ML20012A305

Requests Info Re What Blueprints,Plans,Diagrams & Catalogs Available to cross-ref Various Welds & Weld Locations at Unit 1 & Why Both Surface & Volumetric Weld Insps Required

ML20012A305
Person / Time
Site:	Seabrook
Issue date:	02/26/1990
From:	Liederman S AFFILIATION NOT ASSIGNED
To:	Nerses V Office of Nuclear Reactor Regulation
References
NUDOCS 9003090210
Download: ML20012A305 (4)

Text

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4 a' 'STUART M. LEIDERMAN 2.Sunsurf Avenue Hampton Beach, NH 03842 (603)926-5820 February 26, 1990 Victor Norses, Project Manager ,

Project Directorate I-3 Division of Reactor Prcjects I/II Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION Washington, D.C. 20555 Ret Docket No. 50b443,

Dear Mr. Nerses:

I have just read your February 15, 1990 package to Mr. Edward A.

Brown, President and Chief Executive Officer, Public Service Company of New Hampshire, concerning Seabrook Station's Unit 1

-First 10-year Inspection Program Plan.

Although I expect to send you a more detailed letter containing.

my comments on this plan, I have some questions.and requests for information that I hope you can provide at the moment:

1) What blueprints, plans, diagrams, catalogs, etc. are available to cross-reference the various welds described by code number in the package, with their actual location in ceabrook Station Unit l? Would you provide me with that/those documents (s) ?

Does each code, for example RC-RPV-103-121 in the Reactor

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Pressure Vessel, designate a) a single weld or a group of welds; b) an actual weld or a presumed weld in that/those location (s) ;

or c) an area of actual or presumed welds; or is it' a combination of these possibilities?

3) Why are both surface and volumetric weld inspections required?

What is the relative importance and information -value of each kind of inspection? What are their principal distinct or overlapping objectives, with regard to plant and component integrity, safety, etc.?

4) Wh6t is the expressed or implied reason why the American Society of Mechanical Engineers Code for the inspection of nuclear power plant components requires that 100% of the plant's welds be inspected? Would you supply me with the documentation for this?

5) From my reading of the package, PSNH has requested the NRC's permission to not inspect 100% of the welds in Seabrook Station's reactor pressure vessel, pressurizer, steam generator, ' Class I piping and Class 2 residual heat removal piping. In many cases, PSNH has requested NRC's " relief" to inspect less than 50% of the welds in these components and areas. Would you provide me with the~ history of 10CFR50-55a(g) (6) (1) that allows a nuclear power plant licensee (in this case, PSNH) to request relief from inspecting: welds if the licensee determines that it is " impractical for his facility", as stated in this package? Further, what is the

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Victor Norses February 26, 1990 page two percentage of nuclear power plant licensees in the U.S. that have exercised this provision? What tests , critoria, deliberations ,

hearings or other means are applied to these requests to insure that they "will not endanger life or property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that would result if the requirements were imposed", as stated in this package to PS NH? I would like to know who determined this provision, who applies it, what parties are normally involved, and what public participation and appeal procedure is there?

6) I understand that this 10-year inservice inspection program  !

is an important requirement to determine ntructural and plant integrity changes that take place over time, under various load conditions, whether the plant is operational or not. Given the provision of " relief" from inspection of welds, does this mean there is a possibility that some percentage of welds will never j

3. be inspected, purely on the grounds of impracticality to the i licensee, during the 10-year period post-construction, or beyond? l Is this taken into account, contemplated or expected by the ASMF Code that nonetheless requires 100% inspection? If yes, where is this expressed or implied? If no, how does ASME and the NRC identify and rank the inspection criticality (my term) of welds in a nuclear power plant to insure that none of the most critical

-ones are exempted because the licensee claims that a certain i percentage of them are impractical to inspect? Where is that ranking for welds in Seabrook Station?

7) I understand that most of the reasons PSNH cites welds are impractical to inspect has to do with design and construction. . .

a process that is coordinated by NRC, PSNH and the various contractors, viz., welds that are claimed to be obstructed or inaccessible in some way. Please tell me who is accountable for ,

constructina a nuclear power plant in such a way that the ASMF Code cannot be fulfilled, ret this important inspection milestone?

• On the New Hampshire seacoast, as well as in communities throughout '

the U.S. , homeowner's commonly f ace the ire of building inspectors when wiring, pipes, etc. are unable to be inspected because they ,

have been covered over with sheetrock or obstructed in other ways.

For the inspector to do his/her job properly, the walls.are usually required to be removed, without entertaining " requests for relief from inspection". Further, inspectors could not approve original  ;

designs and blueprints that would prevent inspections being done '

later down the line. What is unusual about the Seabrook Unit 1 design that precludes 100% weld inspection: during this 10-year j inservice inspection? Are any other inspections or performance '

tests precluded by its design? Why did the NRC permit such a design?  !

Finally, I would like to cross-reference welds for which  ;

8)

PSNH has requested relief from inspecting with those cited in the June 4 th , 19 8 5 U. F . District Court, New Hampshire, Grand Jury indictment of James Vincent Padavano, weld inspector at Seabrook  ;

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Victor Nerses February 26, 1990 page three I

' Station. There were 11 counts-to'this indictment:

Date of Count Field Weld Number Number Report  ;

l' FW 4600-1406 '

3-15-83 t 2 FW 4600-1407 3-2-83  :

3 FW 4601-1102 3-3 4 FW 4601-1103 3-3-83 5- FW 4 601-1106 3-3-83  ;

6 SW 1803-0202 T-17-83  ;

U 7 SW 1803-0203 3-3-83.

f- 8 RC 801-0101 7-30-82 9 CS 465-0101 10-23-82 10 NG 1656-0106 2-28-83 11 DG 4419-0307 1-17-83 Mr. Padavano entered a Plea Agreement of guilty to the first two counts. . .concerning falsifying inspection reports. My

. interest-is not with Mr. Padavano per se, but in the thorough- ,

ness of NRC's ':, coordination of information and safety matters during the entire lifetime of a nuclear power plant. . .from design to construction to operation to decommissioning. Therefore, I would like to know if the agency or its delegate has Ltaken this ,

s particularsmatter into consideration in granting requests for ,

relief from inspection, and further, what other welds in the plant have come under questioning scrutiny of any kind that should reasonably preclude them from being exempt from inspection at j

this time ?

Your helpful responses to my questions under-these eight categories would enable me to complete my comments to the referenced package concerning Seabrook Unit l's 10-year inservice inspection program .

plan. ,

Thank yo ,

Stuart M. Leiderman Y

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