ML20027E115
| ML20027E115 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/16/1982 |
| From: | Gilbert E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20027A786 | List:
|
| References | |
| FOIA-82-328 NUDOCS 8211120078 | |
| Download: ML20027E115 (18) | |
Text
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Os NOT D;SCU'.';E ASSESSMENT OF THE RESPONSE BY REGION III TO ALLEGATIONS CONCERNING 7" THE OFF-GAS FILTER BUILDING AT THE CT:T',iS !.. ;. - Q j of LASALLE NUCLEAR STATION r-u h:a..
- ,.. 3;UfCs p
- c. ; t.: b
-; Summary
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Between January 26 and March 8, 1982, Region III received allegations of i structural deficiencies in the roof of the off-gas filter building at the LaSalle County Nuclear Station.
Region III concluded an inspection and/or investigation of these concerns was not warranted.
On March 24, 1982, the State of Illinois Attorney General filed a petition requesting a Show Cause Proceeding concerning several issues of claimed safety significance including the reported off-gas filter building deficiencies.
As a result of this petition, IE conducted an independent assessment of actions taken by Region III in response to the allegations related to the off-gas filter building, and to determine the propriety of the decision not to pursue the matter. The assessment disclosed that Region III properly examined, researched and documented the allegations.
Specific action by Region III included contacts with the alleger, quiries of Region III staff personnel with expertise in BWR plant systems and an evaluation of the safety significance of thc off-gas filter building by reviewing the LaSalle Final Safety Analysis Report (FSAR).
The independent assessment concurred with Region III's conclusion that the allegations pertained to a non-safety related building, system and equipment which required no additional action or follow-up by the NRC regiilatory process.
The IE assessnent also 3 included an analysis 'of the technical adequacy of the off-gas filter building
- roof to refute or substantiate the allegations.
The results-of this technical evaluation are reported by separate documentation.I I/ /f k2 [
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~8211120078 820917
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ENCLOSURE 1 PDR FOIA STEPTOE82-328 PDR i
D' 40T DISCLOSE-
. Conpirf5ilde!91tysof o
Confidential Source Purpose of Inquiry j
This inquiry was conducted by IE to obtain an independent assessment of
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actiods taken by Region III in response to allegations of structural deficiencies in the off-gas filter building at the LaSalle County Nuclear Station.
Background
On March 24, 1982, Tyrone C. Fahner, Attorney General. State of Illinois, filed a petition to suspend operating license proceedings and to institute a Show Cause Hearing. The issues involved alleged rebar cutting and alleged structural deficiencies in the roof of the off-gas filter building.
These concerns had reportedly been previously~ verbally communicated to Region III.
The Illinois Attorney General's petition with the forwarding letter is Attachment (1).
On March 29, 1982, a conference call was held between James G. Keppler, Harold R. Denton, Edson G. Case, Richard C. DeYoung and Victor Stello to discuss the issues contained in the petition.
They agreed to have IE conduct an independent review and assessment of the allegation concerning the deficiencies in the off-gas filter building. This independent approach I
was reconinended since the petition expressed concern that Region III had f
previously concluded that an investigation of these alleged deficiencies was not warranted.
ItwasalsodeterminedthattheIErevfewshouldinclude both an assessment of Region III's handling of the verbal notifications regarding this allegation and an analysis of the technical adequacy of the off-gas filter building.
Keppler's memorandum to DeYoung, dated March 30, 1982, reporting this information, is Attachment (2).
s
^
D NOT DiSCLQSE
, Contginsildshidy of Cortfidential Sou'rce On March 30, 1982, Richard C. DeYoung, Director, IE, appointed Edward C.
I Gil,bert, Senior Investigator, IE, and Robert E. Shewmaker, Senior' Civil-Stjuctural Engineer, IE, to conduct the ' independent assessment of (a) actions taken by Region III in response to allegations re' lated to the off-gas filter building and (b) the structural adequacy of 'the off-gas filter building.
INVESTIGATOR'S NOTE:
The results of the technical evalcation of the structural components of the building are documented in a separate report.
Review of the Region III Files The following pertinent documents from Region III files were made available to IE for review on March 30 and 31,1982:
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Memorandum for the Region III files, dated January 28, 1982, from Robert a.
F. Warnick, Director, Enforcement and Investigation Staff, Region III (Attachment (3)) - This document reports that on January 26, 1982, Doug iongenie, a newscaster for Channel 5 television, telephonically contacted Warnick. Longenie related the receipt of allegations regarding the LaSalle County Nuclear Station from aho had worked at the plant, b alleged that while drilling 8 inch anchor bolts in the ceiling of theioff-gas filter building they penetrated the r'oof which was suppose to be i
12 inches thick.
Warnick told Longenie that Region III would contact u
i and follow up on the allegations.
I e
DCNOT DISCL SE l
l 1 Conialifs identiiy'cf o
Cofifidential Source.
b.
Memorandum for the Region, III files, dated February 10, 1982,5 from Ja es E. Foster, Investigator, Region III (Attachment (4)) - This> reports th t c'i February 4,1982, Foster telephonically contacted rwho requested confidentiality.
In regard to the off-gas filter building, 5
stated that holes drilled for expansion anchors in the ceiling at the 725 foot elevation penetrated the concrete and asphalt roof covering.
advised
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that water which had accumulated on the roof came down through the holes, also reported the existence of cracks in the concrete since the holes were lled too close.
a noted some patching was subsequently performed.
Memorandum for the Region III files, dated February 26, 1982, from Gerald c.
A. Phillip, Senior Investigator, Region III (Attachment (5)) - This documents that on February 22, 1982, Phillip received information that Mrs. Judith S. Goodie, Assistant Attorney General, State of Illinois, had called Region III concerning the allegations made by o Longenie.
Prior to returning Mrs. Goodie's telephone call, Phillip reviewed the allegations contained in the two memoranda (Attachments (3) and (4) pertain) and discussed the status and resolution of the matter with Roger Walker, Chief, Reactor l
Projects Section 1-C, Region III.
Based primarily upon information obtained l
from Walker, Phillip determined that the allegation regarding the off-gas fil er building is not of concern to the NRC since this structure is not j
considered safety related, i.e. subject to seismic considerations.
On Februa ry 23, 1982, Phillip telephonically contacted Mrs. Goodie. ;He told her that Region III was evaluating the various allegations to ascertain what action would be taken.
In this regard, he explained that since the off-gas filter l
l l
'M T NOT DiSCLORE
-s-Con,tpirrfidht or of Comidential Sou ce building is not a safety related structure, the allegation concerning the roo,f thickness was not within the regulatory purview of the fiRC. 'Mrs.
Go'odie apprised Phillip of an additional allegation by ng the' drilling into rebar.
Phillip acknowledged he was not previously aware of -this allegation which would be of interes't to the fiRC.
Subsequent to Phillip's conversation with Mrs. Goodie, Phillip had additional discussions with Region III personnel who furnished amplifying information indicating none of,
6 original allegations required further action by the fiRC.
Therefore, Phillip concluded that with the exception of the reported drilling into rebar, all of
- allegations had been, satisfactorily resolved i
and/or did not require pursuing by the tiRC.
Phillip recommended that the tiRC's explana_ tion and position concerning various allegations be conveyed to and that be quiried regarding the alleged drilling into re ar to ascertairi whether that matter warranted further action by Region III.
d.
Memorandum for the Region Ill files, dated March 13, 1982, from Foster (Attachment (6)) - This reports that on March 6 and 8,1982, Foster was telephonically contacted by Mrs. Goodie who reported that 4 had told her that rebar was often cut by 7 cre$ when they drilled cores or holes.
Foster responded that he w,uld attempt to discuss this with
.e since h had not mentioned the cutting of rebar during their previous conversations.
Mrs. Goodie also expressed concern that the allegation concerning the off-gas filter building was not being pursued by the tiRC since she understood some equipment in the building was intended to reduce or mitigate radioactive releases in the event of an accident.
Foster explained to
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-a
-y-,-
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NOT DISCLOS'E7 9
'C Conta nsloeg. ty of Qort idential Source her that since the off-gas filter building is a non-safety, non-seismic str,ucture, it should not contain safety-related equipment, Mrs.boodie i
rerrjarWd that she had spoken to " nuclear experts" who had advised her di ferently.
Foster recontac on March 8,1982.
revealed that when crew hit rebar duririg core drilling in the reactor
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building and off-gas finer building, a special crew was called who then
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used a water cooled diamond drill to cut the rebar.
added that this practice was continued until approximately Septemb~er 1980"when a " work notice" system was instituted by Quality Control to stop the uncontrolled cutting.
identified -
as a current employee on site who may be able to provide additional information.
Foster suggested various actions
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to resolve the allegation, and recommended that the issue receive priority attention by Region III.
Memorandum for Charles E. Norelius, Director, Division of Engineering e.
and Technical Programs, Region III, from Warnick, dated March 25, 1982 (Attachment (7)) -
This reflects that on March 22, 1982, Warnick discussed i
the alleged core drilling through rebar with Norelius.
In view of the imminent issuance of an operating license at LaSalle and the unavailability of investigators, Norelius agreed to have his Division assume responsibility for. resolving the allegation.
2
.i
- f. 'Memorandem for the Region III files, dated March 31, 1982, from Foster (Attachment (8)) - This reports that on March 26, 1982, Foster t lephonically apprised Mrs. Goodie that Region III had not been aware of the allegations of rebar cutting made b.)
a former LaSalle employee, prior to
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D'.]OT DISCLOSE 7-Con alffs loht'ty of Ce fidentialSou ce the Attorney General's p'etition being filed.
Mrs, Goodie explained there hap been no intent to withhold information and she had assumed Re'gion III was' aware o concerns and 'had contacted him.
Foster also asked why llegatioiis were not included in the petition.
Mrs. Goodie responded that had declined to submit an affidavit since ired confidentiality.
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g.
Off-Gas Building Roof Report, dated March 29, 1982 (Attachment (9)) -
This report, submitted by Daniel L. Shamblin, construction engineer, Commonwealth Edison, refuted the alleged structural roof deficiencies in the off-gas filter building which had been cited in the Illinois Attorney General's petition.
Interviews of Reaion III Personnel James E. Foster was interviewed on April 1,1982.
Foster reviewed and attested to the accuracy of the Region III memoranda reporting the receipt, handling and resolution of allegations regarding LaSalle (Attachments (3) through (8) l pertain).
He advised he initially became aware of allegations when he received Warnick's memorandum dated January 28, 1982 Attachment (3)).
He continued that Warnick asked him to "look into" the allegations by obtaining more information.
Therefore, on February 4,1982, he (Foster) telephonically
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contacted Foster stated he does not recall
- - c $ nentioning tha reporte y daylight could be observed through holes drilled in the off-gas filter building roof since he (Foster) would have included this information in his memorandum of their conversation.
Foster averred that his memorandum of February 10,1982 (Attachment (4)) contains all significant information furnished m
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Con irifIchts' pf C nfidential Sout e b
He added that this was prepared from copious notes _ he had e conversation, and that he subsequently gave his no(es to ta en o
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iGtA. 3hillip.
He added that the safety significance of the off-gas filter building was not discussed during his first contact with or addressed in the ensuing ' memorandum sinc'e, at the time, e was no personally familiar with this building.
Foster remarked that he subsequently discussed the off-gas filter building with Roger Walker, the former Resident Inspector at LaSalle who is very knowledgeable of BWR's.
He stated that Walker assured him the building and the equipment housed in the building are not u Nty related; and he noted they reviewed Table 3.2-1 of the LaSalle Final Safety Analysis Report (FSAR) which verified this non-safety related classification.
Foster also pointed out that to his knowledge Region III had not conducted any inspections or investigations of the off-gas filter building since it is not a seismic structure.
He disclosed that as reported in his memorandum of March 13,1982 (Attachment (6)), he informed and Mrs. Goodie of the non-safety classification of the off-gas filter building and related equipment during telephone conversations on March 6 and 8,1982.
He added t
that Mrs. Goodie claimed that " nuclear experts" had told her differently, however she did not identify these individuals.
Foster advised th prima ry intent of his March 13 memorandum was to document and initiate priority action concerning the rebar cutting allegations on safety-related. structures i
which had also been reported in Phillip's memorandum of February 26, 1982 (Attachment (5)).
He added that at this juncture he had no reservations a
concerning the decision not to pursue the off,-gas. filter buildi.bg allegations 3
i in view of the information provided by Walker and contained in the FSAR, l
l
F 1 NOT DISCLOSE 9-Cont. xins Mqnu..ty of Con identialBource In this regard, Foster advised that he concurs with the conclusions and rqsolutions concerning all ? ' ',
allegations.specified by P illip in his memofondum of February 26, 198.
Foster related that as a result of the
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Attorney General's petition of March 24, 1982, a meeting was held in Region III on March 26, 1982.
He advised that he (Foster), Warnick, Norelius, Phillip, Keppler, Frank Hawkins and Richard Knop were in attendance.
He stated they discussed the various allegations which had been made against the LaSalle Nuclear Station, the thoroughness of' Region III's handling of the allegations, the classification of the off-gas filter building as a non-safety, non-seismic structure and the possible necessity of an independent assessment of the situation by IE.
Foster remarked that his first knowledge of the allegations made by
- egarding the rebar drilling resulted
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from the appearance of ffTdavit in the Attorney General's petition.
He noted the information was very detailed and he had no reason to question its validity or accuracy.
Foster stated he was upset that Region III did not have the benefit of testimony at an earlier date to assist in their review of the alleged rebaFdrilling._ He stated that he telephoned Mrs. Goodie on March 26, 1982 to point out that..
y nformation had not previously been made available to Region III.
He adviseTthat his i
memorandum of March 31, 1982 (attachment (8)) documents this conversation.
Foster added that during the March 26 meeting,Hawkins disclosed that he had sp ken t F ter advised that Mrs. Goodie attended a meeting comprised of representatives of Regio'n III, the office of Nucleah Reactor Regulation (NRR) and Commonwealth Edison held in Bethesda, MD, o March 31, 1982.
He understood that during this meeting Mrs. Goodie commented that he e
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")0 OT DISCL SE Conjaiffs ident}Ey'of-C,onfidential Source (Foster) had stated the'NRC had confirmed allegations that the roof of e off-gas filter building was less than 12 inches thick.
Foster noted ti$at Cordell Williams, who was present when Mrs. Goodie made this statement, excused himself from the meeting to call him (Foster) regarding this remark.
Foster related he assured Williams that Mrs. Goodie was mistaken since the NRC had not determined the roof was less than 12 inches thick.
- Further, he declared that he never made this statement to Mrs. Goodie during their various conversations on March 6, 8 and 26,1982.
In this regard, he reiterated that he informed Mrs. Goodie that since the off-gas filter building is classified non-seismic and non-safety related, it would not contain safety related equipment; and the NRC does not have a regulatory responsibility for a non-safety related structure.
Foster also pointed out that a report prepared by Commonwealth Edison on March 29, 1982 (attachment (9)) indicated the roof was built according to specifications, will serve its' intended function and contains no abnormal cracking.
Foster also disclosed that on March 31, 1982 he learned Mrs. Goodie had telephonically contacted NRR on liarch 18, 1982 concerning the drilling of rebar allegations.
He provided a copy of Mrs. Goodie's letter documenting the conversation.
This letter, dated March 18, 1982, is Attachment (10).
Foster expressed l
l dismay concerning a comment by Mrs. Goodie in the letter indicating that he;(Foster)wasgoingtowriteareportonhisinvestigationregardingthis allegation.
He explained that during his discussions with Mrs. Goodie he had only told her that Region III would "look into" the alleged rebar cutting.
t Foster concluded that he documented all pertinent information regarding the various allegations and that Region III accomplished all necessary action within the regulatory guidelines to satisfy and resolve the allegations.
00 NOT DISCL SE
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Conipirfs lhtity of godidential SouYce Foster also prepared and submitted a partial chronology of event,s related tj the various allegations including the.off-gas filter building! The ch[ror.'ologyisAttachment(11).
Gerald A. Phillip was interviewed on April 1,1982.
Phillip' reviewed the Region III file material regarding the LaSalle allegations (Attachments (3) through (8) pertain) and considered it an accurate account of the Region's actions. He advised that on February 22, 1982 he received a message that Mrs. Goodie had called the Region III office seeking information concerning the LaSalle allegations.
He observed that prior to this time he was only generally aware of the allegations through conversations with J.E. Foster.
Phillip stated that he assumed the responsib.ility for returning Mrs. Goodie's call since Foster was in a travel status on an unrelated natter.
He advised that prior to contacting Mrs. Goodie he researched the issues by reviewing the memos prepared by R.F. Warnick and Foster (Attachments (3) and (4)),
speaking with R. Walker and examining the LaSalle FSAR.
He remarked that l
Walker told him the off-gas filter building is a non-safety related structure and Walker showed him a clart in the FSAR which confirmed this classification.
Phillip stated he telephonically contacted Mrs. Goodie on February 23, 1982 and apprised her of the contents of the memos which Warnick and Foster had submitted. Additionally, based upon information he had obtained from Walker, I
l he: explained the NRC's position regarding the various allegations to her.
In this regard, he informed her the NRC did not intend to pursue the alleged structural deficiencies in the off-gas filter building since it sas considered a non-safety related structure.
Phillip noted that Mrs. Goodie did not question his explanation although he did not know whether she was familiar 9
DL d!OT DISC OSE
- Cont insMeetityof G nfidentialSburce with the f1RC regulatory distinction between a safety and non-saf,ety related iJem. He continued that he suggested to. Goodie that she call Fo' ster the i
following week since Region III was still evaluating the allegations to determine what action was required.
Phillip disclosed that during this conversation, Mrs. Goodie also raised the issue of the alleged rebar cutting which she had reportedly obtained during a discussion with p Phillip stated he told Mrs. Goodie he was not aware of this
~ allegation although it is of interest to the NRC.
He advised that following his conversation with Mrs. Goodie he received information which resolved a few of the allegations made by J Phillip related he documented this information and his conversation with Mrs. Goodie in a memorandum dated February 25, 1982 (Attachment (5)).
Phillip pointed out that the memorandum included his opinion that with the exception of the alleged rebar drilling, none o oncerns appear to warrant further action.
He conceded that he did not retain the notes which he had taken during his telephone conversation with Mrs. Goodie.
Phillip advised that when Foster l
l returned to the office on March 1,1982, he briefed Foster on his conversation with Mrs. Goodie and suggested that he (Foster) contac regarding the rebar allegation.
Phillip remarked that his only additional involvement in the off-gas filter building allegation was his attendance at a meeting, in{RegionIIIonMarch 26, 1982.
He explained that six or seven Region III pehsonnel met with the Regional Administrator to discuss the petition filed l
by the Illinois Attorney General.
He noted that L'alker and Fost6r agreed with him that the off-gas filter building is not within the regulatory purview of the NRC since it is considered a non-safety related structure.
Phillip
E NOT DISCLOSE
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Conta'nsYdeliity of Cp idential So. nee opined that the Attorney General's concerns are primarily politi,cally mqtivated since he is apparently using the allegations to gain,p0blicity 1
a i
fo,r his election campa'ign.
He furnished a copy of an editorial which appeared in the March 28, 1982 issue,of the Chicago Tribune supporting this contention.
This article is Attachment (12).
Richard C. Knop, Chief, Projects Branch #1, Region III, was interviewed on April 1, 1982.
He advised he initially became aware o allegations regarding LaSalle in February 1982.
He explained that R.
a er -
and possibly J. Foster and/or G. Phillip were in his office reviewing items of noncompliance.
Knop understood that Mrs. Goodie had contacted Phillip to express an interest in the allegations, however he (Knop) could not recall or was not informed of the specifics of their conversation.
In regard to the off-gas filter building, Knop stated they had determined the building was depicted as a seismic category II and as such was not a safety-related structure according to Section 3.2.1 of the LaSalle FSAR.
He pointed out that this classification had been developed by the licensee and subsequently approved by NRR.
He was aware of no independent efforts or further evaluation of this non-safety classification by Region III.
Additionally, he did not believe inspection activities had been directed toward the off-gas filter building sinte there was no requirement for this 1
l fr5m a construction standpoint.
Knop noted that a safety-related category clkssification applies to pressurized water reactors (PWR's) witt gaseous 3
hold-up tanks, however the laSalle facility is a boiling water r$ actor (BWR) without these tanks.
He continued that with this understanding, everyone agreed that the allegation pertaining to the off-gas filter building did l
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.N O T D IS C L O S E f~"~
Con airiliIdehqf p nfidentialSource
, not warrant additional 5ction bf the NRC since the building is a*non-safety
,related structure.
Therefore, to his knowledge, Region III did n,ot physically l
e$ amine or survey the building in respect to the alleged structural deficiencies.
Knop stated that as a result of the Attorney General's petition."'
dated March 24,1982 (Attachment (1)), he (Knop) attended a meeting convened by the Region III Regional Administrator on March 26, 1982.
He explained that J. Keppler wanted to insure that the off-gas filter building allegation had been properly evaluated and handled by the Region since the petition implied th'e Region had acted improperly by not pursuing the allegation.
Knop advised that all attendees at the meeting concurred with the non-safety related assessment of the building which did not necessitate further action by the Region.
However, in view of the Attorney General's concerns, they discussed the advisability of requesting an impartial analysis of the situation by another Region or IE.
Knop could offer no additional information.
Charles E. Norelius, Director, Division of Engineering and Technical Programs, Region III, was interviewed on April 1,1982.
He stated he never became involved in pursuing the allegations concerning the off-gas filter building since the Region III investigators had concluded they pertained to a non-safety related structure and system.
He added that he had no reason to question th.is decision and he did not consider it necessary to initiate an independent i
asiessment of the non-safety classification of the building.
Norelius re ated his first knowledge of the llegations occurred when he j
received J.E. Foster's memorandem dated March-13, 1982, (Attachmbnt (6)),
l which recomended priority attention be directed toward the rebar drilling l
l allegation. He noted that neither this issue nor the other allegations had previously been discussed by R.F. Warnick during daily meetings of the Q
L
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Contpirrs idehtgof Coniidential Source Region III Directors. Norelius related that as a result of Foster's F
memorandum he discussed the matter with Warnick and c'ntacted R? Walker
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tf ocertain what actions) had been initiated.
He disclosed that Walker responded by a memo the following day acknowledging he was aware of the allegations and recommending that Frank Hawkins assist Foster in resolvirig the rebar drilling issue.
Additionally, Walker reported that the, off-gas filter building has no structural requirements according to Table 3.2.1 of the LaSalle FSAR.
Norelius provided a copy of Walker's undated silemo which is set forth as (Attachment (13)).
Nore ius stated he furnished Foster's March 13 memorandum to Cordell Williams who assigned Hawkins to conduct the inspection. He advised that on March 25, 1982 Hawkins told him he had made inquiries regarding the rebar drilling issue but,he
)
had not pursued the off-gas filter building allegati,on.
Norelius stated he attended a meeting in Bethesda, MD, on March 31, 1982 irr which Mrs. Goodie had remarked that Foster had indicated tid NRC had confirmed the allegation of the roof being less than twelve inches thick. He continued that C. Williams then called Foster who denied makir.g this statement.
Mrs. Goodie was apprised of Foster's denial and told that the off-gas filter building 3
allegation was not investigated by the NRC since it was not a category 1 (safety related) structure.
Norelius added that to his knowledge, Region 113 had not examined thetthickness of the roof or made any statements concerning its construction.
Norelius concluded that in his opinion the Regionactedproperlyinnotpursuingthisallegationsincethefuilding was determined to be a non-safety related structure.
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M NOT DISCLO E' ContainDi, ity of ConfidentialSou e
Cordell C. Williams, Chief, Plant Systems Section, Region III, was i,nterviewed on April 1, 1982.
Headvisedthatpriortothisdat(ethe t
c'nly documentation regarding the LaSalle allegations that he was aware of was Foster's memorandum to Warnick dated March 13,1982 (Attachment (6)).
He explained that No'relius had given this memorandum to him during the week of March 22 - 26, 1982 with a request to initiate an inspection concerning the rebar drilling allegation. Williams related that he then assigned the matter to Hawkins who conducted appropriate inquiries concerning the rebar, and had an exit interview of his findings on March 24, 25 or 26,1982.
He related that Hawkins had completed his inspection prior to the Attorney General's petition being made available to Region III.
Williams remarked that he agrees with the opinions of Foster, Phillip and Warnick that the off-gas filter building is a non-seismic, non-safety related structure, and, as such, does not require inspection and/or investigation by the NRC.
Roger, Walker, Chief, Reactor Projects Section 1-C, Region III, and former l
Resident Inspector, LaSalle County Nuclear Station, was interviewed on April 1, 1982.
He acknowledged that in early February 1982 he received l
an "information only" copy of Warnick's memorandum dated January 28, 1982 (Attachment (3)). He recalled that Foster, Warnick and Knop subsequently sdught his assistance in resolving the various allegations. Accordingly, hafresearchedthevariousissues. In respect to the off-gas filter building, Walker declared that to the best of his knowledge and based upon Table 3.2.1 of the LaSalle FSAR, this building has no structural requirements and 1
contains no equipment to mitigate radioactive releases during an accident.
M NOT DISOL -8E COnijd!C '
O'i Corffidentia! Source Therefore, he recomend'ed that since the allegation pertained to.a i
ngn-safety related structure, no further action by the NRC was warranted.
i Wilker disclosed that at a later date Foster showed him his (Foster's) i memorandum dated March 13,1982 (Attachment (6)) wherein Mrs. Goodie was quoted as saying " nuclear experts" had questioned the classification of the building as non-safety related.
He continued that he (Walker),
Foster and Phillip attempted to call Mrs. Goodie regarding this issue but she was not available.
He recalled that Foster left a message to have Mrs. Goodie return his call.
Walker stated that subsequently
.Norelius solicited his comments on Foster's March-13, 1982 memorandum.
He advised that he responded with a memo to Norelius (Attachment (13))
wherein he recommended an expeditious investigation of the rebar cutting allegation and reiterated his determination that the off-gas filter building was a non-safety related structure which did not require additional action by the NRC.
He related that Hawkins arrived at the LaSalle sit;e on March 24, 1982 to conduct inquiries concerning the alleged rebar drilling.
i Walker concluded that Region III responded properly to all,he allegations within the regulatory purview of the NRC.
Attempts to Interview Additional Region III Personnel The following additional Region III persciinel were variously involved in th Region's actions in response to the alleged structural deficiencies ih the off-gas filter building roof:
J. G. Keppler, R. F. Warnick and l
F. C. Hawkins.
none of these individuals were available for interview on April 1 and 2, 1982 while this independent IE assessment was being conducted.
I e
OT DISCLOSE
-'8-Contains'!dantit]hp Confidential Source Conclusions
,5 i
Based upon an examination of pertinent documents and interv'iews of cognizant fI Regi$n III personnel, no improprieties were surfaced in Region III's handling of the allegations related to the off-gas filter building.
Upon receipt of the allegations, Region III personnel initiated appropriate inquiries and reviewed the LaSalle FSAR to determine whether the allegations pertained to a safety related structure, system or component.
Since knowledgable Region III staff and reference material revealed the al' legations concern non-safety items, no further action was taken.
All pertinent information was properly documented and the original alleger and other interestel parties were notified of the findings.
No additional follow-up was required by Region III since the NRC regulatory proce'ss does not address non-safety related issues.
Attachments 1.
Petition by T. C. Fahner, dated 03-24-82 2.
Memorandum from J. G. Keppler, dated 03-30-82 3.
Memorandum from R. F. Warnick, dated 01-28-82 4.
Memorandum from J. E. Foster, dated 02-10-82 5.
Memorandum from G. A. Phillip, dated 02-26-82 6.
Memorandum from J. E. Foster, dated 03-13-82 7.
Memorandum from R. F. Warnick, dated 03-25-82 8.
Memorandum from J. E. Foster, dated 03-31-82 9.
Report by D. L. Shamblin, dated 03-29-82 10.
Letter from Mrs. J. S. Goodie, dated 03-18-82 i 11. Chronology of pertinent events, undated
- 12. Article from Chicago Tribune, dated 03-28-82 i 13.
Memorandum from R. Walker, undated i
Et h d C. k N.
4)l4 Reported by:
0(te Edward C. Gilbert Senior Investigator Office of Inspection &
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March 24, 1982 Secretary, U.S. Nuclear Regulatory Com:nission Washinc. ton, D.C.
20555 Attention:
Chief Oceketing and Service Section Re:
Request to Institute A Show Cause Proceeding and for Other Relief Com.cnwealth Edison Com.pany Doc.%et Nos. 50-373, 50-374 Ocar Sir:
Please find enclosed an original and 3 copies of Request To Institute A Show Cause' Proceeding and for Other 3elief for -
filing with the Suclear Reguistory Comrtission.
Please file the original and 2 copies as required by 10 C.T.R.
- 2. 7 0 3 (d).
Please stamp the third copy as " filed" and return it to t.his ef free in the enclosed self-addressed stamped envelope.
Very truly yours, Jt!OITu. S.
GCODIS Assistant Attorney General Environmental Control Division l'8 B '.les: Randolph Street Suite 2315 Chicago, Illinois 50601 (312) 793-2491 CSG:bl E.. closures
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UNITED STATE OF 7d4 ERICA NUCLEu, RECULATORY COMMISSION
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In the Matter of
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CO!O'.ONNEALTH EDISON COMPANY
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Docket Nos. 50-373
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and LaSalle County Nu' clear
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50-374 Generazing Station, Unit 1
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and Unit 2
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REQUEST TO INSTITUTE A SHOW CAUSE PROCEEDISG 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 13 C.F.R.
52.206, hereby reques ts the United States Nuclear Regu _atory Corr.ission.(Con-nission), or t.he Director of Nuclear Reactor. Regulation, to insti.ute a proceeding pursuant to 10 C.F.R. 52.202, to, suspend operating license proc. edings and for other appropriate relief, in, light of newly disco'vered safety' issues.
I.
PROCEDURAL BACKGROUg Cor.r.onwealth Edison Company (Edison) has been authorized by Construction Perr.it Nor. CP?R-99 and C??R-100 to build the i,aLalle
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r-2 County, Illinois Nuclear Station consisting of two genereting '
units, Unit l'and Unit 2.
Constrbction has been ongoing since -
1974 or earlier.
The construction of Uni: 1 is substantially complete.
Unit 1 is scheduled for commercial service in September, 1982.
Unit 2 is schnduled for completion in October, 1983.
O' perating license proceedings for Unit 1, Docket No. 50'-573, and Unic 2, Docket No. 50-374, are pending befor,e the Cor.m.i s s ion.
Illinois is inforr.ed that no hearing has been requested or noticed in said operating license proceedings.
Illinois is also informed that Edison has ndvised the Office of Nuclear Reactor Regulation that it is ready to ebtain an coer-ating lice.nse for fuel loading and low power testing of Unit 1, pursuan t to 10 C.F.R.
- 52. 764 (b), (d).
- II.
STATEMENT OF FACTS I
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 co..-
struction practices which are the subject of this Roquest to t
Institut'c a Proceeding (Recuest), and.which are r. ore fully dcs-cribed belcw, relate to Unit 1 and to Unit 2
P Cn :4a rch 2, 1982 Robert J. Schultz, a vice presider.t of Edison, stated that Edisc. cxpected to lead nuclear fuel and to begin low pcwer costine within 30 to 40 days.
III. Ccmmerce Corsnissicn Docket No. 02--0025, report of proceedin m _co U n~
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ecuipment,.at least as early as 1978, until the end.
of 1979', ' holes in the rein'ferced conci ete walls, ficors,
4 and ceilines of the. reactor buildinc.s and other build-
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thrcugh the ings were, as a catter of course, drilled reinforcing steel or rebar.
Depending uoon the size
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ne t. ic,xness or une rcoar, o,
the.no,e anc n
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' drilling practice :.ay danage or completely sever one or more ' lengths of rebar, or cut chunks out of the reber.
3.
The affidavit of w a driller who worked a the LaSalle Ccunty cor.structio.7 site
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during the years 1978, 79, ah.d 80, is attached to this secuest as Exhibit 1 and is incorporated herein
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affidavit explains in by reference.
greater detail,.the drilline practices. alleged herein.
l 4.
..s unknown number of drilled holes, ranging in the. order of thousands, are likel, to have been cut through s teel reinforce-cent in the concrete walls of safety related buildings,, including
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.the reactor buildings.
Although Illinois does not have acccss :o Edison: a records,thich doc raant these drilling practices, it uhderstends from the c =fidavit of
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.. s th at such'
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a records were nade at the tine the alle gd practices occurred.
are essential to t~ne Corr.is5 ion's Thesehecords, or drill sheets, m
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detemination of the extent to which steel reinforcernent was daoaged or scvored in the concre(e structure 'of Units i and 2 during Eonstruction.
The records are believed to be presentiv in Edis. s.c,ossessicn or control.
The corr.ission 'has access to drill sheets, engineering plans, and other construction recc.rds, pursur.t to 10 C.E', R. ' 5 50. 7 0 (a) and 42 U.S.C.
S 22 32 (a).
S.
According to avit, the practice of cr2.ll2.ng througn recar uns ca.scont.inued, or subjected to the case by case approval of an engineer, s'ome tinte in late 1979 or eerly 1980.
Illincis has no infonnation which sugcests that any engineering cpproval was ever obtaine.d from Edison's
'encineering consulta.nts for the rebar 'chtting which occurro:i prior to 1980.
6.
The removal, damagimg, or severance of unknown amounts
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of reinforcing steel in the wc11s of the reactor buildings and Other rblated structures presents a substantial health and safety issue which recuires the imediate attention of the Cc= mission.
Attached to this Request as Exhibit 2 is the affi-davit of Dale Bridenbaugh, an expert in the field of nuclear,,
plan t construction.
Accorciing to Mr. Bridenbaugh, the prac'tice of cutting through reinforcing steel should be thorough]y e
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investigated prior to plant operation.
Ec states that if the rebar was danaged or severed wibhout appropriate structural.
i analysis, and if the drilling practice was widespread, "it seer.s nearly certain that some safety-related structures would have been affected."
(Exhibit 2, at 3-4) 14r. Bridenhaugh explains that the potential consequence of degradation in structural quality is the " failure of the structtres and/or
. systems to perfor n their safety related functions under accident or seisnic conditions."
(Exhibit 2 at 5)
He reconcends that a.y repairs shich =ay be required to rer$dy structural degra-dation be irade before the. safety systems are called upon to prevent or nitigate the consequences of an accident.
7.
A second type of structural deficiency at LaSalle Statica hcs gome to the attehtion of Illinois.
The off gas building is a structure which seryes Units 1 and 2.
A former cor.struction I
T fore ~ an,' whose identity is being.keet confidential by the 2
..egion JII staff, had told Region III that the concrete cciling or, roc f of.the of f' gas building was actually only 8 inches thick even though the scecifications called for this rccf to be 12..
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inches thick.
Illinois is also informed that a transformer sits atop this roof, and that the concrete has cracked substantially 3
i due to the nur.ber of anchor bolt neles drillad in.it.
The 6
- l
Jr affidavit of Dale Briden,baugh states that the of f gas building :
houses equipment containing radiodetive gases. (Exhibit 2 at 4)
The ef f-gas building also contains nonitoring equipment for reasuring radiation lovcis in the building.
The inadecuate thickl noss and cracked concrete of the roof on the of f-gas. building, the presence of a'nchor 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-g'as building in the event thc roof or ceiling should fail.
8.
In view of the substantial health and safety issues
. resented in this Request 'and in the af fidavits attach'ed hereto, the loading o f nuclear fuel into the reactor building of Unit 1 is inadvisabl~e at this time.
The affidavit od Dale Bridenbaugh attests to the reasons why fuel loading should be postponed.
(Exhibit 2 at 5)
The presence of nuclear fuel severcly limits a
the ability of investigating personnel to perform'the necessary investigation, by maki.}g access to some portions of the plant either extremely difficult or impossible.
Until the Commission f,ully examinos the potential safety hazard presented b'y the cut-ting of -reinforcing steel as alleged herein, it will not be known whether corrective reasures will be n'eeded to ensure the struc-tural integrity end safety of Units 1 and 2.
The prosance.cf i
nuclear fuel within the structure of Unit i vill make more diffi-cul: no: caly the investigatica itscif, f.ut else the pe.rformance 4
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of e.ny correct.ive nea'sures which may be ordered by P.he Cor=ission
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for Units 1 and 2.
~ 9.
Illinois has not previcusly been a party ta.iny proceeding,
cencerning the licensing of the LaSalle Count'- Nucioar Station.
The facts alleced in this Request which create a substantici to the Requestor
. issue.of health and safety were not known Illinois until.?cbruary, 1932.
Thus.it is only now-thab the
..tterney General of Illinois finds it necessary to snek the relief recuested,herein.
.The continued protection of the health and sa f etv. of the Peo.nle of Illinois recuires that the cuestions ra'ised by this Recuest be fully resolved before the Ccr.T.ission authoriacs the operation, at low power or at. full oower, of dnits i and 2.
RECUESTED RELIEP III.
e 1
For the reasons set forth above, Illincis request 5 t! hat the Ccer.ission institute a proceeding pursuant to 10 C.F.R. 52.IO2 and-1.
Irr. mediately suspend consideration of Edison's request for a fuel Icading and. low power testing licenso i
at IJait 1 until the Comaission in/cstigates the alle-
~ c.ations contained in this Rec. test and decides whether to ins;1tute a Chow Cause prcceecing.
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i 2.
Suspend or s tay all proceedings concerning '-
Zdiscn's applications for operating licenses for the LaSalle County Nuclear Station Units 1 and 2, 'includ-ing in particular consideration if '-he granting of authority.tc begin fuel. loading and icw pcwer testing,
.unti] the Cemriission investigates the structural inta-grity of the Lnsalle Station and de termines thh ey.tedt to which corrective.mcasures will be required to eli:.i::e te a n v. ^otentially hazardous condition.
e 3.
Upon a dete.m. ination by the Cor.ission in the requested proceeding that corrective measures will ha required to eliminate such hazardous condition es may be found,. modify the construction permi'ts for Units 1 and 2 accordingly.
4 Grant a hearing in the recuested proceeding and admit Illinois as a p$rty thereto.
5.
Order such additional relief as may ba appru pr_4 ate unu.er the circumsc.ances.
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In the al ternative, if the Co:xui.ssion chooses t5 consider this Reque.st within the fra::.ework of the.pendina..
cperat nc,1 cense proccou ngs, the Corinission 1:. requested to admit !ilinois as a party to such proceedings (Docket Scs. 50-373 and 50-374) and grant a hearing therein limitad to the -.ct ters raised in this re q.:es t.
Respectfully submitted, o
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torney General of ~111::oic Of Counsel
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Chief, Envircar.sntal ' Control Division
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..ttorneys General Environ-.en ta l. Control Division l?.3 West P.andolph ' Street Sulte 23~.5 Chicaco, Illinois 60601 (3-v, 7 o. 3, n* 9,-
u Dated:
March 24,. 1982 E
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