ML20082K030

Affidavit of Sandler in Support of Coalition for Safe Power 831014 Show Cause Petition

ML20082K030
Person / Time
Site:	Columbia
Issue date:	10/13/1983
From:	Sandler S NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:
Shared Package
ML20082K035	List: ML20082K030 ML20082K047
References
NUDOCS 8312050018
Download: ML20082K030 (7)

Text

~ -

~$@RDS@H W E@sBGB 'po{ '

- L Paq, Original d:cument nst available to NRD

~

. s 9

' 5 '

Certified by ' 80,' ; CA dc.c s _'

DOLKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION  ;

13 GH 18 P3:29 BEEgBE_IHE_Cg5HISSIgN CFF."~ C: 5. ,

CC' : _i 'liG 5 Hb ."

) 3RMlCH In the Matter of

)

WASHINGTON PUBLIC POWER SUPPLY SYSTEN ) Docket No. 50-397 et. al. ) Permit No. CPPR-93

) -

(WPPSS Nuclear Project No. 2) ) I AFFIDAVIT OF STUART SANDLER IN SUPPORT OF SHOW CAUSE PETITION OF COALITION FOR SAFE POWER .

l 1

1. My name is Stuart Sandler. In 1977 I obtained a bachelor's degree in welding engineering from Ohio State University. The Ohio S'c ate curriculum included extensive training in American Welding Society (AWS) Code interpretation. Ohio State is one of the few schools in this country with an accredited welding engineering program.

I was certified by the American Welding Society in SMAW and GMAW processes.

2. I was a welder for 5 years, have designed and constructed welded corra11 systems for cattle handling, and during 1977-78 worked for Commonwealth Edison of Chicago as Quality Assurance engineer for welding at the Braidwood nuclear site. From April 1978 to May 1979, I was employed by Burns and Rose Welding Engineering (Burns and Roe) as a I welding engineer at the WPPSS #2 nuclear co,nstruction site.

8312050018 831013 PDR ADOCK 05000397 G PDR l

3. While employeed at the WPPSS #2 site I held the position of Welding Engineer in charge of all site welding l

procedures. I reviewed all welding procedures for j conformance to Code and Specification requirements, and for j engineering suitability to the Job requirements.

4. The subject of this affidavit is the lack of ,

quality construction and effective on-site Quality Assurance f at WPPSS #2 and the roles of the Nuclear Regulatory Commission, WPPSS, and Burns and Roe. .

5. In April 1978, rework on the structural members of the WPPSS #2 containment was proceeding with three full shifts of welders and fitters per day. The rework was necessitated following the widespread cracking of welds in -.

the Sacrificial Wall surrounding the reactor and in the structural beams and columns welded to the Sacrifical WaII.

The construction of the containment. superstructure had not addressed weld sequencing, as directed by the AWS Code, and this was known to Burns and Roe, WPPSS and NRC. Weld seq'uencing determines the order in which welds are made in a structure to control the direction of the heat flow in the structure and to ultimately minimize the amount of shrinkage the structure undergoes upon cooling.

Structural steel in the containment had been welded 1 into an overly restra'ined condition which, coupled with 1

numerous incidents of defective welding, led to the cracking of many ma3or safety-related welds.

.- <r,, - , . e- -, - -- e

l '.

i

, 3-5 ,

, l

6. Burns and Rose discovered in 1978 that many of the l

l AWS welding procedures previously used in the containment i j

j involved numberous violations of the AWS Code. All of those 7

)  !

I procedures had been signed off by both Engineering and  ;

1 i Quality Assurance personnel. But the fact is that the 4

procedure had been_ approved by en Engineering group which i

had little, if any, formal welding engineering background at the time, and by Quality Assurance personnel with no formal j engineering background at all.

j j Federal document 10 CFR 50, Ligensing_gf_Egggustigg_agg M1111391190_E99111tigg, Appendix B, states that Quality i

j Assurance shall establish measures "a =

• to assure that

• special processes, including welding * *

• are controlled , ,

i l

and accomplished by qualified personnel using qualified procedures in accordance with app 11 cable codes, standardai l

l specifications, criteria, and other special requirements. *

• * [The3 individual or group * ** assigned the j responsibility for a *

• verifying that an activity has been correctly performed [must be) independent of the individual

{ or group directly responsible for performing the specific 1

l activity." During the time I was on site, Quality Assurance did not operate independentJy of Engineering in its reviow I of welding procedures. Nor was Quality Assurance involved l

l in making sure that the procedures used to repair the critical structural welding in the containment were in i

accord.nce .ith the app 11 cab 1e code. .nd s,ecific.tions.

I

?

1

l I

4- i l

l For example, one of the procedures used to weld the structural steel in the containment was WP-14, which provided the instructions for reworking the cracked j t

containment welds. During the time I worked on the WPPSS #2 l sita, that procedure was constantly being revised without ,

any Quality Assurance review. Major changes to the procedure requiring a whole new revision number were signed off by Quality Assurance, but it was merely a rubber stamp without thorough inspection. Only one member of the Quality Assurance group signing off on changes to WP-14 had any formal engineering training. The rest were high school graduates, although some were ex-welders, having little in-depth understanding of the complicated code they were .

s supposed to be referencing. Eventual they received formal on-site instruction in AWS code review. Even so, these Quality Assurance employees did not.have sufficient authority to assure an adequate, independent review of the welding procedures. The routing of the prccedures for approval within the system had been turned around so that final review of procedures was done by Engineering rather than by Quality Assurance. Quality Assurance comments or

! disapprovals which did not coincid,e with Engineering I - decisions were simply ignored.

Enginer: ring also' made specific additions to and deletions from the repair procedure on a case by case basis with no Quality Assurance review whatsoever, and without any independent check on the quality of those changes or their

.-.n . . . - . . , . . . _ ,

5-adherence to Code re uirements. I and other Barns and Roe personnel made countless changes in.the instructions for the repair of individual welds without any consultation with Quality Assurance.

7. In November 1982, I talked with Mr. Toth of the NRC, headquartered in San Francisco. I asked him about the roles of Quality Assurance and Engineering in qualifying procedures to Code. Toth replied that code interpretation was an Engineering function having nothing at all to do with Quality Assurance. He also said that checking qualifications of Engineering personnel on site was still a problem as late as November 1982. The most effective means at Quality Assurance's disposal to check on the .

qualifications of Burns & Roe engineering personnel was the audit. Such an audit was never conducted by Quality E-Assurance during the period I was present. In fact, there were no qualification checks of on-site Engineering personnel at all.- Had such checks been conducted, they would have revealed the numerous individuals who were called engineers but who in fact had no formal engineering training whatsoever.

8. My experiences at WPPSS #2 evidenced'that Quality Assurance was considered only a paperwork function. Conformance to Code requirements was Iett up to.the 86=- Engineering groups which had been responsible for oli the design arrors and I

1 4

• - . _ , , _ . . . . , . . ., ._ .,. , , _y , _ , , ,

_a___ _m_,,,,.m - . - -

I l l ,,

j Code noncompliance *in the first place. Engineering wrote i l

its own procedures and then approved them with no regard for j the checks and balances supposedly built into the system by i federal regulation and NRC supervision. Quality Assurance did not assure the control of qualified welding demanded by 10 CFR 50, and this lack of proper Quality Assurance i

surveillence was.known by the NRC. 5uch systematic negligence forbodes many future problems and poses an undue risk to public health and safety should the plant be permitted to go on line.

-- d&ww AA-- Stuart Sandler Dated this 13th day of October, 1983 ,

I

,- - . l

, e 1

s STATE OF OREGON )

) an. .

County of Multnomeh )

I, Stuart Sandler, hereby swear and affirm that the foregoing affidvait is true end correct to the best of my knowledge, information, and belief.

__M_M/h__

Stuart Sandler ,

• s N

SUBSCRIBE AND SWORN to before me this  ! day of

__$fdd2 (c__,

~~~~~~~

1983. . E

_ _________o_d_s_!_______

Not ry Public for Oregon Commission Expires:

l l

5 l

l

. . - - -