ML20206C463
| ML20206C463 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/02/1987 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Tracy S EMPLOYEE'S LEGAL PROJECT |
| References | |
| NUDOCS 8704130064 | |
| Download: ML20206C463 (35) | |
See also: IR 05000443/1986052
Text
.
_ ,
_ _ _ _ _ _ _ _ _ - _ _ - _ _ - - _ _ _ _ _ _ _ _ _ __ _ ___ _
__
,
' .s w. '
'g Lf
. sp w ..,;.
'
'
"
APR0a n
.
- Docket' Nos.' . 50-443; 50-444' 'i
Employee's Legal Project -
. ATTN: Ms..Sharon Tracy.
.
.P.O. Box 633-
Amesbury, Massachusetts 01913
. Dear Ms. Tracy: *
s I ;p' l ,
On March 19, 1987, Mr. .J. Durr of this office contacted yodby telephone regarding ,
the." Employee's Legal Project Draft Respons,e to NRC Special Inspection No. 50-443/
86-52,"-(ELP Draft Response) which had been mailed by your organization to our
resident inspector at Seabrook. Specifically, the purpose of that telephone con- -
versation was to determine whether the ELP, Draft Response was a complete set of
allegations or a " draft" for which we would expect to. receive additional allega-
tions. We understand that the ELP Draft Response should be considered a final-
response to the special inspection (50-443/86-52) conducted by this office in
November 1986. Therefore, your response, as an enclosure to this letter, is being
.placed in the Public Document Room and is being provided to the normal distribution
list for Seabrook Station. We also understand that you intend to provide us-with '
further clarifications of some of the original set of allegations;and that you in-
tend to provide us with those clarifications during the first week of April 1987.
7
During the telephone conversation ~with Mr. Durr, he indicated our. intent to conduct
an additional inspection at Seabrook Station to further evaluate those areas where
your response appears to provide either additional or clarified information rela-
stive to that which you provided with -the original allegations and subsequent in-
.terviews. Since you stated-that, while there are no new allegations, further
amplification of the original issues is forthcoming. We again request that this
additional data.be provided to us-as soon as possible, so that we may include it
in our inspection plan. ,
{
Mr. -Durr also indicated that after the conclusion of the follow-up inspection at
Seabrook Station, relative to your further clarification of the existing concerns, ;
we intend to propose a meeting.with you to address those concerns and any further
questions you may have relative to our inspection program of Seabrook Station con-
. struction'. We will coordinate this future meeting with you shortly after comple-
tion of our follow-up inspection.
If you believe our understanding of any of the above information is incorrect or
if you feel you cannot provide additional details and amplification of the speci-
fics of the existing allegations, as was stated by the first week in April, please
contact us as soon as possible.
Sincerely,
William F. Kane, Director
Division of Reactor Projects
8704130064 870402 A
PDR ADOCK 05000443- ; <
f_ 0]
G PDR
V/
Il
.. . .-
_- _
_
s *e
e; 4
. Employee's Legal Project 2
q 3
Enclosure: As Stated
'
cc w/ enc 1:
Seabrook Hearing Service List ~
R. J. Harrison, President and Chief Executive Officer
Ted. C. Feigenbaum, Vice President of Engineering and Quality Programs
William B. Derrickson, Se_nior Vice President
Warren J. Hall, Regulatory Services Manager
Donald E. Moody, Station Manager
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
.NRC Resident Inspector
State of New Hampshire
.
bcc w/ encl:
Region I Docket Room (with concurrences)
Managemc6t Assistant, DRMA (w/o enc 1)
DRP Section Chief
Robert J. B' ores, DRSS
A. Cerne, SRI
T. Elsasser, 3RP
J. Durr, DRS
E. Wenzinger, DRP -
iW. Kane, DRP
A. Shropshire, 0AC
v
..
gCerne/meo
%"
Elpasser
"l%
Durr h"G
pzinger
- /gf
) 3/30/87 QM37 $g/ T7
OFFICIAL RECORD COPY
_
'
Seabrook'1 Service Hearing List
Thomas Dignan, Esq E. Tupper Kinger, Esq.
John A. Ritscher, Esq. Assistant Attorney General
Ropes and Gray Office of Attorney General
225 Franklin Street 208 State House Annex
Boston, Massachusetts 02110 Concord, New Hampshire 03301
Mr. Bruce Beckley, Project Manager Resident Inspector
New Hampshire Yankee Seabrook Nuclear Power Station
P.O. Box 330 c/o U.S. Nuclear Regulatory Comm.
Manchester, New Hampshire 03105 P. O. Box 1149
Seabrook, New Hampshire 03874
Dr. Murray Tye, President Mr. John C. DeVincentis, Director
Sunn Valley Association Engineering and Licensing
209 Summer Street Yankee Atomic Electric Company
Haverhill, Massachusetts 08139 1671 Worcester Road
Framingham, Massachusetts 01701
Robert A. Backus, Esq. George D. Bisbee, Esq.
O'Neill, Backus, and Spielman Assistant Attorney General
116 Lowell Street Office of the Attorney General
Manchester, New Hampshire 03105 25 Capitol Street
Concord, New Hampshire 03301
Mr. Phillip Ahrens, Esq. William S. Jordan, III
Assistant Attorney General Diane Curran
Office of the Attorney General Harmon, Weiss, and Jordan
State House Station # 6 20001 S. Street, N.W.
Augusta, Maine 04333 Suite 430
Washington, D.C. 20009
Jo Ann Shotwell, Esq. D. Pierre G. Cameron, Jr. , Esq
Office of the Assistant Attorney General Counsel
General Public Service Company of
Environmental Protection Division New Hampshire
One Asburton Place P. O. Box 330
Boston, Massachusetts 02108 Manchester, New Hampshire 03105
Ms. Diana P. Randall Regional Administrator, Region I
70 Collins Street U.S. Nuclear Regulatory Commission
Seabrook, New Hampshire 03874 631 Park Avenue
King of Prussia, Pennsylvania 19406
Richard Hampe, Esq. Mr. Alfred V. Sargent
New Hampshire Civil Defense Agency Chairman
107 Pleasant Street Board of Selectmen
Concord, New Hampshire 03874 Town of Salisbury, MA 01950
Mr. Calvin A. Canney, City Manager Senator Gordon J. Humphrey
City Hall ATTN: Tom Burack
126 Daniel Street U.S. Senate
Portsmouth, New Hampshire 03810 Washington, D.C. 20510
_ - _
, .
Ms. Letty Hett Mr. Owen B. Durgin, Chairman
Town of Br:ntw:od Durhaa B2ard of Selectmen
RFD Dalton Road Town of Durham
Exeter, New Hampshire 03833 Durham, New Hampshire 03824
Ms. Roberta C. Pevear Charles Cross, Esq.
Town of Hampton Falls Shaines, Mardrigan, and McEaschern
Drinkwater Road 25 Maplewood Avenue
Hampton Falls, New Hampshire 03844 P. O. Box 366
Portsmouth, New Hampshire 03801
Ms. Anne Verga Mr. Guy Chichester, Chairman
Chairman, Board of Selectmen Rye Nuclear Intervention Committee
Town Hall c/o Rye Town Hall
South Hampton, New Hampshire 03827 10 Central Road
Rye, New Hampshire 03870
~
Mr. Angie Machiros, Chairman Jane Spector
Board of Selectmen Federal Energy Regulatory Comm.
for the Town of Newbury 825 North Capitol Street, N.E.
25 High Road Room 8105
Newbury, Massachusetts 01950 Washington, D.C. 20426
Ms. Rosemary Cashman, Chairman Mr. R. Sweeney
Board of Selectmen New Hampshire Yankee Division
Town of Amesbury Public Service Company of
Town Hall New Hampshire
Amesbury, Massachusetts 01913 7910 Woodmont Avenue
Bethesda, Maryland 20814
, Honorable Peter J. Matthews Mr. Donald E. Chick, Town Manager
Mayor, City of Newburyport Town of Exeter
Office of the Mayor 10 Front Street
City Hall Exeter, New Hampshire 03823
Newburyport, Massachusetts 01950
i
Mr. Warren J. Hall Mr. William B. Derrickson
Public Service Company of Senior Vice President
New Hampshire Public Service Company of
P. O. Box 300 New Hampshire
Seabrook, New Hampshire 03874 P.O. Box 700, Route 1
Seabrook, New Hampshire 03874
Administrative Judge Administrative Judge
Alan S. Rosenthal, Chairman Bary J. Edles
Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal
Board Board
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
-Washington, D.C. 20555 Washington, D.C. 20555
Administrative Judge Administrative Judge
Howard A. Wilber Helen F. Hoyt, Chairman
Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal
Board Board
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
Washington, D.C. 20555 Washington, D.C. 20555
- _ _ _ _ _ _ _ _ ______ _ _____
, .
Administrativa Judg] Administrativ2 Judge
Emmeth A. Lusbka Jerry Harb:ur
Atomic Safety and Licensing Board Atomic Safety and Licensing Board
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
Washington, D.C. 20555 Washington, D.C. 20555
Edwin J. Reis, Esq. H. Joseph Flynn, Esq.
Office of the Executive Legal Assistant General Counsel
Director Federal Emergency Management Agency
U.S. Nuclear Regulatory Commission 500 C. Street, S.W.
Washington, D.C. 20555 Washington, D.C. 20472
Edward A. Thomas Carol S. Sneider, Esq. I
Federal Emergency Management Agency Assistant Attorney General
442 J. W. McCormack (P0CH) Office of the Attorney General
Boston, Massachusetts 02109 One Ashburton Place, 19th Floor
Boston, Massachusetts 02108
Paul McEachern, Esq. Richard A. Haaps, Esq
Shaines and McEachern Haaps and McNicholas
25 Maplewook Avenue 35 Pleasant Street
Portsmouth, New Hampshire 03801 Concord, New Hampshire 03301
J. P. Nadeau Allen Lampert
Board of Selectmen Civil Defense Director
10 Central Street Town of Brentwood
Rye, New Hampshire 03870 20 Franklin Street
Exeter, New Hampshire 03833
William Armstrong Sandra Gavutis, Chairman
Civil Defense Director Board of Selectmen
Town of Exeter RFD #1, Box 1154
10 Front Street Kensington, New Hampshire 03827
Exeter, New Hampshire 03833
Anne Goodman, Chairman William S. Lord
Board of Selectmen Board of Selectmen
13-15 Newmarket Road Town Hall - Friend Street
Durham, New Hampshire 03824 Amesbury, Massachusetts 01913
Michael Santosuosso, Chairman Jerard A. Croteau, Constable
Board of Selectmen 82 Beach Road
South Hampton, New Hampshire 03827 P. O. Box 5501
Salisbury, Massachusetts 01950
Stanley W. Knowles, Chairman Judith H. Mitzner
Board of Selectmen Silverglate, Bernter, Baker, Fine,
P. O. Box 710 Good, and Mitzner
l
'
North Hampton, New Hampshire 03862 88 Broad Street
Boston, Massachusetts 02110
Norman C. Katner Bary W. Holmes, Esq.
Superintendent of Schools Holmes and Ells
School Administrative Unit No. 21 47 Winnacunnet Road
Aluani Drive Hampton, New Hampshire 03842
Hampton, New Hampshire 03842
Jane Doughty
Seacoast Anti-Pollution League
5 Market Street
Portsmouth, New Hampshire 03801
_ _ _ _ _ _ _ _ _ _ _
. . .
.
9
e ; .
Employec's legal Project
P.O. Box 633
Amesbury MA 01913
(G17) 3884Mi20 -
Employee's Legal Project Draft Response to NRC Special Inspection
No. 50-443/86-52
INTRODUCTION
This is an analysis by former Seabrook nuclear plant employees of
the Nuclear Regulatory Commission's (NRC) Special Inspection
Report No. 50-443/86-52. The NRC Report ostensibly dismisses .
former employees' concerns about safety violations in the
Seabrook nuclear plant's design, construction, and documentation.
The NRC terms these concerns "not substantiated." The
Employee's Legal Project (ELP) and these former employees
believe the NRC report raises more questions about the Seabrook
nuclear plant's overall safety than their original allegations
did.
Most of the information used in this analysis comes directly from
information provided by the NRC in their special report; the page
numbers and allegation numbers refer to the NRC's report. In
several cases, some meaningful historical information is included
to give a context for questions allegers have raised concerning
the NRC report.
,
It may be helpful to provide here a brief outline of how the NRC
,
Special Report and this analysis of it came to be. In September,
1986, the ELP made public a number of safety concerns raised by
1
_ ._ . _. . . . . _ . __ _ . .
.
. -
.
-
- ;-. '
~
.
former Seabrook. nuclear plant employees who askeyl their
.
identities remain confidential. Those allegations.were sent to
Massachusetts Governor.Dukakis, were made public at a press
conference, and were simultaneously sent to the NRC's Region 1
in
head, Richard Starostecki with whom the ELP had already been
contact. Starostecki had been reassigned, and William Kane-took
his~ place. Apparently during that transition, the ELP's
'- information was misplaced. The NRC received it a week later from
a media source. The NRC restated, numbered, and categorized the
allegations.
In October, two former Seabrook employees, Douglas Richardson,
,
who had been an as-built piping inspector for Pullman-Higgins,
k and Raymond Lavoie, a former electrician, made their concerns
l' about safety problems at the Seabrook plant public at a press
I conference..In early November, the NRC sent up a team of 6
! inspectors to investigate the allegations. Engineer Jacque Durr
1
!
-interviewed ELP coordinator Sharon Tracy on November 4 in the
presence of the ELP attorney to " clarify" allegations from
,
anonymous former Seabrook workers. Later that evening he
'
interviewed Raymond Lavoie, whose own attorney was present. The
next day, he interviewed Douglas Richardson.
!
Within two weeks, the NRC investigators had completed their work;
i the Special Report was released on December 24, 1986.
1
i
l
l
l 2
i
, . . - - - - . - - - , - . , - . . - , , , , . . . , - . - - , - - , , - , , , , - , , , , , , , , , - - - - . - _ - . - , - , , . . - , - , , , - , _ , , - _ , , , , , - _ -
_- - _ - ____ - _ _ _ _ _ . .. .
.. .
. .
.
. .
.
e ; s
.
The first section of this response to the NRC report analyzes
.information cited by the'NRC throughout their report regarding
cold pulling, poor design control and construction practices,
training,.and quality assurance. The ELP analysis then examines
and critiques specific NRC allegation responses and asks
questions elicited by the NRC report: Does the-NRC information
show a major breakdown in design control, construction practices,
training, and quality assurance and control by both the major
piping contractor and the licensee and a breakdown in NRC
oversight? Are NRC assurances that procedures exist to
prohibit certain unsafe practices enough to show those practices
did not take place?
This is an analysis of one small NRC rep' ort out of many, many
others written over the years. What questions would be raised by
an analysis of those other reports? It should be noted that'the
NRC says in their report that the agency has put in 20,000 man-
hours of Seabrook plant investigation. On the surface, that may
.seem-substantial, but it works out to one full-time person on the-
job for the life of the construction; not much when the magnitude
of the project is considered.
OVERALL QUESTIONS RAISED BY NRC REPORT 50-443/86-52
Cold Pulling (Cold Springing)
- Pullman-Higgins (P-H) was the piping contractor for the Seabrook
3
__________
.. -. - .. . . . . -
> e
.
. . .
nuclear plant. Various sections of the. report seem to show P-li
< was unaware of regulations prohibiting " cold pulling" (" cold
'
stretching" or " cold springing). This is a practice where pipes
which don't fit up properly are forced into place using a come-
along or ropes and pulleys, thus putting undue stress on the
'
1
- pipes and welds.
1
Allegations #40 and #46 on page 74 show the scope of the problem.
After the licensee discovered P-H was engaged in cold pulling,
"the licensee determined that the contractor.was not fully
cognizant of the details of Specification No. 9763-006-248-51
which required that no mechanical means could be used to move
pipe more than 1/8 inch off its centerline position."
+
Allegations 840 and #46 are about cold pulling incidents. The NRC
says these allegations refer to "a well documented licensee-
identified cold pull incident" in the main steam feed line.
However, neither allegation referred to that particular cold
pulling incident ( Nonconformance Report No.80749). Although the -
- 40 and # 46 seems to indicate there
4
NRC response to allegations
l
f is only one documented case of cold pulling, there is evidence
,
. throughout the report to show that cold pulling was a serious
problem.
,
- For instance, allegation #46 (see also allegation #55, page 91)
refers to cold pulling in the condenser piping (extraction
system), not the main steam feedwater system mentioned by the
l ,
NRC. Allegation 47, page 28, refers to cracking in the cement of
i
4
l,
.--r-w- ,m-.. .-m..r.. - - - , _p# .--.w.e , ,%,,-_,r ..-p,-_ .y-.1 w. --m.v e.,, ,,-m,-,,. , - - _ _ , ,y.e e,
_
, .
.
e , e
the cenent-lined service water pipes. In 1984, the NRC staff
reviewed licencee records (Inspection Report No. 50-443/84-12),
and visually inspected 40 feet of a 42-inch service water pipe to
" determine the conditions and controls applicable to pipe cold
springing." The service water pipe "is classified as safety-
related ;,SME Class 3, Seismic."
Apparently cold pulling was so serious a problem that the licensee
submitted a Construction Deficiency Report (CDR) to the NRC in
1982 evaluating seventy piping systems for the effects
of cold pulling. The CDR also said " procedures were revised to
preclude recurrence," and the NRC report states the corrective
actions were in place by January 1983 (pages 74 and 75).
Although the NRC 1984 report decided "it is unlikely that the
cement lining would have been subjected to sufficient forces to
cause signifigant cracking by cold springing during pipe
installation," the report said "The lining did contain hairline
cracks, although these were of a width much less than the 1/32
inch acceptance criteria." This implies cold pulling was
responsible for pipe lining cracks in the service water system,
a safety-related system.
The contractor was not aware of prohibitions against cold
pulling; the licensee inspected 70 piping systems in relation to
cold pulling; and the allegers were referring to different cold
I
pulling incidents than the one acknowleged by the NRC. There are
l
1
l
5
l
l
l
-
t
-
,
.
. . .
indications the problem.was vastly more widespread than simply
'one incident.
It-is interesting to note that the licensee's service water
system report dealing with cold pulling was date.d 1984, but
procedures were changed in 1983 so cald pulling would not recur
(page 75). Did cold pulling continue to be a problem after the
procedure was rewritten?
Poor Construction Practices
The NRC speaks to allegers' concerns about the poor relationship
-
between P-H, the piping contractor, and United Engineers and
Constructors (UE&C), the construction manager (allegations #33,.
834, #47, #59, and #60, pages 66-68). The NRC says this bad
relationship was due to P-H's poor job performance. "In
the early 1980s, significant concerns with P-H's job performance
were-identified by the NRC...primarily with design control and
the use of construction practices which were in conflict with
-
UE&C specifications" (page 67).
According to the NRC, corrective actions regarding the piping
,
contractor 's poor job per formance resulted in a major
l reorganizational effort, " organizational and procedural changes
i
! which ultimately led to increased licensee and UE&C control of
P-H activities" (page 67). Coupled with the statement P-H did not
!
know cold pulling was a prohibited practice, and the inspectionn
!
f
of the 70 piping systems, this major reorganization indicates the .
,
6
[
L
. _. . _ _
. .. . .__
--.- ,
.
. . .
,
possibility of an extensive piping problem.
l
t
I How extensive was- this problem? It was discovered af ter the
-
piping in the plant was substantially installed. According to the
allegers, there were numerous instances of cold pulling neither
the licensee nor the NRC knew about, since the NRC says there was
i
only one documented report of cold pulling.
1
L
Poor Design Control
The NRC report shows an overall design control problem, and
,
cites such a problem in relation to Pullman-Higgins' work. Further
i examples of design control problems may be found in the NRC
.
response to allegations 851,(page 86) and 854 (page 90).
Allegation #54 says parts of the air conditioning / refrigerant
i system of the Control Building Air Handling (CBA) system were
i
built without design drawings. Although the NRC says this
'
allegation could not be substantiated, and says design drawings
4
have been issued on the system in question, when were those ~
! drawings issued?
4
!'
.
According to the alleger, the CBA system as originally designed
called for two identical air conditioning systems. Because the
original system lacked sufficient capacity, two more supplemental
systems had to be added. The tubing for these supplemental
1
1
systems was field run, or put in without design drawings for
.
guidance. Just the fact those supplemental systems had to be
- ,
added shows there were design problems.
t
7
- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ .-_
- --__ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. ..
.
. . .
Another issue pointing to either design control or construction
practice problems is raised in the NRC response to allegation
- S4, the CBA system: steel piping was installed originally, then
had to be replaced by copper piping. The code as cited says "all
piping associated with the system is rigid copper piping. Steel
piping is not used in any part of the system." Yet steel was used
the first time around. Were design specifications unclear, or was
the design not properly followed?
Another instance where the correct specifications were not made
known can be found in the NRC response to allegation #51, page
86. Although to NRC says, "all piping (in the CBA system) is
seismically supported...," the alleger, an as-built piping
inspector for P-H in 1982, was not told about specifications
requiring those pipes to have seismic supports. Did the
regulations change, or did piping inspectors and perhaps even
piping installers, receive incorrect or insufficient information?
Training
Adequate and appropriate technical training for craftspeople
engaged in nuclear plant construction is essential for making
sure the plant is properly inspected and safely built. The NRC
response to the allegations that training was poor and not well
monitored ("not substantiated") raises questions of how closely
the NRC actually oversaw the Seabrook plant.
8
..
_ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. , .
.
6 ; ,- ..
'
The NRC response cites a number of reports saying the training
was. fine and that the " quality of the training programs was
ultimately ^ reflected in the quality of the equipment
installations. The quality of equipment installation was
extensively examined by the NRC" (page 35).
Yankee Nuclear Services Division conducted 11 audits between May,
_1978 and December 1981; UE&C conducted 10 internal audits on
training between July 1974 and October 1985. "No significant
deficiencies were found...The NRC inspected training and
qualification programs as a routine part of the inspection,
program during the construction phase"(page 35).
Allegation ill, page 37, refers to' communication and
comprehension problems for engineers and other employees whose
first language was not English. "If the communication problem was
severe, it would be reflected in unacceptable work and be
detected by the multiple checks and counterchecks." -
p-H was a contractor with a major role in building the plant:
installing the miles of piping which makes up a nuclear power
plant. Yet it wasn't until 1983 that the licensee took action
because p-H did not know cold pulling was prohibited, and had job
performance problems with " design control and use of construction
practices" (page 67). If a major contractor had major problems
which weren't acted on until seven years after construction
l ,
I began, what does that say of training, quality of equipment
9
_ ._ . , _ - - . ._. - _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ __ ______ _
-e ..
-
.
~
'o ,- .
,
i installation, and the NRC's oversight of either?
,
As far as being able to track people's training records, the NRC
,
states on page 35 that qualifications for contractors performing
1.
'
welding or quality control work were documented and are
available. And again, on page 63, the NRC states that during the
hiring. process the " individual had to demonstrate his
,
j
qualification. Examples of these are welders and nondestructive
examiners." And, " Nondestructive examination personnel were
tested to assure their qualifications met the code..., the
i individual's experience record was verified..."
i
I
1
I How well did the system work? James Padavano, a weld inspector,
i
falsified his qualifications on his resume, then went on to
I
i falsify documentation on 2,399 weld inspections. Some of those
,
' welds were safety related, and some were inaccessible due to
i
concrete pours by the time Padavano was caught (in 1983) and
convicted (in 1985), and could not be checked. His
! -
" qualifications" may have been documented, but they were
1 ' certainly never checked. Only after Padavano's case went
! before a Grand Jury was it was discovered he falsified his
i
i
j resume and references.
!
(
4
Allegations #12 and #27 (pages 38 to 41) refer to improperly
trained welders. The NRC report cites many inspections of l
4
1
training programs and welding procedures. But how good were these
l
!
'
programs and procedures? The NRC performed "in excess of 26
i 10
i
..- ,m_~,-.. _..-,.,_,__,........_,.,,_m--- m ., _ _ _. , - -, - , - _ _ . , , , _ _ - - , _ _ ---,,.m,._ .
_ . _ _ _ - _ _ _ _ _
. ..
.
o g .
inspections" and "over 592 independent examinalions of welds at
Seabrook." Of all the thousands of welds in the plant, only "145
pipe welds were selected by the NRC and examined by
radioagrapnic, ultrasonic, magnetic particle, or liquid penetrant
testing methods." The rest of the 592 were visually examined,
according to the NRC.
The NRC is satisfied with welder training and qualification
programs, and is satisfied that procedures were understood.
Again, responding to allegation #25, page 60, that construction
procedures were written in ambiguous language, up to
interpretation by the reader, the NRC says, "a formal process
existed for clarification of procedures or interpretation of
technical requirements." How well did that formal process
actually work?
On page 1-5,the Executive Summary, the report says workers were
trained and qualified to American National Standards Institute
requirements. However, Doug Richardson, an as-built piping
inspector for P-H was not certified to these requirements and
never heard of " ANSI N45.2.6."
It seems , at least in the case of P-H, welders were not aware
If training is not truely
, cold pulling was a prohibited practice.
adequate, construction work quality suffers.
11
_- _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,....
-
.. .. .
.
i ; e
,
-Quality Assurance / Quality Control
The NRC explains the quality assurance program as a three-tiered
system, the first level being inspections by the contractor, the
second and third being audits and surveillances of the
contractors' inspections by Yankee Atomic Electric Company. The
NRC then audited.those audits. It is up to the contractor doing
the work to police themselves, then the NRC examines the
contractor's inspection reports.
On page 69 allegation #36, the NRC finds no problems with the
quality assurance, quality control program at the Seabrook plant.
-However, the apparent breakdown in other aspects of the NRC's
oversight procedures raises questions about the NRC's assurances
here.
NRC presence at the Seabrook site was not omnipresent. Prior to _
1980, there was no on-site NRC inspector, so the NRC performed
only flying inspections. In 1982, a second NRC inspector was
assigned to Seabroon. Considering the 8,000 to 10,000 people
working onsite at any given time, and that a good part of an NRC
inspector's job is paperwork, it would be extremely difficult for
t_ NRC inspectors to discover the smallest fraction of violations.
The 20,000 man-hours the NRC puts forward as evidence of the
.
quality of.NRC oversight is somewhat misleading in light of the
size of the job site and the number of people who worked there:
12
_ _ _ _ _ _ _ _ -
_ _ _ . - _ _ __ - . - . _ _ . - - - - . - _ - _ _ . _ _ _ _ _ _ _ _._ ._ __
.' ..
.
- :o g .
.
- one inspector for the entire. project over ten years.
.
1
i
An example of quality assurance breakdown is.found on page 74 (70
piping systems were evaluated) where the NRC verified that
supports were " installed on piping systems... assuring that the
effects of cold pull...were minimal." But cold pulling should
never have occurred. It was apparently determined in the summer
.
=of'1982 thatiP-H did not know about the prohibition against cold- ,(
i
pulling. New procedures to reinforce the cold pulling prohibition
.
,
! were produced in 1983. Two years later, the service water system
!
- was tested and found to have cracks in the cement lining,
1
possibly due to cold-pulling. Was cold pulling continuing despite
,
procedures being rewritten to prohibit it? (see page 75).
!
) Pu llmar. Powec Company, P-H's parent company is "N" qualified by
,
>
j- the NRC to perform nuclear plant-related work. How reliable is
j that "N" qualification if P-H didn't even know about an important -
c
prohibition? Does this point not only to a generic problem with
P-H understanding of quality assurance / control, but to questions
on the understanding of the other constractors as well?
i'
Although the NRC's inspections, procedures, and quality
.
l
assurance / quality control programs are cited extensively to prove
! allegers' charges are unsubstantiated, they clearly failed in one
w
- major case (P-H and cold pulling). Shouldn't procedures and rules
l
, be considered suspect in declaring the allegations
i
!
- 13
!
.
. -. -- . . - . . - - . . -. . .- . . .-
,
. . ..
+
.
1 -.j .
1
.
! " unsubstantiated"? Is it possible all piping installations up
i
until 1983 are questionable?
The 'NRC says all quality assurance / quality control requirements
were met, but is this accurate? P-H, piping contractor for major
,
work, had its role severly curtailed when cold pulling and
construction practice problems were discovered. At that point the'
y
plant had been under construction for seven' years,
b '
i
! One issue not addressed in the NRC report, but related to
i
} contractors' quality of work and interrelationships, has to do
1
4
with UE&C. In 1984, Public Service Company of New Hampshire
4
(PSNH), the lead owner.of the Seabrook nuclear power plant, was !
<
in severe financial straits. Construction was shut down, and
!
- there were massive layoffs
- 6,000 people. At that time, there was
,
mention in the media that PSNH was considering suing UE&C. That
1
'
suit never came about, so it is_ unclear why PSNH was looking into.
'
that option. PSNH owed UE&C money. When the project restarted
I
{
(after Merill-Lynch got involved in restructuring the project's -
i
- financing), Pullman-Higgin had been fired, but UE&C was still on
! the job. UE&C had changed the debt PSNH owed into a loan.
i
4
i In a more recent development, a stockholders' suit against both
t
PSNH and UE&C in Federal District Court for mismanagement, among
i
other things, was settled out of court in November of 1986.
].
L PSNH's insurance company agreed to pay $1) million to ratepayers
a
j
to settle the suits against both UEEC and PSNH. Why was PSNH
I 14
i
, _ . . _ . - _ . _ _ . _ _ _ - . _ - . _ . , _ . _ _ . . _ . . - _ _ _ - _ . _ - . , . _ . . _ . _ . . . _ _ . . _ . . . . . ._._ _ _
._. . . . . - _ -- . .- . -. - - .-
C
, .. ..
.
, j .
contemplating a suit against UELC _ iti 1984? Why did PSNil decide
not to file suit,'and why was UELC retained?
j
>
1
[ CRITIQUE OF SPECIPIC ALLEGATION RESPONSES
.
Page 1 of the NRC's Executive Summary states investigators are
'
authorized "to expend whatever resources were required to resolve
the issues." Yet the report also says that by the time the NRC
made their investigation into the allegations , the specific
contractors referred to by the allegers were no longer on site.
Consequently, the-NRC gathered only secondhand information from
- the licensee staff, and made no effort to contact companies
- responsible for the work on systems examined.
'In many cases, the NRC refers to programs which were instituted
} after construction was substantially complete, notably the
I security, drug.and alcohol testing, and personnel programs.
- The NRC also relied almost exclusively on previously generated
.
}
paperwork.
!
!
- When Jacque Durr, the engineer heading the NRC inspection,
- interviewed the allegers, he baldly stated he expected to find
t
! nothing. wrong, demonstrating an unacceptable degree of wishful
i thinking. lie also told the ELP coordinator, in the presence of
the ELP attorney, he flatly refused to interview whistleblowers
! if they wanted the ELP coordinator to be present. In addition, he
!
said the ELP was interfering with the NRC, and that there was no
!
15
,
l
'
_ . _ . _ _ _ _ . _ , , . _ _ . , . _ _ . , _ . _ . _ _ . _ , . _ _ _ _ _ . . , , _ , _ _ _ . , , _ _ _ _ . . _ .
_
. . - - .- - _ _ , _ - . - ~ . . . _ . - - . -
. ...
.
e. 4 e
,
4
role for the ELP since whistleblowers should g directly to the.
'
NRC. Ilowever, people in contact with the ELP are hesitant to go
to-the NRC believing the agency will whitewash their concerns and
could compromise their confidentiality as has occurred at other
nuclear plants. The charge of interference was puzzling since the
4
NRC would never have been aware of these allegations without the
4
help of the ELP.
CRACKS IN Tile CONTAINMENT CONCRETE (allegations #1,#2, 83, #4,
and $17, pages 15 to 23). Allegers refer to major c, racks, some
'
leaking water. The NRC reply only addresses reports on surface
cracks concerning surface cracks, finding the allegations are
!
"not substantiated." Bdt the NRC does in passing mention there
'
are some cracks which leak water (page 22). If the cracks leak
' water, then aren't they more than simply " surface cracks"? The
I NRC says the cracks leaking water are adequately patched, and
cite reports on inspections done in late summer and early fall.
Since the water table is usually at its lowest then, is it
possible the cracks would leak when ground water was higher?
1
t
The NRC says minor cracks in the containment are acceptable
i
because the reinforcing bars prevent containment failure , and
l!
because surface cracks don't affect the rebar, cracks as a
l
i-
,
problem is "not substantiated." There is no discussion of the
i
cracks which did leak water (NRC reports in 1982, 1984, and 1986,
i
page 23), and the water's effect on the rebar. The NRC discussion
i
'
of the structural integrity test implies the containment will
l
l
'
16
-. - . . - -- - - . - . - - - - - . - - - . . . . - - - - . - - . . . . - - . . - . -
.. ,.
.
o ; e
flex, and that weak spots are susceptible to pressure.
Isn't it possible that when the concrete leaks, the rebar loses
its protection from corrosion, so losing its tensile strength?
-
This would create weak spots. As the rebar weakens with age, the
containment loses its margin of protection as it increasingly
needs it. Also, if water can leak in, can't radiation leak out in
a pressurized situation?
Allegation #2, a rejected batch of concrete was poured anyway,
was dismissed by the NRC. Even though that allegation had been
clarified, showing the incident occurred in Unit II, the NRC
dismissed the allegation, citing records from Unit I.
Even though the rods supporting the containment were improperly
severed, the NRC says that was not a problem because the rods
were reattached using the "cadweld" process. The NRC statement
that this process makes the rods stronger than if they had never
been improperly severed is debatable. .
THE FIRE PROTECTION SYSTEM'S CLOGGED PIPES addressed in
allegations #6, #49, and #50 (pages 25 to 27) drew an inadequate
response from the NRC. The following analysis was provided by
Raymond Lavoie, a former electrician at the Seabrook plant, who
saw 12-inch pipe so clogged there was only a 4-inch diameter
hole.
On page 25, paragraph 2, he did not find it helpful to learn that
17
.
.
. _ . .
. ..
.
. s .
the inspector simply reviewed documents and ensured that
procedures were in place for maintenance of the fire protection
equipment. Some effort should have been made to inspect the pipes
which he observed to contain thick sedimentation. The fact that
surveillance and testing programs are in effect is not evidence
of ability to implement them, even if they are adequate. It would
also be helpful to know what specific procedures exist.
Page 25, paragraph 3: the NRC inspector reported that "to
establish the condition of the fire protection system," he
observed fire hydrant testing, sprinkler system testing, and
examined screens. It is not sufficiently clear when this was
done, i.e., 1983 or during the onsite visit in 1986, whether it
was the onsite 1986 inspector who observed the testing, or
whether it was a report that the onsite inspector observed of
testing done on some other date. The report also fails to
indicate from where the screens were removed. The remainder of
paragraph 3 again only refers to review of written documents and
-
procedures that had been provided. The paragraph also refers to
" inspection of fire pump house piping." One assumes the reference
is to piping inside the fire pump house and not outside the pump
house where the actual piping was observed to contain thick
sedimentation. Overall, the review appears to be only a paperwork
review.
Page 26, paragraph 1, an interview with the American Nuclear
. Insurers representative reportedly took place. Since the nuclear
industry backs ANI, any conclusions arrived at by the NRC may
18
_ _ _ _ _ _ - _ _ _ _ _ _ _
, , , , , , , , , ,. . _ . . . . _ . _
.. ,.
.
. .
lack credibility. Again, paragraph i does not provide us with any
dates. At best, it appears that the NRC reviewed a memorandum
dated October 22, 1986, prepared by ANI.
Page 26, paragraph 2, the NRC report indicates that on November
4, 1986, (the same day Raymond Lavoie was interviewed, the NRC
" observed insurance tests for systems "P" and "I," the electrical
transformer 2-inch drain tests and the hydrant il flow tests and
the " expected pressure and water volume flow characteristics were
achieved with no evidence of line blockage noted." Again, the NRC
does not indicate whether they were observing written reports of
tests done prior to November 4, 1986. While the NRC admits to
some blockage and evidence of sedimentation, the actual test
performed (on some unknown date) was inadequate. The system should
have been achieving several thousand gallons more of water per
minute from the nozzels.
.Raymond Lavoie believes the NRC should have used at least 20 2-
inch nozzels. Also, the fact that " water flowing from the nozzel
was clear" is not indicative of anything if the sedimentation in ~
the pipes was hardened and crusty, as Lavoie observed it to be.
Arrangements should also have been made for producing several
streams of water.
The NRC does not specify what activity it was involved in or what
it observed that caused the NRC to conclude that the Fire Pump
House was always kept locked when not attended. Furthermore, the
.NRC apparently is indicating in paragraph 2 that the inspector
reached his conclusions prior to interviewing Lavoie. Such an
19
- - - ____-_.
. ;.
.
a : .
interview, therefore, could not be characterized as one conducted
in good faith. The paragraph also states "the stream through a 1
3/4-inch nozzel reached beyond 200 feet." In Lavoie's opinion,
this is inadequate evidence of ability to put out a major fire at
the plant, i.e., there would have to be evidence of the stream
reaching far beyond 200 feet.
Page 26, paragraph 3, the NRC inspector noted that " chlorination
had been in progress," but the reference is to the word
" initiated" in 1983. The report further states the purpose of
chlorination was to prevent microbiological induced corrosion
(MIC). Allegations #6, #49, and ISO do not speak about corrosion,
rather they speak about sedimentation, a completely different
process. Furthermore, the NRC talks about preventing corrosion in
the " unlined pipes," while the pipes in question were not unlined
pipes. The NRC admits this further on in their report where the
inspector indicates that the pipes in question were lined with
cement and therefore could give the impression of being clogged
with sediment. _
Again, the NRC states that the pipes were removed or disassembled
inside the fire pump house to remove MIC deposits, and not
disassembled outside the pump house where workers actually
observed the sediment or clogging. Further, the NRC reports that
the evidence of success of the chlorination project was verified
by the clarity of the water. Again, Lavoie believes clear water
could be achieved if a pipe was filled with hardened sediment.
The real question is: would the amount or volume of water be
20
. ,.
.
.-e .
sufficient to put out a major fire?
' Conclusion: the NRC's inspection did not adequately address the
allegations and it is debatable whether or not an actual onsite
inspection occurred.
-CEMENT COATING' BREAKING OFF INSIDE SERVICE WATER LINES,
(allegation 87, page 28)is dealt with as a cement problem, and is
severed from the cold pulling problem raised in other parts of
the report, although NRC comments on this allegation imply the
cement cracking could have been due to cold pulling.
TRAINING INADEQUACIES (allegations #10, #11, #12, #27, #29, and
- 35,-Pages 35, 37, 38, and 63) were dismissed by the NRC which
relied on reports by the licensee and companies it hired. The NRC
also affirmed procedures were adhered too, and they met NRC
requirements. However, other parts of the report (pages 28,
66,74, and 86) show a major failure of those NRC assurances.
Pullman-Higgins, the piping contractor is cited as not knowing,
seven years into the plant's construction that cold pulling is a_
prohibited practice, and with having problems with design control
and construction practices. If the procedures worked so well, why
weren't these problems discovered much earlier?
.
.
HARASSMENT OF WORKERS REPORTING SAFETY PROBLEMS: DRUG AND ALCOHOL
ABUSE (allegations #13, #16, and #21, pages 42 and 49) are
dismissed as "not substantiated." The NRC reasoning? The rules do
not allow that kind of behavior. Such rationale doesn't account
for the fact that rules get broken.
21
_ . _ _ . _ . . . . , . . _ _ _ _ _ _ . _ . . _ . - . _ . .
.. ,.
e. # .
DEBRIS IN AN ELECTRIC GENERATOR, FIRE IN AN ELECTRICAL CONDUIT, A
FILTHY REACTOR, PAINT THINNER SPILLED ON ELECTRICAL CABLES,, WORN
ELECTRICAL ~ CABLES WHICH~GAVE OFF SPARKS (allegations 818, #19,
- 38, #39, #43, pages 50, 51, 71, 73, and 80) refer to an overall
housekeeping problem in the Seabrook plant's construction. They
were symptomatic of an ongoing generic problem of poor working
conditions and an uncaring attitude toward building a nuclear
elant. Looking at the issue now has no bearing on the actual
working situation. ,
The fire in the electrical conduit caused by a ci arette
h was
'
dismissed by the NRC with rather speculative language, "if a fire
had occurced..." The alleger rei*terates: a fire very definately
occurred. Is it possible debris or garbage had also fallen into
the conduit and burned hotly enough to burn the cables? That
possibility was not considered by the NRC in addressing this
. allegation.
-
CHECK OFFS FOR STARTUP WERE DONE CARELESSLY (allegation 820, page
53) was decided to be " unsubstantiated" by the NRC. The response,
- "if erroneous information was gathered, it would have been
j
detected and corrected" does not take into account that
information not collected cannot be checked. Inspection work
which is not done with first-hand knowlege is sloppy work; it is l
,
not according to procedure. The NRC is willing to concede
!
I erroneous information may have been gathered in the inspection
1
i
procedure; why then assume the follow up procedures function
22
.. - _
- , -
,
. ./
- f.
'e ; e
correctly if other procedures apparently have failed?
SECURITY problems (allegations #22 and #23, pages 55 and 56) were
'
, dismissed by the NRC'wh'ich cited access control reports. One
alleger-responded that in 1982, security didn't seem as
interested in controlling access as in searching outgoing
. personnel to prevent theft from the site.
,9
- 1,
The NRC report does not address security during construction so
,
much as it analyzes post-construction security. Essentially the
s
'
NRC accepts the licensee's word that security worked simply
because the licensee's procedure was NRC-approved. Is the
presence of an NRC-approved procedure enough guarantee the
procedure worked?
DEFICIENCIES WITH NONCONFORMANCE REPORTS (allegation #24, page
58) was found to be " unsubstantiated" by the NRC because all the
,
appropriate reporting, engineering, and quality assurance
procedures were NRC-approved. -
l SAFETY RELATED CONSTRUCTION PROCEDURES AMBIGUOUS (allegation #25,
page 60) was dismissed by the NRC because NRC-approved rules and
procedures to prevent such problems were found to be acceptable
by the NRC.
i
,
TRACKING OF BLUEPRINTS AND DRAWING REVISION CONTROL WERE
INEFFECTIVE (allegations #32 and #57, page 64) were found by the
NRC to be true "in isolated cases", but were " unsubstantiated" in
l
23
.--.-- -_- -
. , . . . ,.
. . . - .
.
. .
e. e
,
,
o : . ,
the NRC conclusion. However, the NRC procedures only actually
call'for inspections in isolated cases anyway. If only a small
number of cases were examined by the NRC, and within those were
found " isolated instances" of this problem, might there have been
many more cases never discovered?
Pullman-Higgins, the piping contract,or, lost its document control
responsibilities to UE&C in 1983 (see page 67). That action shows
more of a problem than the NRC acknowleges in the " isolated
cases" cited.
. BATTLING AND SABOTAGE BETWEEN CONTRACTORS (allegations #33,#34,
859, and.t 60, page 66, "could not be fully substantiated by the
NRC, but no safety related equipment deficiencies could be
identified..." No contractors from P-H, one of the contractors
mentioned in the allegation, remained on site at the time of the
-NRC's investigation, and the NRC ms .e no apparent effort to h
contact any of the P-H employees who had worked on seabrook. No
4
safety problems were found because the NRC didn't talk to anyone .
who would know about the problems referred to in the allegations.
.
PRIMARY AND BACKUP FEEDWATER SYSTEMS SUPPORTED BY A SINGLE
STRUCTURE AND NOT ADEQUATLEY SEPARATED (NO FIREWALL BETWEEN THEM)
(allegation #48, page 85) was dismissed as "not substantiated" by l'
the NRC, but the allegation, made by Douglas Richardson, was
misinterpreted. The alleger was concerned an accident,
specifically a fire or a seismic event, could destroy both
systems at once; the NRC only analyzed a situation where a
) l
-
24 t -
l
' l:-
.
.. . .
_ _ _ _ _ _ _ _ _
r-
s. .
. - i .-
nissile from the turbine driven pump wrecking the system "is not
a' credible event." That was not the concern raised by Richardson.
THERE IS NO FIRE BARRIER OR OTHER SEPARATION BETWEEN' CONTROL
BUILDING AIR CONDITIONING SYSTEM REFRIGERANT LINES (allegation #
51, page 86) refers to no separation of power sources and no fire
barriers between primary and backup systems. The NRC agrees that
is the case, but says the " design...does not degrade plant
safety." But is the design truely adequate for protecting public
safety? The alleger, Douglas Richardson, was told by NRC staff
the lack of separation was based on the proper functioning of the
fire protection system. But that system has been called into
question (see page 25).
EMERGENCY FEEDWATER SYSTEM FED FROM THE SAME TANK WHICH SERVES AS
CONDENSATE STORAGE FOR THE MAIN STEAM FEEDWATER SYSTEM
(allegation 852, page 87) was found to be " unsubstantiated" by
the NRC. However, the rationale assumes a minimum requirement,
.
that the heat removal system will work. Does this follow the
defense-in-depth requirement? -
.
Both the primary and backup system are connected to the same
I
water tank. This tank is backt' -Jp by the concrete enclosure
'which will catch water from the tank if it ruptures. However,
does this rationale take into account a rupture high up in the
tank preventing water from flowing into the concrete containment?
Wouldn't water inside the ruptured tank then be inaccessible?
,
f
,, ; '
25
,:
A
4
-____-_____-_ _ __ _____ _______ _
e .
o- , .
Also, if the tank ruptures, is potential clogging from debris
from the rupture, or failure of alarm and level gauges taken into
account? The system is also defended by citing administrative
controls which rely on operators taking correct actions. Does
this analysis look at the fact that human error is the cause of
many nuclear plant accidents?
The tank has six nozzle penetrations; other systems are hooked up
to it. Will there always be a full tank? Is design adequate?
Wouldn't two tanks in different locations be safer?
The feedwater system is an extremely important part of the
I
nuclear plant, and its safe design and construction is crucial to
the plant's safety. It should be noted that this system failed in
the Three Mile Island nuclear plant, and this systems's failure
caused an accident more recently at the Davis Besse nuclear
plant in Toledo, Ohio.
UNEVEN SUPPORT LOADING UNDER HEAT EXCHANGERS: LINES RUN IN WRONG
SLOPE; WELD IDENTIFICATION PROBLEMS; COLD PULLING IN THE
CONDENSER PIPING, PROBLEMS IN THE TURBINE EXHAUST SYSTEM AND
CONDENSER PIPING (allegation ISS, page 91) was found
unsubstantiated because the NRC misconstrued the alleger's
(Douglas Pichardson) concerns and looked at an entirely different
system. The NRC examined the feed water heaters, not the heat
exchangers, even though the alleger showed the NRC on their own
drawings the exact system to which he was referring.
.
26
' -
.
. - _ _ _ _ _ _ _ _ _ _ _ _ _ -_ \
. -_
,
. -.-
o e ,
but
The-NRC says the sloping of the pipes was part of the design,
the alleger, a former as-built piping inspector, would not
confuse.a designed slope for a construction error.
The weld identification problems were dismissed because according
to the NRC, that information was "not a regulatory requirement."
The_ alleger was told by P-H that weld identification was a
requirement, and part of his job. That program was cancelled at
the same time there was a major restructuring of P-H's role in
the Seabrook plant construction. Is there a relationship between
,
the decision to cancel the program and the discovery that P-H was
suffering from reports of poor job performance (see page 67)?
The alleger addressed a problem of cold pulling in the condenser
piping. The NRC looked at an entirely different system and cited
~ s
a cold pulling incident which had already been documented and
dismissed as an isolated incident (see page 74).
4 The NRC inspected the main steam and feedwater lines instead of_
the turbine exhaust system and condenser piping, even though the
- alleger was very specific on the location and function of the
system he was concerned about. In inspecting the wrong system,
.
.the NRC found it had no problems and dismissed the allegation.
Photos numbers 11 and 12 are not the heat exchangers described by
Douglas Richardson to the NRC. There is no question of mistaken
terminology: the NRC examined the wrong system.
27
r -- w a v+~v ,--e
n~rr-- e, -em----m----d.9-v- e s *www* --
-tv--
. .. . . . . . _
.
- o
'
. e2
e o ,
TRAINING WAS OF UNEVEN QUALITY (allegation #58, page 95) was
misinterpreted by the NRC, thus was "not substantiated." Allegers
referred to specific technical training; the NRC sidestepped this
concern and addressed only general orientation procedures.
.
CONCLUSION
From random indications that something was not right here and
there, the information in the NRC report shows the feeling on the
allegers' parts that something was wrong is justified. Cold
pulling was not known to be a prohibited practice by the piping
contractor who also.had job performance problems. Those problems
!
weren't discovered until long after construction was begun,
calling into question effectiveness of training, of quality
,
assurance and quality control programs (if the contractor didn't
,
know about prohibited practices, neither did their inspectors),
and of NRC inspection and general _ oversight of the Seabrook plant _
construction.
Some NRC decisions are questionable. For instance, the fire
protections system is not classified as safety related. However,
the NRC relies on the_ fire protection system in calculations on
how well safety related systems and their backups should be
separated. For that reason, shouldn't fire protection systems be
considered safety related?
,
28
-
,. - - - - _ _ _ - . . - . - . _ _ _ _ _
,_ _ _ . , _ , , _
_ _
L
- . o
b
o oe
Douglas Richardson, former piping inspector, was told by NRC
engineer Jacque Durr, and on-site NRC inspector Anthony Cerne,
that the NRC was not concerned if non-safety related systems
don't. work. However, on page 92, the NRC states it is concerned
about the general quality of all plant systems to avoid failures
and challenges to safety systems.
<
The' quality of the report itself is poor. The NRC sidestepped
allegations, misconstrued allegations, which had been made very
-
clear. The NRC accepted licensee analyses and reports, and quoted
-
rules and procedures prohibiting certain actions as proof those
actions could not have taken place. Yet there are indications,
those rules have been broken repeatedly. The NRC arguement that
the existence of certain procedures means those procedures
couldn't have been violated seems to be a way for the NRC to
insulate itself from questions of how well the agency protects
public safety.
Even though the NRC inspection team for this report was -
specifically asked to look at the individual allegations as
examples of generic problems, the NRC made every effort to avoid
doing so. Larger questions, beyond the allegations and the NRC
response to them are raised by this report. How valid is the
framework within which the NRC operates? Is it enough for the NRC
to say there are procedures to prevent certain prohibited
activities? Rules aren't always obeyed. Is it enough for the NRC
to approve a nuclear plant's safety based on audits of a very
small percentage of licensee reports on self-inspections?
-29
1,,.. -
- - _ . - _ _ _ - _ .
- - - - - - - - - _ - - - - - - . - - - - - - - - - - _ _ - - - _ - - - - - - - - - _
.
,
.. o ,
e cm
Additional questions to be addressed are how were similar
allegations and problems at other nuclear plants around the
country treated by the NRC? It seems there was a serious quality
assurance breakdown with at least one contractor at the Seabrook
nuclear plant. Several companies which worked at the Seabrook
I
plant were cited for serious quality assurance breakdowns at
(
other nuclear plants. For example, the Byron nuclear plant was.
denied an operating license in 1984 because Johnson Controls and
Pittsburg Testing Labs (both contractors at the Seabrook plant)
f
had quality assurance breakdowns there.
!
l
l
t
The NRC response to'the allegations in many instances widely
missed the issues allegers brought up. First hand information was
not gathered. If this NRC report is-an example of how well that
agency carries out its responsibilities, it is not encouraging.
' Fail safe" is a concept whose meaning has changed since _
Chernobyl.and the Challenger accidents. The NRC assurances the
~
Seabrook nuclear plant is fail safe are undercut by information
provided in the very report meant to substantiate them. Shouldn't
assurances the Seabrook plant is safe be put in the hands of an
independent investigator, who, with considerable public
oversight, can comprehensively examine the plant?
.
30
~
~~~~ ~
. . . .. . . -. - _ - _ - - _ _