ML20077J092

Informs That Applicant 830520 Ltr 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: ML20077J089 ML20077J091 ML20077J092 ML20077J093 ML20077J096
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 20, 1983 from Mark J.

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."

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 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 .

control Nos. C-63-20 and C-63-21 dated Jan.Mr. Wetterhahn's fifth paragraph 17, 1977 (attachment 7).

Appendix A, Notice of Violation under A, Whereas per 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.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-

• 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).

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

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?)

PDR O ADOCK 05000352 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 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--

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.

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.

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' t ' 'S

/ 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-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.;

• ! ark J.lletterhahn.

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

w +. u -

[ y ' g / g. (s, r, 'p* 2hhr * * h **

%1cf 'CY bY N .