ML19323D093
| ML19323D093 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/23/1980 |
| From: | Christopher R, Mcgaughy R, Remaklus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19323D091 | List: |
| References | |
| 50-322-79-24, NUDOCS 8005210075 | |
| Download: ML19323D093 (61) | |
See also: IR 05000322/1979024
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800521007 5
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-322/79-24
Docket No.
50-322
License No.
CPPR-95
Priority
--
Category
B
Licensee:
Long Island Lighting Company (LILCO)
175 East Old Country Road
,
Hicksville, New York
11801
)
Facility Name:
Shoreham Ruclear Power Station, Unit 1
Investigation At:
Shoreham, New York
Investigation Conducted:
December 11, 1979 through March 19, 1980
M-ll- 90
Investigators:
O.
J/
^
C. O.
11ina,' h.D.,
Investigation Specialist
date
C
Y//y/Ao
L. M. Narrow Reactor Inspector
date
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W W TD
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p.P.eDurr,ReactorInspector
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L y se
S. D. Reynoldih, Jr. , Reactor Inspector
date
// N
w
. C. Higg~iits, S . R sident Reactor Inspector
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F) H. Nicholas,
ctor Inspector
I date
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R. K. Christoph
' Investigation Spec'f alist
date
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Wtt<L
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L. /P. Remaklus, Ihvdstigation Specialist
date
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Reviewed By:
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R. W. McGaughy/Cnfef, Project Section
date
RC&ES Branch
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Region I Form 143
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(Rev. October 1977)
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Investigation Summary:
Investigation from December 11, 1979 through March 19, 1980 (Investigation
Report Number 50-322/79-24)
Areas Investigated:
The investigation covered thirty (30) allegations related
to construction irregularities at the Shoreham site.
The allegations were
made via court testimony, personal interviews, magazine articles and alleged
phone calls by third parties to one of the known allegers. The investigation
involved 410 man-hours on-site by three (3) NRC investigators and (5) NRC in-
spectors.
Results:
Of the thirty (30) allegations investigated, none were found to be
substantiated.
During the course of the investigation, two (2) items of
noncompliance were identified: (1. Infraction - failure to identify nonconfor-
mance, Paragraph D.2; 2. Infraction - improper weld rod requisition forms,
Paragraph D.10)
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TABLE OF CONTENTS
I. BACKGROUND
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A.
Reason for Investigation
B.
Identification of Involved Organizations
II. SU M RY OF FINDINGS
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A.
Allegations and Investigation Findings
B.
Items of Noncompliance
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C.
Management Meeting
III. DETAILS
A.
Introducti..n
B.
Scope c' Investigation
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C.
Perso .s Directly Interviewed and/or Contacted During the NRC Investi-
gatr on
D.
NRe., Investigation Findings and Conclusions Related to Allegations
IV. EXHIBITS
A.
Referenced Codes, Specifications and Procedures
B.
Notice of Investigation
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I. BACKGROUND
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A.
Reason for Investigation
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The Nuclear Regulatory Commission (NRC), Office of Inspection and Enforce-
ment, Region I, was first informed of potential construction irregularities
at the Shoreham Nuclear Power Station (SNPS) on December 1,1979 when the
NRC's Resident Inspector at the Shoreham site was contacted by Mr. Leighton
Chong, one of the defense attorney's for an individual charged with
trespassing at the Shoreham site during an anti-nuclear demonstration in
June of 1979.
During the week of December 3 through 10, 1979 additional
information concerning these irregularities was presented by Mr. Chong
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and Mr. John Hall, a local independent TV producer. In addition, testimony
presented during the above referenced trial on December 6, 1979 and local
newspaper coverage thereof on December 7,1979 was also made available by
the NRC's Public Affairs Office. Based on the information received, the
NRC initiated an investigation into alleged construction irregularities
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at the Shoreham site on December 11, 1979.
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B.
Identification of Involved Organizations
1.
LONG ISLAND LIGHTING COMPANY (LILCO)
,
175 East Old Country Road
Hicksville, New York 11801
An electric utility licensed by the NRC to construct a nuclear power
plant under NRC Construction Permit No. CPPR-95. (Occket Number
50-322)
2.
STONE AND WEBSTER ENGINEERING COMPANY (S&W)
245 Summer Street
P. O. Box 2325
Boston, Massachusetts 02107
A company contracted by the licensee to perform various construction
management activities at the Shoreham site.
3.
GENERAL ELECTRIC COMPANY (GE)
175 Curtner Avenue
San Jose, California 95125
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A company contracted by the licensee to provide the nuclear steam
supply system and related components at the Shoreham site.
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4.
GENERAL ELECTRIC COMPANY, I&SE DIVISION (GE)
777 West Putnam Avenue
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P. O. Box 6850
Greenwich, Connecticut 06830
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A company contracted by ,he licensee to provide the turbine generator
and related components at the Shoreham site.
5.
DRAVO CORPORATION (DRAVO)
Neville Island
Pittsburgh, Pennsylvania 15225
A company contracted by the licensee to perform various construction
activities at the Shoreham site.
6.
COURTER & COMPANY (COURTER)
317 West 13th Street
A company contracted by the licensee to perform various construction
activites at the Shoreham site.
7.
L. K. COMSTOCK & CO. INC. (COMSTOCK/ JACKSON)
155 East 44th Street
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A company contracted by the licensee to perrorm various construction
activities at the Shoreham site.
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8.
REACTOR CONTROLS, INC. (RCI)
1245 South Winchester Boulevard
San Jose, California 95128
A company contracted by the licensee to perform various construction
activities at the Shoreham site.
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9.
PROTECTIVE SPR/.Y PLASTICS, INC. (PSP)
1130 Crose Avenue
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A company contracted by the licensee to perform various construction
activities at the Shorehan site.
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10.
REGOR CONSTRUCTION CO., INC. (REGOR)
P. O. Box F
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East Northport, New York 11731
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A company contracted by the licensee to perform various construction
activities at the Shoreham site.
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11.
JOHN GRACE & COMPANY (GRACE)
34 Washington Parkway
Hicksville, New York 11801
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A company contracted by the licensee to perform various construction
activities at the Shoreham site.
12.
C. P. BENNETT/F&G CO., INC. (C. P. BENNETT)
231 Russel Street
Brooklyn, New York 11222
A company contracted by the licensee to perform various construction
activities at the Shoreham site.
13.
KTA-TATOR ASSOCIATES (KTA-TATOR)
3020 Montour Street
Coraopolis, Pennsylvania 15108
A company contracted by the licensee to perform selected QA/QC
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activities at the Shoreham site,
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II. SUMMARY OF FINDINGS
A.
Allegations and Investigation Findings
This investigation involves allegations that were introduced by various
methods by several individuals.
The investigation was initiated on
December 11, 1979 as a result of the testimony of two individuals testi-
fying on behalf of the defendant in a trial related to trespassing charges
incurred at the Shoreham site in June of 1979.
On December 12, 1979 an
allegation was received in connection with the Shoreham site from an
unidentified alleger through a local shopkeeper. This allegation is
described and numbered 1 below.
On December 17, 1979, NRC investigatort
met with Witness A in the above referenced trial.
Witness A's allegations
are described and numbered 2 through 9 below.
On December 17, 1979 NRC
investigators met with Witness B in the above referenced trial.
Witness
B's allegations are described and numbered 10 through 18 below.
On
December 17, 1979, defense attorneys in abova referenced trial presented
NRC investigators with allegations from other witnesses who were not
called to testify and who wished to remain anonymous. These allegations
are described and numbered 19 through 21 below.
On December 17, 1979,
the defense attorneys also presented NRC investigators with allegations
from a former boilermaker F.t the site.
These allegations are described
and numbered 22 through 25 below*.
On January 9,1980, NRC investigators
met again with Witness A who presented three (3) additional .llegations
allegedly received by anonymous phone calls.
These allegat1ons are
described and numbered 26 through 28 below.
On February 26, 1980, NRC
investigators met again with Witness B at his request at which time
another allegation was introduced.
This allegation is described and
numbered 29 below.
Throughout the initial investigation, defense attorneys
reported that pressure was being applied by the licensee (LILCO) and/or
related unions in order to prevent workers from coming forth to the NRC
with information.
This matter was covered as a separate allegaticn and
numbered 30 below.
- Knowledge of the existence of these allegations was made known to the NRC
Resident Inspector at the Shoreham site on or about December 12, 1979 and
appeared, in part, in an article published in Seven Days, Volume III, No.12,
dated October 26, 1979.
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Allegations
NOTE:
The allegations listed below have been summarized for clarity. The
actual allegations are cited in detail in Section III of this investi-
gation report.
1.) Inspection of the N-11 steam lines revealed cracks which may require that
the entire system be replaced.
The NRC investigation found no evidence and/or information to substantiate
this allegation. (Details, Paragraph D.1)
2.) Following concrete placements for the Reactor Pedestal and Reactor Building
Primary Containment Wall, heaters were not used as required for curing
during the winter months of 1973-1974.
Similar conditions were allowed
to occur in the Radwaste Building during the winter months of 1974-75 and
1975-76.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.2)
3.) Following concrete placements for the Reactor Pedestal, Primary Containment
Wall, and Radwaste Building, forms were improperly stripped on the day
following concrete placement instead of the required seven (7) days.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.3)
4.) Following the stripping of concrete forms for the Reactor Pedestal and
Primary Containment Wall, large cracks, honeycombing deep enough to
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expose the rebar and through-cracks were patched over with mortar prior
to inspection by QC.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.4)
5.) Cadwelds for rebar in the concrete located in the Reactor Building were
in some cases found to be loose with concrete poured over the loose
cadwelds.
The NRC investir tion found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.5)
6.) Rubber waterstops between concrete layers in the Radwaste Building were
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not installed properly and sometimes omitted entirely.
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The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.6)
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7.) A carpenter was permitted to weld studs to embedment plates used for pipe
supports in the North wall of the Radwaste Building even though he had
failed the welding test seven (7) times.
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The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.7)
8.) Threaded tie rods without sleeves used as form ties for the Reactor
Pedestal were pulled from the concrete after it had set, leaving a void
in the wall. In some cases, large amounts of concrete were pulled from
the pedestal wall in this manner.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.8)
9.) Several through-cracks were observed in the Turbine Building wall that
separate it from the Reactor Building.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.9)
10.) During the first three weeks of February 1979, several dissimilar metal
welds were made with ER-308 and/or ER-316 weld rod instead of the required
ER-309 weld rod because welders claimed that it was too cold to return to
their foreman and have incorrect weld rod requisitions changed.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.10)
11.) In a covert attempt to use substandard materials, E-6018 electrodes were
used rather than the required E-7018 electrodes.
The NRC investigation found no evidence and/or informat!cn to substantiate
this allegation.
(Details, Paragraph D.11)
12.) A large scale repair on the feedwater condenser jacket was performed by a
Regor boilermaker instead of the usual Courter and Company steamfitter in
order to avoid having the crack reported to Courter QA personnel which
would have raised the issue as to the integrity of the entire jacket.
The NRC investigation found no evidence and/or information to substantiate
i.iis allegation.
(Details, Paragraph D.12)
13.) Due to the impraper estimation of the depth of the water table by LII.CO,
salt water is seeping through the Secondary Containment wall at the 8
foot level and around-the-clock efforts are being undertaken to pump the
water out.
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The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.13)
14.) Stone and Webster lost its general contractor duties when it repeatedly
complained to LILCO about the incompetence and corrupt practices of its
contractors, such as Regor and Courter, which LILCO insisted on using.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.14)
15.) In addition to seven (7) major failures of hydroflushes of the primary
closed loop piping system, a gross failure on or about June 15, 1979
caused valves to pop and s section of pipe to be ejected 50 feet into the
air.
It was also alleged that the hydrostatic test of the system in
September of 1979 could not have been valid since it occurred too soon
after the gross failure in June 1979 to have permitted proper shutdown
and repair.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Par graph 9.15)
16.) The outfall pipes for the circulating water systems have n-ver been
properly anchored and due to the tidal action in Long Island Sound, have
shifted, broken and separated from the line itself.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.16)
17.) NDE technicians were not adequately qualified for the jobs they were
performing.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.17)
18.) Large quantities of green dye used for dye penetrant testing were being
discharged by b LCO without proper approval and are polluting Wading
River siellfish.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.18)
19.) Supervision of trade workers is inadequate and being performed by unquali-
fied indiJiduals.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.19)
20.) Qualification and training of subcontractor personnel at the Shoreham
site is inadequate.
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The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.20)
21.) Workers painting the inside of the Reactor Primary Containment were not
qualified and when discovered by the NRC, most workers were layed off but
the substandard work was not inspected and allowed to remain. It was
further alleged that the remaining workers completed the jobs and on one
occasion worked a 30-hour shift on methedrine.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.21)
22.) Tube support sheets in the condenser box were so misaligned that titanium
tubing which should fit loosely, was hammered into place resulting in
damage severe enough to cause a tube to break with the possibility of a
radioactive spill.
The NRC investigation found no evidence and/or information t9 substantiate
this allegation.
(Details, Paragraph D.22)
23.) Radiographic tests revealed that the longitudinal seam welds for the con-
denser box were improperly done and when opened for rework were found to
contain dirt, rubbish and weld rod stubs.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.23)
24.) Misalignment of the condenser tube support sheets required re welding so
often that in some cases the " mother material" around the weld had to be
cut out and replaced with a fresh substitute section.
The NRC investigation found no evidence and/or information ta substantiate
this allegation.
(Details, Paragraph D.24)
25.) Welds to be inspected are pre-marked by QA in order that the best welders
can be assigned to these jobs while other welds are made by lesser quali-
fied welders and never inspected. This resulted in a degradation of the
overall quality and resultant safety factors at the Shoreham site.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.25)
26.) Turbine foundation bolts were installed so far out of alignment that it
was necessary to chop out the concrete around the bolts, heat the bolts
and bend them into a "Z" shape in order to fit them to the foundation
plates.
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The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.26)
27.) When concrete was placed in a cold joint on the 63' level of the Reactor
Primary Containment, a large amount of rubbish and trash was permitted to
remain within the form and the concrete placed on top of it.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.27)
28.) Soil percolation testing results were falsified and test results withheld
in LILCO's submission of this information to the NRC.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.28)
29.) Welder performance qualification records were postdated for welders who
qualified after performing welds for wh.ih they had not been qualified.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.29)
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30.) Pressure was applied to construction workers by LILCO, its subcontractors
and/or related construction unions in order to prevent and/or discourage
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workers from coming forth to identify construction defects and/or irreg-
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ularities to the NRC.
The NRC investigation found no evidence and/or information to substantiate
this allegation.
(Details, Paragraph D.30)
8.
Items of Noncompliance
During the course of the investigation,'two (2) items of noncompliance
were identified related to concrete records and dissimilar metal welds.
Item No. I was corrected prior to the completion of the investigation.
1.) (79-24-01) Contrary to Criterion XVI of Appendix B of 10 CFR 50, the
licensee failed to identify the nonconformance of Concrete Placement
RS-4-12 with respect to curing requirements and consequently failed
to take appropriate corrective actions at the time.
(Details,
Paragraph 0.2)
2.) (79-24-02) Contrary to Criterion V of Appendix B of 10 CFR 50, the
licensee issued two (2) Weld Material Requisitions which indicated
ER-308 weld material instead of the required ER-309.
(Details,
Paragraph D.10)
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C.
Management Meeting
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A management meeting was held on March 19, 1980 with licensee representa-
tives at the conclusion of the investigation in order to discuss the
NRC's investigation findings. The following individuals were in attendance.
L. Narrow, Reactor Inspector (NRC)
J. C. Higgins, Sr. Resident Inspector (NRC)
J. P. Novarro, Project Manager (LILCO)
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W. J. Museler, Assistant Project Manager (LILCO)
T. F. Gerecke, QA Manager (LILCO)
W. Hunt, Project Engineer for Construction (LILCO)
J. M. Kelly, FQA Manager (LILCO)
T. Arrington, FQC Superintendent (S&W)
A. F. Earley, Attorney (Hunton and Williams)
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III. DETAILS
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A.
Introduction
This investigation was initiated as a result of the NRC-Region I being
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informed of various alleged construction irregularities at the site of
the Shoreham Nuclear Power Station (SNPS).
The exact number of allegers
could not be determined due to the manner in which the allegations were
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received, i.e., court testimony, personal interviews, magazine articles
and alleged phone calls by third parties to one of the known allegers.
The primary initiating event of the investigation was the testimony
provided on December 6, 1979 by two (2) former construction workers at
the Shoreham site who were defense witnesses for an individual charged
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with trespassing during an anti nuclear rally at the Shoreham site in
June of 1979.
B.
Scope of Investication
This investigation included an examination of pertinent documents and
records at the Shoreham site and at the NRC Regional Office; interviews
and contacts with several licensee and contractor personnel (present and
former employees); observations by the investigators as well as independent
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testing as applicable by the NRC through an outside testing laboratory
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(The Franklin Research Center).
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C.
Persons Directly Interviewed and/or Contacted During the NRC Investigation
During the course of this investigatior, representatives of various
subcontractors at the Shoreham site were contacted in order to set up
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interviews with their employees.
The subcontractors contacted have been
delineated in Section I-B of this report.
The principal licensee repre-
sentatives were identified in Section II-C of this report.
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Several licensee and' subcontractor personnel, present and former workers,
at the Shoreham site were interviewed by the NRC in investigating the
allegations contained herein.
In order to protect the identity of those
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individuals, alphabetic designations have been assigned to individuals
noted within the context of the report only when such designations are
required in order to differentiate between the statements of one or more
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of the individuals. Otherwise, descriptive designations (e.g. QC inspector,
welder, etc.) are used.
Throughout the investigation, sources of information were not identified
by name to persons being interviewed unless (a) such person was identified
by another independent document or person other than the source or (b)
the person being interviewed independently acknowledged the identity of
the source to the NRC. All' individuals interviewed were notified of the
voluntary nat.ure of the interview, the right to have another person of
their choice present during the interview, and the confidentiality provi-
sions of tMs investigation.
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0.
NRC Investigation Findings and Conclusions Related to the Allegations
1.
Allegation No. 1
a.
Allegation
A random visual inspection of the Main Steam Line System (N-11)
revealed cracks which had to be repaired.
No further inspections
of the N-11 System have been undertaken, and it is alleged that
there are many other cracks in the system.
It was further
alleged that the entire N-11 System may be unfit and may have
to be repaired or replaced.
b.
NRC Investigation Findings
NRC investigators identified the extent of the N-11 System
referred to in the allegation by a review of all of the N-11
System isometric drawings, including a review of the history of
the piping from the steel mill to site ecection.
QA documents
on pipe irregularities were also reviewed as well as an inspection
of the piping itself.
The subject piping is that piping which carries main steam from
the isolation valve outside of Primary Containment to the Main
Steam Stop Valves for the Turbine.
This pipe is 24" 0.D., 900
psig rated SA-106, Grade B seamless carbon steel material
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obtained for spool piece fabrication by DRAVO from U. S.
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Steel.
The piping system was designed by S&W to ASME Section
III, Class 2 requirements.
The site welding was performed by
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COURTER with inspections by COURTER and S&W surveillance in-
spection groups.
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The NRC noted that manufacturing linear surface indications are
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to be expected in pipe of this large a diameter and these
indications were acknowledged along with acceptance and repair
methods in Paragraph 20 of the material specifications for the
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pipe. ASME NC-2550, 2551 and 2558 also indicate the acceptance
and repair methods for surface indications in this type of
pipe. NDE surface examination is not required by the code.
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The NRC noted that the 0.D. of the pipe was visually examined
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during site fabrication, prior to the installation of required
insulation material.
A total of fifty eight (58) COURTER
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Deficiency Correction Orders (DCOs) were written describing the
surface irregularities as linear indications.
These documents
were included into COURTER Nonconformance Reports (NRs) NR-466
and NR-466A.
The disposition and correction of the problem was
also documented in S&W Engineering and Design Coordination
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Report (E&DCR) F-18716 and F-22478.
The NRC determined that
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the disposition was in accordance with SA-106 and NC-2250 code
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requirements and included grinding to remove the vast majority
of the surface indications and repair welding of some defects
shown by ultrasonic testing (UT) to encroach on the minimum
wall dimensions.
NRC investigators interviewed the cognizant engineer who had
provided the disposition of E&DCR F-18716 and who was knowledge-
able of E&DCR F-22478.
The NRC also interviewed one of the
COURTER welders who worked on the repair of the linear indications.
Both individuals independently stated that the linear indications
identified were not cracks, but rather those types of metal
forming irregularities acknowledged in the material specification.
The S&W engineer indicated that the steam lines were completely
examined by visual methods and all linear indications were
dispositioned without any difficulties being encountered.
An NRC investigator visually examined all N-11 piping not
covered by insulation and found no signs of " linear indications"
but a large number of ground out areas as expected from the
DCOs.
One complete steam line had been previously inspected by
the NRC and this inspection was documented in NRC Inspection
Report No. 50-322/78-03. No items of noncompliance were identi-
fled in this area.
The NRC determined that the " cracks" ;a the main steam line as
reported in the allegation were in all probability a misinterpre-
tation of the normally occurring seams and laps found in material
of this kind and were not cracks, per se.
The disposition of
these visually observed linear indications more than satisfied
the minimum code requirements and no other deficiencies were
observed by the NRC in the N-11 System.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
1
'
2.
Allegation No. 2
a.
Allegation
Following concrete placements for the Reactor Pedestal and
Reactor Building Primary Containment Wall during the winter
months of 1973-1974, heaters used to maintain the required
curing temperatures were either not used, or when used were
permitted to go out for extended periods of time during the
night shifts.
It was also alleged that ice was allowed to form
on the concrete, a condition noticed when workers arrived in
the morning.
It was also alleged that the same conditions were
allowed to occur in the Radwaste Building during the winter
months of 1974-75 and 1975-76.
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b.
NRC Investigation Findings
'
The NRC investigators reviewed applicable sections of S&W
specifications and QC procedures, including American Concrete
Insititute (ACI) standards referenced in these specifications.
These, as well as other selected specifications, standards and
procedures reviewed during this investigation are referenced as
Exhibit A of this investigation report.
The documents reviewed established as a requirement for the
winter curing of concrete that the temperature be maintained at
40* F or higher for mass concrete (pours in excess of 30" in
thickness) and 45* F for other concrete placements (pours in
excess of 8" in thickness).
The time period for this temperature
maintenance ranged from 2 to 3 days depending upon the concrete's
'
exposure to the elements, with a maximum allowable drop of 20*
F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the removal of heat.
The NRC investigators irtterviewed several LILCO site QA personnel,
S&W QC personnel, S&W construction engineering and supervisory
personnel as well as ORAVO craft and supervisory personnel, all
of whom had been involved with concrete curing from 1973 through
1976.
From a review of procedures, documentation and these
interviews, the NRC was able to establish that the winter
control of curing temperatures was accomplished in the following
manner:
Concrete placements were contained within temporary enclo-
--
sures fabricated prior to placement of the concrete.
Heaters within the enclosure were provided.
These heaters
--
were maintained within the enclosures by laborers assigned
to each of the areas.
In the case of the failure of a
heater, it was either repaired immediately or replaced by
spare heaters provided for this purpose.
In the case of
damage to the enclosure itself, supervisory personnel were
notified immediately and crews were assembled to effect
the repairs.
Construction engineers took three (3) sets of temperature
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measurements, (a) outside ambient, (o) ambient within the
enclosure and (c) concrete surfaca temperatures.* These
temperatures were taken daily inc;. ding weekends at not
less than 6-hour intervals.
In addition, the outside
"These surface temperatures were considered to be conservative since the
actual bulk temperatures of the concrete pour would have been somewhat higher
than the surface temperature due to the heat of hydration released during the
curing process.
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ambient temperature was obtained daily from a thermometer
which indicated the maximum and minimum temperature ex-
perienced during that time period.
The daily minimum
concrete and outside ambient temperatures were recorded on
specially designated Curing Reports.
Construction engineers
also stated that during extremely cold weather, additional
temperature readings were frequently taken. Temperature
,
readings below the minimum specified were reported to
Field QC personnel.
i
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Field QC personnel performed periodic reviews of all
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curing records to assure that the temperatures of the
concrete met curing specification requirement:.
Nonconforming conditions were written up on Nonconformance
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and Disposition (N&D) reports for evaluation and disposition
by Engineering. Nonconforming temperatures reported by
Construction Engineering personnel were also written up on
N&D reports.
NRC investigators reviewed in detail over 150 written curing
reports for the time period from 1973 through 1976.
The areas
of the pours included concrete placements in the Reactor Pedestal,
the Reactor Building Primary and Secondary Walls anJ the Radwaste
Building.
During the course of this review, one (1) concrete
placement in the Reactor Secondary Wall (RS-4-12) was identified
i
with a recorded temperature of 38* F on December 3, 1974, the
second day of curing.
The NRC investigators reviewed in detail
all N&D reports for 1973 through 1976 written for failure to
maintain the required temperature during the curing period.
Six (6) N&D reports were found in this regard but it was noted
that Placement RS-4-12 had not been identified as nonconforming.
The dispositions of the six (6) N&Ds identified required the
l
removal of defective concrete if necessary and the testing of
the concrete with a Windsor Probe in order to demonstrate that
the compressive strength of the concrete conformed to the
'
construction specification.
The NRC identified no problems in
the disposition of these six (6) N&Ds.
The NRC investigators noted, however, that the failure to
identify the nonconformance of the RS-4-12 Placement with
respect to curing requirements and the failure to take necessary
corrective action was considered an item of noncompliance with
respect to 10 CFR 50, Appendix B, Criterion XVI which states,
in part, " Measures shall be established to assure that conditions
adverse to quality such as...nonconformance are promptly identified
and corrected."
(79-24-01)
!
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Prior to the completion of the investigation, the licensee
reviewed the curing reports for all concrete placements made
from November of 1973 through February of 1980 (2156 in number)
under winter conditions (818 pours) and summer conditions (1338
pours).
Eight (8) additional placements were identified where
either (a) no temperature was indicated for a given day (b)
temperatures were identified which did not meet specification.
The lowest temperature recorded during the time periods of the
referenced winter placements was 37* F.
The referenced place-
ments were identified on N&D No. 2877 and 2909 and Windsor
Probe tests were performed and witnessed by Field QC.
Two (2)
tests of three (3) shots each were made on each placement.
Calibration procedures and test results were reviewed by NRC
investigators and no irregularities were noted.
In each case,
the average of three (3) shots showed the compressive strength
of the placements in question to range from 5200 psi to 6900
psi, well in excess of the design strength of 3000 psi.
The
item of noncompliance was considered resolved and NRC investi-
gators noted that the minor deviations identified would only
retard the early strength developed by the concrete and not
cause any permanent damage, a conclusion further verified by
the Windsor Probe tests.
NRC investigators could find no instances where concrete had
been exposed to freezing temperatures, a condition that would
I
have been evident even after the fact as the freezing would
cause the surface of the concrete to chip and flake away.
Of
all the individuals interviewed, none could remember any circum-
stances relating to freezing conditions on the concrete and/or
forms.
One laborer foreman stated " Occasionally one (heater)
would fail but it would be repaired quickly.
Laborers would be
circulating constantly to check on the heaters." He also stated
that in critical Meas additional laborers were assigned over
and above those making the rounds in order to keep the heaters
in operation.
c.
NRC Conclusion
Although the NRC identified isolated instances where heaters
had failed, this condition was to be expected and was corrected
by licensee contractors in a timely manner.
The NRC investigation found no evidence and/or information to
substantiate this allegation.
3.
Allegation No. 3
a.
Allegation
Following concrete placements for the Reactor Pedestal and
Reactor Primary Containment Wall as well as concrete placements
in the Radwaste Building made from the end of 1973 through the
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beginning of 1976, forms were improperly stripped on the day
following the concrete placement instead of the required seven
<
(7) days after placement.
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b.
NRC Investication Findings
>
i
NRC investigators examined applicable S&W specifications and
ACI standards as referenced in Exhibit A of this report.
It
was noted that under ordinary conditions, when form removal is
not controlled by specification, wall forms may be removed
within 12 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following concrete placement.
S&W specifi-
cations state that wall forms may be removed when the concrete
has achieved a minimum compressive strength of 500 psi and that
this strength should be achieved within one (1) day.
,
.
l
NRC investigators examined several recordc of the 24-hour tests
i
of concrete cylinders of 3000 psi concrete.
These tests indicated
that a range of from 789 psi to 1497 psi and an average strength
of 1173 psi had been achieved after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
NRC investigators examined several curing reports and conducted
,
interviews with several S&W QC, construction engineering and
construction supervisory personnel, as well as DRAVO craft and
,
supervisory personnel involved in the piecement and stripping
of forework from 1973 through 1976.
Thase records and interviews
indicated that wall forms were removed after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and that
this time period was closely monitored by QC and engineering
personnel.
The NRC noted that there was no ACI requirement or specification
requiring these forms to remain in place for seven (7) days,
although on occasion, forms were kept on for periods in excess
of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement.
This latter case was usually
dictated by work or location requirements such as when forms
could not be removed from the lower areas of the Reactor Pedestal
due to space limitations in that area;
Although various indivi-
duals noted that there might have existed some engineering
request for this particular extended support, the NRC could not
confirm that fact by any written engineering documentation.
No
irregularities were noted in this area.
The NRC noted that although the alleger claimed that the seven
(7) day stripping requirement was part of his training as a
carpenter's apprentice, no substantiation of this fact could be
obtained in the interviews of various craft personnel. As noted
earlier, the seven (7) day requirement did not exist.
c.
NRC Conclusion
The NRC investigation found no evidence and/or information to
substantiate this allegation.
'
4
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4.
Allegation No. 4
a.
Allegation
,
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!
Following the stripping of forms from concrete placements for
the Reactor Pedestal and Primary Containment Wall, large cracks,
honeycombing deep enough to expose the rebar and possible
through-cracks (cracks appearing at the same azimuth location
on both sides of the wall) were all patched over with mortar
prior to inspection by QC.
It was alleged that the patching
was performed by laborers in order to complete the work before
QC had an opportunity to inspect the concrete surfaces and the
patch work was done improperly, covering the honeycomb or crack
with a loose mortar mixture.
It was further alleged that
patching in this fashion was a common, almost daily practice
during the time that the alleger worked on site from 1973
through 3976.
b.
NRC Investigation Findings
NRC investigators examined applicable S&W specifications, ACI
standards and procedures for the repair of concrete (see Exhibit
A). The NRC also examined in detail all N&D reports of concrete
related defects in the Reactor Support and Primary Containment
Walls covering the period in question (1973 through 1976) and
interviewed several S&W QC inspectors, construction engineers,
construction supervisors as well as DRAVO craft and supervisory
personnel involved in the stripping of concrete formwork and
concrete repair.
All of the individuals interviewed were emphatic in stating
that the concrete repairs could not have been performed by
laborers. .The NRC noted that repair work of this type was under
the jurisdiction and contract of the cement finishers and that
the assignment of this work to laborers, or any attempt on the
part of laborers to perform this work, would in all probability
have resulted in a jurisdictional dispute which in turn would
have caused the job to be shut down by the involved unions.
Although the NRC realized the possibility of these conditions
and questioned the alleger if possibly he had meant the masons
.
(cement finishers) instead of the laborers, the alleger insisted
that it was the laborers and not the masons who had performed
the unauthorized repairs.
S&W QC personnel informed the NRC that they were required to
inspect all concrete surfaces after stripping and that they had
all been given verbal instructions to perform the inspection
within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the forms had baan removed.
QC inspectors
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stated that due to the nature of the repair work and mortar
i
used, any attempt at an unauthorized repair would " stick out
like a sore thumb" and lead the inspector to chip into the
patch in order to determine if a significant problem existed.
All personnel interviewed confirmed the repair of any honeycomb
or cracks prior to QC inspection would have been obvious to
'
anyone experienced in concrete work because of the difference
in surface color and texture between the poured concrete and
the patched area.
This was later confirmed by NRC investigators
as they examined various concrete pours throughout the plant.
Investigation of the aforementioned concrete related N&D reports
'
indicated that a report had been written for any honeycomb
which exposed rebar to one half of its diameter. A review of
the disposition of the N&D reports indicated that they included
a detailed repair procedure approved by Engineering.
The
repairs were inspected throughout by QC inspectors in order to
insure the removal of all defective material down to sound
concrete and subsequent repair in accordance with the specified
repair procedure.
Defects which did not expose the rebar
within the concrete were considered to be surface defects and
although not requiring a specific N&D report, were repaired
under QC supervision in accordance with ACI-301 and utilizing a
special concrete bonding agent.
The above repair requirements were confirmed by interviews with
involved cement finishers who stated "(There was) no way that
repair work could have been done without QC seeing it as soon
as the forms were raised. QC would be all over it."
Another
cement finisher stated "We won't touch a thing until QC has
looked at it. We never do any repair work on our own.
watches everything, how the mortar is mixed, placed and set -
everything."
The NRC also noted through its interviews of several involved
personnel and related N&D reports that through-cracks were
unlikely due to the amount of rebar and due to concrete pouring
,
techniques. No through cracks were identified at the Shoreham
'
site in the areas examined.
c.
NRC Conclusion
The NRC investigation found no evidence and/or information to
-
substantiate this allegation.
!
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5.
Allegation No. 5
a.
Allegation
Cadwelds of the rebar in the concrete located in the Reactor
Building were never x rayed and were in some cases found by the
alleger to be loose.
It was further alleged that several loose
cadwelds were found in the Reactor Building Outer Wall (Secondary
Containment).
b.
NRC Investigation Findings
NRC investigators examined applicable S&W specifications,
General Procedures and QC procedures for cadwelding (see Exhibit
A). These documents require that a specific number be assigned
to each cadweld and this number is stamped on the sleeve of the
individual cadweld. Each cadweld is subsequently inspected by
QC and marked to identify it as either satisfactory or unsatis-
factory and the sleeve number, welders symbol and result of the
final inspection are marked on a Cadweld Control Record.
In
addition to the inspection of completed cadwelds, QC is required
to monitor in process cadwelding activities on a random basis.
The location of all cadweld splices are noted on drawings by
Field QC and these drawings are maintained in the QC file.
NRC
investigators noted no irregularities or deficiencies in these
areas.
NRC investigators interviewed QC inspectors who had performed
inspections of cadwelding during 1973 through 1976.
It was
noted that each individual interviewed stated independently
that they had inspected each completed cadweld in addition to
pet .'orming several in process. inspections on a random selection
af cadwelos throughout the time period in questions. The NRC
noted that problems identified were infrequent and when identified
were corrected in accordance with accepted procedures.
The NRC
also noted that although no x-rays of cadwelding was required,
the integrity of the cadwelds could be determined satisfactorily
by mechanical and visual means. The NRC also determined that
the control, inspection and documentation procedures made it
unlikely that a loose cadweld would have been missed.
General Procedure W-300 provides for protective measures to be
taken if cadwelding which is in process cannot be completed by
the end of the shift. At first, it appeared that perhaps the
alleger may have observed a partially completed cadweld left
for completion on the next shift and assumed that it had been
completed and accepted.
This assumption had to be discounted
,
as a possible explanation for the alleger's observation since
l
it was determined that such occasions were infrequent and the
'
cadweld would have been wrapped in plastic clearly identifying
it as "in process" and incomplete.
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c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
6.
Allegation No. 6
a.
Allegation
Rubber water stops between concrete layers in the Radwaste
Building were not installed properly (not sealed or nailed to
keys) and sometimes omitted entirely.
b.
NRC Investigation Findings
NRC investigators examined applicable S&W specifications, and
procedures for preplacement inspections i.e., inspections
performed prior to the placing of concrete (sco Exhibit A).
These documents require that prior to release for concrete
placement, the Field QC inspector shall complete the preplacement
inspection portion of the Field Data Sheet and sign the " Release
for Pour" block of the Concrete Pour Card. The "Preplacement
Inspection" portion of the Field Data Sheet includes waterstop
installation as one of the items to be inspected.
NRC investigators examined several Field Data Sheets and Concrete
Pour Cards for Radwaste Building concrete placements for 1973
through 1976, the period of employment of the alleger.
The NRC
identified no deficiencies or irregularities in this area as
all waterstop inspections had been performed as required and
the pour cards had been properly signed by QC.
In order to confirm these findings, NRC investigators interviewed
several S&W QC inspectors, construction engineers and construction
i
super'.isors, as well as DRAVO craft personnel and supervisors.
All of the individuals interviewed had been directly involved
in the installation, supervision of installation and inspection
'
of waterstops in the Radwaste Building. The NRC noted that none
of the individuals interviewed could recall any problem with
the installation of waterstops.
Craft personnel described the
method of sealing the joints as well as methods of holding the
waterstops in position using wooden blocks and wedges.
These
individuals also denied the use of any nails for attaching
waterstops. The NRC also noted that training had been given in
this area prohibiting the use of nails. QC personnel stated
that the waterstop installation for each concrete placement was
checked against the appropriate construction drawings as part
of the preplacement inspection in the same manner as other
embedments.
The NRC noted that several craft individuals
expressed mixed frustrations at times because of the several QC
24
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inspections which had to be performed as the overall concrete
placement operation progressed.
None of the individuals,
however, reported any irregularities in these operations whether
they pertained to water stops or other involved inspection
criteria.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
7.
Allegation No. 7
a.
Allegation
The alleger stated that as a carpenter he had been permitted to
weld studs to embedment plates used for pipe supports located
in the North wall of the Radwaste Building.
It is further
alleged that the welding was allowed even though the alleger
had failed to pass the welding qualification test seven (7)
times. The alleger also stated that the work was ordered by a
carpenter foreman who provided him (the alleger) with the
needed welding rod.
b.
NRC Investigation Findings
NRC investigators examined the construction drawings (FC-25F-6
and FC-25K-6) which show the wall elevations and details of the
Radwaste Building in the area described by the alleger.
Drawing
FC-25F-6 depicts the "V" line wall as the North wall.
The NRC
noted that the drawings do not specify any cmbedment plates to
be located in the Parth wall.
NRC invest'igators vis.
/ examined the North wall of the
Radwaste Building and a; adjacent walls and surrounding areas
and noted only three (3) locations where embedments were required,
two (2) were for waste treatment equipment and one (1) was for
a roll-up door.
The NRC noted that there appeared to be no
pipe support embedments on the North wall of the Radwaste
Building.
Further investigation of the Radwaste Building
revealed that pipe support embedments were used very sparingly
in the entire building and that most of the pipe supports in
the Radwaste Building were of the concrete expansion anchor
type.
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The NRC investigators reviewed the quality assurance program in
this area and noted that embedments were normally prefabricated
in shops adjacent to the construction area.
The embedments
were made of structural shapes such as plates, channels or
angles and manufactured studs were welded in rows to these
shapes.
The NRC noted that the welding was performed with a
" gun" which secures the stud and welds it under controlled
electrical conditions.
These controlled electrical conditions
provide a fairly uniform and repeatable weld.
In contrast, a
manually performed weld on studs of this relatively small
diameter would be extremely difficult to make in a uniform
manner even by an experienced welder much less by an individual
who could not pass the welding test.
The NRC noted that the quality assurance program not only
limited the number of people authorized to perform this welding
but also limited the number of people authorized to receive
welding rod and to sign the welding rod withdrawal form.
From
the standpoint of welder qualification, a review of all appli-
cable records and interviews with several DRAVO craft and
supervisory personnel indicated that (a) the number of qualified
carpenter / welders was very limited,* (b) very few carpenters
were ever selected to take the test and (c) an individual could
only fail the test twice, for if he could not pass it on the
second attempt, he was not allowed to take the test again,
The
NRC was also able to determine that the alleger was never
selected to take the welders test and consequently could not
have failed it one time much less seven (7) times as alleged.
From the standpoint of weld red issue, the NRC noted that the
quality assurance system closely controlled the issue of welding
i
materials to qualified personnel only.
The contractor involved
in these areas had only four (4) indi <iduals authorized by
letter to sign welding material withdrcwal slips.
The issue of
welding material was controlled by an irdependent group who,
j
without proper authorization, would not issue welding materials.
The NRC noted that the signature authorizing the withdrawal of
welding materials must be authenticated.
This was considered
important due to the fact that the carpenter foreman who al-
1egedly ordered the unauthorized welding and who allegedly
1
provided the weldir.g material was not authorized to withuraw
the material.
t
"only th T een (13) carpenters had been qualified in the past seven (7) y rs
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The NRC noted, therefore, that in addition to the fact that
there were no embedment plates used to hold pipes on the North
wall of the Radwaste Building, the alleger was not selected to
take the welding test, could not have failed it seven (7)
times, would have had difficulty obtaining welding rod because
he was unqualified and finally, determined that it was unlikely
he received welding material from a foreman who was not authorized
to sign weld rod withdrawal slips.
!
Ir order to further confirm the above findings, the NRC noted
that the Radwaste Building was designated as a Seismic Category
I structure, meaning that the quality assurance program applied
for safety related structures would require a "preplacement
inspection" for every concrete placement performed. 'This item
i
was documented on Field Data Sheets (Form T-S-31) and reviewed
by the NRC.
One of the attributes requiring quality control
inspectors sign-off was "Embedments".
The NRC interviewed five
i
(5) of the original QC inspectors for the Radwaste Building who
stated that all embedments were visually inspected for location,
i
conformance to drawing details, and restraint to avoid movement
!
during the actual placement of concrete.
Although interviewed
individually, all of the QC inspectors independ-ntly agreed
that a manually welded embedment would be readily :esognizable
and would have been immediately questioned.
To the best of
their knowledge no manually welded embedments were ever noted.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
'
8.
Allegation No. 8
a.
Allegation ~
The alleger stated that threaded tie rods were used as form
ties for the Reactor Pedestal along with she-bolts attached to
the rods to hold the forms in place.
It was further alleged
that whc.7 the she-bolts were removed, in many cases the threaded
rods would slide out of the concrete and a small patch would be
j
put on the hole leaving a void in the center of the concrete.
i
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In some cases, it was alleged that when the she-bolts could not
j
be removed at one end, the entire tie rod was pulled through
'
the concrete pulling a large amount of concrete off the pedestal
wall.
It was alleged that rods were pulled through the concrete
approximately twenty (20) to fifty (50) times in this fashion.
,
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b.
NRC Investigation Findings
NRC investigators examined several slides showing the actual
concrete forms in various stages of installation for concrete
placement for the Reactor Pedestal.
The NRC also interviewed
several QC and construction personnel in order to obtain infor-
mation concerning the use of threaded bolts for form ties.
The
information obtained indicated that in general, standard manu-
factured (Williams) form ties and she-bolts were used.
Although
threaded rods and she-bolts may have been used in certain
locations where the standard form ties did not fit the required
configuration, interviews with the above referenced individuals
could not determine these locations exactly.
The NRC noted
that either type of tie rod was acceptable, hence the matter
was not pursued further.
The MRC also noted that the alleger's statement that the threaded
rod would slide out of the concrete when the forms were stripped
appeared to indicate that the rods were installed in sleeves, a
fact which the alleger denied, stating that threaded rods not
in sleeves were pulled from the concrete after the concrete had
set. This was in apparent conflict with all of the individuals
interviewed who stated that even when threaded rods were used,
they were not in sleeves as the alleger stated but that they
definitely remained in the concrete after the forms were stripped,
ir. conflict with the alleger's statement.
l
The NRC did not attempt to pursue the matter further in order
to resolve the conflict due to the fact that (a) either method
of installation (with or without sleeves) was acceptable in the
Reactor Pedestal and (b) if the rods were installed without
sleeves as stated emphatically by the alleger, it would have
been physically impossible to remove them from the concrete
once it was set.
The NRC determined that the alleger's state-
ment that tie rods without sleeves were pulled out of the
concrete could not be considered as credible.
The NRC also
noted that had sleeves been used, patching the holes would not
have affected the structural integrity of the Reactor Pedestal,
nor was the Reactor Pedestal designed to maintain airtight
integrity.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
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_
- - - -
-
,
- - , - -
r
~
w+,
. _ _ _ .
_ _ .
__.
- _ - _ _
_
_
.
.
9.
Allegation No. 9
a.
Allegation
Several through-cracks were observed in the Turbine Building
wall that separates it from the Reactor Building.
It was
further alleged that the cracks were so wide one could see
through to the other side of the wall.
b.
NRC Investigation Findings
The NRC noted that although the Turbine Building has a sheet
metal roof and upper wall which are designed to blow off during
a design basis tornado, the overall Turbine Building is not
seismically designed nor is any credit taken for leak tightness.
The design of the Turbine Building Ventilation System calls for
it to exhaust air from lesser to progressively greater potentially
contaminated areas to a monitored final exhaust.
Thus even if
a crack did exis t, its significance would be minimal. The NRC
noted further ttat there was no common wall between the Turbine
Building and the Reactor Building so a crack in the Turbine
Building wall wo11d not mean a crack in the Reactor Building.
In addition, any crack large enough to see through would be
difficult to patch on any permanent basis without the crack
opening up periodically.
On February 21, 1980, the NRC inspected the entire South wall
of the Turbine Building, the wall facing the Reactor Building.
Although several temporary openings were noted (cpenings scheduled
to be closed at a later date), no significant cracks were
identified.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
10.
Allegation No. 10
a.
Allegation
During the first three weeks of February 1979, welders were
asking for ER-309 weld rod in lieu of the ER-308 and/or ER-316
weld rod specified on their weld rod requisitions for scheduled
work oa dissimilar metal welds. When refused by the weld rod
clerk due to the improper designation on the weld rod requisition,
i
the welders stated that it was too cold to return to have the
I
requisition corrected to the required ER-309 and that the
j
l
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1
-
.
ER-308 and/or ER-316 would be utilized in its place.
It was
!
alleged that these instances occurred two to three times each
l
day during the three week period in February of 1979.
The systems alleged to have been involved were the Control Rod
Drive System at Elevation 7C' in the Reactor Building; the Flow
and Pressure Instrumentation Lines in the T-?8 Primary Control /At-
mospheric Control System, the G-33 Reactor Water Clean-Up
System; and the G-41 Fuel Pool Cooling System.
b.
NRC Investigation Findings
NRC investigators reviewed in detail the flow diagrams of the
four (4) alleged systems involved in the allegation as well as
seven (7) additional systems.
These flow diagrams depict
material specification changes and pipe line numbers which can
be traced to a specific weld. This review identified (12)
The document packages for each of
these welds were examined to verify that ER-309 weld rod was,
in fact, used to make the specified weids.
The result of this
examination revealed that one of the welds (Weld Joint Number
1G-33-WD9-3-1-FW "0") was welded on May 19, 1979 using ER-308
material.
No utilization of ER-316 was identified during this
review.
The licensee was informed that 10 CFR 50, Appendix B, Criterion
V requires in part, that " Activities affecting quality...shall
be accomplished in accordance with these instructions, procedures,
or drawings".
The COURTER and CO. Welding Procedure Specifi-
cation NW-100-01-08011AA, Revision 0, specifies that the filler
metal for this weld be AWS Class ER-309.
Contrary to the
foregoing, Wald Material Requisition No. 55780 was issued to
weld joint 1G-33-WD9-3-1-FW "D" specifying ER-308 material.
This was considered an item of noncompliance (79-24-02).
Based on this finding, two (2) separate and distinct reviews
were initiated by ooth the NRC and the licensee. All Category I
piping isometric drawings were reviewed and all dissimilar
l
metal welds were identified.
In addition, all Task Engineering
Component Checklists were checked and it was found that all
dissimilar metal welds were listed.
A cross check of these two
sources of information indicated that all dissimilar metal
welds had been identified. Four hundred and twenty two (422)
dissimilar metal welds were identified and cross checked in
this manner
The document packages for each of the 422 dis-
dicil: metal welds were examined in order to verify that
ER-309 material had been used as required.
The results of this
examination identified one additional weld (Weld Joint Number
30
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.
.
_ _ _
____ -. .
_ _ _ _ . - - _________ ___
-
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.
M50-CW3-3-99) welded on April 12, 1979 that also had been
welded utilizing ER-308 material.
None of the dissimilar metal
welds were identified as involving ER-316 material.
As an independent verification of the above findings, and due
to the fact that ER-308 material was found in two (2) of the
422 welds examined, NRC investigators listed all of the identi-
fiable ER-308 weld rod issues for the month of February 1979
from the weld rod control log.
This log listed the date and
use for each wald rod issue.
The weld rod issues were cross
referenced against the appropriate piping isometric drawing
which would identify any dissimilar metal welds.
Even if the
pipe line d'd not represent a dissimilar metal weld joint, on
isometric crawings which show more than one pipe line number,
any dissi.nilar metal weld depicted on the drawing was examined
in order to verify that ER-309 was in fact used. This independent
verification of over six hundred (600) log entries dispositioned
indicated no further discrepancies.
Independent cross checks
were also made by the NRC investigators on the completeness of
the dissimilar weld ter, ting and no discrepancies were identified
in this area.
NRC investigators interviewed all available principals involved
in the above referenced item of noncompliance.
Interviewees
included the Assistant Construction Manager, the welders who
made the welds, involved weld rod checks, welding supervisors,
area supervisors, assistant area supervisors and deputy foremen.
As a result of these interviews, the NRC was able to determine
that the misuse of ER-308 weld rod materials were relatively
isolated occurrences rather than any significant breakdown in
the licensee's construction QC program. The problem appeared to
stem from paperwork errors related to the similarity of procedure
numbers (08011AA for ER-309 and 0811AA for ER-308) and not a
deliberate attempt by the welder to utilize the improper weld
rod.
The two welds in question were cut from the system in the
presence of the NRC on March 4 and 5, 1980.
The removed welds
were bisected and analyzed independently by both the licensee
and the NRC to confirm the composition of the weld rod material
contained therein.
By chemical analysis, performed at the
Franklin Research Center, the NRC determined that the weld
material was in fact ER-308. Similar results were obtained by
the licensee using spectrographic and chemical analyses.
The NRC determined that all welding performed on the control
rod drive mechanisms was performed by Reactor Controls, Inc.
(RCI) which maintained its own weld rod issue facilities,
31
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_
__
__
,
_
_ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
,
totally separate from weld rod issues of COURTER for whom the
alleger was employed.
It was impossible therefore for the
alleger to hava dispensed weld rod utilized for the control rod
drive mechanism.
This system was included nonetheless in the
NRC review and no irregularities were noted.
NRC investigators noted that the identification of the two
welds containing the improper weld material while constituting
an item of noncompliance, did not substantiate the related al-
legation due to substantial differences in time frame, scope,
causality and magnitude. The NRC also noted that the use of
ER-308 in place of ER-309, while not in compliance with specifi-
cations, would not have a significant adverse affect on the
structural integrity of the two welds in question, a conclusion
confirmed by the Franklin Research Center which stated that
both welds were sound and that they were deposited without
excessive base metal dilution.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
11.
Allegation No. 11
a.
Allegation
Although taught that only E-7018 electrodes were to be used at
the Shoreham site, E-6018 electrodes were issued to a single
welder who continually drew weld wire separately from other
welders. It was further alleged that the above practice was
performed in order to covertly use substandard materials.
b.
NRC Investigation Findings
NOTE:
The NRC noted that the ASME Code,Section II C,
SFA-5.1 does not list an E-6018 electrode. It was
assumed that the alleger meant E-6010 electeddes
which are listed in the ASME Code and are in common
use within the industry.
The NRC conducted several interviews with S&W QC inspectors,
construction supervisors, weld rod control supervisors and weld
rod issue clerks.
These interviews disclosed that the only
E-6010 electrodes used at the Shoreham site were utilized in
connection with the carbon dioxide fire system installed by the
C. P. Bennett Company.
The NRC noted that extremely rigid
32
.
.
controls had been imposed on the issue, use, handling and
return of the E-6010 electrodes in order to assure that their
use was limited only to this fire system. Each weld electrode
issue was counted and verified by the rod issue clerk, the
welder, a LILCO QC representative and a representative of C. P.
Bennett.
A similar procedure was followed when the unused weld
electrode and weld electrode stubs (used electrode) were returned.
A LILCO Work Directive (WD-PS-4894) directed the Bennett Company
to hire "...one Quality Control Inspector. Inspector's sole
responsibility will be to ensure that the E-6010 Series Welding
Electrode is used exclusively on the CO2 System pipe welding."
NRC investigators conducted an additional interview with the C.
P. Bennett General Foreman in order to confirm the above re-
ferenced procedures. No discrepancies were noted.
The General
Foreman stated that possibly no more than two (2) 50 pound cans
were used for the CO System and that only three (3) employees
2
were authorized to sign for the E-6010 electrode issue.
NRC investigators noted that the allegation was presented in
such a manner as to indicate that the licensee was covertly
attempting to introduce substandard material into the con-
struction project. Coworkers of the alleger indicated that this
was not credible since all involved individuals (including the
a11eger) were carefully informed that the strict procedure was
required in order to comply with the increased QC requirement.
In fact, one supervisor stated that the alleger was fully aware
of the purpose of E-6010 electrode and he (alleger) complained
that the procedures were too strict.
The NRC did not pursue
these conflicts further as it did not affect the evaluation of
the validity of the allegation.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
12.
Allegation No. 12
a.
Allegation
A large scale repair of a 10 to 20 foot crack was performed on
the feedwater condenser jacket by a REGOR boilermaker instead
of the usual COURTER and CO. steamfitter in order to avoid
having the crack reported to COURTER QA personnel which would
have raised an issue as to the integrity of the entire jacket.
It was also alleged that an exceedingly large quantity of weld
l
electrodes had been drawn in order to effect this repair.
33
__
,
.
.
b.
NRC Investigation Findings
NOTE:
The NRC was informed by the alleger of the welder's
symbol and the Weld Rod Requisition Number, which was
170376.
An NRC review of plant equipment disclosed that what was referred
,
to as the "feedwater condenser" was in fact the Main Turbine
Condenser. This condenser is located in the Turbine Building
and parts are located at the 63 foot level where the alleged
irregularity occurred.
In reviewing the time period in question,
the NRC noted that the condenser was hydrostatically tested and
a leak was found on or about August 25-28, 1978.
The leak was
located in the general area of the interconnect between the
'
condenser shells. Weld Rod Requisition Number 170376 was
confirmed by the NRC to have been issued on August 29, 1978 to
the welder identified by the alleger. The requisition was for
100 each, 3/32" diameter, E-7018 welding elect-odes for " repair
weld condenser."
The NRC review indicated that the 3/8" fillet weld on the
interconnect had been leaking and approximately 10 linear feet
of this weld had been removed in order to repair the leak. The
NRC noted that there was no " crack" in the strict sense of the
word. Due to the fact that the area which was leaking was
inaccessible from the outside of the interconnect and that the
exact location of the leak could not be pinpointed, the weld in
the immediate area of the leak as well as additional weld
material on either side was removed by air carbon arc gouging.
It was noted that the removal of the weld by air carbon arc
gouging would also remove some of the base material therefore
adding to the volume of weld metal needed to replace the weld.
The rewelding procedure would involve a minimum weld size from
1/2" to S/8" instead of the original 3/8" fillet weld.
NRC investigators performed calculations in order to determine
the number of 3/32" diameter welding rods needed to fill a 3/8"
X 10 foot * weld groove. The NRC determined that the issuance of
100 each, 3/32" diameter electrodes was not excessive relative
to the volume of weld deposited in the prepared grove.
^ Includes the cutting and repair of various stiffners which had to be removed
in order to gain access to the leaking area
34
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.
.
-
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__.
.
_ _ - _ _ _
.
.
!
i
The NRC noted that since REGOR was contractually responsible
for the work on the condenser, they were assigned to perform
the repair work and that the job would not have been assigned
to COURTER in any event.
The NRC noted no deficiencies and/or
irregularities in the repair operation.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
13.
Allegation No. 13
a.
Allegation
Salt water is seeping through the Secondary Containment Wall at
the 8' level and around-the-clock efforts are being undertaken
to pump the water out.
It was further alleged that the seepage
occurred due to LILCO's improper estimation of the depth of the
water table under the plant.
b.
NRC Investigation Findings
,
NRC investigators questioned several individuals working at the
i
Shoreham site concerning the allegation and were unable to
j
obtain any confirmation that any seepage had occurred.
The NRC
reviewed construction descriptions of the various waterproofing
methods and other means of preventing water seepage and deter-
mined that the possibility of seepage in this area was highly
unlikely.
In order to confirm the above. finding, the NRC personally
examined the areas in question during high tide on January 31,
1980, a date where according to local marina owners, tides were
expected to be their highest due to the full moon.
The NRC
noted that there was absolutely no indication of leakage or any
signs (e.g., water marks) that seepage had occurred in the
past.
In fact, the NRC noted that dust accumulations ia some
parts of the 8' level floors of the Secondary Containment
indicated that the area had not seen water for some time.
Interviews by the NRC of various LILCO personnel indicated that
on infrequent occasions in the past that some water might have
reached the 8' level from within containment due to leakage of
the temporary drain system or leaks from various hydrotests
above that level within the plant but that to the best of their
knowledge, no through-wall seepage problems had occurred in
this area.
,
35
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.
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..
_ - .
- .
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_
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,
1
i
l
Interviews by the NRC of various S&W construction personnel
confirmed the above observations but added that a minor problem
had been experienced in the past with rainwater leaking onto
the 8' level floor through an unsealed spare penetration during
periods of heavy and sustained rainfall. The water wcs not
extensive and merely flowed to one of the several permanent
sumps located on that level for such purposes. S&W personnel
stated that when sump pumps were operated, the water from the
sump was held up for chemical analysis and filtering prior to
discharge to the store drain system in accordance with EPA
guidelines. The NRC Resident Inspector was present at this
penetration during a recent heavy rainstorm and no leakage
>
problems were identified. S&W representatives stated that when
the pumps had to be operated, they were operated by a repre-
sentative of the operating engineers' union in accordance with
union agreements and this condition would in all probability
remain in effect until the pumps were transferred from the
construction to the start-up group at which time automatically
,
operating systems would be employed.
,
From the standpoint of other pump opceations, the NRC noted
<
that pumps outside of Secondary Containment were merely pumping
i
water from the temporary drain system within the building into
exterior drains and no irregularities were observed with respect
i
to this practice.
The pumping operation was due to be gradually
phased out as the permanent drains within the building were
integrated into the overall drainage system. The NRC also noted
that extensive pumping operations were undertaken when the
concrete was initially poured several years ago but that this
t
was part of the normal dewatering operations conducted during
'
construction work of this kind and did not indicate any seepage
or water leakage problems or problems with any codes or other
requirements.
'
c.
NRC Conclusion
,
The NRC found no evidence and/or information to substantiate
this allegation.
14.
Allegation No. 14
.
a.
Allegation
Stone and Webster (S&W) lost its general contractor duties when
it repeatedly complained to LILCO about the incompetence and
corrupt practices of its contractors, such as COURTER and
j
REGOR, which LILCO insisted on using.
In August of 1978, S&W
1
was relegated to design, drafting and general QA duties while a
dummy corporation, UNICO, assumed QC duties, and COURTER QA
personnel assumed the QA field inspection duties.
,
36
..
.-
,
.
. _ .
.
.-._ .. ---
- . -
.. .
. . _ _ _
. _ _ _ _ _ _
,
,
b.
NRC Investigation Findings
NRC investigators examined the various changes in the management
of the Shoreham project.
Among the items reviewed was a memoran-
dum dated March 8, 1977 which documented a meeting between
representatives of LILCO, S&W and the ASME Subcommittee on
i
Certification. The subject of the meeting was S&W's application
for NA and NPT Certificates of Authorization which would have
allowed S&W to perform ASME Code work at the Shoreham site.
The ASME Subcommittee agreed to grant the Certificates of
Authorization subject to certain conditions, among which was
the transfer of the contract between LILCO and COURTER and CO.
to a contract between S&W and COURTER and CO. This condition
was prompted by the fact that the ASME required QC operations
to be performed by the actual contractor and not the subcontractor.
)
N L' investigators were informed that at this time LILCO was
considering changes in construction management, and in a memoren-
dum dated August 11, 1977 recommended that LILCO assume the
leading role in construction management with S&W retaining
responsibility for engineering and quality assurance.
As of
September 12, 1977 LILCO did assume the leading role in construc-
tion management. This change was effected by having LILCO
1
assume leadership of the joint S&W/LILCO unified construction
team (UNICO) through the appointment of a LILCO Construction
Manager reporting to a LILCO Project Manager rather than the
S&W corporate construction organization.
LILCO also increased
its participation in the UNICO organization by the transfer of
a number of qualified construction supervisors to Shoreham from
other LILCO departments.
As part of this change, LILCO decided to retain the COURTER and
CO. contract directly rather than transfer it to S&W.
Since
COURTER was now the contractor, the ASME would not allow S&W to
perform the code work as either LILCO or COURTER had to obtain
the ASME Certificate of Authorization.
Therefore, COURTER was
directed to obtain the ASME Certificate and in order '- do so
was given the responsibility for quality assurance (or their
work on site.
The ASME transition date was January 1, 1978.
The only reference to any changes occurring in August of 1978
was a memo dated August 28, 1978 where some duplication in the
inspection of non-safety related mechanical equipment and
insulation was corrected by transferring the responsibility
from the Construction Inspection Program (CIP) and FQC to the
CIP alone.
There were no complaints involved in the memo, only
'
l
non-safety related equipment was involved and the NRC determined
l
that there was no problem or irregularity associated with the
transfer.
37
_
._
.
The NRC noted that UNICO was formed prior to March of 1977. The
change of QC fucctions from S&W to COURTER was occasioned
primarily as a result of ASME requirements and not due to any
actions by S&W and/or COURTER.
NRC investigators also interviewed
several individuals involved in the S&W QC and COURTER QC
organizations and the referenced transition and were not able
to identify irregularities or deficiencies, either past or
present, resulting from this transfer of responsibility.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
15.
Allegation No. 15
a.
Allegation
At least seven (7) major failures of hydroflushes of the Primary
Closed Loop Piping System have occurred and during the flushing
'
of the system on June 15, 1979, a gross failure of the primary
system occurred involving valves popping and a section of pipe
being thrown fifty (50) feet into the air.
It was also alleged
that the hydrostatic test of the system in September of 1979
could not have been valid, since it occurred too soon after the
gross failure in June of 1979 to have permitted proper shutdown
and repair of the system.
b.
NRC Investigation Findings
The NRC reviewed all possible primary system hydrotesting
records and interviewed several involved personnel and could
not identify any major failures of the Primary Closed Loop
Piping System during the time period up through and including
June of 1979.
Examining the time frame around the alleged June
15, 1979 date, the NRC noted that on June 13, 1979, one minor
incident was identified where during the flush of the Core
Spray System, a temporary gasket in a bc1ted joint failed and
sprayed water over a large area.
There were no major failures
in the system, no valves failed nor were pipes thrown into the
air.
This review was documented in NRC Inspection Report No.
50-322/79-20.
The NRC investigators noted that the primary system hydrostatic
1
test was not conducted until September 21-22, 1979.
The NRC
reviewed all test procedures prior to the test, was present and
witnessed the actual performance of this test, and independently
38
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, ---
. ._
_ _ .
_ - - _ _ _ _
_
.
.
.
verified the acceptability of the test results.
The NRC noted
no gross failures and the details of the test were documented
in NRC Inspection Report No. 50-322/79-15.
The NRC reviewed documents referred to them by the alleger and
found them to be outdated copies of normal check off sheets for
the hydrotests which he (the alleger) had taken off site prior
to his termination in May of 1979.
The NRC was unable to
reconcile the alleger's claim of having seen the gross failure
(June 1979) since he had terminated one month prior to its
allegedly having occurred. The NRC was also unable to reconcile
the alleger's statement that exclusive of repairs it would have
taken 4 to 6 weeks to shut down from the alleged failed test
due to the fact that the shutdown operation can be performed in
a matter of hours or at most days, depending on the procedures
utilized and the system involved.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
16.
Allegation No. 16
a.
Allegation
The diffuser (outfall) pipes for the circulating water system
have never been properly anchored and due to the tidal action
in Long Island Sound, have shifted, broken and separated from
the line itself.
It was further alleged that a LILCO QA map
documented the separated pipe pieces located in the Sound.
b.
NRC Investigation Findings
The NRC investigators noted that a similar 411egation had been
made by a contractor employee in 1978 and had been investigated
by the NRC in October of 1978.
The results of this former
investigation are documented in NRC Inspection Report No.
50-322/78-16.
i
NRC investigators pursued this matter further and interviewed
various individuals associated with the placement and securing
of the Offshore Discharge and Diffuser Pipe System.
The NRC
was able to determine that the fiberglas pipe sections were
placed on the floor of the Sound and then covered with a uinimum
of 3 feet of crushed stone (approximately 1.5" in size) and
then covered with a layer of armour stone (6" to 2' in size).
The NRC identified the fact that while the outfall was being
placed, prior to securing the outermost sections with stone,
storms caused various sections to work loose and suffer some
39
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_ _ _ _ _ - _ _ _ _ _
.
.
damage.
A weekend storm of October 2-3, 1976 caused damage to
four (4) sections of the outfall,
This occurrence was covered
in N&D Report No. 1000.
Another storm from May 6 to 9,1977
caused damage to two (2) sections of the outfall, one of which
was ' replaced as documented in N&D Report No.1253.
In October
of 1977 an underwater inspection of the outfall verified that
it was secure but the inspection indicated minor damage to a
diffuser, a condition repaired and docun.ented in N&D Report No.
1466. The NRC identified no instance whereby secured sections
of the outfall had broken loose and separated from the system.
In attempting to determine the validity of the allegation with
respect to the map depicting the location of separated outfall
pieces, the NRC determined that a map of the outfall was po.ited
when the system was being placed and being secured by rock
The map and diagram indicated which sections had been covered
with the various sized rock and the flags indicated the lacation
of the barges containing the rock used to secure the pices and
'
not section of pipe which had broken loose.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
17. Allegation No.17
a.
Allegation
l
NDE technicians were not adequately qualified for the jobs they
were performing.
b.
NRC Investigation Findings *
NRC investigators examined prior NRC inspection reports for the
Shoreham site for the years of 1977, 1978 and 1979.
It was
noted that from January 1977 through June 1979, NRC inspectors
reviewed the qualification records and observed NDE technicians
performing tests during eight (8) inspections.
In addition, it
was noted that during welding inspections, NRC inspectors
- frequently include the inspection of the performance of nonde-
j
structive tests and also review the results of these tests,
'
observations that would not necessarily be reported unless
nononforming conditions were identified.
The NRC evaluation
indicated that no deficiencies in the qualifications or per-
'
formance of NDE technicians were identified during any of the
NRC inspections reviewed.
- Due to the fact that no specific NDE technicians were identified by the
alleger, the NRC evaluated this allegation as it pertained in general to the
overall construction operation.
40
.
.
.
During this particular investigation, NRC investigators examined
a random selection of experience, training and qualification
records of NDE technicians currently at the Snoreham site.
This examination showed the men in question to have been ade-
quately qualified for the level of performance for which they
are certified and to a degree commensurate with their responsi-
bilities.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
18.
Allegation No. 18
a.
Allegation
Large quantities of green dye used for dye penetrant testing
were being discharged by LILCO without proper approval and that
this green dye was visible on the "outake" canal and polluting
Wading River shellfish.
b.
NRC Investigation Findings
l
The NRC assumed that since there is no "outake" canal at the
Shoreham site, that the alleger was infact referring to the
intake canal.
The NRC noted that LILCO had discharged
green dye to the Sound and that this matter had been identified
.by the NRC and dccumented in NRC Inspection Report No. 50-322/78-16.
During that inspection, the NRC inspector observed the green
color of the water in the intake canal at the screen wall and
\\ at the storm drain discharge in the canal.
The NRC requested
1 identification of the substance and examination of the discharge
permit provision which allowed the discharge.
LILCO representa-
tives identified the material as a fluorescent dye and identified
the individual within the New York State Department of Environ-
mental Conservation (NYS-DEC) with whom approvals had been
coordinated.
NRC environmental inspectors were notified and
subsequent contacts with NYS-DEC verified their cognizance of
the discharges and their acceptability.
NRC investigators examined the intake canal and adjacent shore-
fronts on Long Island Sound, including the most susceptible
areas of Wading River, and found no visible evidence of green
dye.
c.
NRC Conclusion
.
The NRC found no evidence and/or information to substantiate
this allegation.
!
41
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19.
Allegation No. 19
.
!
a.
Allegation
Supervision of trade workers is inadequate and being performed
by unqualified individuals.
i
b.
NRC Investigation Findings *
!
During the course of this investigation, several construction
workers from various trades and crafts were interviewed privately
by NRC investigators.
During these interviews, selected workers
were asked their opinion not only of their own supervisors but
of other supervisors within their own craft.
The NRC noted
that the majority of workers believed their supervisors to be
qualified for their positions and in general providing an
!
adequate amount of supervision.
Although some workers did not
feel qualified or able to evaluate their supervisor's performance,
they did state that they did not have any problems in this area
at this time.
The NRC noted further that even in areas where
workers admitted to personal differences with their supervisors,
i
they still acknowledged their supervisor's ability to meet his
,
supervisory responsibility.
A random evaluation by the NRC of
various supervisor's qualification did not reveal any inadeca.cies.
!
1
In order to indirectly determine the adequacy of supervision on
site independent of workers interviews, NRC investigators
requested one of the contractors (COURTER) to provide an indi-
cation of the number supervisory and non-supervisory personnel
currently at the Shoreham site in construction related work
areas.
The NRC noted that the information provided indicated
that in the four construction areas reviewed (Radwaste, Reactor,
Instrumentation and Auxiliary / Yard Area), a supervisory individual
was provided for every 2.4 craft individuals.
Supervisory
personnel included Welding Department Supervisors, Deputy
Foremen, Area Foremen, General Foremen, Assistant Area Supervisors
and Area Supervisors.
If COURTER QC personnel were included,
there would be one (1) supervisor for every 1.9 workers.
The
NRC determined that this level of supervision appeared to be
commensurate with the extent of construction activities being
performed at the Shoreham site.
l
c.
NRC Conclusion
i
l
The NRC found no evidence and/or information to substantiate
this allegation.
"Due to the fact that no specific instances and/or individuals could be obtained
from the allegers, the NRC determined the validity of the allegation as it
pertained in general to the overall construction site.
42
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20.
Allegation No. 20
a.
Allegation
Qualifications and training of subcontractor personnel at the
Shoreham site is inadequate.
b.
NRC Investigation Findings
During the course of the investigation, several subcontractor
'
personnel were interviewed by the NRC.
During the course of
these interviews, individuals were informally questioned with
respect to their job responsibilities and past experience as
well as how various aspects of their particular jobs were
perfor:ned. The NRC noted that the workers interviewed appeared
to have a degree of knowledge (by experience and/or training)
commensurate with the job responsibilities given them, noting
also that this level of knowledge covered s wide area ranging
from the novice apprentice to the experienced journeyman.
Some
workers noted frustration in not being able to perform their
jobs as they were accustoraed due to the several QC checks which
'
were required and which would delay the job until the inspection
was performed and proper standards were met.
Although some
workers admitted not knowing all the standards in detail, they
]
stated that they had no problems in this area due to the fact
that their supervisors and QC inspectors would handle these
areas.
The NRC found no instance where a job requiring a high
degree of skill was performed by an individual not having the
qualifications and skills commensurate with the job.
The NRC also interviewed several QC inspectors and supervisory
personnel in a similar manner. as described above and were able
to determine that their knowledge of the appropriate standards
and procedural requirements was also commensurate with their
responsibilities.
No irregularities or deficiencies were
identified (see also Paragraph 17 of this section).
From the standpoint of the actual training of subcontractor
personnel by their own crafts, the NRC did not review the
actual apprenticeship program of the various crafts as this was
outside the purview of the NRC's responsibility.
The NRC did,
however, review the training provided by the subcontractors to
these individuals as it pertained to their activities and
responsibilities at the Shoreham site. The NRC reviewed a memo
by S&W to all subcontractors dated August 20, 1976 describing
the implementation of a site-wide training program, separate
43
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from other training requirements as described in the Field QC
Manual.
Each contractor was directed to provide a minimum
three (3) hour orientation program and to ensure that each new
employee attended the courses.
The NRC selected the Orientation
1
Manual for DRAVO and reviewed it in detail. No apparent defici-
encies were noted.
A check of an alphabetical listing of DRAVO
employees reflected the fact that all onsite employees were
recorded as having attending this particular training.
The NRC reviewed Orientation Manuals for other subcontractors
and determined that the DRAVO Manual was generally reflective
of all submitted manuals in terms of content and course design.
The NRC also conducted a random inspection of several of the
training records in various areas as given by various contractors.
For example, from April 26, 1977 through May 31, 1977 a one (1)
hour course was given several times on the installation and
inspection of wedge type anchor bolts which were installed in
concrete to secure various pipes and equipment. Approximately
660 workers were given this course over the time period stated
above.
Similar classes were noted in welding and other craft
activities on site.
The NRC was able to determine, therefore, that based on personnel
interviews and training records reviewed, that the training of
subcontractor personnel appeared to be adequate for their
duties at the Shoreham site.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
21.
Allegation No. 21
a.
Allegation
Workers who commenced the task of painting the inside of the
Reactor Primary Containment were not qualified.
It was further
alleged that an NRC inspection of worker qualifications resulted
in a majority of the workers being ordered off the job; however,
the substandard work that had been done to that point was
allowed to remain and was not inspected by the NRC inspector;
the remaining workers were ordered to complete the task on
overtime and on one occasion they worked a 30-hour shift while
on methedrine.
44
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b.
NRC Investigation Findings
NRC investigators noted that painting specifications, procedures
and records were reviewed, as well as an in progress inspection
performed, by an NRC inspector as documented in NRC Inspection
Report No. 50-322/79-20.
No items of noncompliance were identi-
fied by the NRC inspector and the performance of the work as
well as the QC inspection associated with it were considered to
be acceptable.
NRC investigators also reviewed all NRC inspection
reports for 1975 through 1979 and found no record of an NRC
inspector questioning painters qualifications at any time
during this period nor any report of painters being layed off
as a result of the NRC having questioned their qualifications.
The NRC interviewed S&W construction and QC personnel responsible
for painting as well as QC personnel working for KTA-TATOR
Associates, the consultant responsible for the inspection of
painting within the Suppression Poo1*.
The NRC noted that
during July through November of 1978, the painting of the
Suppression Pool required a large amount of overtime, with men
working 12-hour shifts, 7 days a week, using two (2) shifts per
day with a day off every two or three weeks.
The NRC could not
identify any 30-hour shifts worked at any time.
During this painting operation two (2) types of coating systems
were utilized in the suppression pool, an epoxy (K&L) system
above elevation 30 and an epoxy phenolic (Plasite) system t'elow
that elevation.
The NRC noted that painters were qualified
separately for each system in accordance with a proposed ASTM
qualification method.
Qualification for the Plasite system was
considerably more difficulty because of the coating system
itself as well as the use of a more complex qualification
panel.
A .large number of painters who had qualified on the K&L
system could not qualify on the Plasite system panel.
As the
work in other areas neared completion, the men who had qualified
for both system were retained while other painters with lesser
qualifications were layed off.
!
7 the Suppression Pool is the lhwei portion of the Reactor Primary Containment
45
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.
Individuals interviewed by the NRC stated that the most visible
effect of the long hours was a decrease in productivity. They
stated further that the effect on quality was not identifiable
and the reject rate was little if any greater.
The NRC noted
that the requi,? rents for *-ection and testing before, during
and after applicati;..
-3
-lficient to identify any decrease
in quality. During this investigation, NRC observation of
in progress painting showed no irregularities or deficiencies.
As mentioned earlier, 30-hour shifts could not be identified by
NRC investigators.
From the standpoint of the methedrine
allegedly used during this shift, the NRC found no indications
of drugs being used in this manner whether in the area of
painting or other construction areas covered in other aspects
of this investigation report.
Although the NRC was informed
that the labor problems engendered by the aforementioned layoffs
may have initiated this allegation, this matter was not pursued
inasmuch as problems were not identified with the painting
operation itself,
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
22.
Allegation No. 22
a.
Allegation
,
i
Tube support sheets in the condenser box were so misaligned
that titanium tubing which is supposed to fit loosely through
the support holes was often hammered or twisted to fit through
the sheets.
It was alleoed further that the damage was extensive
enough to cause
tit- to break with the possibility of a
radioactive spill.
b.
NRC Investigation Findings
The NRC noted that the " condenser box" or Main Surface Condenser
is not a safety-related unit, nor is it classified as an ASME
Code Vessel as the shell side is under vacuum.
The unit itself
is pre-assembled without the tubes, disassembled for shipment
to the site, where it is reassembled, welded and tubed.
This
particular condenser was designed and shop assembled by Inger-
soll-Rand (IR) in accordance with S&W Specification SH 1-6
dated June 16, 1969 and revised on August 15, 1969 and february
27, 1970.
The NRC noted that the original specification called
for SB111, Alloy CA706 (Cu-Ni) tubes but that the decign was
modified to improve water-side corrosion resistance Ly employing
ASTM:8338, Grade 2 welded titanium tubes.
I
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The NRC noted further that at the time of the material change
to the improved titanium tubes, assembly of the condenser was
i
'
!
partially completed to the Cu-Ni design.
Since the maximum
unsupported span for the titanium tubes was approximately 20%
,
less than for the Cu-Ni tubes, the total number of supports had
i
to be increased by approximately 25%.
Due to the fact that the
original tube support plates had been installed, the decreased
unsupported span was achieved by the installation of additional
i
partial tube support plates between those already installeo.
S&W stated that such a procedure was a standard solution for a
retubed or partially built unit.
This was confirmed by the
NRC.
'
The resultant tube support plate system was reported by S&W to
contain approximately 60-70% more tube support plates than
'
would normally be necessary for a completely new design with
some tube support plates as close as 18 inches apart.
The unit
was also designed to accommodate the MAN in-service (brush
type) cleaning system by extending the tubes a minimum of 3/8"
beyond the tube sheets.
The NRC noted that the unit was reassembled and fabricated in
accordance with S&W Specification SH1-223 with surveillance
inspection recorded for nine (9) attributes on the " Condenser
i
Tube Installation Inspection Checklist." The NRC noted further
j
that the increased number and decreased span of the tube support
plates was recogr.ized early as potentially producing a tube
insertion problem prior to the tubing of the unit.
This fact
was documented in meeting minutes on the subject " Erection of
the Surface Condenser" dated November 13, 1975 with LILCO, S&W,
IR and REGOR (the condenser erector) in attendance.
It was
recognized at this point that the tubes would be scratched
during the tubing operation and a maximum 0.004" scratch was
permitted.
S&W indicated that the 0.004" was acceptable based
on equivalency to the current SB333 NDE Calibration Standard
(Paragraph 10.2.1.2) of 0.004" and the UT Calibration Standard
in the tubing Purchase Order Specification SH1-299.
As indicated
in an S&W 1etter dated July 22, 1976, a series of calibration
comparison scratches were prepared for use during tuoing in
,
order to the able to determine acceptable scratch depths,
i
The NRC noted that as anticipated, there was a tube insertion
!
problem due to alignment difficulties.
This fact was acknowledged
in the " Condenser Tube Installation Inspection Checklist"
review which indicated that tubes with scratches exceeding
0.004" were removed from the condenser and scrapped.
A detailed
examination of these records indicated that the A-2 section of
,
47
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the condenser was the most difficult to tube. S&W stated that
the unit was tubed from the outlet side and consequently the
outlet tube ends extending into the water box for the A-2
!
section of the condenser were visually examined by NRC investi-
1
gators. Only minor inconsequential nicks were found at the ends
1
of these tubes. S&W stated that no tube ends had required
reforming for the insertion of the closely fitting rolling
,
tool, a further indication that the tube ends were not deformed
during tubing.
Tubes accessible for *sisual examination on the
shell side of the A-2 section of the condenser were also visually
inspected by the NRC investigators.
Only minor scratches were
observed and these appeared to be in the 0.002" dimensional
range.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation insofar as the tube insertion problem had been
anticipated and was performed in an acceptable manner without
any significant damage to the tubes. The NRC noted that a tube
failure would not normally result in a radioactive spill. The
condenser is under vacuum, and a leak would result in water
from Long Island Sound leaking into the condenser rather than
radioactive water leaking out.
23.
Allegation No. 23
a.
Allegation
Radiographic tests revealed that the longitudinal seam welds
for the <:endenser box were improperly done and when opened for
reworkinJ, it was found that the welds often contained dirt,
rubbish and weld rod stubs.
It was alleged further that these
conditions were sometimes discovered when the condenser had to
be cut open to correct misalignment problems.
b.
NRC Investigation Findir.gs
The NRC noted that the condenser is not part of any safety-re-
lated system and is not clasified as an ASME Code Vessel as the
shell side is under vacuum.
The unit was reassembled on site
by a LILCO constructor (REGOR) in accordance with S&W specifi-
cations and with S&W performing surveillance quality control.
The specification requirement for nondestructive examination of
the welds was for visual examination only.
48
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The NRC was informed through discussions with the S&W engineer
responsible for condenser fabrication that as a result of the
Field QC questioning the achievement of full penetration welds,
"information only" radiographic and ultrasonic examinations of
the welds were performed.
The results of these examinations
confirmed the lack of full penetration welds.
Field QC . ported
that the radiographic examination identified welding technique
problems including indications of slag, porosity and lack of
,
fusion, but showed no indication of foreign objects such as
rubbish and weld rod stubs.
'
The NRC noted that an S&W 1etter (SNPS No. 3850) dated April
19, 1976 describes the welding deficiencies and S&W E&DCR No.
F-5104, dated November 5,1976 submits the welding nonconfor-
mances to Engineering for review. Resolution of the E&DCR
required that all accessible welds be air carbon arc back
gouged and back welded.
Inaccessible welds were strenghtened
by the welding of a stiffner to the face of the weld in order
to provide the equivalent weld strength.
Conditions of this
type were not found when misalignment problems were corrected
although in certain instances arc back gouging and back welding
were performed as part of the realignment of installed partial
tube support plates.
The NRC noted further that in the majority
,
of cases involved, the orientation of the welds would have
1
inhibited the inclusion of any foreign objects.
l
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
j
this allegation.
24.
Allegation No. 24
a.
Allegation ~
Misalignment of the condenser tube support required rewelding
so often that in some cases, the " mother material" around the
weld had to be cut out and replaced with a fresh substitute
section.
b.
NRC Investigation Findings
The classification, fabrication and field assembly of the
condenser have been described in Paragraph 22 of this section,
together with the tubing changes and the installation of addi-
tional partial tube support plates.
Discussions by the NRC
with S&W personnel and a letter dated October 14, 1975 by
Ingersoll-Rand (IR) the condenser fabricator to their site
erection supervisor, established that the partial tube support
49
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.
.
plates do not provide any structural support for the condenser
box.
These support plates are installed in order to mitigate
the flow-induced vibration of the titanium condenser tubes.
The NRC noted that the partial tube support plates were cut
into pieces at the shop, reassembled in the field and installed
by welding them to support hangers which spanned the distance
between the original tube support plates.
The difficulty
encountered in the tube insertion revealed some misalignment
problems between the original tube support plates and the
additional partial tube support plates.
The partial tube
support plates were then cut from the support hangers, recut
into sections and reassembled in order to improve the alignment.
In order to facilitate the reassembly of the partial tube
support plates and its attachment to the support hangers, flat
plates, similar to stiffner/ backing straps were installed for
ease of welding.
The NRC noted that this practice is in ac-
cordance with standard practices for the industry.
The NRC concluded that it was the stiffner/ backing strap-like
plates that were mistaken as the " fresh substitute section"
referred to in the allegation.
The NRC noted no unusually
<
1arge amount of rewelding associated with the realignment of
i
the partial tube sheet support plates.
The flat plates were
installed to facilitate reinstallation, the work was approved
by engineering and inspected.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
25.
Allegation No. 25
a.
Allegation
Welds are marked by quality control before welding in order
that the best welders can be assigned to these jobs.
This is
done to assure that they pass examination.
Other welds are
made by lesser qualified workers and never inspected, implying
a degradation in overall quality and resultant safety factors
at the Shoreham site.
b.
NRC Investigation Findings
The NRC noted that welds in safety-relatad syarems are required
by the NRC to meet varying levels of qutlity basci on their
importance to the safety of the reactor. These welds are
50
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required to conform to the applicable codes and standards.
For
example, at the Shoreham site, all safety-related pipe welds
must meet ASME III and ASME IX Codes. The reactor coolant
pressure boundary must meet ASME III Code, Class 1 by the NRC
regulatory requirement.
Welds of lesser sensitivity are permitted
to meet ASME III Code, Classes 2 and 3, again, based on their
relative importance to safety.
The ASME III Code specifies what testing methods are to be used
for each class of weld; surface examinations for Class 3,
radiography for Class 2 and a combination of these for Class 1
The execution of these welds is controlled by an approved
Nuclear Quality Assurance Manual which directs the project
engineer to predetermine the inspection requirements for each
weld on the component checklist.
These checklists are posted
at each weld where work is being performed, providing an addi-
tional indication of the classification of the weld involved
further insuring that the more sensitive welds receive appro-
priate attention as required.
i
The NRC noted that welders working on safety-related pipe are
,
qualified to the ASME IX Code.
This code only recognizes
" qualified" or " unqualified" welders with no grading system
within the " qualified" classification. The assignment of the
more skilled welders to the higher classification of welds
would mean that the best craftsmen are working on the more
sensitive jobs, a process consistent with good practice and
generally enhancing the safety of the general public.
The NRC observed that if the inspection requirements were
performed on a random sampling basis rather than the system
described above, then the activities as alluded to by the
allegation might have the potential of affecting the overall
quality of the job by alerting individuals to those safety re-
lated welds to be " randomly selected". Since all safety-related
welds are inspected, this concern is not justified.
c.
NRC Conclusion
>
l
The NRC found no evidence and/or information to substantiate
this allegation.
26.
Allegation No. 26
a.
Turbine foundation bolts had been installed so far out of
alignment that it was necessary to chop out concrete around the
bolts, heat the bolts and bend them into a "Z"
shape in order
to fit them to the foundation plates.
l
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_ _ _ _ _
.
b.
NRC Investigation Findings
NRC investigators interviewed S&W construction personnel and GE
Installation and Service Engineering Department (GE I&SE)
employees who were responsible for the turbine installation.
The NRC also examined relevant GE procedures for the setting of
the foundation plates.
These procedures require that 2 to 3
inches at the surface of the concrete foundation be chipped out
prior to setting of the foundation plates in order to permit
packing of grout under the plates.
GE representatives explained
that the centerline of the turbine must be aligned within
hundredths of an inch. In order to meet this requirement the
bolts were installed within sleeves so that they are free to
move within the sleeve once the concrete has set. This is a
conventional method of setting anchor bolts.
The GE and S&W personnel who were responsible for establishing
the alignment and for setting the foundation plates all stated
that there had been no problem with the alignment of the bolts.
The only problem encountered had been the cleaning out the
space between the bolts and sleeves to permit adjusting the
]
bolt location within the sleeve.
.
i
NRC investigators examined slides showing the actual chipping
,
of the concrete in progress and the installation of the foundation
l
plates.
No significant alignment problems were identified in
these slides.
The NRC noted that the planned chipping away of
2 to 3 inches of concrete was an extensive operation and may
have created the impression of improper alignment which was
responsible for this allegation.
The chipping of the concrete
was performed by laborers who would not be fully cognizant of
<
the foundation plate installation procedure further leading to
the misunderstanding.
l
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
l
this allegation.
27.
Allegation No. 27
a.
Allegation
When concrete was placed in a cold joint on the 63' level of
the Reactor Primary Containment, a large amount of rubbish and
trash was permitted to remain within the form and the concrete
placed on top of it.
!
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b.
NRC Investigation Findings
NRC investigators reviewed concrete inspection records and N&D
reports of concrete placements within the reactor building.
There were no records of any cold joints in the Reactor Contain-
ment Wall but N&D No. 594 identified a cold joint in the shield
wall at the 63' level.
A preplacement inspection of the area
had been made and documented prior to the placement of additional
concrete and no irregularities were noted.
The NRC questioned several S&W QC inspectors and construction
engineers as well as DRAVO craft and supervisory personnel
concerning a cold joint in the Reactor Primary Containment
Wall.
Some of the individuals questioned mentioned one or two
'
'
cold joints, including the one in the shield wall but were
unanimous in stating that there were no cold joints in the
Primary Containment Wall at or near the 63' level.
The NRC noted that the requirements for preplacement inspections
prior to the placing of concrete above a cold joint are the
same as for any concrete placement.
A review of preplacement
records by the NRC and interviews with several S&W and craft
personnel identified cleanliness as an item of major importance
during preplacement inspections to the extent that craft personnel
were frequently delayed in placing the concrete in order to
satisfy QC cleanliness requirements.
The NRC acknowledged that
while it was probable that the alleger mistakenly identified
the shield wall cold joint as being in the primary containment
wall there was nothing to support his allegation with respect
to the lack of cleanliness.
c.
NRC Conclusion
The NRC found no evidence and/or information to substantiate
this allegation.
28. Allegation No. 28
a.
Allegation
'
__
Soil percolation test results were falsified and test results
were withheld from LILCO's submission of this information to
the NRC.
1
b.
NRC Investigation Findings
Due to the nonspecificity of this allegation, the NRC examined
two (2) areas which appeared to have been responsible for the
allegation being made.
With respect to the soil percolation
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tests themselves, the NRC noted that these tests are utilized
!
to size and locate septic systems and are not used with respect
i
to any structural design considerations. The NRC interviewed
LILCO representatives with knowledge of this area and noted
that the installation of the Office and Service Building septic
system coincided with investigations into the potential for
,
soil liquifaction under the service water system.
On one
occasion during the soil liquifaction boring program, and
!
subsequent to a heavy rainfall, the building service engineer
'
asked the geotech engineer to take borings in the vicinity of
,
the septic tanks to find out why they would not drain.
Three
(3) borings were taken and given to the building service engineer,
'
but the logs /results of these borings were not included in the
liquification information for the FSAR.
The NRC determined
that this request to withhold the nonrelated information might
have been misconstrued as a willful attempt to withhold infor-
mation from the NRC.
Th: other area evaluated by the NRC investigation was the soil
liquifaction work itself.
The NRC noted that this matter was
covered in the licensee's FSAR (Section 2.5) and Appendices 2A,
2I, 2J, 2L and 2M thereof and basically involved tests to
obtain additional information on the soil conditions in the
j
vicinity of the various components making up the service water
i
system in order to determine the liquifaction potential in the
event of a design basis earthquake.
The various components
making up the service water system included the service water
piping between the Reactor Building and the Screenwell, the
Screenwell, the wingwalls adjacent to the Screenwell and the
Intake Canal itself. During the investigation, the NRC investi-
gators did not evaluate the results of these tests as this had
already been performed by the NRC as part of the overall licensing
process.
The NRC did note, howaver, that the licensee's response to
Request 324.5 of the FSAR provided LILCO's response (March
1976) as to why test boring data had been changed from the PSAR
results.
The investigators noted further that the changes
primarily appeared to be minor accidental omissions of data
which occurred when unnecessary data was intentionally removed.
The NRC investigators found no intentional attempt on the part
of the licensee to withhold information from the NRC, although
someone not familiar with the matter again may have misconstrued
it as such.
c.
NRC Conclusion
,
The NRC found no evidence and/or information to substantiate
this allegation.
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29.
Allegation No. 29
a.
Allegation
Welder performance qualification records were postdated for
welders who qualified after parforming welds for which they had
not been qualified.
b.
NRC Investigation Findings
NRC investigators reviewed 1300 COURTER and CO. Nonconformance
Reports (NRs) for indications of welding by improperly qualified
welders.
One (1) NR was identified which showed welds performed
by an unqualified welder. NR-837 dated May 22, 1979, stated
that in accordance with the Procedure Qualification Test Method
(PQTM), the welder was required to qualify to Performance Test
(PT) C-1 in order to weld a P-8 to P-1 material socket fillet
weld in accordance to Weld Procedure Specification (WPS) 08011AA.
The NR was dispositioned to " accept as is" on June 11, 1979
since the weldar was qualified to (PT) C-11 for welding P-8 to
P-8 material.
ASME Section IX, QW 310.5 permits a welder
i
qualified to weld P-8 to P-8 to also weld P-8 to P-1. Since
j
ASME Section IX is the authority for welder performance qualifi-
catiuns, this permitted the welder to be authorized to weld on
the P-8 to P-1 joint in question.
The exception to the PQTM
was authorized as a specific case and the welder was not added
to the list as having passed the (PT) C-1 test.
The NRC identified
no problem in the disposition of this NR.
NRC investigators also interviewed the UNICO individual responsi-
ble for maintaining the listing of qualified welders who stated
most emphatically that there had not been any postdating of
welder performance qualifications.
Although stating that an
authorized mechanism existed for post qualifying a welder in
accordance with an E&DCR*, that this mechanism had never been
utilized at the Shoreham site and in any event would not involve
postdating any existing records.
To do so, she stated, would
require (in accordance with QAP-7.2) postdating and signing
authorizations on five separate documents prior to inclusion on
the qualified welders list and then the postdating of the
qualified welders list itself. The NRC noted that such a::tions
would be easily noticed if attempted.
c.
NRC Conclusion
The NRC found no evidence and/or information to support this
allegation.
^This mechanism is different from the disposition of the Courter NR as described
earlier.
In this later case, the welder would have to be actually requalified
on the weld type in question and if he could not be, the weld would be removed
from the system and performed by a qualified welder.
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30.
Allegation No. 30
a.
Allegation
Pressure was applied to construction workers by LILCO, its
subcontractor and/or related construction unions in order to
prevent and/or discourage workers from coming forth to identify
construction defects and/or irregularities to the NRC.
b.
NRC Findings
In order to determine the validity of the allegation, NRC
investigators provided several pathways by which current or
former construction workers could contact the NRC with infor-
mation in this regard specifically (i.e. , intimidation) or or
with respect to construction defects in general.
The results
of these efforts are reviewed below.
1)
Public Notices
From January 3, 1980 through the end of the investigation
on site on March 12, 1980 (a period of 70 days) notices
were placed at several frequented locations at the Shoreham
site. This fact was confirmed by the NRC Resident Inspector
and NRC investigators on site throughout the course of the
investigation. A sample of this notice has been attached
as Exhibit B of this report.
The notice provided a minimum
of three (3) points of contact with the NRC, one of which
was manned on a 24-hour basis.
The 24-hour number was
also made public via a local newspaper, covering therefore,
off-site and/or former employees still remaining in the
area.
In each case, full confidentiality was offered and
workers had the option to call anonymously with their
concerns if they so desired.
During the 70 day period that this notice was published,
the NRC received two (2) phone calls.
One of the phone
calls was from a construction worker at the site who
stated that he had worked at other non-nuclear power
plants and that by comparison, Shoreham was "over-designed"
and " super-safe".
The other caller was a member of the
general public who had concerns about nuclear power in
general and specifically Shoreham because he lived in the
area of the plant.
Although his concerns were addressed,
he provided no information related to a construction
defect at the Shoreham site.
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ii)
Interviews of Construction Workers On-Site
During the course of the investigation, several workers
were interviewed.
All of the workers were interviewed in
private, some during the investigation of the other al-
legations, some specifically selected at random in order
to determine the validity of this particular allegation.
In the latter case, site representatives for various major
subcontractors on site were contacted by the NRC and asked
to provide a list of all current employees to NRC investi-
gators.
The investigators then selected at random a
sampling of carpenters, laborers, masens, welders, electri-
cians, boilermakers, teamsters, mi11 wrights, insulators,
steamfitters, sheetmetal workers, weld rod control clerks
and QC inspectors.
Through the sampling process, shop
stewards as well as workers were also selected. Each
)
individual was (a) interviewed in private, (b) informed of
confidentiality, (c) provided with information for a
callback to the NRC if desired and (d) was allowed to
express his concerns in any area (i.e., construction
defects) in addition to the specific area of intimidation
as stated in the allegation.
Every individual interviewed informed the NRC that none of
the workers had teen directly or indirectly intimidated by
any individual, union, contractor or licensee, in an
attempt to prevent taem from coming forth to identify
construction defects and/or irregularities to the NRC.
Each individual further informed the NRC that they had
neither observed nor heard of such actions being executed
on any of their friends or other, employees not directly
questioned.
The NRC did not receive any callbacks at
other' times from the individuals interviewed in this
regard.
Severe
of the workers interviewed volunteered statements
to the
C to the contrary of this allegation stating that
if anything, the opposite of the allegation was true.
Some of the statements made are included as follows:
Steamfitter A stated: "We never took a shortcut. ~his is a
Class A job.
Our relationship with LILC0 is good and they
cooperate fully with our concerns."
Mi11 wright A stated: "Our local is very conscientious with
nuclear energy.
This (RCI) is the most conscientious
outfit I've worked for."
57
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Boilermaker A stated:
"The union would be very supportive
of our complaints."
Boilermaker B stated:
"We've done our job right to the
specs."
Boilermaker C stated:
"If we ever found a problem it
would be taken care of. They (LILCO) check out everything."
Electrician A stated:
"Just the opposite.
Everyone is
concerned with QC.
I've seen some of the better workmanship
in the trade on this site."
'
Electrician 8 stated:
"I haven't seen any problems in 5
years."
Electrician C stated:
"No threats whatsoever. They (union
and contractors) promote safety, especially on a nuclear
job."
Electrician D stated:
"We are told to bring up safety-re-
lated issues.
Everyone is doing a Class 1 job.
We are
all going to suffer if something happens (when the plant
is operational) so we are all supersafe about our jobs."
Millwright D stated:
"Just the opposite. We are all told
to look for problems.
I haven't seen any so I don't know
how they'll handle it."
Boilermaker D stated:
"I would go to the NRC without
,
hesitation.
I live in the area and I wouldn't want anything
'
to go wrong."
Sheetmetal Worker A stated:
"They (foreman) tell us to
report everything suspicious to them.
I wouldn't be
afraid to speak up."
Sheetmetal Worker B stated:
"The company here (LILCO) is
far superior to any other company I've ever worked for."
Sheetmetal Worker C stated:
"Noone is afraid to come
forward. In my opinion the job is being done better than
it has to be."
Sheetmetal Worker D stated:
"Something like that (threats)
would get around fast, therefore no way they would do it.
This job is going slow because all the safety checks you
i
have to go through."
58
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Sheetmetal Worker F stated:
"I'm a shop steward. We watch
who we send out there because it is a nuclear job.
If
they don't want to give quality work, they won't be kept
here.
I'm a shop steward and I have no fear of coming
forth to the NRC."
Carpenter B stated: "I never saw a better job in my life
and I've been in concrete for 26 years."
Mason A stated:
"This is one of the best built jobs I've
worked on."
Mason B stated:
"I've been encouraged to bring problems
to management. There would be more white hats (QC, S&W,
NRC) than we knew what to do with. The QC here is tough."
iii)
Resident Inspector
NRC investigators were informed by the NRC Resident Inspector
that during his entire assignment at the Shoreham site
(from October 1, 1979) even prior to the initiation of the
investigation, no workers at the site (licensee or contractor)
had ever approached him with any form of problem relative
,
to construction defects and/or pressure not to present
their concerns to the NRC.
The Resident Inspector stated
that he had made several tours of the site during this
time, not only during normal working hours, but also
during off-hours, weekends and holidays, and that to date
he had yet to be approached in this regard.
iv) Protective Agreement
Attorneys for various allegers claimed that several other
workers wished to present information on construction
defects but would not do so without a formal protective
agreement provided by the NRC in order to ensure their
confidentiality.
A draft of this agreement was presented
by the attorneys to NRC investgators on December 17, 1979.
This agreement was forwarded to NRC Headquarters for legal
review and subsequently sent to the allegers' attorneys
for implementation.
When no new workers came forth even
with the protective agreement, the NRC investigators
inquired as to the reason.
The attorneys stated that they
(attorneys) had decided not to risk the lives of these
'
additional allegers due to potential threats to their jobs
and/or persons.
)
l
!
!
59
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The NRC could not reconcile this statement insofar as it had
noted in i), 11) and 111) above that no evidence of any threats
whatsoever could be substantiated during this investigation.
c.
NRC Conclusion
The NRC found no evidence and/or information that would sub-
stantiate this allegation.
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IV. EXHIBITS
Exhibit A: Referenced Codes, Specifications and Procedores
Specifications for Structural Concrete for Buildings
Recommended Practice for Cold Weather Concrete
Recommended Practice fo Concrete Formwork
ASTM (Draft 14)
Proposed Manual of Coating Work for Light Water Nuclear
Power Plant Primary Containment Facilities (Subcommittee
D-01.43)
SH1-64
Specifications for Substructure Work
SH1-354
Specification for Concrete Work
,
SH1-228
Protective Coatings Within the Primary Reactor Con-
tainment Structure
SH1-228.700
Procedure for Applying Protective Coatings Within the
Suppression Chamber
W 300-Section A
General Procedure for Cadwelding of Reinforcing Steel
QC-10.3
Field Quality Control Procedure - Concrete Quality
Control
QC-14.2
Field Quality Control Procedure - Cadwelding
QC1-10.3.012
Quality Control Instruction - FQC Preplacement Pour
Card
QCl-10.3.013
Quality Control Instruction - Preplacement Inspection
.
QC1-14.2.001
Cadweld Data Analysis
61
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- e,M N
EXHIBIT B
- o,
UNITED STATES
8
NUCLEAR REGULATORY COMMISSION
,
o
D
j
REGION I
$
631 PARK AVENUE
4,***** ,@g
KING OF PRUSSIA, PENNSYLVANIA 19408
NOTICE
The U. S. Nuclear Regulatory Commission is conducting an investigation
into alleged improper construction practices which may have been
undertaken at the Shoreham site. Any worker having information
concerning these al*iegations or other concerns is urged to contact
the NRC (collect) at 215-337-5000.
NRC investigators will be on site
from February 11-15,1980*and may be contacted through the NRC Resicent
Inspector (extension 83-221) or at the Holiday Inn at Riverhead, New
York, (516-369-2200).
The NRC wf'll maintain the confidentiality of
the source of any information received during this investigation and
in any resultant reports.
- new notices were posted prior to each on-site visit and the appropriate
,
dates inserted at this location