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UNITED STATES E"'
NUCLEAR REGULATORY COMMISSION
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.,E WASHINGTON, D. C. 20555 fig L tb NOTE T0: Robert Bernero, Director, DBL FROM:
Gus C. Lainas, AD-BWR: DBL
SUBJECT:
CONGRESSIONAL TELEPHONE CALL - EARTHQUAKE AT PERRY A conference call was held on Monday, February 3, 1986, with Congressmen Eckart and Siberling and staff assistant Richard Udell, Region III, IE (Jordan), NRR (Lainas, Reiter, Stefano), and PA (Fouchard). The purpose.
of the call was to brief the Congressmen on the results of the augmented investigation and answer previously provided questions to Region III.
Carl Paperiello, Region III, described the licensee's activities and the results of the augmented investigation. Mainly that there was no damage to the safety-related systems and some movement in the small diameter pipes in non-safety systems. A leaky flange was discovered in a non-safety related water heater in the radwaste treatment building.
Hairline cracking of some structures was identified but it could not 1
be established whether they existed prior to the earthquake.
Some of the more significant specifics addressed during the call are as follows:
1.
Were seismic design limits exceeded?
It was explained that there were indications based on installed instrumentation that for certain frequencies the 0BE and possibly tha SSE were exceeded, however, the definition of exceedance is complex and has to be verified through further evaluation of plant instrumentation and recorded data. Preliminary analyses showed that design seismic accelleration values were exceeded at frequencies above 15 to 20 hZ but for very short times (about one second).
As to whether this did mean that the design base was exceeded should be left to further evaluation of the instrumentation l
data.
1 2.
What actions would be required by the NRC if design limits were i
exceeded, e.g., re-inspection, repeat of pre-operational testing?
I Theextentofeitherre-inspectionandadditionalpre-opefafional testing would depend on the interpretation M the instrument data and the applicant's damage assessment.
1 8605300675 860321 PDR FOIA HIATT86-91 PDR f,
W
,.V-pgg 3 gp, A reeting with the NRC is scheduled at the site en Friday, February 7, 1986 at which time the licensee will present his views on both items and damage assessments. The NRC will evaluate this information to determine further action.
3.
Did seismic instrumentation operate as specified?
We believe that the data is usable, however, we are relying on the epplicant's vendors to confirm that the data is usable to evaluate structural responses. Reports from the vendors of the instrumentation are due by the end of the week.
4.
What is the probability of earthquakes of this magnitude or for the SSE et the site?
At this time, we are not aware of seismic probabilistic estimates specifically made for this site. The SSE was established considering historical data. This is in accordance with Regulations.
5.
Why did the licensee declare a site area emergency if SSE was not exceeded?
The applicant based this decision on prudent interpretation of instrumentatian indications and alarms in the control room.
The Congressmen believed that the call was useful and clarified many of their concerns and requested an update next Monday.
Gus C. Lainas AD-BWR: DBL cc:
H. Denton J. Stefano L. Reiter 4
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m INiilA!.ED TfcV!2W OF DAILY IMITi1UC7 IONS SIGTS 1
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hY. Y-memorandum
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Gilbert / Commonwealth Date:
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To:
NW
/*PM//
Prom:
D. E. Dietrich (E150)/S. C. Dodeja (E180)
Subject:
Review of Work Requests for Potential Earthquake Effects Please review the work request (s) noted against your name to determine whether the problem could have been caused by the earthquake event. If your answer is no, then i
please provide a brief explanation for your answer.
This review is needed prior to doing the work on the WR. The Intention is not to repair anything that could have been caused by the earthquake without the NRC's knowledge.
Please provide a prompt response (one-day turnaround) for these reviews.
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D. E. Dietrich/S. C. Dodeja Dat'e:
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To:
D. E. Dietrich (E150)/S. C. Dodeja (E180)
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1 ORIGINATOR INITIATING DOCUMENT = = = > If applicable, list ID and No.
(F.D.I., 0.I., C.R., etc.)
ID No.
EQUIPMENT O NON-EQUIPMENT (FACILITY)
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[ ] ACCEPTED=== enter Responsible section Corrponent Category - - -
Problem summary ENTERED BY W.O. NO.
DATE
/ /
COPY DISTR!9>f!ON:
salfE wo k Package AIM Originator CANARY Syltee R.E. Itchnical Section COLDO800 ProjectworkCenter e
p;\\p
/S.0(f/i+t) ns. s sn a,. e n The Cleveland Electric illuminating Ccmpany 2'l5 W Det*-
TELEPHONE AND CONFERENCE MEMORANDUM Time:
O82O Project Perry Nuclear Plant l
av:
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Copies To: E PJAdood 64-)
M Lvstw i
S F KAs,*kU l
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February 4, 1986
-g
,.N A
Honorable Chairman Nunzio Palladino
[-
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/Q
- t
-i Nonorable Lando Zeh Honorable James Assaltina FEg 4
?<
Honorable Thomas Roberts 0*i'
}4\\ d, ~
United States Nuclear Regulatory Commisalon t
a ef-Washington, D.C. 20555
%.,,,S*.Y ra[Qtf' V
Re: Petition pursuant'to 10 C.F.R.i2.206
.M 2.,' ~'W[y a
Perry 1 &-Perry 2
Dear Cr==4saloners:
The Western Reserve Alliance (WRA), requests that the Nuclear - i
- - 6
.; t Regulatory Commission'-(NRC) take immediate action to protect the
- a:
i public health and safety of Ohio, Pennsylvania, and Canadian i
reaidents through the"following actions:
Require the complete and permanent closure of the Perry i.
i..
1.
nuclear plants because 'of the Perry plants' inadequate
- i. :
i seimmi,c design.
CEI and the NRC set the standards for 4.
the Pekry plants' ability to withstand gravitational-forces well-below the actual' gravitational forces i that"** ' '
,.:n. e,uu 4 u.
the plants are:being subjected to during actual i
earthquakes.f. m in was clearly demonstrated during the
- tii earthquake,
- of* January 31, 1986.
2 i
I e
2.
Require an independent design and construction l
verification' program (IDVCP) -to assess the integrity of
... j,,,
the..
prtig, Perry,0ne and Perry..Two. alte quality assurance -(QA) I.
i si rams and its implementation because the Cleveland '
Illuminating Company (CEI) and its contractors have8 i
failed to implement an acceptable design and constru_ction program for the Perry One and Perry Two i
nuclear plants that meet.the requirements of 10 C.F.R. 50, Appendix B.
3.
Review the Application before the Securities and Exchange Commission (SEC) of Centerior Energy
.i.. L. :
Corporation (CEC) (formerly North Holding Company),.6 which, seeks, by its application, the SEC's approval to.
.t.
i acquire all of the outstanding shares of the Cleveland Electric Illuminating Company (CEI) and Toledo Edison
- .,i...
. t,
.i (TE), obio corporations, and approval of the related
'a ;. # a u t i mergers by which 'thm transactions will be effectuated.:. 5 i
a.
WRA contends that the Application of CEC before g
[Y Okk w Tr n.,.
.; e..;
j
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<o h
.c
.)
.n 6 ;'. d io e i.
the SEC violates 10 C.F.R. 140 because it wasi h
di 1
er
. created in a hasty and thoughtless manner in;ordert. iin
+
to cover up severe financial problems faced by.CEI.: D W i i i
and TE.
It is WRA's contention that ultimately r8 1 -
the application by CEC before the SEC will cause :
CEC, CEI and TE to be unable to meet the require-ments of 10 C.F.R. 140 because they will be unable to provide financial protection of the licenseem and other persons pursuant to to section 170 of i
the Atomic Energy Act of 1954 (68 Stat. 919), as
- 1 amended.
4 ei
.J ti b.
. On June 25, 1985, when CEI filed Form S-k filing
.,r,:
x before the sEC on August s, 1985, when CEC (North i'i.
i n h !.
.. Holding Company) filed with the SEC an Application. ; W h,;; a
'!!r' i
-e on Form U-1 undar Section 10 of the Public Utility 11 Holding Company Act of 1935; and on August IJ, i
'"1945 in proceedings before the Pubic Utilities i il.ou i
c - i=sion of Ohio (see WRA's Amplification to i
e q.
Motion to Intervene and Request for Hearings i
i.before.the SEC, file No. 70-7149), CEC, CEI and TE i-t i
t'had only a slight idea of how the reorganization c
.iI
- would be implemented.
Further WRA, in its q original Motion to Intervene and Request for r:
i Ji i; Hearings and in its Amplification before the SEC N in the matter of Centerior Energy Corporaton (CEC)
- J! (formerly North Nolding Company, file No. 70-7149)
- 2 i
t.'-
- 4 WRA contends that CEC's Application contains
.Wiin rers c.wwr :4.+;t*M$dactualefalsehoods, unsupported allegations"and
fo peculations. WRA contends that this matter before
.. n. ' s a i s
i
. ir. '
the SEC will result in the violation of 10 C.F.R.
i.q i : i s :T -
.;a 140 because of the financial danger it creates' for
' the companies.
\\
g WRA had,;also raised other issues in its filings before the i !..
- 0 5.:..
an ap...ty.SEC in this matter -that tend to show how the Application of CEC 1
't ' Lbefore the SEC V111 aid the continuisc violation of other NRC 4
F: t :!.i H F.I ;u. i.
! rules and regulations and in fact will c:=use them to increase.
WRA has also raised the question of jurisdiction between
+
<r. the SEC and NRC which the NRC needs to addresa as it relates to CEC's applicat' ion.
>n This should be accomplished through a Director's order for:
i.
iu i 3 r li s i a.. san lasediate and permanent halt on all construc-
- .: ii
.c.t.i '. :.:
- 17 tion and any other activity with the exception of
.I i-
,.,,' y the permanent removal of all radioactive materials
- j..
.a at the Perry nuclear plant site.
a.
.g t i V~ !' I r( F0 ' -
' b.
The establishment of a special inspection team to review allegations that are enclosed.
It is of prime importance that this team be completely f
2 i
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4-independent since the current NRC QC andiQA b.i
- .I D y r!.
inspections and other special inspection: teams l-have failed to adequately deal.with the enclosed
. o..
r allegations.- The inspection team must consistitof '
inspectors from different regions other than
- l Region III and others from outside the NRC itself.
WRA requests that the outside inspectors come from e;
the covernment Accountability Project (GAP), the
- Union of Concerned scientista (UCs), and Ralph i
t Nader's Public Citizen.
t.
- c. 3 1n the event that the plant is deemed to comply r
1 a Wjwith meismic and quality standards, an audit to I
i
- i...
- n I n7
.: ?.
.see how the Application of CEC before the SEC will
,)
i.'
s affect 10 C.F.R. 140 and any other provisions o'f '-
- n i iW p.
.:p, i 5:.
.the code as they relate to the NRC.
The audit l' i f
}'j 1
..W should be conducted in part by independent r
. auditing firms that are free from outside economicl
(:
1-T.or political influence.
d.>
1.-
BACKGROUND a )..-Perry i two unit reactor under construction near
- r i Cle veland,' ' Ohio.
It is being built by the cleveland Electric
- M Illuminating}jCompany.
i
- 1-m
- Perry' Unit 1 is allegedly over 90 percent complete.
Unit 23 3 U.. is allegedly.".46 percent complete.
However, the degree of canni-
..e tw. tit.<i:.a!.u Mgubalizptionvo$Iqit 2.that has taken place since its "unofficialMt i: t abandonmentf makes that estimate fanciful at b'est.
I i
i.
2:1k
- .. ii/.... ii i -
.... As m' result of severe financial problems, as well as con- '
i!!i. iin.ctrtiction andl' operational difficulties at the Davis-Besse, Beaver:
.r l
Valley,. and Pe' ry sites,- Toledo Edison (TE) and CEI ' joined forces
.u.
i ei F r
- to form a holding company called Centerior Energy Coporation
~
- i r :: -
, dCEC) (former.y North. Holding Company).. CEC has filed an.
i -l t. /. I 5 :' d :; : application w)ith the securities and Exchange Commission (SEC) I ' It *I
.... :.. :> i
.~.
.;r y requesting an order of the Commission approving its acquisition t
+
of all of th'eVoutstanding common stock of CEI and TE.
oa :-
l' t.
WRA has made formal requests for hearings and intervention
?
in.this matter and has asked the commission to deny the applica -
tion of CEC and not issue the requested order.
.r One of.'the reasons the Application.of CEC should be denied ti.
4..
1.
5 r * ::. is because.of unsafe conditions at the Perry planta, which we I!
1.
t' t a it.: l believe has T4"en caused at least in part by the influence of i
. f f 8' organised crime on the construction of the plants.
i I't
.' t q' E iln.I i i
' senate inheatigations, testimony before Ohio House sub -
Hu 7"
e 4 rWie comipittees, and other sources have all indicated heavy influence '
w 4
of organized crime at the plants.
3 l
,,y.,,,
..,,,,-9,
,,.,.___-,.--y--,
g.
7,_,
,y.y..,
.,...wyey,..
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l' t,.:.~ -
gig,]
d, djl
.;I f
3,. m i,i r i.
The Western Reserve Alliance (WRA) contacted the Government:il i'i. D l
AccountabilityiProject -(GAP)y because of the large number of Hil'l.Ldil iI, i
..!ic: i i
a..
workers and former workers that were contacting WRA.
Since thatt: 'lI i
- i. r i.
time GAP has been advising and assisting WRA in regard to dealing'nitf-with the numerous allegations made by the large number of i.
whistleblowers that contacted WRA.
(See Section II)
WRA and numerous other consumer groups rained the issues i
concerning major earthquake faulta near the Perry nuclear power I':
i a
plants and a fault line on the plant site.
An earthquake of a a 1
..i ic magnitude of approximately 5.0 on the Richter scale struck on a 'it i l l.i January 31, 1986.2f i;
1,/ GAP acknowledges the lead role that it has played in F
i f.j p. i i r.pt.
2nvestigating and submitting the allegations and documentation l' ii 1. d !
regarding the Perry site.
GAP will continue to followup these
.l
..! E
.y. >
.j
.,: ii;.
, and any subsequent allegations and documentation.
GAP has turnedl :i. I '
3, :
this material over to OCRE and WRA.
WRA is to be considered th'et l vu i:
,a
.i !U.
formal filera of this. petition pursuant to 10 C.F.R. 2.206.
GAPI t ;..
r e intends to continue its investigations into the situation at the9.6' Perry facility and will turn over any.new material to OCRE and
'4 Y
WRA to be added to this their present petion under 10 C.F.R. a 3a i
),.. :
2.206 or any new or different filings that WRA may deem needed in. 3 -
i.
the future.
i.
2f some of the issues surrounding the earthquake are as follows a 0 58
[
' (*td9 F.e i 1.
The. Perry plants. ware designed to withstand extremely l;<.{".
JL
.. i.r; a F.
F
~ elinimal gravitational forces (.15).
The earthquake of^
'~
, $kl;. :$ $' %:
January 31g 1985 subjected the Perry plants to liiubstantially4i M'
- i... i ih i 1. M.t. t.
greater. gravitational forces than the planta were designed'&
- r i i:
i 4
vi.: :: i L.r to withstand (.193.23;.25)
F
- ,8 g
- t. ;g J.
2.
The epicenter of the January 31, 1985 earthquake was i~
,. p. !, p -]i'ht extremely,.close to the Perry nuclear plants.
! y)t[ 4.sFMin e
' ("
.43" l
l,i.r S. t > 6 3.
The' Perry plant site is literally on a fault line..
l c
5 t i
4.
CEI filled the fault line with cement and said it was a glacial scar.
5.
CEI built the plant at this dangerous location over.the l r :. r.:t +
L.,-
objections of consumer groups who raised the earthquake and r;a fault line issues most vigorously.
4:
'l
,:liin sq. '-ye!"41 p. :. ;
6.
A fault line can move at any time no 1satter how new or.'.:. ti 3.1 old.
.. r a
i
'th 1.mt-:ol h e:
7.-
iBecause of the vibration and ground acceleration, the il ip..iigriplum:
soil conditions at the Perry site subject the plant to i. L '.' i.' ftj
. s..t h. n. o greater degrees of gravitational forces than would occur in i-6!
other parts of the world, i
i l
4 I
i i
L
... _ _ _. _ -_ ____.. _., _ _....-__,___.,._. _ -._,,,,_ _ _ t
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'I 2.
LEGAL BASIS i
l A.
Legal Requirements i
The law gives the Commission broad discretion to revoke suspend, or modify the construction permit of an NRc licensee,.
42 U.S.C.
2.206 states thatt r; :.
(a) Any person may file a request for the Director of
. 's. i.. ;;..t i ;
Nuclear Material safety and Safeguards, Director, iOffice of
.l,,, i :,s.
Inspection and Enforcement, as appropriator to institute a i ;.
,e
.. i 1. n i i..
proceeding pursuant to section 2.202 to modify, suspend or,
's i
oe revoke a: license, or for auch other action' as may.be-proper...
L-t c
[.:
!! i, j
In NUREC-0797, Supplement No.10, Safety Evaluation. Report g,
,.. 's: s t. related to the operation of Comanche Peah; Steam Electric Station, Units 1 and 2, Docket Nos 50-455 and 50-446, Texas utilities
'h, t
i j
l i :. o Generating Company, et al.,.the NRC saw that as the construction.
r il..
.of the plant was nearing completion, issues that remained to be i
I" resolved prior to the consideration of the issuance-of an
- p a
- .s.,
operating license were complex, resource intensive,.and spanned ti more than one NRC office.
To ensure the overall coordination.and l
s.
a.:r integration ofi.'these issues, and to ensure their resolution prior l
ti..
to licensing decisions, the NRC Executive Director for Operations i
(EDo) issued a memorandum that directed the NRC's Office of P.. :. I*IFE%.. Nuclear Reactor 3 Regulation to manage.all necessary.NRC. actions.1.
4.. i m
le'ading'to prospb licensing decisions, 'a'nd assigning the
.,,. : q -
Director, NRC. Division of Licensing, the lead responsibility for R(;:
.i d
r coordinating and eintegrating the reinted efforts' +of various iQ yi : n offices within,Ui,e NRC. Technical concerns and allegations about t
4P the plant aros.e.imainly from the quality assurance / quality control u:.:.
aj:
1..:
programs. In ad.dition to the NRC, individuals with allegations 4,1 6-i were also sponsored by the Citizens Association for Sound Energy.;
. O !!hd4 x (CASE). and 'th"S) Government Accountability Project 1(GAP).
General
- i 1 i.r
,i.
allegations about poor construction work at Comanche Peak also
'*i.
-l am :.'
'i,,
,,dj's..
appeared in sev'eral newspaper articles.
Technical concerns were
- 1-i.
grouped by subject into a number of areas.
The NRC investigated and issued a number of reports.
WRA contends the Perry plants are deserving of similar investigations and reports before any iicense is considered.
'I B.
Critairia to Exercise Discretion g
' 9!!. ;f y. I According..to.10 C.F.R. 2.206, the NRC "may institute a
'.'i 4 t. i ::
proceeding to modify, suspend or revoke a license or for such other action ag.may be proper by serving on the licensee an order
)
p, 11:d..
e
,,i..., t r, ; to show cause which wills (1) allege the violations with which h D 4
~
,- o.9 the licensee is'. charged,. or' the potentially hazardous condition f i w I-
'i-
- t. i or other facts'-deemed to be sufficient. ground for the proposed i action."
As interpreted by the Proposed General Statement of 5
O O
O
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_,,7.m..,,,eg,,.,
uf v
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.ilb>R l{
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.t
-- y h.A 143 e iblicy. andk ' \\, urkfob Enforcement Action, published in the til :
.4 m
.5 Federal Register, 44 Fed. Reg. 66754, Oct. 7, 1980 (10 C.F.R. 2.204), suspending orders can be used to remove a threat to the
- i-in 4
public @amith.ind safety, the cr==nn defense and security or.the environment.
M More specifically, suspension orders can be issued to stop facility constructionishen further work would preclude or i
significantly. hinder the identification and correction of an improperly constructed safety-related system or components or if the. licensee.!silqualilty assurance program implementation is not
.4 adequate and 5.' ffsetive'.to provide confidence that the e
constructionaEtii'vities'.are being properly carried out.
More-over, orders' ' '
be issued when the licensee has not responded t
i adequately to, r enforcement action or when the licensee interfers with%e conduct of an inspection or investigation or
).: i a, i,
?
for any tenson4not mentioned above for which the license revoca-
~
tion is. legally 9uthorized.
In order to help determine the significance wf iviolations within this list, the Commission i
established "sejerity categories" ranging from the most serious a
structural flaws 5(Severity I), to minor technicalities (Severity VI). 44 Fed.. Reg. at 66758-59.
? 'T.
spec.ific Bases for Suspension C
~
It is our Niief that an NRC investigation will confirm first, the seiknic design inadequacy of the plant, and second, i:
n%,ogg.p. demonstrated.ang$ntire construction of the Perry plants CEI has i
that during the mwillingness to pursue. the minimum necessary.
....t,n commitment to.* Comply with the laws and procedures surrounding the r
construction t.he Perry power plants.
e D.
5heyoftheEarthquake
. sql.
a The, Perry nuclear plants are built on a fault line that WRA.
.a contends is $tpa. glacial scar. iWRA contends that there will n
p'.s t
- r." t be more earthquakes of a greater magnitude.
The epicenters of
- e these quakes may be even closer to the Perry plants.
The current 8 i-i.
. delay in determining what the devices are that measure the gravita -
yF.
m.
t '-
tional forces is indicative of the shoddy attitude with which CEI'
- I constructed these plants.
The current reports that these devices can only be road.and interpreted by the vendora is most 1
disturbing.
Also, the delay in getting this information makes a
. reasonable person highly suspicious of the credibility of both
-i CEI and the NRC[,
r
'.:.M.
h l'
.-III.
LIST OF,'. ALLEGATIONS AND SUBSTANTIATING DOCUMP.NTATION
-1 b
The follo(wing is a list of. allegations-and documentation Ni -
7-a
, i
.: o v., v.c.w given to CAP by various whistleblowers through the course of its t
investigations.regarding the Perry plants.
6
u.,.,. p u &,.,... X
~
T
' b:,1R = v j'%.. g.. _.
G..
'Q q y[
k i.
1 u
We expect that the affidavits, and subsequent ior and IE o t ' -
d o
gi
.,z
- i p.
investigations and inspections, will be reviewed by the
) e rr Commission and/or the Director in making the determination i.
whether or not to grant both the immediate relief sought in this * !
matter, as well as the suspension of the construction permit
- until such time as the Commission is able to determine the extent of the problems at the Perry facility and the appropriate 1
solutions.
a w
h With regard;to NRd regulations, the Final Safety Analysia 1.
1 Report (FSAR)i3 Environmental Safety Eiport (Safety EvaluationI H
i Report) NREG 8p? which was made specifically for Perry and 10
,' i.
- ,. CFR 50:
workers allege there has been less than the previousi
.. r. :l
!. 3 r commitment ont.the part of CEI.
'I j
..t. e\\.
p,,,
I
,G.
'. r
- 2. ~
CEI made'A:ommitment for radiation vaste management' system 1.::
. M
- r. (SER).
Worker's allege.that in fact there exiists no rea'l quality c.i
.! l 4
.'. i.
system, no qu'a11ty program.
CEI led.tlie NRC to believe CEI was committed tb Regulatory
- 1 3.
1
'A Guide 1.143 9T2ie NRC Nas led to believe'that CEI was committed 70..
ie t' :". '
to this plan in"its entirety.
Workers allege that there was only q
i p;
random oc at best.
There are many welds that would not meet code requirements. 3 A W w.
{
\\
j i
4.
Workers al-lege that the above conditions have.been pes.mitted p". g:.
because CEI h'a p fraudulently classified $he waste management l
g.,6 ge. system.... Workeg may the class system that-CEI-has designated (for*f" E'
- 4...p). i.. i commitmenta. ?}'his impropriety has been committed by CEIthe wiste
,1 j,
t 4
1,1,.
.li;l i..-i deliberately.to avoid safety requirements,, workers allege.'
r r..
cG 5.!
CEI committed itself to the 1979 regulatory guides..
l
.q ' i Under these guides f. hey may not have to build. Class 3.section or 1.i.
i y:
., specification?Lut they are. supposed to.,have a particular oc/QA -. y 1.:
.fi +,.i. program.< Workers allege they do' not have such programs in these areas. -
- JJ
. - } 1. -
.'In these.}. areas welds have bee.n installed below standard a l
t i6.
a
(
there is a bad. valve problem, workers allege.
- i.
ir.
7.
Every weld that was bad on every valve that was not up to par was thus classified by CEI as a non-safety item.
trnder this
/
classification;.of non-safety item it really meant no QA.
4
..e
[.. y.
- a.-
There werge man./ problems with the.' hydrostatic testa.
i iu
..i.9.
CEI did.not even have state inspectors,in regard to[these
.p te'sts. *
%y
=
^*
m'w 10.*Ther'e are problems with the G.50 systeui.
This is the liquid I
rod waste system.
Workers allege that the way the system is o
7 l
l l
r
~
. ~
P
? Mme e =1
- 6. & m q
m,s
..,j 4d f
,. f.
(,'
5}*
f r
u
/
... n-
,e
- ~,:rQih.
' currently set up radioactivity yj']J1, h gut intotLake Erie.
(K
- 4 tr much'? Unantlyzed by CEI...)
}.
t P.
. l} lE BylawitshouldbenotedinktheFSARanytimeithereisalf.tW.lf'f e.
e ;s 11.
!.n lessening of CEI's coletitment to NRC rules.
CEI ' ham :made several t . f ' I changee to its commitment to the NRC rules buti.they have not tai t
iI reported them in the FSAR.
\\
\\
12.
CEI said they would have a syst'em of alarms that would go H
i i,.
off in the rod waste room conttul ands the main control room at.
.i. 8 1
the same time.
Although CBI made the Y M taant to-the NRC, CEI" " 'i: !. t
'i decided not to have the dual system of alarms installed as i.
'fl I I promised.
CEI never reported.this ch e in their plansito thec..;.'d V t t
,, NRC.
This is a lesser commitment than as. originally told : to the ', Ji l' 1
NRC.
ii 13.
CEI mentioned in the FSAR its plans to deal with beta and t' i t! : " h i
gamma radiation.
Subsequently CEI changedi ta plans to include-iI LI.1t(
5i i.,s only gamma radiation.
CEI. never reported this subsequent changet l *<ti j id in the FSAR. y
\\
~' F
~
\\
,, i.
14.
In the containment building, regarding steel-penetration and I !!. i :'I.
pipes,.the welds:are cracked.
\\;:
' PI VIM
.t -
n
, i n 15.
Boots around the. penetrations were redesigned to expand a i i l 'I '
little more; some of the penetrations go in and: out at an angle." l '
m:-
i The pressure isigoing through the penetrationsiand this'.is the
.c only seal.
There are plastic seals around the penetrations.
IfI a
.%,io
.. w..,.a. the. plastic. boot;.around :the penetration. fails,,.the system' could i i :'&
I- ?
belch hnd radilittion :could.go out.
This is true because even8
- ia u
m,; a.,
though dhere is.~ negative pressure, the system 'coul'd still belch.
t*
r is, a n i Also.it is possible that in some cases.there* may riot be negative ~
t i..
pressure.
If. this were to occur, radiation would just leak out.'
iMost nuclear plants use metal boots, but CEI uses plastic because rit is faster, workara allege.
These are in the containment
- J ' ',
vessel.
p hl.:..
[
.Wr
.y.. < y
.: i t i. n
. 16.
Workers allege dresser valves are a fiasco (rod waste
'f
- 1. o : r q:, system).
This'can be'seen by looking at DAR 2.12.
These are
t')
vent valves and drain valves to drain radiation.
(some of these -N -
- i.. t,-
valves are already 10 yea ~ra old.)
workers allege that the design i
i +,
of the valve is not any good.
The rework program of CEI reworked 100 of these valves.
They put the redesigned valves through a i
,'3. m test.- It is called an in-service leak rata test.
Many of the
.;, ;. g.,
redesigned valves fallad the test.
These are.small bore valves.
i~,:. cu.i r, e, i.s 17.
Workers allege that the Borg-Warner. valves $(rod waste
.i. * !!
l
...,s.. ! < >..i system) are causing a lot of trouble.
This can 'be seen on DAR '
' ' '3 6 '
l
...e..;. i ;.. 2.13.
(Some of these valves are already 10 years old.)
The X-13*
(. - w.,i.,ila i terays of the valves do not match up with the valves (compared with"fl "'
'/;.:,;tiet u nl.tr what,is currently installed).
Later they found they would not 48/i a i
e i ::
open or close properly.
These valves would not work except when they were in a vertical position.
They were designed to work in 8
- n.... w a
~
.D s.
.Jbi 1
- .y
> e p !. i!
the horizontal position but they did not work in that position. m h i' t 4
some of these valves are 20 inches in diameter.
i
- i euul4
.c !
18.
cEI has on occasion used nonconformance reports :.to.make d
design changes, as opposed to the appropriate design change
'l
. i request forms.
An ASMF, experienced engineer should be able to' find many examples of such situations.
.t.
i 19.
Men in certain unions that have been tied to corruption or
. organized crime activity have tried to prolong their jobs by
+
sabotaging many items at the Perry plants.
i:
i a
20.
During the IIJtI test C2% was trying to get up to 30 lbs. PSI.
4 i
yet they could not arven make 12 or 15.
CEI did not know where 1i i
the leaks were.
s i,
s i
n i..:
21.
Workers allege while working at Perry Nuclear Power Plantm 1 ti
,i.
they have seen smoking of marijuana and drinking of intoxicants.
i <e 1 :
9#
22.
Workers allege they have seen welders taking tests illegally i:
r 4
at the Power site, with no supervision.
a.'
a l Workers aklege they have seen contractors overloading jobs,
. i-1 23.
r-While many workers just sat around for days doing nothing.
1 a
24.
Workers allege they have been approached by members of Local'!
>I l
744 and " asked if I wanted some cocaine."
i' r.
y,es.Q Am.q,, 25... Workers allege they. turned the above information.over to the 111 i
'. i.
FBI anH have h'eaid nothing since.
o q
! 26.
Workers allege they saw men who " stayed loaded on cocaine I
t L
the whole j ob. "-
L ia a
.27.
The workers allege that foremen knew about. men being stoned
.l Q
p;icA,j1iji;;p~n.oncocainebecausethemen"didnothide'it."
Yet.there.is no :,J
, J. o s
avidence that the foremen did anything at all fin this regard. + - " - r a
s.:i.e r 28.
Workers inllege that uncertified welders would use the names -
+b of certified welders on welding jobs when the certified welders were not even on the site.
The foremen at the plant site were
- a the ones who approved and encouraged such activity.
I. c 29.
40,000 tons of reinforcement rod was wrongly ordered and t
. is i
.o
,q than sent to the scrap yard by truck.
.3,.i.s s iJ !,. a, 3 0.. -Insulation - 500 penetrations were installed wrong.
Sleevesi' 5 should have been put on before insulation.
Now the insulation ct us -
will break up from the pipes moving back and forth.
, r,i.,
i.
a :i 9 ;i er. 31.
Portions of the containment vessel are now musceptible I-becanse the sprinkler system came on for undisclosed, accidental,
. i..
or unknown reasons.
9
t
. ~ ~ -
r p.yy y.;:..
~..
w ~..,
Ii
.t 1
< f t-
- 32.
Power outage in the plant caused evacuation and cause.of theI outage is uncertain.
i
- 33.
The quality of the paint job at the ' plant site la not I
unifora.
In some areas of the plant the paint is already i
i i
starting to come off.
One can see this on the equipment hatch at
- in-the top of the unit. Other paint should have been taken off.but was not.
- - i.
34.
CEI negotiations with unions were in part responsible.for
.i
... ;. r-bad feelings between unions.
situation. arose where carpenters
- l
... v were supposed to give orders to laborers.
This resulted in'no R
% ; :b %:
one bringing cut boards to the app p priate local.
Thus CEI had1
.1 6 ',
E I.. i p;..
to permit the union to go back to their old way of doing things.'
'.l
?.i.i Si p uin t This type of management caused wasta, confusiona bad feeling',~'end t1-.i I:
i.s s.. a lack of concentration on meeting' health and.mafety standards. "
y'......tt+
35.
Local 744 of the Boilermakers hired unqualified men under i u i.
the direction of Louis Jewels, president of the local, to work'atie ?
H i,. i n *:..
i
, 1. P mi t the Perry plant.
They were paid journeyman wages but should have l':'
, i.
9 been paid apprentice wages.
Numerous workers have stated that i
+
this occurred because of corruption in Local 744 and the International.. Numerous workers have stated that vast sections i
ir li.
of the plant do not meet NRC standards because of this activity. '
i 36.
A lot of voids existed in the bioshield wall.
These were fixed, but not properly.
Q.
- d.. j...
e '.
9
- i'.:
37.
stealing 1s'very widespread at the Perry plant.,.Even CEI yg personnel are involved.
i i.
c.
38.
The standard procedure regarding the way welding is done and-inspected at Perry is not in compliance with current NRC code.'
- i 4 1 :..lj.d.
39 There -were, irregularities in1.the welding.' tests that were.. m.; i. ".
! b 3 ".hmf i given at Perry.8 r: Indications are that'some men -took the test fori'l )
4i r.
other men who were unqualified.
Some men took a welding test "
4
- '.t j
that took a day, while others were permitted to take as long as a a i, i ui a.
week.
1 j
i- :i 40.
The polar crana in Unit 1 rides on a support beam above the -
reactor.
The beam that the wheels of the polar crane ride on is i -
defective.
The beam that the track sits on is defective.
This beam case into the plant in sections.
The welds that were made in the plant are good welds.
The welds on the beam that'were -
l.l :
p.: ci j
sade outside the plant or fabricated by vendora are bad.. Thus i
ti a1-the rail that the polar crane ridea on la defective.
e
': ! t l
Oc inspectors were harassed-and ' intimidated in an attempt to klik g,
ei.;i
.41.
I get thes not to report Oc violations.
'! ! 8 42.
This harassment and intimidation of QC inspectors took place i 10
-_._-__.r._,.
.. - -_.__.m.my._,,.m,-_-.,.
W.' ~ ~ ~ ~ ' ' ' ' ' '
w
- +
s n. m kn'wsta
- (
'~
- ' 'iQ
. i;
. -lhh-h P
b
- FdQlf 3
i-
,1 f
't, f
E 8, ; q.,.
and affected'the quality of inspection at the diesel generators'
- i'i 1,
of Unit 1, Unit 2, and'the 620 Central compler.
l 43.
of number of Oc inspectore for the job.The main control zoom suffere i
~,,
Qc inspectors, the verification work that should have been doneDue to the sh j
(regarding all electrical work, power modulators, and instrumentation) was not dona in the main control room.
44.
Due to overwork, the two QC inspectors were not allowed to see the computer room at elevation 63a.
set up to deal with this.
The program was just not y,
45.
pecker heads terminations.There are probleas with emergency aarvice water rega j
e
..i V;,
The vendor iside in different from the
.> y.:
Gilbert drawings.
The rotation for the motor is opposite to
?
industry drawings.
The. rotation for the motor la 99-100%
different from Gilbert drawings.
100% because they have never seen one that van correct. Workers any they fee The concern of the workers is that they feel this situation could cause them to run backwards and "you would have a hot reactor."
46.
In the containment vessel there are numerous and aerious '
cracks in the first 60 feet of stainless steel clad.
t cracks in the other parts of the stainless steel clad, but the There are first 60 feet of the lower portion is extremely bad.
3 l
be in the area of f1 ring and 82 ring.
This would There are "a lot of cracks in the double bar around the first ring, it."
the bottom ~of
- J-g 47.
The welds in the fuel pools are bad.
Do tests hiuIre.
Look at the welds.
They are bad;
...s 48.
The question was raisN.
gridder in Unit 2 but not in Unit 17""Why did they fix tho' bad crane i
Unit 1 crane gridder is bad.
It is alleged that the i
IV.
CONCLUSION Tor all of the reasons stated above, WRA seeks an immediate closure of the Perry plants and/or an independent investigation of QA/qc problems outlined in this letter.
review of the compliance of CEC pursuant to 10 C.F.R.Further, we seek a 140.
We look forward to your immediate response.
Sincerely,
$& L S Donald L. Schlemmer DIN:41806 11 l
CONFIRMATORY ACTION LETTER CAL-RIII-86-01A b
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A-l FEB 041986 g
d Docket No. 50-440 Docket No. 50-441 The Cleveland Electric Illuminating Company ATTN: Mr. Murray R. Edelman Vice President Nuclear Group Post Office Box 5000 Cleveland, OH 44101 Gentlemen:
This letter refers to our earlier Conr.
dated January 31, 1986.
Item 5 of that i equipment will be maintained in the "as f
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maintenance to be performed. As a result ui
... by our %
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Investigation Team (AIT) and the subsequent conven ns between the AIT leader, Dr. C. J. Paperiello, and Mr. M. D. Lyster, si your staff, we are amending and clarifying Item 5 as follcws.
It is our understanding, with regard to this matter, that you will-1.
Maintain all seismic monitoring instrumentation in the "as found" i
condition. Take no action such as removing, repairing, calibrating or replacing instrumentation which would destroy or cause to be lost, any evidence which would be needed to investigate the event. Maintenance, surveillance, and calibration will be perfonned only with the prior i
concurrence of NRC Region III management.
L 2.
Resume all other activities including work such as, but not limited to, maintenance, training, surveillance, operations and calibrations under the following conditions:
i A.
All off normal conditions identified during these activities will be documented in accordance with CEI's programs and procedures.
r B.
Off nomal conditions will be evaluated to determine if they were potentially earthquake related.
l g7 CONFIRMATORY ACTION LETTER r
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CONFIRMATORY ACTION LETTER The Cleveland Electric Illuminating 2
Company C.
Equipment identified in an off normal condition will be maintained "as found" until evaluated.
Equipment determined to be potentially earthquake affected will be maintained in an "as found" condition until released by the NRC.
D.
The NRC will be notified of all off normal potentially earthquake related conditions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.
Develop special procedures to implement Item 2.
Please let us know immediately if your understanding differs from that set out above.
Sincerely, Original.sjsood Ay Jeaes G. Ke7;;er James G. Keppler Regional Administrator cc:
J. J. Waldron, Manager, Perry Plant Technical Department M. D. Lyster, Manager, Perry Plant Operations Department L. O. Beck, General Supervising Fuel Management Section DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA Terry J. Lodge, Esq.
James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health l
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CONFIRMATORY ACTION LETTER
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coMwmx ON 9ttRGY ANO. COMMERCE WASHDeGTON, DC 20515 i
Februar.y 5, 1986i 1
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The sonorable unnzio J. palladimo '
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Dear Mr. Chairman:
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tee', y., f s sy,4 ;g ha brought Congressman Dennis Eckart, a Member.of the subcom to my attention,an issue of potential concern relating to the Perry Nuclear Power Plant.in Ohio.
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As you know, an earthquake. occurred in the vicinity sof Perry on January 31, 1986.
preliminary information provided to the Subcommittee appears to indicate that actual ground movement. at the site may shave exceeded in some respects the seismic specifications for which the plant was designed.
The subcommittee is most interested in learning whether f and to what extent the Safe Shutdown.,garthquake_(SSE) of 0.15g that o/ Perry '~sas" de,s_ighe-a35]copfy_1.t{sifely was,,, exceeded du' ring' the 'teismic acYivity that occurred last Friday.
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It in also my understanding that there may be some minor impact or damage to parts of the plant.
The Subcommittee is also interested in a p complete reporting of any damage and its_sijnific_ance.
I have reviewed both letters forwarded tO the Commission by Congressman Eckart and Congressman John Seiberling, a Member of the Interior committee.
Both letters raise significant concerns to which the Commission should respond as promptly as possible.
I concur completely with their correspondence with you.
The Subcommittee also
/ would appreciate receiving _your, r_es_pqpee,to,,the matters that.,they raise.
g/ Additionally, the Subcommitetes'regues;ta all,docmments, relating to this issue, including, but not limited to, NRC analyses and memoranda, documents generated by NRC's augmented incident response team, and licensee, contractor and vendor documents.. These documents should be provided by February 14, 1986 with weekly supp1_ements as additional doc,uments are generated or received At congress: nan Eckart's request, the Subcommittee intends to follow this matter closely.
I request that the subcommittee be kept fully and currently informed of all developments as your investigation proceeds.
In advance, thank you for your cooperation,.
sincerely,
'O iN Edward.J. % rk
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Py. W u A-o_ n EDO PRINCIPAL CORRESPONDENCE. CONTROL d." [
FROM:
DUES 02/14/84 EDO CONTROL: 001392 DOC DT 02/05/86 REP. EDWARD J. MARKEY, CHAIRMAN FINAL REPLY:
SUBCOMMITTEE ON ENERGY CONSERVATION AND POWER TO:
CHAIRMAN PALLADINO FOR SIONATURE OF
- M PRIORITY wm SFCY NO:
CHAIRMAN DESC RollTING:
EFFECTS OF 1/31/06 EARTHQUAKE ON PERRY NUCLEAR STELLO
. PLANT ROF.
RFHM DATE: 02/05/86 SNIEZEK ASSIGNED TO: NRR CONTACT: DENTON TAY1OR KEPPLER GC13NNINGHAM SPECIAL INSTRUCTIONS OR REMARKS:
HELTEMES 1.
I HAVF SEPARATEl.Y ASKED BERNERO TO GET ME A TENTATIVE SCHEDU1.E FOR A 4. B TO ASSI.fAOF.
CONGRESS IN THE VERY SHORT TERM.
- 2. R1II SHOULD BEGIN IMMEDIATELY PULL 1NG.
TOGUHER THE DAMAGE INFO - WHILE AWAITING D10.CUSSION WITH NRR.
3.
IE t R1II START SE ARCHING FOR DOCUMENTS TO 9.1.tBMIT TO NRR.
NOTE THE REQUEST FOR PERIODIC SUPPLEMENTS.
REF. EDO 139e.
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BasWagten,B.C. 20615 February 4,1986 Honorable Nunzio J. Palladino Chatman Nuclear Regulatory Connission 1717 H Street N.W.
Washington, D.C.
20555
Dear Mr. Chaiman:
On Monday noming, February 3, we were briefed by several members of the NRC staff conceming the impact of last Friday's earthquake on the Perry Nuclear Power Plant in Perry. Ohio. Although we malize infomation currently avail-able is still preliminary, we appreciate the Connission taking the time to keep us up to date. Mr. Carl Papemillo, Director of the Division of Reactor Safety at NRC's Region III, and leader of the NRC investigation team sent to Perry after the incident, was particularly informative.
During the course of the briefing, we learned, among other things, that the data recorded by the seismic indicators at the Perry facility during the event will be evaluated by the vendor companies who provided those devices to the licensee.
Obviously, the analysis of the data, uncertaintfe1, impiteit in any such analysis, and the relationship of the results of the analysis vis-a-vis compliance with the Comission's seismic criteria and mgulations is of crl-tical importance. Of additional concern is the fact that a seismic event of this magnitude has apparently nevei before occurmd at a nuclear power plant in the United States, giving the actfons we take now a special significance 1
for the future.
I Therefore, we are requesting that the Comnission seek a rovfew of the data and its implications by the Advisory Connittee.on Reactor Safeguards (ACRS) and its seiwie consultants, fneluding those seismologists and earthquaku enyi-neers who have assisted the ACR5 in its evaluation of 'Diablo Canyon, San Onofre.
and other plants where earthquake considerations were important.
Mr. Paperiello indicated during yesterday's briefing that thivendor compan-ies' analysis should be complete by the end of this week. Accordingly, we would appreciate hearing from you on Monday, February 10,regarding the initial results of that anal independent review. ysis, as well as a target date for completion of the k you in atyce for your continued cooperation.
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DENNISE.ECKAd t
JOHN. SEk8ERbNG Member of Congress Member of Congress
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'SECY MtPEER:
LOGGING DA E 2/ W 0M1 0FFICE OF THE SECRETARY Ref. EDO 1386 Denton for Action Cys: stello ACTION OFFICE:
Eno Roe Rehm AUTHOR:
iep. Dennis E. Eckart, Rep. John F. Seiberling Snie2ek GCunningham AFFILIATION:
U.S. House of Itepresentatives Taylor Keppler LETTER DATE:
2/t./86 FILE CODE l
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ADDRESSEE:
Palladino
SUBJECT:
Request the Conus. to seek a review of the data by the ACR5 re the earthquake on the Perry Nuclear Power Plant.
ACTION:
Prepare Response for Chairman's Sign and Come Review...Date due: Feb. 7 DISTRIBUTION:
RF, OCA to Ack. cy: ACRS SPECIAL HAN0 LING: NONE SIGNATURE DATE:
FOR THE C0fMISS10N sac b
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