is in right now) but have been refused.
This is consitant with NRC non-cooperation.
AWPP has enough information, documents, logs, etc, so we could help direct where more information is. Such an effort for the peo-ple of Montgomery County and Philadelphia to avert an accidett from known fraudulent welding and other consturction defects, would be a highly necessary effort to avert possible tragedy.
Air & Water Pollution Patrol is very small in membership and is at the end of out-of-pocket money.
We cannot hold on any longer without Federal or Congressional aid, not in money but in a com-plete investigation at Limerick, similar to that done at Zimmer.
It would be a shame to allow negligence, contempt for public safety, dereliction of duty by the NRC, and selfishness of Philadelphia Electric, to go unchallenged simply by default.
Sincerely yours, AIR & WATER POLLUTION PATROL
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FraM R. Romano, Chairman 61 Forest Ave.
Ambler, Pa. 19002 l
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I License 2. CFFP.-107 Fhilad=3phia Electric Co:pany Inspection W. 76-06 Attentici< :
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- 5. Esyer Docket ::o. 50-153 Vice President i
Enginecting and Research g
2201 Market Stree:
Philadelphia, Pe:r.sylvania 19101 Centlenotp
'This refers to tha ir.spectica conducted by :*.r. A. Toch of this of f Oc:aber 16, 19-22, 1976 authorized by ::2::.icense W. C??1-107 a:f,co the disc =ssic s of eur the findir/gs held by ::r. Toth.tish : r.,J. Corcoran of your staff a:
cemelusion of the inspection, and to a' subsequent telephose discussion.
betvtan ::r. To:h and :tr. Corcoran on ::ove:.ber 2,1975.
I Aress er.ani=ed dIri=g this inspection are described
- ithis these areas, the inspectics consisted of selective ih er.e icatien*.cf yrecedures an1 representati e :: rris,12:strit :s w t letter.
pars.iusci, : asure. aca r.a.:4 by the inspector, and observations oy tas inspector.
Based on the results of this inspection,1: appears that certain of your i
conducted in tvil ec=pliance with ::ZC ret.uire=en:s, as set forth in the ::etice of Y1olation, escissed herr.ith as Appenaix activities were ca These ite=s of noncocaliance have beas carestriza!. into the j
31, 1971.. 2his as described in our correspondance to yo.: dated Dece=her A.
f the notice is saat to you pursuant to the pryrisiens of 5.,cties 2.201 o
- 1C's " Rules of Practice". Far: 2. Title 10, Code of Tederal F.a:clacions.
Section 2.201 requires you to submit to this of fice, within tvsnty (20) days of your receip: of this notice, a vrf ttes sca:e *.nc or e=pinnation (1) corrective steps which have been taken by ycu and the results achieved; (2) corrective step's which w in reply includi=g:
will be achieved.
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s In accordar.ce with section 2.790 e f the *2C's " Rules of Practica". Part
- 2. Title *.0. Cole of Federal Regulations, a copy of this letter and the If this enciosares will lie placed in the :. AC's Public Docu=ent Boo =.
report cer.tains any infor=atica that you (or your contracter) believe to be proprietary. 4 is neccesary that you aka a written applicatianw disclosure. Any such application must be acco=panied by an affidavit executed E ne owner of the information, which identifies the document or part scusht to k withheld, and which contains a state =ent of reasons which Addresses with specificity the iter.s which will be considered by The the Co==tasima as listed in subparagraph (b) (4) of Section 2.7 If we do not hear from you in into a separzte part of the affidavit.
this rers d within the specified period, the report will be placed in the Fukite bes=a=c A.oen.
Should yoa have any questions concerning.chis inspection, we vill be pleased c:. discuss thes wich you.
Sincerely.
. Robert T. Carlson Chief Reactor Construction and Er.gineering Support Branch
Enclosures:
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Appe=diz A. L tice of Tiolation 2.
IE Inspection Report Xe. 50-353/76-06 l
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U. S. I:UCLT*a REC *JLSTQT.Y CC:*:::SSIO:t O TTI C C U T 1::3P;;CT1 0:: :.::D C.7C::CC'.C.T RFJCIO:2 I No:
So-353/78-M.
_ Docket Co: 50-353 II Inspection Kc; ::
C$rr.-197
_ License ** :
rhiladelphia Electric C.=ssne Licensec: _._
reg,cggy:
2301. arke't Street M
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19101 Category:
Philadelphia, ?cn.sylvania Sstecs:rds Croup:
Liscrick. Pennsvlyania Io acic=:
f Sk'R - 1065 !!.*e (CT.)
Ty;.e of Li:casce:
Routinc. Una==c.:nced Tyg.4 of I J',we t tu r:
October 16. IS22,1976 Dates of Ir.spect'.:n:
July 16-25.1976 -
Dates o, Prev!cus IE.:yeccion:
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DATE O' #
F.cNetir.;; Inspect:::
___A.D. Toth, Rehter * =4pector Nene DATE Acco pstyi=g Ins;c:: ors:
DATE DATE I'**
Othee Acces-anyi::;; ?ctsennet:
DATE I
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hcing Ch.ir'C'.' Construction Freicces Sewslos E. Ke taig.,
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AFFENDTZ A
- 0TICE OF '.'*n*d.TTOf*
Based on the results of tha ::P.C inspection co=decte.1 on October 16,19-22,197G. it appears chat certain ist yoar a=:1vitics vare nos conde.:ted in full cocpliance with conditions of ycur ::"..C yacill:7.icense :;o.
1 CFFR-107 as indicated below. These ite=s are infra::fons.
10 CTR 50. Appendix 3. Cri:crion II cc.uires in part. <easures shall be established to assure chat special processes, includ1=;
A.
velding....are conten1Jcd and ac a:-=11shed by qualified perss=r.a1 using qualified precedures in accardanew vich a;plicable codes.
y standards, specificacians. criteria and other special require-cents."
Contrary to the above, che' established :.easures were insufficion:
g to assure that veldia: ei structural =cuel := 5epta=her 22 l'nt-'h e l
was acec=plished is a:cordance with the applicable A*S-D.1.1.
I fillec welds en s:ructural steel,bea.m c'e==ectic=s at elevacia: 233.
' -- seet the ;
ty raquirc=an.s of th cel.=:n= 23,C - ' '
AWS Structural Veldi=g Code.
k*elding alcetrode holders were used accached to estension acicks which were not " dest ned or manufactured so as to enable qualif ted welders...co accaia the rasvics prescribed" in the L3 coda, nor were procedures alternatively qualified to escablish that accep able Quality cont:31 veld quality could be actained with such scicks. surveillance insp i
and effect correction of the conJittoc.
for 10 CP1t 30. Appendix 3. Criterion X requires in part. "A progra::
inspection of activities affe'eting quality shall ha escallished and E.
executed by or for the orgsnizacion peric. ing the activity te
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verify coefer ance with :he secu=e=ced insecucticas...shall be performed for each vocit operation where necessary to assure quality."
Contrary to che above, che inspeccien of accivicies during occcher 1976 did not verify conformance with Specification A-26 Revision 2 requirements for pectection of eachined surfaces during sandhtasting and painting operations on the contain= ant da a. and such arotection was not maintained and the nachined surfaces were inadvertantly painted and possibly sandblasted.
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ne fellowing three scens appeared to involve acrec=pliance with f
ref/.;1ations of the.Tuclear Re.tulatory Cca:sissic= or condittens c These ic e s are imitactions.
the applicable *;?.C license.
-a.r.s qt:
Ta!!cre To *.* eld Str*Jetvyal Steel per Aus cedgt tes During observation of veldteg of structural steel at Area 13 elevc:
233. ithe inspector observed that one ateel flocr team passed close to The clearance was swh *as ce 11=it access celuis H se vall line 23.
h bea end sad the te the required fillet velds of angle citps to t eIntervievs with craf t and supervisica the velding with the electrede holder 4 eaded on wall !;o. 23 revealed the p,lan to perfocfaste=ed to the end of a broc= stick; the personnel gel i
roach and centractor C/. and QC persone.cl later confir=ed that th s app had been used se the sfallar 11eited access veld joints at elevatic:
253. colusca F and 11 at wall 23.
i' l) g The scapector deterstned that the weld procedure PI-A-1.h (Structura act Rec. C had act been qualified using elect.rede helder es:ensicas, Altlici th the tad the veld.-r t=e= atualified using such es:ecafees.decs not soectitcall the use' of.
ary11:sbie Ced: N4 01-1-72 i
electrode beider extcasions vich respect to precedure ec3.1.2 require that h results cations ic does la Part manutscrured se as to enable qualified velders to at ain t eThe inspector c
~
vis prescribed to the AE5 Code.
sia differvat wWeen!Igur-holder attae* ed to a _s. tick d'E par **ar this recutement unless pre
~
siUstactory by qualtffc~ahon test for rE4 The 11:ensee dis-aciens ce be welded ac the 11atted access jotats.
d to per=1t agreg. and the taspeccoe requested that provistens he ma ei a:ica his visual tasrei: sten af the limited access welds perfec=ed at e erAn elevate nusters 23237.
The welds 253 es steel besa piece cies attrer and light were made avstlatie to the inspector.1 1 SeIt' ion 3 ame_ comply withJ e reeutrasensp of W.N- -
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Cen-
- 4er's=anship." in that the velds"Eere of unaccee6ble pr we_re fe -d to lover j
)
Fer che veld joints
(' k [, r edge of the sagte citp (root pass coentese. only. designa
,a,, g dj 1
de inspection Icees had,,,beejtehecked-off_, y the 5echtet e
,d b
The qc teseection or. includink **FlaalJustity Ver1Tication."t AE5-0-1-1 Section 6 apparently did met comply with the requirements ethe inspector reviewe in ys gP "laspection."
relative to the above item:
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u y r 3
OEC 1 1975 a
v e.eovea 3 j Mr. Ja=es F. O' Reilly.
- sc:c;legulttery c:==ission g\\ - ]
?agio: I Cattad States Nuclez a:d I:fsrce:a==,
of Inspec:is:
Cffice h
631 ? ark Avenua Pa. 1?*35 1976
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King of ?:ussia.
dated Novecher 10, 19-22, 1976 4
- 2
- :I te::a of ceceber 16, j
Subject:
$*:e I spec:to:
50-352/76-05
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5:stion
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a CCAL 1- - -2 (76-06)
,;t D ylla:
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Dear Mr. O'1cilly:
f =11:vi=1 =asyc=se s== che subj ectto Linarick UEC visit I
We offer the regs; ding 1:e=s ide :ified durf=3 the 16,,19-22, 1976 for i ed by 31C Licessa
[
2 on oc:aba; Canera:isg Stac' ion - :: :of constructi== activities auchor z inspection No. C7?1-107.
I - tespo:se s Ices A of APPa= dix A laccer.
Attachman:
of subject I:e= 3 of APPandix A
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- Iesponsa==
Accach=at: ::
cf subja== lac:ar.
dix A
- I - Easpe=se =o Ice = C of APP **
. t:
N latter.
Attachne. :
of subjec was exceeded to Deca =bar 15.
Should you j
The dus data for chts respo sa ber 2, 1976.
vould be pleased to 1976 in a calecon with your sca!! on 3 ace =
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items, va have any quascions c::carsi=g chase with yes.
discuss chan p<
Sincerely.
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i:e= A ef Aeae=ditt A lessonse :s 2eficie :r Criterion II requires is part.,
"10 Cy1 50 Appendix 3. established to assure that special P
shall be includitt veldics,... are. cont: wiled and
" Measures 2
j-f d
accomplished by qualified persocnel using quali ie pr,ocen ses, sta:dards.
with applicable ccies, criteria and other special require =e :s.".
accordance i
procedure.it specifications, established naascres vere the Cottrary to the above, that'veldi g of s :tetural steel insufficient to assure september 22, 1974 vas acco=plished in accordance The fillet velds on etwith the applicable AV5-D.1.1.
elevatios 25 3. '
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s::ve: ural steel bea= connectio=s atthe, quality requirs=am:s
=
colu==s 23-C and E.
did not =se of[dheAUS,Structuralk*aldingCede.used attached to extensi,c=*,
Ta7l ding e'lectrode holders were" designed c; =a=uf ac:= red so as :s Sticks whi:h vere net
... to a:tain the results pre-enable qualified welders vere procedures' alternatively, scribed" in the A7S code, acceptable veld quality could no qualified to establish that Qu'ality coctrol surve'111a=ce be attained with such s:icks.
identify and inspections conducted and docune::ed,did =st correction of the conditio."
effect specifically "Although the applicable Code ATS D1-1-72 does,notaddress th it to procedure /valder qualifications,be desig=ed and na sf actured so as to require that equip =en:
ibe.d.in enable qualified welders to attain the rarcits prescr the AVS Cods."
Rosecese -
The following corrective esasures have been taken:
1.
velds on structural steel been s.
The fillet elevation 253, columns 23-C connections at and I, have been repaired.
inspecter, who originally accapted chase longer a= ployed by the con-b.
The two velds, is no cractor and a rainspectio= of all other work 353ns-c6
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2-r a::::p.is ed.. tete has bes:
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ed b,. Cf app;;xisate..
s..e. deft:iencies *#4:e,-- *;-
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a:cessitie.
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actisc has beas ta'ae:.
- or
- ective 2.
ActiohA * # 28 <!*****
3 l' 0 c:aining class was coed:-ted Cc-:be
'or re-indoc::inat.on and.accepta:ca of cc:pleted vo;4 A
a.
reviewing of inspection griseria, as,:,*
,.,,7,._
e'*various aspec.s o.
A1. C a,
sibili:Les of welding i= spec:::s.:st: *
- S field veidt g pe:sonse craining class.
this C s:;o1 Me= ora =d:=. ?CM-23I + *sa s t
h o.,.. e
.issuei prohiti:ing the use of
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extensions.
10' II~# "ll~~'*ld'~h'~
-'*ec:ive O*ce:bausa c' veld ez:e=st-s sha...e c
he' quire identified and approved by the ea,. ve--
the engineef.
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2-C7d 50. Appe:r. dix E. Critcrion Y requires La part. 7 Activities.
Irjfecting quall:7 shall be prescribed by docia. Anted instructier.s.'.
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a.d 6611 Le aceu p113.1.e4 in accord.ince with these instructius..."
s
- 20. 1976 the ilocussat co:icrol Co_trity to the sihow, en October rcT.ste=ents ad jeb rulet JR-C-f *.wre not i=plomented foe des darfslone ber=.s at. elevatic,= 2*i) of Area 3 3 of the coactor betiding.
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7.f UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION t,/,I O
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ing Board N
Before the Atomic Safety and L cens V
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NY In the Matter of Docket Nos. 50-352
)
50-353 Philadelphia Electric Company
)
)
(Limerick Generating Station, 1Ita f
e
)
Units 1 and 1)
PARTICULARIZATION APPLICANT'S ANSWER.TO THE F ITTED CONTENTIONS Introduction Informal continuing, and order
" Memorandum ification of Condition-In its Discovery, Providing for further Spec Dismissal of ECNP" And Noting Admitted Contentions the Atomic
-(" Memorandum and Order"),
ally or. " Board").
10, 1983)
(February
(" Licensing Board" Safety and Licensing Board required, inter alia, that:
ll The intervenors shall particularize a ith -
conditionally admitted contentions, wplanning of emergency extent exception fullest the to the i
practicab'le in light of the informat on contentions, supplied since the special prehearing l
t the judging and 4
In l
such contentions, the conference.
particularity of of 4
in support Board supplied contentions, level of the bases particularized the
. will take into account available*
on I
information presently to a as they apply intervenors plans l
l.
Applicant's Accordingly, lieve missing contention.
l
[
should explain why they bea contention from information prevents is set being particularized beyond whatupcoming refi the g
forth in the 5
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the public."
This contention is complotsly 1ccking in basis.
Initia'11y, the examples given fail to establish any There is no link
/
pattern as alleged by intervenor Romano.
among.the deficiencies which were found by the Nuclear
~
A number of non-conformances are not,'*
Regulatory Commission.
There is absolutely j
unexpected for a project of this size.
..t no showing that there is a pattern or link among these
?,
,,'i been extraordi-h,t g v.'
nonconformances nor that their number has G;',R Nor has Mr. Romano demonstrated how these occurrence /,.
.Y nary.
could " increase the risk of an accident.during operation." 4'c..
ipplicant submits that the Commission has not set up this U,
Board to duplicate the Staff's role of providing oversight of construction of the facility.
Applicant sees nothing j
l a specific litigable issue which would in any way present i
regarding the overall quality assurance program at the i
In particular, with regard to Limerick Generating Station.
f subpart a, Applicant submits that this is based upon a misunderstanding of the actions taken subsequent to the t
As set forth in documents indicated Notice of Violation. all welds inspected by the made available to Mr.* Romano, not only accessible
- weds, wer inspector,'
particular is lacking in founda-
_j U
reexamined.
Therefore, this subpart s
tion and is without basis.
Intervenor Romano states that he is unable at this to provide further specificity regarding his contention.
Applicant submits that the enumerated reasons for riot doing
1
_ 44 -
which would allow him to so do not constitute good cause i
amend his contention in the future.
Intervanor alleges that the Applicant has failed to 4
requested during informal.discov-supply certain documents ery.
He asserts that "certain inspection reports and.
related correspondence known to exist have not been provided j
(or not properly identified in the large volume of documents that intervenor produced in Applicant's discovery room so could locate them)."
App 1'icant asserts that it has made every effort to respond fairly and completely to the discov-The documents responsive to his ery requests of Mr. Romano.
requests were of a technical nature and it is possible that j
understand their import.
Mr.
j he, as a layman, does not Romano has never specifically brought to Applicant's atten-I tion any particular documents he believes were not provided i
To the and should have been as responsive to his requests.
extent possible, documents have been segregated in separate i
folders'respondive. to each specific request.
With regard to the second reason, Bechtel Power Corpo-ration has stated that they would not make available the records of an individual inspector name and the employment "except in response to a subpoena or other lawful process."
Applicant does not understand how the refusal to provide a single name and resume would prevent specification of these quality assurance contentions.
in mail of one of The third ceason given is the loss intervenors two September 3,1982 written discovery requests I' -- --
"Nme.p%, _.,,
1 P
While Mr. Romano states that other parties on to Applicant.
I the service list did receive the
- letter, Applicant has 1
stated that this letter was inquired of Staf f counsel who not received by the NRC Staff.
In any event, a complete
~
l letter was sent to Mr. Romano on April 6, response to that 1983 and, on that date, documents responsive to that request were placed in the Applicanti's document room.
no' connection between any
- Finally, Applicant sees I
allegations of conditions at Three Mile Island or at the Midland site in relation to the' construction of the Limerick Generating Station.
Certainly, Mr. Romano does not demon-strate any such relationship.
In response to the note contained in the section stating that Mr. Lewis " intends to discontinue his par-
.", Applicant intends ticipation in the QA/QC contention.
at the to respond to any irgument Mr. Lewis might present I
prehearing conference.
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s LAW OFFICES I
GoNNEa Sc WETTERHAHN. P.C.
1747 P ENN S YLV ANI A AV ENL*E. N. W.
sa.sIwat a n n.as'x WAS HINOTON. O C. 30004
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May 20, l')83 4
ef Judge Lawrence Brenner Judge Richard F. Cole Atomic safety and Atomic Safety and Licensing Board Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Ccemaission commission Washington, D.C.
20555 Washington, D.C.
.20555 Judge Peter A. Morris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
. Docket Nos. 50-352 and 50-353 Gentlemen:
This letter is being submitted in response to the Atomic Safety and Licensing Board's " Order Regarding Quality
. Assurance Documents" (May 13, 1983). is a copy of HRC I&E Inspection Report No. 50-353/76-06, including the of Violation.. Attachment 2 is Applicant's related Notice response thereto which is a letter from V. s. Boyer to J. P.
1976 with three attachments of o'Reilly dated December 15, I
which only the first is relevant to the matter raised by Mr.
Romano. is a December 29, 1976 letter from of Mr.
t R. T. Carlson to V.
S. Boyer acknowledging receipt Boyer's December 15, 1976 letter.
Counsel for the staff has reviewed these three documents and agrees that they are 1
accurate ccpies.of the inspection report and letter sent by it~and Rr. Boyer's letter received by it.
t 4
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l Jcdge' Richard F. Cole Judge Peter A. "erris
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May 20, 1993 Page 2 i
The remainder of the attachments hereto (Nos. 4 - 9)
I
- are tho.se documents which were made available to Mr. Romano in response to his informal discovery reque.st.
39 dance With BY conversation with Mr. Romano yesterday, I as i
,y sending to him by Federal Express a copy of this letter and f
(, attachments such that he may make any presentation. to the 7 Board that he desires regarding these documents.
The
- s remaindet of this letter discusses how the documents made y available to Mr. Romano demonstrate that all suspect welds, p rather than those which were merely accessible, were rain-.
}
n specteds l
Aggathment'4 is a Philadelphia Electric Company Quality issued to the i
Assuranse Finding Report No. N-093 which was Sechtel Power corporation (october 27, 1976).
This Finding is the method by which, inter alia, NRC. items of noncompliance are entered into the quality ' assurance system. '
Report i
of the Philadelphia Electric Company for followup and i
disposition.
Page 2 of the finding report notes the issu-of Honoonformance Report No.
("NCR" )
1980 which. was ance utilised by techtel 'to disposition the specific welds which were found to be deficient by the NRC inspector.
Bechtel l
i NCR No.1980 is provided as Attachment Su r
PSCO Quality Assurance Finding Report N-093 also i
a reinspection. of all other accessible welds requires inspected by the particular Bechtel Quality Control Inspec-tor who accepted the deficient velds described in the subject HRC Inspection Report and NCR No.
1980.
Bechtel.
Field thspection Reports (sometimes referred to as "QCG1-1 Reports
- after the form utilized) which have control Hos.
C-43-7 through C-63-19, issued from October 26, 1976 through
- 1976, (Attachment 6) document the reinspection November 4, ion of welds examined in 1976 in response to and disposit PECO findiRS E* Fort N-093 and which form the basis for Mr.
j Boyerta Letter.
3eshtel Field Inspection Reports Control Nos. t-63-20 and c-43*21, both dated January 17, 1377, (Attachment 7) l l
document additional reinspection of welds which were subse-I been possibly inspected by the' quantly determined to have No particular Bechtel Quality Control Inspector involved.
unsatisfactory weids were found.
r
'Bechtel Field Inspection Report Control No. C-63-22 dated &pt&% 4, %%M %&%s4thment 8), documents the couprehen-j review conducted to determine which of the welds sive j
inspected by the particular sechtel Quality Control Inspec-l tor were not accessible as a result of being embedded in
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-e =-w- =e-. -use
l Judge I.awrence Brenner Judge Richard F. Cole
.udge Feter A. Morris j
May 20, 1963
?sge 3 concrete and which of the welds not previously accessible, e.g., due to construction scaffolding, were then sufficient-
[
~*
ly accessible fer inspection.
The results of this review are documented in Bechtel Inspection Report No. C-63-22.
Page 8 of 8 is a' Field l
summary correlation between the original Welding Inspection Plans-in which the particular Quality Control Inspector participated and the Field Inspection Reports which document the reinspection of the affected welds.
Bechtel Field In--
spection Reports Control Nos. C-63-24 through C-63-32 and i
C-41A-493 dated July 1, 1977 through July 6, 1977 (Attach-ment 9) document reinspections not previously performed -
because of accessibility problems in 1976.
Field Inspection Reports control Nos. C-63-30, C-63-31, l
C-63-32 and C-41A-493 describe reinspecticas of certain-welds which were partially embedded in concrete.
NCR-2710 i
which was generated as a result (not provided) demonstrates the acceptability of these welds.
That nonconformance I
report documents that, for purposes of analysis, it was.
assumed that only the reinspected portions were sound and that the remaining embedded portion of the weld was nonexis tent or failure of the entire weld was assumed.
In all
- cases, the function of the structural member was not impaired.
I would note that Field Inspecticn Report Control No.
C-41A-493 which is similar to the other nine in this catego-not provided to Mr.
Romano during inadvertently ry was If the Board has any questions.concerning this i
discovery.
matter, please let me know.
i sincerely, l
Mark J. Wetterhahn l
Counsel for the Applicant l
MJW:sdd Enclosures i
cc: Service List l
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('y ATTACHMENT 4 Philadelphia Electric Company Quality Assurance Finding Report No. N-093, dated 10/27/76 l.
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in....n N l CORRECTIVE ACTION TAKEN TO l 101YE FINDING. {l",.. s,, f;, u,,,n,
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Issuance of NCR 1980 to a[ knowledge the nonconforming con *dition
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and to acquire dispositioning to correct same.
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.F..I A Reinspection of all other work perfor.ned by the' particular
- -l [t inspector who accepted the welds, in question was accomplished 2.
wherever accessible.
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CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE
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A training class was held 10-25-76 for re-indoctrination and re-orientation in the various aspects of acceptance of completed work.
j ',t reviewing or inspection criteria and ulti= ate responsibilities fcr weld inspections with all personnel in attendance from both the i
QC and field welding groups.,
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satti i., 3 FINDING REPORT
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Limerick Units 1 & 2
's. Irrt: C avoir O sva'titta cr G L'iN NRC
- sestet
,, ativasats Q m:a 0 :: arcis't actica ara..
se:htei power corp.
E Item of Noncompliance 3
ens.: a..
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- e. ISSUED To c.K. Soppet - Project Manager 4._arruructs
[f.0RG'NIZATION Bechtei Power Corporation
- ) ^
E.I.I~.71'18d 72 4 74 editions e.THOSE CONTACTED T. Alton - K. Sishop
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- e. lO Crt 20. APP!NBl! 8 Clif. Ala p,g,***s,5{Qg j
i.. FINDING tosc ano scrutact aesstionat, smens as arcs:sts)
I-..
Twoweldsfonthebeamtothecliponbea=s23b87and23239inunition Elev. 257 were both inco:plete and unacceptab'le and were made with the alid
of a brcon stick handle attached to the stl'nger"to rea,ch the joint to be y
. welded; which is contrary to AlfS section 3s1.2.
~
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Furthir, inspec-ion sun eillanbe records'indics ed that these. b=sm connec-ions were inspected.
~
it0ISCUSSION (vst ans arrucaer annitionat suttts as arssiern Bechtel issued NCR No.1980 identifying the non-conforming condition.
- . RECD'3ENDATl0N test aun arrratact anoittomat inters as stonistu et ta ele tstett tatt istxteritz A. Both Inspector 10/27/76
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UNITED STATES OF AMERICA p
NUCLEAR REGULATORY C0f941SSION y,y r
a F g6
/ k ATOMIC SAFETY AND LICENSING BOARD 7
)
BEFORE ADMINISTRATIVE JUDGES:
b 1, ' p '
f Lawrence Brenner, Chainnan Dr. Richard F. Cole M*
l Dr. Peter A. Morris 3
I i
In the Matter of
)
Doc"kat Mos. 50-352-OL
~
- l 50-353-0L i
PHILADELPHIA ELECTRIC COMPANY l
h LBP-83-39 (LimerickGener$tingStation, 1
i Units 1 and 2)
J July 26, 1983
)
SECOND SPECIAL PREHEARING CONFERENCE ORDER The Board held a special prehearing conference in Philadelphia on May 9-11, 1983, to discuss proposed contentions and further scheduling of these proceedings. On May 16, 1983, we issued a " Memorandum and Order Confirming Schedules Established During Prehearing Conference".
Our order today provides further rulings on the' basis of,that special prehearing conference, including rulings on the admissibility of conten-J tions and the provision of specific dates for schedules which were previously described only in terms of triggering events.
In its filings prior to the special prehearing conference and at the conference itself LEA indicated that a number of contentions were These are Contentions 1-1; I-2; I-5; I-6; I-13; I-16(c) l being dropped.
- (.1); I-17; I-18; I-19; I-20; I-21; I-22; I-24; I-25; I-27; I-28; I-29; I-32; 1-33A, C F, G, H, ! & L; I-34; I-35; I-36; I-37; I-39; I-43; I
s, 39 -
welds were reinspected.
G1,ven Applicant's asserted follow-up, however,. g It may be that Applicant's' letter of December 15, 1976, only intended to c
r,eport on reinspections perfonned by tha't time.
If so, it would certainly have been useful for Applicant to have indicated in that response that further inspections and analyses would be performed.
v
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- The Bechtel inspect on reports do not by themselves make'<1 ear that s/
the welds listed are those which h1d'been inspected by the same I
ps
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inspector cited in NRC Staff inspection. report 76-06, or that the other,
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statements in counsel's letter are accurate descriptions of the ports
'(attachments 4-9).
In addition, we have no sworn affidavit testing to the fact that the structural analyses, showing the assuadd absence of the er-$edded welds as acceptable, were' performed.
(Thedetailsofthese structural analyses are beyond the scope of the contention that QA/0C follow-up actier, to this Staff ir.spection report was improperly limited.,
to reinspection of accessible welds.) However, it presently appears.
frort counsel's representations of facts that there is no basis to admi j
- Tven this part of AWPP's contention. We will not do so, subject to Applicant providing, as soon as practicable, appropriate affidavits of i
knowledgeable persons verifying the accuracy of the statements in its counsel's letter of May 20, 1983.
l f.othing in AWPP's letter to the Board of May 25, 1983, responding r-to Applicant's counsel's letter of M4y 20, 1983, remedies the fatal e
absen:e cf bases for believing that Applicant limited its follow-up c'
actier to accessitie welds, f I.t g
8
. AWPP seeks to conduct further discovery to better specify the We have already permitted ' WPP about a year to examine A
corttention.
QA/QC documents and it has been unable to frame an admissible contention.
Further discovery is unwarranted given AWPP's failu-e to specify with any reasonable particularity what it would seek to litigate within the broad area of QA/QC. ThefEtthatAWPPhasnotreceived details of everything it might need to actually litigate a case at an evidentiary hearing does not excuse its failure now to state an acmissible contention with reasonable specificity and basis.
"ta
.,.7, ve* ^
For the reasons stated, this contention which had been condi-
,-/
tionally admitted in an earlier form, subject to AWPP providing better'I b
specificity and basis, is rejected, subject to our acceptance of the affidavits to be filed by Applicant.
DISCOVERY Discovery may begin imediately on contentions admitted by the Board in this order. All discovery requests must be served by October 14, 1983. Discovery is subject to the directions and time limits set forth in our Order of May 16, 1983.
e
. 1 ORDER 1)
Contentions I-8. 1-15 and I-33M are admitted for litigation.-
The litigation is to be within the scope described in this memorandum and order.
2)
Contentions I-4. I-7. I-10.1-11. I-12.1-14.1-16a. I-16b.
1-23.1-26.1-30.1-31.1-38. I-60. VI-1 (provided appropriate confimatory affidavits are filed by Applicant), and the five new probabilistic risk assessment contentions are denied.
3)
Discovery on the admitted contentions may start insnediately ar.d will follow our instructions set forth in,this memorandum and order and our " Memorandum and Order Confiming Schedules Establish'ed During Prehearing Conference" (May 16,1983).
Pursuant to 10 C.F.R. I 2.751a(d), parties nomally any file 4) objections (requests for reconsideration) to this Order with the Licensing Board within five days after service (ten days in the case of the Staff) of the Order. Parties may not file replies to the objections unless the Board so directs.
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42 -
I'Th5SCGRDERED.
ATOMIC SAFETY AND LICENSING BOARD W
Lawrence Brenner, Gnairman ADMINISTRATIVE JUDGE C2c/P. A Dr. Richard F. Cole ADMINISTRATIVE JUDGE P h Q, L --
Dr. Peter A. Morris ADMINISTRATIVE JUDGE Bethesda, Maryland July 26. 1983 e
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E.AW OFFICES GONNER Sc WETTEREAHN. RC.
4747 PENN SYLVANIA AVENUs. N. w.
WAS EINGTO88. B* 8. 80006
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Augsst 10, 1983 1
m.,
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Judge Lawrence Brenner Judge Richard F. Cole
~
Atomic Safety and Atomic Safety and Licensing Board Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Judge Peter A. Morris 5
l Atomic Safety and Licensing Board U.S. Nuclear Regulatory f
Commission Washington, D.C.
20555 In the Matter of Philadelphia Electric Company N
(Limerick Generating Station, Units 1 and 2)
Docket Mos. 50-352 and 50-353 Gentlemen:
t In the course of preparing to respond to the Atomic Safety and Licensing Soard's request contained in its second Special Prehearing Conference order (LBF-83-39) dated July i
25, 1983 at 38-39 for an affidavit to verify the statements contained in counsel's May 20, 1983 letter to the Licensing Board, it was learned that all inspections performed by the quality control inspector had not been identified subject and therefore not reinspected as previously believed.
I The Applicant is reviewing the entire matter thoroughly, and will report to the Licensing Board as soon as possible.
The affidavit of John S.
- Kemper, Vice President, Engineering and
- Research, setting forth the present status of the review is attached.
We presently
f Judge Lawrence Brenner Judge Peter A. Morris Judge Richard F. Cole August 10, 1983 Page 2 expect to complete the review and report to the Board within one month.
sincerely, Mark J. Wetterhahn Counsel for the Applicant MJW:sdd Service List cc:
Enclosure d
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UNITED STATES OF AMERICA l
f.'4 NUCLEAR REGULATORY CCmISSION
\\ 'h
/r S ATOMIC SAFETY AND LICENSING BOARD L
5 '.r-BEFORE ADMINISTRATIVE JUDGES:
Lawrence Brenner, Chairman b 3,, d Or. Richard F. Cole Or. Peter A. Morris
)
In the Matter of
)
Docket Nos. 50-352-OL
)
50-353-OL PHIL ADELPHIA ELECTRIC COMPANY (Limerick Generating Station.
)
October 28, 1983 Units 1 and 2)
MEMORANDUM AND ORDER CONFIRMING RULINGS MADE AT PREHEARING CONFERENCE The Board hereby confinns the rulings made on the record of the i
prehearing conference held on October 17 and 18, 1983, at Phoenixville, Pennsylvania.
Admissibility of Contentions, LEA I-41 (U.S. I. A systems interactions)
LEA Contention I-41(a) was admitted as respecified in LEA's filing of September 28, 1983.
The contention is set forth with reasonable bases and specificity and is not otherwise legally barred.
Tr. 4809-13.
Subsection (b) was withdrawn.
Tr. 4807-08.
______w.._
_.__._mmm._
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i AWPP VT-1 (quality assurance)
AWPP Contention VI-1 was partially admitted on reconsideration by the Board.
It was reworded by the B ard as follows:
r Applicant has failed to control performance of welding and inspection thereof in accordance with quality control and quality assurance procedures and requirements, and has failed
~
to take proper and effective corrective and preventive actions 3
when improper welding has been discovered.
Tr. 4912-14.
The Applicant and NRC Staff shall promptly make available, in the greater Philadelphia / King of Prussia area for inspection and copying by AWPP, all documents regarding welding pertinent to the Limerick l
facility. This includes documents in the possession of consultants, contractors or other agents utilized by the Applicant and Staff.
The term " documents" includes, but is not limited to, reports of inspections and audits, whether internal or external, and related correspondence.
Within thirty days of completion of discovery (including responses relevant to Contention VI-)), AWPP shall file a list of all instances of improprieties with regard to welding and/or inspection and correction l
thereof, which will form part of its case on the merits of the contention.
For each instance listed, AWPP shall identify the particular portions of inspection repnrts or other documents which relate to such instance.
AWPP shall also briefly state what it is about m
Conclusion
- For the reasons discussed above, the conditionally
)
admitted contentions should be denied and no further consid-eration need be given to them at this time by the Licensing Board.
Respectfully submitted, CONNER & WETTEREARN, P.C.
Mark J.
etterhahn Counsel for Applicant Apri) 27, 1983
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c,,p c Contrary to the above, on September 15, 1976, concrete repair sork above the personnel hatch of the containment drywell wall uncovered #9 and #14 parallel reinforcing steel tied together in direct contact at two places.
Following identifics, tion, of this noncompliance by the inspector, the licenses site quality assurance organization insediately issued finding reports No. C-88 and C-89, which require evalu-ation and corrective action by the contractor. The licensee's response to a previous noncompliance regarding reinforcing steel clearances is documented in his August 27, 1975 letter to NRC.
c.
76-09-03: Infraction: _ __ __
_ ___ ___ Failure To Imolement Nonconformance Control System For Loss of Concrete Mix Proportion Control 4
Criterien XV of Appendix B of 10 CFR 50 requires that "Non-conforming items shall be reviewed and accepted, rejected, 4
repaired, or reworked in accordance with documented procedures."
i Criterion XVII requires that inspection and test records shall as a minimum identify the inspector or data recorder, the type of observation, the results, the acceptability and the action taken in connection with any deficiencies noted.
Bechtel Field Inspection Manual Procedure G-3 Rev. 6 requires.
that nonconformances shall be identified and reported in a controlled manner.
It provides that use-as-is determinations require Project Engineer approval prior to implementation, and concurrence by the Project Field Quality Control Engineer.
It requires documentation of engineering rationale where a use-4 as-is determination is made.
It provides a standard Non-conformance Report for the mechanics of, obtaining and documenting the above actions.
Contrary to the above, on September 16, 1976, the quality control inspection reports for June 23-24, 1976 concrete placement of the containment drywell walls did not reflect:(a) that concrete ingredient proportions were suspect for six truck load _s_of concrete, and any not have been within specifi-cationsi (b), that th_is situation had been reviewed by appro-priate personnelsfe) that the concrete _ use-as-is decision was supported by engineering rationale;((d.), that this matter was j
identified and reported in the controlled manner provided by the nonconformance report system, i
-~..-_-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)% - /V
~
Before the Atomic Safety and Licensing Board In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
AFFIDAVIT OF VINCENT 5. BOYER SENIOR VICE PRESIDENT, NUCLEAR POWER PHILADELPHIA ELECTRIC COMPANY vincent S. Boyer being first duly sworn according to law deposes and states:
I am Senior Vice President, 1.
My name is Vincent S. Boyer.
Nuclear Power, of the Philadelphia Electric Company (Company).
In this position, I have overall responsibility for the nuclear power activities of the Company, including the Limerick Generating Station.
2.
On August 10, 1983, John S. Kemper, Vice President, Engineering and Research, executed an affidavit dealing with the company's continuing investigation to assure that welds which in 1976 were the responsibility of a certain Quality Control inspector had been reinspected or otherwise dispositioned.
The affidavit reflected the fact that the Company had discovered, contrary to its previous belief, that not all such welds had been This affidavit provides a progress report on the identified.
ongoing investigation and discusses the findings to date.
=
i i
I 2
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3.
The Board's special Prehearing Conference Order, LBP-82.-43A, 15 NRC 1423, 1520-21 (June 1, 1982), provided for informal discovery.
Pursuant to that Order, on September 3, 1982 the Air and Water Pollution Patrol (AWPP) requested certain documents relating to NRC Inspection Report 76-06.
This request l
j was designated " Discovery 2 * (Enclosure 2)."
As it relates to this matter, the following documents were requested:
1,
"(7) Provide record of all welds accepted i
by inspector who accepted welds at ele-l vation 253, columns 23G and H, and provide j
record showing percentage of welds inspected i
by inspector in (4) above that were rein-spected."
l j
4.
By letter dated January 11, 1983, the documents which I
had been identified as responsiv'e to this request were made available to AWPP.
These documents were later provided to the i
Board by counsel for the company on May 20, 1983 pursuant to its 4
Order Regarding Quality Assurance Documents (May 13, 1983).
In order to understand the status of the Company's continuing investigation, it is necessary to discuss certain of the docu-ments provided to AWPP and the Board.
The same designation of attachments is used as was utilized in the May 20, 1983 letter.
5.
A letter from V. S. Boyer to J. P. O'Reilly dated December 15, 1976, designated Attachment 2 stated that, with respect to the structural welds which were cited in NRC Inspec-tion Report 76-06 the corrective action therein was as follows:
d
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"1.
The following corrective measures have been l
taken:
1 l
a.
The fillet welds on structural steel l
beam connections at elevation 253, columns 23-G and H, have been repaired.
l 4
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3 1
l b.
The inspector, who originally l
accepted these two welds, is no longer employed by the con-tractor and a reinspection of all other work performed by him 4
has been accomplished, where accessible.
Of approximately 350 welds reinspected, two de-ficiencies were noted and cor-i rective action has been taken."
6.
The above-quoted statement was based upon a Bechtel response included as part of Attachment 4, Philadelphia Elec-tric Company Quality Assurance Finding Report No. N-093 dated October 27, 1976.
That response at Sheet 2 of 3 states that i
the following corrective action was taken to resolve the finding:
"A reinspection of all other work performed by the particular inspector who accepted the welds in question was accomplished wherever accessible."
That same page carries the handwritten notation that Bechtel j
j Field Inspection Reports C-63-7 through C-63-19 (identified collectively as Attachment 6) provide the basis for the above quoted statement.
Additional welds which were the responsibility of the 7.
See Bechtel 3.'
subject inspector were identified in early 1977.
.(>
Field Inspection Reports Nos. C-63-20 and C-63-21, collectively i
identified as Attachment 7.
On. April 5, 1977, Bechtel Field Inspection Report 8.
C-63-22 was initiated in order to redetermine the accessibility for inspection of the installed structural steel beams and columns previously identified in Attachments 6 and 7 to allow further reinspection and assure that all accessible welds were inspected.
This Field Inspection Report is identified as Attachment 8.
4
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- 9. contains additional Bechtel Field In-4 spection Reports which were initiated to document further j
inspections which resulted from the preparation of Bechtel Field Inspection Report C-63-22 (Attachment 8).
j 10.
Page 8 of 8 of Bechtel Field Inspection Report C-63-22 is a reconciliation of all Wald Inspection Plans that had been f
identified as the responsibility of the subject inspector against the Bechtel Field Inspection reports which indicated that such welds had been reinspected.
It was thus concluded by Company personnel on the basis of the Bechtel reports that all welds j
l which had been the responsibility of the subject inspector had (NCR-
- s been reinspected,or analyzed, and a non-conformance report 3
s
_ ~
dispositione inaccessible 2710 referenced in Attachment 9
-/ s ev or deficient welds.
11.
In preparing its response to the Licensing Board's Second Special Prehearing Conference Order, LBP-83-39, July 26, 1983, and to review independently the validity of the information contained in reports previously submitted to the Board and AWPP, the Company conducted a review of the original quality assurance welding records prepared during the term of employment of subject inspector at the facility.
This review took approximately four weeks and 2500 manhours.
As a result of this extensive review, it was determined 12.
that the subject inspector had responsibility for a total of 709 safety related welds at the facility, of which 462 were
~. _
structural welds and 47 were on components other than structural
S steel, such as hangers (43), pipes (2), and electrical condui supports (2).
It was also determined that the review program which was initiated as a result of NRC Inspection Report 76-06 and completed by the end of July, 1977, resulted in 403 accessible welds having been rain-
~.
spected with four minor deficiencies noted.
Thirty-one welds remained inaccessible but were dispositioned. _
13.
The remaining 228 structural welds include 16 which are totally accessible and 212 which are partially or totally inaccessible.
The 16 totally accessible welds have now been reinspected with one minor deficiency found.
An engineering
~
analysis is continuing to disposition the 212 partially or totally inaccessible welds and the one deficient accessible weld.
This analysis is expected to be completed in approxi-mately one month.
The 47 non-structural welds are all totally accessible and have now been reinspected with 19 minor de-ficiencies found, all of which are hanger welds.
Although these hanger weld deficiencies would be dispositioned normally l
as part of the final hanger completion and inspection program, i
they will instead be specially dispositioned within one month.
The company's review of this matter is continuing.
14.
The program includes a further physical reinspection of a reoresentative numbec. of the welds for which the subject h *.sb b
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There are initial imitent s,
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inspector was responsible.
not pet confirmed, that some additional deficiencies may" Y
be present.
' Vincent S. Boyer
(/
Sworn to me this date ofw A:2 c.
/', 1983 tI
- n.c.b AY - rz er l
Notary Pub).2tf ; (
f' Notary Putdic.Philaselphie.Pini.ew,ma c.,
eg,mg.g.,"/ [f, /f My Caesdssion Espires J
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i AIR and WATER W
Pollution Patrol BROAD AXE, PA.
DIRECTORY Re First Set of AWPP Interrogatories p-l New Things F
p-2 Questions not answered 2
P-3
' Contradictions dL f fM p-if - d<p ~ ~~
- M% < / og / /hp wg 3
p-5 New Facts of Evidence p-6 p-7 Central Ideas i
p-8 l
p-9 Evasion of Interrogatories and misinformationh/ J,3J, fo1 4 i z-M#em l
l
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AIR and WATER Pollution Patrol BROAD AXE, PA.
(1)
Re 1st Set of Awpp Interrogatories New Things (a)
All IE reports since contention was admitted (b)
Material obtained during Discovery--like NRC #1980 with all its detail--add dates, different elevations (c)
Pattern of predetermined response to infraction in the form of "use as is", and Rational--the weld is O.K.
because it won't have to carry over 230 lbs NRC 1366 (give full non-conforming condition wordage)
Even a strong human being can support that weight!
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AIR and WATER Pollution Patrol BROAD AXE, PA i
(2)
T Questions Not Answered i
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AIR and WATER Pollution Patrol BROAD AXE, PA.
(3)
Contradictions (a)
(b)
Re 353-76-01 Amswer to 1st set (6) was that G.P. Auclair was a qualified welder.
Did Applicant mean G.A. Auclair was qualified to be welding the 76-06-01 welds in controversary?
Do you mean G.
P. Auclair was qualified by qualification test for the six different weld configurations to be welded at the limitied access jounts?
(c) 1st Set (8)
Applicant's Boyer and Corcoran re welding extension and understending 76-06-01 say "any such equipment needed for use at Limerick would be procured from a vendor of such equipment" - well it was needed...why wasn't it available to the welders in the " broomstick affair". (also see p-9 in d)
(d) m.-
24n@'
AIR and WATER Pollution Patrol BROAD AXE, PA.
(5)
New Facts Or New Things (a)
See First page at (a)
(b) ( d) l
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I ief UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board t
i f.Y 0
In the Matter of Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S SECOND INTERIM REPORT TO LICENSING BOARD RELATING TO CONTENTION VI-l Applicant is hereby forwarding to the Licensing Board and parties the attached Affidavit of Vincent S.
- Boyer, Senior Vice President, Nuclear Power, Philadelphia Electric company dated September 29, 1983.
This report updates Mr.
Boyer's affidavit dated September 16, 1983 which was transmitted to the Board and parties by Applicant's Interim Report to the Licensing Board Relating to Contention VI-l of the same date.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Mark J. Wetterhahn Counsel for Philadelphia Electric Company October 4, 1983 I
/j
2 structural steel, such as hangers (577), pipes (2), and electrical conduit supports (2).
'13 '
It was also determined that the review program which was initiated as a result of NRC Inspection Report 76-06 and completed by the end of July, 1977 had identified 426 structural welds, 423 being accessible and 3 inaccessible.
The 423 accessible welds were reinspected with 6 minor defi-Four of these were reworked, and 2 were found ciencias noted.
The 3 inaccessible welds acceptable by engineering analysis.
k were found by engineering analysis to be acceptable.
4 1983 review identified 228 additional The extensive August, i
structural welds, 16 being totally accessible and 212 partially A*
The 16 totally accessible welds have
- (
v or totally inaccessible.
I This now been reinspected with one minor deficiency found.
k 4
weld, together with the 212 partially or totally inaccessible welds, have been found bv_ engineering an g to be acceptable.
The non-structural welds, totalling 581, are all totally Of these, 577 represent hanger welds with 534 of l
accessible.
l the 577 being welds of hangers which were completely reinspected I
l prior to August,.1983 as part of a separate hanger inspection The remaining 43 hanger welds for which final in-program.
spections had not yet been made, together with the 4 non-hanger.
These hangers contained 19 welds, have now been reinspected.
minor deficiencies which would have normally been dispositioned as part of the final hanger completion and inspection program.
They, instead, will be specially dispositioned within one week.
3 t
t 3.
The number of structural welds previously reported was reduced from 662 to 654 due to the elimination of 8 welds which, in 1976, were classified as safety-related welds but due to their location and function, were subsequently reclassified as non-safety related welds.
4.
In the interest of reporting all possible safety-related welds which could be considered to be the responsibility of the subject inspector, a number of welds which were initially examined by him, but which were subsequently reinspected for programmatic reasons beginning in late 1980, are being included.
This explains the increase, noted above, in the number of safety-related non-4 structural welds from 47 to 581.
In December, 1980 a general hanger reinspection program was initiated due to job conditions which re-sulted in additional hanger work being required after partial in-spections had been performed.
This reinspection program required I
a final QC inspection of all welds of all safety-related hangers regardless of their previous inspection status.
The subject in-spector had made inspections of 534 welds on partially completed hangers which had subsequently been subject to modification and i
completely reinspected prior to August, 1983.
A current reinspection by Philadelphia Electric Company of 60 of these 534 completed hanger welds was performed with one minor deficiency being detected which I
has been found by engineering analysis to be acceptable.
The reported numbers relating to the review program of 5.
safety-related structural welds completed by the and of July,1977 are changed due to the initial inclusion of non-safety grade welds in the inaccessible count and a corresponding error in the breakdown
4 of the number of accessible and inaccessible welds.
The corrected count is th,at by the and of July, 1977, 423 accessible welds were reinspected (corrected from 403) and 3 inaccessible welds (corrected 1
from 31) were identified and dispositioned satisfactorily where re-quired.
6.
The Company's physical reinspection program, as reported in paragraph 14 of the September 16, 1983 affidavit, involved further Fifteen physical reinspection of 67 safety-related structural welds.
of these were from the 1983 reinspection group of 16 accessible welds discussed in paragraph 13 of the September 16, 1983 affidavit and 52 were from the 1976/77 reinspection group of 423 accessible welds.
Six deficiencies were identified from the latter group, and these have been found by engineering analysis to be acceptable.
ypa M)&
vincent S. Boyer
(/
Sworn to me this 2
date of NAE 1983 M_
dek Notary Public PATRICIA D. SCHOL.C smay
- P***
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L
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
Docket Nos. 50-352 Philadelphia Electric Company 50-353
)
)
(Limerick Generating Station,
)
Units 1 and 2)
AFFIDAVIT OF VINCENT 5. BOYER SENIOR VICE PRESIDENT, NUCLEAR POWER PHILADELPHIA ELECTRIC COMPANY Vincent S. Boyer being first duly sworn according to law deposes and states:
I executed an affidavit which was I
1.
On September 16, 1983, submitted to the Atomic Safety and Licensing Board dealing with the i
Company's review of welds which in 1976 were the responsibility of That affidavit indicated that a certain Quality Control inspector.
I The purpose of this affidavit is to up-l the review was continuing.
date and correct information previously reported.
To reflect the current status of the review, paragraphs 12 2.
and 13 of the September 16, 1983 affidavit would be modif ei d as set forth below with the reasons for these changes being discussed here-f with and in subsequent paragraphs.
it was determined As a result of this extensive review, 12' l
l of that the subject inspector had responsibility for a tota 1235 safety-related weld inspections at the facility, of which 654 were structural welds and 581 were on components other than
AIR and WATER Pollution Patrol BROAD AXE, PA.
Central Ideas l
l
@;jsh AIR-and WATER W
Pollution Patrol h*
BROAD AXE, PA.
Directory - - page 9 subject Evasion Of Interrogatories and Misinformation in Answers To First Set Of Interrogatories (a)
Ist set (6)
Applicant-evades other welders who used unqualified extensions - by referring only to G.P. Auclair. But according to line 2,3, 2nd par. under 76-06-01, it is stated:"nor had the welder been qualified using such extensions.(broomstick)
(b)
Applicant evades the gist of the question which is that there possibly were other " broomstick" incidents by other welders.
Where and who?
(c)
Ist set (7)
Applicant says 76-06-01 involved two bean connections as area 13 at El, 253.
However, 76-06-01 under " Failure to weld S'tructural Steel as per AWS Code states broom-stick affair involved welds at El, 283 - and El 253.
That involves more than two welds (d) 1st set (9)
Applicant's Boyer, Corcoran, Clohecy - evaded the Interrog-atory re Applicant's disagreement over inspectors request for
" visual inspection of the limited access welds performed at elevation 253 on steel beam piece numbers 232B7.
They evade it by saying, they, quote: " disagree with AWPP's character-ization of theInspection Report identified in this Inter-rogatory". (76-06-01)
C AIR and WATER Pollution Patrol PROAD AIE, PA.
(9a)
(d) continued:
But under 76-06-01: Failure to Weld Structural Steel as per AWS Code: The inspector considered that an electrode holder attacehd to a stick did not meet this requirement unless proven satisfactory by qualification tests for the six different werd configuarations to be welded at the limited access joints.
Further, re Interrogatory #9, Applicant said what J.M.
Corcoran disagreed about was the need for certain quali-fication tests (what tests) Part 3.1.2 requires proper in order to insure results prescribed in AWS Code.
equipment While the Applicant stated AWPP mischaracterized the dis-agreement, the NRC inspector concluded:The welds were found to not comply with the requirements of AWS-D-1-1 Section 3 " Workmanship," in that the welds were of Un-and acceptable profile, contained wxcessive undercut, were incomplete at the upper and lower edge of the angle clip (root pass complete, only).
For the weld joints des-ignated #3 in the record drawing of the in-process check-list, all inspection items had been checked-off by the Bechtel quality control inspector, incluidng ;rinal Quality verification."
The QC inspection apparently did not com-ply with the requirements of AWS-D-1-1 Section 6 " Inspection."
On Friday, March 2, 1984 Applicant's Mr. Wetterhahn on a
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Letter from R. T. Carlson to V. S. Boyer, dated 11/10/76, transmitting NRC IE Inspection Report No. 50-353/76-06 e
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Pollution Patrol BROAD AXE, PA.
T (9b) telecon including Staff's Ann Hodgdon suddenly on opening the conversation stated that V.C.Ferretti (of the 76-06-01 broomstick affail) quote:"Was not fired"--as if making a confession to evasive wording of Applicant's answers to AWPP's 12th set, interrogatory 7k o'f Jan 14, 1984 The evasion is evident in its answer to Interrogatory No. 11 of AWPP's First set of Interrogatories dated Nov. 11, 1983, as to the name of the inspector involved in the 76-06-01 falsification of welding records, and specifically,"was inspector (who falsified welding' records in the 76-06-01 affair) separated from employment from Bechtel and/or Applicant in 1976?
Applicant answered that the inspector was V.C. Ferretti, who was employed by Bechtel Power Corp.
until his separation in 1976.
Now Applicant's counsel, aur months later, blurts out "Ferretti was not fired"-thus throwing me off Mr. Ferretti's trail, including the certainty of deposing him.
This is another reason for extending discovery.
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'SEMP AIR and WATER Pollution Patrol BROAD AIE, PA.
l EVASION OF INTERROAGATORIES AND MISINFORMATION IN ANSWERS TO TENTH SET OF INTERROGATORIES (a)
Applicant on page 4 of Discovery 25 dated Feb. 1, 1984 evades Interrogatory 2a of AWPP's 10th Interrogatory--
Applicant deos not state the procedure that came up with 709 number of welds.
(b)
Applicant on page 5 evades question 2b.Why so unsure?
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AIR and WATER MW Pollution Patrol BROAD AXE, PA.
EVASION OF INTERROGATORIES AND MISINFORMATION IN ANSWERS TO THIRD SET OF INTERROGATORIES (a)
In Answer to interrogaotry No. 3 of AWPP's 3rd Set of Interrogatories dated Nov. 23, 1983 which asks "Indi-cate name of welders who more than one time, were invol-ved in reported deficient welds, and who never the less were not discharged or separated from work at Limerick" Applicant states at p.6 of Discovery 17, of 12/19/83 that "Therefore, not all welders who performed deficient welds, identified by the NRC as welding infractions, have been identified".
And on the same page Applicant states welders involved with unacceptable welding performance or non-adherence to specified welding procedures are retrained they are not necessarily discharged.
AIR and WATER
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W Pollution Patrol BROAD AXE, PA.
EVASION OF INTERROGATORIES AND MISINFORMATION IN ANSWERS TO TWELTH SET OF INTERROGATORIES (a)The 16 accessible welds refered to in par 13 of Oct. 4,1983 Affidavit were previously O.K'd...but now one deficiency is found on re-inspection.
If one out of 16 is characteristic (or even one out of 32 on re-inspection is found to have a deficiency, that 's 3%.
3%
of the thousands of welds would be unacceptable, that's why 76-06-01 is a warning that there are other more serious welding deficiencies.
(b) As per paragraph 6 page 4 of Boyer's Sept. 29, 1983 Affidavit there were 423 welds, but Applicant's answer to 79 of 12th Interrogatory is stated as 439.
(c) As to 7h of AWPP 12th Interrogatory Applicant does not andw-er... Applicant mearly says PECO just decided what to check with no concern to meet statistical procedures re validity of results.
(d) 9 i
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AIR and WATER W
Pollution Patrol BROAD AXE, PA.
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Ccnfusion on Number of Welds, and Imployment Status of Inspector Involved In 76-06-01 Broomstick Affair (a)
The Dec. 15, 1976-Vincent Boyer letter to Mr. James O' Reilley stating "the inspector involved (in 76-06-01) is no longer employed by the Contractor". Further, Mr.
Boyer informed that in the re-inspection of the welds inspected by the inspector no longer employed, approx-imately 350 welds were re-inspected.
(b)
The Sept. 16, 1983 Affidavit of Vincent S. Boyer sub-mitted to the Atomic Safety & Licensing Board, at 11 &
12, referred to " original quality assurance welding records prepared during the term of employment of sub-ject inspector (76-06-01) at the facility (Limerick), and after extensive review it was determined the subject in-spector had responsibility for a total of 709 saftey related welds.
Two weeks later, on September 29, 1983, Vincent S. Boyer submitted another affidavit to the Atomic Safety and Licensing Board stating at 12' under 2:
"As a result of this extensive review it was determined that the subject inspector (re 76-06-01 and ostensibly fired) had responsioility for a total of 1235 safety-related weld inspections at the f acility... " (Parenthesis by AWPP).
The above confusion is an example of breakdown in Quality Assurance that makes it apparently possible to exist more times than is brought to the surface.
AIR and WATER d
u, MW Pollution Patrol BROAD AXE, PA.
1
- T Confusion on Employment Status of Inspector Involved In 76-06-01 Broomstick Affair (a)
The Dec. 15, 1976--Vincent Boyer letter to Mr. James O'Reilley stated "the Inspector involved (in 76-06-01) is no longer employed by the Contractor".
(b)
In Applicant's Dec. 5, 1983 Answer to AWPP's First Set of Interrogatories at no. 11, Applicant again states the in-spector involved in the 76-06-01 broomstick affair "was em-ployed by Bechtel Power Corporation until his separation in 1976".
(c)
Finally on March 2, 1984 Applicant's Mr. Wetterhahn on a telecon with Staff's Ann Hogdon suddenly on opening the conversation stated that " inspector involved in the 76 01 " broomstick affair" was not fired, as if making a con-fession.
Certainly if the broomstick affair inspector was "not fired" after his responsibility in the infraction described in 76-06-01, the Applicant, the Contractor and the NRC were blatantly negligent.
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