ML20077J092: Difference between revisions

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{{#Wiki_filter:AIR and WATER                                   5p Pollution Patrol                                             -
{{#Wiki_filter:AIR and WATER 5p Pollution Patrol BROAD AXE, PA.
BROAD AXE, PA.
Hay 25,198383 AUS 11 P2:25 Atomic Safety and Licensing Board U.S''. Nuclear Regulatory Commission Lawrence Brenner, Chairman
* Hay 25,198383 AUS 11 P2:25 Atomic Safety and Licensing Board U.S''.
-} hp,;
Nuclear Regulatory Commission Lawrence Brenner, Chairman                                                           -} hp,;
Vashington, D.C.20555 SRANCH In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Vashington, D.C.20555                                                           SRANCH In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 Lawrence Brenner, Chairren; Dr. Richard F. Cole; and Dr. Peter A. Morris Gentlemen:
Docket Nos. 50-352 and 50-353 Lawrence Brenner, Chairren; Dr. Richard F. Cole; and Dr. Peter A. Morris Gentlemen:
This letter is being submitted in response to letter of May 20, 1983 from Mark J.
This letter is being submitted in response to letter of May Mark J. Wetterhahn, Counsel for the Applicant re:IE Report No.50-353/76-06 20, 1983 from want to state at the start that I
want    to Wetterhahn, state at    Counsel for the Applicant re:IE Report No.50-353/76-06 the start that                                                 . I do not at all, quoting Mr. Wetterhahn's letter:the documents submitted to me by Mr. Wetterhahn velds,                                                " demonstrate that all suspect rather than those which were merely accessible, were re-inspected."
do not at all, quoting Mr. Wetterhahn's letter:the documents submitted to me by Mr. Wetterhahn
The third paragraph of Mr. Wetterhah..'s May 20 letter referring to Finding report No N-093, inter alia, and NCR report 1980 has to do with the velds which were found deficient by the NRC inspector after they were certified acceptable by the inspector of the Applicant and Rechtel's inspector. Nouhere does the report made accessible and, thirdly, re-inspected completely, as inferre                             ,
" demonstrate that all suspect velds, rather than those which were merely accessible, were re-inspected."
In Mr. Wetterhahn's fourth paragraph he discusses Finding Report N-093 which he writes, quote:" requires a re-inspection of all other accessible velds inspec             -
The third paragraph of Mr. Wetterhah..'s May 20 letter referring to Finding report No N-093, inter alia, and NCR report 1980 has to do with the velds which were found deficient by the NRC inspector after they were certified acceptable by the inspector of the Applicant and Rechtel's inspector.
ted by port No.the   inspector who accepted the deficient velds referred to in NRC I&Ee-50-353/76-06'.'                                                                   R it does not solve the question of inaccessible welds (emphasis by Roma             .
Nouhere does the report made accessible and, thirdly, re-inspected completely, as inferre In Mr. Wetterhahn's fourth paragraph he discusses Finding Report N-093 which he writes, quote:" requires a re-inspection of all other accessible velds inspec ted by the inspector who accepted the deficient velds referred to in NRC I&E R port No. 50-353/76-06'.'
control Nos. C-63-20 and C-63-21 dated                     Jan.Mr. Wetterhahn's fifth paragraph 17, 1977 (attachment 7).
it does not solve the question of inaccessible welds (emphasis by Roma e-control Nos. C-63-20 and C-63-21 dated Jan.Mr. Wetterhahn's fifth paragrap 17, 1977 (attachment 7).
Appendix A, Notice of Violation under A,                                         Whereas per Report No,50-353-76/06, it is stated the
Whereas per Appendix A, Notice of Violation under A, Report No,50-353-76/06, it is stated the deficient welds were at elevation 253, celumns 23G and H, Inspection report C 63 20 and C-63-21 above refer en " control room, reactor building Unit'2, elevation 257 tn 264"respectively. elevation 269 and 289, Area 8 headed " Failure to weld structural Steel per AUS Code" mentions elevation 283 Ar a Further, 76-06-01 13 and clevation 253, colums F and H at wall 23 c
deficient welds were at elevation 253, celumns 23G and H, Inspection report C 63 20 and C-63-21 above refer en " control room,                                                   -
Because of confusion, Applicant must supply the name of the Rechtel and Applicant's inspectors, ber of welds and locations can he proven accessible or inaccessible together with in-Applicant For the icity, and t!.cn refer to uelds which were, nuote:"possiblyto provide statnents j
reactor building Unit'2, elevation 257 tn 264"respectively.Further,  elevation     269 and 289, Area 8 76-06-01 headed       " Failure to weld structural Steel per AUS Code" mentions elevation 13 and clevation 253, colums F and H at wall 23                                           . c 283 Ar a Because of confusion, Applicant must supply the name of the Rechtel and Applicant's inspectors, together with in-
i ticular Bechtel nuality Control Inspector involved" indicates uncertaintinspected by the par-nullifying specificity.
* ber of welds and locations can he proven accessible Applicant                                                                              or inaccessible For the                       j icity, and t!.cn refer to uelds which were, nuote:"possiblyto provide statnents                                 i ticular Bechtel nullifying          nuality Control Inspector involved" indicates uncertaintinspected specificity.                                                        y totally by the par-(emphasis by Ronano).
(emphasis by Ronano).
record that the names of the inspectors in the " broomstick" incidentIt is important also for the
y totally the names of the inspectors in the " broomstick" incidentIt is important also for the record that
: 06) with work records at the time of the incident, to the present. These        (50-353/76-made available to me.                                                               were not Further, as it relates to the sixth paragraph, reference to Bechtel Field In-snection Report Control *lo.C-61-22 dated April 4, 1477 (Applicant means April 5, 8300120242 G30005                                                                                1977?)
: 06) with work records at the time of the incident, (50-353/76-to the present. These were not made available to me.
PDR O    ADOCK     05000352 PDR
Further, as it relates to the sixth paragraph, reference to Bechtel Field In-snection Report Control *lo.C-61-22 dated April 4, 8300120242 G30005 1477 (Applicant means April 5, 1977?)
PDR ADOCK 05000352 O
PDR


AIR and WATER Pollution Patrol BROAD AXE:, PA.     May 25, 1983 (2) the report, at 6, indicated quo : " Type of Inspectior.. . . Visual". Certainly a visual inspection cannot inspec concrete. imbedded or otherwise non-visible welds.
AIR and WATER Pollution Patrol BROAD AXE:, PA.
Further, the inspection was, quote:"of installed structural steel, beams, and col-umns to determine its accessibility for inspection." Nowhere is 7 shown that report C-63-22 reports on accessible or inaccessible welds caused y scaffolding or otherwise. I ask applicant to supply date that scaffording was removed in that specific area. Since inspection of 4/5/77 is six months after the " broom--
May 25, 1983 (2) the report, at 6, indicated quo : " Type of Inspectior.... Visual". Certainly a visual inspection cannot inspec concrete. imbedded or otherwise non-visible welds.
stick" defici nt welds incident, it seems, because of the s cident, that3 nspection of welds by the inspectors involvedy iousness of the in-should have been made immediatedly after the incident.
Further, the inspection was, quote:"of installed structural steel, beams, and col-umns to determine its accessibility for inspection." Nowhere is shown that 7
Paragraph seven of ?fr. Wetterhahn's letter again refers to Report C-63-22 together with related items in the suenary of Page 8 of 8, mention is made of, cuote: " the particular Ouality Control Inspector..." In actuality, however, there were two inspectors who were involved in falsely 0.K.ing deficient velds in the 50-353/76-06 incident. It ie #for the Applicant also to explain why the serious question of repeated failure to perform velding as per specified At!S code on Oct.
report C-63-22 reports on accessible or inaccessible welds caused y scaffolding or otherwise.
16, 19-22, 1976             s allowed to remain unre-inspected as to accessibility until       .
I ask applicant to supply date that scaffording was removed in that specific area. Since inspection of 4/5/77 is six months after the " broom--
July 1977. g g f y -fS Rf pich g.,cpgf?s.es uen obw snest .d e .wKi'                         t ' 'S
stick" defici nt welds incident, it seems, because of the s 3 nspection of welds by the inspectors involvedy iousness of the in-cident, that should have been made immediatedly after the incident.
                              / WJ$4c$7W /gpW)Y c19xcheA- #
Paragraph seven of ?fr. Wetterhahn's letter again refers to Report C-63-22 together with related items in the suenary of Page 8 of 8, mention is made of,
As it relates to eighth paragraph, Field Inspection Reports Nos. C-63-30,31, 32, and C-41A-493, do not provide proof of inspection of inaccessible welds. In fact those reports prove inaccessible welds,as stated, cannot receive a full in-spection because of being inhedded in concrete. Neverthe-less the Applicant states NC3-2710 explains how, in spite of being inhedded in concrete, the welds are declared acceptabic...but does not providd the manner by which the unsubstan-tiated conclusion that welds were acceptable on the basis that , quote:" ..."the embedded portion of the weld was non-existent..." It seens the inaccessbile welds were declared, capriciously and unilaterally , acceptable on the convient and unscientific declaration that welds that cannot be re-inspected because they cannot be made accessible are, therefore, acceptable. Public safety d :mands Philadelphia Electric to categorically prove its statement (2nd Paragraph of !!r. Wetterhahn's
" the particular Ouality Control Inspector..." In actuality, however, there cuote:
  ?tay 20 1cteer), nuote: "...that all suspect welds, rather than those which were merely accessible, vere reinspected."               P.E. must also prove that all u ids, acc-essible and unaccessible were not just inspected but were acceptablJe Sincerely, ANPP Frank R. Ronano, Chairman First class mail service to: Richard F. Cole, Peter 'forris, Atomic Sefety & Licensing Appeal Panel; Rocketing and Service Section; Ann P. Ilodgdon, Elaine I. Chan; Atomic Safety & T.icensing Board Panel, Phila. Electric, Ent> C. Rauer; Roht. L. Anthony; !!srvin f.ewis; Judith Dorsey; Charles EJliott; Alan J. :Togec; Thomas Y. Au; Thomas l'hite III; Judith Johnsrud; Roht. Sugarman; James N. Neill; Director PEftA; Trob n. Conner,Jr.;
were two inspectors who were involved in falsely 0.K.ing deficient velds in the 50-353/76-06 incident.
  *! ark J.lletterhahn.
It ie #for the Applicant also to explain why the serious question of repeated failure to perform velding as per specified At!S code on Oct.
su) $ ?se so w ( 4/. '- ,.             u /cy';
16, 19-22, 1976 s allowed to remain unre-inspected as to accessibility until July 1977. g g f y -fS Rf pich g.,cpgf?s.es uen obw snest.d e.wKi' ' 'S t
w +. u                         -
/ WJ$4c$7W /gpW)Y c19xcheA- #
[ y ' g / g. (s, r, 'p*   2hhr * * '' h **
As it relates to eighth paragraph, Field Inspection Reports Nos. C-63-30,31, 32, and C-41A-493, do not provide proof of inspection of inaccessible welds.
                %1cf 'CY bY N                       .}}
In fact those reports prove inaccessible welds,as stated, cannot receive a full in-spection because of being inhedded in concrete. Neverthe-less the Applicant states NC3-2710 explains how, in spite of being inhedded in concrete, the welds are declared acceptabic...but does not providd the manner by which the unsubstan-tiated conclusion that welds were acceptable on the basis that, quote:"..."the embedded portion of the weld was non-existent..." It seens the inaccessbile welds were declared, capriciously and unilaterally, acceptable on the convient and unscientific declaration that welds that cannot be re-inspected because they cannot be made accessible are, therefore, acceptable. Public safety d :mands Philadelphia Electric to categorically prove its statement (2nd Paragraph of !!r. Wetterhahn's
?tay 20 1cteer), nuote: "...that all suspect welds, rather than those which were merely accessible, vere reinspected."
P.E. must also prove that all u ids, acc-J essible and unaccessible were not just inspected but were acceptabl e Sincerely, ANPP Frank R. Ronano, Chairman First class mail service to:
Richard F. Cole, Peter 'forris, Atomic Sefety & Licensing Appeal Panel; Rocketing and Service Section; Ann P. Ilodgdon, Elaine I. Chan; Atomic Safety & T.icensing Board Panel, Phila. Electric, Ent> C.
Rauer; Roht. L. Anthony; !!srvin f.ewis; Judith Dorsey; Charles EJliott; Alan J. :Togec; Thomas Y. Au; Thomas l'hite III; Judith Johnsrud; Roht. Sugarman; James N. Neill; Director PEftA; Trob n. Conner,Jr.;
*! ark J.lletterhahn.
su) $ ?se so w ( 4/. '-,.
u /cy';
w
+. u
[ y ' g / g.
(s, r,
'p*
2hhr * * '' h **
%1cf 'CY bY N
.}}

Latest revision as of 01:26, 15 December 2024

Informs That Applicant Re IE Insp Rept 50-353/76-06 Fails to Demonstrate That All Suspect Welds Reinspected.Util Should Prove That All Welds,Accessible & Inaccessible,Inspected & Determined Acceptable
ML20077J092
Person / Time
Site: Limerick  
Issue date: 05/25/1983
From: Romano F
AIR AND WATER POLLUTION PATROL
To: Brenner L, Cole R, Morris P
Atomic Safety and Licensing Board Panel
Shared Package
ML20077J090 List:
References
NUDOCS 8308120242
Download: ML20077J092 (2)


Text

AIR and WATER 5p Pollution Patrol BROAD AXE, PA.

Hay 25,198383 AUS 11 P2:25 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Lawrence Brenner, Chairman

-} hp,;

Vashington, D.C.20555 SRANCH In the Matter of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50-353 Lawrence Brenner, Chairren; Dr. Richard F. Cole; and Dr. Peter A. Morris Gentlemen:

This letter is being submitted in response to letter of May Mark J. Wetterhahn, Counsel for the Applicant re:IE Report No.50-353/76-06 20, 1983 from want to state at the start that I

do not at all, quoting Mr. Wetterhahn's letter:the documents submitted to me by Mr. Wetterhahn

" demonstrate that all suspect velds, rather than those which were merely accessible, were re-inspected."

The third paragraph of Mr. Wetterhah..'s May 20 letter referring to Finding report No N-093, inter alia, and NCR report 1980 has to do with the velds which were found deficient by the NRC inspector after they were certified acceptable by the inspector of the Applicant and Rechtel's inspector.

Nouhere does the report made accessible and, thirdly, re-inspected completely, as inferre In Mr. Wetterhahn's fourth paragraph he discusses Finding Report N-093 which he writes, quote:" requires a re-inspection of all other accessible velds inspec ted by the inspector who accepted the deficient velds referred to in NRC I&E R port No. 50-353/76-06'.'

it does not solve the question of inaccessible welds (emphasis by Roma e-control Nos. C-63-20 and C-63-21 dated Jan.Mr. Wetterhahn's fifth paragrap 17, 1977 (attachment 7).

Whereas per Appendix A, Notice of Violation under A, Report No,50-353-76/06, it is stated the deficient welds were at elevation 253, celumns 23G and H, Inspection report C 63 20 and C-63-21 above refer en " control room, reactor building Unit'2, elevation 257 tn 264"respectively. elevation 269 and 289, Area 8 headed " Failure to weld structural Steel per AUS Code" mentions elevation 283 Ar a Further, 76-06-01 13 and clevation 253, colums F and H at wall 23 c

Because of confusion, Applicant must supply the name of the Rechtel and Applicant's inspectors, ber of welds and locations can he proven accessible or inaccessible together with in-Applicant For the icity, and t!.cn refer to uelds which were, nuote:"possiblyto provide statnents j

i ticular Bechtel nuality Control Inspector involved" indicates uncertaintinspected by the par-nullifying specificity.

(emphasis by Ronano).

y totally the names of the inspectors in the " broomstick" incidentIt is important also for the record that

06) with work records at the time of the incident, (50-353/76-to the present. These were not made available to me.

Further, as it relates to the sixth paragraph, reference to Bechtel Field In-snection Report Control *lo.C-61-22 dated April 4, 8300120242 G30005 1477 (Applicant means April 5, 1977?)

PDR ADOCK 05000352 O

PDR

AIR and WATER Pollution Patrol BROAD AXE:, PA.

May 25, 1983 (2) the report, at 6, indicated quo : " Type of Inspectior.... Visual". Certainly a visual inspection cannot inspec concrete. imbedded or otherwise non-visible welds.

Further, the inspection was, quote:"of installed structural steel, beams, and col-umns to determine its accessibility for inspection." Nowhere is shown that 7

report C-63-22 reports on accessible or inaccessible welds caused y scaffolding or otherwise.

I ask applicant to supply date that scaffording was removed in that specific area. Since inspection of 4/5/77 is six months after the " broom--

stick" defici nt welds incident, it seems, because of the s 3 nspection of welds by the inspectors involvedy iousness of the in-cident, that should have been made immediatedly after the incident.

Paragraph seven of ?fr. Wetterhahn's letter again refers to Report C-63-22 together with related items in the suenary of Page 8 of 8, mention is made of,

" the particular Ouality Control Inspector..." In actuality, however, there cuote:

were two inspectors who were involved in falsely 0.K.ing deficient velds in the 50-353/76-06 incident.

It ie #for the Applicant also to explain why the serious question of repeated failure to perform velding as per specified At!S code on Oct.

16, 19-22, 1976 s allowed to remain unre-inspected as to accessibility until July 1977. g g f y -fS Rf pich g.,cpgf?s.es uen obw snest.d e.wKi' ' 'S t

/ WJ$4c$7W /gpW)Y c19xcheA- #

As it relates to eighth paragraph, Field Inspection Reports Nos. C-63-30,31, 32, and C-41A-493, do not provide proof of inspection of inaccessible welds.

In fact those reports prove inaccessible welds,as stated, cannot receive a full in-spection because of being inhedded in concrete. Neverthe-less the Applicant states NC3-2710 explains how, in spite of being inhedded in concrete, the welds are declared acceptabic...but does not providd the manner by which the unsubstan-tiated conclusion that welds were acceptable on the basis that, quote:"..."the embedded portion of the weld was non-existent..." It seens the inaccessbile welds were declared, capriciously and unilaterally, acceptable on the convient and unscientific declaration that welds that cannot be re-inspected because they cannot be made accessible are, therefore, acceptable. Public safety d :mands Philadelphia Electric to categorically prove its statement (2nd Paragraph of !!r. Wetterhahn's

?tay 20 1cteer), nuote: "...that all suspect welds, rather than those which were merely accessible, vere reinspected."

P.E. must also prove that all u ids, acc-J essible and unaccessible were not just inspected but were acceptabl e Sincerely, ANPP Frank R. Ronano, Chairman First class mail service to:

Richard F. Cole, Peter 'forris, Atomic Sefety & Licensing Appeal Panel; Rocketing and Service Section; Ann P. Ilodgdon, Elaine I. Chan; Atomic Safety & T.icensing Board Panel, Phila. Electric, Ent> C.

Rauer; Roht. L. Anthony; !!srvin f.ewis; Judith Dorsey; Charles EJliott; Alan J. :Togec; Thomas Y. Au; Thomas l'hite III; Judith Johnsrud; Roht. Sugarman; James N. Neill; Director PEftA; Trob n. Conner,Jr.;

  • ! ark J.lletterhahn.

su) $ ?se so w ( 4/. '-,.

u /cy';

w

+. u

[ y ' g / g.

(s, r,

'p*

2hhr * * h **

%1cf 'CY bY N

.