ML20206M182
| ML20206M182 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/16/1987 |
| From: | Davis P NRC COMMISSION (OCM) |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#287-3125 OL-1, NUDOCS 8704200048 | |
| Download: ML20206M182 (21) | |
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UNITED STATES g~ " - -
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NUCLEAR REGULATORY COMMISSION ~
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WASHINGTON, D.C. 20555
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sEP,' LED A??,61987 OFFICE OF THE April 16,1987 If5.h '
MEf10RANDUM T0:
Emile Julian, Acting Chief Docketing and Service BrancNFFt..D %w 00CM f.
FROM:
Patricia R. Davis, Legal AssistantnWT ~ ":
Office of Comissioner Asselstine
SUBJECT:
SEABROOK PROCEEDING Please serve the attached letter on the parties to the Seabrook proceeding.
8704200048 870416 PDR ADOCK 05000443 3
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.A BECAUSE WE CARE ABOUT ROWLEY AND YOU 280 Main Street, Rte. lA Rowley, Massachusetts 01%9 Stephen B. Comley MA: 617-%d-1959 Executive Director D.C.: 202-628-2100 April 9, 1987 Earl E. Shamwell, Jr., Esq.
U.S.
Department of Justice General Litigation and General Advice Section Criminal Division Washington, D.C.
20530
Dear Mr. Shamwell:
On January 23, 1 ~9 8.7, I wrote to you following our meeting in
, January 15, 1986 regarding my concerns over the Seabrook Nuclear Power Station and the Nuclear Regulatory Commission.
To date, I have yet to have a response to my letter.
Recently, the Atomic Safety and Licensing Board recommended that Seabrook be allowed to conduct low power testing of its facility.
l That recommendation is now awaiting action by the NRC.
Once low power testing is conducted it will be impossible, due to l
contamination, for the company to convert the plant to a more conventional form of power generation.
Therefore, it is essential that we all act quickly to insure that the plant is indeed safe and that the NRC has been vigilant in discharging its responsibilities in this area.
To update you on recent developments, the plant has had several problems with faulty valves in the last few months.
Not all of these problems have been reported to the NRC, as required.
Considering the fact that the plant has had past problems with falsification of documents and that the NRC acknowledges that one of the Seabrook subcontractors--Pullman Higgins--has a reputation for sloppy workmanship, these latest events cast serious doubts o,n the safety of the plant and the diligence of the NRC in regulating nuclear plants.
I also enclose a report of the Employee's Legal Project of' Amesbury, Massachusetts.
The report was drafted in response to an NRC investigation of 61 allegations made by former Seabrook workers.
As you will note, the NRC overlooked significant evidence in concluding the allegations were unsubstantiated, including evidence the NRC had previously collected in earlier investigations.
Due to the length of the report, I have included only the text, but will provide the exhibits upon request.
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s Please advise me on any efforts your agency has made in these matters.
r ru y yours en B.
om..ey cc: L. Lippe R. Matakas enclosure O
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Empl:syee's Legal Prcject
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P.O. Box 633 Amesbury. MA 01913 (617)388-9620 UPDATE OF ELP DRAPT RESPONSE g, NRC SPECIAL INSPECTION NO. 50-443/86-52 '
F COtfrENTS 1
Introduction...................................... 1 Concrete..........................................
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Cold Pulling......................................
4 Service Water System..............................
5 Service Water Line Welds.......................... 7 e
Piping............................................
8 Trainirq......................................... 10 Document control and Design control.............. 13 Conclusion....................................... 16 EXHIBITS i
A.....ELP Draft Response to NRC Special Inspection No. 50-443/86-52 B.....NRC Report No. 50-443/84-12 (applicable sections) i C.....PSMi correspondence With NRC, 6/11/84; 2/25/85; 3/29/85 D.....INPO Evaluation of Seabrook Station,12/84 (applicable sections)
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- E..... Direct Testimony of Gregory C. Minor and Lynn K. Price on Behalf of State of Vermont Department of Public Service (applicable sections)
G..... Direct Testimony of Minor and Price, Vol. II, Attachments, Section MHB-9, Pullman-Higgins Problems H.....Seabrook Station Worker's Critique of NRC Report No. 50-443/84-12 I.....New Safety Problem: Welds in Service Water Pipe J.....NRC Safety Evaluation Report 6/86 (applicable sections)
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1 Empl:yee's. Legal Project P.O. Box 633 Amesburf, MA 01913 (617) 388-9620 l
April 2, 1987 UPDATE OF ELP DRAFT RESPONSE E NRC SPECIAL INSPECTION NO. 50-443/86-52 INTRODUCTION I
@is is an Update of the ELP Draft Response to NRC (Nuclear Regulatory Comission) report No. 50-443/86-52 on 61 allegations of safety problems in Seabrook Station's design, construction, and documentation made through the ELP by former Seabrook Station enployees. Although the NRC said the inspection found no safety problems, this Update, and the ELP Draft Response (Exhibit A), calls the NRC conclusions into question.
2 W e ELP Draft Response, released February 8,'1987, relied primarily on information found in NRC report No. 50-443/86-52, and on critiques by former workers who had made the allegations. This Update relies on additional information received by the ELP since the Draft Response was prepared. This Update also includes some new allegations which substantiate previous statements regarding problems with piping and welding (Exhibit I).
It is apparently NRC policy to put the burden of proving allegations on the allegers, people who do not have access to the documents and equipment necessary to prove their statements. The NRC does not prove the allegations false,'rather, allegations are found to be " unsubstantiated," meaning the ' ',
NRC hasn't proved them to be true. Also, in some cases, for instance NRC report No. 50-443/84-12 (Exhibit B), thr.. J describes problems as
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' unresolved,' but it is not clear what actions will be taken to resolve
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Perhaps the NRC did not have access to documents cited in this Update, and thus arrived at the conclusion that the allegations raised were not safety problems. In any case, the NRC has neither the resources nor the staff needed to undertake a full-scale investigation of these issues.
Issues raised here point to plant-wide problems which call into question
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the safety of the entire plant. Only a conprehensive,. independent, investigation of the entire plant's design, construction, and all documents related to those areas, can resolve serious questions about the plant's I
safety. Such an investigation should be ordered by the NRC intnediately, before the plant is activated, and before systems requiring investigation become radioactive.
CONCRETE
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There are major unresolved cracks in Seabrook Station's Unit I containmenti, waste process building and equipment vault.'The walls shrank or settled,
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causing. cracking. Thus, because they are weak spots, any stresses on the I
walls are directed toward the cracks. The repairs made so far don't address causes of the cracking, and they merely plug the leak frcun'the inside.
NRC Report No. 50-443/86-52, to which this analysis responds, in the section on allegations 4 and 17, concludes there are cracks, but that the cracks are expected and permissible if they do not affect the structural integrity of the ccincrete. However,'a 1984 NRC report (Exhibit '
B)showsgroundwaterinfiltrationintothesecrackscanaffectpeconcrete 2
s and the reinforcement bar.
atching on the inside of the walls does not stop' groundwater fran affecting the rebar. In NRC Report No. 50-443/84-12 (Exhibit B) section 3.3b, the NRC said in the review "...of waste process building exterior f
concrete wall crack repairs and observation of their present condition... waterproofing menbrane was found not to acconplish its intended purpose."
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4 In that same report and section, the NRC identified possible future changes in groundwater chemistry which could cause rusting of steel bars and affect the concrete as well as the steel, and stated, "his is an j
unresolved item nunber 50-443/84-12-01." h e report also states the steel 3
reinforcement bars would possibly be subjected to continual groundwater contamination, resulting in oxidation and swelling of the rebar.
NRC report No. 50-443/84-12 (Exhibit B) section 3.4 said, "W e control
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methods of repair called for chipping out of concrete to enlarge the crack I
to the required width and depth as specified for application of the special capillary waterproofing (CP) mortar, identified as Vandex C.P. conpound."
According to a Vandex dealer, Vandex C.P. conpound is a cementitious material. It is designed for static crack repair in concrete; it does not eliminate the original cause of cracking, nor does it prevent further,
cracking. It cannot resolve the potential for more leaks at the reapired site, nor can it be determined how deep the crystalline growth of the n= mund penetrates. It is quest.ionable whether the compound penetrates through the entire crack. It probably goes only deep enough to act as a superficial patch. (See also Exhibit H, pages 1 and 2.)
. A more effective trade practice for patching cracks of this type is an A
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3 epoxy injection application. This method is more expensive than the use of Vandex, but is not being used for these repairs ac. cording to workers still on site.
COLD PULLING (See also ELP Draft Response, pages 3-6, Exhibit A)
Cold pulling, also known as cold springing is a prohibited practice, and is defined in NRC Report 50-443/86-52, page 74: "No mechanical means could be used to move pipe more than one-eighth of an inch off its centerline position." In Report 50-443/86-52, th'e NRC tried to establish there was only a single instance of cold pulling. On page 92, the NRC states workers were aware of the requirement and the need to iglement it. However, several studies cited below, as well as information in Report 50-443/86-52 itself, provide information suggesting cold pulling was not unccanon.
Public Service Cogany of New Hagshire (PSNH) correspondence June 11, 1984 to the NRC (Exhibit C) states installation procedures were revised and crafts supervisors and QA/QC personnel were retrained in cold pulling i
requirements. The letter also refers to an investigation of a possible
' generic problem with the use of tooling clags (a means of mechanically s
I forcing pipe into place), but notes the company does'not'believe the cold' pulling problem meets reportability criteria under 10CFR50.55 e, and apparently the NRC agreed. A 10CFR50.55e problem denotes one serious enough to affect the safety of the plant.
But two further pieces of correspondence from PSNH, dated 2/25/85 and 3/29/85 (Exhibit C) state that their final report only covered lines which sere co @ letely welded and that they were still determining which piping may have been omitted from their report.
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l An INPO (Institute of Nuclear Power Operations) Evaluation of Seabrook Station Construction Project, December 1984, (Exhibit D,'pages 14 to,16) fourid problems in the control of construction processes. NH Yankee's responded to that criticism by stating that for ASME III piping (safety-related piping)
"the engineering specification addressing requirements for cold pulling of i
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pipe has been revised to allow more precise interpretation and inplementation. "
cold pulling must have been a greater problem than the NRC acknowleges in Report 50-443/86-52 since engineering specifications were rewritten, installation procedures were revised, and quality assurance, quality control (QA/QC) personnel and supervisors were retrained. See also ELP analysis (Exhibit A, pages 3 to 6). All of these changes occurred after the time the NRC said the cold pulling issue was satisfactorily resolved, according to Report No. 50-443/86-52, pages 74 and 75.
SERVICE WATER SYSTEM (A safety-related system) 2 e ELP has stated the concrete coating of the service water lines broke off during testing, and that only the elbows in the lines were replaced.
2 e NRC report No. 50-443/86-52 did not deny these statements, but said the lines had been inspected for cold pulling, no evidence was found of that
, practice, and said this was not a safety problem. Howeverl there is S ~ '
evidence there was cold pulling in those lines which caused the cracking, and that cold pulling has resulted in safety problems.
l NRC Inspection report No. 50-443/84-12 (Exhibit B) addresses an allegation of cold pulling in the service water system line in the pipe slot area ~~
between the Waste Process Building and the Diesel Generator Building. @ e NRC found, "It is probable that some " popping" noise could be heard when the' i
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pipe {isstressed."TheNRCreportconcludedthatcrackingoftheservice.
water pipe cement lining, although unlikely, could occur'if excess force was applied to the pipe.
-In NRC Report No. 50-443/86-52, an allegation stated that when the service water system lines were tested, some of the inside cement coating broke off. The NRC dismissed this allegation citing report No. 50-443/84-12.(Exhibit B), saying "Ebr cement-lined service water (SW) pipe, the staff reviewed records and drawings, interviewed engineering and supervisory personnel and observed concrete lining inside pipe. The staff entered the 42-inch pipe '
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and visually inspected approximately 40 linear feet...the staff visually inspected accessible interior and exterior portions of the SW pipe in several areas..."
However, the allegation reported on in NRC Inspection No. 50-443/84-12 referred to the area between the Waste Process Building and the Primary Auxiliary Building, not between the Waste Process Building and the Deisel Generator Building. The NRC conducted their inspection in the wrong location (Exhibit H, pages 2 to 3).
In the pipe slot, cold springing was used to fit up pipes ranging from 24-inch to 42-inch diameters with lengths no longer than 14 feet. The NRC
, cites a manual on cement lined pipe saying there was no problem with m-deflecting a 72-inch by five-sixteenth inch pipe with no inpairment of the one-quarter inch lining, but neglected to state the length of the pipe deflected, and over what distance the deflection was absorbed. It should be noted that the service water lining is thicker and less tolerant of deflection.
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Inspection report No. 50-443/86-52 uses the findings from report No. '0 F
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443/84-12 to dismiss the allegation that the cement linin'g of the service water" pipes was breaking off. But Inspection Report No. 50-443/84-12 was conducted before the hydrostatic start-up testing, in the wrong location, and only looked at 40 linear feet of pipe. Inspection report No.50-443/84-12, Section 4, says, "In addition it is possible that cracks could occur due to mishandling during transportation."
Based on this assessment of the NRC inspection reports, it seems quite likely that future problems could occur in the service water system.
Indeed, one informant recently said there is grit in the valves in the service water system.
% e service water system is a safety-related. system. Cold pulling was a problem in this system, and seems to have caused detrimental (and possibly dangerous) effects. Therefore, it is quite possible this is a safety-problem requiring extensive evaluation and repair.
s For a more conprehensive analysis of NRC Report No. 50-443/84-12 Section 4 by the individual who made the original allegations, see Exhibit H.
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i SERVICE WATER LINE WELDS A recent problem presented to the ELP describes poor welds in the service water lines due to porosity and mismatch. The problem, described in more detail in Exhibit I, also mentions the use of pipe alignment clamps, possibly inappropriately. It also substantiates previous allegaticns of poor welder training, inexperienced welders, and poor weld inspections.
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t is. individual can specifically identify 3 bad welds in the service water system which should not have passed inspection, but which did. Possibly many other welds in this area are suspect as well.
PIPING W e ELP response to NRC Report 50-443/86-12 (Exhibit A) states that the NRC report calls into question the entire piping system of the seabrook plant.
Further information cited below substantiates this statement.
In 1984 a seabrook worker told the NRC that the welds in the pipe tunnel suffered fran excessive suck back, lack of fusion, center line shrinkage, e
and unconsumed ring. Se crew cut out six of the 100 welds and found each of
.them had up to 75 percent of their root below accepted standards. During work on this system, the pipe was classified.as a safety related system.
After the problems were discovered, the system was downgraded. NRC report No. 50-443/84-12 (Exhibit B) which resulted from these allegations, stated the system was not safety related, and that some accessible welds were examined, me author of the allegations has prepared a more extensive
- rebuttal of the NRC's findings which is found in Exhibit H, pages 3 and 4.
He believes all of the welds in the pipe tunnel are questionable, as are the Diametric welds fabricated in Turbine I building since the same process was used there.
Another problem raised by the same worker and dealt with by the NRC in the same report were prefabricated sections of welded pipe manufactured by
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Dravo. Many times the joints did not meet ASME codes (Exhibit H, page.6).
He observed the same problem of inproper Dravo welds in the radioactive tunnel. When he tried to call them to the attention of the Pullman Higgins' 8
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quality assurance inspector, he was told that Dravo shop welds were not Pullm'an-Higgins' concern.(ExhibitH,p.6).Hebelievesthhisissuewasnot reso1v'ed in NRC report 50-443/82-12 (Exhibit B). 21s shows a problem in vendor surveillance and quality assurance / quality control of manufactt red
. equipment.
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Another problem this worker believes was unresolved was separation of the nozzles from the steam generators. It was discovered that one of the i
nozzles (the only one inspected and repaired as far as he knows) was contaminated by large amounts of slag. We other three were never repaired
- as far as he knows (Exhibit I, p.5).
i In a Safety Evaluation Report dated May 28, 1986, the NRC granted the utility a waiver on indpecting these welds (Exhibit J, page 4). However, the type of testing the utility had already done, which the NRC found acceptable, would probably not have discovered the serious problem of f
separation of the steam generator nozzles from the steam generator (Exhibit I, p. 5).
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More general proof of piping problems is found in other d~'"aants.
An 11/82 INPO report said, "We piping contractor's activities were the most significant area of weakness identified during the evaluation. %e areas of weakness identified by this evaluation reinforce the need for the project to continue to monitor closely work performed by this contractor, and to consider other remedial actions that would prove effective in inproving work quality and schedule performance. Areas of weakness relate to contro of damwnants, including design changes, work planning and supervision, craft training and quality control" (Exhibit G, p. 5).-
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It seems these problems were not sufficiently resolved subsequent to the INEO report. For exanple,4/23 to 5/4 and 5/14 to 5/25,1984 Construction Appraisal Team Executive Stimary (Exhibit G, p.15) says, " Weaknesses involving piping support installations have been previously identified by NRC region I. Many of these weaknesses have existed for some time. The NRC CAT inspectors noted similar programatic weaknesses with regard to installation activities in the mechaniccal construction area...."
'Ihe 9/24/84 Yankee Atomic Electric Conpany Audit Report says, "The same deficiencies closed in P-H internal audits are recurring and being addressed in YAEC audits" (Exhibit G, p. 16).
'IRAINING NRC Report 50-443/86-52 found no significant training problems, and says that United Engineers (UE&C) and Yankee Atomic found no s'ignificant deficiencies. Furthermore, the report says training adequacy is proven by the high construction quality at the plant. However, NRC report 50-443/86-52 failed to examine documents cited below which contradict those conclusions. In particular, the 1984 INPO report (Exhibit D, pages 2,5,20,23,24) shows there were training problems as late as 1984, when 1
construction was 904 couplete. Since there were apparently noticable problems in training at this late date, what assurances are there that the plant was built by properly trained personnel?
Yankee Atomic Electric Conpany (YAEC) audit No. SA565CS184 (12/81) reconsnended "a 'more conprehensive indoctrination tra'ining and assessment program be established and that more corporate support to the field be 1
provided." Quality assurance training on site is referred to as l
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s indoctrination (Exhibit G, p. 2).
YAEC audit No. SA784CS319 (12/83) says, "It is evident that there is a need for changes in Pullman-Higgins' training program to enconpass the construction and engineering personnel...(there is) a need for Pullman-Higgins management to display a proper sense of urgency relative to identified program deficiencies." (Exhibit G, p.13).
YNSD Monthly Report Notes No.58 (Exhibit G, p.ll) concerning a stop work order on all safety-related work by Pullman-Higgins cites the need to assure "that the necessary training for those personnel responsible to assure design control is being maintained as conducted." This document inplies Pullman-Higgins did not conduct a consistent training program.
t INPO Project Evaluation 11/82 (Exhibit G, p.5) says, " Areas of weakness relate to control of documents,' including design changes, work planning and 1
i supervision, craft training, and quality control."
INPO Evaluation of Seabrook Station Construction Project, 12/84, (Exhibit D)' repeatedly cites needed inprovements in training:
Page 2: "Inprovements were reconnended in a nunber of areas. The following are considered to be among the most inportant.. increased enphasis on training craftsmen and inspectors in site requirements. Include provisions to retrain personnel.as requirements change."
I NH Yankee's response to INPO's finding of inadequate craft supervision was, "In January 1985 all I&C (Instrumentation and Control) craft pipefitters, I
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supervisors, engineers, and QC inspectors received intensive training on the Field Instrumentation Proceedures, Appendix B of 10 CFR 50, weld symool i
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nomenclature, and general Nuclear Quality Assurance Manual (QA) requirements" (Exhibit D, p.5).
te same report (pages 14 and 15) shows foremen had to be retrained and then trained again in field electrical procedures because of recurring reworks due to damaged cable. However, NRC report 50-443/86-52, in dismissing allegations of damage to cables during construction said,
...there is no evidence to indicate that these instances involved safety related cables."
1 te 12/84 INIO report (Exhibit D, p.15) also cites problems with hangers, pipe installation, and welding processes. NH Yankee responded by saying "W e site is presently reviewing training needs for supervisory personnel as well as craft personnel to clearly establish resposibility for quality and j
training programs," for ASME III (nuclear related) piping. W e same report pages 20 and 21, says, "Inprovement is needed in the training of l
craftsmen and quality control (QC) inspectors. Some craftsmen and QC inspectors are not effectively trained in installation procedures and acceptance' criteria." And on pages 23 and 24, the INIO report cites concerns about inadequate quality control inspection work and recommends
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the utility "... provide ~ training to both QC inspectors and craftsmen to
' ensure their understanding of..~. program requirements." Again, on pages 34 and 35, the INPO report cites plant operators' lack of knowlege of plant systems and equipment and recommends improved training.
NRC report No. 50-443/86-52 said the NRC and other sources showed no significant problems in training, and stated the quality of construction proves the point. However, M mants cited below show only a few of available exangles of serious problems in construction quality.
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Testimony tf MHB, nuclear consultants cites repeated problems with Pullman-Higgins installation of the piping system (Exhibit E, p. 71 and'72).
A letter from the PSNH Site Manager to UE&C Resident Construction Manager, 6/20/80, (Exhibit G, p. 1) says: " W e quality of pipe welding which we have been getting at Seabrook Station is cause for serious concern. @ e rejection rate for radiographed safety class welds performed by Pullman-Higgins was 38% as of 6/10/80. The rejection rate for weld
, repairs was 50% for the same period. From the period 5/1/80 to 6/10/80 the rejection rate for both new weld and repairs was 60%.... The above exanples show an unacceptable situation wherein the quality of welding is poor and seems to be worsening."
An 8/8/83 Systematic Assessment of Licensee Performance: Summary of Results (Exhibit G, p. 11 & 12) says, "W e Piping Systems and Supports functional area has been a continued area of concern..." and refers to an 11/81 INPO. sponsored Self-Initiated Construction Evaluation which cites
...the piping contractor's activities as the most significant area of weakness."
Document Control and Design Control NRC Report 50-443/86-52 said only one violation of document control was found and corrected, and that " isolated cases of outdated drawings were found during these inspections, and in eadh case, the situation was corrected" (pages 64 and 65 NRC Report No. 50-443/86-52). In the incident cited in this allegation, the NRC said the drawing used by the workman 13
"could have been correct for the portion of the drawing being used."
Issues which are raised here include late and inconplete revision of documents; craftsmen working with outdated documents; construction flaws due to poor document control; ineffectiveness of corrective measures; and the wide scope of the document control problems. In the related area of design control, the following issues arise: inadequate review of design changes; procedural changes which allow existing (previously unacceptable) situations to stand; and construction flaws due to design control problems.
MHB, a nuclear consulting firm, cites the inability of UE&C to control the design change process (this process encompasses document control) as one of two significant problems at the plant (Exhibit E, p. 54). On page 71 of the same report, MHB states that one of the major problems P-H had was
" keeping the necessary drawings and records up to date. This problem was compounded by an inefficient document control cycle."
Four ECA (Engineering Change Authorization) Task Forces failed to improve performange in document and design control, and the 1984 INPO report
'(Exhibit D, p.2) recommends that.one of the most inportant inprovements to be made is "to inprove the quality of preparation and review and the timely issuance of Engineering Change Authorizations."
ECAs are the mechanism by which problems requiring changes to the design of the plant, or to construction procedures used in the plant, are resolved.
A 1982 Construction Appraisal Team Report (Exhibit E, p.74) identified concerns with P-H's design control problems, saying, " Audit reports of the 14
piping subcontractor revealed several specific problems, which when viewed collectively, indicated a programatic weakness. @ese were identified by the licensee's audit program circa mid-1981. Although efforts to resolve.
these problems have been initiated, they have been ineffective. Response by P-H to these audits provided acceptable corrective action for the individual deficiencies, but did not acknowlege or respond to the rdcomendations for correction of programmatic or repetitive problems.
A 10/82 UE&C memo (Exhibit E, p. 77) cites "...several exanples of P-H
, construction aid drawings which did not agree with the UE&C drawings. Piece marks were different, revisions were different, and dimensions were incorrect, just to name a few. Steve Madaras, a design supervisor in the field, showed us P-H construction aid drawings where dimensions were incorrect up to 13 inches off. Steve indicated that P-H was making changes and not informing UE&C, thereby causing the possiblity of more interferences. We were also told that there is not a check of P-H drawings to see if they agree with our UE&C drawings. Steve also indicated that UE&C changed their NQA manual to indicate that checking P-H drawings against UE&C drawings was not required."
' A Pullman-Higgins letter to UE&C 11/18/82 (Exhibit G, p. 6) says "...we cannot guarantee that piping and pipe support erection is being performed t
in accordance with the latest design documents."
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tis information refutes the NRC statement in 50-443/86-52 that there is
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only one case of problems with document control, and that design control was only a problem in isolated instances. The above cites are only a few exanples to be found in documents available to the ELP, but they show a l
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serious document and design control problem.
Exanples of construction flaws which occurred because of document control problems include:
Cygna, a consulting firm, said "...over 50% of hangers in process have required. redesign (Exhibit G, p. 7).
An 11/10/82 letter fran UE&C to P-H (Exhibit G, p.6) says, "... erection in process and final inspection are performed to the P-H drawings and not iin accordance with the UE&C design drawings." A Quality Assurance Audit Report NH-590 to which that letter refers says,"...out of a sample of 66 hanger drawings selected fran work in progress,16 were' observed to have a later revision or ECAs issued against them."
A further exangle of problems caused by poor document and design control can be found on pages 7 and 8 of the ELP draft response to NRC report 50-443/86-52 (Exhibit A).
CONCLUSION
'Itie information in this Update of the ELP Response to NRC Report No. 50-443/86-52 was found in only a few, and sometimes inconplete, documents, documents which the NRC apparently neglected to refer to in preparing report No. 50-443/86-52. Either those documents were unavailable to the NRC, or the investigators did not feel they were applicable. In Sy~
case,. information cited in this Update shows many of the allegations dismissed by the NRC in their report are substantiated. It also shows NRC J
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o report No. 50-443/84-12 did not adequately address safety problems raised by a worker in 1984. How many other NRC reports did not have adequate and appropriate materials to work with,' and therefore reached incorrect conclusions?
Only a conprehensive independent investigation would be adequate to resolve the safety questions raised by the overwhelming evidence available both in utility and NRC documents, and in the construction of the plant itself. As further information becomes available to the ELP, the Project will continue to expand on this Response.
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