ML19241B271
| ML19241B271 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/06/1979 |
| From: | Like I SUFFOLK COUNTY, NY |
| To: | |
| References | |
| NUDOCS 7907130400 | |
| Download: ML19241B271 (7) | |
Text
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FIATED QORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0dIC SAFETY AND LICENSING E0ARD NRC PUELIC DOCDENT P.00M
_-___--_-_x In the Matter of LONG ISLAND LIGHTING COMPANY Docket No. 50-322 3
(Shoreham Nuclear Power Station, Unit 1) cr.
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COUNTY OF SUFFOLK'S SECOND SET OF p
INTERROGATORIES AND NOTICE TO PRODUCE g
g TO APPLICANT AND NRC (a
By letter to Chairman Elizabeth S.
- Bowers, dated May 17, 1979, the County of Suffolk requested that the NRC conduct an audit and a nhysical inspection of the Shoreham plant to evaluate the signif cance cf the engineering documents describing safety related prob-lems which were found in the Southold Town Dump.
The County's technical consultant, Mr. Marc Goldsmith of Energy Research Group, Inc., has reviewed some 51/
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c f these documents and with his aid, the interrogatories hereinafter set forth are propounded to the Company and the NRC.
It is respectfully requested that prompt responses be furnished in view of the concern that has been expressed in some quarters that these documents reveal serious defects in the Shoreham construction.
For example, Dr. Michio Kaku, professor of nuclear physics at the City College of New York is reported as expressing such opinion in the news and broad-cast media.*
With respect to the interrogatories which follow, tne ground rules and definitions set forth in the County's First Set of Interrogatories dated March 28, 1979 are herein incorporated by reference.
opect'ully submitted, A
Dated:
Babylon, New York Irvi i L Me June 6, 1979 spc ial Cou lsel for the County of Suffolk 200 West Main Streat Babylon, New York 11702 Tel. No. (516) 669-3000 I
See Southampton Press article of May 31, 1979, attached hereto and made a part hereof as Exhibit 1.
On June 4, 1979 Channel 7 Eyewitness News reported Dr. Kaku's concerns regarding construction problems at the Shoreham plant.
The Channel 7 Newscast of May 31 and June 1, 1979 reporsed alle-gations of loose security and workers' sabotage.
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APPENDIX " A'.
b w e. W phs & WY"
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Interrogatories Directed to LILCO jfy)
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A.
Relating to record keeping.
1.
Are the LILCO Shoreham construction and design documents on microfiche or hard copy?
2.
Does LILCO retain originals of all-of these documents on site?
3 What is LILCO's practice with respect to the disposal of documents?
4.
Does LILCO claim that such disposal is permitted by any regulation of the NRC; (a) if so, cite the regula-tion.
B.
Relating to Cable Tray records.
1.
Are the problems described in these records safety related?
2.
With *egard to any problems identified in LILCO's engin-ering snd design coordination reports (herein-6 after 1._ __.ed to as the " Reports") concerning cable trays, were FSAR changes required? ; (a ) if so, were such changes in the FSAR made and cite the sections.
3 Was client approval requested and given with respect ta such changes?, (a) if not, why not.
4.
Has there been a quality assurance /quallev ormtrol
("QA/QC") check wich regard to such changas?; 'a) if yes, when was such QA/QC check performed and g:. ie the details thereof; (b) if not, why not.
5 What, are the criteria for verification of impleme.+a-tion of any change or fix with respect to the cable trays?
o.
Who in the LILCO construction organisation (which is deemed to refer also to Stone & 'febster) makes the decision regarding QA/QC approval, client approval and FSAR change?
7 Is the person who makes that decision the lead engi-neer?; (a) if not, does the lead engineer or design engineer have to approve or sign off as to such change?
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221 8.
If the item as to which the change is made is safety class 1, have analysis been done of such change to reconfirm seismic and design adequacy?
9 What are the system identifiers?; (a) explain the numbering system for cable trays and safety related systems so as to permit determination of what the systems are.
C.
Relating to County's prior letter to Chairman Bowers dated May 17, 1979 The County requests that the information demanded in its letter of May 17, 1979 be deemed in the nature of interrogatories and that they be responded to in the manner requested in said letter.
APPENDIX "B" Interrogatories Directed to LILCO and NRC A.
Relating to variances.
Background
The County is concerned whether the final drawings reflect "as built".
It is the QA/QC function to de-termine that both the finC
"^ wings and the "as built" drawings comply with all NR; iuirements.
For example, County is interested in deter...ining whether a ay change or variances from the original drawings is acceptable to the engineer responsible for the system described in said drawing and that such change will not weaken the integrity and function of the structure.
The County also wishes to ascertain whether any revised drawings reflect "as built".
The interrogatories which follow reflect the County's concerns in this area.
1.
How is the variance finally reflected in the drawings and materialt svallable to the plant operators and the NRC?
2.
How does the NRC monitor changes in design and con-struction?
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What are the ff.nal documents that the N3C reviews prior to recommending for or aGainst a licence?
4.
How does the NRC reconfirm design ant safety adequacy after field variances and changes?
B.
Relating to NRC and LILCO's incoection oractices.
1.
Has the NRC Inspection and Engineer ("I&E") Division inspected Shoreham drawings against complete systems installed to insure that the drawings reflect the "ae built" system, that the original design quality requirements are not violated and that the procedures specified by the drawings are followed?
If so, give full details as to such inspections and provide copied of inspection reports; if not, explain why not.
2.
Has the NBC I&E Division checked Shcrehan drawings randomly?; (a) has it' checked them for all systems?
3 Did the NRC's check include a records check to assure that all deviations and changes during con-struction have been verified and reflected on the "as built" drawings?
4.
Has the NRC ILE Division rated general contractors on site cleanliness and general morale of their spe-cific construction sites?; (a) if so, provide copies of any reports; (b) if not, explain why not.
5 Hou do LILCO'.s and Stone & Webster's effoFts aompare with.those of other utilities?
6.
How is the better performance of some general _a tractors related to and impressed on other contractors and utilities?
7 Has anybody in the LILCO construction organisation in-spected Shoreham drawings against complete systems in-stalled to insure that the drawings reflect the "as built" systems, that the original iesign quality re-quirements are not violated and that the procedures specified by the drawings are followed'; (a) if so, specify who in LILCO's construction organisation has performed this responsi'r'.y and have any reports concerning such inspec
>een prepared?; (b) if so, provide copies; (c) if n-why not?
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Has LILCO checked these drawings randemly?; (a) has it checked them for all safety systems?; (b) has it checked them for all systems?
9 Did LILCO's check also include a records check to assure that all deviations and changes during con-struction have been verified and reflected on the "as built" drawings?
10.
Arc s gestions or complaints received by LILCO from craftsman with regard to such practices?
If so, how does LILCO integrate and utilize such suggestions and/
or complaints to improve and verify proper construction practices?
C.
Relating _*.c Hydrostatic Testing.
1.
What critical hydrostatic tests regarding safety class fluid systems have been performed and are scheduled and on what dates?
Provide test procedures and acceptance criteria for such systems.
3 Provide reports as to the results of such tests.
4.
Has the NRC I&E Division observed any of such tests?
' so, provide copies of any inspection reports.
5 Is LILCO willing to allow the County's consultant to observe one of the tests chosen at randon on safety class equipment?
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-c tuMTED CORRI3Puwuus Southampton Press May 31, 1979 Expert Reviews
%-Plant Reoorts:
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'Dr.. Kaku stressed that pipsng in a m
h "At best the Sh'oreham plant is a lemon.
nuclear plant must be able to withstand Iat' worst it's.a real threat to the health and "one and a half times the design pressure of,
safety of the people of Long Island.- These,
l.M0 pounds per square inch."
i
' reports revear,an absolutely outragemzs
) Improper welding, he noted, "can lead to Tatterri-of 9 shoddy. work. They are
= wM break of a pipe and if it's in a,
- damning.".
pirr ry cireait, that's it A !oss of coo'v t,
- -:'So said.Dr..Michio Kaku, professor of n..r.h n, a1 catastrophic meltdown can
" nuclear physics ~at the City Collegt cfNew wit "
Yorkc Wednesday. morning abo st. t.
Dr. Kaku s' aid 'the dm:uments, prepared '
boxto~ad of ;t'. Engineering and dalg.~
ty the 'Sto..e J & Webster Engineering Coordiaation. :: Reports" cur.:acniv CcNration. which LILCO describes as-problems in the construction of the nuc! at
' urin er.2 :with C its executives as plant. being built / hy the Lon.. Isl "censtruction managers" on the project, Lighting Company st Shoreham.
"are ^ full of examples cij. shoddy
_. Copies of the reports.-some 416 of w! *
. orkmanship. - -. '
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. involve what is l described on them as
- . ??The t eports concerning rebars are most
" nuclear safety' related" problems - are
.important," he went on. "Rebars are
'being circu!ated to independent nuclear reinforcement bars in concrete and they're scientists around the ; nation. Dr. Kaku.
'tiot supposed to be hit or cut or the tensile afterstudying the papers which were found
trength of the concrete is reduced. In one s
under a bush in the Southold Town dump document,in ten incorrect tries to make a declared: "What'.are involved are most
' hole, seven rebars are hit."'
serious problems in the most sensitive i YDr.. Kaku also rexpressed concern for '
areas of the reactor,"
mistakes in construction of "the primary He was concerned about violations of the containment - what actually bolds the American Society of : Mechanical,
granium fuel rods.There is no more crucial Engineers' standards on pressure pipe area in a reactor," in the "rmidual beat welding. "The ' attitude through the
. remover" system.."This is an area which documents is one of, 'Let's just sand it malfunctioned at Three Mile hbnd," and smooth and pass it on,'" he said.
i,n the plant's turbine room.
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nO uw Exhibit 1