ML20063G993
| ML20063G993 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/26/1982 |
| From: | Bursey B BURSEY, B. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17198A158 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8209010263 | |
| Download: ML20063G993 (3) | |
Text
- UNITED-STATES 0F.AliERICAg,, _.s [,, ;. g..,
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NUCLEAR REGUL'ATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 00gRC 0
In the Matter of
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'82 ISO 31 A10:28 South Carolina Electr.c and Gas J
Company, g _a],.
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Docket No. 50hMEb SECRETARY I
DC sEimG & SERvrE
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Virgil C. S mmer Nuclear Station,
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DHANCH Unit 1
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INTERVENOR'S SUPPLEMENTAL FILING ON MOTION TO REOPEN THE RECORD AND CONDUCT FURTHER HEARINGS A review of the applicant's documentation on the cadwelding and 'rel'ated
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qua'lity control matters reveals the record is more seriously ince.Niete in
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this 'regards than I had previously suppose'd.
None of Mr. Jennings"alTegations can be refuted by the applicant's, recifids.'But rather, the lack'of records, the admitted inadeq acies in Quality control. and record keeping serve to buttress Mr. 'Jennin~g statements, especially about the pervasive nature of Q.C. inade-quacies.
The applicant restricted my access' to their records - I could not make copies
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3 or remove documents - and consequently, Mr. Jennings was unable to review the records, including those purporting to.be signed by him.
The training guidelines' on cadwelders were not applied in Mr Jennings' case (no classroom instruction, no written exam, no one week apprenticeship).
There is no reason to believe that the training guidelines were regularly applied.
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Jennings' testimony and the related s'erious GC deficiencies clearly contradict the Board's finding of fact and the Board's. ultimate rejection of 38 i
9 my QC contention #9.
Mr. Jennings' experience contradicts the Board's finding
>O 80 at page 33 of its Supplemental Partial Initial Decision of August 4,1982. To oru 7b wit:
Employees were obviously not " indoctrinated" properly concerning the oum 8Ei importance of an effective QC program, but rather indoctrinated in methods to O CD g'U(J ru circu:nvent required construction specifications.
" Pressures of construction jo-schedules. and cost concerns" likely led to the widespread practice of falsify-ing cadwelds to alleviate the need for cutting, sp
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'as required by specified procedure - contrary to Board findings. As already argued, the program of employee training and retraining was defective'.
In addit. ion a number of Board factual findings corroborate this new evidence of systematic QC/QA deficiencies, ie. deficiencies in the Daniels QC program were supposed to be remedied by SCE&Gs parallel inspection program and demands for more effective performance by the constructor.
Only after the complaints by a fomer welder, Clarence Crider, did SCE&G subcontract for the 100% reinspection of some 14,000 socket welds leading to the reworking of several thousan'd, all of which has been previously pass' d by QC.
Many were not reinspected or reworked e
because they were imbedded' in concrete; these were deemed " acceptable because of the' reinforcing and restraining action of the concrete", and design
" conservatism".. I wonder how many interelated construction deficienc'ies can be overlooked in the name of design "conserv'atisrh".
In support of my Motion to Reopen the Record and conduct further proceedings.
on contention #9, I request the opportu'nity to review and respond to the submission of the Staff and Applicant prior to the Board's ruling on 'this mot' ion.
I believe this is necessary in order to p'ennit Mr. Jennings to refresh his recollection concerning specific welds he performed and the apparent falsification of QC documents.
This will also provide an opportunity to confirm Mr. Jennings' evidence and belief concerning the widespread nature of welding And QC falsi-fication.
In addition, since I am unable, due to lack of resources and the availabi-lity of technical expertise (as described in ray affidaiit) to present facts which may be essential to ray Motion to Reopen, I request this opportunity to respond to Applicant's and Staff, and the opportunity to permit further affidavits to be.obtained.
If necessary, in order to supplement an unsatisfac-tory record, I hereby request the calling of independent consultants by this board in order to reach an informed decision by this board.
SCE&G (Virgil C. Summer Unit 1), Al.AB-663,14 NRC 1140,1152 (1981).
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3 Attached, hereto, I am also enclosing my affidavit, and the sworn statement of Mi. Jennings as given to Mr. Bruno Uryk of NRC Region 2 Office of Inve tiga-
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tions.
Included are FSAR figure 3.8-11, " Wall Reinforcement"; figure I, React'or Building, and Crack Pattern Area, figbre No.145 from _tje Reactor Containment Building Structural Acceptance Test GAI Report No. 2278.
Respectfully submitted, L4JLu Brett Bursey, Inrervenor
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August 26, 1982 e
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