ML20080P909
| ML20080P909 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/07/1983 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8310120099 | |
| Download: ML20080P909 (11) | |
Text
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FJCATO COER2570 C.10E
\\
L-October 7, 1983
- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMNISSION 00]g]o Before the Atomic Safety and Licensing Board.
In the Matter of
)
CLEVELAND ELECTRIC. ILLUMINATING
)
DocketNosh.$$hkNh[f;,I7 COMPANY, Et A1.
)
5 004r"
)
(Operating License)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
)
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OCRE _ REPLY 'TO ; APPLICANT AND STAFF AFFIDAVITS CONCERNING
~
THE MOTION TO REOPEN THE QA RECORD
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Ohio Citizens for Responsible Energy ("OCRE") hereby replies l
to Staff and.. Applicant affidavits' filed pursuant to the Licensing Board's August 18, 1983 Memorandum and Order (Motion to Reopen),
Applicants include in their reply an attack on the Board's action in that Order, claiming that the Board's sua sponte action has sanctioned OCRE's "tandy approach to discovery."
OCRE, while agreeing with the Board's action, takes issue with its reasoning in its denial of OCRE's motion.
The Board claims that the FOIA request could have been filed much earlier. 'The fact.is that OCRE did maks such a request months earlier, in November 1982, and the Comstock and QAAC' documents were not released ('or even identified) in response, 5
+
most_ likely because ' the documents were not yet in the Staff's 8
g Eo files.
mn O
y The Board also claims that more diligent discovery from 00 Applicants would have uncovered the Comstock concerns.
This again 8*
is. inaccurate.
The Board seems to forget that formal discovery gg ma.o closedalmohtth,eemonthsbeforeitidentifiedCEI'scontrol r
li
over Comstock as an issue to be litigated.
The 81-19 in-
.c vestigation report was issued concurrently with the close of
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discovery.
The first mention of the L.K. Comstock task force y
was made in the 83-06 report, which the Board itself found
" cryptic and unsatisfactory."
It thus seems that the Board would have intervenors seek through discovery documents which 4
they had no reason to believe even existed.
It is, of course, pg possible that the documents could have been discovered if OCRE had at least $100,000 to spend on copies of every QA-related document ever written at Perry, and 100 full-time researchers to look through the mountain of paper.
Needless to say, OCRE does not possess such resources.
[
OCRE further believes that.the Board placed an unrealistic burden on OCRE in requiring it to explain what a then-unknown
'}
writer meant by-his comments on the adequacy of the quarterly p _y reports.
LBP-83-52 at 11.
The Board also apparently misunderstooi OCRE's citation of Article 318 of the National Electrical Code.
anb.4
' *#j OCRE did not arge, as the Board claims (LBP-83-52 at 10-11),-
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that' cable tray overfill violated that code; rather, OCRE used
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the code as.an example illustrating how overfill could cause
.Wi g,;ri safety-related problems.
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p'sy('y',
With the exception of these items, OCRE agrees with the Board's.
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'n h::i$E3 Order; reopening the record is the proper action to be taken in
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lMM re,qs3 these circumstances.
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Contrary to Staff and Applicant assertions, the Board's action is sanctioned.by precedent.
See, e.g'.,. Carolina Power and b e- ?]
Light (Shearon-Harris Nuclear Power Plant, Units 1-4), LBP-78-2, h{ft; 7 NRC 83, 85 (1978) (reopening the record.may be proper even though Sq;&{
(next page) a
The affidavits submitted by both Staff and Applicants de-emphasize the significance of the inspection certification and QAAC questions.
This attitude, especially concerning the former, seems anomalous in comparison with a recent NRC order imposing a civil monetary penalty on the Niagara Mohawk Power Company (48 Fed. Reg. 40581, September 8, 1983, ottached) for a violation involving the use of uncertified inspectors (although that situation also involved the falsification of inspection documents, which does not appear to be the. case at Perry). Both Staff and Applicant imply that the final inspection at system turnover will ensure plant safety.
This attitude is not sanctioned by the Commission. See Order Imposing a Civil Monetary P'enalty on Consumers Power Co. (48 Fed. Reg. 40579, September 8, 1983): "the philosophf of inspection quality into a
the job cannot be accepted as a substitute for the philosep / of building quality into the job."-
Other than the limited comments above, OCRE has no reply to
.. h:;.: '
Applicant and Staff affidavits.
OCRE has no further evidence to present concerning the issues.
The Board will have to take the word of Applicants, who have a $5.2 billion interest to protect, and Staff, which for less obvious reasons, usually sides with Applicants to an extent that it would not be far-fetched to say they are acting in tandem.
OCRE believes that this leaves the Perry facility in a state of indeterminate safety.
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1/ continued.
the evidence to be received micht not be so
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sig'nificant as to alter the original findings or condlnsions, when the new evidence can be received with little or no burden on the parties.
To otherwise exclude evidence because the Board's 33 (next page)
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The very circumstances of the reopening of the record j
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- .11ustrate this.
The Board found that the witnesses, who
'. =s, I were sworn to tell the whole truth (Tr. 1027), in fact neglected
.);
to mention the certification of Comstock inspectors or the
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meeting frequency of the QAAC.
The Board even stated that the S,taff's testimony seemed " artfully drafted to conceal" the x.
q upl latter problem.
These circumstances corroborate the observation
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[2R of a participant in'the British nuclear licensing process,
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that "you can expect a scientist,to tell the truth, and nothing but the truth, but not the whole truth." --2/
The unfortunate fact is that witnesses will not reveal the whole truth unless it is pried out of them through cross-examination, and the resources with which to accomplish this are generally beyond
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citizen intervenors.
. 12 For this reason, OCRE agrees with Staff and Applicants that w
a a further hearing should not be held on the matter.
The purpose
- j of a hearing is t.c elicit the truth and to provide due process
~m.
for all parties.
Under the present circumstances, it could do
.s 979 N;ct QE neither.
The Supreme Court has said.that due process must occur qg in a meaningful time and a meaningful manner.
Armstrong v. Manzo, k"g g.
. ra.fl 1/
continued.
conclusions may be unchanged would not always Mio satisfy the requirement that a record suitable for review be O@bE preserved (10 CFR 2.756).
The Appeal Board has found that "f?
sua sponte reopening is required when a Board learns, from any
_jti source, of a significant safety issue.
Vermont Yankee Nuclear f'I Q$
f Power Corp. (Vermont Yankee Nuclear Power Station), ALAB-124,
->jg 6 AEC 358 (1973).
Reopening may also be appropriate when newly
4; discovered evidence tends to show that testimony in the record 6,};,
was false.
Toledo Edison Co. and Cleveland Electric Illuminating ff; Co. (Davis-Besse Nuclear Power Station, Units 1, 2,
and 3; Perry 7[j Nuclear Power Plant, Units 1 and 2), ALAB-430, 6 NRC 457 (1977).
yisi
_2/
From " Nuclear Energy: How the Odds are Stacked Against Its.
" <5 Opponents", Nature, Vol. 277, 22 Feb. 1979, 594-5.
y w.h r
3_
,e 380 US 545, 85 SCt 1187, 1191 (1965); Goldberg v. Kelly, 397 US 254, 90 SCt 1011, 1020 (1970).
Without the resources to effectively present a case (" meaningful manner"), OCRE finds that it will not have due process.
Such a hearing would not even rise to the level of CEI's word against intervenors'; it would.be CEI's against no one's, an obviously unsatisfactory arrangement when the Appeal Board has' held that,*10 CFR 2.732 notwithstanding, intervenors must essentially prove that safe Union plant operation will be compromised. by QA deficiencies.
Electric Co. (Callaway Plant, Unit 1), ALAB-740 (cited by Applicants).
Unless and until Congress and the Commission see fit to ftmd citizen intervenors, or Perry workers choose to risk their careers and perhaps their lives to make the truth known, OCRE sees no point in holding a QA hearing, which would 9
o-merely be an exercise in futility.
However, OCRE'does not condone closing the record on QA at this time.
OCRE is conducting a campaign encouraging Perry h,
workers to come forth with information; it is appropriate to s
A x
hold the record open to receive any evidence such persons may it The construction of Perry is far from complete; provide.
is likely that further QA deficiencies will occur at the plant, and that many of these will rise to a level demanding consideration One such event has recently occurred (see attached
/ by this. Board.
There is no compelling reason to close the record on
, articles).
7 at the earliest.
Unit 1 cannot load fuel until December 1984, QA.
Justice will be better served by permitting intervenors equal and uncomplicated access to adjudication until the time of fuel
' ' r' ' load, s
e w
r.
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Respectfully submitted,
+Y7 b
Susan L..Hiatt OCRE Representative 8275 Munson Rd.
Mentor,.OH. 44060 (2161 255-3158 CERTIFICATE OF SERVICE This is to certify that copies of the foregoing were served by deposit in the U.S.
Mail, first class, postage prepaid, this 8th day of-October, 1983 to those on the service list below.
M =. f / Y SERVICE LIST Peter B..Bloch, Chairman Terry Lodge, Esq.
Atomic Safety & Licensing Board McGomack, henW.
Lodge-U.S. Nuclear Regulatory Comm. 2-4-Na-ti-orra-1 Dank---Bldg Washington,'D.C.
20555 ToledogrOH-._4-3f 04-Dr. Jerry R..Kline y fg.(/.///fcg4,(,v'[7 Atomic Safety.& Licensing Board v < 7N / 05 U.S. Nuclear. Regulatory Commission Washington, D.C.
20555 g
g gg Mr..Glenn'O. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 s_-.S&W ki.h? hk
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Office.6f the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Jay Silberg, Esq.
Shaw, Pittman, Potts, & Trowbridge 1800 M Street, NW
. Washington, D.C.
20036 Docketing & Service Branch 4
Office of'the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic. Safety.&. Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission gl;y Washington, D.C.
20555 f.Q. Z
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I 4.' :, ~. fed;ral Egist:r [ Volc'48,'No.175 / Thursday, September 8,1983 / Notices 40579 I
hearing or petition for leave to intervene he entire m ting will be open to wr 202/634-1414) between 0:15 a.m. and public attenda ce.
'?li 5:00 p.m e.d.t.
6 hall be served by the requestor or p
petitioner upon the applicant, the The agenda er the. b'jec, t meetingM)U Dated: September :lf 1983.'
Executive Legal Direct r. U.S. Nuclear p
su shall be as folpwsr f*/;
gg Regulatory Commsss; n. Washington.
Thursday.Sep ember 8,1983 5:00p.m> h Af.
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D.C. 20555. The Secte ary. U.S. Nuclear
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g r1W Regulatory Commiss m and the unti/J2.Wndon.;.,.3.,,er9.1983-~8:00 a.m.'gv Friday, Septe.
,,,,,,q Executive Secretary, epartment of
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e,
.,The Subcom..ittee will continue itsg4 State, Washington,.C.20520.
review of the b salt waste isolation.;. '
Inits review of a plications for Y
project'at the H 'ord site and possibly(' Applications for 1.lcensen To Export licenses to expert roduction or Ij h
. review the DOE s site characterization y Nuclear Faclllties or Materia!s utilization faciliti =, special nuclear i
r materialer sourc material, noticed plan for the proposed ' site if it is.,,,m.d Pursuant to to CFR 110.70(b) "Pubh.c herein, the Comr ission does no, available by theh.1.w, n:..,w,c,v.krf.
notice of receipt o! an app!! cation,
evaluate the he.th, safety or All other itemp regarding this meeting.i thet the Nuclear environmental ffects in the recipient
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remain the samq as announced in the < C. please take notice
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ssion has received the nation of the f -ility or material to be I 99 Federal Registe; published Monday @, u$'.a. Regulatory Comm!
foliowing applica( ons for export exported.The able below lists a!! new h
August 22,1983 [48 FR 38123).1 c -
N; Oj Further information regarding topliis": *.
at Regulatory
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licenses. A copy o ' each application is maior applica ions.
.' 7 to be discussed,iwhether the meeting ~q. on file in the Nuc!v 4d has been cancel d orres'cheduled. thF \\ Commission's Pubic Document Room Dated this 3 day of August at Bethesda,
[g H Street. NW.,
wryland.
sent oral' statement (. 4 located at 1717
'on requests for the '
For the Nuc ear Regulatory Commission.
[
. #) Chairman's rul iWashington. D.C.
opportunity.to p )ted therefor can be 2
,,' A request for a } earing or petition for James V. zim norman.
and the time allc
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obtained by a prgpaid te!ephone call to. leave to intervene may be fil within 30 Assistant rimaornport//mport and the cognizantDesignated Federal 1.p.
days after publica ion of this notice in Internationo!Sofeguards off,ce c/
Y' Employee, Ms. R. C. Tang (telephoneudi the Federal Regispr. Any request for,
Internationo.'Proproms.
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~ ; Vf ! Docket Nos. 50-329 and 50-330: itu,ra oA '; assurance program as evidenced by Ill
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Construction Permit Hos.CPPR-81 and Mv.b numerous examples of noncompliance Upon consMeation oMonsumers CPPR-82, EA 33-03]pp.s%i..f.i/g.'. with nine of the eighteen criteria as set Power Company,a responses (March 10, q;
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. - & 6.U.Q Q forth in 10 CFR Part 50. Appendix B.
June 24, and July 12.1983) and the 4'
Crnsumers Power Co.(Midland;.g f.
. n..$ r. The breakdows' was caused by statements of fact, explanation, and L
FY Energy Center),Orderimposing'Cl41I M',p rs nnelwh faued to foUow argument in denial or mitigation k M3netary Penaltlee +ypm:. t-iW!*grirq ' 'e " mP. procedures, drawings, ar,,
contained therein, as set forth in the
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ph 5M I..Ni f.M rd.'M. hbf 'N hQ f
i b fi lint nervisors Appendix to the Order, the Director of
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g. Consumers Pow.M'"w.$'
.~.,.qp;.. speci icat ons; y rst
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.and field engirieers.who fa..ec to
, the Office ofInspection and-
'm er Company (thew,. identify and correct unacceptable work:
'"f # ** *" h "' d * <
d that th*
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" licensee")is the holder of Constructionri by construction management who failed
, ' y Permits No' CPPR-81 an'd No. CPPR-82 V to call fer quality control inspections in designated in the Notice of Violation J. [the " permit") issued by,the Nuclear ~ N'.' a timely manner, and by quaHty and Proposed Imposition of Civil w.j' Regu1atory Com.d.s's'on (t! eg,tf.m' #a.h ' assurance personnel who fai!ed to Penalties should be imposed. However, g
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%B " Commission").These Constructionvrdn and ensure that in view of the 53.500 overpayment made 0$.O Permits authorize the construction.of the <,. identify the problems.
corrective actions were taken.The NRC by Consumers Power Company in
.MN MI.These Construction Permits weredO.'.
%D Midland Energy Center near Midland -
served the licensee a written Notice of response to the January 7.1981 Notice of
.s' Violation and Proposed Imposition of Violation and Notice of Proposed
- ' ".54 isst'ed on December 15.197,2/S I. ydf,PJ Civil Penalties by letter dated February imposition of Civil Penalties, the f.
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...,.y.fb,!&s, ;g,_tt.t 8.1983.The Notice stated the nature of cumulative amount of civ'.1 penalties due prp g.
is reduced from 5120.000 to $118.500.
I q ma. "W.s. the Nuclear Regulatory O
As a r[ suit of a specialinspectie of c ssion s yequirements that were j
M the lice isee's facihties by the Nuclear 4,
i 7.N, ' Regulatory Commission's Region III.WC; vi lated, and tne amount of civil penalty I
office during the period October 12 !,g'; Pr Po' sed for each violation.The In view of the foregoing and pursuant November 25.1982, and on January 19D. licensee responded to the Notice of to Section 234 of the Atomic Energy Act f
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21.1933, the NRC Staff determined thath. Violation and Proposed imposition of of 1954, as amended {42 U.S.C. 221:2.
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a breakdowh had occurred in t'hed m..a*%. CMI Penalties with letters dated March Pub. L. 9S-295), and 10 CFR 2.205 it is Implementation of the Mid!and quakity.c.
- 10. June 24. and July 12,1983.
hereby ordered that:
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Feder:1 Pagistir / Vol. 40. No.175 / Thursday. Septernber 8.i1983TNotices
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6 40580
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The licensee pay civil penalties in the total item B-Statement ofNoncomp!ionce mW \\ ' design requ!rements as committed to in 0
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'. FSAR. (See item 2.d.) -
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Q 1d, amount of One Hundred Sixteen Thousand 10 CFR 50. Appendix D. Criterion II This is a Severtty LevelIII violation requires holders of construction permits for Fise Hundred Dollars within thirty days of the date of this Order. by check, draft, or nuclear power plants to document. by written; g(Supplement II) (Civil Penalty]-.500.000) i ~
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United States and mailed to the Director of niisurance program which complies witn the. y. The licensee admits that with the excer money order payable to the Treasurer of the policies. procedures. or instructions a quality.?, ye,o,,,,, g,,pon,, go gA, yjoforjon p 6
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the Office of Inspection and Enfcrcement, requirements of Appendix B for all activities. f J
of portins of examp es B.I.a and B.1.f, ta j
(JSNRC. Washington. D.C. 20555.
affecting the quahty of safety.relsted structures, systems, and components and to, J violation occurred as stated in the NOV.
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implement that program in accordance with jNRCEvoluction
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i ' CoMerding.ex'a'mple B'1:a..'the ll) ens
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The licensee may within thirty dcys of Contra ot above. Consumers P er tJ contends that since the inspection reecrt f
c.4 the date of this Order request a hearing.
Company and its centractor did not s
J
, A request for a hearing shall be adequately implement a quality assurance M. ; panels 1C-111.1C-uz. 2C-111. and 2C-r
.'t addressed to the Director. Office of pregram to comply with the requirements of :
' were open with attributes such as washe:
and torquing not yet inspected. the penic' Y
I, Inspection and Enforcement. A copy of Appendix B as evidenced by the following 7.
i n; 9 the hearing ' request shall also be sent to examples:
the nucompliance pennining to nat was 4
- 1. to CFR 50. Apendix B. Criterion Vd ' "( ' was not a violation.The licensee a posa
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the Executive Legal Director. USNRC.
requins. In part. ** Activities affecting qualf ty,
. that open inspectica records can negate :
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Washington.D.C.20555.If a hearinE s failure to install the required flat washe i
shall be prescribed by documented
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requested. the Commission 'willissue an instructions procedures, or drawings of a,'ii.
' unacceptable.The philosophy of inapecti.
jw Order designating the time and place of type appropriate t'o the circumstances and he i rquality into the job cannot be accepted e
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hearing. Should the licensee fail to shall be accomplished in accordance with a f. substitute for the philosophy of buildir@
5,.y request a hearing within thirty. days of these instructions. procedures, or drawings."i I ; quality into the job.The license (ad=ity N
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Consumers Power Quality Assurance
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- remaining portion.cf the violation,which' the date of this Order the provisions of.. Program Policy No. 5. Revision 12. Paragraph deals with the omission of bevel washed D
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this Order shall be effective without 14 starn. in part. " Instructions for cetm!!ing i.Concerning example B.I.f 'the lic.ensep further proceedings and. if payment has end performing activities affecting quality of. ; contends that. centrary to the Not;ce of-
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h not been made by that time. the matter equipment or activities such as.... 'sjea *, Violation, all steelin the "Q' 4reawcs "
rnaY e referred to the Attorney General construction, installation... are. ' J1 # '. identified in accordance with procedurei
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documented in instructions. procedures.. [trcanufacturer's mark
- .Thelicensee contends that some J.,
for collection.
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and other forms of documents."
In the event the licensee requests a~
Z hearing as provided above, the issues to Contrary to the above the fo!!owing
? iconfusion. At the time of the NRC inspec
,g A
f be considered at such a hearing shall be: instances of failure to accomplish activities.-r the inspectors observed yellcw. colored )
..t affecting quality in accordance with m ) on steelin the "Q". area.This condition..
1 :
(a) whether the licensee was in instructions. procedures, specifica tions, or
.. stated in the Notice of Violation,is contr.
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e 5'#4 'L o the re3uirements of FieldInstruction F violation of the Commission,s drewing requirements were identified: '
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requirements as set forth in the Notice unstaliation of diesel generator engine? '19.000. Revision i. The licensee's content-2Cu2 was not in accordatee with the..i;.w].: qmanufacturers do control panels ICni.1Cuz. 2 Cut, and M*
th t this paint was applied by,some N
?".2 jg j of Violation and Proposed Imposition of Civil Penalties referenced in Section 11 AM
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Drawing 7220-M18-250 in that the foundation hSite quality control requirements delineated on foundation -
f Mi above, and
! detected the nonconferrr.ing paint and-
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(b) whether on the basis of such bolt washers required by the subject drawing 7. initiated proper corrective' actions. The :
5 4+{8 violations this Order should be were n t installed.
.n' 11icensee admits the remaining portion of g*
1.'
sustained.
[ Items B.i.b through B.1.e are not restated... Aviolation which deals with the marldng o
- f. The inspectors identified various stock,g,f. steel in "non-Q
' here.)
'j h Dated at Bethesda. Maryland. this 29th day 2.N N.
of August 1983.
steel shapes in the "Q" area with yellow.y Cenclusion,,,,. 4 4gggg.S
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For the Nuclear Regulatory Commission.
colored paint on the ends (indicating the i..
These violations did occur as origmal 1
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y Richard C. LeYoung.
material was non "Q") and various steel..aq. j otated.The information'in th' licensee's e
h@'.
P
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Director. Office offnspection ond stock shapes in the non "Q" area withoutgy\\. response does not provid M
3 Enforcement.
painted ends (indicating *Q" material),.Q modification of the enforcernent action.'
g< $
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contrary to the requirements of Field " ' W \\ Licensee's Requestfo o
o Appendix-Evaluations and Conclusions Instruction FIG-9.800. Revision 1.
' PNllf" #Y'7,'.$.;, Y 7
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. Th'e licensee admits violation A occurrred
[ Items B.I.g through B 8 are not restated
, as stated.The licensee also admits violation here.)
.P $.. Thelicensee statu thatit does not cc; CT Q
'. n! the validity of the violations and agrees MD, AC B occurred, but takes exception with portions Contrary to the above:
+
- a. Measures were not established or=... J a civil penalty is urranted, but bebeve, Vaf i ? bI of examples B.1.a and B.1.f. Although the heensee admits the two violations, the implemented to determine if materials certain mitigating facters should be* "-
ultimately restricted [per Nonconformance,.,, : considered. Specifically, the licensee be v
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licensee requests that certain mitigating Report No. 320e) from installation or use in mitigation is warranted on the basis cf !
ASME Class ! systems were actually [ ] ;1 / corrective actions. o
- Y 5 bl factors be considered.
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The particular portions ofitem B of the Insta d
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4Evclu'dtion of, Licensee' ire [sponse3 ass 1
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Notice of Violation l dated February 8.1083).
9 9
o which were denied by the licensee, are nonconforming conditions identified by the.
The licensee's corrective actions'are m.,
restated below.The Office ofInspection and NRC on October 12.1982, and confirmed by., recognized as being both comprehensivi gs i,
Enforcement s evaluation of the licensee,a the licensee on October 19 and 25.
far reaching. However, given the naturs
,4,.<~; g ; yy response is presented, followed by respectively, had not been documented on a.
severity of the noncompliance'identifec g-y g g y!*
conclusions regarding the occu rence of the nonconformance report, a quahty assurance *. during the diesel generator buildmg i, r, cXp O,
noncompliance and the proposed civt!
report, cr other apprcpriate report.The two =
inspection and the history of the qdalft;
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.{ j penalty. In addition, the licensee's requent for nonconforming conditions were:
T ' assurance program implemented et the jj; reduction of civil penalty is summarized (1) The diesel generator exhaust hangers
- Midland facility, the actions are no(y below.The Office of Inspection and were not classified, designed, or built as "Q"< ' unusaa!!y extensive end. under the..
'N*
jr
. w.-
,d,
Enforcemenre evaluation of thelicensee's as committed to in the FSAR. (See item 2.c.).. circumstances, do not warrant mitigatic f,E'* sqj request is presented followed by conclusions (2) The design of diesel generator monorail eddition, we perceive the issuance of -
,g
,l regarding the proposed civil penalty.
was not analyzed to seismic Category I
- nonconformance reports in March 1923
,,M,
- 'N$.ig,
^
.Mi
- f3 *
. L.y
.:r
' i E.p,Q. f
#~2M;'*f,#*(") *g 5 l'"'. modified droft (Rev. 2. dated May 16,
' 1983). Comnents received by the 19ft3 to the Notice of violation and y } onclusidif.%'atioIl b5e'Ic'erise*e's~rkguest}
' j[IJ The inforS Director. Office of Nuclear Regulatory Proposed Imposition cf Civil Penalty Research, U{S. Nuclear Regulatory was received from the licensee.
r, isen not provide a basis for reduction of them; (y'g
.roposed civil penalty. y; n,,1..,.,,..,.,..p:,
Commission Washington, D.C. 20555, by III a,.* I. n ow. 33-avia rild w-eE sis.W.n.W.
3 ttih. October 21, y983, will be particularly h
.gM ; wwo coot mo-ci-u :< i.', u...#-Jo.W": useful to the p.S. representatives to the Upon consideration of the answer t.
...m. : m.s., Technical Re few Committee nnd the received and the statements of fact,
- y-;3 s
., s
.y
,. r
.4
't Senior Advis ry Group in developing explanation. and argument for p u, gp taternational Atom! Energy AgencyC heir positic cn its adequacy prior to mitigation of the proposed civil penalty t
g,.y Draft Saf ety Gulde; vallabillty of Draft' their nextl " meetings.
contained therein, and for the reasons
,,. ; Gy Single copi s of this draft Safetyset forth in the Appendix to this Order, ior Public, Comme 7.. g Qdgi
.TheIfit'e'rnatiosa AtoYiYEnergygm.p uide may be obtained by a written the Director of the Office of Inspection
&y' #. Agency.(IAEA) is trector, Office of Nuc! ear and Enforcement has determined that inpleting p:g cagg.. request to the i
arch. U.S. Nuclear the penalty proposed for the violation.
%d development of.a r umber of,Lhn:a. Regulatory Re mternationall/ acceptable code's ofifvhn. Regulatory Co mission, Washmgton, designated in the Notice of Violation hp:} > ytactice and safet)guides for nucleartf. D.C. 20555, and Proposed Imposition of Civil Penalty should be imposed.
[, M'b, power plants.The!
e codes and guidesW. (5 3.f.S.C.522(a))
mp.-
,tre in,the following five areas:-
9.;
Dated at Washington. D.C. this 1st day of Il,
- 6 Government Orgardzation, Desigt't. W*i September 19c3.
. For the Nuclear 3egulatery Commission.
In view of the foregoing and pursuant d-1 Siting, Opera' tion.dd Quality '.',*T,"Ef)) / Robert B. Minogue to Section 234 of the Atomic Energy Act Assurance.jAllof the codes and most the proposed safety guides have been.m ' Director. Office of.'uclearResulatory of 1954, as amended (42 U.S.C. 2282, h Ng,
e.
ose of these codes:,% Research.
Pub. L 90-295), and 10 CFR 2.205, it is
@m completed The pW - countries beginning uclear power,.%@74 ewwo coo y
Qg.md guidesis to pro ide guidance to ;,
p on.ama na w.as. s o.ml hereby ordered that:
Theb.censee pay a cml penalty m the kg% programs.'.p t.wm3 fd;my :.t. vt:
k-Nima; amount of One Hundred Thousand Dollars
,i;g.J.C The IAEA codes o, practice'ariddbly;{g (N eloped in the'76e Docket No. 50-410, Construction Permit
($100.000) within thirty days of the date of 2
g. v -..
8d$M. safety guides'aie dev this Order, by check, draft or money order, M.
G. A receives'and ly o.CPPR-112 and EA 83-161 payable to the Treasurer of the United States id t---@S[:
ggi;g collates te7ev. T.he.,Ltmg information h y Niagara Mohawk Power Corp.(Nine and mailed to the Director.of the Office of following way.t exu y w..... e.. '
an ggk.; used bymember coultnes m a specifiedstartmg pomt an,lAZA wo d Mlle Point, Unit 2); Order imposing a inspection and Enforcement. USNRC g
safetyare,a3Usin'g th a collation as ag.P
. Washington D.C. 2c555.
@:g p
q gg a few experts devel(ps a prehmmary,lg. I y
m q,.,
i.;-w draft of a code or sej ety guide which is" ; Niagara Mohawk Power Corporation The licensee may within thirty days of yif 'then reviesed and odified by.an IAEA Y,(the " licensee") is the holder of the date of this Order request a hearing.
[5D TechnicalReview ommittee w.it.
- 2 Construction Permit CPPR-112 issued by A request for a hearing shall be m?
c corresponding to't specified'ere'abTh'e C the Atomic Energy Commission, now the addressed to the Director, Office of tidraft codeof pract e or safety guide is % Nuclear Regulatory Commission ("NRC.,
Inspection and Enforcement. A copy of
'Sinfor Advisciy'tK s and mo'difies as W.or" Commission"), which authorizes the the hearing request shall also be sent to
' ' then'sent t'o the-4/# e CrotiF*hiEh'rdvi licensee to construct Nine Mile Point, the Executive Legal Director, USNRC,
[S J necessary tN'dfa sif all' codes and Ni Unit 2in Oswego County, New York.
Washington, D.C. 20555. If a heermg is YM guides prier'td'th ir being forwarded toh The Construction Permit was issued on requested, the Commission willissue an Da the IAEA Se'ciet in't and thence to t!ie.,A Order designating the time and place of
[@ Y Taking into account the comments '.@fie[l June 24,19'4.
bM 1AEA Mehiber St tes for comments. - -
a.
hearing. !f the licensee fails to request a
- II#aM -
,tF
~
hearing within thirty days of the date of e Member States, thel.6.?.
'An' ins'pection'of the licensee's this Ordtr the provisions of this Order
" received from th W d Sehlor Advisory Group thin modifiesMi activities under the permit was shall be effective without further the draft as necessary fo reach :i.e;n.- ; conducted between August 30 and proceedmgs:if payment has not been
),hgg 5%g agreement befop^ forwarding it to'the-r September 30,1982 at the Nine Mile made by that time, the matter may be Qh IAEA Director ueneral with a /
<":1 Point Nuclear Station, Unit 2 in Oswego referred to the Attomey General for M
fthit it bela'cc5tedW0,' County, New York. An investigation col:ection. In the event the licensee
~
f"",*?$
recomme'ndatic As part.of.this program, Safety Gu'id5M was also conducted at Nine Mde Point
'MM SC-D13.."Reacior. Cooling Systems in Nuclear Station, Unit 2. on November 1-requests a hearing as provided above,
[f.yf Nuclear, Power )lants." has been t!.j. N[$ 4.1982. As a result of the inspection and the issues to be considered at such 3,d develop'ed.The working Froup..,l1.."Y did not conduct its activities in fullinvestigation it appears that th herring sha!! be:
u (a) whether the licensee was in W W.9 consisting of Mt. G. Ellia from France:
br$
Mr. C. N, Bapat from. India:.Mr. P. C.as:6 compliance with NRC requirements. A violation of the Commission's f.3 Dannatt from th = Unted Kingdom; and etr written Notice of Violation and acquirements as set forth in the Notice 4[M, of Violation and Proposed Imposition of C
Mr. W.H D*Ardenne (General Electricy, Proposed Imposition of Civil Penalty
[
Companyl from ho U.S.AJ developedf ^ was served upon the licensee by !etter Civil Pena!ty referenced in Section 11 c
-- A M ih. initial draft c'f tais guide from an. d% dated April 26,1933.
above,and JM
^Q 2'
3 ny
,A.' 3
M.M M &.
.;.v ' ' si.
y
s s
n 40582 Fed:ral Regishr / Vol 48, No.175 / Thursday, September 8,19831 Notices ~
i
~_J ',
d p-(b) whether, on the basis of such furnish evidence of activities affectmg "althcugh'not preperly certified inspectors, d.
vic!stions, this' Order should be
- quality, may have been qualified individuatscThe r 4
1i sustained.
H wever. Stone a Webster Level H quality - staff also reccgnizes that the practices -
V W
assurance inspectors signed several
... involving use of trainees and falsifyingi g*
Dated at Bethesda, Maryland this 24th day inspection reports ind:cating they had
,, ' records were not 6tected by NMPC or SWCC of August 1983.
performed the inspection when,in fact, the upper management, but ' hat supemscry h
For the Nuclear Regulatory Commission.
inspections were performed by a trainee.
' involvement was limaed to the first and,'..
K Richard C. DaYoung, Etone a Webster's first and second line
'1 second !!ne supervisors within SWEC, The Director. Office of/nspection and supervision was aware of this practice, but H staff agrees that there was no ind: cation t.%:t.
'a L,.
En/virement.
did not taae action to discontinue it.
""W the violation occurred in aoy,other area
,N This is a Severity Level III violation -
l.
4 except the electrical FCC gmup.The NRC-,
p y./
Appendix-Evaluation and Conclusion (Supplement ll) Civil Fenalty-S100.000,..T staff further acknow: dges that f ts inspeeden p
The violation and associated c:vil penalty Summary ofLicensee Response d.n and invest:gation did net indicate that theme
,)
identified in the NRC's April:6.1983 Notice v ' pr.ctices resulted in cens'.ructiona x_..
s of ViMation and Proposed Imposition of Civil By letter dated June 30,1983, the hcensee defmie;-d m.
.r
-I-'
S ~...
Penalty is restated, the licensee's response is.
admits that espections were performed at :
[ ?[$l summarized, and the NRC's evaluetton and Nine Mile Pcmt. Unit 2. by uncertified
- ,.. Nonetheless, the staff ma!ntains'that the "
signif cant cencerns in tbs caso are the fuc:s,
in conclusion regarding the licensee's response trsmees who were not accompanied by Level,'
that:(1) Contractor trairees performed :
{-
,,i are presented in this appendix.The hcensee's '
Ilin8pectors and that the LevelIIinspectors who were supervising such trainees indicated, inspections that they were
- I responne was provided in a letter dated June
. perform:(2) LevelIIinspectors signed > ~
~
Q 30.1983. from Cerald X. Rhode, Senior Vice acceptance of the inspection results by co..;
4, President. Niagara Mohawk Power signmg and initialing inspection reports. Thegl.. inspection reports indicating they an inspection when in fact the inspection was
,J Corporation (NMPC), to the Director, Office beensee states that the LevelIIinspectors 21R performed by an uncented trainee: and (3F g
of bspect;c n and Enfercement. The NRC believed that the trainees were quah!:ed, tog g g g
,g gt staff evaluatien and conclusion are based on perform the inspect 2cn tasas.
g.
m tidh mh h~ -
[
the June 30,19B31etter.
The licensee states that its own mvestigation, and an investigation by SWEC,p M
sM6s d b. M. hs-A also aware cN..s practce,yet nper ~
%M Statement of Violation revealed that the inspectors were adequately m
g GI 10 CFR 50. Appendix B requires that each qualified and tramed individuals, but were
% supusor took act2on to discentcue the.;,
licensee implement a quahty assurance not cert.fied because they had not completed practice.L,:censees are responsible fer 3
g,,
b
, M program to be applied to the design, the three month period of working
'i assuring that inspecticas are properly ; g*
fabrication construction and testmg of the experience.The bcensee also ind: cates that d performed by certi5ed mmuels that_s Ib records of inspections accurately reflect the ll-
!.l structures, systems and cornponents of the such qualification is evidenced by the fact fa cility.
that all the trainees were subsequen+,
+1 work inspected and the mdividual perforr.mg I
Contrary to the above. the licensee did not successfuDy certified upon completion of As s that inspectiert and that such inspection ; -
d.
comply with the provisions of Append:x B for experience requirements. However, the
- d. activities are properly supervised. ' W,::
il the period June 1 through September 17,1982 licensee acknowledges that it was imprcper Although a 540.000 civil peoalty is the base as evidenced below:
to use these trainees to perforrn inspections.M, arnount for a Seventy levelIII violation, the,
r.
i A. Criterion 1 of Appendix B requires the The licensee claims the false records were0! staff has deterrined to impose a civil pena!ty ;
d h
establishment and execution of a quality the result of.rnisunderstandings in connection., cf $100.000 to e=phasize both the seriousness.
with SWEC's FOC procedures rather than' M of falsificatio
'11 assurance program which assures that iU) activities affecting safety-related functions intentional falsihcotion of documents, but thel supervision's awareness of a practice I.,,,s.
h Iti.
have been correctly performed. Niagara licensee acknowledges the seriousness of. 7, involving falsification and their failure los; M
Mohawk power Corporation's application for false records under any circumstances.
', take action to discontinue this practice."'.',
UlD
- # OP *PN '
a Construction permit for Unit 2 commits to The hcensee requests reduction of the ~[r '1
<"*WWF 1
adherence to ANSI N 45.2b-1978.This
'N{.
proposed civil penalty from S100,000 to il standard requires that each person who
$40,000, claimmg that amount is
,g
' Itis ' iolation did occur as o-igirally stated. The violation is appropriate 3yc:j v
rd verif es the conformance of work activities to commensurate witn the findings of the d
=
nr T
quality requirements shall be certified by his
^
investi ation as a Severity LevelIII violation.7 classified a t Severity Iesel IIl and VJ.%r 2
(
6 employer as being qualified to perform his The licensee provides the following bases for!,1 assessment of a $100.000 civil penalty'is Mit.!
N i a.
assigned work, and the period of certification mitigation: (1) The deficiencies noted did not [ } appropriate in this, case because it involves.,G I.*
shall be established. ANSI N 45.2.6-1978 also involve inspections which were not
@ \\ fals!Deation cf records under circumstances.c.
' performed, attempts to conceal unacceptable'.0 'practicwhere requires a Levell rating classification as a prerequisite for inspecting and accepting work, or misrepresentation of the quality of
- e. and failed to take approp-iate action h,
safety-related installations. Stone & Webster ccnstruction a t Nine Mile Point. Unit 2: (2) the ! to discontinue it. The information is the '.'.;
rd Engineering Corporation (SWEC) Quality reinspectien work which was performed licensee's response does not provide a basis ;
p Assurance Directive (QAD) 2.5, Revision F.
demonstrated the problem did not result in for rnodifying the proposed enicreement q' '
. -d allows trainees possessinF Associate Degrees construction deficiencies:(3) neither NMPC -. action. Js " '
MN9M -
m ;
to be certified as Levellinspectors after a nor SWEC management, with the exception.
of the first ime supervisor and possibly the.,,;, :p Ess-use ra.d e-t-ata4s
'Y l;s three month training period provided the a:Liawa coot 7sso-e644W dWNW.b
' p, trainees work under the direct supervision of second line superviser, were aware of the
.; e cy o -o
.'t j higher level personnel capable cf performing existence of these practices prior to NRC ' '/
assigned tasks.
investigation, and demonstrates that both
..n~
~
t' g,
However, numerous safety related NMPC and SWEC management attempted t - OFFICE OF MANAGEMENT'AND.NO 9
electrical mstallations (involving stud-provide proper d:rection regarding the g
g*,
q
. welding, embedments, supplemental steel, manner m which inspections were to be Ih,
cable, raceways. welding, and raceway conducted and documented; and (4) the W.
.9--
u
-~ -
12k,b.'
supports) were inspected by Stone A Webster licensee's investigation mdicated that the.
Amendment to OMB Circu!ar
(
g hw * ;i l personnel classified as trainees with problem was hmited to the electrica! Field
" Prompt Payment,, Opportunity.forg,,',
m h
b Associate Degrees. Installations inspected ny Quality Control group and did not reflect an. Comment ? Qgd g gg,y gg F: q Q.
these trainees were accepted by Stone 4 across-the-board deficiency in NMPC's w AGENCY: Office of Management anMM p
g.
Webster even thougn the trainees were not quality assurance program.
Bud et U T 'N
"; d
- W:f##
r"'
certified because they did not possess the E
L f,j k-requrred three months inspection experience.
N/IC Eucluation of Licensee Response
. d,
.s LA y
I f'
B. Critenon XVII of Appendix B requires,in The NP.C staff acknowledges that the '
ACDON: Comment on proposed'OMB ' '
r part, that sufficient records be maintained to trainees who performed the inspections.
' ',.,.T ' '
circular amendment.
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he accident occurred when workersy: somef darnage to 'the'jysteam 'sep'arator; *.
. Workers were'doing r..outine'maliite.' f ked a giant crane to 'the; reactor's'u;'. core tirea."R.'/L;;gy. 4 : l W.'g i. cap, then tried to lift out the s' Right below the steam separator is the-nance when they lifted off the reactor's. 4 -
m separato'r', which sits #n;to'p,0f,$
core, and' tried..to choist.it otit'W WiWM?h.0< p d
- '. '/.'t i.. "9 '
t iout unt'olting it fro'm the reac' lor'sMk full #! 'Ml:.e 4"WG.Y ;. separator.. The
6' Ir walls, 1Icf fne'r'said.' W. saf' tyPl.t A., l not be avadable for as long hs '
v.' feet high, Ifcffner sa,id. '.
e assessment.of damages and
~
?..
,}.:f,;..p'V hanism o'n the ciane called a '.' jig'?A.. costs.wd itually t' rip' ped, Icausing" the ' preim twp,l.wec,ks' but ' CEI. hopes.the.,
Ifcffner said he does not knoir e to stop, but not before 'the'cranei.. construction. schedule,.which has been which worker or group of workers is -
iaged,Ileffner said.h. par'ator/werei./ elayed many times, will not be setZ.-lK.E 4,.. bac c d
jig and the steam se respor,isible for the accident butihat'is bemg mvestigated.
, An:yllU". l.%G[W, K the,first of two reactors being bu,ilt at:
d q,
~
W~.T.
l.'M
'M j; the plant. The first reactor is scheduled -
"There is some check'ing being done' '
; (.
They 'werel.flifting -(the c steam.4.to. be loaded with. fuel in D'ecember to find out exactly what is taking Irator). out ' rand ~ they Qhad. ' 1984 and begin operating in mid-1985.
place," lieffner said. "Apparently, 'i rlooked its' being. bolted down,"E. The ~ second ' reactor 1 would. not jbeu they jiist overlooked something. I i' Tfner said.."It,;ap;iarently caused.. operated until mid-1988.
% don's know who it has.",
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