ML20149M442
| ML20149M442 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/06/1987 |
| From: | Tracy S EMPLOYEE'S LEGAL PROJECT |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20149M429 | List: |
| References | |
| NUDOCS 8802260048 | |
| Download: ML20149M442 (4) | |
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Empigee's legal Pr lect s
P.O. Box 633 ENCLOSURE 2 Amesbury. MA 01913 (617)388-9620 July 6, 1987 William F. Kane, Director U.S.NRC, Division of Reactor Projects 631 Park Avenue King of Prussia, PA 09406
Dear Mr. Kane,
Enclosed are the answers to some to the questions the Employee's Legal Project received at the beginning of June regarding affidavits and statements submitted to Jacques Durr in April,1987. We are still working on getting the answers to many of the questions, but I wanted to send you the answers we have received thus far. They are on the following 3 pages.
Some information found in a utility report regarding cold springing may be of interest to you. Cold springing or cold pulling is an issue which comes up again and again in allegations by former enployees. @e statement was made in Inspection Report 50-443/86-52 that the NRC was aware of only one documented case of cold pulling. In a Report of Self-Initiated Construction Project Evaluation submitted by Public Service Conpany of New Hanpshire to the NRC for the period October 25 through November 5, 1982, cold springing is mentioned on page 90 in the middle of the page:
"A review of closed NCRs from January through March of 1982 indicated a number of NCRs were originated as a result of cold springing of piping. At the present time, there is no trend analysis of NCRs by the Piping Contractor at the site."
% is report was received by James M. Taylor, Division of Reactor Programs, IE on April 26, 1983, and seems to indicate extencive cold springing was documented. The section of the report quoted was sinply using,.old springing as an exanple of another problem (lack of trend analysis). It does, however, substantiate allegers' contentions that they witnessed many incidents of cold pulling.
Several problems with falsification of mnufacturers' inspection records by vendors, and lack of inspection certifications by manufacturers require reporting. Material manufactured by Boston Pipe, including valve 2, custom-n made spool pieces, and other stainless steel piping was installed although y@a.
they were never certified as inspected by the manufacturer as required by
-g procedure. The alleger observed this deficiency between the spring of 1982 So and the spring of 1983. Electrical equipnent supplied to UE&C by Mass. Gas and Electric between the sunmer of 1983 and the sunmer of 1984, including but not limited to wiring and circuit breakers, was never certified as
@d inspected by the manufacturer. Instead, the supplier, Mass. Gas and 8@
Electric, signed off on the equipment as intpected although that conpany g4 was not qualified to do so.
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@@o I will speak to you by phone about these problems in case you have l
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aMitional questions.
- cerely, L&t t ta haron Tra Project Coordina
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Emplsyee's legal Project P.O. Box 633 Amesbur/, MA 01913 (617)388-9620 ANSWERS 'IO NRC QUESMONS REGARDItG INFORMATION SUBMI'ITED. APRIL,1987 Attachment C: This affidavit was not submitted by David Day. We are expecting answers to your questions from this individual soon.
Attachment E: We have sent this individual your questions. At the moment he is ill, but will respond when he can.
Attachment F: No answers yet.
Attachment I, Paragraph 6, Question 1: About 2 1/2 to 3 years ago, while he was with a New Hampshire Yankee inspector and another inspector, they were there while the core barrel was being moved. He saw a crack about 18 inches long which changed direction about four or five times. both of the other inspectors saw it as well, so it was reported at the time to NHY.
His job was final inspector for Pullman-Higgins, but he maintained a continuing interest in the problem.
Question 2: h e cracking problem was supposedly reported in NCR
- NISCOf 3, but when he saw the NCR after he went to EARS with the problem, he saw the NCR. It was 13 pages long, and conpletely out of order: page 3 was written before page 1, page 6 before page 3, and so on. %e NCR didn't make any sense, as the EARS person admitted. As far as he knows, there was never any disposition of the NCR. and the NCR rade no mention of any repair procedures having been done on the core barrel, nor did it mention any defects in the core barrel. He also reported the problem during his exit interview in July of 1986, and subsequently received a letter from Public Service Conpany saying there was no problem and the case was closed. (He thought when he talked to EARS that he was talking to the NRC.)
Question 3: @e crack was located in an area where there is an upper and lower flange protruding out from the core barrel. Sketches to follow later.
Question 4: He has not seen any evidence the core barrel was ever inspected in a proper nanner. When he took the problem to EARS, he went with two EARS engineers to look at the core barrel, but it was at an angle where the crack could not be seen.
Attachment J, General: Ihe allegations were rade by four different people.
Allegations three and four were made by the same person.
Attachment J, Paragraph 1.a through Paragraph 1.e: We are waiting for answers to these questions.
Attachment J, Paragraph 2.b, Question 1: The problem with "greylining" is that specifications are supposed to have some meaning. When procedures are rewritten to conform to practice, it undermines the purpose of having standards and specifications in the first place. Greylining could be conpared to rewriting the law to legalize a prior illegality. Both voiding large nurrbers of NCRs and the process of greylining are perceived as problems.
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Question 2: At this time the alleger does not have a list.
Question 3: Greylining was practiced by all contractors.
Question 4: All NCRs should have been logged; a voided NCR abould still be in the log.
Attachment J, Paragraph 2.c, Question 1: The lack of the engraved manufacturer's nunber was the materials traceability problem.
b Question 2: Missing nunbers create traceability problems. In the event of an accident or equipment failure,-neither the vendor nor the manufacturer can be located without the number.
Question 3: Relief valves 456A and 456B, on the steam generator, noted during the first hydro test in Unit 1 (RC IT 01A).
Question 4: %e incident ocurred during the first hydro test of Unit 1.
Attachment J, Paragraph 2.d, Question 1: Cannibalization and retagging mean non-specified equipment or parts are used in place of the specific equipment of parts called for in design specifications.
Question.2: It is unknown who retagged the equipment, how it was done, and why it was done. The tank and punps in the deisel generator system had retagged equipment for which a UE&C NCR was written, referring to "DG-SKD" or "TK."
Question 3: The problem with retagging and cannibalizing equipment is that the non-specified equipment and parts may not function the way the specified equipment and parts are supposed to, and traceability becomes very difficult.
Question 4: The alleger does not have a list of the equipment.
Question 5: he retagged equipment could be located by conparing the inventory of materials not used in Unit 2 and the materials specified for use in Unit 1.
Attachment J, Paragraph 3.a, Question 1: Procedure was violated because a welder welded past the thickness maximum allowed by ASME code, wo welders are required to corplete work on large bore pipe, a practice referred to as "stacking the welders." No documentation could be located to certify that two welders had done the work.
Question 2: The alleger would need to review a blueprint to give the exact location of the weld.
Question 3: The NCR nunber is not in the alleger's possession.
Qeestion 4: %e alleger was working for Pullman-Higgins. His supervisor's name is not available.
Question 5: %e remaining 20 to 30 welds are thought to be problematic C _ ________ ______._________________
O because of the aforementioned problem.
Question 6: W e problem occurred in late 1984 or early 1985.
Attachment J, Paragraph 4.a, Question 1: The alleger speaks to a welding process which requires two welders, depending on the thickness of the weld.
Question 2: All large. bore pipe is affected by this concern.
Question 3: n e alleger does nct have tER nunbers, but states they would have been filed between late 1984 and early 1985.
Attachment J, Paragraph 4.b, Question 1: His supervisor harassed the alleger.
Question 2: The alleger did not report this harassment.
Question 3: S e alleger was searching through rod slips looking for documentation that two welders had cor:pleted the work so he could certify the W1d.
Question 4: Quality Assurance engineer.
Attachment J, Paragraph 4.c, Question 1: n e alleger believes all the large bore pipe welds are not properly certified because he could not find dxurentation that they were welded to code, r
Attachment J, Paragraph 5, Question 1: The alleger did not searer. the boxes of documents taken off the site, and so does not know what documents they contained.
Question 2: All processes requiring docum',ntation could be affected by the loss of the documents. Utility and G'c inspections could ~oe hanpered by loss of documents. Traceability of specific problems is it:possible without documentation.
Question 3: Alleger was enployed by Pullman-Higgins.
Attachment K, Paragraph 7: Wis allegation was made through an anonymous phone call to the ELP, and the alleger has not called in since the original conversation. Thus, answers to these questions are not availabk at this time. If contact is ever reestablished, the ELP will attempt *.o answer these questions.
Attachment L: The ELP will write the alleger to obtain answers to these questions.
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