ML20150C521
| ML20150C521 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/24/1978 |
| From: | Wilt D STEWART & DECHANT CO. |
| To: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20150C524 | List: |
| References | |
| 781028, NUDOCS 7811240072 | |
| Download: ML20150C521 (3) | |
Text
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O STEWART AND DECHANT CO.. L P. A.
ATTORNf YS AND Col:NSELLORS AT LAW LAWRL N C E E 5T EWART Ti(OMAS H. DECI! ANT CL VELAND, OHIO 44114 CALVIN I. k lH RD. IR ARL A CODL 21G GLORG)
- 1. I RAN I Z 78b22b8 twm L D. Wirr October 24, 1978 i R E D Wf N D E L 111 RODF RT f, VOI H SCOT ~r f.. STEWART MARK 11 KN f V1.L Mr. John C. Davis Acting Director Office of Inspection and Enforcement United States Nuclear Regulatory Cottnission Washington, D. C.
20555 RE:
Perry Nuclear Power Plant
Dear Mr. Davis:
Thank you very much for your letter of September 19, 1978, together with its enclosures.
I have now reviewed the enclosures, particularly dealing with the January and Pebruary NRC inspection of the Perry Nuclear Power Plant.
I have several questions dealing with the inspection, particularly, as it relates to the NRC Reactor Safety Philosophy.
As I understand, the results of t.he inspection, there were eleven (11) separat. items of non-compliance whic a were brought to the attention of the Iltuminating Company.
Several o these items seem to r
deal with adequacy of paperwork, but several more of the items deal with rore substantial matters such as quality control, quality construction and quality storage of the materials being used to build this pouer plant.
It is tay understanding of the NRC React ir Safety Philosophy program that the NRC concerns itself with t hree taain areas.
These areas deal w.ith the initial design of the plant; the proper construction of the plants; and the eventual safe operation of the plant.
In order to assure itself that the nuclear plant is being built according to standards, the NRC issues regulations which minutely acal with construction matters, audit procedures and quality assurance programs.
781124O 07Z
From my reading of the specific complaints levied against the Perry Nuclear Power Plant, it would appear that quality assurance pro-grams were not properly implemented; that there were several instances of non-quality construction; there were several instances of non-quality storage of materials, Two major points of the inspection and the response of the 111uminating Company concern me.
First of all, your inspector discovered that the National Mobile Company was preparing concrete not in accordance with the applicable standards of the NRC.
The National Mobile Company was preparing concretc in accordance with Revision Six (6) of Sp 4549-00, even though this specification was revised by Revision Seven (7) and even though the National Mobile Company had actual notice of the revised specification.
Your inspector reported that more than 140,000 cubic yards of concrete had been placed which was not in accordance with Revision Seven (7).
The Illuminating Company responded to this infraction of NRC Regulations by stating that Revision Seven (7) of specification Sp 4549-00 dealt with matters in the following areas:
1.
Expansion and clarification to remove redundancies acd resolv2 conflicts; 2.
Modification of certain procedural changes that did not effect quality; 3.
Modificatiens of certain requirements to facilitate field conditions wfthout sacrificing quality.
In other words, I take it that it is the position of the Illuminating Company that Revisio't Seven (7) dealt more with procedural matters as opposed to quality considerations of the actual concrete.
I would.like to know what the NRC response to this position is D:ac tly what d Ld Re-vision Seven (7) of this specification do and are there any consider-ations in Revision Seven (7) which specifically deals with quality of Concrete.
Another infraction of the NRC Regulaticas chich concerns me deals with the " batching" of the concrete.
Appar :ntly, this was done again not according to standards in the view of your inspector.
In fact, your inspector had to call this infraction to the attention of the appropriate officials at the plant twice and had to threaten a stop work order in order to gct compliance.
This seems to me to be indicative of a very serious lack of concern on the part of cit aer Cl3 or of its subcontractors.
My fear is that if improper construction.ls done in the very view of an NRC Inspector who is there only ol occasion, what goes on when there is no URC Inspector on site?
-?-
h Other quality assurance violations deals with welds, the storage of materials, and the fict t.ha t some of the personnel who were suppose (ly quality assurance inspectors, where not fully advised as to their jobs.
It seems that it is at the heart of NRC's Reactor Safety Philosophy program that much of t.he quality assurance standards are lef t to the contractors and subcontractors of the utility.
Obviously, it is impossible for the NRC to have an inspector at a construction site at all times. Due to the extremely critical nature of the components and materials being dealt with in the construction of nuclear power plants, with a track record the CEI obviously has, how can the NRC be assured that quality construction procedures will always be used and followed?
I would also like to know what part of the nuclear power plant was being built with substandard concrete? Has the Nuc] ear Regulatory Commission verified that seventeen (17) reactor building columns are, in fact, being repaired? Has the NRC verified that the welds which were cited to be improper, have been repaired, and further, t. hat welding is being done according to NRC standards?
Senator Glenn sent a letter to Dr. Hendrie, wherein he quest.ioned whether or not the NRC was insuring that a more severe set of safeguards l
were being imposed on the Illuminating Company due to the fact that the l
reactor was being luilt very close to a large urban area.
I have not yet received a response to Senator Glenn's question, and I would very much like to have a response to his question.
1 In reviewing the materJals you sent to me, it is obvious that l
the NRC conducted subsequent visits to the Perry Power Plant.
I would l
like to obtain copics of these inspection report a f or my review.
Thank yot for your cooperation in this matter.
Very truly yours,
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D'aniel D. Wilt l
DDW/kgb CC:
Senator John (lenn Dick Sering CJeveland Coalition >
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