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A_P F I D AtV I T |

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lly name is Dennis Wayne Swartz. I am submitting i

this affidavit freely and voluntarily, without any threats,!

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inducements or promises of reward,.to Mr. Thomas Devine, '

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who has identified himself as the legal director of the '

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Governnent Accountability Pro' ject of the institute for.

Policy Studies. I wish to register my concern about safe-:'

ty defects due to construction shorte'uts at the LaSalle.

nuclear powcr plant. These defects.are massive and, in.

my opinion, must be correc+ed before the plant goes into

operation. -

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I worked at LaSalle on and offias a laborer between .

1973 and early 1982, when I resigned:in protest. During

ny employment at LaSalle I was bothta steward and a fore-.

man at vari'ous points. My job gave me a chance to directly ;

observe concrete work throughout the: plant. I also worked' '

on mixing mortar. Now that the plant is so near to com- '

pletion and the flaws were iot repaired, I have to speak

out about what I saw. .

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''Prdbably the most serious . construction deficiencies'

that I. personally observed occurred during a February-,

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March 14, 1980 stretch that I worked at LaSalle. The flaws.

involved the concrete in the containment wall and the reac-' +a.

tor pedestal. We were helping.toainstall supports for .

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large tubes that came out of theesuppression pool betweens\

\ the, reactor pedestal and the containment wall. Chicago\

Bridge and Iron cut out stainless steel panels and then

the concrete was core-drilled to inst:all the supports. I

personally saw holes at least a foot to twenty inches deep

being drilled into the containment:at the 710 foot elevaa

tion. In the process,.nany of the reinforcement bars were

severed. I personally saw a half: dozen rebars severed on

each of two or three occasions during the first few days

of core-drilling. This scared me..because cutting through

tbd pedestal rebars is like takingjout your vertabrae.

( "|he pedestal is the backbone of the i reactor - - it holds'

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the reactor up. ,

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The problem of shattered rcbars iis not limited to

the pedestal. I saw rebars; severed"all over the plant|

| during core-drilling. Construction * crews should have

known where the rebars are located, if the blueprints had

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been accurate.

It is not as if the concrete were so solid that it '

idid not,need the reinforcement bars.. I was struck one ,

day as I was climbing up a ladder on my way to lunch. I

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was about 25 feet above the suppression pool.

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, third up the east side of the reactor <pedest l, or one- "

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Chicago Bridge and Iron had justa

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finished scarfing, or .

cutting out, a steel panel.-

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Removing.the pe.nel revealed,

a glant void in the concrete, .so large th,

climb right in and lie down. at a man couldI couldn't believe it.

Construction crews patched up the holethe bonding is not as strong as if

.with grout, but.

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to start with. the concrhte were solid-

More important,I wondered how many other

spots on the pedestal were honeycombed with h l

construction crews did not renove all'theo es. The

steel plates tocheck.

I have seen enough cases .of shoddy cmy question is not oncrete work that

a shot in the darkathe poor work was because of press Most of the time

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Construction shortcuts have been goinure!to rush the job.g on for years. Forinstance, in 1974 construction crews

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!the screenhouse. poured concrete for

it was supposed to, however.The concrete. hardened much faster thar.'

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days to harden, but you could walk oIt should :take three to f our-

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n this concrete su ahalf hour.That is unrealistic, sin ~ce the floors

four feet t. hick. were

When concrete hardens that quickly you\

cannot count on the strength of the bondin-

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It wa's not a mystery why -the concrete. ,'(,

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set so fast. , (3 r,

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There was chloride added to it*

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. ' The chloride was very hot to : speed up the process.'

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and would burn your hands and-

. face if it splattered.., *.

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, I repeatedly saw the results,of sloppy concretepours- holes and honeycombs in <the concrete

the reason was because the areas were not. Often

properly before the pours. cleaned outI first noticed fhe problem

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in 1974 atthe outer containnent walls.

to cle.~.n out We were supposed

accunulated debris so the concrete could fillup a-clean surface area.The debris included wires, paper

cups, soda pop cans, beer cans,and even timber-like two-by-fours.

Unfertunately, constructicm crews had ithe rebars and nstalled

ties for the walls bef. ore the area wcleaned out. as

As a result, we could 'not reach all the dbris.

You couldn't even . slide your hand in toe-

debris. reach the.

Even worse, the crews poured the concret--

e before wewere done eleaning the area andithe junk jOne tine they.went so quick 1.y that the

ust stayed there.t

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concrete was pour,edon 'op of one man's head.

items left behind. I personally saw hundreds of

the outeg containment wall and generallI observedithis. practice on about i of.

y on the concretefloors'II saw the same type of probl

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em in 1975 at the'

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J-line wall that separates the reactors from the auxiliary, ,

building.'

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Other times the da' age was due to ' pouring too muchm

concrete at once in a limited area. Concrete has to sitlong' enough to hold its own wei.ght. Due to the speed-up,

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though, the pressure would b'e t9o great and the wallswould push out. For instance,.I can_ point oyt one section

. of the outer cont'ainment wall poured in 1974 that site aboutfour inches off-whack. In 1978 I saw another example when

the excess pressure blew out a section of the turbine wallseparating the turbine from radwastes The blast blew onefellow 20 feet away.

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A final reason for the shoddy, concrete also involvedspeed-up pressures. Before a pour, concrete has to be" vibrated" to get out the air; bubbles and be bondable. *

I observed the process in 1975 or'1976. But constructionwas in such a hurry that the bubbles were not all removed.That may be'another reason for the-honeycombing in the con-

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crete..

Similar to the concrete miseries, I do not trust the'.

mortar work at LaSalle. Sometimes the problem was that themortar was not used. The walls are constructed with high- .

density blocks five to six feetathick. The blocks.have,

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All the blocks are . supposed to be packed,

metal inside; '

The construction crews would pack .

together with mortar. a.

hthe outer two or three blocks with mortar and Jyst s ove~

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the rest in without any' binding.When I complained to a

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foreman he said that Quality Control' did not care. .

build-served this practice in t e radwaste and auxiliaryh

ings, as well as the turbines..

Even when mortar was used, it was shoddy quality.Sometimes you

There was too much sand in the nortar..

There was so muchnail and write in it..could take'athe bricklayers couldn''t pound the blocks down.

sand that iwhen I worked m x-I witnessed the abuse during:1976-78',

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ing the mortar, and later asia foreman and steward in the.

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same area.

You are supposed to, nix,7 shovels of sand with eachThat.is how I mixed it

bag of nortar and some waterearound, a third of the time my t

Butwhen I worked alone.superintendent was present and ordered me to add extra

I'd ' estimate about three to four bags of sand weresand. d thaninvolved for each bag, which meant up to 507. more san

ThereAll .that ; mortar is suspect. ,

there should have been.the superintendent always knew when

were nortar tests, but *

me do it right then. .

the tests were scheduled and l'et ''.But 7S%Walgreen, the contractor, finally lef t the site.

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(to the best of my knowledge, theof the masonry was done; I-. .

! shoddy mortar was never found and replaced .; ;.

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Another LaSalle worker told me of a particularly I

frightening incident in 1978. It makes me wonder if

LaSalle is ready to start opernting. In 1978 there was

a reactor pressure test that literally blew the roof off..

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It'was replaced, at several million dollars expense._

Even after such a shocking incident, management tried toThe accident.also ripped out the bolts forcut corners.

sone of the piping. Instead of doing the holes over, they.

just redrilled the old holes and m'ade them bigger. The

and theripes may be less secure now than during the test,

bolts didn't hold then. I am not aware of any new pressure

test since tne roof blew off. I believe the plant should

have to pass this test before operations begin. If the top ,

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blows during a test, it"can blow when the plant is running,l

All of titese disasters have. lef t tbc morale very low-

| among the workers. It is frustrating not to be allowed to '

1 There is;"No Nukes" graffitti scattered.

|do your job right.

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throughout the plant periodically. ,

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The "No Nukes" graffitti turned.out to illustrate'

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more th.an \jhe insight of nuclear construction workers..

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.'It showed,the problem of worker safety. Management had us ;GP, ,,

clean th.e walls with a poisonous substance called electro-.

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clean that was making us sick.There was a skull and

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crossbones right on the label.-

Therlabel also sai.d, I

" Toxic,.do not breathe, use in,a well-ventilat dg.

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e area."I resigned in protest.,

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This was not the first time management has 1 nored,

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6the workers' health.

Over a half dozen workers have diedat'the plant, due 'to getting' hit with steel that

fell, or '

falling due to unsafe hand railings or holes in the floor'

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Management just did not care.aboutthe hazards. As

a steward for a year during 1975 and:1976, I pointed out

unsafe condit ions to Fred Hill,. the. company saf ety manIt was like talking to a brick wall.

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He would not take*

reasonable steps to pro'tect us.

It reached the point of total. disregard for humanlife.

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In 1975 or 1976 a' man fell through a hole and hadto be scraped up off the floor. It was awful. Managementhad the laborers clean up the mess.

Even with the puddle,

|of blood still on the floor, the superintendel.t wanted usto just keep working.

He said that :ft would not help the '

worker any to stop.We insisted on' paying our respects byleaving. I told the superintendent that a man had just

lost his. life trying to make bread .and butter for hi,

i. s fam-ily. We left.

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the Nuclear Regulatory Commission-

/I am sorry that *

("NRC") has not had any noticeable impact on these prob-~

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always kn'ew t.wo days in advance of NRClems. Management

superficially. .

inspections and had us clean up the plantThe NRC never took initiatives to t

That was good enough.In fact, during all?my. years at-

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talk to us workers. "

resident inspector namedLaSalle I had never heard of t /

We always wondeted why' the NRC didn' t coneRoger Walker. '

Maybe the in-,

know in advance.when the utility didn' t ,

vestigators would have found more Problems.6

too late'to repair the damage, however.It is not

tour, I would be gladIf the NRC wants help on a plant

out holes in the concrete,. areas where concreteto point "

idwas poured over debris, and areas where blocks were la !

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without mortar.

I an speaking out pub 13 cly because the plant was not,

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for years wittiiri the company.built right. I spoke out

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any followup.The response was always noncommital without

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:to work at LaSal'le I thought we were.

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IWhen.I first went But many workershelping to solve the energy crisis.

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Like others,have seen how this nuclear plant .was' built.

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I don' t want to be living in the. area when this thing kicks t-

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off. -'

I have read the above 9 page affidavit and it is true, -. .

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ibc15cf. and complete to the be t - of my knowledge.

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