ML20062H770

Ack Receipt of IE Investigation Rept 50-322/79-24. Investigation Conducted in Manner Which Precluded Any Meaningful Assessment of QC Procedures

ML20062H770
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/20/1980
From:	Chong L AFFILIATION NOT ASSIGNED
To:	Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19344E167	List: IR 05000322/1979024 ML20062H745 ML20062H749 ML20062H751 ML20062H756 ML20062H767 ML20062H770
References
NUDOCS 8008270569
Download: ML20062H770 (9)

Text

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. A T1pmosEY AT L.ame .

464 WES";" SRCAoWAY NI"W YORK. N.Y.10012 V nem. oe 4c.ec.

ne . ma~ . -- omce g

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May 20, 1980 Janes M. P l an, Deputy Director U.S. Nuclear P.egulatory Cc " ssion r, 631 Park Avenue .

King of Prussia, ?a- cylvania 19406

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Da> - Si== .

'f",=-k yon for fo wa-ding a copy of NRC Investigation

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Report No. 50-322/79-24 concerning the allegations of construc-tien defects at'the Sherak> Nuclear Power Station.. I have reviewed the repc_-t = 4 would like to cc= ment en its scope, methodology, and f 4 -A i gs. , ,

? on our earliest centacts in providing in'o_ ation on

- the defects to Dr. Cha-les Gallina and other'NRC investigators,

.- .. we have tried to i= press upon the NRC our belief that the prob-

. la-= at Sho:aka re__ " - e generally the failu e of LILCO's oroj ect.na- =ge=e=t to implenent the stringent labor practices.

. and exercise the supervisory control recuired for defect-free cons;._ action of the nclea: reactor systen. Tais failure is

--i=plicitly acknowledged by LILCO in explanatics fe the soaring ccst everruns and delays to completion of the reacter, was noted 'in the 3 ooc-M ' e= study done fc LILCO in 197 8, . is docu-mented in =en+My centractor s - m=-ies and trend analvsis recorts . . . .

snow:.=g repeatec. de:..1c:. enc:.es and low wor.xer procuctivity, is

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the subject of investigatics by the Public Service Co 4ssion of New Yc k, c=- he 4 # erred f cs the variety and depth of the defects alleged, and appears to be co= men knowledge amo:g the werke s tha = elves e en speaking privately c: anonymously.

However, the point sea-= to be lost with the NRC which, accor e i;

to Dr. Galli-a, "does not get involved with labor problems."

The nyopia of the present investigation report, which looks c=1y ,

. to s'pec-fic 1 pieces cf * =-dwa e without regard to the centext of

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the allegations, unferscores ever more clearly the urgent need

~ forac%1ete physical i spection of the ec=struction thus far

.and a reviews of e.c.r.li:v cen ol =.rocedures and documents b..v an

. indepencent and cbjec ive consultant, in order to dete==i=e whether the Shereha= reactor has been const=ucted or can be ce=-

pleted in a ec dition whip:h ensures the public safety.

Mere =ver, the methofclogy cf this i vestigatien shcus that the NRC is usw3 1 ' # m g c: incapable of taki,g the action 1 l

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.V.S. Enclea  ?.cgnlatory Cc-4ssion .

4 necessar.:- to ->ke.the safe constructica To give you of Shereham a background an issue to the real .to itself and to LILCo.

investigatien, we provided Dr. Gallina with relevant court transcripts, news clippings, magazine articles, and ah'stracts of discicsces frcm confidential sources describing construc-tien 3 chless at Shcreha= alleged by at least 16 present or We also arranged personal Ibr=e wc kers at the site.

inte: views with two of the wc kers a.nd provided szentacts fe

lea @4 g others. We advised Dr. Gallina of our' belief that other werkers would not cone forward with infc= nation unless they were cenvinced.that the investicatien would do sonething

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subs'2-tive for the sa'ety of the reactor, that their identi-

• t:ies- verld be pectected, and that they would not be proseented

' if they 4 'c- =d the N3C of w ongdoing in which they were im-plicated. We further advised him that the issue of co=structics defects might be associated with the controversial. ~

was trial of anti-nu~clea: . protestors cut of which it arese r a sore point v_- _h the unions whose workers are e= ployed there, ami had. Seen referred _to. ;in an A3C televisien docn=entary on drug abc.se and lax security at the Shoreham site. .

3ather than dealing effectively with these circumstanc'es,

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...'% 4-vestigation was c'enducted in a nanner which Leads precluded any were not

. m a = '--' assessnent of the problens alleged.

fellcwed, we we e effectively excluded f:cm pa-ticipatien, the perception of rou' 4 e NRC inefficacy was.'nct ove:cene, and' ~

i little was done to provide the kind of assurances and protective l atmosphere w'-kh would. encourage workers to disclose infernation.

App;cval of a written fo:s of confidentiality agreement was  !

stai'ed un-21 -Se investigation was many weeks underway, and . . .

even adter was not used in the en-site interviews with workers at the )

site. Che pesting of notices and I'-"ning one-inch ads 1 in he hackpages of the local newspaper gave the investigatics Quite only 2-al v.sibility 4 and little c no credibility.

si= ply, the "" eged defects could not be substa .tiated because in which J '

the ERC took no effective seasures to create the context i that was possible. ,

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• With resnect to the alleeations which were specifically raised, the N?.C fin 4#-*gs display a propensity for discounting the 73 e t te'stinony of wc kers who witnessed the def ects and relyi=g instead pen LILCo's paperwork and written p ccedures

- whose reliahty is far f cs established, and which the NRC itself cited fc deficiency en nunerous occasions, and (as a last resc:t) by accepting the blandishnents of LI:.,Co espicyees, cen.racter and subcontracter persennel, and .cther biased epinient The substance of the allegations,is that defactive work at )

Sherehz= is being concealed or overlooked, and it will net be fctnd by relying upon the scurces which have prevented its S'---*-i ed.below are =y ec=nents en the deficien .

i discovery.

cies in he fi= dings cf the investigation: e f

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. ~ U.5. Enc 1 Gar lec...1 ate _b. Cc-4 ssion . .

'.llecatic No. 1 3' g to the allegation of cracks in the main In respc stean ' 4 es fc svsten, the NRC noted that. .the

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QA c.oc =ents s.nowen 28 2. stances c: p:.pe cafects rounc sy the cost act '= # spection 3_Ap. F cm this, the NRC concludes that no further defects r*-*#9 ,

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+ Ecwe7Er, 'h4 s 277 egation Concerns Cracks 2.3 d e main.

. stea:= 14 es which were not documented and rep

• 4 ed. The NRC ec2 cedes, +%=t it has inspected only one of the four main lines

. and su of the exposed areas. No attempt was made to inspect the-other ^~ ee "" es in areas which are not exposed. , ,

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'It sionld be noted that during a previons randem in-sr_ection, the NRC found -Lhat L'ELCO had f ailed to document this-wall defici=-r-ie's in -Lhe steam piping. The NRC required LI.,Co to fill out the ree-4 ei nonconfcM ty repe-ts and to send sections of ' h piping back to the vender for repair. . Thus, the NRC's re' 4='ce here on LILCO QA doct=ents is nisplaced, ~

a.nd it shonid have actually inspected the stea= lines in

. reso. c. 274-= to this allega-Lion. .

. ' ' eca n No. 2 .

I F:cs a review of te=peratre records in the c=ine. rescrts .

the investigation found 4-e instances of nonce =pliance which sr.hs'*-tiate ^~- 4 e =egation that the heaters used for curing ~

the critical concrete placements fer the cont 4-- ent walls were not =:c:4:1v maint=4 ed.

Six previcus NED (nonconfor=itv) re-pc ts we e also fou=d.

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In the -4-d s .S=a ac ach en race 17, the repert states that te:=eratt e rea73 gs were taken daily at =ct less than 6-hour inte- ;rals.  ? ss---=kly,1 cager intervals occurred be-tween sc=e rea73 gs. A te=peratr e reading the next day wculd

=c: necessa-ily shew whether the heaters had been kept en d= ing the night.

Almn@ the investigate:s state that expos =e of the

- s=f ace a# "-- concrete to freecing temperat=es would have

. caused chipp'i=g or fla?' g, there is no indica _ien how dili-

. cently c ex ensively they checked fer such flaking c: fer' pate' 3 g eve- the .flakbg.

A11ecation Nc. 3 "ne NRC responded to the cllegatics that the fer=s fer pc=ing were scripped f:c= the cencrete less than 24 h==s afte:

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t.S. Nuclear Reg latcry Cc d.ssion ,

pouring hy challenging the alleger's knowledge of concrete pouring and by no'4 g that the QA documents shcw that the fem were re=cved afte- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

N allegation is that forms for these pours were often poed the very next day (Tr. Dec . 6, pp. 19,22) , i.e., in'scne ce.ses, the nor-4,g afte a pour on the previous afternoon, and tihat this was not recorded by QA inspectors (Tr.nDec. 6, pp.

2'3-24). Wii=-n Muselar, the assistant p cj ect.ranager, .

testified under c c>ss ex=-4 ation at the protestors trial (Tr.

Dec. 7, pp. 83-89,105) that the field inspectors inspectedThus,- the concrete wi+4' 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after stripping of the forms.

the field 4 =pectors we:e not present during the stripping of '

. the fc-c , and the time of stripping noted in their reports was based c=1y upon state:1ects by the foreman on the job. The ' '

alleg'er stated than the fora un on the .j ob regularly cent:a- --

vened the Q.2 regri enents. Thus, the NRC reliance on the QA records is insufficient to respond to this allegation. The -

NRC did not conduct any actual testing of the placements on which the idan'4 'ied fore =an worked. .

..Aliecation No. 4_

. The f4w?4 ,gs here att=npt to rebut a detailed eyewitness account of i=p:cper patching of concrete defects (Tr. Dec. 6, pp.23-33) by discussing what the proper procedure should have been. If crack.s and honeyce=bing were being concealed, it would ce-">4-'y have b.een done without obj ecticn frc= the QA inspec-2:s and without triggerring a laber dispute on between one hand, it trades. The findings are also inconsistent:

was the usna,1 practice for the OA inspectors to check a pour up to 24 he rs after the fo =s were stripped; on the other hand, the repern quotes coment fi i shers as saying that the inspecters wc"'M % - -- as socn as -; he fc_as were raised. -

A11ecation No. 5 The megatien here is that in = y instances faulty (locse) cadwelis were encased 'in the concrete pours. To refute

' this, the KRC investigate s rely solely on what the p cper

-precedures sho.C!.d have been, and upon the ec=pleteness and iac-curacy of the cadweld inspection rece:ds. The KRC itself previously cited LILCO for failure to keep in-process cadweld inspectic records and fe;- f ailure to fellow in-process cadweld procedures (_.nspectics Reper-;. No. 74-02: LILCO letter cf May 6, 1974). These violaticas occurred during the time period cf

- the allegation ani nay therefera be deemed to substantiate the allegatica.

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U.S. Nucica: Regul'atc y Co-4 ssica

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1 Allecation No. 6 i

I The alleger stated that en numerous occasiens he wit-nessed watersteps not being p cperly sealed c: even c=itted entirely. The NRC da-4es his allegation by noting that the waterstep inspection rec,c ds show that the wate_ steps were dere properly. Yet, the NRC itself previously pited LILCO fc the i= proper marking cf waterstep inspection" records

. =cu'-4 mely with an "S" (for "satisf actory") even though the .

- item was not applicable (Inspection Report No. 75-03) . This also occc red during the alleged time frame and tends to

- substantiate the al'egation. .

' ' ecatiics No. 7 .

1The alleg'er testified that he was allowed to weld "a:cher plates that were used to hold pipes to the wall" (T The Dec. 6, p. 45) even though he was not a qualified welder.

NRC finM gs speak only about a-kedment plates and ignoras

• pipe supports widely used in the Radwaste anilding of the

- cencrete exp=-< ion anchor type.

.a' legation No. S This m" egation '. hat % eaded t:.e roc.s c: th'e concrete f c:=s were p" ed f c=. the concrete , is consistent with alle-gation No. 3 that the forms were pulled less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after pouring. Renoval of a 9 eaded rod without a sleeve ma=-s that the concrete was still soft. The NRC denies this eyewitness account as not credible withcut any actual inspectics of the areas uhere threaded rod was used.

Allegation No.10 1

In responding to this allegation, the investigators .

reviewed the doc = ent packages for diss --ila netal welds to dete =ine if IR-308 weld wire was i= properly used. The re-crisitics fc-= the=selves co'.ild have been '4 ad in afte-eards

.tc indicate the wasrectired made toIR-309 wire.when metallurgically ex= in #,e factanone was used.

representative Ne attenp:

he welds done i= the specified areas and time fra=e sz=pling cf to deter-4-e if IA-308 .i.n, fact was i==. coe:1.v. used. -

Allegation No. 12 Although the NRC found no irregularities in the repai

' cf this defact.ive turbine condenser weld, we helieve that a 1 .

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-0.5. N==Len- As=clatc - v- C- *ssion .

large-scale reg =4- of 10 linear feet of weld is exactly the kind c' # egularity in the cc=s-duction which puts in denht the efficacv cf the c.cality. centrol =. cocram and the safetv.

of the reacter syste=.when it is operated rader the s-desses o f act-- = ' ogera-#-e. ceniitions. .

A11ecanics No.14 c.

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- -L The allegation is that S&W, formerly the lead contractor on the censactics project, was relieved of its responsibilities

. when it conid not control the deficient perfo_-= ce of sub-cent acters, sunh as Regor and Courter, which LILC'O insisted

<o= nsing.~ Dn-ing the period from Septe=be- 1977 ongh Augnst 19 7 8 , f---4-= '= 7 shifts occu red in project management, includ-i=g ase _--tics of lead role by LILCO and/or UNICO and relega-tien cf S&W to lesser, engin==-4 g duties, depart:re of Thomas Burke and a__ival of Joseph Nosarro as project --e=ger, and the 3coz-A11en audit ordered by the ?SC for LILCO of the con-struction at Shoreham. The NRC report is silent as to why .

these changes were made and how they related to the cuestions

.conce - u c=st overru=s e dela.v.s and ext emely low worker pro-

...d ctivity.

A11ecation No.15 -

. As ncted in the NRC findings on allegations Nos. 12 and 13, hyd:ctes'4 g of the syste= revealed a 10 foot crack in the tn: hire condenser welding a .i caused wate leakages'to reach the 8 foot leve' 4- "e secondary containment. A hydroflush on June 13, 1979 res:1ted in at least a blown gasket in the core s= ay syster. The latter was not witnessed by N2C inspectors but c:1y re-iewed fres documentation after the fact. These ,

f ailures substantiate the +' 7st of this allegation that the QA/QC prog as has net been effective and that -le reactor svste= =av exoerience failure under the stresses of actual co-era-- g co--- tions. .

A11ecatics No." 21 . .

r.is =~iec.ation was directed to the coa'# c. en the inside of nhe rea==== pressere vessel, not the pr#-a y contaic=ent w=

s disc..ssed in the report. The c daring of uncualified persensel cff he ich =ay not have been docu=ented is the NRC inspectics re===ns. .Several cf the wc:kers who centinued on the task were in' f aen not enalified.

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. U.S. Nuc1 car 3:gniatory Co==ission ,

Allecation No. 22 The N3C findings substantiate this allegation of severe The inves-

chl -= encoc=terec.c.s unbine the condenser box.

tigatcrs =ade no inspection of' the tubes for. gouging c:

- potential fractu a but reli,ed instead on S&WAlthough documentation the con-and

-1 "4ted visual inspection of tube ends.

i denser nor-=y operates under vacuum, there ag.e some types

+ of svstem f= 4'ures which could result in release of radioactiv-

'- ity 'inte the cooling water from the Sound.

Allecation No. 23 Ynis finding substantiates the allegation as to defect-ive welding of the condenser box. No atta=pt was made by the investigators to ex= ine the radiographic rece ds for evidence of the. =ec.ed foreien obj ects found in the defective welds.-

' Again,- the N3C discou=ted the direct observations of welders who did the repair work and accepted the op4- 4 on of Field .QC that -le e were no foreign objects problems. .

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A11ecation No. 28 .

Oc=nent on

-4 s NRC finding is reserved pending a furthe:

_ review cf the da a s"- 4tted by LILCO cn soil liquefaction

ponentiz.1 under the reactor building.

. A11ecation No. 30 . .

The 53C '#-di=g en this allegation bracenly states that

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it found no evidence of pressure en construction workers not

. .. to ecse fervard with infc==atics to the NRC. .

Tk = finding does nct mention that Jchn Iverett, a car-i pester who worked at Shoreham f:cm 1973 to 197 6, was removed '

fres his positics as shop steward by his unien, was te==inated by his e=cicyer, and has received anonymous +" eats on his life after he tes-4"ied abent construction pechle=s at Shereha= dur-

. ing the trial in Decie=ber 197 9. At a hearing en a =cticn fc:

- pre 14 3 .z:_A injnnetien in a suit by Mr. Everett for reinstate-

=est, D . C=1'i a testified under subpoena from Mr. Everett's asterneys that it is not uncv=nen for verkers in Mr. Everett's oositic: to feel that kf,nd of pressure. 0 her cons's.:ction ,

works:s who were asked to testify at Mr. Everett's hearing l refused to do so because they were afraid of losing their jobs.

y.:. Everett's suit is still pending.

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U.S. Nuclear Esgu1ato-v. Cc-- 4 ssion .

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l Jock Mcc 3stal, a fermer veldred cent ci clerk at Shore-l ha= e_o also testified about defects at the trial, has had a from five stories

! ladder suspiciously 'k own or dropped near k4 up, has been the brunt of cther inti=ication at his workplace, a=d has also received +' eats on his life.

Dr. G=4 = was advised of the above and~ expressed his I

f.,; nab 4'4 ty to p ovide assistance or take rem =Ad a.T action. .- ..

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~ Tere:ghout its findings , the investigation evidences a g eater i=^= est in questioning the credibility or the under-s'=-74,g of+-k. allegers than in getting to the be~ttem of the l

=esations. The shallowness of the findings suggests to me t'a.t perhaps the investigators the=selves were under pressure -

The repo-t goes to unseemly-to p oduce a whitewash for LILCo.

'eng-= to -f-= size that none of the allegaticas were substan-tiated. Ecwever, a more cbjective interpretation would be that l

allegatio=s Nes. 2, 5, 6, 14, 15, 16, 22, 23, and 30 were groundet 1 Allegations  !

in fact er " "errable f:cm the overall context.

Ncs . 1,3,4,7,8, 9, 10, 27, 28 and 29 were insufficient 1v in- i

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vestigated, and Nos.12, 13,18, 24 and 26Allegations were of a nature Nos. 17,

^=t jus'4'ied the allegers' conce ns.

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19, 20, and 21 were either too generally stated or misinterpreted l

Finally, the findings in sene cases differ l fc resolutics.

-arka#'y' f c= the prelim 4"ary reports I received f:cm the inves-indicating that l

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.tigators en the prog ess cf the investigation,

-substantial ediWg of the w-itten findings has taken place.

. In cice4 g, I would strongly urge that the NRC. correct the t.re ce_, clencies in its :..Incnngs anc, _urt.ner, consica larger i= plicatic: s of the se__y histery of laber practices and GA/QC deficiencias at Shorehan which the specific allegations  ;

highlight. As a further exz=ple of the necessity for a nere l cesscie==icus 530 =cle, I note the recent errest of a LILCO con-tractor's q-="ty assurance inspector for selling marijuana l

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dr i g a lunch'4-e bee: and pot party involvi g some 30 to 60 The fact that many workers are )

e- -=was ce=str.:ction verkers.

en the job ste ~3 is well known to everyone except, apparently, the ERC and I,IICo management. The response of a LILCO cfficial was typical: just because the QA inspecter was a rested fer

. selling c :gs off the site does net necessarily mean that .:-

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'wc k c= thessite was deficient.

' We, as does the general public, rely heavily upon' the

-tegrity cf the NRC to take every step necessary to ensure the safe c==s':= :ction and cperation of the nuclear power plant.

che ::20's reluctance to agg essively regulate LILCO's constructi e

prac ices a.s e=ocL=g pucarc con,acence :.n t.ne NEC, Ls putt ng

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r u c.=e s .~.. . e.nr ve===v utrec c:

. ~ U.S. Nuclem- Recul'atc ,7 Cc

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4 ssion * *EC 9 .

in dccht "->t the reactor system could operate without a =aje:

accide=t, and is fc cine resocnsible state and local authorit-es to cons:..cer tsce. . - tar.. g an incepencen - rev:.ew c: the cen-st: cticn, a step which should be unnecessary if the NRO . vere deine its deb s with intec.-itv and cc =itnent to cublic sadetv.

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Sincere 1V. voerst

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Leighton K.,Chong cc: Dr. &=-les, Gal' im* .

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