ML20027E079
| ML20027E079 | |
| Person / Time | |
|---|---|
| Site: | 05000000, LaSalle |
| Issue date: | 09/17/1982 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Steptoe P ISHAM, LINCOLN & BEALE |
| Shared Package | |
| ML20027A786 | List:
|
| References | |
| FOIA-82-328 NUDOCS 8211120010 | |
| Download: ML20027E079 (9) | |
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- , g WASHING T ON, D. C. 20555 N,*****/
September 17, 1982 Docket No. 50-373 Philip P. Steptoe, Esquire Isham, Lincoln & Beale Three First National Plaza IN RESPONSE REFER Chicago, IL 60602 TO F01A-82-328
Dear Mr. Steptoe:
This is in reply to your letter dated July 21, 1982, in which you requested, pursuant to the Freedom of Information Act, copies of all documents relating to the NRC's 1982 investigations of improper construction practices at the LaSalle Plant, including, but not limited to, those allegations submitted to the NRC by the Government Accountability Project of the Institute for Policy Studies, the Illinois Attorney, General's Office, and Illinois Friends of the Earth (Mrs. Bridget Little I
Rorem).
y In response to your request, we are providing you with copies of the documents listed on Appendix A.
The documents identified with an asterisk I
on Appendix A have the names and personal identifiers of individuals deleted in order to protect the personal privacy of the individuals or to protect the identity of a confidential source.
This information is being withheld from public disclosure pursuant to Exemptions (7)(C) and (D) of the Freedom of Information Act (5 U.S.C. 552(b)(7)(C) and (D))
and 10 CFR 9.5(a)(7)(iii) and (iv).
Pursuant to 10 CFR 9.9 of the Commission's regulations, it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest.
The persons responsible for the denial of the portions of documents marked with an asterisk (*) are the undersigned and Mr.
James G. Keppler, Regional Administrator, Region III.
This denial may be appealed to the Executive Director for Operations
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within 30 days from the receipt of this letter.
Any such appeal must be in writing, addressed to the Executive Director ~for Operations, U.S.
Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial FOI A Decision."
As you may be aware, it is NRC's policy to place documents subject to F0IA requests in the NRC Public Document Room in Washington, D.C.
For consistency and the protection of the personal privacy of individuals 8211120010 820917
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- Philip P. Steptoe, Esquire -
naned in those documents, we have removed certain names and personal identifiers from all copies of the documents.
You may, therefore, be aware. of the identity of sone individuals which we have removed.
If you wish to discuss the deletions made on any particular document, feel free to contact Mr. John C. Carr at (301)492-8133.
The charge for reproducing records not located in the NRC Public Document Room is five cents ($0.05) per page as specified in 10 CFR 9.14(b).
Accordingly, the cost of reproducing the 508 pages provided to you with this letter is $25.40.
You will be billed for this amount by our Division of Accounting.
Si
- erely,
]
. M. Felton, Director Division of Rules and Records Office of Administration
Enclosures:
As stated i
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J JAfl 2 51982 FCTC:PJiG 71-6698 to /
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?!uclear Assurance Corporation
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ATT!!: Mr. Charles R. Johnson
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24 Executive Park West
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Gentlemen:
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Atlanta, GA 30329
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9 XB-Enclosed is Certificate of Compliance ilo. 6698, Revision 110.15 for t!e Model flo. ilFS-4 shipping package.
Tne certificate has been renewed until Decenber 31, 1982.
In this regard, a consolidated application, preferably in the famat of Regulatory Guide 7.9, should be submitted at least 30 days before the expiration date of this certific~ ate.
Resolution of the issues raised in our letter of December 29, 1981 must also be included in the consolidated application.
This will require your continued efforts to resolve outstanding issues.
ilote that the certificate places restrictions on the packaging of failed fuel assemblies and fuel rods, requires positive steps to insure that the package is shipped dry, eliminates the use of pipe plugs in drain or vent lines, and extends the cavity inspection frequency from 6 months to one year.
Sincerely, Ori;ir ?.1 ;r;i ~g C21.ELIS 1. I.LM W.LD Charles E. MacDonald, Chief Transportation Certification Branch
.fE Division of Fuel Cycle and Sjc.
Material Safety, IE1SS
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Enclosures:
o 1.
Certificate of Compliance ng.j ito. 6698, Rev.15 ca 2.
Approval Record C' Q L
cc: See attached list nQ C"
Registered users:
See attached list j jpg
cc: w/cncis Mr. Richard R. Rawl Department of Transportation Dr. Donald M. Ross Department of Energy Nuclear Fuel Services, Inc.
ATTH: Mr. Larry Miedr. ann P.O. Box 124 West Valley, NY 14171 e
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Addressee's: w n Ltr dated Babcock and Wilcox Company Florida Power and Light Company ATTil: Mr. D. W. Zeff ATTH: Mr. Robert E. Uhrig P.O. Box 800 P.O. Box 529100 Lynchburg, VA 24505 Miami, FL 33152 Baltimore Gas & Electric Company Florida Power Corporation ATTN: Mr. A. E. Lundvall, Jr.
ATTU:
Dr. Patsy Y. Baynard P.O. Box 1475 P.O. Box 14042 Baltimore, MD 21203 St, Petersburg, FL 33733 Battelle Columbus Laboratories General Electric Cmpany ATTH: Mr. Harley L. Toy ATT'l: Mr. D. M. Dawson 505 King Avenue 175 Curtner Avenue-Columbus, OH 43201 San Jose, CA 9512,5' Boston Edison Company Jersey Central Power & Light Cmpany ATTN: Mr. G. Carl Andognini ATTH: Mr. John Sullivan, Jr.
P.O. Box 388 800 Boylston Street Boston, MA 02199 Forked River, NJ 08731 Commonwealth Edison Maine Yankee Atomic i)ower Co.
ATTN: Director of Nuclear Licensing ATTN: Mr. L. H. Heider.
P.O. Box 767 Turnpike Road (RT 9)
Chicago, IL 60590,
L'estboro, MA 01581 Connecticut Yankee Atomic Power Company Northern States Power Company ATTil: !!r. R. H. Graves ATTN: Mt. L.O. Mayer R.R. flo 1, P.O. Box 127E 414 Nicollet Mall, 8th Floor East Hampton, CT 06424 Minneapolis, MN 55401 Dairyland Power Cooperative Oak Ridge National Laboratory ATTN: Mr. R. E. Shimshak ATTN: fir. Milliam E. Terry P.O. Box 135 P.O. Box X Genoa, WI 54632 Oak Ridge, TN 37830 Department of Energy Reynolds Electric and Engineering ATTN: Mr. A. T. Newmann Company, Inc.
P.O. Box 14100 ATTH: Mr. Arden E. Bicker Las Vegas, NV 89114 P.O. Box 14400 Las Vegas, NV 89114 Depart: rent of Energy ATTN: Mr. James M. Peterson Rochester Gas & Electric Corporation ATTN: Mr. L. D. White, Jr.
P.O. Box 550 Richland, WA 99352 89 East Avenue
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Rochester, NY 14649 Dake Power Company ATTN: Mr. W. O. Parker, Jr.
422 South ~ Church Street Charlotte, NC 28242
Southern California Edison Company
'ATTH: Mr. William H. Seaman P.O. Brx 800 Rasemead, CA 91770 Westinghouse Electric Corporation ATTN: Mr. A. J. Hardi P.O. Box 355 Pittsburgh, PA 15230 Wisconsin Electric Power Company ATTN: Mr. Sol Burstein 231 West Michigan Milwaukee, WI - 53201 D
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CERTIFICATE OF COMPLI ANCE e
F;r Radioactia Mat:ri;is Pickiges 1.fa) Ce t f te Number 1.(b) e ision No.
1.(c) Pack eI a
1.(d) Pages No. 1.(e) otal No. Pages
- 2. PRE AMBLE 2.fa)
This certificate is issued to satisfy Sections 173.393a,173.391,173.395, and 173.396 of the Departrnent of Transportation Hazardous Materials Regulations (49 CFR 170189 and 14 CFR 103) and Sections 146-19-10a and 146-19-100 of the Department of Transportation Dangerous Cargoes Regulations (46 CFR 146-149), as amended.
2.(b)
The packaging and contents described in item 5 below, meets the safety standards set forth in Subpart C of Title 10, Code of Federal Regulations, Part 71. ** Packaging of Radioactive Materials for Transport and Transports.;on of Radioactive Material Under Certain Conditions.
2.(c)
This certificate does not relieve the consignor from compliance with any requirement of the regulations of the U.S. Department of Transportation or other applicable regulatory agencies, including the government of any country through or into which the package will be transported.
- 3. This certificate is issued on the basis of a safety analysis report of the package design or application-3.(a)
Prepared by (Name and address):
3.(b)
Title and identification of report or application:
Nuclear Fuel Services, Inc.
NFS application dated October 6,1972, P.O. Box 124 as supplemented.
West Valley, NY 14171 3.(c)
Docket No.
7]_6698
- 4. CONDITIONS This certificate is conditional upon the fulfilling of the requirements of Subpart D of 10 CFR 71. as applicable, and the conditions specified in item 5 below.
- 5. Description of Packaging and Authorized Contents, Model Number Fissile Class, other Conditions, and
References:
(a) Packaging (1)
Model No.:
NFS-4 (2)
Description A steel, lead and water shielded shipping cask.
The cask is a right cicular cylinder with upper and lower steel encased balsa impact limiters. The overall dimensions are 214 inches in length and 50 fr.ches in diameter. The gross weight of the cask is approximately 50,000 pounds. The inner cavity is 178 inches long and 13.5 inches in diameter.
The thickness of the inner shell is 5/16 inch and 1-1/4 inches for the outer shell. The two stainless steel shells are welded to a 2-inch thick stainless steel shield disc at the bottom. The annulus between the inner and outer shells is filled with lead (max. lead thickness 6-5/8 inches, minimum 5 inches).
The lid is stainless steel frustum of cone 7.5 inches thick. The lid is secured to the cavity flange by six, ASTM-A320, Grade L43,1-1/4 inch diameter bolts. The seal is provided by two polytetrafluoroethylene 0-rings.
Four neutron shield tanks, each with surge tank and rupture disc, provide a 4-1/2 inch thick (borated) water-ethylene glycol mixture around the outer shell.
Four trunnions, two located on either side of the upper or lo.wer impact limiter, are provided.
Other cask features include two drain valves located in the bottom shield disc, vent valve, head closure gasket leak check valve, rupture disc-pressure relief valve system located in the cavity flange, fuel canisters for PWR and BWR shipments, and spacers to accommodate shorter fuel assemblies.
For transport the cask may be enclosed in an expanded metal cage.
M COAAA 920125
?DR ADOCK 07106698
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Page 2 - Certificate No. 6698 - Revision No. 15 - Docket No. 71-6698 5.
(a)
Packaging (continued)
-(3)
Drawings The NFS-4 shipping cask is constructed in accordance with Nuclear Fuel Services, Inc., Drawing No. E 10080, Sheets 1 through 4, Rev.19.
The fuel assemblies are oositioned within the fuel canisters shown in Figure 2.1.3 of the application dated October 6,1972.
Spacers may be used to accommodate shorter fuel assemblies within the fuel canisters.
(b) Contents (1) Type and form of material The minimum cooling time of each fuel assembly and rod must be 120 days; and (i)
Irradiated FWR or BWR uranium oxide fuel assemblies with the following maximuin active dimensions and maximum -compositions prior to irradiation:
Fuel Assembly Data PWR BWR Envelope, in 8.60x8.60x150 5.44x5.44x144 Enrichment, w/o U-235 3.6 3.0 Weight of Uranium, kg 480 197 H/U atomic ratio 5.51 (ii)
Fuel assembly enriched in the U-235 isotope to not more than 2.5 w/o, with active fuel dimensions not to exceed 4.2" x 4.2" x 110" long.
(iii)
Byproduct and special nuclear material in the form of irradiated uranium oxide fuel rods.
(iv)
Solid nonfissile irradiated hardware and neutron source components.
(v)
Fuel assembly enriched in the U-235 isotope to r.ot more than 4.1 w/o, with active fuel dimensions not to exceed 7.8" x 121" long.
(vi)
Byproduct and special nuclear material in the form of irradiated uranium and plu; onium oxide fuel rods.
Prior to irradiation, the maximum enrichment in U-235 plus plutonium not to exceed 4.0 w/o.
(vii)
Reconstituted PWR uranium oxide fuel assemblies with:
less than the original number of fuel rods,
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Fage 3 - Certificate No. 6698 - Revision No.15 - Docket No. 71-6698 5.
(b)
Contents (continued) additional fuel rods secured in guide tube thimbles, or i
combinations of both cases above.
Fuel assembly described above must conform to the maximum active dimensions given in item 5(b)(1)(i).
Any fuel assembly shipped without one or both end fittings must be equipped with an assembly carrier as shown in Battelle Drawing No. 00-001-576 or equivalent.
(viii) Irradiated BWR uranium oxide fuel assemblies.
Prior to irradiation, the maximum enrichment in the U-235 isotope must not exceed 4.0 w/o with active fuel dimensions not to exceed 5.63" x 5.63" x 83.8" long.
(2) Maximum quantity of material per package.
Not to exc'eed a decay heat generation of 2.5 kw; and (i)
Item 5(b)(i) above:
One (1) PWR fuel assembly, or Two (2) BWR fuel assemblies; or (ii) Item 5(b)(1)(ii) above:
Four (4) fuel assemblies contained within the fuel basket shown in NFS Drawing No. 1A-T-1107, Rev. 0; or (iii) Item 5(b)(1)(iii) above:
- Maximum Fissile Maximum Enrichment Mass Limit (w/o U-235)
(kg of U-235) 3.0 2.0 4.0 1.6 6.0 1.5; or (iv) Item 5(b)(1)(iv) above:
As needed, appropriate component spacers must be used in the cask cavity to limit movement of contents during shipment; or
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l Fcge' 4 - Certificat No. 6698 - Revision No.15 - Docket No. 71-6698 5.
(b)
Contents (continued)
(v) Item 5(b)(1)(v) above:
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l One (1) fuel assembly; or m
(vi) Item 5(b)(1)(vi) above:
lii Fuel rods within the fuel canist' rs described in 5(a)(3). The e
uaximum mass of U-235 plus plutchium must not exceed 4.0 kg.
A suitable fixture may be used tonsecure the fusl rods within the
' canister; or (vii) Item 5(b)(1)(vii) above:
rii The maximum compositions of onemPWR fuel assembly including additional rods must conform tolsItem 5(b)(1); or (viii) Item 5(b)(1)(viii) above:
rii Two (2) BWR fuel assemblies.
P.cfor to irradiation, the maximum uranium content per assembly must not exceed 122 kg.
(c)
Fissile Class III Maximum number of packages per shipment Jec One(1) 6.
The cask cavity must be dry (no free water) whien. delivered to a carrier for transport. If the package is loaded or unloaded:cunder water or water is introduced
.into the cavity, residual moisture must be rembved from the cask cavity by positioning the cask vertical and with both drain lines open.
Air pressure must be applied through the open vent line in such mmianner to insure no liquid remains in the cask cavity and drain lines.
Alternatively, the cavity must be evacuated until pressure falls below 1" of Hg i(0.5 psi) at 80*F and remains there for 15 minutes. Valve off the vacuum limf and remove vacuum source.
Cavity must maintain a vacuum of at least 1" of Wg for an additional 15 minutes before returning to atmospheric pressure.
i; 7.
Except for fuel with minor cladding deflects s'uch as pin holes and hairline cracks, failed fuel assemblies and fuel rods must be delivered to a carrier for transport within an inert atmosphere (at atmospheric pressure) in the cask cavity. Drying of the cavity must be accomplished by the alternate procedure (vacuum drying) described in Item 6 above.
Failed fuel assemblies (pellets) which are oxidized are not authorized.
- tt E.
The water-ethylene glycol mixture in the neutron shield tanks may contain up to 1.0 weight percent boron. This mixture must no't freeze or precipitate in a temperature range from -40 F to 330 F.
to 9.
The cask contents must lie so limited unrMr nontiil conditions of transport that 27 times the neutron dose rate plus 1.4 times the gamma dose rate will not exceed 1,000 millirems per hour at three (3) feet from the external surface of the package.
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Page 5 - Certificate No. 6698 - Revision flo.15 - Docket tio. 71-6698
- 10. The vent and drain valves must be 1/2" FG 466TSW Miser ball valves (Worchester Valve Company,Inc.).
The ball of the valve may have a bleed hole to equalize the pressure between the cask cavity and the ball passage in a closed position.
11.
In addition to the requirements of Subpart D of 10 CFR Part 71, each package prior't'o first use must meet the acceptance tests and criteria specified on pages A-21 thru A-34 of the Nuclear Fuel Services, Inc. application dated October 6,1972,
, amended, March 1,1973 and Nuclear Assurance Corporation letter dated November 1,19/4.
The results of these tests must be documented and retained for the life of the cask.
- 12. At periodic intervals not to exceed (3) years, the thermal performance of the cask be analyzed to verify that the cask operation has not degraded below that which is licensed.
Following the initial acceptance tests, the heat source may-be that provided by the decay heat from the contents of the package provided that the heat source is equal to at least 25% of the design heat load for the package. Each cask i
that fails to meet the thermal acceptance cri.teria given on pages A-21(a) and A-21(b) using the TAP computer program, or equivalent, must be withdrawn from service until corrective action can be completed.
- 13. The rupture discs for the neutron ' shield tanks must be type "B" or "DV" (BS&B Safety Systems, Inc.) or equivalent.
14.
In lieu of the requirements of 10 CFR 571.54(h), the licensee must perform periodic maintenance and testing of 0-rings, drain and vent ball valves, relief valves, and rupture discs of the cask as indicated in the table given below. During inactive periods, the maintenance and testing frequency may-be disregarded provided that the package is brought into full compliance prior to the next use of the package.
Cask Component Period Test / Action Ball Valve Each shipment Hydro test to 80 psig*
Ball Valve Annually Replace seats and seals 0-rings Each shipment Test to 80 psig*
0-rings Quarterly Test to 167 psig*
0-rings Annually Test to 1006 psig*
Inner Containment Vessel Quarterly Test to 250 psig*
Cavity Relief Valve Annually Test at set point Cavity Rupture Disc Annually Replace Neutron Shield Tank Rupture Disc Annually Replace Impact Limiters Annually Test for leakage
- There must be no visual (pressure gauge) indications of pressure drop for the component under test during a 10-minute test period.
Otherwise, corrective action must be taken and the test repeated until such time as the component meets the specified test.
(Test to pressures equal to or greater than those indic.ated.)
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- Fage 6 - Certificate No. 6698 - Revision No.15 - Docket No. 71-6698 15.
(a) The containment vessel (cavity) dimension of each cash will be measured prior to the first shipment of irradiated fuel after December 12, 1979, and at intervals not exceeding twelve (12) months thereafter.
Should a cask be removed from
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service, the cavity will be. remeasured prior to the next shipment of irradiated fuel if the previous cavity measurements were made more than twelve (12) months -
prior to the shipment.
(b) Cavity measure.ments will be accomplished using six (6) calibrated guages mounted on a six (6) anned fixture movable over the length of the cavity. The gauges are mounted and oriented such that " radial" measurements may be made at 30',
90',150*, 210, 270*, and 330 from a 0* point, which is the center of the center valve port.
The measurements may then be converted to diameters at azimuthal locations of 30*-210, 90*-270*, and 150*-330".
Axial locations for cavity measurements to be recorded will be nominal 4! and 12! inches from the top of the cavity and at nominal 6-inch intervals thereafter over the length of the cavity except that the axial interval between the two measurements at the bottom of the cavity shall be approximately 3 inches apart. This will result in
" radial" measurements at 29 axial locations for a tctal of 174 values.
Three consecutiv'e meastirements will be considered a cavity measurement set. The measuring equipment will be removed from the cavity and disassembled between each measurement operation to assure as well as possible that measuring equipment and set up variance are incorporated in the results.
The true cavity dimensions will be considered the average values from one or two consecutive cavity measuremt sets. All measurement that are made of the cask cavity must be included when determing a cavity measurement set (i.e., no measurement may be excluded from the sample).
(c) The cask will be considered as meeting dimensional requirements when the differer between the maximum diameter at any location in the vessel and the minimum diameter at any location in the vessel is no greater than 0.270 inches and the straightness of the inner surface along the axis at azimuthal locations of 30',
90, 150, 210 270', and 330 is within the tolerance specified in Drawing No.
E10080 Sheet 1, Rev.19.
The meaning of the straightness tolerance shall be as described in ANSI Y14.5,1973, "Dimensioning and Tolerancing."
(d) Any cask which does not meet the criteria stated in paragraph (c) above must be withdrawn from service.
(e) The cavity measurements and data reduction to arrive at true dimensions will be carried out under an NRC approved Quality Assurance Program (10 CFR 571.51).
Shipment of an " empty" cask (containing only residual internal radioactive contamin 15.
need not meet the requirements of Items 12 and 15 above.
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Page / - Certificate No. 6698 - Revision No.15 - Doc'et No. 71-6698
- 17. The package authorized by this certificate is hereby approved for use under the
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general license provisions of 10 CFR 571.12(b).
18.
Expiration date:
December 31, 1982.
REFERENCES fiuclear Fuel Services, Inc. application dated October 6,1972.
Supplements dated:
November 9,1972; January 10 and 22, February 1 i ad 28, Marcii 1,14, and 21, May 4, June 4, and July 26,1973; July 17,1974; May 4,1976; and November 9, 1977.
Nuclear Assurance Corporation supplements dated:
November 1,1974; August 13 and December 2j 1975; September 13, 1976; October 20,1977; May 25, July 18, and September 25, 1978; June 8, July 26, and October 31,1979; 'and March 3, July 3,1980 and December 1,1980.
FOR THE U.S. NUCLIAR REGULATORi C01NISSION Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety JAN 2 5193~9 Date:
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l U.S. Nuclear Regulatory Comission Transportation Certification Branch Approval Record Model No. flFS-4 Docket No. 71-6698 By application dated October 27, 1980, Nuclear Assurance Corporation requested renewal of Certification of Compliance No. 6698 for the Model No. NFS-4 packaging.
Since December 12, 1979 three casks which meet the design approved by the Comission have been authorized with certain restrictions placed on their use.
Certificate of Compliance No. 6698 has been under timely renewal in accordance with 10 CFR 52.109 since December 31, 1980.
Certificate of Compliance No. 6698 has been renewed until December 31, 1982.
This will provide time to resolve the issues raised in our letter of December 29, 1981 and for a consolidation application to be submitted at least 30 days prior to the expiration date of the Certificate.
Issues include N
resolution of the effect of deviations for casks not constructed to the design Thes~ casks are not authorized for use.
approved by the Comission.
e Conditions to the certificate have been modified or added to take into account recent operating experience.
These include a condition to assure that the cask is properly drained and prepared for shipment in the dry state.
In addition, vacuum drying and inert atmosphere is required for shipment of failed fuel, shipment of oxidized fuel is not authorized. The use of a pipe plug in the drain line has been deleted.
These conditions are to assure that the package has been properly drained and that possible oxidation of fuel b
during shipment is minimized.
Also, the cavity inspection frequency has been extended from 6 months to one year since no adverse changes to the cavity have been detected for the packages in use.
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Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety JAH 2 51939 Date:
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- (M January 28, 1982
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MD10rJJiD31 FOR:
Region III Files - LaSalle TE031:
Robert F. Uarnick, Director, Enforec:nent and Investigation Staff
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SUBJECT:
TELEPHONE CALL FROM DOUG IEGDi1E OF CHAl!EL 5 TV
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ALLEGATIONS AT LA SALLE
' Doug Intenic called on January 26, 1982 at about 2 p.m. regarding infor-nation he had been given uhile pursuing other neus stories. Doug indi-
.v cated tha source of his information was Ion,qenie indicated he would contact n anua
, an pave the way for us to contact to get specific details of the follouing allegations:
1.
lained that when they were putting in conduit, the vasn't adequate. They did not do a good job of grocn no grinding off the zinc.
2.
knows where tuo radiation monitors were supposed to ta led in the off gas building but were not actually installed.
3.
All of the regnAred heating pads in the off gas building were not installed.
4.
The ceiling (in the off gas building, I think) vas supposed to be 12 inches thick. Uhen they were drilling 8 inch anchor bolts, they penetrated the ceiling and could see sky.
5.
The fire alarm system in reactor building No. I does not ccet specifications.
A CAR was issued but.it has been written off without the uork being done. This problem was also mentioned by a second individual but the necond person vill not talk to us about it.
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.F MEMORANDUM FOR: Region III Files FRO 8 James E. Foster, Inve tigator s
SUBJECT:
TELEPEONE CONTACT RE LA SALLE ALLEGATIONS (Ref. Warnick Memo of 1/28/82)
W indicate Mat I contacted l
on February 4, 1982, at approximately 7:30 p.m.
1 u
_.ngenic the Channel 5 newscan who providedM l
name to Warnick, had not advised that E vould be contacted by Region l
III. Nevertheless was very willing to discuss E concerns with me.,
at length.
equested confidentiality.
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I discussed each point enumerated in the Warnick meno, and developed the following information:
f 1.
Conduit grounding was not properly done f'or most LaSalle construction.
During the late phase of construction, had read the grounding speci-j fication, questioned a QC inspector regarding specification requirenents, j
pointed out deficiencies, and grounding was properly performed from that point on.
Frior to that time, crews had not cicaned and copper coated conduit threads nor adequately ground off the zine conduit coatings where grounding straps were attached.gestimated that some l
807 of the installed conduit was not properly grounded (per specification, j
developed from a NDIA requirement).
I j
g 2.
In the off-gas building, there is a location where radiation sensors for Unit 1 and Unit 2 are in close proximity. This was described as bef og at the 710 foot elevation, East of An wall, between 14 and 13 line in the filter building (part of the off-gas building). The sensor that is not installed is for Unit -2.
feels that the Unit 2 sensor should be installed now, as t ie ocat on vill be radioactive and the installation difficult af ter Unit 1 is in operation.
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File No. 8208 a
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ig,n'tity of Region 11I Files-1.aSalle,
conf en 1 source 3.
stated that approximately one month ago, five heating pads were removed from the re-heat cylinders located in the off-gas building.
These re-heat cylinders are reached via an entrance on the 710' elevation, and then by going down two elevations. The heatin ads were removed to allow some work being performed by^ fitters, and believes that the pads were not replaced when the area was " closed up.
4.
11 oles drilled for expansion anchors in the ceiling of the off-gas building (725 foot elevation) penetrated the concrete and asphalt roof covering.
There wa's water accumulation on the roof, and water came in via the anchor bolts. There'are cracks in the concrete between holes because the holes were drilled o close to each other.
This was brought to the attention of from Sargent & Lundy, and some, patching was performed.
5.
The fire detector modules have been wired without regard to separation criteria. The crews were viring the detectors from any hanger indis-criminately.
6.
Dust protection was not installed on conduits and conduit boxes as specified for dust protection. Scme have seal gaskets but no o-rings.
hobserved this during installation of the security system viring, and the required seals were installed af tergbrought this to the
~
attention of In addition to the abov information-( ich e an on that provided by Doug Longenie),
indicated that as in charge of an area which had noncontormances written on some o e equipment, but the work was not corrected as indicated in the nonconformance report close-out.
had the nonconformances approved as completed when the regular inspector was absent.
%also indicated that some core-drill sheets were found to have information which had been whited-out.
(This may be related to the TV-5 story "drillin for dollars" which aired on the 10 o' clock news, February 4,1982.
stated that 1.ongenie had advisedEthat the story would air that evening.
m4 M James E. Foster Investigator DO NOT DISCLOSE Contains identity 01 confidential source e
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confidential sourca February 26, 1982
( F XEMORANDUM FOR: Region III Files - LaSalle
" ~
- lTU'.D:
Robert F. Warnick, Director, Enforcement and Investigation I
Staff FROM:
C. A. Phillip, Investigator
~
SUPJECT:
TELEPHONE CONT 1CT FROM MRS. JUDITH COODIE, ATIORNEY,
~
ILLINDIS ATTORNEY CENERAL'S OFFICE On February 22, 1982 I was informed that Mrs. Judith Coodie, an attorney.
in the Illinois Attorney Gener
's office 2-793-2491), had called concerning allegations made by via TV Channel 5 reporter Doug Longenic.
Information rigar ng t ese 11egations is contained in two nemoranda to Region III Files, one prepared by R. F. Warnick dated January 28, 1982, and the other prepared by J. E. Foster dated February 10, 1982.
Before speaking with Mrs. Goodie I attempted to obtain additional infor-nation regarding the allegations a~nd any action we had taken or planned to tale. The follo.iing information was obtained, prinarily through discussions with Roger Walker, regarding the items listed in the above ceroranda.
1.
Conduit grounding is an industrial safety not a nuclear safety concern and therefore need not be pursued by NRC.
2.
Since it is not known whether Unit 2 vill be built, the NRC cannot force the licensee to take action to install a Unit 2 sensor.
3.
The absence of the heating pads would become apparent during pre--op testing.
This is a radiation safety concern.
In all likelihood tbc licensee has a means of tracking this matter to assure that the pads are replaced.
We could with little effort confirm this.
h4.
This natter is not of concern to NRC since this structure is not considered safety reinted, i.e. subject to seismic considerations.
5.
No additional information obtained.
6.
No additional infornation obtained.
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DO NOT DISCLOSE b
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Region III Files -
aSalle -
February 26, 1982 During a telef aic conversation with Coodie on February 23, 1982, I discussed the above with her and indicated we were evaluating the allegations to decide what action we would take.
She indicated she would call Foster or me on March 1 or 2 to find out what we planned to do.
Goodie indicated she had talked with and asked whetherllllhad made an allegation during our contacts uit regarding the drilling into rebarwhichjl((saidhadoccurredduringt.heearlystagesofconstruction.
~
I indicated that I was unaware of that allegation but that it would be of interest to us.
Following my conversation with Mrs. Goodie I was advised by Walker that the laSalle Resident Inspector had determined tha,t the heating pad removal vas documented on Pre-operational Deficiency No. 402 and they were required to be replaced prior to fuel load.
Regarding Items 5 and 6, Ron Cardner advised that we.do n'ot inspect security equipment wiring.
I believe it is NRC?s poi $ tion that security equipment must function as required by the liepnses's security plan commitments and if they fail compensatory mea 7ures must be taken until they are repaired and operational.
'l'i the basis of th above
. appears that there is no need to further h
pursue the matters has brought to our attention.
This should, be conveyed te at t s same time we should attempt to determine whetherl((]has inf ormation regarding the drilling into rebar that warrants further action.
"~
Gerald A. Phillip Investigator cc:
R. Walker J. Creed R. Cardner l
J. Foster l
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l DO NOT DISCLOSE Contains identity of confidential source i
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Region III Files THRU:
Robert F. L'arnick, Director Enforcement and Investigation Staff FROi!:
James E. Fuster, Investigator
SUBJECT:
ALLEGATION RE REBAR CUTTING AT LA SALLE, DOCKET NO.50-373 (REF. PHILLIP MD10 OF 2/26/82) i On March 6 and 8,1982, I was contacted by Ms. Judith Coodie, of the Illinois Att n
Cencral' Office.
She indicated that she had been in contact with gardin allegations concerning work E t the LaSalle site.
Ms. Goodie indicated tom er t had often cut reinforcement bars (rebar
.w en drillin cores or es at LaSalle.
She also indicated she felt that concerns regarding equipment in the off-gas building should not e
1smissed, as some equipment in the building was intended to reduce or mitigate radioactive releases during an accident.
I advised Ms. Goodie that ad not made any allega_tions to me regardi_nE_ cutting _of rch. uring _ourJrevious conversations, and I would t% recontactMI also advised tEati~ th'e71f-gas bB1 ding was a no7 safety, non-siesmic structure, and as such should not contain safety ^
_related equipment (NRC definition of saf ety-reTiteT).
She inl itatEd she had talked to " nuclear experts" who had advised her differently.
I recontacted at approximately 9:18 p.m.
on March 8, 1982.
E stated tha up until a roximately a year and a half ago (September 19807) when hit a rebar during core drilling, a special crew was called. This crew operated a special, water cooled, diamond drill rig, which would cut the rebar.
This was referred to as a " wet hole" due to the water cooling, and the utility was billed for the extra work entailed
_ (crew, diamond drill use, laborers to cican up the water).
indicated worked in the reactot_ building _and in the of1-gas building, but the problem wa P g NerEc" to LaSalle, as other crews also followed the same practice in other areas.
stated that a notice (" work notice") was finally put out by Quality Control stopping the uncontrolled cutting.
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I inquired if any present worker would be abic to provide ion III vith additional inforuation, and indicated that a nay still be onsite, and may be a e to provide additional ~
ornat on an locations of cut rebar.
It appears that the allegation can be checked by a review of billing records for core drilling.
Those with additinnal charges for the diamond drill crew should provide locations where reinforcement bars were cut by the drilling.
It should also be relatively easy tio locate a work notice inforning the creus that uncontrolled rebar cutting was to stop.
' As the LaSalle plant vill be ready for operating license issuance in the I
near future, I reco:= cad that this issue receive priority attention.
j James E. Foster Investigator cc:
L. Spessard R. Usiker R.- Cardner C. E. Norelius O
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i'!? ' Of fice of Nuclear Reactor Regulation (N O
Mr. Anthony Bournia
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Wachington, D.C.
20555 i
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Dear Mr. Bournia:
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This letter will confirm our telephone conversation
'~2 of this morning.
I called you to inquire when you antici-pated that fuc1 loading would begin at Co:monwealth Edison Cornpany's LaSalle Cou'nty Nuclear Station Unit 1.
You informed'me that.a meeting is. scheduled for March 19, 1982 to determine the fuel loading date.
You also advised that the company projects a date between March 21 and March 31,
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1902,_whereas the NRC is suggesting.May'1, 1982, plus or minus 2 wooks. 'It . -- n
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.J informed._you that the Illinois... Attorney _ General's
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Offico recently Icarned that during construction of the
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QS'ille County Station; it was a co5 mon p~r'a'ctice in con "
nection with the inctal_Lation _of electrical _e_quipment; for fi61~es in the concrete structure to be drilled through
~concrete reinforcement or "rebar" D en rebar was contacted.
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We believe.this practice continued for at least 1 to 2
'.; years.g e J.?T'?:'.: p!&.YQSyg.'..:!..,*Z3;-~F2'..*
T I~ told you that I had related this information to r
James roster at the NRC Region III Office of Inspection and Enforcement, and that he was going to write up a report on his investigation.,
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Mr. Anthony Bournia; I
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tre believe you would want to be aware of our concern regarding any potential safety problem due to the rebar r
cutting in advance of your meeting with the company.
The company is also aware of our concern.
I, Thank you for your cooperation.
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- y Very truly yours,
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f,*r$t U JUDITH S. GOODIE
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Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 r.
Chicago, Illino.is 60601 (312) 793-2491.;
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TYRONE C. FAHNER ATTORNEY GENERAL STATE Or ILLINOIS 160 NORTH LA S ALLE STREET 7ELEPHoNC cHicAce suoi
-2500 EXPRESS MAIL March 24, 1982 Secretary, U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Chief Docketing and Service Section Re:
Request to Institute A Show Cause Proceeding and for Other Relief Commonwealth Edison Company Docket Nos. 50-373, 50-374
Dear Sir:
find enclosed an original and 3 copies of Request Please To Institute A Show Cause Proceeding and for Other Relief for Please file filing with the Nuclear Regulatory Commission.
- 2. 708 (d).
the original and 2 copies as required by 10 C.F.R.
Please stamp the third copy as " filed" and return it to this office in the enclosed self-addressed stamped envelope.
Very truly yours, JUDITH S.
GOODIE Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 l
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Enclosures
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UNITED STATE OF AMERICA NUCLEAR REGULATORY COMMISSION F
)
In the Matter of
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos. 50-373 and
)
LaSalle County Nuclear
)
50-374 Generating Station, Unit 1
)
and Unit 2
)
REQUEST TO INSTITUTE A SHOW CAUSE PROCEEDING AND FOR OTHER RELIEF The People of the State of Illinois (Illinois), by TYRONE C. FAHNER, Attorney General of the State of Illinois, pursuant to the Atomic Energy Act and 10 C.F.R. 52.206, hereby requests the United States Nuclear Regulatory Commission (Com-mission), or the Director of Nuclear Reactor Regulation, to institute a proceeding pursuant to 10 C.F.R.
S2.202, to suspend operating license proceedings and for other appropriate relief, in light of newly discovered safety issues.
I.
PROCEDURAL BACKGROUND Commonwealth Edison Company (Edison) has been authorized by Construction Permit Nos. CPPR-99 and CPPR-100 to build the LaSalle i
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County, Illinois Nuclear Station consisting of two generating units, Unit 1 and Unit 2.
Construction has been ongoing since 1974 or earlier.
The construction of Unit 1 is substantially complete.
Unit 1 is scheduled for commercial service in September, 1982.
Unit 2 is scheduled for completion in October, 1983.
Operating license proceedings for Unit 1, Docket No. 50-573; and Unit 2, Docket No. 50-374, are pending before the Commission.
Illinois is informed that no hearing has been requested or noticed in said operating license proceedings.
Illinois is also informed that Edison has advised the Office of Nuclear Reactor Regulation that it is ready to obtain an ocer-ating license for fuel loading and low power testing of Unit 1, pursuant to 10 C.F.R. S2.764 (b), (f).*
II.
STATEMENT OF FACTS 1.
Several of the buildings which comprise LaSalle Station Units 1 and 2, including the reactor buildings, are physically connected to each other.
In some instances a single building houses equipment which serves both units.
Therefore the con-struction practices which are the subject of this Request to Institute a Proceeding (Request), and which are more fully des-cribed below, relate to Unit 1 and to Unit 2.
- On March 2, 1982 Robert J.
Schultz, a vice president of Edison, stated that Edison expected to load nuclear fuel and to begin low power testing wit;.in 30 to 40 days.
Ill. Commerce Commission Docket No. 82-0026, report of proceedings, p.370.
2.
During the installation of electrical conduit and other equipment in Units 1 and 2, as in nuclear power plants in general, thousands of holas were drilled into the reinforced concrete structures of the plant.
Reinforced concrete contains numerous reinforcing steel bars which add strength to the con-crete structure.
The steel is commonly called "rebar."
The holes have two general functions.
Large holes, up to 8 inches in diameter, and ranging from 1 to 7 feet in depth, were drilled through walls and floors to carry conduit from one room or building to another.
Small holes, up to 3/4 inch in diameter and up to 6 inches deep, are used to mount the hardware from which conduit, cable trays and other equipment are suspended on walls and ceilings in the plant.
Anchor bolts are inserted into the small holes to support brackets which hold the equipment.
3.
In February, 1982, it came to the attention of the Office of the Attorney General of Illinois that during the construction of Units 1 and 2, certain practices related to the drilling of l
holes in the concrete walls, floors and ceilings of the Unit 1 and 2 buildings have created a potentially hazardous condition which, upon the operation of either unit at full power, may be injurious to the public health and safety.
A.
These practices are generally described as follows.
From the beginning of the construction work associated with the installation of electrical
equipment, at least a,s early as 1978, until the end of 1979, holes in the reinforced concrete walls, floors, and ceilings of the reactor buildings and other build-ings were, as a matter of course, drilled through the reinforcing steel or rebar.
Depending upon the size of the hole and the thickness of the re'bar, this drilling practice may damage or completely sever one or more lengths of rebar, or cut chunks out of the rebar.
B.
The affidavit o a driller who worked at the LaSalle County construction site during the years'1978, 79, and 80, is attached to this Request as Exhibit 1 and it incorporated hNrein by reference.
vit explains in greater detail the drilling practices alleged herei'n.
4.
An unknown number of drilled holes, ranging in the order of thousands, are likely to have been cut through steel reinforce-ment in the concrete walls of safety related buildings, including the reactor buildings.
A)(Mough Illinois does not have access to Edison's records which document these drilling practices, it understands from the affidavit of uch records were made at the time the alleged practices occurred.
These records, or drill sheet _s, are essential to the Commission's.
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determination of the extent
)
to which steel reinforcement was i
damaged or severed in the concrete structu during construction.
re of Units 1 and 2 in Edison's possession or controi'The records are be The Commission has access to drill sheets, engineering plans, and other construction records, pursuant to 10 C.F.R. S50. 70 (a) and 42 U.S.C.
S2232 (a).
5.
According to s af fidavit, the practice of drilling through rebar was discontinued, or subjected to the case by case approval of an engineer 1979 or early 1980.
some time in late Illinois has no information which suggests that any engineerin g proval was ever obt ained._from_. Edis.o.n ',s engineering consultants for the rebar cutting which occbrred prior to 1980.
m 6.
The removal, damaging, or severance of unknown amounts of reinforcing steel in the walls of the reactor buildings and other related structures presents a substantial health and safety issue which requires the immediate attention of the Commission.
Attached to this Request as Exhibit 2 is the davit of Dale Bridenbaugh, an expert affi-plant construction.
in the field of nuclear According to Mr. Bridenbaugh, the practice of cutting through reinforcing steel should be th 1
oroughly
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investigated prior to plant operation.
He states that if the rebar was damaged or severed without appropriate structural F
analysis, and if the drilling practice was widespread, "it
.seems nearly certain that some safety-related structures.
would have been affected."
(Exhibit 2, at 3-4) Mr. Bridenbaugh explains that the potential consequence of degradation in 4
structural quality is the " failure of the structures and/or systems to perform their safety related functions under accident or seismic conditions."
(Exhibit 2 at 5)
He recommends that any repairs which may be required to remedy structural degra-dation be made before the safety systems are called upon to prevent or mitigate the consequences of an accider.t.
7.
A second type of structural deficiency at LaSalle Station has come to the attention of Illinois.
The off-gas building is !
\\
a structure which serves Units 1 and 2.
A former construction i
foreman, whose identity is being kept confidential by the Region III staff, had told Region III that the concrete. ceiling or roof of the off-gas building was actually only 8 inches thick f
even though the specifications called for this roof to be 12 inches thick.
Illinois is also informed that a transformer sits atop this roof, and that the concrete has cracked substantially due to the number of anchor bolt holes drilled in,it.
The
~
6 affidavit of Dale Bridenbaugh states that the off-gas building houses equipment containing radioactive gases. (Exhibit 2 at 4)
F The off-gas building also contains monitoring equipment for measuring radiation levels in the building.
The inadequate thick-ness and cracked concrete of the roof on the off-gas building, the presence of anchor bolt holes which may have been drilled through rebar in the concrete roof, and the presence of a heavy transformer on top of this roof, raise a question of possible damage to the equipment housed in the off-gas building in the event the roof or ceiling should fail.
8.
In view of the substantial health and safety issues presented in this Request and in the affidavits attached hereto, the loading of nuclear fuel into the reactor building of Unit 1 is inadvisable at this time.
The affidavit of Dale Bridenbaugh attests to the reasons why fuel loading should be postponed.
(Exhibit 2 at 5)
The presence of nuclear fuel severely limits the ability of investigating personnel to perform the necessary investigation, by making access to some portions of the plant either extremely difficult or impossible.
Until the Commission fully examines the potential safety hazard presented by the cut-ting of reinforcing steel as alleged herein, it will not be known whether corrective measures will be needed to ensure the struc-tural integrity and safety of Units 1 and 2.
The presence of
. nuclear fuel within the structure of Unit 1 will make more diffi-cult not only the investigation itself, but also the performance._
of any corrective measures which may be ordered by the Commission for Units 1 and 2.
F 9.
Illinois has not previously been a party to any proceeding concerning the licensing of the LaSalle County Nuclear Station.
The facts alleged in this Request which create a substantial issue of health and safety were not known to the Requestor Illinois until February, 1982.
Thus it is only now that the Attorney General of Illinois finds it necessary tc seek the relief requested herein.
The continued protection of the health and safety of the People of Illinois requires that the questions raised by this Request be fully resolved before the Commission authorizes the operation, at low power or at full power, of Units 1 and 2.
III.
REQUESTED RELIEF For the reasons set forth above, Illinois requests that the Commission institute a proceeding pursuant to 10 C.F.R. 52.202 and:
1.
Immediately suspend consideration of Edison's request for a fuel loading and low power testing license at Unit i until the Commission investigates the alle-gations contained in this Request and decides,whether to institute a show cause proceeding.
f 2.
Suspend or stay all proceedings concerning Edison's applications for operating licenses for the LaSalle County Nuclear Station Units 1 and 2, includ-1 ing ir. particular consideration of the granting of authority to begin fuel loading and low power testing, until the Commission investigates the structural inte-grity of the LaSalle Station and determines the extent to which corrective measures will be required to eliminate any potentially hazardous condition.
3.
Upon a determination by the Commission in the requested proceeding that corrective measures will be required to eliminate such hazardous condition as may be found, modify the construction permits for Units 1 and 2 accordingly.
4.
Grant a hearing in the requested proceeding and admit Illinois as a party thereto.
5.
Order such additional relief as may be appro-priate under the circumstances.
In the alternative, if the Commission chooses to consider this Request within the framework of the pending 7
operating license proceedings, the Commission is requested
.to admit Illinois as a party to such proceedings (Decket Sos. 50-373 and 50-374) and grant a hearing therein limited to the matters raised in this request.
Respectfully submitted, PEOPLE OF THE STATE OF ILLINOIS
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BQ-O.ONE C.
FAh W torney General of Illinois Of Counsel PHILIP C. PARENTI Chief, Environmental Control Division JUDITH S. GOODIE Assistant Attorneys General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 Dated:
March 24, 1982
[
STATE OF ILLINOIS
)
)
SS.
COUNTY OF LASALLE
)
r' AFFIDAVIT being fully sworn and under oath do state:
I, Illinois.
I was I reside at dison LaSalle County employed as a core driller at the Commonwealth E 1978 until
- June, nuclear plant construction site from approximately July, 1980 1978 until about February 1980 my employer was From about June, My duties were the Commercial Concrete Sawing and Drilling Company.
I drilled holes ranging in diameter drilling of holes in concrete.
I also drilled from 1/4" to 3/4" with a small hand drilling machine.
to 8",
with a large ranging in diameter f rom 1-1/2" larger holes, for Anchor bolts for the small holes were used boring machine.
The and other electrical _e_quipment.
cable trayA hanging conduit, through walls and floors.
large holes were used to carry conduit all elevations, at I performed core drilling in all buildings, including the reactor buildings for Units
- site, throughout the plant of the year 1979, my partner and I were 1 and 2.
During most We drilled at all dings.
assigned primarily to the two reactor buil During the time o,f my employ-elevations in the reactor buildings.
illing, I received my ment with Commercial Concrete sawing and Dr Exhibit 1
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- foremen, 111ing instructions orally from my11y work was observed Y
t by i
.mmercial Concrete emp o neral contractor, Foley Electr -
l yee.
superintendent employed by the ge 99 y
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a til t LaSalle in June,1978 un al C o..
From the time I began drilling ait was the usual p tacting 80, lbout February, 19 b r during core drilling, to and to metal reinforcement or re aI was instructed to fo his practice, g the the metal rebar.
it was the general practice amon Q4a 'I d
the best of my knowledge, were instructed to stop an "E
Y"#"
Occasionally we But during most of
,a other core drillers.when metal was contacted.
Sen) f' s
tw relocate the holes cut through the metal.
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the time period, we g
dk i g sizes:
3q Small holes were of the follow n Geoth (inches)
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4 (inches)
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Diameter 1-1/4 1/4 44-1/2 3/8 1/2 5
S/8 6
3/4 with dianeters drilling small holesdrill", which was When rebar was contacted inchanged to the larger " w wet drill The of 1/2 to 3/4 inches, we water spray.
bit and a contacted a boring drill with a carbon When rebar was d 3/8 inch holes.
My partner d the holes.
was too large for 1/4 ansmallest holes, we relocate We con,tacted and in drilling these of small holes per week.
and I drilled hundreds l l
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During the than 1/4 of those holes.
kd
<f cut through rebar in less all hole cut through rebar was mar e lattor#part of 1979, each smunable to estimate the number of I am a felt pen.
with paint or robar " cuts more precisely. i; diameter from 1-1/2 inc a
Large holes, ranging The depths of the large ing machine.
all cut with the large bor walls, floors, or ceilings h
equalled the thicknes of t eand ranged from about 1 foot to waro holes un cut, with dia-les through which the ho hmeters, the bits were carbon For the largest core drillers were 1978-79, During my ephyment in ted during the 6 feet.
mond chips.
throug rebar when it was contac failed to contact rebar with cut instructed to of larce holes.We seldomhinc.My partner and ctice; d illi Until the large boring mac did also.
) sledge the other drillers ws re drilled and to the best of mybelFihat all o<
.-g> e large holes we end of 1919, I
[oyees.
the by Commercial Concrete,r-reactor buildings for during
~
When I worked in walls between the two re-klesa through the M reactor and the off-gas building, and drilled large hMWwn 1979, I were Large holes actor buildings, Meane auxilliary building.
When rebar reactor ncrete.
between the of aboufoot per hour through co rate cut at a longer.
contacted and cut tookbe drilled were lai,d out by was The locations fc holes toto the best of my knowledge m l
of Foley Elc.
i employees U
e detecrors were not used during the first 7-8 monhhs of my emplov-ment for locating the holes.
A Quality Assurance inspectorjt]a;_
spected my work beginning several months af ter I__ started working.
?
" I can recall two specific incidents concerning the drilling i
of large holes through metal rebar.
On one occasion I drilled a' 6" diameter hole through rebar in the reactor building of Unit 1, at an elevation below 710'.
It was at a place where all the steel tied together, and I removed about 25-40 pounds of steel.
It took me 2 or 3 days to drill this holes cted me to keep drilling this hole, and he added, "If you can't do it, we'll
[
get someone who can."
On a second occasion I drilled a 7" diameter hole in the re-actor building of Unit 1 at elevation 73,5.
I hit the 2" rebar, and I asked
- )c as I continued to drill the rebar was splitting.
- esaid, "No."
That and if I could relocate the hole.
hole was drill'ed to a depth of 6 to 7 feet, where we hit a beam inI This hole was the floor of a room where steam pipes were located.
l.
l' because it was improperly locatedi later grouted in, a wri_t w aport, or dril3 sheet, on each hole We filled out r
we drilled for both small and large holes.
The reports showed the location, depth, and diameter of each hole.
They also showed(
~
whether rebar was contacted or cut.
_a_
on sick leave.
out From November 1979 to February 1980 I was 980 I worked as a core
[
When I returned to the site in February 1 During this time h
1980.
driller for Foley Electrical Co. until July We were i,
were changed.
b period the procedures for contacting re ar and as contacted,
~
instructed to relocate small holes when rebar wh the rebar e
we were only allowed to cut throug h hole drilled Written reports were also made of eac by an engineer.
I stopped working at the LaSalle plant as during this time period.
because of an injury.
of July 31, 1980, i
SUBSCRIBED AND SWORN TO
/ -'- DAY BEFORE ME THIS
_1982.
OF _ W..
/
~Nl
. s. _.LJ / y,mO[
Notary Public e
_-.----,--.,m.
t AFFIDAVIT OF DALE G. 3RIDEN3AUGH
,f' I'.
2;.
)
3.' STATE OF CALIFORNIA
)
ss..
)
4h COUNTY OF SANTA CLARA I
l d
5ii deposes and says DALE G. BRIDENBAUGH, being duly sworn, 6
a 7]asfollows:I am a Professional Nuclear Engineer, technical 8d 1.
of MH3 Technical and a founder and president O
consultant, i
- ent, 10j Associates, technical consultants on energy a Suite K, San Jose, 1723 Hamilton Avenue, 11!! with offices atI have participated as an ex:ert witness in i California.
12ll!
l tory 13lj licensing proceedings before the U.S. Nuclear lie NRC; 74ll Commission (NRC); have served as a consultant to t the request of the Advisory Committee on l'
15ilhavetestifiedat16h Reactor Safeguar ittees i
f the U.S. Congress and testified in various state licens ng 17 1: and regulatory proceedings.
h I am a graduate engineer thoroughly familiar wit 73[i ion of nuclear generating 2.
/ 79 the design, construction, and operat 1
and system 20' including operational errors, equipment could lead to adverse safety l
21h P ants,f ailures, and other problems tha i
22 23h and reliability consequences. Engineeri d Technology 24 h
state of Cali-25[ in 1953, and have since been registered in t e Further details 2G!i rnia as a Professional Nuclear Engineer.
'l f
AG/3 i
Exhibit 2.
1 '. of my experience and qualifications are contained in my resume, 2d Attachment 1.
I is to identify my 3 ".,
3.
The purpose of this Af fidavit 4!! concerns regarding the adequady and quality of construction p
5j of certain structures which make up an essential portion of I have Gi: commonwealth Edison Company's LaSalle Nuclear Plant.
C which describes 7 reviewed the Affidavit.of
.I I numerous cases of anchor bolt ole rilling and condui_t
~
SlT) drilling _in the LaSalle Units 1 and 2 reactor
(
g jFpa s s a geway core 1978 through July, 1980.
10j, buildings during the period of June,
fidavit, such drillin'g 13 If, as is reported in reinforcing steel in concrete walls was j2[ was conducted so that the benefit of 13.l damaged and/or completely severed without this would appear to me-to 14;l appropriate structural analysis,
15l',be a condition with potential safety significance and one that Y
LaSalle prior to plant 16; should be thoroughly investigated at 77[ ope ra tion.
I have no way of knowing whether the reported practice 18lt 4.
19.j has in fact jeopardized safety-related structures as I do not li locations of the holes that were drilled 20 'have access to the exact 4 Affidavit, however, indicates that such drilling 21 l the~
22, practices were " usual" with the associated implication that 23l practice was in common use by a large number of electr l
If the practice.was widespread 24', working throughout the plant.
during this time period, it seems near13 t-25;j and used by all drillers si some safety-related structures fthose associated.
26llcertain that l'
i.
'I '
I with systems or components assuring the integrity of the if 24 reactor coolant.oressure boundarv. or those necessarv. to 3;i maintain the capability to shut down the reactor and maintain.
84!!it in a safe shutdown condition, or those needed to prevent
!I 5" or mitigate the consequences of accidents which could result Gj in potential off-site exposures) would have been affected.
- I 7 ' If so, the associated damage or degradation of safety margins S. of safety-related structures would appear to have violated I
9[ the quality requirements imposed by the U.S. Code of Federal i
10j Regulation, 10 CFR Part 50, Appendix A, General Design Criteria i
11' for Nuclear Power Plants and Appendix B, Quality Assurance 12; Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
I 13'l It is also possible, if the practice was widespread to the
.ii 140 extent that it also was used in the attachment of components 15 and equipment to the primary containment structure, that the structure could be affected.
The LaSalle 16,l integrity of that I
37 ; Nuclear Plant configuration includes a Mark II concrete e nt inment structure designed to contain and mitigate the 18; I
39 consequences of design-basis accidents that could occur during 20 the operation of the plant.
The U.S. NRC reviews the 21, adequacy of this containment to assure its compliance with 22j federal regulations.
Standard Review Plan 3.8.1, Concrete 1
33, Containment, discusses the points normally covered by the 1
2p NRC in such review.
The impact of the drilling' operations i
25' described in W Affidavit would be relevant 2Ght the review conducted in accordance with Part II.6, I
ll ll -
4
- - - - - ~ ~
I!Page 3.8.1-14, which covers materials, quality control, and I
23 special construction techniques of concrete containment.
l 3lIThe concepts expressed _.in this Review Plan applying to conc:
c-q 4p containment would also aoply to the structural integrity of 5j other concrete safety-related walls and structures.
6[
5.
I have been informed that some of the facts contail 7l in
-HAffidavit have been verbally communicated i
8D to the U.S. Nuclear Regulatory Commission as called for in i
Di 10 CFR Part 21 (U.S. Code of Federal Regulations), but that r
10I investigation has yet been reported.
I have also been info 1-10 that the U.S. NRC has been verb:11y informed (by an unident i
12! employee) that the concrete roof slab making up the ceiling i
13! the LaSalle off gas building is below specified thickness a 14h{ contains numerous holes and cracks.
I have further been II 15', informed that the NRC's response to the report of this 16] condition was that no investigation of this condition was 17 warranted.
While it is not likely that failure of the off i
in a " calamitous" accident, 18j. g s building roof would result it does contain equipment and components handling radioacti 39 20' gases.
The primary significance, however, of the reported failure to investigate this condition by the NRC is the 21; 22 question that it raises as to the effica_cy_.of the entire i
23l.qu lity g ersicht function conducted by h NRC_on the Plant.
This question 24J vera11 construction of the LaSalle urgent the necessity to resolve the reported i
25hmakesmore 26 /////
I e
ki
!! {
m 4
in the reactor building (and l' deficiencies that may exist
<f 2.fotherstructures). action to investigate these concern s is 1
6.
Prompt the LaSalle Unit 3:.
is my understanding that d
It d which would permit 4,.important.
I 5;. operating License is about to be issue d initial operation
- l 6!jthe loading of fuel into the reactor an likely to change U
While fuel loading in itself is not lly affected structures 7 to begin.
8:o,the loading conditions of the potentia h
fuel loading does so that a failure, would be expected,is of significanc 9
in time that 10;irepresent a point ion that may be required.
ti 13ll proper conduct of the investigat wer operation is possible, i
12{ When fuel loading occurs and low po including portions of l
t 13] access to certain areas of the p an,and reac controlled h
74 primary containment from compartment to ent 15 land/or minimized and the free movemnn t*
16j compartment by investigatory persohe reactor cou i'
17] Subsequent power operation of t least ible or at D
73:IIextremely limited.
f the structural The consequences of the degradatio 39 7.
20[
21,hl quality p tentially representewalls is the of the l
l steel in the concrete their safety related f
structures and/or systems to per orm In my opinion 22 l
i conditions.
uncti ns under accident or seism ca thoroug 23 by the 24 This woul h
is essential that f the allegations raised.
hit 95 8PPropriate authorities o l
-U 26
'l 3
l"i l
r
- I 1
Ijassurethat damage to the essential structures, if it in fact 2j exists, has been properly analy:ed by appropriate technical
.f 3'i experts and repairs or modifications are.iade if needed before
.I 4[ these safety systems are cal' led upon to prevent or mitigate 5;
the consequences of an accident.
6;f I'
7I I
8ll
')
H
/
gy Dale G. Bridenbaugh n
10l,. March 17, i
1982 Illl Subscribed and sworn to before i
12!!methis /7 day of[//78C[ 1982.
13;!
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commission expires:
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ENIATCg OF 3A_I G.
P ROFE S SIO" AL 0*: A*_~ FI C A!!CN S
,f DALE G. 3 RIDEN3 AUGH 17 2 3 H a=11 ton Av enue Suite K 95125 CA S an Jo se, a
('03) 266-2716 1
EX?IRIENCE:
197 6 - P RESENT S an J o s e,
Specialists Technical Associates, cons ult in g interested fir =.
- MH3 technical groups Consultant
? resident
_Co-founder and partner ofgovernmental and othersafety and licensing.N Illi-to in energy consultingevaluation of nuclear plantagencies in Calif ornia, and to the Oklahoma and MinnesotaSwedish N state inin this capacity to i
nois, N ew Jers ey, P ennsylvan a, Nuclear Power Committee, P er-and environmental group s.f or S and various o ther organizations Norvegian Review of d S cientis t's analysis fety !sprove=ent f ormed extensive saf ety the Union of Concernet o th e U. S. N RC - LU the contributed to and the Depart-Consultant Analysis of Spen:
and contributed,tof or S andia Labora-W ASH-14 00.performed Cost N atural Resources Def ens e Council,of Energy LW
- Program, t Program and s tate utility Served as expert mest cories.
co= mission hearings.
197 6 - ( FEB RU ARY - AUGUS T)
Survival, Palo Alto, in Project ca=paigns Consultant, itiative Nu=arous work on Nuclear S af eguards In and Colorado.
- o d alternativ e ' energy op tion sres
- Arizona, Volunteer O re g on, W as hin g ton,
presentations on nuclear power an California, Also and college groups. and television.
civic, government, presentations on radio public service General ElecELL:
1973 1976 and I mp r ov emen t, Calif ornia.
Manager, P erf ormance Evaluation S an Jose, Division.
- Nuclear Enertv n clerical personnel with l
yompany of systems to Managed seventeen technical and seveand management and systes responsibility f or es tablishment Water Reactor equipment resources 1
Integrated General Electric and measure 3 oiling of cause coordina:ed corree:ionimprov
=onitor operational performance.modif ications,
in customer plan t to efforts of forced outages and of of 3WR systems.
formance
f an c e 197 6 (Contd) of Division Master P er ormspecial assign-ff for the Resp on sible f or developmentwell as for numerous Scaon special assignment f olve j
Improvementlong-range studies. ad hoc projects formed to res Plan as Was ments on of two different managementtechnical problems.
unique Nuclear 8
1973 General Electric Company I
- Service, California.
Mannter, P roduct S an J o s e,
clerical personnel.l of twenty-one technical aninterface and liaison personne
- Division, d four Enarty warranties.
required under contractperformance direct Managed group to Prime responsibility wasactions d service planning, supporting all com-corrective functions General involved incharge of refueling an communicationower reactors supplied byny, I taly, J ap an,
Also in and service
- analysis, and overseas (Spain, Germa plated commercial nuclear p both domestic India, and Switzerland).
- Electric, Nuclear Energy 1968 1972 General Electric Company
- Service, Product California.
h the d six clerical personnel wit
- Manager, S an J ose,
execution planning andd ep ar tment-
- Division, Managed sixteen technical anfor all customercustomer acceptance
- contact, sale r e s p ons ibility he This volume of work required after t ipmen t.
Sales 972.
and renewal parts.1968 to over S3,000,000 in 1 supplied plants and/or equ and delivery of sparaincreas ed f rom' $1,000,000 in Gener al Electric Comoany -
1966 1968 and W arranty Califor g.
S erv ic e,
Comolaint S an JosL for customer
- Manager, Divi s ion,
with the responsibilityof work required af te tomer Nuclear Energy Managed group of six persons and executionsupplied plants and/or equ p contacts, planning accep tance of dep ar tment-domestic and overseas.
Installation
- Comoany, 1963 1966 Supervisor, General ElectricLos Angeles, California.
Department.
with responsi-Tield Engineering and Service Engineering l tion and field representativesand gas turbine inst of i ht Supervised approximately e g Arizona,for the installationunits, plus steam bility f or General Electricwork in S outhern Calif orn ia, res pons ible s team turbine generatorcontact, prepa-main ten anc eDuring this period was Nevada.
central stationWork included cus tomer different ac tiv ity.
n e go,t iation s.
eight much maintenance and contract ration of quotations,,
1956 - 1963 i
Field Engineer, Gene ral Elec tric Company. Installation and Service Engineering Department, Chicago, Illinois.
Supervised installation and main ten ance o f steam turbines o f a L1 s ize s.
Supervised crews of from ten to core than one hundred =en, depending on the j ob.
Worked primarily with large utilities but had significant work with steel, petroleum and other process industries.
Had four years of experience at construction, s t a r tu.p,
trouble-shooting and refueling of the first large-scale commercial nuclear power unit.
1955 - 1956 En g in e e rin g Training Program, General Electric Co=pany, Erie, Pennsylvania, and Schenectady, New York.
Training assignments in plan t facilities design and in steam turbine testing at two General Electric Factory locations.
1953 - 1955 United S tates Army - Ordnance School, Aberdien, Maryland.
Instructor - Heavy Artillery Repair.
Taught classroom and shop disassembly of artillery pieces.
1953 En ginee rin g
- Trainin g Program, General Electric Company, Evendale, Oh io.
Training assignment with Aircraft Gas Turbine Department.
EDUCATION & AFFILIATIONS:
3SMI - 1953, S outh Dakota S chool of Mines and Technology, Rapid City, South Dakota, Upper k of class.
P rof es sional Nuclear Engineer - Calif ornia.
Certificate No. 0973.
Member - American Nuclear S ociety.
Various Compery Training Courses during career including Prof es-sional Bus ine.
Management, Kepner Tregoe Decision Making, Effectiv.
l Presentation, and numerous t echnical semin ars. _ _ - _ _ _
~
e HONORS &
A'a* A RDS :
S igma Tau - Honorary Engineering Fraternity.
General Managers Award, General Electric Cocpany.
F
?ERS ONAL DATI:
B orn November 20, 1931, Miller, South Dakota.
Married, three children 6'2",
190 lbs., health - excellent H on o rable discharge from United States Army Hobbias:
Skiiing, hiking, work with Cub and Boy Scout Groups.
PUB LI C ATION S & TES TIMONY :
1.
Operating and Maintenance Experience, pres'ented at Twelfth Annual S eminar f or Electric Utility Executives, Pebble Beach, California, October 1972, published in General Electric NEDC-10697, December 1972.
2.
Maintenance and In-Service Inspection, presented at IAEA Sy=posium on Experience From Operating and Fueling of Nuclear Power Plants, B ridenbaugh, Lloyd & Turner, Vienna, Austria, October, 1973.
3.
Operating and Main tenance Exp erience, presented at. Thirteenth Annual Seminar for Electric Utility Executives, P =bble B each, California, November, 1973, published in General ilectric NED0-20222, January. 1974.
4 Improving P lan t Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, Cali-fornia, November 1973, published in General Elcctric NEDO-20222, January, 1974.
5.
Application of Plant Outage Experience to Improve Plant Per-formance, B ridenbaugh and B urds all, American Power Conference, Chicago, Illinois, April 14, 1974.
6.
Nuclear Valve Testing Cuts Cost, Time, Electrical World, October, 15, 1974 7.
The Risks of Nuclear Power Reactors:
A Review. of the NRC Reactor Safety Study WASH-1400, Kendall, Hubbard, Minor &
Bridenbaugh, et al, for the Union of Conc erned S cientis ts,
August, 1977. '
3 ar s eh sek Risk.!s ses smen t,
the (Published by S a f e ty Studv:
Swedish Reactor January, 1978.-
Ds1 1978:1) 3.
Technical Associates,of Indus try as Docu=ent MH3 Swedish Department G.C. Minor to R.3. Hubbard, on Resources, Land I.
Bridenbaugh, l
Testimony of D.G.
Com=ittee the Calif ornia S tate As sembly 9.
March 5,
- 1976, Use, and Energy, and G.C.
Minor Bridenbaugh, R.,B. Hubbard, Committee on Atomic e
Testimony of D.G.the United S tates Congress, DC (Published by the Joint 10.
,before 18, 19 7 6,
'a' as hin g ton,
i February Cambridge, Union of Concerned S cientis ts,
the California Energy
- Energy, Testimony by D.G. Bridenbaugh bef ore hic Accidents entitled, Initiation of Catastropon Emergency Planning,
i Avila l
11.
Commission, Hearings 4,
1976.
Diablo Canyon, Calif ornia, November at la-B ridenbaugh bef ore the U.S. Nuclear Regu
- 3each, Perfor-Diablo Canyon Nuclear Plant Testimony by D.G.
- December, subject:and Licensing B oard Hearings,
12.
tory Commission, Atomic S af ety m an c e_,
1976.
the Calif ornia Energy Testimony by D.G. Bridenbaugh bef oreFuel Storage Considerations, Interim Spent 13.
Commission, subject:
the New Y ork S tate Public March 10, 1977.
Bridenbaugh bef ore oncerning the James-Testimony by D.G. Service Commission Siting Board Hearings c of Technical and 14.
Effect subject: _ Cost and Reliability, port Nuclear P ower S tation,on Nuclear Plant Deficiencies 4
Safety April, 1977.
the Calif ornia S tate of Pressurized Testimony by D.G. Bridenbaugh bef oreDecommissionine June 9, subject:
- Hearings, 15.
Energy Commission,Sundesert Nuclear Plant W ater Re ac t or s_,
1977.
the Calif ornia S tate Testimony by D.G. Bridenbaugh bef oreEconomic Relationshiosf or th of subject:
f 16.
Energy Commission,Sundesert Nuclear Plant, 15, 1977.
l Decommissioning, Defense Council, July State Board
' Resources he Vermont Y ankee Nuclear Plant Tes timony by D.G. B ridenb augh b ef ore tOoeration of Vermont October 6, 1977.
17.
and Safeti, l
of Health, subject:
on Public Health and Its Impact the U.S. Nuclear Regula-l Tes timony by D.G. B ridenbaugh bef oreAtomic S af ety an subjec
~
Lack 18.
l tory Commission, Evaluation Diablo Canyon Nuclear Units in S af etv l
Deficiencies Finding of Safety, of a Definitive California.
l October 18, 1977, Avila Beach, r
I
~5-l l
u,___._._,__
19.
Testi= cay by D.C. 3ridenbaugh before :he Nervegian Cc mission 1
on Nuclear ? over, su bj e c t: Reacto: S a f e:v /Ris k._0c tobe r 2 5 1977.
20.
Testimony by D.G. 3ridenbaugh before :he Louisiana 5: ate Legislature Co==1::ee on Natural Resources, subject: Nuclear Power ?lant Deficiencies I=cacting :n Safe:v & Reliabili:v, 3aton Rouge, L ouis iana, Fe}o ru a ry 13, 1975.
21.
Spen: Fuel Disposal Costs, repor: prepared by D.G. 3ridenbaugh for the Natural Resources Defense Council (NR3C), Augus: 31, 1978.
1 22.
Testisony by D.G. Bridenbaugh, G.C. Minor, and R.3.
Hubbard before the Atomic Safety and Licensing Board, in the matter of the Black Fox Nuclear Power S tation Construction ?ermit Hearings, September 25, 1978, Tulsa, Oklahoma.
23.
Testimony of D.G. Bridenbaugh and R.3. Hubbard before the Louisiana Public S ervice Commis sion, Nuclear ?lant and ?cwer Generation Costs, November 19, 1978, 3aton Rouge, Lo uis ian a.
i 21 Testisony by D.G. 3ridenbaugh before the-City Council and 1
Electric Utility Commission of Austin, Texas, Design, Con-struction, and Oserating Experience of Nuclear Generating Facilities, December 5, 1978, Austin, Texas.
i 25.
Te s timony by D. G. 3ridenbaugh for the Consonwealth of Massachusetts, Department of Public Utilities, Imoae: of Unresolved S af e ty Is sues, _ Generic De ficien cias, anf_!hree Mile Island-Initiated Modifications on ?cwer Genera: ion Cost, at the P roposed Pilg rim-2 Nuclear P lan t, June 8,
1979.
l 26.
I mo rovin g the Safety of LWR P ower P l an t s, MH3 Technical Associates, prepared for U.S.
Dept. of Energy, Sandia j
Labora:ories, S ep tember 2 8, 1979.
1 27.
3WR Pion and No zzle Cracks, MH3 Technical As so cia tes, for the S wedish Nuclear P ower Inspectorate '(SKI), October, 1979.
28.
Testimony of D.G. 3 ridenbaugh an d G. C.
Minor bef ore the Atomic S af ety and Licensing B oard, in the matter of I
Sacramento Municipal Utility District, Rancho S eco Nuclear i
Generating Station f ollowing TMI-2 acciden t, subject:
Ope ra tor Trainin g and Human Factors En g in e e rin g, for the California Energy Commission, February 11, 1980.
29.
Italian Reactor Safetv Studv:
Caorso Risk As s e s smen t, ME3 Technical As socia:es, for Friends of the Earth, I:aly, March, 1980.
30.
Decontamination of K ryo ton-8 5 from Three Mile Island Nuclear P lan t,
R.
- Kendall, R.
Follard, &
D.G. 3 r id en b au g h, et al, The Union of Con cerned S cien tis :s, delive re d to the Governor of Pennsylvania, May 15, 1980. -
31.
Decon:anination of Krveten-85 frca Thre. Mile Island Mu: lear
- Plant, H.
- Kendall, R.
Pollard, 5 D.G.
3ridenbaugh, et al, The Union of Concerned Scientists, d eliv er ed to the Governor of P ennsylvania, May 15, 1980.
32.
Testimony by D.G. 3ridenbaugh before the New Jersey Board of f
4 Public Utilities, on behalf of New Jersey Public Advocate's Office, Division o f Rate Couns el, Analvsis of 1979 Salen-1 Refueling Outage, August, 1980.
,3 3.
Minnesota Nuclear Plants Gaseous Emissions S t u d 1_, MH3 Technical Pollution Control Agency, September, g
Associates, for Minnesota 1980.
on the Storare and Proposed Rulemaking 34.
Position S ta tement, Discosal of Nuclear Waste, Joint Cross-Statement of Position and the Coalition on Nuclear ?ollution of the New England Natural Resources Defense Council, September, 1980.
35.
Testimony by D.G.
Bridenbaugh and Gregory C. Minor, before the New York State Public S ervice Commission, In the Matter of Long Island Lighting Company Temporary Rate Case, prepared for the Shoreham Opponents Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.
Bridenbaugh before the New 36.
Supplemental Testimony by D.G.
on behalf of New Jersey Jersey Board of Public Utilities, of Rate Counsel, Analysis Public Advocate's Office, Division of 1979 Salem-1 Refueling Outage, December, 198,0.
37.
Testimony by D.G.
Bridenbaugh and Gregory C.
Minor, before Utilities, on behalf of the New Jersey Board of Public New Jersey Department of the Public Advocate, Division of Rate Counsel, Ovster Creek 1980 Refueling Outage Investigation,
~
February, 1981.
Ownershio Interest in Palo Verde Nuclear 38.
Economic Assessment:
for The City of Riv er s id e,
Station, MH3 Technical Associates, September 11, 1981.
39.
Testimony of D.G. Bridenbaugh before the Public Utilities
(
Commission of Ohio, in the matter of the Regulation of the l
Contained Within the Rate Schedules Electric Fuel Component subj ect :
of the Toledo Edison Company and Related Matters, Davis-Besse Nuclear Power Station 1980-81 Ou tag e Review,
October, 1981.
of D.G. Bridenbaugh before the Public 40.
Supplemental Testimony in the matter of the Regulation Utilities Co= mission of Ohio, of the Electric Fuel Component Contained within the Rate Schedules of the Toledo Edison Company and Related Matters, Davis-3 esse Nuclear Power Station 1980-81 Outare Revi subj ec t :
November, 1981.
. ~ _ _ - _. - - -
_.. _ ~ - - _ _. _ - _., _
2 Phase Failure Criterionthe Swedish..uc icar and Sincia Systems InteractionTechnical Associates for 1982.
- January, E.
MF.B (SKI),
C. Minor Atomic on Reoort,Inspectorate Bridenbaugh and GregoryJr. h, before the f
Power j
dG. Brown Testimony of D.G.
behalf of Governor EdmunSaf ety and Licensing BoarJ C. Minor on behalf regarding d,
62.
1982.
Pressurizer Heaters,
baugh and Gregorythe Atomic Saf ety Testimony of D.G. Briden Jr. before
- Brown, s
of Governor Edmund G. regarding January 11, 1982 43.
and Licensing Board, e
P O
I e.
e 4
3 t'
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El 25.1982 MEMORANDUM FOR: Charles E. Horelius, Director, Division of Engineering and Technical Programs FROM:
Robert F. Warnick, Director, Enforcement and Investigation Staff
SUBJECT:
ALLEGATION RE REBAR CUTTING AT LA SALLE-DOCl2T No. 50-373; 50-374 The four attached memos document concerns expressed by an alleger and Ms. Judith Goodie of the Illinois Attorney General's office regarding core drilling through rebar.
Because of the high priority of LaSalle and the unavailability of investi-gators, this matter is being transferred to your Division as we discussed on March 22, 1982.
EIS would appreciate receiving a ecpy of the documentation of your findings and closcout.
Robert F. Warnich, Director Enforcement and Investigation Staff Attachments: As stated cc w/ attachments:
R. L. Spessard R. Uniker J. Foster i
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R. C. flcYoung,111 rector, Office of Inapaction and Enfnrcenent FROM:
Junes G. Keppler, Regional Adminiarratur, Regluu III Stim.l FUT:
1.A SA1.LE COUNTY NUCLEAR STATION - PETITION FROH ILLINOIS NiTORNEY GENERAL As you know, un b rch 24, 1952,' the Illinoir. Attorney Cencral petitlened the NRC to suspend licensing proceedings at La Salle. pe.nding investination et recent silegations and to institute a Shuv Cauwe Hearing with Illinois ss a party to the !! caring. N AlleCarions deal with the overall adequacy of sefety related structures as a result of videspread rebar cutting and c.per.ific. c.trur.rnrn1 defieleneles in the ruuf of the off-gas building.
A c.nnfercr.cc call war. hnid on March 29 Involving Meesrs. neutuu, Cave,
,Sec11o, DeYeung and Keppler rn diveuss the hand) lng of these Inve=LigaLIuus.
Ve agreed that, becau'se the petition expresses concern that thu off-gas building defielencies hed been verbs 11y corcunicated earlier to NRC,and that the NRC had concluded an investigation of these n31cEcd deficiencies was not varranted. it vould be prudent to have an independent review of thir.
silegation by 1E (since IE was not involved in the, consideration nst to inve s tiga te). This review should address both thu'techuleal. Jequacy of the ntf-gan huilding r.nne.p.rns as vall as the NRC's handling of the earlier notitiention in this regard. With respect to the concerns associsted with euttlug through rebar this cutter will be reviewed by Region III with technical ssr.ir.rance from NRR.
L Tealita your staf f is aliendy depicted as a result of other investigation etusistance you are giving us, and your willingneum to assist lu this effort is Renuinely appreciated.
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[ James C. Keppler Regional Ad=inistratue cc:
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ctcu rttvu,ittinois sois7 PfA 31.1982 DO DISCLO Contains entity of s'
C nfi ntia source MEMORANDUM FOR:
Region III Files FROM:
James E. Foster, Invest.igator
'HROUGH:
R. W. Warnick, Director, Enforcement and Investigation Staff T
SUBJECT:
CONTACT WITH JUDITH GOODIE I contacted Ms. Judith Goodie, of the Illinois Attorney General's Office, at approximately 9:10 a.m., on March 26, 1982.
I advised Ms. _ Goodie that Region III had not been aware of allegations by
- regarding LaSalle, and inquired why the Illinois Attorney enera s petition did not mention allegations from M. Goodie slaled that she had " assumed" that Region III had otten ame from NBC (as she had) and had contacted
- She indicated had declined to provide her office with an affidavit for fear o name being known, and so was not included in the submitted petition.
I indicated that the 'nformation p_rovided by was much more detailed l
than that provided by and would have assisted ~ Region III in its I
review.
Ms. Goodie stated that she had not meant to withhold any information, and that "it should have been obvious that we were working on something".
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./ James E. Foster Investigator cc:
R. L. Spessard R. Gardner
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W. Walker C. E. Norelius n(l DO NOT DISCLOSE g
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