ML20024E333
| ML20024E333 | |
| Person / Time | |
|---|---|
| Site: | Perry, Harris  |
| Issue date: | 08/04/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20024E334 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8308100258 | |
| Download: ML20024E333 (18) | |
Text
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UNITED STATES OF AMERICA August 4,1983 NUCLEAR BEGULATORY COMMISSION N
h p
Rregg.ED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright f
US 8 ; 03 > Y Dr. James M. Carpenter
%,Nfc'e_'"l*tx Janes L. Kelley, Chairman llI st I
SEcy. " c cn QITO In the Matter of Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
50-401 OL (Shearon Harris Nuclear Power Plant,
)
Units 1 ani 2)
)
ASLBP No. 82-h68-01
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Motion to Compel Discovery re Eddleman 41 & 65 Following the breakdown of negotiations on these resconses (7-25-83), Wells Eddleman now respectfully moves the Board to compel Applicants to respond to di.;covery on Eddlenan 41 and 65 and general interrogatories as follows.
Since there is a massive amount of information involved on Eddleman 41 (pipe hangers) limited and I have
. access to experts on Eddleman 65, I need to get as much information that could lead to admissible evidence in the first round of discovery as possible, to be able to frame an adequate second round of questions (this is one of the dis-advantages of being limited to 2 rounds of discovery).
Applicants have already produced some 15000 pages of info on Eddleman 41,Q.pfs e6. ve one gvise me enua I
but have not produced much needed information.
They a that they will not provide any more documents referred to in these pages, even the field change requests etc which they had I
provided some of during document production.
8308100258 830804 I
G
., Disputed matters are addressed here in the order they appear in Applicants' response (re 41 and 65, dated May 12 883, served 5-13 and received by me 5-16).
j Interrogatory G-8 (pp 6-7).
Applicants ' answer, insofar as it addresses matters presently known, is accentable.
I have dug into some cases on interrogatories and understand that what is NOW known is the proper subject of interrogatories of this om c.
To the extent that the answer will be undated (as this is a continuing interrogatory), I do not choose now to try to compel discovery on G-8.
l In so doing, I do not agree that this or any other failure to move to compel on G-8 constitutes agreement with any objection to it.
Nor do I waive the right to move to compel if information resnonsive to G-8 is not made available in a reasonable time.
If, arguendo, the position of Applicants is the.t they will provide nothing beyond their May 12 answer (that d2ey have nothing responsive to Interrogatory G-8) and will not provide it, then I do seek that they be compelled to provide such information.
In so seeking, I do not ask for work product; as to other privileged material, Applicants should identify any such in objecting to the interrogatory (they have not so far), and state the privilege i
they claim is applicable.
I have no means other than discovery to obtain the information available to Applicants about welds and concrete inside their plant (and specific answers, if they know them, about concrete in base mats at other Daniel-International-constructed plants).
Information Apulicants f
rely on is clearly information that could lead to admissible I
evidence.
If this interrogatory be cai sidered premature, I note that it is continuing and should be answered when information it l
asks for is available to Applicants.
. Response to Interrogatory 41-1(b) (p.7 of resp;nse)
CP&L did not state"what tests in welding inspection she or he passed" for each inspector, the"resultsof such test", the " requirements of J_
such test or questions on it", other information as to the
" content or nature of such test or tests", or any "other information".
(All quotes above are from interrogatory 41-1(b)).
Applicants did not object to answering these parts.
I have only the supposition that "other information " may be considered too broad.
I can narrow it, i.e. to "any information indicating such person is unqualified to inspect welds, or information that such person has approved defective welds after inspecting them."
I think that lesser request is specific enough.
All parts of this interrogatory Applicants didn't object to, they should answer.
They're highly specific except as discussed above.
This is the kind of question that on other interrogatories, Applicants have been willing to suoplement answers to (see 6/30/83 re Eddleman 75 and 83/84, sunplement by Applicants, and the interrogatories for which such sunnlement was made -- as identified in said suoplement).
He 41-1(d) (pp8-9 of response)
Applicants give no qualifications of the checkers of blueprints other than to say that they are " degreed engineers".
Are they degreed solar engineers, nuclear engineers, or maybe welding engineers?
The answer is not responsive.
"A degreed engineer" by itself is not a statement of what the qualifications of a person are, see (resp.at 8) except perhaps in the most minimal and incomplete sense.
Applicants go on to give qualifications (resp. at 9) as "most...
are degreed engineers".
This is not resnonsivs.
m
-h_
Although Apnlicants object to the research to identify the information by symbol and drawing, they refuse to allow me to have access to the information to do such myself.
Although I probably don't have time to review 50,000 drawings, I have pages of reviewed 5000 weld data reports in less than 3 working days in July when they made those documents available to me.
I think Auplicants are unreasonable in denying me access to the drawings because (1) you can't tell if welds match a drawing without seeing the drawing.
I have a diploma in welding and got an A in ny blue-print-reading course, so I can do this, if I can see drawings.
(2) It has been adnitted that incomnlete, unclear and wrong welding symbols were used on drawings at Harris (See Annlicants' renort, Revision 1, acconnanying their first set of interrogatories to me datad 1-31-83).
Thus the information is relevant and could well lead to admissible evidence.
(3) Even NRC Staff itself deals with large amounts of data like this by sampling.
See at pages 67 (bottom),68 of N9C Staff response to ny first set of interrogatories.
(4) I am willing to do such sampling myself if I can get access to the packages containing the ifformation requested.
This is a position of which Anplicants are aware.
41-1(e) (reso pp 9-10) This answer is very general and orovides no specific information.
Anplicants know that welds were made with unclear symbols (see Exhibit 2 to their renort to NRC, 5/27/81, re pipe hangers, attached to their 1st set interrogs to ne).
The answer is incomplete and perhaps evasive. Annlicants also refused to provide any drawings, saying they're "not referenced in our answers" (but see at 9) As to the specific information by symbol, etc, I am willing to dig it out myself and the above reasoning for why I should be allowed to do so (see re 41-1(d) object'on, above on this page) annlies.
This applies to drawing revisions also, which Auplicants have not nrovided.
l
-5 Re 41-1 (h),(
i) and (j) (resp pp 10-11).
The objection says Auplicants won't do the research.
I think I should be allowed to do it myself, daen, at least on a sanoling basis
~ with free access to the Weld Data Reports (WDRs).
Applicants identify
" roughly $$" file drawers of WDRS.
Even assuming small file drawers, the WDRS so far made available would fill only 9, as they fit into four 3' x l' x l' (anurox) boxes.
The reasons for allowing direct inspection, and my qualifications to do so, are the same as discussed on page 4 above for 41-1(d).
Re 41-1(k) (reso. p. 12)
Approximately12,000 pages were produced of the " roughly 20,000 pages of WDRs and work packages" identified by Applicants.
Applicants selected all the papers
(
produced and refuse to allow any access to the other WDRS and j
work packages.
I was able to look over the 12,000 in 3 days, and the copying I requested was done within 2 nore working days of the end of my inspection, so CP&L informs me.
The objections as to interruptien of work are not specific; the 12,000 pages l
were also evidently active files: the WDRs contained many uink sheets of recent inspections, and the HVAC file had "everything" in it regarding those hangers and was assembled (so it says ) for Steve Mountcastle, who's in charge of HVAC pipe hangers at Harris.
I am willing to work out arrangements with Applicants to see the rest of this information, part at a time, or however reasonable.
Their ref.usal to provide the information AT ALL is not reasonable.
Applicants allege an " unrecognizable benefit" to me from seeing the rest of this info.
First, I'm not sure they haven't been selective in what they've revealed; second, the benefit in I
inspecting these reports is to see how good the insnections a_re.
.. _._ ~, _ _ _ _. _ _
. I have already found a number of pipe hangers where the earliest record supplied to me is a " reinspection" finding the whole thing OK, followed by another inspection finding defects.
Two such are A-1-190-1-PD-H-37, rejected 3/18/8E "for weld type not same as on drawing", re-rejected 1/11/83 for defects, two of which apparently had been OKd twice previously; ditto-number ending in PD-H-k1 was reported 12-28-82 undersize 1/16 on bottom weld af ter previously being OKd.
There are dozens of such, not just on PD-H's.
I think it reasonable to look at the rest of the reports to see if problems like thee, or other problems, are found for those hangers.
(Ditto PD-H-42 OKd 10-25-80 on re. inspection, 5 defects found,1-6-83) 41-1 (1,m,n,o,p,q,r,s) (resnonse pp 12-14).
Apnlicants object to all of these, basically the same; the objection is onlysetoutfor41-1(V)atpage12.
These interrogatories all seek information as to the identity, qualifications, training, hiring, discharge (records of such also), blueprint-reading knowledge, and record (if any) of making defective welds for persons welding oipe hangers at Shearon Harris, and whether any person (s) have been discharged for making defective welds on pipe hangers.
The objection is that the interrogatory is outside the scope of " inspection of pipe hanger welds".
But this set of interrbgatories can lead to admissible evidence.
The defective welds were obviously made by welders.
Some of these defective welds were then approved by CP&L's inspectors.
Knowing what welders were involved gives me the chance to find out if there were more (ar, possibly, less) defective welds than renorted.
Knowing if
. the welders could read welding blueprints is clearly relevant when unclear welding symbols (Exhb 2, pg. 1, to CP&L rev. 1 report dated June 11, 1981 on nipe hangers welds at Harris) were a major cause of rejecting pipe hangers previously OK'd by CP&L inspectors.
One of CP&L's mitigation strategies was to retrain the welders (same report), af ter which 12.7% of welds in a test following retraining contained defects (or 12.7% of the hangers did.
Exhibit 1, ibid, title off top of page).
The welding tests passed, etc, are relevant because if the welders aren't really qualified, they'd tend to make more defective welds.
Defect rates as high as 95% (see n.4, sane report referenced above, for sample of h00 hangers) have been reported, in welds approved.
I need to check into dae welding to see Waat problems the insoectors w ould confront.
Obviously you can't have 95% defective pipe hangers without a lot of defective welding going on -- and being anproved by inspectors.
The questions as to whether Aeplicants know who made the defective welds are obviously relevant.
What action did QA/QC take with respect to these welders?
The defect rate of welders is relevant also -- were welders retained who had lots of defects, in their work, and if so, why.
If CP&L doesn't know the defect rates, what kind of QA/QC is that?
If CP&L doesn't know the welders of the defective nipe hangers, is that good QA/QC or not?
If persons were discharged for making defective w61ds on pipe hangers,' that's obviously relevant -- it shows QA/QC found who was causing some of the problems and took strong action,, at least in sone cases.
If they didn't, it shows further weakness.
As to discharges prior to 9/3/80 (when the defects were first noted in approved welds by the NRC inspector), and after, that l
. would show if any change occurred between practice before that time and af terwards.
When CP&L includes changes in w&lder training and review of blueprint reading for welders in its nitigation program for defective pipe hangers, they can hardly argue that such information is irrelevant.
After all, one way to reduce the number of defective welds aporoved is to reduce the number of defective welds.
In exploring information available to welders on these pipe hangers, relevant information on the extent of defective welding of such hangers, the inspectors' uractices as cerceived by the welders, and the welders' capabilities and instructions, can be developed.
What CP&L knows about who made the defective welds is certainly relevant to the ability of their QA/QC progran to handle defective welds on eine hangers (and, one night hope, to urevent such from occurring or being OK'd).
see d4o q \\o he\\ow - % W 4](Uk & sajo a fyWVufWW)
I assume the answer to 41-1 x) (p.14) is also "no."
Arolicants l
l stand on their answer, and if they won't tell me, I think they l
should be compelled to answer, since this is a different question than the referenced 41-1(w).
(p.1%$)
41-1(y) is the sane objection as to 41-1(k) above.
I refer to my discuss *on of that (ppy-6 above) and request access to all l
the information for the same reasons. Applicants should identify l
also all errors they know are documented in these records.
41-1(z) (p.15) I believe there is later infernation concerning pipe hanger welds, inspection, and possibly errors in specifications at Harris since the 6-11-81 recort. See answear of NRC Staff to ny interrogatories (1st set) at 69.
Arolicants refuse to provide the information in a " july 1983 renort" (or6ginally scheduled for May, 1983), referenced in a document they did produce this July.
I don't know why they refuse; their document production people indicated they could supply it
1
. but I have heard no reason for not supplying the document.
The report is promised in a 3-31-83 letter of Parsons, CP&L, CP&L is to O'Reilly, NRC, recheEking 900 suspect welds, hope to finish $/83.
(ref. p.13 of my working notes, July 1983 at document production).
If there is a delay, Applicants could sinnly produce this document.
I request they be also compelled to produce documents related to the pipe hanger weld problems identified by NRC Staff (response to my interrogatories at 69, June 1983), since these are also restonsive to 41-1(z).
41-3( e), response at 17(also objection at 16)
The objection is about the sane at to 41-1(k); I request I be given access to the information requested.
These waf vers and field change requests have the effect of turning defects into approved items.
After providing sone during document production, including sore referenced in WDRs but not provided originally as documents produced, Applicants now refuse to produce any more.
The FCRS and PWs and other changes (RCIs, etc) are just as common anong the non-HVAC pipe hanger WDRs, but Applicants refuse to nroduce those (non-HVAC FCRS, PWs, RCIs, etc)
The info is relevant in that it is part of the inspector's job to make sure the hanger conforms to any changes approved.
(It's also relevant since there appears to be no seismic analysis in the approvals of FCRS and PWs I have seen, just vague references to strength of welds -- but not to vibrational modes, flexibility,etc, which are as critical to seismic integrity as strength, if not more so.
Overwelding that rigidifies a joint beyond what it should be increases strength but may increase the chance of seismic-induced failure.
Many oversize and over-think welds are OKd at Harris in what I've seen)
. The requested informaticn is as relevant for non-HVAC hangers as for HVAC (moreso, in fact, since other systens are more inportant to safety than is HVAC).
Aonlicants should produce it.
Note also Applicants' answer to 41-3(p.17 f) which deals with FCRs and PWs and says "Any nodifications or request denials can be identified by reviewing the subject documents."
But not where those documents are not supelled!
41-3(f) is not limited to EVAC hangers.
Objection to h1-3(f) is sane as to (e) so above discussion covers it also.
41-4(e).
Apolicants may have a point in calling the question re other welds irrelevant (e.g. embeds), resp at 18).
But the coint is to see if the nolicy is different for other safety related welded complex structures, of which enbeds are an obvious exanple.
It wouldn't hurt Apolicants to answer this.
The possible adnissible evidence would be that their standards are weaker, stronger, or the same for other welded complex.
That would assesswhether CP&L quality standards had to be ungraded on pipe hangers, when; or if standards for eine hangers have always been as strict (or lax) as for other such structures as described above, e.g.
enbeds.
I Re 41-h(h), pp 19-20, the answer says that the sunervisor requires a "denonstration of the individual's understanding of apolicable requirenents" for persons who are to inspectpipe hanger drawings.
(Note that, in contrast to 41-1 1 thru s above, A olicants do not object to supolying info here about ueople who p
check the weld drawings.
See pp 6-8 above. )
It is evident this ik the only qualification, but the answer is vague and should supplemented (I ve requested this -- refused).
Just what f
be
. is the required demonstration (qualificat*on): whatever convinces the supervisor?
identifying 5 out of 5 cases where requirenents are net and 5 out of 5 where they are not on a test?
This answer seems to say the required qualification is "none" excent for this"denonstratioh", so it is reasonable the "denonstration" be specified.
41-4(1) (p.20)
I want to know who's not there for 2 reasons:
to get access to peonle who've done this work but whose jobs do not now depend on CP&L or its contractors, and to see if anyone has been discharged for failures in checking the pipe hanger drawings at Harris.
Aunlicants should have the info and give no reason to withhold it.
It isn't " irrelevant" for the reasons above.
k1-k(1) p.21, doesn't say how many have been resinsnected.
Due to the form of the question, I will ask a followup (Applicants object that answer to (j) is not affirmative, so they could just not answer at all).
41-5(a) thru (g) and second (g) ("(g) sic" as Annlicants term it) are the sane as objection to 41-1(1) (pp 22-23).
The relevant iten is that instructions as to what to do about knelear symbols on blueprints are part of Applicants' " cure" for the Harris pipe hanger problen.
See 6-11-81 report.
The above discussion re k1-1(1) pp 6-8 above, anplies here since it's the same objection.
Anolicants have provided info on the training of insoectors, the procedures used for welding, the identity.of folks who review cipe hanger drawings, and other interrogatories at least as "far" fren the contention about oK
'ing of defective pipe hanger welds as is this. If the welds are defective and welders ' instructions are changed thevefore, isn't the past instruction to welders relevant?
r
. 41-5 (1) p.24:
The objection as to burdensoneness could ba handled by giving ne access to the info (see discuss'on at 4 above).
As to relevance, the policy of returning drawings to the Site Mechanical Unit is nart of CP&L's handling of the pine hanger problem, for unclear weld symbols. Exhibit 2 to their 6/11/81 report on that nroblen shows that many crevicusiv OK9d welds had symbols so unclear they
. could not be checked as conforming or not.
Weld inspectors have to compare welding to the blueprints.
Changes are nade on the blueprints (compare Arnlicants resnonse to 41-1(e) or nage 9 of their resnonse).
The nunber of returned bluenrints shows how nany blueprints got by the review by CP&L's people, which CP&L didn't object to answering cuestions about (see resnonse to k1-4(f),100% of drawings are reviewed; hl-k(h) they do review then since 9/3/60, 41-h(j) on,e or more ue-sons of CP&L review every drawing prior to release to the field; 41-1;(o) drawings are reviewed prior to release to the field).
This cuestion is, how nany of t hose drawings are then returned by the field because of drawing e"rors or ohysical limitations that got by this review.
It's relevant and Apolicants should answer it er nake the info available to me.
41-5(j) the requested info should be made available in documents made available to me.
Reasons are discussed above re 41-5(1) for which the objection is the sane.
41-5(k) ADD 11 cants refuse to troduce the waivers.
Resp. at 25.
Discussion at pp 9-10 above, re PCRs and waive-s, applies. Discussier on this page above acclies to nroducing the info for insoection if they can't search the information out.
It should be troduced or they should answer.
41-6:
Answers and objections same as above.
Arrlicants should answer this for anythinE re 41-3,4,5(& subparts thereof) above that they are ordered to answer.
41-7 (p.26) the objection is to information "outside the scope but again, the treatment of other welded supnorts could be usefully compared to the treatment of pipe hangers.
This could lead to admissible evidence.
See discussion of 41-k(3e) above at 10, which is equally apolicable to this objection which is similar.
As to the answer, Applicants say the sketch of the subjects covered is all the information available re retraining of welders.
(For info on the failure rate of wolders retrained, see Exhibit 1 following p.h of their (CP&L's) 6-11-8) renort of pine hanger weld problens, attached to their first set of interrogatories to me 1-31-83)
(p.27) 41-8.
The issue is the sane as with 41-7, basically.
The defective welds made by persons retrained are certainly relevant to the effectiveness of the retraining, which is part of CP&L's remedial program, and the number of defective welds and how well they are identified is relevant to inspection of welds.
41-9.
If Anplicants can't review the info they should let me at it.
See discussion above at 4, equally ann 11 cable here.
41-11 (p.28) same as hl-9.
If they don't have the info they should let ne have access to it.
(NOTE: Annlicants' attorney does not necessarily agree that these objections are the same or the sane thread of objection. I do not renresent that l
he has ever said they are. I think they are).
Discussion on p.4 re providing access is relevant here too, whether objection is the same or not.
(pp29-31) 65-1(a) and (b) objection to other than containment structures, I want to connare then with the ones in the contention.
Also sane objection to 65-$(c) p.40, 65-1(c), 65-1(h), same reply fron me.
l Refusal to provide the concrete placement packages or copies thereof for inspection and conying, I think this data is most relevant to the contention and I should have NDess to it.
.. Applicants are unwilling to arrange this in any form as far as I can tell. If concrete placement reports aren't relevant to a contention about concrete defects I don't know what is.
65-2(a) (p.35) The objection, to the extent it depends on the Board's prohibition of a " broad-ranging review", is falsely premised.
These questions are highly specific.
I have provided Applicants long since with a document alleging these defects, and from which the questions were drawn:
The Ironworker, Sept 1979, copy attached of relevant pages.
Applicants define " Applicants" to include their contractrons one of whom is Daniel.
Daniel should have the information.
They should produce it.
It is specific inquiry re the necord of their prime contractor, relovant to the contention.
65-2(b), 65-3(b)
(a). (c) pp35-36, same as 65-2(a) so compelling is same.
The questions are quite specific.
65-3(c) might be considered " broad-ranging" and Anulicants' objection to it may be reasonable.
65-4(a) pp 36-37.
No masonry drawings were uroduced.
Apolicants say they've produced everything they think is ressonsive.
If there are any relevant concrete or masonry drawings, they should also be produced.
Applicants do not say (yet) there are none.
65-5(a) p.39, sane as 651(a) above, p.13. same reason to compel.
65-5(c) pp 39-40 Applicants object to producing the info by research.
Then they should let me have access to their data that is r'elevant: Discrepancy Reports, Batch Tickets, and QC test logs.
I can sample the info and review it, see p.h above.
As to non-containment info, again I want to comrare it with data for the cientainment, same as in 65-1(a), p.13 above.
65-5(d) and (e), pp 40-kl, are the same objection and
.. same rationale to conpel as 65-5(c), p.114 above.
CONCLUSION For the reasons given above, I request that Applicants be compelled to provide answers and/or access to docunents in their possession or in possession of their contractors (e.g. Daniel, Ebasco, Bergen-Patterson) as requested above, m
'[/
pt 8/4/83 Wells Eddleman of attachment referenced on p.14 Below is M N C 8 I h iC6 t0 W [Jd p A f'O M d
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n Open Shop at Wolf Creek Problems and Co;nplaints Plague Construction Of Non-Union Nuclear Power Plant in Kansas
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Work has resumed at the trou-to accommodate Daniel's sub-troubled plant, originally sched-bled Wolf Creek nuclear power standard pour. Daniel reportedly uled for operation next year but plant in Kansas, a controversial bought a makeshift mix from a now projected for 1983.
operation conducted open shop local company, originally formu-The critical base mat, upon by the Daniel intemational Cor-lated for highway, not nuclear, which a 340-ton nuclear reactor vessel and containment structure poration.
construction.
in a strange, unparalleled deci-As work resumes amid reports will sit, got a delayed start on sion, the federal Nuclear Regula-of shoddy construction and prob. December 12,1977. A few tory Commission (NRQ decided lems on the job, the Kansas months before the 6,660 cubic to lift a seven-month suspension Building and Construction Trades yards of concrete were poured, of construction a4er huge voids Council (KBCTO has set up an the largest single pour in Kansas were found in the exterior of office in nearby New Strawn, history, the prime owner of Wolf the containment structure. The Kansas. The unrepresented, non. Creek, the Kansas Cas and Elec-ten-foot thick reactor base mat, union Wolf Creek workers are tric Company (KC&E) delegated poured in December of 1977 was invited to stop by the office "for responsibility for the concrete to found to test out far below speci-a cup of coffee and let their con. Daniel, according to NRC rec-fied strength, but NRC reduced cerns be heard." In turn the ords. Daniel then switched sup-the concrete strength require-KBCTC office will " monitor the pliers and secured a concrete ments by more than 10 percent quality of construction" at the formula from a local ready mix THE IRONWORKER 26
company, a formula intended for sued a " Notice of Violation" to probed the accident, issuing no l
" ditch linings and box culverts" Wolf Creek owner, K.C.&E., find-citation. David W. Bailey, 35, used on a nearby highway proj-ing that less than half the con-died in a Topeka hospital, never cct, I-35. A Kansas State Highway crete samples from the criti-regaining consciousness.
D:partment official later said that cal base mat reached the re-Two new construction prob-csment would not be used for a quired 5,000 p.s.i. "All of the lems emerged, one involving highway surface, much less a items of noncompliance detected substandard rod struts and the
" safety-related" bridge or nu-during our inspection involved other involving damage to a clrar base mat. A Daniel docu-the failure of your contractor valve device. The Kansas Building m:nt in August refers to that mix (Dar:iel) to follow procedures. and Construction Trades Council d: sign as " approved for non-These findings indicate to us an petitioned that NRC to close saf:ty-related mud slabs and fill apparent weakness in your own down the Wolf Creek project for concrete only."
management controls and in the " substandard and inadequatt."
Daniel then, according to NRC effectiveness of your QA (quality construction. The petition called rzports, attempted to " upgrade" assurance) surveillance program, for revocation of the construction tha 4,000 p.s.i. concrete mix by as well as that of the contractor, permit, warning that " operation adding an " air-entraining admix-Daniel intemational."
of the power plant would gravely ture" and a " water-reducing ad-The NRC also pointed to, endanger the public health and mixture" to meet the 5,000 p.s.i.
" voids beneath the equipment safety" and "said danger cannot requirerpents.
hatch and the personnel airlock" be alleviated until the construc-Three months before the criti-and referred to an August 1,1978 tion work, especially the con-cal pour, Daniel stopped taking meeting in Wichita where " con-crete, is redone." That was the high-quality limestone sand and cern was expressed over the third such petition filed with stirted getting cheaper river sand number of noncompliance items NRC against Wolf Creek.
from another supplier. However, detected during construction Mounting pressures of con-an earlier report noted that "a which involved either failure to struction delays, federal investi-opiline sand mixture peculiar to follow procedures, or a lack of gations, consumer complaints tha Kansas and Platte River area procedures." The report noted: and " ballooning interest rates" reacted to Portland cement by "We have preliminarily conclud-prompted utility owner to push severely expanding in five to sev-ed that the compressive strength the NRC for a decision on re-en years" and another report of the base mat does not appear suming work. This pressure trig-noted that "the stone is classed to meet the specified acceptance gered a town hall type meeting cs unsuitable for use in concrete criteria." The 45-page report in mid May conducted by the flitwork."
faulted Daniel for the concrete NRC in Burlington where a de-Nevertheless, although the mix design, testing procedures cision was expected but not is-opo shop construction company and violation of the NRC con-sued. Instead, more than 200 itself conceded that " Daniel was struction permit.
people fired a debate that cen-unable to plan for large, critical Within a month of the exten-tered around a secret contract concrete pours," the big pour sive violation notice, the Kansas provision.
wts made over a two-day period State Building and Construction Wolf Creek officials at the Bur-in December of 1977, a pour that Trades Council launched a probe lington meeting were asked who y
lat:r came back to haunt Wolf of the 51.08 billion Wolf Creek would be liable in case of a fu-j Creek.
project. Council President Allen ture shutdown of Wolf Creek, A year later, on December 13, Thompson, assistant business due to the substandard base mat p
1978, huge voids appeared in the agent for Ironworker Local 10 in or faulty construction. Both the concrete of the huge nuclear Kansas City, pointed to faulty architectural design company, h
reactor containment structure concrete work and problems Bechtel Corporation, and the l-above the base mat. Five days with ironwork and welding. The-owner, K.C.&E., refused to an-later, work en the structure was ories that Daniel would " spy" on swer the question, stating that halted as the NRC, the owners their talkative employees floated such information might be " pro-and the public took "a second, in tne local media.
prietary." An official for the Kan-closer look at the " merit shop" A week later, a young iron-sas Corporation Commission was work of Daniel International Cor-worker was struck on the head quoted at the meeting: "If you poration, a wholly-owned sub-by a 15-pour:d hand tool below pass the costs on to consumers, sidiary of the Fluor Corporation. some scaffolding work at Wolf electricity rates go up, and no-On February 16,1979, the Nu-Creek. For about 10 days he laid body wants that. But if you pass citar Regulatory Commission is-in a coma while OSHA inspectors the costs on to shareholders, SEPTEMBER.1979 3
n
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test the questionable quality of wondering how much the Wolf construction, the substandard Creek construction budget has concrete base pad and the voids been exceeded. The K.C.& E.,
4' in the containment walls.
prime owner and manager of By mid-summer the Kansas Wolf Creek, has refused to dis-Building and Construction Trades close this information but in Council's sub-office near Wolf April went before Kansas State Creek was staffed by Steve in-commissioners asking for a $21.4 gram who served coffee and con-million interim utility rate in-3 versation to the workers and crease. K.G.&E. president stated:
answered the office phone at "The losses we are suffering are l
364-2012. Ingram's main interest beyond our control," asking con-is described "to monitor the sumers to pay more through quality of construction at the higher electric bills. Two months plant." The Council hopes that later, in July, the K.G.&E., went "through communication with before the state utility rates com-employees,if there are problems mission for $33.6 million in high-in the construction they will be er rates, still refusing to reveal'
"/b found while there is still tir.ae to h::w nr.i. w.ntruction costs at j
i remedy the situation."
wolf Creek have exceeded the
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There is also speculation about 51.07 billion budget.
how hard the non-union workers in July, seven months after the
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are pushed by Daniel Intema-concrete voids were discovered i
tional at the Wolf Creek job, sug-and construction halted on the
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gesting why the base mat is sub-containment structure, the Nu-p standard and how those voids clear Regulatory Commission
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appeared in the containment gave Daniel the go-ahead, even structure. The workers work 10 though "about 50 percent" of the p
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hou:s straight for six days, take concrete test containers for the f rh off one day, and work four more base mat failed to meet specified 10-hour days until they get off for strength of 5,000 p.s.i. and in rQ
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, y, three days. The Nudear Regula-spite of the fact that NRC has -
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M tory Commission noted:"During never made an on-site strength M a discussion with personnel asso-test of the base mat. In closing i
there is a good chance the ccm-ciated with the placement, the the case, the NRC wamed: "We pany could go bankrupt, and inspector was told that a ' race' will continue to monitor closely that would leave people without existed between the batch plant your work activity," and so will power."
and placement crew to prevent the Kansas State Building and
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i A few days later, a spokesman or to cause a call for more con-Construction Trades Council from I
for K.C.&E. disclosed that Bech-crete from the batch plant. While their sub-office on Highway 75, tel would redesign anything that the inspector cannot attach any right down from the Arrowhead l
has a design fault in it during the direct significance to this com-Cafe in New Strawn, just three first year of operation. "That is petitive <pirit, it is indicative of miles west of Wolf Creek.
the extent of their liability." No the general ' push' to get this
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reference was made to potential monolithic placement of 6600 problems relating to shoddy con-cubic yards done in a record Ggs, ;.pwj struction or to Daniel Intema-time." Such push, as well as
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tional Corporation.
the erratic and exhausting work
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By the end of May, Daniel re-schedule, apparently has not !
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portedly had made several orga-worked to catch up with all the l nizational changes at Wolf Creek, construction delays at Wolf U
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creating numerous positions at Creek.
the direction of the Nuclear Reg-Meanwhile, the chairman of,7 t, -
ulatory Commission. But public the Kansas Corporation Commis-15l pressure mounted, and on June 9 sion is urging a full audit of Wolf '. gg i
more than 1,500 people showed Creek's construction budget and g
- ,g up in the rain to peacefully pro-the state director of utilities is THEIRONWORKER 3
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