ML20151X026
| ML20151X026 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/10/1986 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20151X013 | List: |
| References | |
| 2.206, NUDOCS 8602120265 | |
| Download: ML20151X026 (28) | |
Text
.
[7590-01]
UNITED STATES NUCLEAR REGULATORY COMMISSION
[ Docket No. 50-483]
UNION ELECTRIC COMPANY (Callaway Plant, Unit 1)
Notice is hereby given that the Director, Office of Inspection and Enforcement, has denied a petition under 10 CFR 2.206 filed by Alan S. Nemes, Esq. on behalf of Missouri Coalition for the Environment and Kay Drey.
This petition is related to the Callaway Plants Unit 1.
In the petition, Missouri Coalition for the Environment and Kay Drey alleged that the Union Electric Company's revoking the certification of quality control inspectors found to have questionable qualifi-cations in early 1985 raised questions as to the adequacy of the inspection process and the safety of the Callaway Plant.
In addition, they alleged that the failure of Union Electric Company's management to identify the problem with inspector qualifications for at least four years showed that the. utility violated its legal obligation to continually monitor safety inspections at the plant and to provide inspectors with direct access to levels of management sufficient to assure prompt reaction to safety violations.
The reasons for the denial of the petition are fully described in the
" Director's Decision Under 10 CFR 2.206" issued on this date, which is available for public inspection in the Commission's Public Document Room located at 1717 H Street, N.W., Washington, DC 20555 and in the local public ENCLOSURE 2 860212026S 060210 hDR ADOCK 030004g3 PDn
document room for the Callaway Plant, located at the John M. Olin Library, Washington University, Skinker and Lindell Boulevards, St. Louis, MO 63130.
A copy of the decision will be filed with the Secretary for the Commission's review in accordance with 10 CFR 2.206(c).
Dated at Bethesda, Maryland, this 10th day of February
, 1986.
- FOR THE NUCLEAR REGULATORY COMMISSION i
/
w WS &
/
/ James M. Taylor f, irector
[
Office of Inspection and Enforcement V
O e
I ;
{+
._.m.
_,__u, m
.m.,.,,,__r
_y.m__e._,,..
___,,7m..
s.,_
.,.cm
0FFICE.OF.JNSPECTION AND.ENFORCEP
~ CT O\\
0FFICE OF THE DEPUTY DIRECTOR 1.
IE ACTION NUMBER 85-165
- 2. DATE: 4 17/85
)
3.
SUBJECT:
EDO 523 2,206 - SHOW CAUSE PETITION REQUESTING SUSPENSION OR REVOCATION OF OPERATING LICENSE FOR UNION ELECTRIC COMPANY'S CALLAWAY NUCLEAR POWER PLANT, UNIT 1 m
n4W 4.
REQUESTOR:
Missouri Coalition for the Environment. 3/25/85 4,# pa 5.
ACTION REQUESTED:
Respond to petition.
df s
_ jft vgm g W
\\ N cs loM 4g ff V
6.
ASSIGNED TO:
/
N
.7.
EXPECTED COMPL ON DATE-
'c f
/
8.
EXTENDED COMPLETION DATE:
9.
COMPLETION DATE:
10.
DOCUMENTATION OF C0t1PLETION:
.11... RETURN THIS FORT 1 TO DEPUTY DIRECTOR'S OFFICE WITH COMPLETED ACTION gt,/ss q '.d M M 7/o/SS M-peos w ded evn g n "//v sr
/
srAc 9'
rs 3
Ill9/sf pnna. dwu/
u m asi.pprg) b em u w+si u kdatuy m, s.
mw my a ~w T'
- o. e a*
, a w w p g >o&c w y.too W-
9,b..'a M % %:."'=;.z w e j'e.i.
gl,.; %. w,.
..t,...
m.<.,c..,,,t.,.
i
. oww -- u.-s. em.. % t.qs -.
..,.,,..,. g. ; e..
s e
..r2
. m
,,h.r s. m.
a.
w u..r 6%..y..a p~ r...
e g.,.1-,3 m.-
.o e
,a
- n..s,..
- 4 ;, 4 g ; ;; ; 'F 4..<., b,. % g,p eg.... j.
...,..... ;, g
.- f
. w.,
w...
.. -w
. +'p r
V' 4.w i..7-Jqgeg.5.;' s ;.:,M pg..,/6'W4' UNITED STATES g
>;' M F.7.+ '
R J.
2' q
g.
s, s e -,.e.ig.:3. a
-;2h e:..r. g'Q.vyh:-. '1;f 3' NUCLEAR REGULATORY COMMISSION ; /* '~
- ' " ~ *
.- A f.
,J.- N wa
- '5-C.
. ;[.
I ;.;g..','.,. r, ;,.'. 4./ + J,.. J
- n...:, *f ;.,.gungeTOtt. D. C. 200m.
.v.-
_,.-+,.v,', _ u".. x... - u.w., %..,. w.-:..
...,...s..
m.
.. s
-......M,,%4 MED0i.! PRINCIPAL CORRESPONDENCE CONTROL....
,t.
..%,' ',* * 'Q '.,.,..* v@f l' G.?: 7.y'.M.... f. n1.wr.Miforp.%...
.. pq;g
,l.z..: :# *
. ' '. ~..* A,,.,s* (
% 4 s '. e
- e.
... m
~
FROM'.
- ,0~..,
L. 95/05/0,~5.
. EDO CONTROL: 000523
.,.t,.,,,..:.-
~..
,... m.,._
T,...
DOC DT: 03/25/95 ALAN S -NEMES ..,.. e..
- .p r.-l. c....-7....-
.h-2.,. c
~
FINAL REPLY:
MISSOURI COALITION ~ FOR. THE ENVIRONMENT"
.,.a;.
z.c.
.L KAY.DREY (PETITIONERS *?
E
- 2. *. w.D'yNJ W.. -....
. 20 - [" hp ';, ' eY.f.** * ',.
I N.,I.' *y
~. *..,.
1
- h l..'.". * !. L,.
, )....,.,p gec u.- n.-r. '...Q:.. *,c.,
f s
.TO..s. :.,...fr,, -, a..
...v.
,.... m gt.
, a. m -. '4. &. :/.cv., t.$,,.-.. 1. L
..v:...-se e e....
,,-a..,..w.m..
.n:
- y.a.w F %;.va....
--, a.
-.r+
- .,,y..
y w3 1M
- s w.
5
-~~;;a a.w...n.x a ?,:..,.n..,,...:.._ -
- .v.. < g3gsup
- .. y,,g.Os..;.. :.
.v-x
.~.
e.
.~.y ;.
. - 2 u., 3 g::y.s -. q.n -.,-:.a.. ra m.
.g,. -, r.
m,. s. v -h...
m;_
.. w w. :r...., e. c..,p..y,w,. w.. gt ~ ; <,r., -.. c..,c..g.-j y m c.,.
2...
S.<.
.e n
.FOR'SIONATURE oft-a,w..i.' a c..w w O R E E N c.tHt h r., g ; ' f.
, d:. *
~ ;.'.ey %.. [< v.. SECY. NOsa
~::;...,.'. *.
i:.~.y..
. z.,* \\.
. *j
~
}*
r
+
s.
..?
-,,a il, t.
y _3 g :_., j;..,,. f t./..
. s..J,,....
g.
.:~ v.,. m..,:cv r w.'
.a E. 7 3 e-.
e
- ~ ww' y, ~~--9: w ~ '.N..d,BOUTINOs..
..,..,.3 2.206 - SHOW CAUSE PETITION REQUESTING SUSPENSION'5.;U.JIhENTON
->4-OR REVOCATION OF OPERATING LICENSE FOR UNION
- -t.
O. TAYLOR T'
ELECTRIC COMPANY'S CALLAWAY NUCLEAR POWER PLANT,
- M 3 *' 'f,'i UNIT 1,.
- 1. ' *p. g.k..
f*
e, DATE: 04/04/85
- ' hhY
$4
' f m'c.:-
ASSIGNED TO: Ert5 'IU CONTACT: 4t$NNtNGHAM '
~ c
'~
SPECIAL INSTRUCTIONS OR REMARKSt r
,7 *,.* -.. v t,:. a -
n a
c
.t
~
'855720' d
t I
t
o UNITED STATES I,,n NUCLEAR REGULATORY COMMISSION T(
WASHINGTON,*o. C. 20555
~^
April 16, 1985 MEMORANDUM FOR:
'J'amas Taylor,. Dimetera Office of Inspection and Enforcemen'.
FROM:
James Liebennan, Director and Chief Counsel Regional Operations and Enforcement Office of the Executive Legal Director
SUBJECT:
10 CFR 2.206 REQUEST SUBMITTED ON BEHALF OF THE MISSOURI C0ALITION FOR THE ENVIRONMENT AND KAY DREY CONCERNING THE CALLAWAY PLANT On March 25, 1985, Alan S. Nemes, Esq. on behalf of the Missouri Coalition for the Environment and Kay Drey, submitted a petition pursuant to 10 CFR 2.206 requesting that an order be issued to the Union Electric Company to show cause why the operating license for the Callaway Plant should not be suspended or revoked pending a " full investigation" of the " violations of law" described in the petition, and further, why the other actions requested should-not be taken. The other actions requested by the petition include:
- 1) an independent investigation of construction and operations quality assurance personnel to determine whether such personnel have met and continue to meet the appropriate qualifications for their level of responsibility; 2) an audit of all testing and inspections undertaken by unqualified QC personnel; and
- 3) an independent inspection of all work inspected by unqualified personnel or reviewed by unqualified personnel. As is evident from the nature of the relief sought, the Petitioners base their request on the possible use of unoualified quality assurance inspectors at Callaway. The petitioners attach several newspaper articles to this effect in support of their request.
' 'Although the petition is jointly addressed to you and Harold Denton, the issues raised and relief requested appear to be more clearly within IE's programmatic responsibilities, and thus, is appropriate for consideration by '
IE. Nonetheless, I would expect that the assistance of Region III and, to a
~
lesser extent, NRR will be necessary in preparing the final decision. You might also note that presently pending in NRR is another petition concern-ing the Callaway Plant. However, the nature of the issues raised in that petition are substantially different from the issues raised by the Missouri Coalition such that it would be inappropriate to treat the petitions together.
We will assist you in responding to the petition. We have enclosed a draft acknowledgement letter and Federal Register notice for your use. The letter and notice should be issued as soon as possible.
If you desire the licensee to respond to the petition, we will assist your staff in drafting an appropri-ateletterunder10CFR650.54(f).
CONTACT: Lillian Cuoco, OELD X27036
. ;.y.
Please ensure that I am on concurrence and distribution for all correspondence and am inforined of me,etings related to this. matter.
j mes Lieberman, Director and Chief Counsel Regional Operations and Enforcement Office of the Executive Legal Director
Enclosures:
1.
Incoming Petition 2.
Draft Acknowledgement Letter 3.
Draft Federal Register Notice cc:
H. Denton, NRR J. Keppler, RIII E. Christenbury, OELD
- eune e
-~-.-m,-, - - -. ~,. -
--s--
,nn.,_-_,
w
March 25, 1985 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission p'
Washington, DC 20555 Show Cause Petition Requesting Suspension or Revocation of Operating License for Union Electric Company's Callaway Nuclear Power Plant, Unit One.
I.
Introduction Come now the Missouri Coalition for the Environment and Kay Drey (" Petition-ers") to petition the Director of Nuclear Reactor Regulation, and the Director, Office of Inspection and Enforcement (" Director") of the U.S. Nuclear Regulatory Regulation, pursuant to 10 CFR $ 2.206 to serve upon the Union Electric Company
("UE") an order to show cause why the operating license for the UE Callaway Nuclear Power Plant, Unit One ("Callaway Plant") should not bessuspended, pending a full investigation by the Ncclear Regulatory Commission ("NRC") of the viola-tions of law described herein, or revoked, and why such other actions as request-ed in this Petition should not be taken.
, I I,.
Description of Petitioner 4
Missouri Coalition for the Environment is a non profit corporation dedicated in part to ensuring proper safety control and environmental protection in the generation of nuclear power and is the successor in interest to an intervenor in the proceedings for issuance'of an operating license at the Callaway Plant.
Kay Drey is a rate payer of UE and a Missouri citizen concerned with proper protec-tion of public health and safety with regard to the generation of nuclear power.
III. Authority Title 10 of the Code of Federal Regulations, 9 2.206(a), establishes the right of the public to petition the Director to institute a proceeding pursuant to 10 CFR $ 2.202(a) to modify, suspend, or revoke a license or for other relief.
Such a petition must set forth the factual basis for the petition and the relief requested.
The Director may, pursuant to 10 CFR $ 2.202(a) institute such a proceeding by serving upon the licensee an order to show cause.
1 EDO 000523
-,.-,-+..----,.-.,.---.,.,my-%
%m,
_,y-.y-w%-_,,_g.,_-~w--
-r----
---,+c-
---w-t----vv- - - - -e r+-----w---r----
e -
UE has permitted -at least twenty two unqualified inspectors, including personnel responsible for supervising safety inspections, to undertake testing and inspections that UE, the NRC, and the public rely upon to insure safe opera-tion of the Callaway Plant.
Inspectors without proper training and expertise have for at least fou'r years tested and inspected every portion of the plant including the reactor building, assuring management, regulators and the public that electrical systems, civil work, mechanical systems and materials are in conformity with prescribed designs for operation and maintenance of the plant.
The disqualification of these inspectors raises serious questions as to the adequacy of the inspection process and the actual safety of the plant.
In addition, the failure of UE management to identify the problem for such an extensive period, despite complaints from the inspectors themselves, reveals violations of UE's legal obligation to monitor safety inspections continually at the plant and to provide inspectors with direct access to levels of management sufficient to assure prompt reaction to safety violations.
i V.
Facts 1.
UE operates the Callaway Plant pursuant to a facility operating license granted by the NRC in October of 1984 (License No. NPF-39).
Construc-tion of the plant was completed in 1984 under a construction permit
- granted by the NRC in April,1976.
2.
UE is required by law to institute and maintain a quality assurance program ("QAP") at the Callaway Plant, during both construction and operational phases. The QAP is designed to assure that every aspect of the design, construction, operation and maintenance of the plant meets the standards set by the NRC to protect the health and safety of the public.
The foundation of the QAP is the quality control program' 4
("QCP") which involves safety inspections and testing of the physical characteristics of materials, structures, components and systems throughout the Callaway Plant.
}
3.
NRC regulations and UE policy mandate quality c'ontrol ("QC") personnel j
be certified as meeting specific training, educational and technical standards in order to insure competent and accurate safety inspections and testing.
4.
Since at least 1981 and until recent weeks, during both construction i
and operational phases of the Callaway Plant, UE has, by its own i
admission permitted an undetermined number of its QC inspectors, 1
including several individuals in supervisory capacities, to conduct inspections and testing for which they were unqualified by NRC require-ments, UE policy, and industry standards.
(The facts relied upon herein, unless otherwise noted, are derived from Exhibits "A" and "B" j
attached hereto, being copyrighted stories in the Columbia Daily
(
Tribune for Thursday, March 7,1985, page 1 and Friday, March 8,1985, page 1 and Exhibit "C", an article from the St. Louis Post Dispatch dated March 26, 1985.) Published articles originally indicated that UE officials had illegally certified at least seven of thirteen QC inspec-tors to undertake inspections for which they were not qualified; only in the recent weeks has UE reportedly decertified these inspectors to i
2
- _. _., ~, -. - - - -,.. - -. -
conduct inspections in specifTc~ areas.~ UE is internally reviewing the
^
qualifications of some fifty to sixty other quality control personnel employed by Daniel International Company, UE's contractor at the plant and other subcontractors, in order to determine whether these inspec-4 l
tors were properly qualified in accordance with regulations. As of the date of submission of this Petition, the number of unqualified inspec-tors has expanded from seven to twenty-two.
The disqualification of the QC inspectors cast doubt upon the validity of least 12,000 work inspections conducted throughout the plant, including those undertaken r
within the reactor building. All of the quality control inspectors described above undertook inspections in one or more areas for which i
they were not properly certified including mechanical, civil, electri-l cal, and materials divisions.
t The NRC relies heavily upon the accuracy of the safety inspections.and 5.
1 testing reports issued by UE's Quality Assurance ("QA") including QC personnel, in order to assure proper functioning of the Callaway Plant and adequate protection of the public health and safety.
In addition, the NRC has relied substantially upon such reports in previously rejecting allegations of safety violations at the Callaway Plant.
(See e.g., Report #50-483/84-45(DRP).
6.
QC inspectors repeatedly and over a long period registered complaints to assistant QC supervisors about unqualified inspectors and supervi-sors, but no actior, was taken by UE.
Inspectors then took their complaints directly to the QA department in December of 1984 but the QA department did not order an audit of the problems for nearly two months thereafter.
l 7.
According to UE officials, supervisors and assistant supervisors in the QC group need not be certified to conduct inspections although they routinely review QC inspections and technical questions of QC inspec-i tors.
Reports indicate that despite such lack of training, QC inspec-tors were ordered by an assistant QC supervisor not to seek technical advice and information from other QA personnel.
8.
UE's QA department has itself determined that UE has violated company policies and NRC regulations regarding qualification of at least twenty i
two QC inspectors, including inspectors with supervisor capacity, and has moved to suspend these individuals from performing inspections in areas for which they were not certified.
UE has reportedly undertaken an audit of over 12,000 work orders dating from 1981 to review the extent to which its thirteen QC inspectors and some sixty inspectors of Daniel International Company and its subcontractors have conducted 4
inspections for which they were not qualified.
4 i
VI.
Conclusions of Law 2
1.
The license under which UE operates the Callaway plant (Facility Operating License #NPF-30) is conditioned upon UE's continued comp 11-ance with the NRC's quality assurance regulations for nuclear power plants.
10 CFR $$ 50.54(a)(1); 50,55(f)(1) 10 CFR $ 50, Appendix B.
4 k
3
}
i
+ -.,.. _, - - - - - -, _ -.. - _ - - _
2.
NRC regulations require that tE QAP, inc15fng QCP " provide for the indoctrination and training of personnel performing activities affect-ing quality as necessary to assure that suitable proficiency is achieved and maintained *.
10 CFR 5 50, Appendix B(I) 3.
The NRC defines " suitable proficiency" for QA, including QC, personnel as the attaining of the level of training and technical expertise as defined by ANSI standards.
See, NRC, " Qualifications of Nuclear Power Plant and Inspection, Examination, and Testing Personnel", Regulatory i
j Guide 1.58 (revised 1980).
UE inspectors and inspectors of Daniel i
International Company and its subcontractors do not meet the qualifi-cation requirements established by the industry and adopted by the NRC.
In addition, UE violated its own established policies by failing to meet the standards set out above.
See UE Snupps-C/ Final Safety Analy-j sis Report 17.2-9 (REV. 7/3/84) l 4.
Due to UE's violation of regulations concerning proper qualification of personnel, there exists an alaming possibility of extensive violations by UE of the quality assurance regulations and design and operation criteria including safety standards: 1)to ensure conformance of materi-als and systems to specifications; 2) to ensure accurate inspection of materials and systems; 3) to identify and correct defective material
{
and equipment; 4) to document testing and inspections.
See 10 CFR 5 50 Appendix B subsections I - XVIII; 10 CRF 5 50, Appendix A.
The extent i
of such violations and the risk to pubife health and safety will not be j
known until proper investigation is undertaken by the NRC.
5.
NRC regulations require that " persons and organizations performing quality assurance functions have sufficient authority and organization-i al freedom to identify quality problems; to initiate recommend or i
provide solutions and to verify implementation of solutions." Further-i more, the regulations require that " irrespective of organizational j
structure, the individuals assigned the responsibility for assuring i
effective execution of any portion of the quality assurance program at any location where activities subject to this appendix are being i
performed shall have direct access to such levels of management as may 1
be necessary to perform this function". 10 CFR 5 50, Appendix B (1)
(1984).
Despite numerous complaints to supervisors by QC inspectors i
- oncerning inadequate training of QC personnel, management was either unaware of or wholly ignored these complaints for an extended period.
1 Indeed, a memo isded by QC's supervisor in Narch of 1984 reveals that j
the QC management had instituted procedures to discourage access to higher levels of canagement. An audit of the problem was undertaken by the QA department only after disgruntled QC personnel brought the matter directly te the QA department. These facts reveal that UE's QAP l
t does ~ not meet tti requirements of providing sufficient organizational l
freedom or direct access to insure proper identification and solution i
of safety problers..
i 6.
UE is required to verify on an ongoing basis that its QAP is function.
ing effectively in accordance with NRC regulations.
10 CFR 5 50, Appen-dix B (I) (b).
As a means of such verification, UE is required to I
undertake a " comprehensive system of planned and periodic audits... to l
4 1
l i
i
.m,__,-_m.
verify compliance with all' as'p~edts of the qiiality assurance program".
10 CFR 5 50, Appendix 8 (XVIII).
UE's inability for at least four years to identify the lack of qualification of QC's personnel in accordance with NRC regulations and guidelines as well as with UE policy ' reflects severe deficiencies in the verification and auditing programs of UE, and a violation of UE's legal obligations to verify proper functioning of the QAP.
7.
UE is required by NRC regulations:
a) to insure the " structures, systems and components important to safety are tested to quality standards commensurate with the importance of the safety functions to be performed", and b) to establish a QAP "in order to provide adequate assurance that these structures, systems and components will satisfac-torily perform their safety functions".
10 CFR $50, Appendix A By allowing unqualified QC personnel undertake critical safety inspections and testing for such an extensive period, UE has violated these impor-tant safety obligations.
8.
The NRC may revoke, suspend or modify in whole or part UE's operating license for UE's failure to comply with the conditions of its construc-tion permit or operating license, or for the revelation of any fact, report, inspection or otherwise that would warrant refusal to grant a If cense upon original application, or for any violation of law, regula-tion or order of commission.42 USC $ 2236; 10 CFR $ 50.100 (1984).
VII. Remedies Petitioners respectfully request the Director pursuant to 10 CFR $ 2.202 (a), to order UE to show cause why its operating Ifcense #NPF-30 for the Callaway Plant should not be suspended pending a full investigation by the NRC or revoked:
(a) for failure to comply with quality assurance regulations and guidelines regarding proper _ training of QA personnel, as described above; (b) for failure to comply with NRC regulations requiring UE to continually verify that its QAP is functioning effectively and in accordance with NRC regulations, as outlined above; (c) for failure to comply with NRC regulations requiring UE to institute and maintain a QAP that provides adequate freedom to identify QA problems and to
. initiate and implement solutions; and (d) for failure to comply with regulations which require direct access by QA personnel to levels of management necessary to effectively provide quality assurance at the plant.
Further, the Petitionere-request that, pursuant to the proceedings institut-ed under 10 CRF 5 2.202(a), the NRC:
- 1) undertake an independent investigation of all QA, including QC, personne.1 during the construction and operational phases of the Callaway Plant to determine whether such personnel have met and continue to meet the prescribed qualifications for their level of responsibility; 2) institute an audit of all testing and inspections undertaken by unqualified QC personnel; 3) conduct an independent inspection of all work inspected by unquali-fied personnel or reviewed by unqualified personnel; 4) implement such other i
actions and remedies that the commission deems appropriate in this instance.
i l
5
\\
L
WEREFOR the Petitioners pray f'oMn~ order granting the request for relief set forth above.
Respectively submitted:
Alan 5. Nemes Attorney for the Petitioners 7541 Parkdale St. Louis, Missouri 63105 Dated this 27th day of March,1985 O
ein 0
4 6
j l
l' I
sr
- e5"-
R o
g s
t a
m, c ll m
ll m
g p
ll a
j s
s.
e n
Rl i
l n
n t
s n
m u _ a a
g n
l f
a p
{
f __.
[
s d
l i
e l
m r
,.. i ll f
T 5 ll e
il a
illl T y
g u
m s" __.
n q
l u
n llll s
u M
l s
Ell$
i t
M e
i g
s I
r r,
l a
t h
t I
!l l
_.E l
B!
i l
_. U i
ll I
A l ;1 l
--+ -
..:V
,;.p.. n,.
m 4 ama'a
.e
.l.';*
.n ~
= :. -
.,._. Qg WC&%%' ~
- '"7_. _._,.,.. q'r-M * %:
.ATI
+
+=m - -
---mm..
k I
b m..mm - -
w g,.
,. hey -,misp,mg M.,s..
Lath su
. m, ed.,,1,.s.
[
b_
9 way Unass paedges
. _.m., I. N.m nu,;.n 107
.h.u m me..eas as wou as r -
2-s s - - -
- ~
ema paay pahei=* IJIMe asteg.
- IMkMR%2-h.i
'yu <,
On Tasader. Omary anW, "We de
,2 4 W '.,
est beheve we have amamm*4 any 1.
M Q'tF%s___ c:
==-i=- " aut Denna mean go serused, inses me rem. e, ta-I
^
['
Usso the adlay and LaJe esen.
l Y
pide melt renews of me eartteca.
A mm prehism tanne sau, me
{
lums an e nnusrud ns.
l latisme" that eenid Isad to disetpha-m_ >#.f & '
- ary acten er Hans by the ensus.
._q y "'
j
- gas,
_m is addnies to engemang tot to avhF W I* "^
a
/g eereikations he paDad from t;w j
save laspectors unto their gienhf6 I
i
- l..
satisas are esaahhahad, he audit proposed arteral scher steps for iso.
T-7',a--y,I
~- -
prertag the eartaScalles process.
'..S!T.*.'g "y' ^,y.
la rupease. Peews and, a grg h*
c.71- _
g g~,-
.e...~,
,,,,,,,, w,,,e,,,,r,s and qualay of hspectars, manage
. s,
- -,3 onesse cenage se meum w mee.d to prveaulag inhaery standards j
i
'g 8sr certincetnam.
Ji c '
M Powers said the review of maisse.
4 _
whs.e wert orders would show anac M,w,_,,gsg r
_m.
s,esm,pa eye.ams a.ed r.eosetism. U.n.u me r m.s.,.ct.d t..d. U.eme is a
..d. a.a,y a.
a o, rte dN.
., tw, as, 7
5 la sanot the wer e h,
q w i.J
%=f
- r 4
ed
-_-T-y
,. _ -. N -,f!'W8'd N
.g,9 anW the man average two le.
^
htrAIW**W y ^ gh -
s gg spectisms a day.
la espiahlag the origia of the eer.
"E_
1-(as7@-M.71 Asesses protdan, Ptwers and aume
.. d.
r hspectare bed been hered by Unaan r+1d.Ah
--- ' r ggasp/-
.NM mectric trem esmeronar Daaid Ia.
turnstlanal C g
,,,,,,,, o. Then, counpaar,m,,aa-semy.y.y m.
~
n
,,,,,,,,ne 1il haamd se enrty breed learpreta.
- m.,W..iw m4 rad.
- * =.A l,,w,-Jw
-. g g f h,, u.(gi;,pf'*.
uma of induary standards. Powers
-e J,
.. p p
%..,.,.%e-i,;
te tap we and. N saadards ser seculs 7--
4-Ld r M : fit G 5 d e e.-.
E,
,=g-y.g,$ g.! m.
may take relaud esperunet unu
- u mtae na enrurytag hapse, QW
.e
" * * * * ~
w,p.7C F., **'.t*t.G. **i "!"N.=r.tk.a. u r
-emmQg
. m w
oc.eesm y?
%sts.
~
saw - me,seur Nr ahmed i;
.R
- N*M ' _c ;
the term rsisted espenance? N 1--
wvwa
, vr : =.
N' kmma hae la we heto a leury man-
.--.,,y._
Tw plaat w close to the problem saW managers had boped sur reitensia ter curreettu acesse:
canaesy plass manager sten isn. as een ruins by==nmaag same la aan manry by emag taspectors
- One of three quality entrol as-tamberger mapended Portelra dual man trten the crtierts without deev-for meltiple setes lastand of turtr,g l
utant sapervisors, Verneo Portan, certhcauan. He retains ble saperW mentang why.
more maployese-schad ancessary esperience La etvil aery pommen.Omary maM. but be has Anar Saialung their report, andl.
Powere dan &ed cast asetaga as a i
ad electrien! laspectaana. Balds he been herred troen farther cretl er tars wtnittled the hat of unqualthad astres. "We felt there were so Mrse~.P.
eisetrw.al laspectnana.
hispectors to seven by verttytag program wenkasons and pertaps
- N man romperdhle for appre,.
- Mesa of the la anna had aemortty n=ramiral prowess ett decisneta amme ledgmata that shouldn1 have 4 certaheauen of taspectors, qua16 for inspectnans la more thaa one of er in laterviews ettb the other la-base made. I ceaseder any valaban controlagervisor Terry she e, on the four tarhavat categottes - le-spectors of the program as a sigruticant cor>
N ect:astana saaet Oct. It vulat. tahag 5 eartthcanons asonag thern
- On free proced aral pehita, quall-cern."
! C4mpaar rWes for eartttytag to.
- he half of these certsfacanons ty control maassers dodged Unaan octors.
,ert food spessuenobie. la some Eactrte's ews writum penetes for Fnda story was compdeaf and writ-i One perees that anew recean-enses, the man did not sneet ertierta proper eerancause of the taspectors ese by ntAnsar repersers Chruteh anded be certaned for two tachal. accepted wtuun the ladustry. la charged with emsertag Callaway's hyf and Dnierw IFhiskeyanas J deines was Porten. tast week.
ethers, Union Deetric had ignored ante sparetten.
and adaar Noel Ameurta
_ - _ _ - - -, _,., _, -. - - - - - - -,., - - - - -,. - - - - + - -
m......
Yearlongworkers'riftrevealed
~
in UEsafetyassuranceproblems i
By CHRISTOPH SZEQiENYI of the Tttbune's staff Shaw's', J. "I would espect a saperviser to be Friction hetween inspectors and their supervisors atcompetent in inspection phuoeophy."
the Causway County nuclear power plant had surfacedSeveral inspectors said ar.h a management stutude nearly a year before Union Electric Ca. started laves-and superetsors' shortage of espertise spurred laspec-tigstag its deteriorating quahty control system, an in-tors
- complaints to Powers' etRce, wtuch did the sud t. It outuned inadequate training, education and espertence terna! memo reveals.
_..eam Company documents show that en Mareb 10, 1984, among seven of 13 inspectors - tecluding Porten and an-quality control supermaor Terry Shaw ordered inspec. alstant supervisor LM. Zahars - and sparbed suspen tors under ham to take technical problems to him or to na slon of some of their duties.
assutant supervtaor before approaching other depart-Fouowing the audit's suggesuon, the company sus-ment managers.
tions are estahnah A Union Electric is al "la past weeks. there have been aumerous lastances demonstrating a lack of effective communication wiuus.
Sed men did inspectiecta that could jeopard the quahty control department " Shaw wrote in the plant's solsty.
memo to 30 people, many of whom were laspectorr
- Our aim is to solve problems through communication, The St. IAuls St0ity ls also reviewing the Credantials }
and work of 30 to 80 more inspectors employed by a firm not create them."
as' y3 t
But sorne inspectors said this week that they repeated-that helped buDd the plant, wtdch setarted gene ly got no action from Sha w when voicing concerns stmt electricity in December, us supernsors woo were unquahhed to make tochtdcal de-The Nuclear Regulatory r'-w b;t on's inspector at 3p etsions for ensurmg safety. la ad& tion, the utility con-Cana way is also planning to rettew some work orders.
firmed today that inspectors took their concerns to Yesterday Mike Qaary, the Fulton Sun quoted plant spokesman Shaw's boas la early December, nearly two months be-pg for recourse.as anytag that "we have a good system here fore the utihty started an audit of problems.
toa up the quauty control chain of command."..I'm not su Several inspectors said they did not trust some super.
ht nsors because they lacked expertise in certain quahtyBut today, Ceary admitted that statement was un-true. He said he had been unaware of the inspectors
- of.
control arsas. "On a day t g
have technical quescons,"o day bass, you're going to a
said one informed souret forts when be talked to the Fulton newspaper.
De i
who requestad anonymity. ** Management wants us to go He conceded that seven or eight inspectors had taken
),
to them for answers, yet how can they discuss thesetheir concerns in early December to Paul Appleby, an 3
f problems when they're not technically quahfied?"
assistant plant manager who oversees quauty control One assistant supervisor, Vernon Portau. recently lost operauons.
r certification for two types of inspections at the 83 billionQeary said the inspectors' concerns "were being I
plant near Fulton. Reactag to the (mished audit datedtaken seriously." After the latervtews, Qaary said. Ap-r Feb. 22. plant manager Steve Mdtenberger susp, ended pleby put together a plan for corrective action. Qeary r
Porteu's certihestion. Portau, however, retains his so-said he ditt't know what changes Appleby had pro-t posed.
pervisory role.
A supervisor does not ha ve to be certified at any level Inspectors said this week that they grew tmpauent e
In any dactphne." said Robert Powers, aaststant man-with Appleby's efforts, and so they asked Powers' quab.
ager of the dvuton that oversees the effecuveness of ty assurance office to investigate. Powers noted that in.
I spectors have the right under cenpany pobey to com.
piam to his dietsion.
THE WEATHER Au6 tors concluded mana
~
- ==a'ar ' !" 'a """a'gers had broken written laspectors."The inspectors check electrical,'m*ech
"c " 6' '
^ < " = '
Fair tonignt with a low in the upper 30s. Mostly etn! and matertal work throughout the plant, includmg g
sunny tomorrow. High around 80.
systems in the reactor buil6ng and other key compo-nents.
l4 h
,--n-.--,
nn
._--,cw.,,_,--_---,..g-,
~
~
,,C "
(St. Louis Post Dispatch. March 26, 1985)
UEIdentifies Unqualified Insp5ctors FULTON. Mo. (AP)
Electnc Co. has identified 22 quality.
- Union control inspectors who lack qualifscations to ensure the safe Nuclear Power Plant, according to aoperation of its Ch Nuclear Regulatory Commission li official.
Earher this monta concluded that seven q. the ut!!ity uahty control ;
inspectors lacked sufficient trainfrig
'or expertence. As a result. Union,
Electric suspended the men from doing certain jobs.
Last week.15 otherinspectors were.
added to the hst, said Bruce Uttle. an 35 miles eastofColumbia.NRC official based at the power pla Acting on an internal tip from an it:spector. Uttle said. Utahty engineers backgrounds of inspectors last monthand auditors began Uttle said the utility had identified.
the unquahfiedabout 250 artspections performed b) past threeyears. inspectors dunfts the But a spectal Union Electne task force has found that the 22 inspectors were qualified to do 2300f the 250;obs that had been reviewed as of Fnda)
Uttle said. The task force has found no evidence of deficiencies in the plant's hardware.he said.
The St. Louis. based utility is I reviewing about 12.000 work orders.
Uttle said. He said his agency sould wait forToion Electric to complete its study before considenna regulatory action.
Mske Cleary, a Union Electne spokesman, satd utshty offscials had l
declined to comment investigation of the inspectors' wort on their lie confstmed that the 22 inspectors lacked certain work credentaats.
s i
l l
l i
Docket No. 50-483 (10CFR2.206)
Alan S. Nemes, Esq.
7541 Parkdale St. Louis, Missouri 63105
Dear Mr. Nemes:
This letter acknowledges receipt of the request for action under 10 CFR 2.206 dated March 25, 1985, which you submitted on behalf of the Mis-souri Coalition for the Environment and Kay Drey. The petition requested that an order be issued to the Union Electric Company to show cause why the operating license for the Callaway Plant should not be suspended or revoked pending an investigation of the issues described in your petition. Those issues pertain to the qual!#f cation of construction and ' operations quality assurance personnel. As stated in 10 CFR 2.206, appropriate action will be taken on your request within a reasonable time.
, Enclosed for your information is a copy of the notice which will be sent to the Office of the Federal Register for publication.
Sincerely, James M. Taylor, Director Office of Inspection and Enforcement cc: Union Electric Co.
Thomas Baxter, Esq.
Shaw, Pittman, Potts and Trowbridge 9
r-
,----,--n-
,-~-.,--,n
-,----,-new----
- ~ ' - "
[7590-01]
NUCLEAR REGULATORY COMMISSION
[ Docket No. 50-483)
UNION ELECTRIC COMPANY (Callaway Plant Unit 1)
RECEIPf 0F REQUEST FOR ACTION UNDER 10 CFR 2.206 Notice is hereby given that by Petition dated March 25, 1985, Alan S. Nemes, Esq., on behalf of Kay Drey and the Missouri Coalition for the Environment, requested that the directors of the Offices of Nuclear Reactor Regulation and Inspection and Enforcement issue an order to the Union Electric Company to show cause why the operating license for
~
the Callaway Plant should not be suspended or revoked pending an investiga-tion of the issues described in the Petition, and why the other actions requested therein should not be taken. The issues raised in the petition pertain primarily to the qualification of construction and operations quality assurance personnel. The petition is being handled pursuant to 10 CFR 2.206 and accorcingly, appropriate action will be taken on the Petition within a
' reasonable time.
Copies of the petition are available for public inspection in the Com-mission's public document room at 1717 H Street, N.W., Washington, D.C.,
20555 and in the local public document for the Callaway Plant, located at Dated-at Bethesda, Maryland, this day of April,1985.
FOR THE NUCLEAR REGULATORY COMFISSION James M. Taylor, Director
4
~
~
March 25, 1985 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Director, Office of Inspection and Enforcement,,s
U.S. Nuclear Regulatory'Coamission s$e Washington, DC 20555 Show Cause Petition Requesting Suspension or Revocation of Operating License fgr, Union Electric Company's Callaway Nuclear Power Plant, Unit One.
I.
Introduction Come now the Missouri Coalition for the Environment and Kay Drey (" Petition-ers") to petition the Director of Nuclear Reactor Regulation, and the Director, Office of Inspection and Enforcement (" Director") of the U.S. Nuclear Regulatory Regulation, pursuant to 10 CFR S 2.205 to serve upon the Union Electric Company
("UE") an order to show cause. why the operating license for the UE Callaway Nuclear Power Plant, Unit One ("Callaway Plant") should not be suspended, pending a full investigation by the Nuclear Regulatory Commission ("NRC") of the viola-tions of law described herein, or revoked, and why such other actions as request-ed in this Petition should not be taken.
. - II;. Description of Petitioner Missouri Coalition for the Environment is a non-profit corporation dedicated in part to ensuring proper safety control and environmental protection in the generation of nuclear power and is the successor in interest to an intervenor in the proceedings for issuance of an operating license at the Callaway Plant.
Kay Drey is a rate payer of UE and a Missouri citizen concerned with proper prctec-tion of public health and safety with regard to the generation of nu' clear power.
III. Authority Title 10 of the Code of Federal Regulations, S 2.206(a), establishes the right of the public to petition the Director to institute a proceeding pursuant
. to 10 CFR S 2.202(a) to modify, suspend, or revoke a license or for other relief.
Such a petition must set forth the factual basis for the petition and the relief requested.
The Director may, pursuant to 10. CFR S 2.202(a) institute such a proceeding-by serving upon the licensee an order to show cause.
1 IDO - 000523
~,
y
.m..
rt-.
-,y
IV.
Summary UE has permitted at least twenty two unqualified inspectors, including personnel respontible for supervising safety inspections, to undertake testing and inspections. that UE, the NRC, and the public rely upon to insure safe opera-tion of the Callaway Plant.
Inspectors without proper training and expertise have for at least-four years tested and inspected every portion of the plant including the reactor building, assuring management, regulators and the public that electrical -systems, ' civil work, mechanical systems and materials are in conformity with prescribed designs for operation and maintenance of the plant.
The disqualification of th'ese inspectors raises serious questions as to the adequacy of the inspection process and the actual safety of the plant.
In addition, the failure of UE management to identify the problem for such an extensive period, despite complaints from the inspectors themselves, reveals violations of UE's legal obligation to monitor safety inspections continually at the plant and to provide inspectors with direct access to levels of management sufficient to assure prompt reaction to safety violations.
V.
Facts 1.
UE operates the Callaway Plant pursuant to a facility operating license granted by the NRC in October of 1984 (License No. NPF-39).
Construc-tion of the plant was completed in 1984 under a construction permit granted by the NR rin April, 1976.
2.
UE is required by law to institute and maintain ~a quality assurance program ("QAP") at the Callaway Plant, during both construction and operational phases.
The QAP is designed to assure that every aspect of the design, construction, operation and maintenance of the plant meets the standards set by the 'NRC to protect the health and safety of the public.
The foundation of the QAP is the quality control program
("QCP") which involves safety. inspections and testing of the physical characteristics of materials, structures, components and systems throughout the Callaway Plant.
3.
NRC regulations and UE policy mandate quality control ("QC") personnel be certified as meeting specific training, educational and technichl standards in order to insure competent and accurate safety inspections and testing.
4.
Since at leas't 1981 and until recent weeks, during both construction and operational phases of the Callaway Plant, UE has, by its own admission permitted an undetermined number of its QC inspectors, including several individuals in supervisory capacities, to conduct inspections and testing for which they were unqualified by NRC require-ments, UE policy, and industry standards.
(The facts relied upon herein, unless otherwise noted, are derived from Exhibits "A" and "B" attached hereto, being copyrighted stories in the Columbia Daily Tribune for Thursday, March 7,1985, page 1 and Friday, March 8,1985, page 1 and Exhibit "C", an article from the St. Louis Post Dispatch dated March 26,1985.) Published articles originally indicated that UE l
officials had illegally certified at least seven of thirteen QC inspec-l tors to undertake inspections for which they were not qualified; only in the recent weeks has UE reportedly decertified these inspectors to 2
4 conduct inspections in specific ~hreas.
UE li internally reviewing the qualifications of some fifty to sixty other quality control personnel employed b and other y Daniel International Company, UE's contractor at? the plant subcontractors, in order to determine whether these inspec-tors were properly qualified in accordance with regulations.
As of the date of submission of this Petition, the number of unqualified inspec-tors has expanded from seven to twenty-two.
The disqualification of the QC inspectors. cast doubt upon the validity of least 12,000 work inspections conducted throughout the plant, including those undertaken
.within the reactor building. All of the quality control inspectors
~ described above undertook inspections in one or more areas for which they were not properly certified including mechanical, civil, electri-cal, and materials divisions.
5.
The NRC relies heavily upon the accuracy of the safety inspections and testing reports issued by UE's Quality Assurance ("QA") including QC personnel, in' order to assure proper functioning of the Callaway Plant and adequate protection of the public health and safety.
In addition, the NRC has relied substantially upon such reports in previously rejecting allegations of safety violations at the Callaway Plant.
(See e.g., Report #50-483/84-45(DRP).
6.
QC inspectors repeatedly and over a long period registered complaints to assistant QC supervisors about unqualified inspectors and supervi-sors, but no action was taken by UE.
Inspectors then took their complaints directly to the QA department in December of 1984 but the QA department did not order an audit of the problems for nearly two months thereafter.
7.
According~to UE officials, supervisors and assistant supervisors in the QC group need not be certified to conduct inspections although they routinely review QC inspections and technical questions of QC inspec-Reports indicate.that despite such lack of training, QC inspec-tors.
tors were ordered by an assistant QC supervisor not to seek technical advice and information from other QA personnel.
~
8.
UE's QA department has itself determined that UE has violated company policies and NRC regulations regarding qualification of at least twenty two QC inspectors, including inspectors with supervisor capacity, 'and has moved to suspend these individuals from performing inspections in areas for which they were not certified.
UE has reportedly undertaken an audit of over 12,000 work orders dating from 1981 to review the extent to which its thirteen QC inspectors and some sixty inspectors of 4
Daniel International Company and its subcontractors have conducted inspections for which they were not qualified.
VI.
Conclusions of Law 1.
The license - under which UE operates the Callaway plant (Facility Operating License #NPF-30) is. conditioned upon UE's continued compli-ance with the NRC's quality assurance regulations for nuclear power plants.
10 CFR SS 50.54(a)(1); 50.55(f)(1) 10 CFR S 50, Appendix B.
t i
3
--m*-v-
--+N-~
+
2.
NRC regulations require that"Thi"QAP, including QCP " provide for the indoctrination and training of personnel performing activities affect-ing quality as necessary to assure that suitable proficiency is
' achieved and maintained".- 10 CFR S 50, Appendix 8(I) 3.
~
The NRC defines " suitable proficiency" for QA, including QC, personnel as the attairiiny of the level of training and technical expertise as defined by ANSI. standards.
See, NRC, " Qualifications of Nuclear Power Plant and Inspection, Examination, and Testing Personnel", Regulatory Guide 1.58 (revised 1980).
UE inspectors and inspectors of Daniel International Company and its subcontractors do not meet the qualifi-cation requirements established by the industry and adopted by the NRC.
In addition,.UE violated its own establist.3d policies by failing to meet the standards set out above.
sis Report 17.2-9 (REV. 7/3/84)
See UE Snyps-C/ Final Safety Analy-4.
Due to UE's viblation of regulations concerning proper qualification of personnel, there exists an alarming possibility of extensive violations by UE of the quality assurance regulations and design and operation criteria including safety standards: 1)to ensure confomance of materi-als and systems to specifications; 2) to ensure accurate inspection of materials and systems; 3) te identify and correct defective material and equipment; 4).to document v.esting and inspections.
See 10 CFR $ 50 Appendix B subsections I - XVIII; 10 CRF S 50, Appendix A.
The extent of such violations and the risk to public health and safety will not be known until proper investigation is undertaken by the NRC.
5.
NRC regulations require that " persons and organizations performing quality assurance functions have sufficient authority and organization-
.a1 freedom to identify quality problems; to initiate f recommend or t
provide solutions and to verify implementation of solution's." Further-more, the regulations require that " irrespective of organizational structure, the individuals assigned the responsibility for assuring effective execution of any portion of the quality assurance program at location where activities subject to this appendix are being any performed shall have direct access to such levels of management as may be necessary to perform this function"' 10 CFR S 50, Appendix B (I)
(1984).
Despite numerous complaints to supervisors by QC inspectors concerning inadequate training of QC personnel, management was either unaware of or. wholly ignored these complaints for an extended period.
Indeed, a memo issued by QC's supervisor in March of 1984 reveals that the QC management had instituted procedures to discourage access to higher levels of management.
An audit of the problem was undertaken by the QA department. only after disgruntled QC personnel brought the matter directly to the QA department.
These facts reveal that UE's QAP does not meet the requirements of providing sufficient organizational freedom or direct access to insure proper identification and solution of safety problems.
6.
UE is required to verify on an ongoing basis that its QAP is function-ing effectively in accordance with NRC regulations.
10 CFR S 50, Appen-dix B (I) (b).
As a means of such verification, UE is required to undertake a " comprehensive system of planned and periodic audits... to 4
nr- -. ~
.-,--,--,--..-,,-,,,,,.,,,w,.,.,,c,,,,w-.,,,,..,--w,__,,,,,,,,,,,,.,,,,,,-m,..,m_y_,
___,m
verify-compliance with all aspects of the quality assurance program".
10 CFR S 50, Appendix B (XVIII).
UE's inability for at least four years to identify the lack of qualification' of QC's personnel in 4
^
accordance-with NRC regulations and guidelines as well as with UE policy reflects severe deficiencies in the verification and auditing programs of UE, and a. violation of UE's legal obligations to verify proper functioning of the QAP.
7.
UE is -required 'by NRC regulations:
a) to insure the " structures,
. systems and components important to safety are tested to quality standards commens0 rate with the importance of the safety functions to be performed", and b) to establish a QAP "in order to provide adequate assurance that these structures, systems and components will satisfac-torily perform their safety functions".
10 CFR 550, Appendix A By allowing unqualified QC personnel undertake critical safety inspections and testing for such an extensive period, UE has violated these impor-tant safety otdigations.
8.
The NRC may revoke, suspend or modify in whole or part UE's operating license for UE's failure to comply with the conditions of its construc-tion permit or operating license, or for the revelation of any fact, report, inspection or otherwise that would warrant refusal to grant. a license upon original application, or for any violation of law, regulk-tion or order of'c'ommission.42 USC S 2236; 10 CFR S 50.100 (1984).
VII. Remedies Petitioners respectfully request the Director pursuant to 10 CFR S 2.202 (a), to order UE to show cause why its operating license #NPF-30 for the Callaway Plant should not be suspended pending a full investigation by the NRC or revoked:
(a) for failure to comply with quality assurance regulations and guidelines regarding proper training of QA personnel, as described above; (b) for failure to comply with NRC regulations requiring UE to continually verify that its QAP is functioning effectively and in accordance with NRC regulations, as outlined above; (c) for failure to comply with NRC regulations requiring UE to institute and maintain a QAP that provides adequate freedom to identify QA problems and to inttiate and implement solutions; and (d) for failure to comply with regulations l
which require direct access by QA persennel to levels of management necessary to j
effectively provide quality assurance at the plant.
Further, the Petitioners' request that, pursuant to the proceedings institut-L ed under 10 CRF S 2.202(a), the NRC:
- 1) undertake an independent investigation of all QA, including QC, personnel during the construction and operational phases of the Callaway Plant to determine whether such personnel have met and continue to meet the prescribed qualifications for their level of responsibility; 2) institute an audit of all testing and inspections undertaken by unqualified QC personnel; 3) conduct an independent inspection of all work inspected by unquali-fied personnel or reviewed by unqualified personnel; 4) implement such other actions and remedies that the commission deems appropriate in this instance.
l l
5 w-w-p--r yy9+pe9n w -e -y.y-_p-e
,,yem,,..yy,
.,y-4y.-.
y--
,rg.y,.y,.,e.--W,,
e
--e--,-,=r
=e--
v
WHEREFOR-the ' Petitioners pray for' &h crder-grantihg the request for relief set forth above.
~
Respectively submitted:
Alan S. Nemes Attorney for the Petitioners 7541 Parkdale St. Louis, Missouri 63105 Dated this 27th day of March, 1985 ee e
G 0
6
I L.Oncern Surfaces aOOut quauty, IX.
"A", p.1 safety assurances at Callaway.
y N less Cohamma DaDy Trthems Umec Doctric Co.has aDowed un-its artstmal price estanate - esp.
E quahSed inspectors for tocre than pues 1,20 magawana for abad 1 three years to halp ansare the safety mCian Unian Doctric custamars in
} gg s
of tia Ca".away Count St. Laels and da=== of Mid huaseert.'.i power plaat. the acry r=y nudaar mach as Ashland and "I'
am m =deh=
u M*
=rere sus-m 3 Iy pended arvue inspectars from sm>
Maherty. After e6sta years et ese-i y
8 marous dunes after na lasernal to-structkaa, the plaat, wtuch is 5 1 3 aI mGes from Columbia, started vest:sataan revealed abortenmlags operstlag in Decundusr.
C-J la their trainlag, education er expo.
Aay estisen may petttice the NRC Q
[
3 rience.
to ha21 the plant's operstion unto the The diaeveary has raland ctanpany sufsty review la fintabad Unsche-otScials' doubts about the plass's shdad " A the enmpany has safe opersman, leading tbsm to
== hat =d would cost the ut!!ny beg:n revan.;ung the qualuy contral abad f?to,tes a day, inspection syntam.
Cancerns won't be runolved ants Doubts about in=pdiaru strike at the ucty ctanplates a mass:ve re-the heart af the plant's quality amur-
- M view oflaspectors' weet daung back ance program, PeCard said "Ihs to 1981, campany d*L-bla sam yes-paper process is the entr way they M
tarday. The review la expected to ante to assure peblic safety."
take at least three more weeks.
Robert Powers, the plant's ammis.
"We're fatarudad in asefa tant goattty assurance manager, there are any safety problema,"g if amid kaarriews with diagn=1Nt le.
~
sam g
spectors revealed that when they en-3 company spokesman Mjke Ceary, esantared wert satside their arena "and la correcting thaun if they of expertime, they paaned the )eb c
i I
exsat."
along to gia!! fled man, ef The St. Imla usc.*.y la reviewing "We don't have any ctecern abod 2
work by M to 80 moriinspectes em-the plaara constructama " he added.
ployed by a ecctractor who helped nutzg that the taspectars dM a2
-h build the plant near Fulton. Union their wort daring whatis casadared Doctne wants to ensure thatinspec-the plass's operational phase, amee
_ "__ ~
h tors had adequate sk:Es and curttS. midyear 1sgL cation.
O M--
One vertar, who requestad ase-C A recent ctanpany audit grompt-stymitT for fear of superiors' repr$-
V ed by mtarsal cay *" anew-sala, saw he faend cert 1Scation Y
vered deSciencias w:th seven of 13 A
j
,g utihty mspectors. As a result, the papers sa Ida desk a few m= wha age UPgMt" c:
aDowsag hka to do hapartims far Ts wort orders this week to datarmine i
S u$ty tegan studyug about 1:,000 widch he lar*=d compmasa trainang.
j He and other wortars sam man i
N wbetber unquahSed man cimadacted ens wastad la improes ""--' --)ag-
"m-M
!a c.'.y inspectacos, hundreds of try l
l l
U wtuch were dme in key safety raist. emag malticart Sed hopectars.
"I was atraid ! migts gut asked Ese
(
ed systac2s. "We need to rettew ta do -=w'*5 I had no expenance y
thane recortis to Sad cat what they in," the weetar anM tids week, "and act::.any dM." sam James Gearbart, the Uraco Doctric st=nloyee who an-et that pakst, I would have had te M
e yssui pervised the sudet.
any, 'Get someboty else in haci who eimm(
y The Naciaar Regulatry (*ew wi=-
knows what they're ddag.'"
Other wo sie has not moved to sfeer ptant cR::amesag rtars said they never re-W x
.M 3
opersums b the wake of the Sa6-wein gesemoded wtta as tr=rarties s'
-m t an taspecfter
- s l
I ings. Bruce 12:taa, c-w ta-for wtzich he esm*t qua?m-d Im W
umme spector at CaEsway, asM be wiH re-
~
sat iasta arus, the wortars saad, the T
emot view some u:11.*.y wort orders. So inspector always turned to n<nmaane ymmW far, the a:thry has reportad no evi-A~ ~
q,a M ad Bat the employees notad imush dance tha the unquauhad inspec-thatthe taspectors in goestam-and C^ T--
W tars etanprtunued safety, IJ:tle their wort - have caused alarm F
aaid.
O The agency's regiceal etSce in !!aal rubag about amisty can camef,.,Jg ahuat the qualtry controlprogram. A fus)
Chicago, r==~-*% for oversmanag enty whos reviene are fkeshed, taas Casa vsy's operstfm, has alertad na worters agreed.
tap dmsic's chiefs and the five etsn-r 1=rmr-es in Washingsce, D.C.121-Two st2ny dtvishes are the key.
3c t!e nam the utiltry m!sts have violas-players: the goalny cetrol branch, LT.
ed NRC rules.
wtsch inspects matrd== nee wortt and repairs la make sore they meet BobPocard,a sta"r-wenkeof the strict anfaty regulanons; and four re s
Unico of Concerned Mas Wast 6gtcm and a former commis-Powers' gnattty assorance wing.
- Oneat la am
'~
which rupsets only to corporate estant so; C,
man wortar, aald regu'.atars abouM beadquarters and fissctans to so-lacked nec z
M abut down the plant until the ucry satt that==mh=es of the qualny and ele com;ustas its reviews.
5 t=*a ew the federal agency's c xeral maft pertarm correctly overisw.
y inactoc. PoCard aaM: "That's ex.
la late Jamsary, the quauty assurw
- The ma ance ot5ce recetred complairma jag certSc act?y vtat the dif5culty la ever at frasn inspectars who quescooed the ty e x
the NRC. Instaad of proaf that a crurtarents and ahuma, of other three occ d
I plant is safe, they operate on the atr gus2 tty cinerst inspectors and tw O
sence cf proof that u la danger-e:vamma supervisors. Powers anM apecto cus."-
h!a andnes began havestigating the One per The D bi!!!ao CaEaway plart -
next day. Among the findings es-spended be etsnplated at more thas ffve t:mes Imod in a Feb. It audtt report and cal dutses
- ~ ~ ~ ~ ~ '
a,,,.. -
e
... r. x. ?,.. -
- n...e&jf,Mi*jkT..
.F..
- =.
,r m s,
Wr3**,f --at _6: h g.,.
i A7 h
b_- - 1 1 ---__c._:rw-e - w.#.,.'.
i
-v_
m
- AY i
__ m. _
- ",--[_ 3,_m. dam, 85E. aim =m.
1 -[ T894% -
w _- --
$yve m, frs,Y4 @
s 2WTW4
~
,ew ;aemen s*c. JJ Y
-c
..__'b m y r.
ea Regdatory cammiamaan mwor _
- - - - -sm m
1__ _ -J"SS 12tle asad u - s*, %
_qq.pM_h _
em
-m een,,37
> - - - ww _w-
- m-, ang paucy vtatatan federW rdes When.
i m
grantadUcenses k baud and m r--
g_.
CnBaway. Union Doctric pledgeid to Q
y
- Ok M Nm
-m u
apboid NRC regganons as edi as "l*L h
emapaay peUden. I.aue assed.
,. k.u-. m-s
-c
- n -4 On Tasaday, Qaary sand. **we do Wi". 79.W*
."Q-
,y M,_ -
-~
as2A J 'I act beusee we have ceumnres 4 any
~
vtalauena." Bat Uslos Lectric,IA.
d mm"~~ Q-Se stammed, knows the rWas.
N i
Unt0 the stany and Imue cem.
2--.-
" T42BD'*h
.m pisse their reverws d u. ew.unce-
^
Mai pnMan IAtle g ne p i
has an considered **posanual vb 1stims** that could lead to martphn.
=
ary action er fines by the canma-J N
bk
. d uces be fr W
A arven laspectors an*C their quahh-a -A, WM.gy.;.-
i-enucos are estabhabad.12w audat u
-8
- "-- C
.< [== '
proposed several othe steps for sm-f M,
TC**.
prvemg the cuttScauce p w
- . 6..,.A I N*-
7, W
In response. Powers said, a group 5;,,M y.rmar.g
_ sr _ ' - ~
ENg,hb+.* Sy /"
=~
af inspectors. managen sud quahty m.
assurance wortars w1!! W
- _ ~ '
2 ~E'K'. _,
1 3g S- -M re__-fj
=parme ebanges to matdn er exceed
-~
'h
- v. _M.
C _+, _ - @-. 2
%L Ble pr Taa!ng IMtustry stapdarda
__s r
.~
surewstacanon.
axe m
m Po.,n aam um,,,i,w,m 4 ?'d N.[
1' Q
gy '
r
,m,,'
mance wort ordes wood abow
- - - >-.<Mg.N Di g, Q w,,,@'
l.
^'
whether some plant erstama need
- -- mG _ mew;#m
.J renspection. Unt the rmew a ha.
o m
e.aegw-a - :6= w-=ev
=w imbed. cacy addee. Unim necme T.
g m...r2 kna emetra: tad to hin two more m.
m 3,q,.,
m
____w
.e_.
~
a-r -
Ostry said the Inse average two in-
.,-c.7=-
w w nm
-W wt:. g 3--
n-
"~'
4"W4EL'"NM.g - -
a day.
e:
e =e me la --d"M the artsin of the ee.
Dispectors been U on
_ - y? "_
n ctrie from cannetcr Daniel In-9 w*.
.cuerf'
-et-temauenal Co. Thac. ctanpaar man.
agers 5 ave them new certtficatons
,cM CJ, f 4'WP 4
based on overty broad loserpreta-M
- @m.~d8- %-N
.ru dQM; @[h w.e.8-M 8 5 N _. 9 [
'F.-
i 5
ties of indastry wa-da ts. Powers u
.<ac u-
~ '=
QMN5ht9M..M.wfYs.r w
said. ne n. a..,ss say ceesata
'M may take mLated experienee ina 5
r Ww &m m
~r--
q_ --%p*u r k~s y' h TE M y '
eAc-esi czumiderstwo a cert: tying on p=~
- h;.gr R1M *"~* g /, q.
..y' ~. _ c i - -
ears.
w w g g;:y. T@ h*:rc t;** d $ p W F-- e _. e.;m m p q un i,rm re"atae expenemf ne r
.:m" hy.N, r#-
3 aid 'n' ' P'"1er: **nry abased h h_ M N
,p-P
-Iogd,'-
asement,am wm., eo.e,o,he non zwo,
problem saAd manages had boped
- r*4Desta for -
.h actioc:
Catawny plant manager Steve MD-its own rules by execzpting same to save man,y by sang inspectors One of three quahty control as-tecberger suspended Portal!'s dual mac frtun the ernena without docu-for muluple duoes instead d hinns an! scpervisors. Vernoc Porte!!. certhentioc. He retains hLs supervi-ment 9r vty.
more employees.
ed necemmary experleoce in ervu sorypos:ncx:.Geary said, but be has After Salahmg their riport, audi.
Powers denied ecst amrings as a elecu.ca! L&_*. 5alda he been barred from further ervil or tors whit:Jed the hat of ungnaMad mattve. "We fen there were some saw.
eisetn:alinspectama.
Inspectors to seven by venfymg program weakasenes and perhaps nemanrew treapprov-
- Most W the is men had authertty tar +mim! prowens wtta documents some Mrm-au that aboddn't have e
'er**hcanoe of inspectors, quah. for inspectons in more than one of er in imerviews wt*h the other in-been made. I canader any valabon ctru!superrtsor Terry Shaw, a the four r.rwent categones - to-spectors.
d the program as a sigr.thcant corr
- ocemaaocs s:nce Oc*. 2" violat. tahng 25 ewtthcanons amag them
- On free procedural points. quad-cern."
ompany rdes for certtfytt.g in-
- but half of those certitcanons ty etuitrol managers dodged Unico tors.
were found questacomble. In some Eactne's own wrtuan pohcias for nir sfary was campasd aad wnt-e person that Shaw rococo-cases the man dad not meet ertiana proper cert 15 canoe of the inspectors Ase by D1bune ruperierr cartstopa ind be certthed for two techni-accipted within the todustry. In charged with ansanag. Canaway's Ca=r*=wf andDoda us FMaintman benes was Porten. Last week, others, Uniae Doctric had ignored safe opersuon.
aad edsar psc/ Jta6erts.
4
,,---.-,,--,.--.,mmm.---. - - -,.,, -,
rx. y i -
Yearlongworkers'riftrevealed in UE safetyassurance problems By CHRISTOPH SZECHENYI of the Tribune's staff Shaw's inspectors. "I would expect a supervisor to be Friction between inspectors and their supervisors at competent in inspection philosophy."
Several inspect the Canaway County nuclear power plant had surfaced t
and supernsors' ors said such a management attitude nearly a year before Union Lectric Co. started inves-shortage of expertise spurred inspec-tors' complaints to Powers' office, which did the audst. It tigating its deterioratin ternal memo reveals. g quahty control system, an in-outlined inadequate training, edu tation and experience
~.
Company documents show that on March 10, 1984, sistant supernsor LM. Zahars W Portall and as.
among seven of 13 inspectors-fa-quahty control supernsor Terry Shaw ordered inspec-sian of some of their duties.
and sparted suspen-tors under tum to take technical problems to him or to an assistant supernsor before approaching other depart-FoDowing the audit's suggestion, the company sus-tions are estabhshed. Unloc Doctric is al ment managers.
"In past weeks, there have been numerous instances demonstratang a lack of effective communication withinsome 12,000 work orders to determine whether disquau-b fled men did inspections that could jeopardize the the quahty control department," Shaw wrote in the plant's safety, memo to 30 people, many of whom were inspectors.
"Our aim is to solve problems through communication, The St. leuis utility is also reviewing the credentials f and work of 50 to 80 more Inspectors employed by a firm
'g not create them."
so But some inspectors said this week that they repeated-that helped build the plant, wtilch sttarted generating electricity in December, ua ly got no action from Shaw when voicing concems about supernsors who were unquahhed te maae technical de-Ibe Nuclear Regulatory f'-la ion's irspector at 9p g;
casions for ensur:ng safety. In adition, the utility con-CaEaway is also planning to review some work orders.
ftt ::ted today that inspectors took their concems to Yesterday, the Fulton Sun quoted plant spokseman Shaw's boss in early December, nearly two months be-Mike Ceary as saying that 'P have a good system bere pg fore the utihty started an audit of problems.
for recourse...I'm not sure *~ r the inspectors didn't go aca Severalinspectors said they did not trust some super-up the quahty control chain or command."
por vise s because they lacked expertise in certain quahty But today Ceary ad=itted that statement was un-control areas. "On a day to day bas:s, you're go:ng to true. He said be had been unaware of the inspectors' af.
I have technical questions," aax! one informed source forts when he talked to the Fulton newspaper.
pe wbo requested anonym!ty. " Management wants us to goHe etaceded that seven or eight inspectors had taken W
to them fcr answers, yet bow can they discuss these their coneems in early Dece=ber to Paul Appleby, anr pt:ble=s when they're not technica!!y quahfied?"
aasistant plant manager who oversees quahty control operatsons.
6r One assistant supernsor, Vemon Portell, recently lost certification ior two types of inspections at the $3 biHion Cleary said the inspectors
- concerns "were being
[
plant near Fulton. Reacting to the fmished audit, dated taken sersously." After the internews, C3en.y said, Ap.
r Feb. :2, plant manager Steve Mi!tenberger suspended p!*by put toEether e plan for correctice accon. Cleary r
PoneU's certiheation. Porten, bowever, retains his su-said he didn't knaw what changes Appleby had pro-posed.
pervtsory role.
"A supervisor does not have to be ceMified at any level Inspectors said this week that they grew impatient e in any disciphne," said Robert Powers, assistant man-with Appleby's efforts, and so they asked Powers' quali.
ager of the dinsion that oversees the e*fectiveness of ty assurance ethee to investigate. Powers noted that in.
J spectors have the nght under cor:pany pohey to com-plaan to lus dinsion.
THE WEATHER Autters concluded managers had broken wntten
- =**""."'I~ne inspectors check electncal, mecharJ inspectors j
Fair tonight with a low in the upper 30s. Mostl esvt! and matenal wort throughout the plant,includng g
t sunny tomorrow. High around 60.
Y systems in the reactor build ng and other key compo-nents.
B B
6
,.--.__,f
*1
Tx. "C" (St. Louis Post Dispatch, March 26, 1985)
UEIdentifies Unqualided Insp5ctors FULTON. Mo. (AP)
Electnc Co. has identified 22 quality.
- Union control inspectors who lack qualifications to ensure the safe operation of its Chilaway County !
Nuclear Regulatory Commission iNuclear Power othcial Earlier this month inspectors lackconcluded that seven q,ainty.controlthe utlhty u
'or expenence.ed sufficient training ;;
Electne suspended the men fromAs a result. Union do1Dg certainjobs.
added to the hst said Bruce L ttle.anLast s eek.15 ot 35 mHes cast of Columbia.NRCotheral based at the powerp Acung on an internal tip from an inspector. Uttle said, utthty engineers backgrounds of inspectors last month.and auditors beg Uttle said the utihty had identified the unquahfied inspectors dunng theabout 250 anspe past thtte years.
But a special Union Electric task force has found that the 22 inspectors were qualified to do 230 of the 250;obs that had been reviewed as of Fnday Uttle said. The task force has found.
plant's hardsare.he said.no evidence of deficiencies in the The St. Leuss based utility is L Uttle sattL He said has agency souldreviewing about 12.0 satt for Union Electric to complete its study before considenng regulatory
)'
acucn.
Mike Cleary, a Union Electne declinedspokesman, said utihty o!!icials had to comment on their investigation of the inspectors' work.
}!e confirmed that the 22 inspectors lacked certain work credentials.
l
~*
s-
< ----