ML040230524

Comment (1) of Kay Drey on Newly Issued NRC Regulatory Guide 1.199, Anchoring Components and Structural Supports in Concrete, (November 2003)

ML040230524
Person / Time
Site:	Callaway
Issue date:	01/08/2004
From:	Drey K - No Known Affiliation
To:	NRC/ADM/DAS/RDB
References
68FR68675 00001, RG-1.199
Download: ML040230524 (1)

Text

co8 Kay Drey 515 West Point Ave. University City, MO 63130 6' ,,y 8,2X04 Rules and Directives Branch, ADM <9 C US Nuclear Regulatory Commission (j/

Washington, DC 20555-0001

Dear Sir or Madam:

- It was of great-interest-to me to read the newly issued NRC Regulatory Guide 1.1999, "Anchoring Components and Structural Supports in Concrete," (November 2003). Although the Nuclear Regulatory Commission inspectors and the licensee knew during construction of the Callaway nuclear power plant, here in Missouri, that embedded steel plates (anchors) to which studs had been defectively welded were installed in concrete structures as supports for components, no special inspections were required and no removal of defective embeds was mandated. The steel embeds were used as supports for safety-related piping systems and other systems and components. Many embeds were installed in concrete walls to support steel structural members (like I-beams) which in turn supported or carried entire floor systems.

I had submitted a great deal of very specific information to the NRC about the defective embeds

'during the construction of the plant.. This informatioii was basically ignored, and I was informed by an NRC inspector that we could not officially protest the defects until the operating license proceeding. At that time our contention about the defective embeds was also ignored.

The very experienced and well-informed ironworker who had given me most of the information, over a period of many months, knew of the significance of the embeds and knew that missing studs and other defects in the embeds posed unacceptable risks. Several days ago I read some sections to him by telephone of Reg. Guide 1.199, including the following sentence: "Anchors used in nuclear power plants may need to withstand stress for long periods of time and may need to compensate the additional transient-imposed stresses as a result of environmental effects."

~--. -(p;-3)

His response was: "I knew at least as early as 1976-77 that many of the Callaway embeds that were being installed were defective. I was totally amazed. It was obvious to me that the embeds that we were instructed to install at Callaway had never been tested to see if the studs had been properly welded to the base plate. We found studs that had become detached just from the mere handling of them. Normally an ironworker or an inspector will take a 4-pound beater or a sledge hammer and hit a stud on the end and bend it over and make sure it didn't come off. If it was fused properly, you could bend the stud over without knocking it loose. I had never before seen even one stud knocked off an embed in my 20.prior years'spent 'working in the commercial' construction industry; I was particularly disturbed because this was at a nuclear power plant."-

ft;~~I I - , ; ,,-- . i ***

My response to Regulatory Guide 1.199 is: We told you so --- and now what?

Sincerely, 3, 6Ze~~~ A'*