ML20127C435
| ML20127C435 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/11/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Garde B GOVERNMENT ACCOUNTABILITY PROJECT |
| Shared Package | |
| ML20126E194 | List: |
| References | |
| FOIA-85-80 NUDOCS 8501240086 | |
| Download: ML20127C435 (34) | |
Text
{{#Wiki_filter:- _ , January 11, 1985 Docket No. 50-483 , Ms. Billie Garde
. Director of Citizens Clinic Government Accountability Project l 1555 Connecticut Avenue, N. W.-
i Suite 202-Washington, D. C. 20555 , i
Dear Ms. Garde:
In our November 7,1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which hRC is treating as a 2.206 petition, we reiterated our willingness to meet with you and the allegers to obtain further factual information from the allegers. l On Never.ber 30, 1984, you and Ms. Varricchio met with Messrs. Miraglia, i Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to determine whether or not there was specific infomation that the allegers {'
,would provide-the NRC and to clarify under what circumstances the allegers would be' willing to provide such infomation to the NRC. i 1
Although you indicated that five of the seven allegers (including the two l individuals who made allegations earlier this year reported in Inspection i Report 50-483/84-30) might provide further factual information, we discussed l the conditions under which GAP would encourage the allegers to. provide infomation such as confidentiality, transcribed interviews, two week notices, i submittal of written questions prior to the interviews, o>portunity to review inspection findings, etc. We have carefully considered w1 ether we should i pursue a meeting with the allegers under the conditions proposed by GAP, notwithstanding that the conditions go beyond current staff practice in Draft Manual Chapter 0517. i Since receiving your letter of September 28, 1984, we have expended considerable inspection resources to pursue the matters raised in your petition as supported by affidavits from the allegers which you subsequently provided. We have concluded that the best course of action for timely resolution of these allegations is to complete our efforts based on available information and to issue our inspection report. After our inspection efforts and evaluation of the results are completed, a decision will be issued on your petition. ; If after reviewing the forthcoming inspection report, you have concerns about the adequacy of our inspection efforts, we would appreciate obtaining these , concerns from you. During the November meeting you took issue with the quality of Inspection Report 50-483/84-30 which was issued September 13, 1984. ; However. we have yet to receive the specifics of your concerns. If efter receiving your specific concerns it becomes necessary to follow up on any of 14 N yg l(, 8 @b/ 2 (vogt
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B. P. Garde 2 January 11, 1985 the allegations, we may wish to pursue a focused meeting with one or more of the allegers. Sincerely. Orfginal sicud 5'-
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l Docket No. STN 50-483 Ms.-Billie Garde Director of Citizens Clinic Government Accountability Project 1555 Connecticut Avenue, N.W. Suite 202 Washirgton, D.C. 20555
Dear Ms. Garde:
In our November 7,1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC is treating as a 2.206 petition, we stressed the need for a meeting to discuss ways to obtain further factual information from the allegers. On November 30, 1984, you and Ms. Varricchia met with Messers. Miraglia, Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to determine whether there was more specific information that the allegers might provide NRC. You indicated that five of the seven allegers (including the two > individuals who made allegations earlier this year reported in Inspec-I tion Report 50-483/84-30) might provide further factual information. You further indicated that you would recommend that the individuals, except for the initial interviews, talk directly to the NRC without GAP being a go-between. You discussed the following actions for interviewing the allegers:
- 1. The identity of the allegers should he protected from disclosure.
5? 2. The interview should be limited to information concerning safety. jg
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- 3. Two weeks notice should be provided of the time and place of the interviews, the interviews should be transcribed, and GAP may attend.
- 4. Areas of specific concern or questions should be identified in advance to provide a'11egers an opportunity to prepare for the interviews.
- 5. NRC should provide a written characterization of each allegation to assure that NRC understands the concerns of the allegers. This may be done during the initial transcribed interview. NRC may also have follow-up discussions with the allegers, if necessary.
- 6. At the conclusion of the NRC review and evaluation of allegations resulting from these interviews, but before reports are finalized, NRC should dis-cuss the factual findings with the allegers to assure that concerns have been addressed.
- 7. NRC should not place unsanitized transcripts in the PDR.
Many of these actions are similar to the draft Manual Chapter 0517 guidance to the staff. Therefore, the new 0517 guidance will be employed in the staff followup with the Callaway allegers. We will be contacting you to make appro-priate arrangements. In addition to discussing the above matter, you questioned the com-plateness of Inspection Report 50-483/84-30. We will be pleased to discuss this report directly with the concerned allegers or you may write Region III with your specific concerns.
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e- - 3-Finally, you inquired as to the status of the requested information concern-
;ing drug issues. We have not reached a decision on that matter and as to whether 100% reinspection is required of matters worked on by those involved in drug activities.
Sincerely, i V I James G. Keppler Regional Administrator h I f t o' t' 6 6
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Document Name LTR BILLIE GARDE 12/17/84 Requestor's ID: SHERYL Author's Name: Lieberman' Document Comments: TYPED 12/10/84 - Re: Need for Meeting r' * ( il i t i e l r.
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t Docket No. STN 50-483 Ms. Billie Garde Director of Citizens Clinic Government Accountability Project 1555 Connecticut Avenue, N.W. Suite 202 Washington, D.C. 20555
Dear Ms. Garde:
In our November 7, 1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC is treating as a 2.206 petition, we stressed the need for a meeting to discuss ways to obtain further factual information from the o allegers. On November 30, 1984, you and Ms. Varricchif met with Messers. Miraglia, Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to determine whether there was more specific information that the allegers might provide NRC. You indicated that five of the seven allegers (including the two individuals who made allegations earlier this year reported in Inspec-tion Report 50-483/84-30) might provide further factual information. You further indicated that you would recommend that the individuals, except for the initial interviews, talk directly to the NRC without GAP being a go-between. You discussed the following actions for interviewing the allegers:
- 1. The identity of the allegers should be protected from disclosure.
- 2. The interview should be limited to information concerning safety.
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- 3. Two weeks notice should be provided of the time and place of the interviews, the interviews should be transcribed, and GAP may l attend.
- 4. Areas of specific concern or questions should be identified in advance to provide allegers an opportunity to prepare for the interviews.
- 5. NRC should provide a written characterization of each allegation to assure that NRC understands the concerns of the allegers. This may be done during the initial transcribed interview. NRC may also have follow-up discussions with the allegers, if necessary.
- 6. At the conclusior,of the NRC review and evaluation of allegations resulting from these interviews, but before reports are finalized, NRC should dis-cuss the factual findings with the allegers to assure that concerns have been addressed.
- 7. NRC should not place unsanitized transcripts in the PDR.
gudsnee c em+=ked I*s Many of these actions are similar to the3 d raft Manual Chapter 0517, N W M / 6 , Tie new 0517 guidance will be employed in the staff followup with the Callaway allegers. We will be contacting you to make appro-priate arrangements. In addition to discussing the above matter, you questioned the com- , pleteness of Inspection Report 50-483/84-30. We will be pleased to discuss conhecY this report directly with the concerned allegers or you may w**s- Region III with your specific concerns.
t l Finally, you inquired as to the status of the requested information concern-yet ing drug issues. We have nota reached a decision on that matter, h Wed-wwitto Sincerely, I l l James G. Keppler I Regional Administrator
1 i _ p .- - r; e; Docusent Name: ; LTR BILLIE GARDE 12/17/84
. Requestor's ID:
SHERYL Author's Name: Lieberman Document Comments: TYPED 12/10/84 - Re: Need for Meeting e t e 4 M
.. : Prx$f fY 12/26lsa Docket No. 50-483.
'Ms. Billie Garde Director of Citizens Clinic Government Accountability Project
-1555 Connecticut Avenue, N. W.
Suite 202 Washington, D. C. 20555
Dear Ms. Garde:
In our November 7,1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC is treating as a 2.206 petition, we indicated our willingness to meet with you and the allegers to obtain further factual information from the allegers. On November 30,.1984, you and Ms. Varricchio met with Messrs. Miraglia,
.Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to detemine whether or not there wa's more specific infomation that the allegers would provide the NRC.
Althoughyouindicatedthatfiveofthesevenallegers(includingthetwo individuals who made allegations earlier this year reported in Inspection
' Report 50-483/84-30) might provide further factual information, no new or
! -additional information was given (or has since been given) to the NRC. , Rather, you discussed the way you would like the NRC to pursue the allegations
. contained in your September 28, 1984 letter.
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Billie Garde 2 DRAFT
- In view of your failure to provide any additional information regarding the 48 allegations, we intend to complete our inspection and issue a report of our findings. A copy of the report will be sent to GAP. The NRC will respond to your 2.206 request after we have completed our inspection of the allegations. ,
Should you or any of the allegers have additional specific infonnation regarding any of the allegations, we would appreciate its prompt transmittal to Region III. d James G. Keppler Regional Administrator cc: W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Region IV K. Drey (o
1 Document Name: l2l2fgy LTR TO BILLIE GARDE ABD Requestor's ID:. bO b8I/ LAURIE CEN luL F Author's Name: i Warnick frp 67eA Mfev1Te-k Document Coments: p3///fi M jfcu M M7 mech & f 1 9 791.
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9 ' Docket No. 50-483 Ms. Billie Garde Director of Citizens Clinic Government Accountability Project 1555 Connecticut Avenue, N. W.
. Suite 202 Washington, D. C. 20555
Dear Ms. Garde:
In our November 7,1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC is treating as a 2.206 petition, we indicated our willingness to meet with you and the allegers to obtain further factual information from the allegers. On November 30, 1984, you and Ms. Varricchio met with Messrs. Miraglia, Liebennan and Forney, and Ms. Stevens. The purpose of this meeting was to determine whether or not there was more specific information that the allegers would provide the NRC. Although you indicated that five of the seven allegers (including the two individuals who made allegations earlier this year reported in Inspection Report 50-483/84-30) might provide further factual infonnation, no new or additional information was given (or has since been given) to the NRC. Rather, you discussed the way you would like the NRC to pursue the allegations contained in your September 28, 1984 letter.- ll k
Although some of the points you made are standard NRC practice (such as not disclosing the names of allegers, not placing unsanitized transcripts in the PDR,etc.),othersuggestionsmadearebelievedtobeunnecessaryatthi,[ time. For example, since the 48 allegations were given to the NRC in writing by GAP, we do not believe it is necessary for the NRC to provide a written characterization of each allegation to assure that the NRC understands the concerns of the allegers. Also, we don't believe it is necessary for the NRC to meet with the allegers unless they have more specific it. formation which they have not yet provided to the NRC. In view of the time which has elapsed since we received the 48 allegations and theapparentfurthertimerequiredtoobtainanyadditionalspe[ific information, we intend to complete our inspection and issue a report of our. findings. A copy of the report will be sent to GAP. Should you have any Mditional questions or wish to have the allegers provide more information afterreviewofthereport,/wewouldbehappytomeetwithyou. The NRC will respond to your 2.206 request after we have completed our inspection of the allegations. Should you or any of the allegers have additional specific information regarding any of the allegations, we would appreciate its prompt transmittal to Region III. II e
James G. Keppler Regional Administrator cc: W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Region IV K. Drey Chris R. Rogers, P.E. Utility Division, Missouri Public Service Connission SNUPPS bec: T. A. Rehm, ED0 H. R. Denton, NRR J. J. Holonich, NRR R. M. Stark, NRR R. C. Brady, NRR J. Lieberman, ELD C. H. Weil, RIII RIII RIII RIII RIII RIII Forney/1s Warnick Norelius Davis Keppler
'12/26/84 l!
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i s. l Docket No.'50-483 Ms. Billie Garde . Director of Citizens Clinic Government Accountability Project 1555 Connecticut Avenue, N. W. Suite 202 Washington, D. C. 20555
Dear Ms. Garde:
In our November 7,1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC'is treating as a 2.206 petition, we reiterated our willingness to meet with you and the allegers to obtain further factual information from the allegers. On November 30, 1984, you and Ms. Varricchio met with Messrs. Miraglia, Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to determine whether or not there was specific information that the allegers would provide the NRC and to clarify under what circumstances the allegers would be .willing to provide such information to the NRC. Althoughyouindicatedthatfiveofthesevenallegers(includingthetwo individuals who made allegations earlier this year reported in Inspection Report 50-483/84-30) might provide further factual information. We discussed the conditions under which GAP would encourage the allegers to provide information such as confidentiality, transcribed interviews, two week notices,
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r .. submittal of written questions prior to the interviews, opportunity to review c inspection findings, etc. We have carefully considered whether we should meet with the allegers either by using our subpoena power or through voluntary ; means under the conditions proposed by GAP. Since receiving your letter of September 28, we have expended considerable inspection resources to puruse the matters raised in your petition. We have concluded that the best course of action for timely resolution of these allegations is to issue our inspection report based on the allegations as contained in your letter of September 28, 1984. Therefore, we are proceeding tocomplete our efforts based on available information. After our inspoection efforts and evaluation of the results are completed, a decision will be issued on your petition. If after reviewing the forthcoming inspection reort or any other inspection report you still have concerns about the adequacy of our inspection efforts, wewouldappreciateobtainingtheseconcerns(inwriting). During the November meeting you took issue with the quality of Inspection Report 50-483/84-30 which was issued September 13, 1984. However, we have yet to receive the specifics of your concerns. If after receiving your specific concerns it becomes necessary to follow up on any of the allegations, we may wish to puruse a focused meeting with one or more of the allegers.
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James G. Keppler Regional Administrator
.cc: W. H. Weber, Manager, Nuclear Construction
- 15. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII~ Region IV K. Drey Chris R. Rogers, P.E. Utility Division, Missouri Public Service Canaission SNUPPS' bec: T. A. Rehm, EDO
-H. R. Denton, NRR J. J. Holonich, NRR R. M. Stark, NRR R. C. Brady, NRR J. Lieberman, ELD C. H. Weil, RIII RIII . RIII RIII- .RIII RIII Forney/ls Warnick Norelius Davis Keppler 01/02/85 ,
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Dear Ms. Garde:
l In' our November 7,1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC is treating as a 2.206 petition, we reiterated our willingness to meet with
.you and the allegers to obtain further factual information from the allegers.
On November 30,~1984, you and Ms. Varricchio met with Messrs. Miraglia, . Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to detemine whether or not there was more specific infonnation that the allegers [ would provide the NRC. Although you indicated that five of the seven allegers (including the two individuals who made allegations earlier this year reported in Inspection Report 50-483/84-30) might provide further factual information, the meeting failed to bring us closer together in our attempts to obtain detail with respect to the allegations. Rather, GAP discussed the way it would like the _ g3 NRC to. pursue the allegations contained in your September 28, 1984 letter. h
While some of the points made by GAP are consistent with NRC practicef(suchasnot disclosing the names of allegers and not placing unsanitized transcripts in the PDR, other suggestions made are believed to be unnecessary at this time and will only contribute to further delays. In view of the above, we are proceeding with completing our insepction effort based on the information available to us. We know GAP will not hesitate to inform us should you believe our inspection failed to address the fundamental concerns associated with each allegation. If it becomes necessary to followup on any allegations, we may wish to pursue a focussed meeting with one or more of the allegers. In any event, the NRC will respond to your 2.206 request i after we have completed our inspection of the allegations. l l In the interim, should you desire to make us aware of any additional information relative to our inspection of these allegations, please contact us. i 13
James G. Keppler Regional Administrator cc: W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Region IV
. K. Drey Chris R. Rogers, P.E.
Utility Division, Missouri
~
Public Service Commission SNUPPS bec: T. A. Rehm, ED0 H. R. Denton, NRR J. J. Holonich, NRR R. M. Stark, NRR R. C. Brady, NRR J. Lieberman, ELD C. H. Weil, RIII I RIII RIII RIII RIII RIII Forney/1s Warnick Norelius Davis Keppler 01/02/85 gg 1
TGK ABD j CEN Document Name: y[ g LTR TO BILLIE GARDE 01/07/85 ; BB Requestor's ID: gg SHERYL Author's Fame: }. tk j y per m )/) M Warnick lik our lasf Document Comments: im Reg. III for-Lieberman 1/4/85 (revision 1 typed 1/7/85) prs 7M /cMgr M )
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~ Docket No. 50-483 Ms. Billie Garde Director of Citizens Clinic Government Accountability Project 1555 Connecticut Avenue, N. W.
Suite 202 Washington, D. C. 20555
Dear Ms. Garde:
In our November 7, 1984 letter acknowledging the receipt of the September 28, 1984 letter from the Concerned Citizens Against Callaway, which NRC is treating as a 2.206 petition, we reiterated our willingness to meet with you and the allegers to obtain further factual information from the allegers. On November 30, 1994, you and Ms. Varricchio met with Messrs. Miraglia, Lieberman and Forney, and Ms. Stevens. The purpose of this meeting was to determine whether or not there was more specific information that the allegers would provide the NRC and under what circumstances would the alleger be willing to provide such information to the NRC. You indicated that five of the seven allegers (including the two individuals who made allegations earlier this year reported in Inspection Report 50-483/84-30) might provide further factual information. We dis-cussed the conditions that GAP would encourage the allegers to use such as confidentiality, transcribed interviews, two week notices, submittal 14-
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of written questions prior to the interviews, opportunity to review inspection findings, etc. Since the November meeting we have expended [significant] inspection resources to pursue the matters raised in your September peti-tion. Based on our findings to date, we have not identified issues of [significant] regulatory concern. We have given careful consideration ~as to whether we should pursue the allegations further by meeting with the allegers either by using our subpoena power or voluntarily under the conditions proposed by GAP notwithstanding that the conditions go beyond current staff practice in Draft Manual Chapter 0517. However, in this case, based upon the generalized allegations raised in the affidavits and our [ extensive] inspection efforts to date of those allegations, we have concluded that attempting to obtain further information directly from the allegers would not be a prudent use of NRC resources. Therefore, we are proceeding to complete our efforts based on available information. Thereafter, a decision will be issued on your peti-tion. If after reviewing the forthcoming inspection report or any other inspection report, you have concerns about the adequacy of our inspection efforts, we would appreciate obtaining those concerns [in writing]. In this regard, during the November meeting you took issue with the quality of Inspection li-
.7 Report 50-483/84-30 which was issued last [ fall], however, we have yet to receive the specifics of your concerns. If after receiving your specific concerns,-it becomes necessary to follow up on any of the allegat8ons, we may wish to pursue a focused meeting with one or more of the allege s.
James G. Keppler Regional Administrator cc: W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DM8/ Document Control Desk (RIDS) Resident Inspector, RIII Region IV K. Drey Chris R. Rogers, P.E. Utility Division, Missouri Public Service Commission SNUPPS bec: T. A. Rehm, EDO H. R. Denton, NRR J. J. Holonich, NRR R. M. Stark, NRR R. C. Brady, NRR J. Lieberman, ELD C. H. Weil, RIII RIII RIII RIII RIII RIII RIII Forney/is Warnick Norelius Berson Davis Keppler 01/02/85 NRR DELD EDO Miraglia Lieberman Rehm l i
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. _ J. TEFy.AN E. HARTIN J. SPENCER C R.-FLUECCE M. MILLER B. STAMIRIS S. CADLER D. MINECK B. STEPHENSON
_l J. CALLO6'AY R. HOSTRCSS H. VOICHT OVER-+
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' _ . _ DPRP DIVISION TILES RESIDENT INSPECTOR MIS /L. SUCHARSKI .
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D,EP DRMSP KEPPLER/ DAVIS COPIES WITHOUT CONCURRENCES W P. ANDERSON W K. GRAESSER)?.E",br$.PA.v j,~ #j". T. NURRAY J. PARKYN L.-BECK /~ J. GUDAC R. CALLEN / D. HOFDIAN T. QUAKA M. CHERRY D. HINTZ R. QUERIO D. CHEVEZ T. HOUVENAGLE R. QUILLAN R. COSARO N. KALIVIANKIS V. SCHLOSSER T. DATTILLO J. KODNER- J. SCHOTT G. DIEDERICH H. KOHN D. SCOTT y K. DREY LeBOUEF, LAMB, L. SHAMBLIN J. DUFFY LEIBY & MACRAE W. SHAMLA H. EVANS W. MARSHALL M. SINCLAIR D. MARTIN G. SORENSEN ___D. FARPAR J. FERMAN E. MARTIN J. SPENCER R. FLUEGGE M. MILLER B. STAMIRIS S. GADLER D. MINECK B. STEPHENSON J. GALLOWAY R. MONTROSS H. VOIGHT OVER--*
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Special 8
- N/ /O# Rx Inspections.)
Inspector (s) Division Director Inspector (s) l '"** Inspectors: /7, M/P/5//
- I I
- 2. Inspectors: he report clearly addresses all safety concerns.
l The report does not clearly address the following safety concerns: I l 1 I ,
, 3. Inspectors: I believe RI!! is effectively dealing with all safety concerns. See attached page
. I do not believe RI!! is effectively dealing with all safety concerns. I suggest RI!! take '
l ,the following actions to assure effective Rl!! action:. ; i I l I l See attached pages l $ //)Q 8/ Yr* M 4 ? l Irspect' ors' Signatures Date ' ' !
' 4. Supervision: If the inspector does not believe that all safety concerns are addressed in the .
I report or that RIII is not effectively dealing with all safety concerns provide your position on these matters including dates by which actions will be taken. l I l. i
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I d2JJD l Superv[s signature Date
lfpp,;yrrence (Only when Section 4. is required to be corpleted.)
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JUN 301983 -
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Docket No. 50-483 { Union Electric Company _ ATTN: Mr. Donald F. Schnell i Vice President - Nuclear - Post Office Box 149 - Mail Code 400 St. Louis H0 63166 : Gentlemen: This refers to the routine safety inspection conducted by Mr. H. Wescott : of this office on June 14 through June 17, 1983, of activities at Callaway : Plant, Unit 1, authorized by NRC Construction Permit No. CPPR-139 and to = the discussion of our findings with Mr. W. H. Weber and others of your :
~
staff at the conclusion of the inspection.
. L The enclosed copy of our inspection report identifies areas examined during -
the inspection. Within these arear, the inspection consisted of a selective e.un.ination of procedures and representative records, observations, and in- l tarviews with personnel. _ No items of noncompliance with NRC requirements were identified during the course of this inspection. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this =
=
of fice by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty l
- days of the date of this letter. Such application must be consistent with ,-
the requirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report'will be placed in the Public Document Room. =
=
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Union Elcetric Company JUN 301963 We vill gladly discuse any questions you have concerning this inspection. Sincerely,
" Original signed by R. C. Knop" R. Q. Knop, Chief Projects Branch 1 -
Enclosure:
Inspection Report No. 50-403/S3-13(DPRP) ec.w/ enc 1: W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager D:!B/Docunent Control Desk (RIDS) Resident Inspector, RIII Region IV K. Drey Ronald Fluegge, Utility 11' Division Missouri Public - l Service Co=nission I
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U. S. NUCLEAR REGULATORY COMMISSION REGION III l Report No. 50-483/83-13 Docket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MD 63166 Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Reform, MO
. Inspection Conducted: June 14-17, 1983 Inspector:
@l +. L dt
- h. M. k'escott
/
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/
/
9/I8 Approved By: .'E. Konklin, Chief 6[2f[78,
/ '
Projects Section 1A Inspection Sumary Inspection on June 14-17, 1983 (Report No. 50-483/83-13)(DPRP) Areas Inspected: Routine, unannounced inspection by the Regional Project Inspector of 10 CFR 50.55(e) reports, I&E Bulletins, and review of previous inspection findings. The inspection involved a total of 30 inspector-hours onsite by one NRC inspector. Results: No items of noncompliance or deviations were identified. i
\
![ ,
4 , DETAILS
- 1. Persons Contacted
-Union Electric Company T. A. Moser, Assistant Engineer R. L. Powers, Assistant Manager, QA B. _ K.. Stanfield, Assistant QA Engineer (Construction)
J. R. Veatch, Supervising Engineer, Construction QA W.'H. Weber, Manager, Nuclear Construction Daniel International Corporation D. A. Boone, Senior QA Engineer J. J. Long, Project Welding Engineer M. K. Smith, Audit Response Coordinator The above personnel attended the exit meeting held on June 17, 1983.
- 2. Review of I&E Bulletins (Closed) No. 79-11. " Facility Overcurrent Trip Device in Circuit
; Breakers;for Engineered Safety Systems."
The inspector reviewed the following:
- a. Letter from Bechtel Power Corporation to SNUPPS, File No.
9415, 0278, stated that the SNUPPS design does not utilize the subject breakers (DB-75 or DB-50).
- b. Letter from SNUPPS to USNRC R-I, dated 7/24/79, File:0278.10, stating:that subject breakers are not used in safety-related applications. This bulletin is closed.
(Open)~No. 79-28, "Possible Malfunction of NAMCO Model EA180 Limit Switches at Elevated Temperatures." This bulletin remains open pending installation of the required gaskets. (Closed) No. 82-04,~" Deficiencies in Primary Containment Electrical Fenetration Assemblies." See 10 CFR 50.55(e) Report NRC No. 82-08 dated 9/10/82, licensee No. UE 42, discussed on page 4 of this report. This bulletin is closed. 2
.. . ~ - . . - _ _ - . . _ _ . _ _ ,_
- u_ .s . _ _ _ _ _ _ . . _ . _ _ . _ _ _ . _ . - .- -_ _ _ . _ _
- 3. Review of 1&E Circulars
' (Closed) No. 80-16,'" Operational Deficiencies in Rosemount Model.
510 DU Trip Units and Model 1152 Pressure Transmitters" The inspector reviewed the Bechtel Power Corporation. letter to SNUPPS, File 10915, which states that the subject pressure transmitters are not used on the SNUPPS project. This circular is closed.
- 4. Review the Licensee's 10 CFR 50.55(e)-Reports
~ (Withdrawn) 10 CFR 50.55(e) Report No. NRC 81-10, dated 8/19/81, Licensee No. U35,
Subject:
Deficiency on the Polar Crane Snubber "A" Wheel Pin. The inspector reviewed the licensee's 50.55(e) report, file package - AB 23.05.35,which contained the following:
" Final Report on Polar Crane Earthquake' Restraint Assembly.
Damage at Ca11away'(Unit 1) for Evaluation of Potential Significant Deficiency per 10 CFR 50.55(e)." ' Revision 2, dated 7/7/82, stated . that the snubber assembly damage was caused by the failure of a bushing due to the sudden shock loads resulting from the misalignment of the polar crane support girders. Engineering analysis shows that the entire polar
. crane support system is of adequate strength to resist the impact of the polar crane.
It was also concluded the condition'did not constitute a significant deficiency. The inspector considers it appropriate that this report be withdrawn. (Withdrawn) 10 CFR 50.55(e) Report No. NRC 82-01 dated 4/6/82,
. Licensee No. U37.
Subject:
Potential Deficiency on Essential Service Water System Pumphouse Embedded Plates. The inspector reviewed the licensee's 50.55(e) Report file package AB 23.05.37 containing the "Callaway Plant Essential Service Water' System Pump Restraint Embed Report" Revision 1, dated 9/27/82. The report concludes that the results of-the engineering analysis demonstrates that the operability of the ESWS pumps would not have been compromised, and the structural integrity of the seismic restraints would have been maintained during a postulated seismic' event. Had the 3
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deficiency not been detected, the operation of the system would not have been adversely affected . ; The inspector considers it appropriate that this report be wi thdrawn. (Closed) 10 CFR 50.55(e) Report No. NRC 82-07, dated 9/3/82, Licensee No. : UE ' 41, Subj ect : Potential Deficiencies in Foxboro Instrumentataan Electronic Modules. The inspector reviewed the licenseek 50.55(e) report file package AB 23.05.41,which contained the following:
- a. Letter, Foxboro to UE dated 7/30/82, notification that UE had
. received the suspect cards / modules listed in the letter. The suspect component was part No. E0285VX, a one-thousand ohm potentiometer utilized to set the alarm point or gap.
The letter further states that Foxboro has not had a reported failure of units' installed in the field. Factory test and ,
~
evaluation, however, reveals that components utilized during ' the period December 1980 to December 1981 may have been subjected to mechanical stress during assembly.-
- b. Shipping. documents returning the relay output cards to the vendor, Order No. Reference 10466-J-110-2, shipped 1/4/82.
The inspector considers this 10 CFR 50.55(e) report to be elesed. (Withdrawn) 10 CFR 50.55(e) Report NRC No. 82-08, dated 9/10/82,
- Licensee No. UE 42,
Subject:
Electrical Penetration Assembly Deficiencies. The inspector reviewed the licensee's 50.55(e) Report file package
, AB23.05.42 which contained Surveillance Report No. 8/82-05, dated'
' 8/10/82 with attached NCR 25N6399E. The Surveillance Report included disposition of NCR 2 SN-6399E, stating that this generic
- investigation established (a) visual- examination revealed that the cracks in question are superficial in nature; no cracks were visually found penetrating the module seal pressure boundary, (b) x-ray. analyses of a representative number of cracked modules ;
- at Callaway and Wolf Creek sites confirmed the cracking to be limited 'l to the conductor extension area with no penetration into the !
-pressure' boundary seal,.(c) to provide additional confidence regarding the integrity of the modules, three representative modules with cracks of the type described in the NCR were further subjected to
. helium leak tests. These tests confirmed that the modules exhibited l no loss of pressure and that the observed leakage was within specification limits, '(d) site records for monitoring of containment 1
4 W - m -s %,.9,.--- ,- w w. y, -
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t module service pressure.also revealed no loss of system pressure other than that. attributed to normal 0-ring seal leakage.
' All action items ' addressed in I&E Bulletin 82-04 (same subject) were satisfactorily addressed.
The inspector considers it appropriate that this report be withdrava. (Withdrawn) 10 CFR 50.55(e) Report No. NRC 83-05, dated 2/24/83, Licensee No. UE 50.
Subject:
Garrett Corp. solenoid valves used to control
- two PORV's.
The inspector reviewed the-licensee's 50.55(e) report file package AB 23.05.50,which contained the following:
- a. Precautionary Notification to USNRC R-IV, dated 1/14/83, stating that Garrett Pneumatic Systems Division had identified a potential long term reliability problem with its Nuclear Solenoid Valve used to control PORV's 3750010 and 3750014, in that long term material galling between internal components was identified as a result of endurance testing. Garrett has mitigated the problem with changes in material and tolerances of detail components.
- b. Letter from SNUPPS to UE dated 3/22/83, File No. 0491.10.2, with a SNUPPS conclusion that the valve problem was a direct outgrowth of intended qualification-testing effort and should not be considered reportable under 10 CFR 50.55(e) criteria.
The-inspector considers it appropriate that this. report be withdrawn. (Withdrawn) 10 CFR 50.55(e) Report No. NRC 83-09 dated 3/29/83, Licensee No. UE-52.
Subject:
DIC-Quality Certification Program Concerns. The inspector reviewed the licensee's 50.55(e) Report File Package AB23.05.52 which contained the following:
- a. 'UE's Report dated 4/27/83, listing a chronology of events with an evaluation of the' findings and their-impact, corrective.
actions taken, and final conclusions. Based on the final conclusions it was determined by DIC Quality Management, with corporate concurrence, that the site Quality Certification Program has not been compromised.
- b. .Stop Work and Partial Stop Work Orders and Start Work Orders as appropriate, for each QC discipline, with corrective action verification.
The inspector considers it appropriate that this report be withdrawn. 5
- 5. Review of Licensee Action on'Previously Identified Items (Closed) Unresolved Item 483/80-05-03, Class II over I Equipment.
Bechtel has established a task force to review drawings and make use of the Callaway scale Model to identify areas in the plant where Class II over Class I equipment is located and to make any necessary changes to protect the equipment. This is a continuing program. This item is considered to be resolved. (Closed)' Noncompliance 483/80-07-OL Welding of Cable Tray Fittings. The inspector reviewed Bechtel letter to SNUPPS, File No. 9740, 5-034, stating that welding is used for preassembly of the cable tray fittings, to attach rungs to the curved side rails. The rungs are then resistance spot welded. Load testing of the fittings
. was performed adequately with no failures when accelerated at levels above those for the SNUPPS program.
This item is considered closed. (Closed) Unresolved Item 483/80-19-03, Material Released for Use Without Proper Documentation. The inspector reviewed the following:
- a. Audit item 4, UTD No. QA-515 with completion of corrective action dated 7/25/80, stating that the subject material was received on RIR B-04164, P. O. No. 10466-E-017-2. This material contained a JDDR No. E017-2-7 stating that IEEE 323 report does not have Code I approval. A Deficiency Report No. 25D-0238-E was written to include the SDDR in order that material could be released to the field and have proper tracking.
.b. Deficiency Report No. 2SD-0238-E dated 2/28/79
- c. SDDR No. E017-2-7, dated 11/8/78.
This item is considered to be resolved. (Closed) Noncompliance 483/82-10-01, Cracked Electrical Penetrations. See 10 CFR 50.55(e) report NRC No. 82-08, dated 9/10/82, Licensee No. UE 42, as discussed on page 4 of this report. This item is considered to be closed.
- 6. . Exit Interview The inspector met with licensee representatives,as noted in Section 1 under Persons Contacted,at the conclusion of the inspection on June 17, 1983, at the Callaway site. The inspector summarized the purpose and results of the inspection. The licensee acknowledged the inforcation.
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-Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail' Code 400
. St. Louis.-MO 63166 .
Gentlemen: This refers to the routine safety inspection conducted by Mr. J. H. Neisler of this office on June 3 through July 27, 1984, of activities at Callaway Plant, Unit 1, authorized-by-NRC Operating License No. NPF-25 and to the discussion of our _findirgs with Mr. W. H. Weber and others of your staff at the conclusion of the irspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective-examination _of procedures and representative records, observations, and
-inte,rviews with personnel.
No itens of noncompliance with NRC requirements were' identified during the course of this inspection.- In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document. Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhnk! information contained therein within thirty days of the date of this lettt.r. Such application must be consistent with the re-ouirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room. t
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We. will gladly discuss any. questions you have concerning this inspection. Sincerely, , Horiginal sign:.:' ' ; .'. F. Varnick" R. F. Warnick, Chief Projects Branch 1
Enclosure:
Inspection Report No. 50-483/84-30(DRP) cc w/ enc 1: W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DMB/ Document Control Desk (RIDS) l Resident Inspector, Rill , Region IV K. Drey-Chris R. Rogers, P.E. Utility Division, Missouri Public Service Comission SNUPPS t I N RJ1 . R111 1 l'Fj r s RfM P ke/db y W[eil Warnjck 08/23/84' 9 p (g j;hl 7/d/fy s
> U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-483/84-30(DRP)
Docket No. 50-483 License No. NPF-25 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway Plant Unit 1 Inspection At: Callaway Site, Steedman, M0 65077 Inspection Conducted: June 3 through July 27, 1984 Inspector: J. H. Neisler Approved By: Q} W. L. Forney,! Chief i/il/M/ Projects Section 1A Date Inspection Summary Inspection on June 3 through July 27, 1984 (Report No. 50-483/84-30(DRP)) Areas Inspected: Routine inspection by the senior resident inspector of licensee actions relative to IE Bulletins; allegation followup; observation of fuel load activities; observation of completed installations of electrical trays and cables, pipe supports and restraints; and penetration installation. The inspection involved 160 inspector-hours onsite by the resident inspector including 20 hours during non-regular hours. Results: No items of noncompliance or deviations were identified, t l ? y f v i tcotuv c
_ DETAILS
'\
- 1. Persons Contacted Principal Licensee Employees D. F. Schnell, Vice President - Nuclear
*W. H. Weber, Manager, Nuclear Construction R. Pows:rs, Assistant Manager, QA
*R. Veatch, Supervisory Engineer, QA J. Laux, Supervisory Engineer, QA
. *C. Plows, QA Consultant
*H. Millwood, QA Consultant L. Cunningham, QA Consultant R. Stright, Licensing Consultant A. Passwater, Licensing Manager R. Hamilton, QA Consultant M. Doyne, General Superintendent, Nuclear Construction Contractor and Other Personnel C. C. Waggoner,-Site Manager, Daniel. International '
*R. Glassner, Compliance Supervisor DELCON J. Ready, Training Supervisor, Quality Services, Daniel International R. Ruggles, NDE Level II, Daniel International M. Majors, Level II Mechanical QI, Daniel International
*J. J. Long, Project Welding Manager, Daniel International
*J. F. Freenan, Project Electrical Supt., DELCON W. F. Reilly, SN'JPPS
- Denotes those personnel attending exit interviews.
-2. Inspectior end Enforcement Bulletins (Closed) IEB 84-02: Failure of GE Type HFA Relays. Bechtel rework plan E-017-3, Rev.1, required Class IE Type HFA relays to be replaced with GE Century series relays and for non-Class IE relays to either be replaced or have their coils replaced. Work is complete for Class IE relays. Type HFA relay with lexan coil failures were reported pursuant to 10 CFR 50.55(e) on February 12, 1981, and closed in NRC Inspection Report 483/83-33. This bulletin is considered to be closed.
- 3. GE Metal Clad Vertical Lift Switchgear (AITS-F03-026983)
(C1csed) During a Region IV vendor inspection at the Medium Voltage Switch-gear Business Section of the General Electric Company, it was determined that deficient vertical lift metal-clad switchgear had been supplied to numerous generating stations. All customers had been notified; however, it was not apparent during the vendor inspection that all had responded. An Office of Inspection and Enforcement letter dated June 2, 1983, requested regional followup action to ensure that the applicable sites were aware of the deficiency and that appropriate corrective actions were taken. 2
a- h l Re-qualification tests indicated that the short circuit bracing designs on l some' vertical lift metal-clad switchgear do not have their intended short
. circuit-withstand (momentary) capability of 80,000 amperes. The main bus and runback supports in these designs were unable to withstand the assigned ;
; full short. circuit rating without some damage to the bus supports and l potential additional problems due to the weakening of the supports. GE-provided field modification kits for switchgear which require high with-stand capability.
-The ' inspector reviewed rework plan RE-009-C, Rev.1, which details the GE recommended modifications for upgrading bus bar bracings and supports to their design momentary short circuit withstand capability of 80,000 amperes.
. _ The completed rework covered 4.16KV switchgear busses NB01, NB02, PB03 and PB04 at Callaway. This item is considered to be closed.
- 4. Allegations
- a. ATS RIII-84-A-0081; ATS RIII-84-A-0082. Region III was contacted by Government Accountability Project (GAP) representatives regarding allegations by two individuals of construction deficiencies at "
Callaway Unit 1. The allegations provided by GAP and the inspector's review of each allegation are as follows: (1) The alleger stated that he'was intentionally exposed to radiation by radiographers. "They... keep aiming these radiograph x-ray machines at me...It happened a couple more times...I'd go in a little place and come back out and it would be on the opposite wall...They weren't taking any pictures. I asked them. And a couple ~of times I'd just walk by and they would flash an x-ray machine at me, I assume just to give me radiation...I say flash because it had a light that flashes...It's a white' light that i flashes. White light flashes when the x-rays are emitted." The alleger stated once when he was on the 1988' level that the radiographers plugged in their machine and while trying to expose him to radiation they turned the power up so high the lights went out. He stated that-these incidents were not job related, but because he was "in an environmental group...somebody thought they would run me off". This allegation was not substantiated. No x-ray machines are used at Callaway. Radiography at Callaway is performed with a Tech-Ops Model 660 radiography camera using an Iridium-192 source. Isotopic radiography sources used in construction are omnidirec-a tional and cannot be " aimed". The radiography cameras require manual operation to position the source for radiographing an object, have no provisions for plugging into an electrical system, nor is the intensity of an Iridium-192 source adjustable; therefore, power cannot be turned up to cause the electric lights to go out. The inspector determined that radiography was ger.erally performed during the third shift, not on the day shift when the alleger stated he was working. On those occasions when 4 3
. - . - : _- .w . - - -- .. .- ~~
it was necessary to perfom rediography on other than the third shift, procedures recuire the area be marked with ropes / tape and signs and cleared of all personnel. Flashing lights were not used to mark a radiography area. In addition, the inspector determined that the alleger's nonnal duties did not take. him into the power block.
-(2) The alleger stated that all plans for the plumbing drains had been lost.
~
Plumbing drains are not safety related, but the inspector exam *ned drawings of plant drain systems in five file cabinets. In addi-tion, the licensee perfonned an inventory of drawings of the plant drain:: in the Daniel (DIC) engineering office at the inspector's request. The inventory revealed more than 130 dif ferent drawings on hand. Drawings are also-on file in the licensee's operations organization, QA organization, engineering, SNUPPS, Bechtel and at DIC docurent control and Quality Services organization. The inspector determined that the plumbing drain plans had not been lost. (3) The alleger stated that in 1980-1981, cables were sabotaged (cut). The inspector reviewed licensee Event of Interest Reports relative to cables that had been cut during the period 1980-1984. Cables--identified as having been cut due to vandalism, sabotage, malicious mischief or through personnel error are:
-Class IE cable IEJ112BA was found with the end cap cut off on January 25, 1980. The cable had been pulled and coiled but not terminated on January 22, 1980. The end cap was replaced and the cable terminated as scheduled. The damaged cable was.
reported to the NRC on January 25, 1980. Class IE cable ISA202KA. On-February 25, 1981, a three inch long section of one conductor was found to have been cut from this cable approximately one foot from its terminal point. The cable was reterminated. This item was reported to the NRC on February'25, 1981. Class IE cable IEMG13AB. This partially pulled and coiled cable was found cut in half on August 12, 1981. The cable had not been terminated but was coiled in the tray. The cable was replaced with a new cable. This item was reported to the NRC on August 13, 1981. Class IE cable 4SAZ0lSA. This cable damage was discovered during testing when it failed a continuity test on February 8, 1983. Investigation of lack of continuity showed that the cable had been cut in half. A new cable was installed. The NRC was informed February 18, 1983. L 4
1 . m _m - 1 e . i Class IE cable IBBR378B. This cut cable was discovered on Febrbary 16, 1983. The cable was replaced with a new cable. The , hRC was notified February 18, 1983. In addition to the five safety related cables above, six nonsafety l related cables were found cut during the 1980-1984 period. Investigations by the NRC resident inspectors, the licensee and
- l the contractor did not determine if cable damage was due to vandalism, deliberate sabotage, malicious mischief or inadvertent cuts caused by other work in the area.
Daniel Quality Services completed a 100% reinspection of safety related cables November 1,1982. The NRC electrical inspectors completed an inspection of filled cable trays February 3,1984 (Report 483/84-06). No damaged or cut cable was found during the inspection. The allegation that cables had been cut was substantiated; however, the cause(s) could not be determined. t Since cables that were cut in 1980-1981 have subsequently been inspected by quality control inspectors, have been tested during preoperational testing and have been inspected at least 18 times since 1981 by the NRC as shown by inspection reports filed since 1981; this allegation is considered to be closed. (4) The-alleger stated that he overheard concrete inspectors com-plaining of concrete being poured on top of ice during the winter 1982-1983. The concrete pours were for outside slabs and some attempts were made to remove the ice. The alleger noted that "sometimes they would meet their temperature requirements by having it covered...take the air temperature. And if it was over 40 degrees they would pour concrete, but yet the ground was frozen solid, but it was documented as acceptable temperature..." The alleger did not krow if nonconformance or deficiency reports were ever written on this condition. The irspector examined concrete placement records (pour cards) of-all concrete pours made during the winter months of 1981-1982 and 1982-1983. For the purpose of this report winter months are November, December, January, February and March. No safety related outside concrete slab pours were made during either winte r.- Additionally, the inspector reviewed NRC civil inspection . reports covering 1976 through 1983 which did not identify any concerns regarding placement of concrete on ice. This allegation was not substantiated. This allegation is considered to be closed. 5 c-
m q __ _~
> (5) The alleger stated that " Installed and approved electrical cables
'in the auxiliary and diesel generator building were damaged by 4- people climbing on the cables. This ' traffic' caused damage to the cable jackets." The alleger recalled observing this condi-tion on black colored cables in the auxiliary building.
Safety related cables at Callaway are red, white, blue, and 1 yellow. Black is the designated color for nonsafety related cables. Raceways are color coded to match the division colors carried by the cables. The inspector visually inspected safety and.non-safety related cables in trays on the 1974', 1988', 2000', 2026'
. and 2047' levels in the auxiliary building, in trays from 2015' to the 2047' level in the reactor building and in the diesel building. No damaged cables were identified. The contractor performed a 100% inspection of cables in trays in November 1982.
The NRC inspected electrical cables in the auxiliary feed system during the Integrated Design Inspection (483/82-22); during electrical walkdown inspection (483/84-06); and during inspections numbers 483/81-20,483/81-25,483/82-10,483/82-13,483/82-15, 483/82-19, 483/82-20, 483/83-03, 483/83-05, 483/83-11, 483/83-14, 483/83-15, 483/83-19, and 483/84-06. The inspector reviewed records of gang box meetings where workers were instructed not to
- climb on plant equipment. .
This allegation was not substantiated and is considered to be closed. (6) The alleger stated that "Many times the holes were drilled oblong, instead of round, into the steel plates. This condition - could not be readily determined as washers covered the holes. This went on for a long time before they decided it was a problem and reinspections made." Nonconforming surface mounted plates were identified by the licensee and reported to the NRC pursuant to 10 CFR 50.55(e) on May 19, 1980. A reinspection of all surface mounted plates was performed as stated by the alleger. Nonconforming plates, including plates in which holes did not mect specifications, were reworked. Quality inspectors were retrained and provided with new more comprehensive inspection checklists. The inspector examined Daniel Procedure WP-100, " Installation of Post-Pour Embedded Items", to verify that the requirement for the foreman to sign-off each plate upon conpletion of the installation and for the quality inspector to physically identify each acceptable plate installation had been included in the procedure. The inspector reviewed noncompliances and their respective cor-rective actions pertaining to surface nounted plates in inspec-tion reports 483/80-09 and 483/82-19. 6
c-A reinspection of surface mounted plates installed by'the secon'd shift ironworkers was conducted by.the licensee during July and August 1982 in response to an NRC finding in report number 483/82-19. , Since the alleger stated that problems with surface mounted . plates occurred prior. to the reinspection of all the plates and the nonconfonning plates have been reworked to an acceptable condition, crafts and quality inspectors were retrained and certified and only one item of noncompliance involving one plate has been identified since 1980, the inspector has deter-mined that the plates meet the design criteria at this plant. This allegation is considered to be closed. (7) "No inspector training program existed at Callaway until , recently." The inspector reviewed the following: Daniel Administrative Procedure AP-VII-01, " Selection, Training, and Indoctrination of Quality Personnel", Rev. O, dated May 17, 1975, thr.ough Rev. 9, dated July 3, 1984.
. Training and qualification records for 15 inspectors who where working at Callaway prior to 1980. Each record indicated that the. individual's training had been conducted in accordance with Daniel Administrative Procedure AP-VII-01.
. During the NRC Region III Construction Assessment Team inspection (483/82-03), twenty-nne randomly selected quality control personnel were formally interviewed by NRC inspectors. The personnel interviewed included individuals form each construction inspection discipline.
Each interviewee was asked his opinion of the adequacy of the inspection training program. Each interviewee stated that he/she considered the training and indoctrination program to be adequate to prepare them to perform inspec-tions in their respective disciplines. training The implementation was inspectedofbythe theCallaway Quality (Inspection program NRC in 1978 Report No. 483/78-09). The inspection consisted of the review of the training procedures, training, experience and qualification records, orientation courses, records maintenance and licensee audit program relative to training and qualification of personnel. The inspection concluded that the QA/QC training program met the requirements of the hRC'and PSAR commitments in effect at that time. ; 1 7
\
~ . - . .
- . Based on review of archival revisions of Daniel training
.c procedures showing that a training program has existed since 1975, review of training and qualification records, interviews with QA/QC personnel, and review of previous NRC inspection -
reports, this allegation was not substantiated and is cor.sidered i to be closed. (8) The individual stated he was insolved in pouring concrete for a fuel transfer canal sump hole. The individual stated the tank that was placed in the hole was improperly mounted and the tank broke loose from the mounting studs. The individual described the mounting studs as being inadequate to hold the tank. The individual was also concerned that the repairs to the tank caused-a concrete " cold joint" which could cause the tank plating to rupture. The " tank" identified by the alleger is the liner for the opending pit. During the placement of concrete around the liner the anchorage for the liner. failed, permitting the liner to float on the concrete. This incident was documented on NCR number 2SN-0075-C. The approved corrective action was to remove the fresh concrete in the area of the liner,' prepare a cold joint
, according to Bechtel Specification No. 10466-C-103(2) and Daniel International Work Procedurd WP-110, replace the pit liner, and place fresh concrete in the area'around and beneath the liner.
The corrective action was reviewed and accepted by the architect / engineer. The alleger was correct in stating the liner became detached during the concrete placement; however, the contractor's corrective action was in accordance with approved procedures and reviev.ed and accepted by the architect / engineer.
. Since the fuel ~ pool liner is leak chased and not a Category 1 >
corponent, the inspector has no further concerns in this area and considers this allegation to be closed. (9) The alleger stated that during 1980, a concrete inspector (not identified) told the alleger of voids in the reactor building liner plate. The concrete inspector "took a piece of rebar and knocked on the plates...could tell the difference with the hollow ring effect in some places." The alleger thought this observa-tion was made on the reactor building west at elevstion 2047' and possibly lower on the same side. This item was addressed in inspection report number 483/84-22. It is common'to have a slight separation, or no bond, between the liner plate and the concrete. Generally, this separation is only a fraction of an inch and results from a combination of concrete shrinkage and dimensional changes in the liner plate due to teriperature. This slight separation is sufficient to give a hollow sound when tapped with a hammer, or similar object, especially when contrasted with the sound emitted when tapping an area backed by a stiffener angle embedded in the concrete. 8
~^ " ^ ' ^^~~^^~~ ~
y lL L - .:^' L . ~ 'L f . l Hollow sounds in the liner plate have been investigated twice previously. Once as a result of. Daniel QC identification and , ~ once at the request of the resident inspector. In both'in-stances.-the architect / engineer's evaluation indicated that the hollow sounds were not the result of voids behind the liner. Subsequent to the containment structural integrity test, walk-- s- downs by the resident inspector and a region based inspector did not identify deformations in the liner plate that would indicate unacceptable voids behind the liner plate. No defonnations in , the liner plato were observed at the 1947 level or below.
-' The review of previous. investigations at Callaway and Wolf Creek and other sites in Region III resulted in a determination that lack of bonding between liner plates and concrete would not have
-an adverse effect on containment integrity. This allegation is considered to be closed.
-(10)The_allegerstated,inpart,that;"theweldingdepartment is required to notify QC when structural , steel was to be welded. .
.However, QC was notified in 1975 and have not been called since.
- ' As a result, welders just went around and welded wherever they wanted...it says in QCP-113 that QC will be notified when
- structural steel will be welded...since QC was not notified a lot of welds were concreted without ever being inspected when problems were identified...when welding inspectors were notified, the inspector would just sign-off the weldments without leaving the office..."
The inspector reviewed-AWS DI.1, 1975 Edition and noted that the - Code does not specifically address notification of QC prior to. start of a welding process. However, paragraph 6.5.4 of the Code states; "The inspector shall, at suitable intervals, observe the technique and performance of each welder, welding operator and tacker to r;ake certain that the applicable requirements of Section 4 are met." The inspector reviewed DIC QCP-113 and rioted'that the requirement for OC notification when structural steel is' welded-is not included in the procedure. However, DIC 007-507, paragraph 3.7, states; The senior mechanical / - - welding quality supervisor shall be notified prior to the com-mencement of welding of material within the scope of the proce-dure."~ A sampling of the inprocess control surveillance reports were review?d by the inspector covering the period from 1977 through 1983 and revealed no areas of concern. In addition, the inspector reviewed weld data packages (travelers) that had been signed off by quality inspectors for inspection of fit-up of components prior to welding. Additionally, the packages included weld inspection records signed by both an inspector and a reviewer. During the past three years, the inspector personally obsarved fit-up inspections, in-process inspections, and final weld inspections of supports and restraints. 9
Interviews with personnel still onsite QC inspectors, civil engineers and one worker indicated that they knew of no instance where concrete was placed before welds were inspected. (11) " Deficiency reports are virtually extinct out there. They just always rework and don't write deficiency reports. I don't know if I should say they rework but...is conunon practice not to write deficiency reports, just try to get it to meet inspection require-rients 'and not reject it at first." "They just don't want to
. write DRs. It makes it look bad and they think...it looks bad for their department...Plus it's too much work and they'd rather not do it. If they find something they will just have the crafts keep doing it until they think it's good enough to sign-off..."
The inspector reviewed computer data listing the Defiency Reports originated since 1975. The data lists show the following: Year Deficiency Reports 1975 3 1976 75- , 1977 368 1978 - 552 1979 1,192 1980 1,993 1981 2,930 1982 4,755 - 1983 3,788 1984(toJune) 1,594 The listing shows that DR initiation rate follows the sitages of construction and increased activity through preoperational testing turnover (where each system was walked down by QC) then the large numbers during area turnovers. The above data shows that Deficiency Reports were and are being initiated during plant construction. This allegation is not substantiated and is considered to be closed. (12) " Problem in the waste water where they had this surge in water. Every time it rains they have this massive water flow through the well. I don't know if you call it effluent or sewage system...they've never been able to identify where it comes from...they've been looking at it for years." The waste water system and sewage plant are not safety related , systems et Callaway. The inspector determined through interviews l with pe'rsonnel cognizant of this alleged problem that the con- ! tractor had identified unusual flows of clean water through this I system. Investigation of these surges revealed that they were caused by demineralized water released during flushing and hydro-i 10
~. -- - . }' static testing of plant systems. No surges of water through the
- t. system have been observed since completion of plant flushing and N hydrostatic testing operations. No correlation has been established linking weather conditions to the flow surges. l Since licensee personnel have investigated this concern and .
apparently identified the source of the water and since this system performs no nuclear safety related function, the inspector has no further questions regarding this allegation. This allegation is considered to be closed. (13) During the Fall of 1983, a laborer (NFI) told the alleger tnat reactor dome liner sheet welds were corroded from acid in the air. The welds were described as having no weld metal left and -
"pla.ces you could stick a pencil in."
At the inspector's request, a 100% reinspection of seam welds in the reactor building dome liner plate by certified Daniel Inter-national Quality Inspectors was performed on July 6,1984. The inspector's observation of the reinspection and review of the results of the inspection indicated that.the welds had not corroded as stated in the allegation. During interviews with the NRC inspector, the Daniel Quality Inspectors stated they had not identified any welds that were not acceptable according to , the original inspection criteria. Based on the results of the reinspection and interviews with the individuals performing the inspection, this allegation is not substantiated and is considered to be closed. (14) At'about the time the fuel pool was to be tested, a hole was found in the liner. The alleger described the hole as "six inches wide, welded through the liner of fuel pool. But I'm sure they fixed that because they had to test it to hold water..." The alleger thought this hole may 4. ave been sabotaaed as "they just had it finished, just had it cleaned...I didn't really hear this sabotage. We kind a assumed it was...that somebody...the official word going through the bosses was that a welder fell against it..." The only hole in the spent fuel pool liner was identified on nonsafety related NCR No. 2NN-2198-CW on August 21, 1981, when during welding activities in the spent fuel pool a welding lead short circuited to the liner plate and burned a hole in the plate. The hole was repaired. The repair documentation in-cluding NDE reports PT-03965 and PT-03970 indicate that the repair was performed according to approved welding and NDE pro-cedures. 11 l l
f .
'V The spent fuel pool liner leak test, cordscted in May 1982, cid not discover leaks in the spent fuel pool liner.
This allegation was not substantiated as to the alleger's inference that the hole was a result of sabotage. This allegation is cen-sidered to be~ closed. (15)'
- Drains were stopped up because of the weight on top of the drains. Also drains were brcken because of the heavy equipment
.; , run over the top of the drains."
E The inspector examined docurentation showing that the safety related drains have been flushed and hydrostatically tested. Additionally, non-safety related drairs hne been flushed. The inspector performed a walk-through inspection of the auxiliary building, reactor building, and control-building to determine if drain covers were in place and plugs remosec. Je
' drains without covers or with broken covers were observed.
Screens or plugs that had been irstalled to pre.ent corstruction debris from entering the drains had been removed. -% 3 This allecation is not substantiated and is considered to be
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3 - closed. . (16) The alleger stated that he worked on the crew that pot *n tus rock beneath the Calleway Fuel Building, and he observed an escassive arount of moisture ir, the base rock. The allege." stated that qLality control inspectces checked the rois'.ure of the rock and found the rock was toc wet. The alleger observed that the rock was still wet after the fill wts cer-clete. According to the alleger the rock was wet even durir.c dry periods in the sunmer and this led him to believe that a spring existed beneath the base rock. The inspector examined photographs of the site showing views of the excasation in the area where the fuel building was erected. The photographs were taken at various times of the year prior to and during backfilling. No evidence of springs discharging water into the excavation was visible. The inspector interviewed persons who were present before back-fill was placed for the fuel building. Nene of the persons who were interviewed had seen evidence of water entering the eactra-tion from springs. Neither the Dames and Moore hydrological survey of the site, nor their test borings identified springs. k'ater was used to aid co paction of cranular structural fill ir e:cordance with Caniel Procedures WP-102, OCP-102 and Sverdrup 1 and Farcel Specification adde dA(Q) which would account for l moisture (wetness) in the fill even in dry periods of the sner, i The inspector c v siders this item to be ursubstantiated and closed. 12 l 1 1- ----- .- -.---- -._-,- __-----_----__---__-_------,.-----__------,---_---------_-.-w-----,--_-
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(17) They have had a lot of problem with the water in lower levels of s the building, and they constantly have to pump them out. And in big rains I've seen down in lower levels they had a whole bunch of cables-going outside and water just pouring in there..." The alleger is correct in that water did enter the building through the wall penetrations at elevation 2000 and below for construction cables during heavy rains. These openings were closed when the cables were removed as no longer needed, over a year before NRC's receipt of the allegation, and the penetrations sealed. The inspector verified that the cables have been removed and the penetrations sealed and that water does not enter the building on the lower levels identified by the alleger. There is no evidence that water entering through these penetratio'ns damaged safety related plant equipment. The inspector considers this item to be closed. , (38)DuringtheSpring1983,theallegerobservedthataconcretepour had begun on "a wall on a cooling tower building" (possibly a pump house) without having mud cleared from the forms. The alleger noted that approximately 4" to 12".of mud stood in the forms before it was cleared out but that after cleaning, one to four inches of mud were left in the forms. There are no safety related structures in this area, so a wall on a cooling tcwer building would not be a safety related wall. The inspector reviewed NRC civil inspection reports covering 1976 through 1983 which did not identify any concerns regarding mud in forms prior to concrete placements for safety-related structures. This item is considered to be closed. (19) The alleger also described a situation during a concrete pour for the site cooling tower's ring footers. The alleger observed
" mud boiling over the reinforcing rod." The alleger continued -
to pour concrete at his foreman's direction, as the alleger thought he would be disciplined for insubordination if he stopped pouring concrete. The NRC was advised of this allegation on May 1, 1979, by an ironworker who worked for the contractor. The cooling tower is not a safety related structure. It is located approximately 1200 feet from the nearest safety related structure. The NRC does not assume jurisdiction over structures or components whose failure would not affect nuclear safety. This item was refered to OSHA on May 4, 1979. This item is considered to be closed. 13
(20) The alleger noted that the bottom level of the Callaway auxiliary
! building leaked. The individual thought the source of the water may be the spring beneath the fuel building base rock. The leaks were stopped by using "waterplug". The alleger observed that the Callaway reactor, fuel and. auxiliary buildings were separated by "Rotofoam" and at the 1974' elevation the auxiliary and reactor buildings were also separated by cork. He stated that the cork in a " hot room" on the 1974' elevation of auxiliary building was exposed and had been damaged by the water seepage. The alleger was concerned that the water seeping into the cork in the " hot room" could become contaminated with radiation and then seep into the environment. The individual thought this concern could be
- corrected by installing a curb or wall in the " hot room" to deflect the water into the sewer. The individual made a sketch of this concern during the interview. The individual asked 6
Region III to look into the material characteristics of the plugging material. , The area discussed by the alleger is on the 1974' elevation at the seismic isolation vertical joint between the reactor building, auxiliary building and the fuel building. The seepage of ground water through the joint was identified on NCR No. 2SN-9608-C in February 1984. The NRC inspector's observations indicated the amount of seepage varies with weather conditions. Seepage increases after heavy rains and decreases to a level such that it is not visible during dry weather. This variation indicates that the seepage is not caused by underground springs beneath the backfill. Disposition of NCR 2SN-9608-C required removal of the existing
*- styrofoam material and replacement with a silicone based material.
The silicone based material was approved by the architect / engineer. The styrofoam has been removed but the new material has not been installed. The architect / engineer performed an analysis of the result of a radioactive water leak in the area. It was determined that water would flow into the drain system since there are four drains in close proximity to the waterstop. However, in the event sore of the water reached the waterstop and leaked to the surrcunding ground, the radiological consequences would be minimal and are enveloped by the accident analyses presented in Section 2.4.13 of the Callaway FSAR Site Addenda. This item remains open pending review by Region III radiation protection inspectors (50-483/84-30-01). (21) Until three years ago cheating was done on inspector certifica-tion exams. Answers were given, test takers were coached, and copies of exams were available before the exam was administered. 4 14
+
.- l I {; Fessible compromise of DIC Quality Inspection Certification pro-gram was reported to NRC as a potential construction deficiency pursuantto10CFR50.55(e)onMarch 29, 1983. The investigation by the licensee and DIC detennined that a 10 CFR 50.55(e) condi-tion did not exist and the report was withdrawn. The item was closed in NRC Region III Inspection Report No. 50-483/83-13. The inspector reviewed the notifications of possible test com-promise to the Atomic' Safety and Licensing Appeal Board dated
- April 8,1983, and April 28, 1983, that described the incident and the licensee's corrective action.
O The inspector reviewed signed statements from quality inspectors in which the inspectors stated that they had not received test answers, questions or materials that identified test information prior to being tested. Licensee and contractor investigators interviewed 145 inspectors randomly selected from all disciplines. Results of these inter-views indicated that the testing program had not been compromised. The practice of having both written and practical examinaticns made cheating difficult. The failure rate.for examinations
'of eleven percent is not indicative of widespread cheating on the examinations.
Additionally, discussion of QC inspector training is provided in
/ paragraph 4.a.(7)above. $
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This allegation was not substantiated and is considered to be closed. (22) Daniels International conducted an investigation into the test cheating and three people who truthfully answered the questions were fired. The inspector determined that six persons had been terminated during the period March through June 1983. Of these six, only one individual had been interviewed during the investigation. This individual had stated that he did not know of any instances of test cheating. The individual was tenninated for disorderly conduct. He is presently employed by Daniel International at another construction site. e' This allegation is not substantiated and is considered to be closed. (23) The alleger stated that he twice assisted in inspections of structural steel bolt torque and found the bolts were overtorqued. Reinspections of the plates found that not only was the torque improper, but also that the wrong nuts and bolts had been used. The reinspections also found the wrong projection existed. 15
f By design structural steel bolted joints were not tightened with a torque wrench, rather load indicating washers were used (/ for assuring sufficient bolt tightness. In addition to verifying bolt tightness at initial installation, the licensee conducted a 100% reinspection of structural steel bolting during 1983. One of the attributes reinspected was sufficient bolt tightness. . The inspector reviewed documentation of anchor bolting for surface , mounted plates and inspection of concrete expansion anchors (CEA) ' o' . _ installed in safety related systems. This documentation indicated that nonconforming bolts and nuts had been replaced where identi . fied. The inspector's walkdown of safety related areas did not- + identify nonconforming nuts and bolts. Additional discussion of the inspector's review of surface mounted plates is provided in
< paragraph 4.a.(6) above.
.. ,sa ?
This item is considered to be closed.~- l
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}v (24) Structural steel was installed, bolted and inspected; however, ~
the crafts later removed the steel and bolts to move in equipment. ,* The steel and bolts were reinstalled, but were not reinspected.. These bolts and steel which were not reinspected were covered
.- over with concrete or spray roating. This occurred in at least the diesel generator building. . -
3 .
. The installation and subsequent removal and reinsta11ation of structural steel was addressed in NRC Inspection Report
~, {-s No. 50-483/77-10. Structural steel bolting was reinspected during 1983. The reinspection encompassed all accessible high strength structural steel bolting in the diesel building, control building, auxiliary building, reactor building and fuel building. Fireproofing was removed to make bolts accessible for reinspection and then replaced. The inspector reviewed records of special training on proper inspection and installation techniques relative to load indicating washers presented to quality inspectors and ironworkers. The reinspection of high strength bolted structural steel connec-tions in safety related structures covered 21,362 bolts. The connections were inspected for proper fastener grade, proper fastener assembly including correct orientation of load indicating washer and proper bolt tension as indicated by the load indicating , washer gap readings. Portions of the reinspection and corrective actions were witnessed by the NRC resident inspector.in the diesel building, auxiliary building, and reactor building.
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tp=Jhf%-a.mvm ,*-e.4w w w-e4e. shy e The inspector reviewed the sequence of installation for equip-
- ment. Major components were installed before steel that would
,e have to be removed was installed. Bolts for structural steel that would have been removed are accessible and were included in the reinspection of 1983. ' The inspector deterinined by visual inspection that. equipment may be installed or removed in the ,
diesel room without removing installed structural ~ steel. Based on review of reinspection documentation, and direct observation by the resident. inspector, this allegation.was not substantiated and is considered to be closed.
. b. Allegation regarding post applied heat numbers (ATS No. RIII-84-A-0060).
It was alleged that pipefitters had installed hangers using materials which did not have identifying heat numbers applied prior to installa-tion at the Wolf Creek and Callaway plants.and that the craft would go ,
, to an identical hanger erected previously, copy the heat number and ' ,
stamp the number on a hanger without a heat number. The incorrect 7 number would then be written on the documentation for that hanger. Field fabricated hangers were the princirial hangers without heat: . , numbersandtraceability. The alleger indicated that hangers coming . ~ from the fabrication shop had heat numbers stamped on their components
- l. in the shop and that field fabricated hangers were usually stamped, (sometimesvibroetched)bythecraftinthefield. The alleger stated that his foreman told him that should he ever be caught stamping the numbers on hangers without heat numbers he was to say he was only making the numbers deeper. He did not recall the name of his foreman
(( who directed him to apply the heat numbers. He stated that only the craft knew of the post application of heat numbers. He indicated that the post applied heat numbers were on pipe supports in the reactor building between' elevations 2000' and 2015'. The seven pipefitters and two hanger quality inspectors remaining onsite stated that they were not aware that heat numbers were being applied after the hanger had been installed. They indicated that when heat numbers were applied in the field, that the heat number on the documentation accompanying the hanger material was applied to the hanger. The inspector examined safety related pipe suppor,ts in the reactor . building below the 2015' level and did not observe vibroetched heat numbers on safety related hangers. The inspector'did not examine nonsafety related hangers. The inspector reviewed procurement specifications for steel shapes used at Callaway. Specification No.10466-M-218 and 218A requires that material supplied to the site for pipe supports will be safety grade material fabricated in accordance with a quality assurance program per Subsection NF of ASME Section III. Specification 10466-C-1310 requires that structural steel supplied will be safety grade material in accordance with an approved quality assurance program. ( d I 17
This item is considered to be closed for the following reasons: (' (1) All hanger material was procured as safety related material. (2) It was welded by qualified welders and it was inspected by certified quality inspectors. (3) The NRC inspector identified no problems during his review of this' allegation. (4) The alleger was ur,able to provide datailed infonnation identifying the pipe supports or systems with the allegedly falsified heat numbers. , -
- c. MATSCO Quality Assurance Deficiencies (ATS No. RIV-83-A-0072).
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The resident inspector received a telephone call from an ' individual with concerns about MATSCO, a Dallas, Texas finn who supplies testing and metrology services for the nuclear industry. The caller stated that MATSCO Quality Assurance had inadequate organizational freedom and indcpendence. That they were not permitted to hire their own personnel. He also stated that MATSCO auditors in the field reported to the operations manager and not the QA manager and that personnel were sent to sites without adequate screening. He stated that MATSCO personnel were involved in preoperational ~ testing at Callaway, Wolf Creek, Fenni, Clinton, Grand Gulf and Waterford sites. In addition, they provided metrology services at
?- Comanche Peak and Northeast Utilities.
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The caller stated that he had called the licensee Quality Assurance Manager prior to calling the NRC. The caller was advised to call the NRC Region IV office regarding ti e 10 CFR 21 notification since he (' was located in Dallas, Texas area as was the Region IV Office and that the Callaway inspector would forward his allegations to Region III. The inspector verified that the same allegations had been made to the licensee.
'The inspector reviewed the report of a special QA audit of MATSCO per-formed by the licensee in response to the above allegations. MATSCO was only one of several companies providing personnel for Callaway's preoperational test program. Preoperational testing at Callaway was perfonned under the SNUPPS 0A program for Design and Construction.
NRC Region IV Vendor Branch Inspection No. 99900539/83-01 was performed at MATSCO as a result of these allegations. No violations were identified during the inspection relative to the qualification of test engineers or technicians furnished to Callaway, QA independence, or auditor reporting. Preoperational testing personnel at Callaway were certified under the Callaway QA program. In addition, the inspector reviewed licensee audit reports which demonstrated that personnel qualifications have been routinely audited during preoperational testing. This allegation is closed. , (-
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- 5. Battery Cell Spacers The inspector reviewed NRC Vendor Programs Branch Report No. 99900841/84-01
, for GNB Batteries. Incorporated which discusses the failure of open cell battery spacer material in that the matbrial became permanently defonned when compressed during seismic testing. ' The original open cell urethane material was replaced by c1csed cell polyethylene material and the seismic
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qualification test was repeated with no failures. - - I GNB developed an approved procedure for the replacement of open cell spacers with closed cell spacers and ryotified SNUPPS. The inspector examined the Bechtel Field rework plan RE-050-A for Ca11away' showing completion of the spacer replacement and Certificates of Conformance showing the material and workmanship to be according to specifications. The rework plan was signed as completed by the vendor and verified to be ' complete by the responsible licensee test engineer.
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- 6. Exit Interview The inspector met with licensee representatives at. intervals during the report period. The inspector sumarized the scope and findings of the
!- inspection. The licensee acknowledged the findings' as reported herein.
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