ML20080B923

Answers to Twelfth Set of Interrogatories on Qa/Welding Contention (Discovery 24).Certificate of Svc Encl

ML20080B923
Person / Time
Site:	Limerick
Issue date:	02/01/1984
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	AIR AND WATER POLLUTION PATROL
Shared Package
ML20080B818	List: ML20080B816 ML20080B891 ML20080B912 ML20080B923
References
NUDOCS 8402070322
Download: ML20080B923 (22)

Text

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'84 FEB -6 AH :40 UNITED STATES OF AMERICA " ' ' ' - - '

NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station )

Units 1 and 2) )

APPLICANT'S ANSWERS TO INTERVENOR AWPP'S TWELFTH SET OF INTERROGATORIES ON QA/ WELDING CONTENTION DISCOVERY 24 FEBRUARY 1, 1984 8402070322 840203 PDR ADOCK 05000352 O PDR

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Interrogatory No. 1 Pursuant to the Board's Order concerning formal discovery, AWPP requests the following re Contention VI-I (Quality Assurance / Control). AWPP requests specific material that will not require searching through voluminous records.

Re " Applicant's Interim Report to the Licensing Board Relating to Contention VI-I" dated September 16, 1983, in particular, Affidavid of Vincent S. Boyer, wherein Mr. Boyer affirms "there are initial indications, not yet confirmed, that some additional deficiencies may be present".

Please provide all documents, logs and reports on all safety related welds involved.

Answer All documents and reports related to the 1983 re-evaluation of the welding deficiencies identified in NRC Inspection Report 50-353-76/06, Item 1 had been previously made available (Discovery 14, Item 7). Applicant's Interim Reports to the Atomic Safety and Licensing Board relating to Contention VI-I dated September 16, 1983, and October 4, 1983, with associated affidavits, were previously provided to the service list.

Participants in Preparation of Answer i V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer l Philadelphia Electric Company

! 2301 Market Street l Philadelphia, PA 19101 r

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e Interrogatory No. 2 At 5b page 3, what deficiencies noted; what corrective action; completion date and manner of correction; and by whom signed off?

Answer The deficiencies referred to are described on Bechtel Nonconformance Reports 1998 and 2000 with the disposition, corrective action, completion, and acceptance also documented an these reports. Bechtel Nonconformance Reports 1998 and 2000 had been previously provided (Discovery 14, Item 7).

Participants in Preparation of Answer j V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 .

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e Interrogatory No. 3 Re Par. 12, what were the "four minor deficiencies noted"?

Answer The "four minor deficiencies noted" are described on Bechtel Nonconformance Reports 1998, 2000, and 2710. Applicant's Second Interim Report to the Atomic Safety and Licensing Board relating to Contention VI-I dated October 4, 1983 corrects the Applicant's earlier interim report stating in paragraph 13', page 2, that there were "6 minor deficiencies noted". The increase from 4 to 6 results from including the two deficiencies originally identified in IE Inspection Report 50-353/76-06 Item 1 which were also documented on Bechtel Nonconformance Report 1980. These Bechtel Nonconformance Reports had been previoulsy provided (Discovery 14, Item 7).

Participants in Preparation of Answer j V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 4

e Interrogatory No. 4 Is 1% of accessible welds improperly inspected permitted by NRC?

Answer Applicant is not aware of any NRC document that permits any percentage of accessible welds to be improperly inspected.

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 5

O Interrogatory No. 5 How were those 4 dispositioned?

Answer As explained in response to Interrogatory 3, there are six minor deficiencies. These were dispositioned rework (four welds) and use-as-is (two welds). See Bechtel Nonconformance Reports 1980, 1998, 2000, and 2710 (Discovery 14, Item 7).

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 6

e Interrogatory No. 6 How were the remaining 31 welds dispositioned?

Answer The number of 31 welds given as inaccessible was corrected to 3 in paragraph 5, page 4 of Applicant's Second Interim Report to Atomic Safety and Licensing ' Board relating to Contention VI- .

The change resulted from the initial inclusion of non-safeuy grade welds in the inaccessible count as explained in the above report. Bechtel Nonconformance Report 2710 (Discovery 14, Item 7), documents the disposition of these three inaccessible welds as use-as-is. ,

i Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 i

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Interrogatory No. 7a Are Re Paragraph 13--one reinspected weld out of 16 is 6%.

those 6% improperly inspected welds within NRC Quality Assurance / Quality Control permissible limits?

Answer See response to Interrogatory No. 4 Participant.; in Preparation of Answer V. S. Boyer , Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clahecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 i

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4 Interrogatory No. 7b On what basis is there assurance that " engineering analysis (is) continuing to disposition the 212, partially or totally inaccessible welds..." will, without any doubt whatsoever, that they in fact are not different? (AWPP has not received any report although stated to be done on October 16, 1983).

Answer Applicant's Second Interim Report to the Atomic Safety and Licensing Board relating to Contention VI-I in Paragraph 13',

page 2, stated that the welds referred to have been found by engineering analysis to be acceptable. The Bechtel Nonconformance Reports 7951, 8095 and 8125 (Discovery 14, Item 7) document the engineering disposition relating to these welds.

,articipants in Preparation of Answer P

V. S. Boyer, Senior Vice President - Nuclear Power '

Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 b

D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 9

Interrogatory No. 7c 19 minor deficiencies out of 47 is approximately 25%. Is 25%

of welds previoulsy inspected and checked off as properly performed permitted by QA/QC of the NRC.

Answer See response to Interrogatory No. 4.

- Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street

' Philadelphia, PA 19101 i

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Interrogatory No. 7d Re Par. 14, what does Applicant mean by " representative number of welds for which the subject inspector was responsible?

Answer Applicant's Second Interim Repor t to the Atomic Safety and Licensing Board relating to Contention VI-I dated October 4, 1983, Paragraph 6, page 4, states that 67 safety-related structural welds were reinspected by the Applicant.

Participants la Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Concoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 11

Interrogatory No. 7e How many welds will be in the " representative number"?

Answer See response to Interrogatory 7d.

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

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Interrogatory No. 7f Who determines which welds will be in the " representative number" selected?

Answer The welds reinspected by the Applicant were determined by the PECo. Quality Assurance Field Branch Head.

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 13

l 6 Interrogatory No. 7q What is the total propor tion which the " representative sample" is to represent?

i Answer Applicant's Second Interim Report to the Atomic Safety and Licensing Board relating to Contention VI-I, paragraph 6, describes the Applicant's physical reinspection program and states that there were 439 welds in the group from which the sample was taken.

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Eranch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 14

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Interrogatory No. 7h Will that number meet statistical procedures regarding validity of results?

Answer The number of welds sampled was judged by the PECo. Quality Assurance Field Branch Head as representative of accessible

structural welds. .;

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 15

0 Interrogatory No. 71 Please provide affidavit that above statistical standard is met.

Answer See response to Interrogatory 7h.

Participants in Preparation of Answer V.-S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA ~ 19101 J. M. Corcoran Quality. Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 I

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o Interrogatory No. 7j Please provide complete information, reports, logs, inspectors involved, test to be run, welds involved and locations of such welds.

Answer Suiveillance Check Repor t G-87 (Discovery 14, Item 7) documents the Applicant's physical reinspection and the results of the reinspection for those structural welds referred to in Interrogatory 7d above.

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head

-Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T..Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 17

4 Interrogatory No. 7k Were any other welders or welding inspectors separated, discharged, or transferred due to improper workmanship, efficiency, or other deficiency, including use of drugs or alcohol?

Answer Bechtel Power Corporation has separated, discharged, or transferred welders from work at Limerick for reasons such as those listed above. No Bechtel Power Corporation welding inspectors have been separated, discharged or transferred for reasons such as those listed above. Also see response to Discovery 17, Item 4.

Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J. M. Corcoran Quality Assurance Field Branch Head Phila6ciphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l

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i COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF PHILADELPHIA  :

V. S. Boyer, being first sworn, deposes and states:

That he is Senior Vice President of Philadelphia Electric Company, the Applicant herein; that he had rond the foregoing ApplicanL's Answers to Intervenor AWPP's Twelfth Set of Interrogatories on QA/ Welding and knows the contents thereof; and that the statements and matters set ferth therein are true and correct to the best of his knowledge, information and belief.

D Senior Vice Presi(;dnt Subscribed and sworn to before me this day of February,1984.

Y- . -

Notuby Public -

PATRICIA D. SCH0!1 Notary Public. Philadcipt.ia. I't.iladtf;;hia Co.

My Cosmmen Expun thiy 10. IwG

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'84 EB -6 All 39 UNITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSIONgypu c; my

• 00CnElitG A set h BRANCH In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of a letter to Frank R.

Romano from Mark J. Wetterhahn dated February 3, 1984,

" Applicant's Answers to Intervenor AWPP's Tenth Set of Interrogatories on QA/ Welding Contention," " Applicant's Answers to Intervenor AWPP's Eleventh Set of Interrogatories on QA/ Welding Contention," and " Applicant's Answers to Intervenor AWPP's Twelfth Set of Interrogatories on QA/ Welding Conter. tion" all dated February 1, 1984 in the captioned matter, have been served upon the following by deposit in the United States mail this 3rd day of February, 1984:

• Lawrence Brenner , Esq. (2) Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section

• Dr. Richard F. Cole Office of the Secretary Atomic Safcty and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• Ann P. Hodgdon, Esq.

Counsel for NRC Staf f Of fice

• Dr. Peter A. Morris of the Executive Atomic Safety and Legal Director Licensing Board U.S. Nuclear Reaulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Hand Delivery

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Atomic Safety and Licensing Steven P. Hershey, Esq.

Board Panel Community Legal U.S. Nuclear Regulatory Services, Inc.

Commission Law Center West North Washington, D.C. 20555 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN: Edward G. Bauer, Jr. Angus Love, Esq.

Vice President & 107 East Main Street General Counsel Norristown, PA 19401 2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue

• Mr. Frank R. Romano Ardmore, PA 19003 61 Forest Avenue Ambler, Pennsylvania 19002 Robert J. Sugarman, Esq.

Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street the Delaware Valley Philadelphia, PA 19107 -

106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I. Lewis Basement, Transportation 6504 Bradford Terrace and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer, Esq. Martha W. Bush, Esq.

Limerick Ecology Action Kathryn S. Lewis, Esq.

P.O. Box 761 City of Philadelphia 762 Queen Street Municipal Services Bldg.

Pottstown, PA 19464 15th and JFK Blvd.

Philadelphia, PA 19107 Charles W. Elliott, Esq.

Brose and Postwistilo Spence W. Perry, Esq.

1101 Building lith & Associate General Counsel Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W., Rm. 840 Zori G. Ferkin, Esq. Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director Governor's Energy Council Bureau of Radiation 1625 N. Front Street Protection Harrisburg, PA 17102 Department of Environmental Resources 5th Floor, Fulton Bank Bldg.

Third and Locust Streets Harrisburg, PA 17120

• • Federal Express

Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 nAL.

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