ML19256A180
| ML19256A180 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/25/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Drey L AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 7811030206 | |
| Download: ML19256A180 (3) | |
Text
PP4 UNITED STATES
[paatop NUCLEAR REGULATORY COMMISSION
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4 GLEN ELLYN BLLINOIS 60137
'49.....,0 October 25, 1978 Mrs. Leo Drey 515 West Point Avenue University City, MO 63130
Dear Mrs. Drey:
This is in response to your letter of September 11, 1978, relative to the construction adequacy of the Callaway Nuclear Plant dock facility.
Your letter indicates you have two basic concerns relative to the barge dock facility:
(1) the safety of personnel involved in the construction and use of the facility; and (2) the protection of nuclear safety-related components during handling at the dock.
With respect to the first concern, OSHA conducted an investigation and could not determine that the conditions alleged af fected employee safety. They did not make a finding of the structural integrity of the dock under load conditions, and referred that matter to us for possible handling. As you know, the NRC only has regulatory jurisdiction over construction activities that relate to the safe nuclear operation of the plant --- and the dock is not in this cat e go ry. We know of no other government agency that might have jurisdiction over this matter and, as such, believe the responsibility for the structural integrity of the dock facility rests with the owner.
Regarding the second issue, the NRC is concerned with the protection of nuclear safety-related components and requires load testing of handling equipment prior to the actual handling of these components.
In the case of the Callaway dock facility, a 430-ton test load was successfully lifted on September 25, 1978. The reactor pressure vessel, which weighs approximately 356 tons, was lifted on October 9, 1978, and subsequently transported to the site without incident.
With respect to the specific questions raised on page 2 of your letter, the following information is provided:
.e
Mrs. Leo Drey 10/25/78 Question - How does OSRA know if the alleged conditions are hazardous if they never asked Bill Smart what the conditions were?
Answer - We have no information on the investigation methods employed by OSHA and this question would more properly be addressed to them.
Question - What did Bechtel and Daniel investigate, and with what method?
Answer - Since the allegations are beyond the purview of the NRC, no investigation was conducted by the NRC. We did, however, pass the allegations which you provided to us on to the lisensee and were subsequently told that these allegations were inve stigated. We do not have specific information as to the methods used.
Question - To whom should Bill Smart now refer his concerns? The NRC apparently has no jurisdiction over temporary buildings, according to 10 CFR 50.10 (b)(3), even though OSHA mistakenly thinks it has and a member of the public thinks it should have.
Answer - Based on the above information, Bill Smart's concerns regarding the dock facility should be brought to the attention of Union Electric Company.
Question - If the Callaway dock was indeed not built as designed and therefore were to collapse not under the test load, but during the subsequent lif t of the vessel itself, is it not correct that the integrity of one of the most critical, safety-related "Q" items at the Callaway plant would suf fer -- that is, the reactor vessel?
(I'm beginning to think that most NRC licensees would probably be able to satisfy the NRC that dropping a reactor vessel is not any more significant than installing it backwards would be!)
Answer - If the dock would have collapsed during lifting of the reactor pressure vessel, it is quite likely the vessel would have been damaged.
In such a case the NRC would require that the licensee demonstrate to the NRC's satisf action, prior to issuance of an Operating License, that the reactor vessel was espable of performing its design functions.
Lastly, your letter questioned how the NRC could have informed Union Electric of the allegations without having reviewed the matter with Bill Smart. When you talked with Gen Roy, Region III Deputy Director, on July 28, 1978, you will recall that you passed on four specific allegations regarding the dock facility. According to Mr. Roy, he told you that, while the NRC did not have jurisdiction in this matter, he felt obligated to pass your concerns on to Union Electric
Mrs. Leo Drey 10/25/78 management and that you had no problem with him doing so.
The information which you provided was forwarded to Union Electric on August 1, 1978. The five allegations enclosed in your September 11, 1978, letter, were essentially the same as those discussed with Mr. Roy, and these were provided _also to Union Electric on September 20, 1978.
We will be happy to discuss any further questions you may have concerning these matters.
Sincerely,
)b? /k James G. Kepp er
' Director cc:
Denver L. Holt and John R. Vetter, Acting Area Directors, OSRA, St. Louis Emil A. Wehmhoemer, Senior Resident Investigator, OSHA, Kansas City Richard E. Beumer, Vice President, Sverdrup & Parcel and Associates LPDR PDR