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,
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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
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over Comstock as an issue to be litigated. The 81-19 in-
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.c vestigation report was issued concurrently with the close of 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 $100,000 to spend on copies of every QA-related document ever written at Perry, and 100 full-time researchers to look through the mountain of paper. Needless to say, OCRE does not possess such resources.
[ OCRE further believes that.the Board placed an unrealistic burden on OCRE in requiring it to explain what a then-unknown writer meant by-his comments on the adequacy of the quarterly
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p _y reports. LBP-83-52 at 11. The Board also apparently misunderstooi OCRE's citation of Article 318 of the National Electrical Code.
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OCRE did not arge, as the Board claims (LBP-83-52 at 10-11),-
that' cable tray overfill violated that code; rather, OCRE used
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the code as.an example illustrating how overfill could cause
.Wi safety-related problems.
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. x . t, . 'n p'sy('y', With the exception of these items, OCRE agrees with the Board's.
. :~ :4 h::i$E3 Order; reopening the record is the proper action to be taken in m4 1/
lMM re,qs3 these circumstances.
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i[ K 1/ 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.
the evidence to be received micht not be so
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1/ continued. ~
sig'nificant as to alter the original findings or condlnsions, when the new evidence can be received with little or no burden 33 on the parties. To otherwise exclude evidence because the Board's (next page)
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j The very circumstances of the reopening of the record
.x t ;.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
.gp meeting frequency of the QAAC. The Board even stated that l:[.. . '
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,
$[h~ that "you can expect a scientist,to tell the truth, and nothing but the truth, but not the whole truth." --2/ The unfortunate fact is that witnesses will not reveal the whole truth unless it is pried out of them through cross-examination, and the resources with which to accomplish this are generally beyond
- c. - citizen intervenors.
. 12 For this reason, OCRE agrees with Staff and Applicants that a w a further hearing should not be held on the matter. The purpose
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- j of a hearing is t.c elicit the truth and to provide due process
.s-for all parties. Under the present circumstances, it could do 979 N;ct QE neither. The Supreme Court has said.that due process must occur qg in a meaningful time and a meaningful manner. Armstrong v. Manzo,
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.fl 1/ conclusions may be unchanged would not always continued.
Mio satisfy the requirement that a record suitable for review be O@bE preserved (10 CFR 2.756). The Appeal Board has found that "f? sua sponte reopening is required when a Board learns, from any
_jti source, of a significant safety issue. Vermont Yankee Nuclear f'If
->jg Q$ Power Corp. (Vermont Yankee Nuclear Power Station), ALAB-124, 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.
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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 9
' known, OCRE sees no point in holding a QA hearing, which would 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,x - s workers to come forth with information; it is appropriate to A
- hold the record open to receive any evidence such persons may The construction of Perry is far from complete; it provide.
' is likely that further QA deficiencies will occur at the plant, and that many of these will rise to a level demanding consideration
/ by this. Board. One such event has recently occurred (see attached .
, articles). There is no compelling reason to close the record on 7
Unit 1 cannot load fuel until December 1984, at the earliest.
QA.
' Justice will be better served by permitting intervenors equal and uncomplicated access to adjudication until the time of fuel
' ' r' ' load, s ,.
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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 U.S. Nuclear. Regulatory Commission ,
v < 7N / 05 Washington, D.C. 20555 , g g gg Mr..Glenn'O. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 hk s_-.S&W ki.h?%
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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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40579
'.: 4 .' :, ~ . fed;ral Egist:r [ IVolc'48,'No.175 / Thursday, September 8,1983 / Notices ,.
I he entire m ting will be open to wr 202/634-1414) between 0:15 a.m. and hearing or petition for leave to intervene
'?li 5:00 p.m e.d.t. 6 hall be served by the requestor or p public attenda ce. -
petitioner upon the applicant, the ;
The agenda er the su . b'jec, t meetingM)U Dated: September :lf 1983.'
Executive Legal Direct r. U.S. Nuclear p shall be as folpwsr f*/;
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Regulatory Commsss; n. Washington.
- " " ' "E ""' D.C. 20555. The Secte ary. U.S. Nuclear Thursday.Sep untillamp. ...... .. ember .u. . .c ... , 8,1983
.u . i. 5:00p.m>
g "), h Af. Regulatory Commiss m and the Friday, Septe. r1W ,,,, ,,,,,,q ,,
unti/J2.Wndon.;. , .3.. ,,er9.1983-~8:00 Executive Secretary, epartment of e , a.m.'gv
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. n .,: r State, Washington, .C.20520. ,! ;
.,The Subcom. .ittee will continue itsg4 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
. review the DOE s site characterization y Nuclear Faclllties or Materia!s utilization faciliti =, special nuclear i h '
plan for the proposed ' site if it is r .,,,m.d .
materialer sourc material, noticed available by theh.1.w , n: ..,w,c,v.krf . notice Pursuant to to CFR 110.70(b) "Pubh.c herein, the Comr ission does no, ,
of receipt o! an app!! cation , evaluate the he .th, safety or
. .s All other itemp regarding this meeting .i thet the Nuclear ;k remain the samq as announced in the < C. please take notice environmental ffects in the recipient M J. ssion has received the nation of the f -ility or material to be 1 I 99 Federal Registe; published Monday August 22,1983 [48 FR 38123).1 c -
' foliowing @, applica( u$'.a. Regulatory ons for export Comm! exported.The able below lists a!! new licenses. A copy o ' each application is h
N; Oj Further information regarding topliis": *. maior applica ions.
.' 7 to be discussed,iwhether the meeting ~q . on file in the Nuc!v at Regulatory Dated this 3 day of August at Bethesda,
. [.,
ic Document Room [g 4d has been cancel d orres'cheduled. thF \ Commission's H Pub Street. NW., wryland.
. #) Chairman's rul 'on requests for the ' iWashington. D.C. For the Nuc ear Regulatory Commission.
sent oral' statement (. 4 located at 1717 for a } earing or petition for James V. zim norman.
['
( opportunity.to and the time allc p )ted therefor can,,'be 2 A request
'.. obtained by a prgpaid te!ephone call to . leave to intervene may be fil within 30 Assistant rimaornport//mport and Internationo!Sofeguards off,ce c/
Y' the cognizantDesignated Federal 1.p. days after publica ion of this notice in Internationo.'Proproms.
Employee, Ms. R. C. Tang (telephoneudi the Federal Regispr. Any request for ,
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-y weswiyame Elecvt co'. .II#r29,1983.* Auft5., 294.50011.480 f g
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~ ; Vf ! Docket Nos. 50-329 and 50-330: itu,ra oA '; assurance program as evidenced by
.MR. Construction Permit Hos.CPPR-81 and Mv.b numerous examples of noncompliance .
Upon consMeation oMonsumers CPPR-82, EA M Power Company,a responses (March 10, q; k
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...,t,- . - &33-03]pp.s%i..f.i/g.'.
6.U.Q Q forth within 10 CFR nine Part of50.the eighteen Appendix B. criteria as set June 24, and July 12.1983) and the L
Crnsumers Power Co.(Midland;.g . n ..$ r . The breakdows' was caused by statements of fact, explanation, and 4'
FY Energy Center),Orderimposing'Cl41I M',p rs nnelwh faued to foUow argument in denial or mitigation phM3netary Penaltlee ..v. . . . . c. +ypm:. t-iW!*grirq ' 'e " mP. procedures, drawings, containedar,, therein, as set forth in the b fi lint nervisors hbf 'N hQ .$'
f i Appendix to the Order, the Director of .{~
5M / An .~.,.qp;...and speci icat ons; yfa..ec rst to
'm g . I..Ni Consumers f.M rd.'M. Pow.M'"w field engirieers.who er Company (thew, . identify and correct unacceptable work:
, the Office ofInspection and-
'"f # ** *" h "' d * < d that th*
9 " licensee")is the holder of Constructionri by construction management who failed
, ' y Permits No' CPPR-81 an'd No. CPPR-82 V to call fer quality control inspections in designated in the Notice of Violation ',
J . [the " permit") issued by,the Nuclear ~ N'.' a timely manner, and by quaHty and Proposed Imposition of Civil w.j' g Regu1atory Com
%B " Commission").These Constructionvrdn
.. .d.s's'on i . (t! eg,tf.m' #a.h ' assurance personnel who fai!ed to Penalties should be imposed. However, and ensure that in view of the 53.500 overpayment made 0$.O Permits authorize the construction.of thecorrective <,. identify the problems.
actions were taken.The NRC by Consumers Power Company in
%D Midland Energy Center near Midland - served the licensee a written Notice of response to the January 7.1981 Notice of -
.MN MI.These Construction Permits weredO.'. .s' Violation and Proposed Imposition of
- f. isst'ed on December 15.197,2/S I. ydf,PJ Civil Penalties by letter dated February .
Violation and Notice of Proposed
- ' ".54 G y - 2 ,.. a- . . imposition of Civil Penalties, the prp g. .. .. .,.y.fb,!&s, ;g,_tt.t 8.1983.The Notice stated the nature of cumulative amount of civ'.1 penalties due !
- is reduced from 5120.000 to $118.500. I O As a r[ suit of a specialinspectie of c q ma.ssion "W.s.
s yequirementsthe Nuclear that were Regulatory 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 In view of the foregoing and pursuant I U office during the period October 12 !,g'; Pr Po' sed for each violation.The November 25.1982, and on January 19D . licensee responded to the Notice of to Section 234 of the Atomic Energy Act f T J': of 1954, as amended {42 U.S.C. 221:2.
7 21.1933, the NRC Staff determined thath. Violation and Proposed Pub.imposition L. 9S-295), and of10 CFR 2.205 it is f r
^
a breakdowh Implementation of the had Mid!and occurred quakity.c. in June
- 10. t'hed m..a*%.
- 24. and July 12,1983. CMI Penalties herebywith ordered letters that: dated March l' 4r d* J e d :. :d g.e n g n .,' ,
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6 40580 Feder:1 Pagistir / Vol. 40. No.175 / Thursday. Septernber 8.i1983TNotices y ;p f
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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 1 p*', -: ' '. FSAR. (See item 2.d.) -
. C, -
Q 1d, amount of One Hundred Sixteen Thousand Fise Hundred Dollars within thirty days of 10 CFR 50. Appendix D. Criterion II requires holders of construction permits for .
This is a Severtty LevelIII violation i ~ the date of this Order. by check, draft, or nuclear power plants to document. by written; g(Supplement II) (Civil Penalty]-.500.000) j('j- ,,
money order payable to the Treasurer of the policies. procedures. or instructions a quality.?, ye,o,,,,, g,,pon,, go gA, yjoforjon p6 '
United States and mailed to the Director of niisurance program which complies witn the . y . The licensee admits that with the excer requirements of Appendix B for all activities. f J the Office of Inspection and Enfcrcement, of portins of examp es B.I.a and B.1.f, ta affecting the quahty of safety.relsted R
2 ' -h{ j Ib:I (JSNRC. Washington. D.C. 20555.
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, ,8 structures, systems, and components and to , J violation occurred as* stated in the NOV.
implement that program in accordance with jNRCEvoluction *
- N'Y 9 '
7 O i ' CoMerding.ex'a'mple B'1:a..'the ll) ens
- ] The licensee may within thirty dcys of .
Contra ot above. Consumers P ers tJ contends that since the inspection reecrt f the date of this Order request a hearing. Company and its centractor did not J
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, A request for a hearing shall be adequately implement a quality assurance M. ; panels 1C-111.1C-uz. 2C-111. and 2C-r
' were open with attributes such as washe:
addressed to the Director. Office of pregram to comply with the requirements of :
.'t I, -
and torquing not yet inspected. the penic' Y Inspection and Enforcement. A copy of Appendix B as evidenced by the following 7 . the nucompliance pennining to nat was i n; 94 the hearing ' request shall also be sent to examples: "'.
.M 1. to CFR 50. Apendix B. Criterion Vd ' "( ' was not a violation.The licensee a posa
) 3. ' the Executive Legal Director. USNRC.
requins. In part. ** Activities affecting qualf ty,
. that open inspectica records can negate :
Njw
- !~' Washington.D.C.20555.If a hearinE i s requested. the Commission 'willissue an shall be prescribed by documented . .u. u instructions procedures, or drawings of a' unacceptable.The failure to install the required flat washe
,'ii . philosophy of inapecti.
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4; Order designating the time and place of type appropriate t'o the circumstances and he i rquality into the job cannot be accepted e hearing. Should the licensee fail to shall be accomplished in accordance with a f . substitute for the philosophy of buildir@
5,.y these instructions. procedures, or drawings."i I ; quality into the job.The license (ad=ity
~ >
- request a hearing within thirty. days of N ! %j' the date of this Order the provisions Consumers Power Quality Assurance of .. Program Policy No. 5. Revision 12.deals
,1 ; remaining portion.cf the violation,which' Paragraphwith the omission of bevel washed D ' ' l l 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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M h not been made by that time. the matter rnaYbe referred to the Attorney General equipment or activities such as . .. . 'sjea * , Violation, all steelin the "Q' 4reawcs "
%~ construction, installation . . . are . ' J1 # '. identified in accordance with procedurei
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p'. . .
for collection. :.Thelicensee contends that some J. ,
documented in instructions.-procedures and other forms of documents."
' . . [trcanufacturer's mark
,g In the event the licensee requests a~
hearing as provided above, the issues to Contrary to the above the fo!!owing ? iconfusion. At the time of the NRC inspec Z
be considered at such a hearing shall be: instances of failure to accomplish activities .-r the inspectors observed yellcw. colored )
..t A f affecting quality in accordance with m ) on steelin the "Q". area.This condition. .
+
1 e
- (a) whether the licensee was in instructions. procedures, specifica tions, or .. stated in the Notice of Violation,is contr.
violation of the Commission,s drewing requirements were identified: ' 5'#4 'L to the re3uirements of FieldInstruction F j ,
requirements as set forth in the Notice unstaliation of diesel generator engine? '19.000. Revision i. The licensee's content-of Violation and Proposed Imposition of control panels ICni.1Cuz. 2 Cut, and M* th t this paint was applied by,some N
?".2 jg j 2Cu2 was not in accordatee with the ..i;.w].: qmanufacturers do AM ;Q !- Civil Penalties referenced in Section 11 requirements delineated on foundation -
f Mi above, and Drawing 7220-M18-250 in that the !foundation detected the nonconferrr.inghSite qualitypaint control and-
?$ d h.bi . (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* 'j h 1.' sustained.
Dated at Bethesda. Maryland. this 29th day
[ Items B.i.b through B.1.e are not restated... Aviolation which deals with the marldng o
' here.)
% f. The inspectors identified various .. stock,g,f Cenclusion,,,, . . g ., y . steel in "non-Q
. 4 4gggg.S 2.N N '
N. of August 1983.
For the Nuclear Regulatory Commission.
steel shapes in the "Q" area with yellow.y , .gj,gy g.
'. colored paint on the ends (indicating the i.. These violations did occur as origmal f< g ; y Richard C. LeYoung.
1 material was non "Q") and various steel..aq. j otated.The information'in th'elicensee's P "
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Director. Office offnspection ond stock shapes in the non "Q" area withoutgy\. response does not provid painted ends (indicating *Q" material),.Q modification of the enforcernent action.'
3 Enforcement.
g<
o $ o Appendix-Evaluations and Conclusions contrary to the requirements
..t:
of Field " ' W \ Licensee's Requestfo
'GC .p
[ Items B.I.g through B 8 are not restated M ' PNllf" #Y'7,'.$.;, Y 7 Instruction FIG-9.800. Revision 1.
I i . Th'e licensee admits violation A occurrred here.)
.P $ .. Thelicensee statu thatit does not cc; CT , as stated.The licensee also admits violation MD, QAC B occurred, but takes exception with portions Contrary to the above: +
'. n! the validity of the violations and agrees
- 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 implemented to determine if materials ., certain mitigating facters should be* "-
v $' heensee admits the two violations, the ultimately restricted [per Nonconformance,. , , : considered. Specifically, the licensee be S!
licensee requests that certain mitigating Report No. 320e) from installation or use in mitigation is warranted on the basis cf !
- Y 5 bl factors be considered. ASME Class ! systems were actually [ ] ;1 / corrective actions. o M'f h.
h'*
- The particular portions ofitem B of the Notice of Violation l dated February 8.1083).
Insta d ,us 9
ass 1 9 9Qs msc o , 7,, ,. 4Evclu'dtion of, Licensee' ire [sponse3
~
m., which were denied by the licensee, are nonconforming conditions identified by the .
The licensee's corrective actions'are 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 g-
,4,.<~; g ; yy response is presented, followed by respectively, had not been documented on a . severity of the noncompliance'identifec conclusions regarding the occu rence of the nonconformance report, a quahty assurance * . during the diesel generator buildmg i, y g g y!*
noncompliance and the proposed civt!
report, cr other apprcpriate report.The two = inspection and the history of the qdalft; r, cXp O, T ' assurance program implemented et the
-N .{ j penalty. In addition, the licensee's requent for nonconforming conditions were:
.* reduction of civil penalty is summarized (1) The diesel generator exhaust hangers - Midland facility, the actions are no(y jj; .
were not classified, designed, or built as "Q"< ' unusaa!!y extensive end. under the . .
'N* jr below.The Office of Inspection and Enforcemenre evaluation of thelicensee's as committed to in the FSAR. (See item 2.c.) . . circumstances, do not warrant mitigatic
. w.- ,d , eddition, we perceive the issuance of -
f,E'* sqj request is presented followed by conclusions was (2) The design of diesel generator monorail not analyzed to seismic Category I
- nonconformance reports in March 1923
,g ,l regarding the proposed civil penalty. ' ^
, ,M,
.L.y'N$.ig,
.Mi n #~2M;'*f,#*(") *g' 1983). 5 l'"'Comnents
. modified received droft by the (Rev. 2. 19ft3 dated May to the Notice16, of violation and y..*} onclusidif.%'atioIl b5e'Ic'erise*e's~rkguest} Director. Office of Nuclear Regulatory Proposed Imposition cf Civil Penalty
' j[IJ The inforS isen not provide a basis for reduction of them; Research, U{S. Nuclear Regulatory was received from the licensee.
(y'g r, .
.roposed civil penalty. y; n,,1 ..,.,,..,.,..p:, Commission Washington, D.C. 20555, by h 3 ttih. October 21, y983, will be particularly III a, .* I . n ow. 33-avia rild w-eE sis .W.n.W.
Upon consideration of the answer
.gM
- y-;3 ; wwo coot mo-ci-ut.
- < i.', .. . u...#-Jo
..m. : m.s. , Technical .W": useful to the p.S.
Re few Committee representatives nnd the received and the tostatements the of fact, s p u, ., s -
.y ,
, , . r .4 't Senior Advis ry Group in developing explanation. and argument for gp taternational Atom! Energy AgencyC heir positic cn its adequacy prior to t mitigation of the proposed civil penalty contained therein, and for the reasons g,.y Draft Saf ety Gulde; vallabillty of Draft' their nextl " meetings. set forth in the Appendix to this Order, Qdgi ior Public, Comme 7 .. g .
, ,. ; Gy Single copi s of this draft Safetythe Director of the Office of Inspection
.TheIfit'e'rnatiosa AtoYiYEnergygm.p uide may be obtained trector, Office by aofwritten Nuc! ear and Enforcement has determined that
&y' # . Agency.(IAEA) is inpleting p:g icagg.. request to the arch. U.S. Nuclear
%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 the penalty proposed for the violation .
and Proposed Imposition of Civil hp:}
mp.-
> ytactice and safet) guides for nucleartf. D.C. 20555, e codes and guidesW. (5 3.f.S.C.522(a))
- Penalty should be imposed.
9.; Dated at Washington. D.C. this 1st day of
[ , M'b,
- ,tre power plants.The!
in,the following five areas:-
- 6 Government Orgardzation, Desigt't. W*i September 19c3.
Il,
. For the Nuclear 3egulatery Commission. In view of the foregoing and pursuant d- 1 Siting, Opera'thetion.dd Assurance.jAllof codes and Quality most ' .',*T,"Ef)) / Robert B. Minogue .
to Section 234 of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2282, the proposed safety guides have been .m ' Director. Office of .'uclearResulatory he.Ng , y ose of these codes:,% Research. Pub. L 90-295), and 10 CFR 2.205, it is
@m Qg completed
.md guidesis to proThe ide guidance pWto- ;,countries beginning uclearhereby p on.ama na w.as. s o .ml power, ordered that:
.%@74 ewwo coo Theb.censee pay a cml penalty m the Nima; ,
kg%
k- programs.'.p t.wm3 fd;my :.t. vt: amount of One Hundred Thousand Dollars
,i;g .J.C 2 g .Docket v - .. No. 50-410, Construction Permit
($100.000) within thirty days of the date of M. The IAEA codes elopedo,inpractice'ariddbly;{g the'76e (N this Order, by check, draft or money order, 8d$M . safety guides'aie dev G. A receives'and id t---@S[: followingte7ev. way y w. ly .. .o.CPPR-112
. e .. ' and EA 83-161 payable to the Treasurer of the United States ggi;g collates an.t exu T.he.,Ltmg information h y Niagara Mohawk Power Corp.(Nine and mailed to the Director.of the Office of d Mlle Point, Unit 2); Order imposing a inspection and Enforcement. USNRC ggk.;
g
@:g used bymember safetyare,a3Usin'g th a collation as ag .P p
coultnes q , , . m a specifiedstartmg pomt an,lAZA wo
. Washington D.C. 2c555.
y gg a few experts devel(ps a prehmmary ,lg. I 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 m?
TechnicalReview ommittee w.it . *2 Construction Permit CPPR-112 issued by A request for a hearing shall be 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
' ' then'sent t'o the- 'Sinfor Advisciy'tK the hearing request shall also be sent to s and mo'difies aslicensee W .or"toCommission"),
construct Nine Milewhich Point, authorizes the 4/# e CrotiF*hiEh'rdvi sif all' codes and Ni Unit 2in Oswego County, New York. the Executive Legal Director, USNRC,
[S J necessary tN'dfa 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 bM 1AEA Mehiber St tes for comments. - -
[@ Y Taking into account #the comments '.@fie[l June 24,19'4.
- a. .
hearing. !f the licensee fails to request a II#aM - ,tF ,
~
hearing within thirty days of the date of
- < " received from th e Member States, thel.6 .?. 'An' ins'pection'of the licensee's this Ordtr the provisions of this Order W d Sehlor Advisory Group thin modifiesMi activities under the permit was shall be effective without further
),hgg the draft as necessary fo reach :i.e;n.- ; conducted between August 30 and proceedmgs:if payment has not been 5%g agreement befop^ forwarding it to'the-r <":1 September Point Nuclear 30,1982 at the Station, Nine Unit 2 in Mile Oswego made by that time, the matter may be Qh IAEA Director ueneral with a / ~ referred to the Attomey General for M recomme'ndatic fthit it bela'cc5tedW0,' County, As part.of.this program, Safety Gu'id5M was also conducted at Nine Mde Point New York. An investigation col:ection. In the event the licensee requests a hearing as provided above, f"",*?$'MM SC-D13.."Reacior. Cooling Systems in Nuclear Station, Unit 2. on November 1-
[f.yf u Nuclear, Power )lants." has been t!.j. N[$ 4.1982. As a result of the inspection and 3 ,d develop'ed.The working Froup .. ,l1.."Y did not conduct its activities in(a)fullinvestigation the issues to be considered at such herring sha!! be:
consisting of Mt. G. Ellia from France: whether the licensee was it appears in that th W W .9 from. India:.Mr. P. C.as:6 compliance with NRC requirements. A violation of the Commission's br$ Mr. C. N, Bapat f.3 Dannatt from th = Unted Kingdom; and etr written Notice of Violation and acquirements as set forth in the Notice of Violation and Proposed Imposition of 4[M, c 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
[
-- A M ih. initial draft c'f tais guide from an. d% dated April 26,1933. '
above,and JM ^Q ny 2'
,A .' 3
3 M.M y M&. .;.v ' ' si . ;
@ !; ; i 40582 Fed:ral Regishr / Vol 48, No.175 / Thursday, September 8,19831 Notices ~
s s
.' n
~_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 of August 1983.
inspection reports ind:cating they had performed the inspection when,in fact, the
, , ' records were not 6tected by NMPC or SWCC upper management, but ' hat supemscry h For the Nuclear Regulatory Commission. inspections were performed by a trainee. ' involvement was limaed to the first and ,'..
'1 second !!ne supervisors within SWEC, The
'a K .
Richard C. DaYoung, Director. Office of/nspection and Etone a Webster's first and second line supervision was aware of this practice, but H staff agrees that there was no ind: cation t.%:t .
., 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 - 4 except the electrical FCC gmup.The NRC-,
p l. 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 s' pr.ctices resulted in cens'.ructiona x_..
- 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 :* , . . Nonetheless, the staff ma!ntains'that the "
summarized, and the NRC's evaluetton and Nine Mile Pcmt. Unit 2. by uncertified
signif cant cencerns in tbs caso are the fuc:s ,
[ ?[$l 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
- I responne was provided in a letter dated June who were supervising such trainees. perform:(2) indicated LevelIIinspectors
, inspections that ~
signed they
> ~ were 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 an inspection when inreports indicatingwas fact the inspection they
,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 perform the inspect 2cn tasas.
,g ,
gt staff evaluatien and conclusion are based on m
- g. tidh mh h~ -
[ -
the June 30,19B31etter. The licensee states that its own -
%M A mvestigation, and an investigation by SWEC,p M sM6s d b. M. hs-Statement of Violation revealed that the inspectors were adequately m also aware cN. .s practce ,yet nper ~g GI 10 CFR 50. Appendix B requires that each qualified and tramed individuals, but were
% supusor took act2on to discentcue the.; ,
b ,
%M licensee implement a quahty assurance program to be applied to the design, not cert.fied because they had not completed the three month period of working 3
practice.L,:censees are responsible fer g,,
! 'idassuring that inspecticas are properly ; g*
fabrication construction and testmg of the experience.The bcensee also ind: cates that performed by certi5ed mmuels that_s Ib *!ll- structures, systems and cornponents of the such qualification is evidenced by the fact .
records of inspections accurately reflect the
. !.l '
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,::
r.
il the period June 1 through September 17,1982 as evidenced below:
licensee acknowledges that it was imprcper Although a 540.000 civil peoalty is the base to use these trainees to perforrn inspections.M , arnount for a Seventy levelIII violation, the ,
d 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 ;
' h
'11 establishment and execution of a quality assurance program which assures that the result of.rnisunderstandings in connection. , cf $100.000 to e=phasize both the seriousness.
iU) activities affecting safety-related functions with SWEC's FOC procedures rather than' M of falsificatio intentional falsihcotion of documents, but thel supervision's awareness of a practice I. , , ,s.
h Iti .
M have been correctly performed. Niagara Mohawk power Corporation's application for licensee acknowledges the seriousness of . 7, involving falsification and their failure los; false records under any circumstances. ', take action to discontinue this practice."'.',
$' U a Construction permit for Unit 2 commits to <"*WWF 1 #
lD$ adherence to ANSI N 45.2b-1978.This The hcensee proposed requests civil penalty reduction from S100,000 to of the # ~[r '1
- # OP *PN 'N{ .'
il standard requires that each person who $40,000, claimmg that amount is ,g stated. ' Itis 'violation did occur as o-igirally rd verif es the conformance of work activities to commensurate witn the findings of the , The violation is appropriate nr d3yc:j =
^
T quality requirements shall be certified by his
(
N i 6
a.
employer as being qualified to perform his investi2 ation as a Severity LevelIII violation.7 classified a t Severity Iesel IIl and VJ.%r The licensee provides the following bases for!,1 assessment of a $100.000 civil penalty'is Mit.!
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 .
requires a Levell rating classification as a "
prerequisite for inspecting and accepting ' work, performed, attempts or misrepresentation of theto conceal quality of unacceptable'.0
- e. and failed to take'practicwhere 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 . 'Y l;s three month training period provided the of the first ime supervisor and possibly the .,,;, :p Ess-use ra.d e-t-ata4s
' p,
. trainees work under the direct supervision of second line superviser, were aware of the a:Liawa coot 7sso-e644W .; e cy o -o dWNW.b -
't j higher level personnel capable cf performing existence of these practices prior to NRC ' '/
assigned tasks. investigation, and demonstrates that both t'
~
. ..n~
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 q -
. welding, embedments, supplemental steel, manner m which inspections were to be u g g*, -~ -
. .9--
Ih , cable, raceways. welding, and raceway conducted and documented; and (4) the W.
( g ' !! supports) were inspected by Stone A Webster licensee's investigation mdicated that the . Amendment to OMB Circu!ar 12k,b.' m hw * ;i l personnel classified as trainees with problem was hmited to the electrica! Field " Prompt Payment,, Opportunity.forg ,,',
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 certified because they did not possess the quality assurance program.
- r"' Bud E et U T 'N
"; d
- W:f##
N/IC Eucluation of Licensee Response . d, . ...- .s LA requrred three months inspection experience. I
L f ,j k- B. Critenon XVII of Appendix B requires,in The NP.C staff acknowledges that the '
y ACDON: Comment on proposed'OMB
.,.T ' '
rf' part, that sufficient records be maintained to circular amendment. ,
trainees who performed the inspections.
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. Workers were'doing r..outine'maliite .' f -
Right below the steam separator is the- nance when they lifted off the reactor's . 4 -
ked m separato'r', a giantwhich crane sitsto 'the;,0f,$
- n;to'p reactor's'u;'. core tirea."R .'/L;;gy. 4 : l W.'g i. cap, then tried to lift out the s' core, and' tried. .to choist .it otit'W WiWM?h.0< p d : ' t. '/.'t i.. "9 '
6' iout unt'olting it fro'm the reac' lor'sMkdamages full #!and'Ml: .e 4"WG.Y ; . separator.. Th
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e assessment.of ' ?..
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hanism o'n the ciane called a '.' jig'?A.. costs.wd W. saf' tyPl.t A . , l not be avadable for as long v.' feet
. hs 'high, Ifcffner sa,id.
.,}.:f,;..p'V .
itually t' rip' ped, Icausing" the ' preim twp,l.wec,ks' but ' CEI . hopes .the. , , Ifcffner said he does not knoir which worker or group of workers is -
e to stop, but not before 'the'cranei. . construction. schedule,.which has been ,
jig and the steam se d respor,isible for the accident butihat'is iaged,Ileffner said.h. par'ator/werei ./ elayed many times, bemg will not be setZ.-lK.E.,. 4,..d bac c mvestigated. < .
q, >
; (. W~.T. , An:yllU".l.'M .
l.%G[W, 'M j; the K the,first plant. The first of two reactor reactors is scheduled being - bu,ilt "There at: 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,"
rlooked its' being. bolted down,"E . The ~ second ' reactor 1 would . not jbeu they jiistlieffner overlooked said. something. "Apparently, I i' 'i Tfner said. ."It,;ap;iarently caused . . operated until mid-1988. .%., % don's know who it has.", ; .c-
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