ML20214C999
| ML20214C999 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/18/1986 |
| From: | Boss T CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML20214C998 | List: |
| References | |
| 2.206, NUDOCS 8602210427 | |
| Download: ML20214C999 (41) | |
Text
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ATTACHMENT 1 February 18, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Macter of
)
)
THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
AFFIDAVIT OF TIMOTHY A. BOSS County of Lake )
ss:
State of Ohio )
Timothy A. Boss, being duly sworn, deposes and says as follows:
1.
I Timothy A. Boss, am Supervisor, Quality Audit Unit, and Corporate Ombudsman at The Perry Nuclear Power Plant.
I an employed by The Cleveland Electric Illuminating Company ("CEI").
My business address is Perry Nuclear Power Plant, 10 Center Road, Perry, Ohio 44081.
2.
As the Supervisor of the Quality Audit Unit, I am responsible for pro-viding a system of planned and periodic internal audits to assure proper imple-mentation of the Quality Assurance program, policy, procedures, and instructions both for construction and operations.
I an also responsible for periodically evaluating and reporting to CEI senior management the status and adequacy of the
. Quality Assurance program. As Corporate Ombudsman, I as responsible for imple-menting and administering CEI's Call for Quality program. The Call for Quality 8602210427 860218 PDR ADOCM 05000440 0
Program, which was instituted by CEI in 1984, is in addition to the quality as-surance/ quality control programs instituted in accordance with 10 CFR Part 50, Appendix B of the NRC's regulations.
Call for Quality provides an additional program through which CEI can receive quality concerns in confidence, investi-gate their merit, document findings, assure resolution of any quality related problems, and provide feedback to the concerned party.
3.
I have reviewed the letter to the NRC Commissioners from Donald L.
Schlemmer of Western Reserve Alliance ("WRA"), dated February 4, 1986, which was filed as a petition pursuant to 10 C.F.R. Section 2.206 (" Petition"). Responses to the 48 items contained in Section III, pages 7-11, of the Petition have been prepared under my supervision. The responses are contained in Exhibit "A" attached hereto.
I am familiar with the contents of the responses in Exhibit A, and have reviewed the various Perry and NRC inspection documents referenced in the response. Many of the allegations raised in WRA's Petition are too vague or general in nature to provide sufficient information for CEI to investigate.
CEI has responded to these allegations with information that appears to CEI to be relevant to the general issue raised. Other allegations raise commercial or other issues which have no apparent relationship to safety. The remaining alle-gations raise matters which have already been fully investigated and resolved by CEI and the NRC.
Thus, for the reasons set forth in Exhibit A. WRA's allega-tions raise no safety issues that have not already been fully addressed and re-solved by CEI and the NRC.
I have personal knowledge of the matters set forth in this Affidavit and in Exhibit A attached hereto, and believe the information set forth to be true and correct.
4.
I have previously attempted to obtain from Mr. Schlemmer his knowledge of any safety concerns with the Perry Plant.
In a newspaper article dated June 15, 1985 (Exhibit "B" hereto), Mr. Schlemmer claimed that he had learned of var-ious safety problems at Perry.
I wrote to Mr. Schlemmer on July 9, 1985, and asked that he provide me with information on these matters so that their signif-icance could be investigated.
(Exhibit "C" hereto).
I stressed to Mr.
Schlemmer that he need not identify the workers who may have provided in-formation to him, so long as the information about the claimed defect was spe-cific enough to permit CEI to adequately investigate whether the defect was present.
Mr. Schlemmer and Ms. Billie Pirner Garde of the Government Account-ability Project (" GAP") each wrote back in response to my letter, refusing to provide the information requested (Exhibits "D" and "E" hereto).
I made a sec-ond request to Mr. Schlemmer and Ms. Garde on September 6, 1985 (Exhibit "F")
but received no response.
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RESPONSES OF THE CLEVELAND ELECTRIC ILLUMINATING CO. TO l
ITEMS IN WESTERN RESERVE ALLIANCE 5 2.206 PETITION DATED FEBRUARY 4, 1986 l
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ITEM #1 With regard to NRC regulations, the Final Safety Analysis Report (FSAR):
Environmental Safety Report (Safety Evaluation Report) NREG 88.7 [ sic]
which was made specifically for Perry and 10 CFR 50: workers allege there has been less than the previous commitment on the part of CEI.
RESPONSE
The design, construction, testing, and operation features and programs for the Perry Nuclear Power Plant are described in the Final Safety Analysis Report (FSAR). These include detailed descriptions of plant specific items as well as descriptions of the degree of compliance with nationally recognized codes and standards.
CEI has procedures and programs to ensure that activities are performed as described in the FSAR. Adherence to these procedures and programs is monitored by periodic audits and surveillances.
Implementation of the FEAR is additionally confirmed by a program of periodic NRC inspections of both the activities and of the documentation at Perry Nuclear Power Plant. These NRC inspections also include detailed examinations and assessments of the management controls and quality assurance program. These periodic inspections cover all aspects of design, construction, testing, operations, and quality assurance.
The NRC has conducted additional inspections and audits to verify CEI compliance with regulatory requirements. Among these are:
1.
Construction Assessment Team Inspection 2.
Independent Design Inspection 3.
Instrumentation and Controls Branch Audit 4.
Fire Protection Assessment 5.
Equipment Qualification Audit 6.
Emergency Plan Evaluation These inspections and audits are performed in addition to the routine inspections by NRC Resident Inspectors and Region III.
This multi-level system of inspections and evaluations provides assurance that CEI is complying with its commitments to the NRC.
ITEM #2 l
CEI made commiteent fcr radiation waste ransgecent system (SER). Workers allege that in fact there exists no real quality system, no quality program.
s
RESPONSE
FSAR Chapter 11 and portions of Chapter 3 describe the radioactive waste system and the basis for design and construction. These documents describe the radioactive waste system including the requirements for quality assurance during construction and testing. The FSAR discusses CEI's implementation of nationally recognized codes and standards such as the American National Standards Institute " Power Fiping" standard and the American Society of Mechanical Engineers " Boiler and Pressure Vessel' Code".
Quality assurance for pressure vessels, piping, valves and storage tanks is fully governed by the ASME. ANSI and other codes listed in FSAR. These codes specify the requirements for in-process and post welding inspection and testing. The ASME code and the ANSI standard dascribe construction, inspection and testing techniques which result in Ligh quality systems.
These codes and standards utilize a multi-faceted approach to quality assurance placing emphasis on conservative design and process control.
In addition, the quality program was implemented through approved construction and welding procedures, welder testing and certification, and specified welding techniques. These aspects of the quality program are supplemented by inspections and testing.
Management, administrative and quality controls ensured compliance with code methods and that quality was built into the system. The quality assurance requirements hpve been implemented at the Perry Nuclear Power Flant. For example, the inspection program for the Liquid Radioactive Waste System (G-50) included over 1.300 surveillance inspections that identified and corrected any construction deficiencies.
Following completion of construction, the integrity of the systems' pressure boundary was verified by hydrostatic test or in-service leak test and pneumatic proof testing in accordance with code requirements. Finally,
the systems are subjected to rigorous and comprehensive preoperational testing as described in FSAR Chapter 14.
These tests verify the design and operability of the systems.
ITEM #3 CEI led the NRC to believe CEI was committed to Regulatory Guide 1.143.
The NRC was led to believe that CEI was committed to this plan in its entirety. Workers allege that there was only randon QC at best. There are many welds that would not meet code requirenents.
RESPONSE
CEI has defined degree of conformance of the radwaste system to Regulatory Guide 1.143 with the exception noted in FSAR Table 1.8.
CEI's quality classification for the radweste system w&s specified in FSAR Table 3.2-1 XVIII. The subject of conformance to Regulatory Guide 1.143 was discussed between CEI and the NpC in correspondence between April 2.1985 and July 24 1985. FSAR Table 1.8 was amended in September 1985 to clarify CEI's position and this acendment was reviewed and approved by the NRC. -
A comprsh:naiva quality casurcnco program fcr tha rad:csto cyctco in compliance with applicable codes and standards was implemented as described in response to item 2.
The Radweste System welds are in compliance with the applicable codes.
There are no indications of a breakdown of any part of the quality assurance program related to the radweste system.
ITEM #4 Workers allege that the above conditions have been permitted because CEI has fraudulently classified the waste management system. Workers say the class system that CEI has designated for the waste management system is not in compliance with FSAR commitments. This impropriety has been committed by CEI deliberately to avoid safety requirements; workers allege.
RESPONSE
The design, construction, quality inspections and testing of the radioactive vaste system were conducted to ensure that the system meets the requirements of 10 CFR 20 and complies with the descriptions in the FSAR including:
- 1) Compliance with Regulatory Guide 1.26. " Quality Group Classifications and Standards for Water, Steam, and Radioactive-Weste Containing Components for Nuclear Power Plants" (FSAR Table 1.8); and.
2)
Implementation of the design specified in FSAR Chapter 11 and the design criterie including industry codes and standards listed in FSAR Table 3.2-1 IVIII; and
- 3) Compliance with Regulatory Guide 1.143 " Design Guidance for Radioactive Waste Managenent Systems. Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants" with the exceptions and clarifications noted in FSAR Table 1.8; 4)
Implementation of the comprehensive program of preoperational testing described in FSAR Chapter 14 l
ITEM #5 t
CEI committed itself to the 1979 regulatory guides. Under these guides they may not have to build Class 3 section or specification but they are supposed to have a particular QC/QA program. Workers allege they do not have such programs in these areas.
-3
RESPONSE
CEI assumes that this item continues to relate to the radwaste system.
The sectement that ASME Class III may not be applicable is correct. As described in FSAR Table 1.8 and Table 3.2-1, the radweste system was built in compliance with Quality Group D criteria as identified in Regulatory Guide 1.26 and also the requirements of Table 1 of Regulatory Guide 1.143 (which identify applicable codes and standards). CEI's compliance with the quality assurance portions of these references is discussed in response to items 1, 2, 3 and 4 and 21.
ITEM #6 In these areas welds have been installed below standard and there is a bad valve problem, workers allege.
RESPONSE
Requirements applicable to the radwaste system are outlined in Table I of Regulatory Guide 1.143 and Table I of Regulatory Guide 1.26 and FSAR Table 3.2-1 IVIII. The methods used to verify the acceptability of welds are clearly established in national codes and standards referenced in the Regulatory Guides (e.g. B31.1. ASME).
The methods prescribed in these codes were implemented and the results documented. There is no indication that any radweste system welds are below standard, i
Operability of the t adwaste system, including valves, is verified during preoperational testing. Preoperational testing of the liquid radwaste system was witnessed by quality assurance as described in Surveillance Report 85-171. All test deficiencies, including' problems with valve operability, were documented, evaluated, and corrected in accordance with the quality assurance program.
ITEM #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. Under this classification of non-safety item it really meant no QA.
RESPONSE
CEI does not downgrade systems or portions of systems due to a parts inability to function as designed. Defective welds or valves are repaired or replaced to meet their intended function for both safety and non-safety systems. There is no basis in this iten that welds or valves were declassified to non-safety because they were bad. Welds in non-safety systems are in corpliance with applicable codes and standards.
ITEM #8 There were many problems with the hydrostatic tests.
RESPONSE
Hydrostatic testing is performed by personnel certified in accordance with American National Standards Institute requirements. Hydrostatic tests are performed using detailed and approved procedures which conform to the applicable codes and standards and good engineering practices. Hydrostatic tests have been witnessed by quality assurance personnel and the results are documented. Any unsuccessful tests are repeated following the completion of the required repairs.
There is no indication that hydrostatic tests were not performed or performed improperly.
ITEM #9 CEI did not even have state inspectors in regard to these tests.
RESPONSE
Hydrostatic and pneumatic proof tests performed under ASME Section III are witnessed by an Authorized Nuclear Inspector (ANI) as required by the ASME Code. In these cases, an Ohio State Inspector is not required to witness the test. Proof tests performed under ANSI Standard B31.1 were witnessed by an inspector who is certified by the State of Ohio; and, the results were documented and reported to the State Authority. CEI ensures these inspections are performed through the use of procedure PA 1007 " State Pressure Piping Inspection Program". Quality assurance document reviews at the completion of testing ensure that test results are not accepted unless the test was witnessed by the ANI or Ohio State Inspector, as appropriate.
ITEM #10 There are problems with the G.50 system. This is the liquid rod (sic]
waste system. Workers allege that the way the system is currently set up radioactivity will be put into Lake Erie. (How much? Unanalyzed by CEI...)
RESPONSE
During the preoperational test program, newly constructei piping systems, including the liquid radweste systen, were flushed to remove dirt prior to placing the system in operation. During the flushing of the liquid radweste system, a temporary drain line was used to discharge flush water into Lake Erie. The flush water is clean water and does not contain radioactive material of any kind. CEI consulted with the Chio Environmental Protecticn Agency and received their concurrence prior to the discharge of this flush water.
The temporary flushing connection on the liquid radwaste system was removed at the completion of the flushing program and the flushing drain connection has been sealed with a blank flange. There is no potential that this connection will represent a discharge path for radioactive material once the system is placed in operation. - - -.
ITEM #11 By law it should be noted in the FSAR any time there is a lessening of CEI's commitment to NRC rules. CEI has made several changes to its commitment to the NRC rules but they have not reported them in the FSAR.
RESPONSE
CEI informs the NRC of changes in design and methods used to meet regulatory requirements. This notification is made through letters and meetings with the staff and documented in FSAR amendments. These changes to the design and methods are a normal and expected part of the operating license application process, as prescribed in the Code of Federal Regulations (10 CYR 50.54a: 10 CFR 50.71e). Changes are subject to the NRC review, comment and approval process prior to receipt of the operating license. This information exchange continues after receipt of the i
operating license as required by 10 CFR 50.59.
The NRC also performs audits and inspections to ensure that FSAR requirements are being implemented as outlined in response to Item fl.
ITEN #12 CBI said they would have a system of alarus that would 30 off in the rod (sic] waste room control and the main control room at the same time.
Although CEI made the cocmitment to the NRC, CEI decided not to have the dual system of alarms installed as promised. CEI never reported this change in their plans to the NRC.
This is a lesser commitment than was originally told to the NRC.
RESPONSE
An earlier version of the FSAR did indicate that there would be a dual alarm in the radweste control room and the " main control room".
Changes were subsequently made and appropriately documented to eliminate the dual alarm for the reasons stated below.
Many radwaste system conditions, including routine changes in pump and tank status, cause alarm indications. The alarm veuld annunciate in the Radysste Control Room and as a generic radwaste system alarm in the " main control room".
The generic alarm had been installed because it was originally not intended to require continuous manning of the Radweste Control Room.
It was later determined that the duplicate generic alarm in the " main control room" could distract Plant Operators,from their primary function without any ccrpensating increase in safety or ef ficiency.
i Moreover, CEI decided that Radwaste Control Room would be manned 24 'murs a day by trained and qualified operators. These operators monitor and respond to all indicatices and alarrs coeing from radwaste systems and report to the operatcrs in the "ea!n control room".
Therefore, the duplicate alarm in the "=ain centrol room" was rencved by an approved design change. This design change was included in Amendment 20 to the FSAR i
(11.2.7.12) in July 1985.
o ITEN 913 CEI mentioned in the PSAR its plans to deal with beta and gamma radiation.
Subsequently CEI changed its plans to include only gamma radiation. CEI never reported this subsequent change in the PSAR.
i
RESPONSE
Perry Nuclear Power Plant is designed and CEI has programs to accommodate both beta and gamma radiation. CEI did not change its plans for dealing with both types of radiation.
The radiation protection design aspects of the plant and the Health Physics Program controls including access controls, radiation monitoring, personnsi dosimetry, and worker training have been evaluated by the NRC and found in compliance with regulatory requirements as stated in the Safety Evaluation Report and in Inspection Reports 85027 and 85068 dated August 29.1985. and November 1,1985. respectively.
i e
ITEM #14 In the containment building. regarding steel penetration and pipes, the welds are cracked.
RESPONSE
A comprehensive program of inspection and testing and, where necessary, repairs followed by re-inspection and re-testing has ensured that containment penetration welds are satisf actory. Welds for sealed penetration pipe assemblies have had 100% contractor / vendor quality control inspection and testing. As a minimum inspection and tests included:
visual inspection leak testing, and either liquid penetrant, magnetic particle, ultrasonic or radiographic testing. Additionally, these welds have had tests witnessed by tl.e Authorized Nuclear Inspector in accordance with ASME Section III. The CEI Quality Assurance Program supplemented these controls through vendor surveillance and field inspections.
i The prodram for welding, inspecting and testing of containment penetrations is covered by the ASME code. CEI has verified that required inspections and tasts were performed by the contractor. This has been verified through a review of contractor installation documentation and the CEI and ANI review of the ASME N-5/N-3 documentation packages.
During the inspection and testing of the flued head structures in sealed containment penetrations some welds were suspected of having cracks. This potential deficiency was reported to the NRC ir accordance with the i
requirements of 10 CFR 50.55(e) on July 31. 1985 as Deficiency Analysis Report 250. Subsequent inspections determined that there were no cracked welds on the flued head structures.
The NRC was informed of this finding by letter on October 22, 1985. (PY-CEI/0IE 0121L). This issue was reviewed l
by the NRC and closed in Inspection Report 85072, dated Decceber 6. 1985.
i 1
ITEM #15 Boots around the penetrations were redesigned to expand a little more:
some of the penetrations go in and out at an angle. The pressure is going through the penetrations and this is the only seal. There are plastic seals around the penetrations.
If the plastic boot around the penetration fails, the system could belch and radiation could go out.
This is true because even though there is negative pressure, the system could still belch. Also it is possible that in some cases there may not be negative pressure. If this were to occur. radiation would just leak out.
Most nuclear plants use metal boots, but CEI uses plastic because it is faster, workers allege. These are in the containment vessel.
RESPONSE
Nylon reinforced silicone rubber seal ' boots" are used to seal the penetrations where the safety relief valve discharge lines penetrate the drywell wall. The drywell wall is completely inside the containment and drywell wall seals are not a direct path for the release of radioactive material to the environnent.
In contrast, containment penetration seal boots, including those at the Perry Nuclear Power Plant. are typically made of steel because they do represent a potential leakage path to the environment.
The drywell penetration seal boots did f ail during the dryvell Structural Integrity Test and prevented drywell pressurization to the required 30 PSIG. The boot f ailure was reported to the NRC in accordance with 10 CFR 50.55(e) on August 6,1985 as Deficiency Analysis Report 251. The boot failure was subsequently determined not to represent a significant design deficiency. Without any seal boots installed, the total leakage of air through the affected drywell penetrations would be substantially less than the amount permitted by the design basis.
The drywell penetration seal boots have been redesigned to prevent permanent creasing and the new boots have been installed. The drywell was pressurized to 30 PSIG and the structural integrity test was successfully completed. This issue was reviewed by the NRC and closed in Inspection Report 86002, dated February 4.1986.
ITEM #16 Workers allege dresser valves are a fiasco (rod [ sic] waste system).
This can be seen by looking at DAR 2.12 [ sic). These are vent valves and drain
{
valves to drain radiation.
(Some of these valves are already 10 years old.) Workers allege that the design of the valve is not any good.
The rework program of CEI reworked 100 of these valves. They put the redesigned valves through a test.
It is called an in-service leak rate test. Many of the redesigned valves failed the test.
These are small bore v alves.
RESPONSE
Deficiencies with the operation of Dresser diaphragm valves were identified by CEI during the preoperational test program.
The cause of Dresser Valve jamming was diagnosed as insufficient clearance between the disc cap and disc guide. This deficiency was reported to the NRC in accordance with 10 CFR 50.55(e) on October 29. 1984 as Deficiency Analysis Report 212. The valves were reworked to correct this problem but retesting revealed that the smallest size Dresser Valves still experienced jamming. This jamming was traced to undersized disc springs and appropriate corrective action was taken. This issue was reviewed by the NRC and was closed during Inspection 85089 which was completed December 18. 1985.
ITEM #17 Workers allege that the Borg-Warner valves (rod [ sic] waste system) are causing a lot of trouble.
This can be seen on DAR 2.13 [ sic).
(Some of these valves are already 10 years old.)
The I-rays of the valves do not match up with the valves (compared with what is currently installed).
Later they found they would not open or close properly.
These valves would not work except when they were in a vertical position. itey were designed to work in,the horizontal position but they did not work in that position.
Some of these valves are 20 inches in diameter.
RESPONSE
This item combines two separate issues related to Borg Warner Valves. One issue is that radiographs "do not match up with the valves (compared with what is currently installed)". The other issue is DAR 213 which dealt with valve operability.
The first issue was the subject of DAR 141 which was reported to the NRC on April 18. 1984 During the comparison of site generated radiographs with those supplies by Borg Warner, three discrepancies were identified. One valve was found to have been machined af ter it had been radiographed. Two other valves were found to have identification narkers interchanged.
Initially, the radiographs did not appear to match up with the installed valves. After an in depth investigation. CEI concluded that these were the only discrepancies where radiographs did not match up.
This issue was reviewed by the NRC and closed in Inspection Report 84-06 dated May 18 1984 Deficiencies with the operation of Borg Warner Gate valves were identified by CEI during the pteoperational test program and reported to the NRC as DAR 213 in accordance with 10 CFR 50.55(e).
Several different sizes and models of Borg Warner gate valves experienced jarming when installed horizontally as discussed in the DAR.
Internal inspections of valves of each size and model nueber revealed the cause of the jamming to be improperly sized or pcsitioned guide rails. A comprehensive program of repairs and retesting was perforced and this issue was reviewed with the NRC and closed in Inspection Report 85080 dated Decerber 2. 1985.
_9_
L
ITEM #18 CEI has on occasion used nonconformance reports to make design changes, as opposed to the appropriate design change request forms. An ASME experienced engineer should be able to find many examples of such situations.
RESPONSE
The use of nonconformance reports are in accordance with CEI's Quality Assurance Program requirements. As each portion of the plant is constructed, it is checked by inspectors and any differences between the design drawing and the installed ites are documented on a nonconformance report. These reports can be dispositioned as: use as is: rework: repair; or scrap. Rework and scrap dispositions result in restoring the installed item to the original design requirement. Dispositions of "use as is" and
" repair" result in final conditions which are dif ferent from the original d es ign. Before approving these dispositions, each is evaluated by engineering to ensure that the proposed as built condition meets the required design criteria. When changes are acceptable to the engineer he signs the nonconformance report to indicate his approval. Consequently.
these conconformance reports become design change documents and are described as such in project procedures.
ITEM #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.
RESPONSE
There have been no known instances of sabotage at the Perry Nuclear Power Plant. Moreover, there are safeguards to ensure that sabotage would not remain undetected. The construction and permanent security program as well as the comprehensive inspection and testing prcgram eliminate the potential that construction phase sabotage could affect safe operation of the plant.
Prior to loading nuclear fuel, the Perry Nuclear Power Plant is subjected to a comprehensive preoperational test program. This program includes detailed visual inspections and operational tests which ensere that systems, equipment and compunents are operating properly.
In thw early stages of this test program. CEI implemented a comprehensive security program which limited access to completed areas of the plant (and later the entire plant) to those personnel who did not complete an employee screening program. This screening program, includes a background investigation.
Additional assurance that sabotage would be detected and not result in unsafe conditions is provided through the ongoing surveillance and periodic test program. This program tests the operation of safety and many non-safety systems ictediately prior to the systems being placed in operation.
1 ITEN #20 During the ILRT [ sic) test CEI was trying to get up to 30 lbs. PSI yet they could not even make 12 or 15.
CEI did not know where the leaks were.
RESPONSE
CEI assumes this item refors to the drywell Structural Integrity Test and not the containment ILRT (Integrated Leak Rate Test) since the ILRT was performed at a pressure of 11.3 PSIG.
The drywell was pressurized to 30 PSIG and the structural integrity test was successfully completed.
ITEN #21 Workers allege while working at Perry Nuclear Power Plant they have seen smoking of marijuana and drinking of intoxicants.
RESPONSE
CEI has always maintained a strict policy at the Perry Nuclear Power Plant regarding the possession of illegal drugs and alcohol which is stated in the Perry Nuclear Power Plant Employee's Handbook. Any person found possessing alcoholic beverages or illegal drugs is turned over to site security and subjected to immediate disciplinary action, usually dismissal.
In the past seven years, approminately 29 individuals have been permanently dismissed from the site for alcohol abuse and approximately 18 more have been dismissed for drug abuse or possession within the plant property.
In preparation for fuel load CEI has taken additional steps to ensure its strict policies regarding illegal drugs and alechol are enforced. These steps are described by the following program:
1)
Prior to receiving unescorted access to the plant, both CEI and non-CEI esployees must undergo a personnel screening process which verifies an applicant's trustworthiness and reliability to perform his job duties within a nuclear power plant.
2)
Supervisors are trained to detect aberrant behavior and are continually watching for changes in behavior or attitudes which may be the result of drug or alcohol abuse.
(
- 3) A trained dog is used to perform periodic checks of the plant l
for illegal narcotics.
4)
CEI perforrs daily checks of lunch boxes and other packages in order to prevent the introduction of drugs and alcohol onto the Ferry Plant Site.
If an individual's perferrance were impaired due to drugs or alcohol. CEI's comprehensive prograns of surveillances, inspections and testing of safety I
related and non-safety equipment would provide a high degree of assurance l
that work performed by such a person would be detected and corrected. !
CEI'c confidcnco in thic prcgram ic b ced upsa tha cenc pt of dsfcnsa in depth. All vital work must be performed using very detailed procedures which receive multiple engineering and quality essurance reviews. During performance of the work, there is close quality surveillance of the entire activity which, among other things. ensures compliance with these procedures. Each critical step in the work procedure is identified as a hold point and the workman cannot proceed past a hold point until his work is inspected by quality assurance personnel. Work is re-inspected when the task is completed. Prior to being tested, detailed reviews are performed by Test Engineers and Technicians to ensure equipment conforma to every aspect of the design drawing. Every piece of equipment is checked for proper calibration and operation during Initial Check-Out and Run-In Testing. Then, every system is subjected to a comprehensive preoperational or acceptance test to ensure conformance with design criteria and proper operation. Finally, before being declared operational and periodically throughout the life of the plant, systems are subjected to aurveillance or periodic tests which reconfira proper operation. Each stage of the defense in depth process is subjected to quality assurance surveillance and quality control inspections. Management controls such as independent verification are also applied to many steps in this process. This program assures detection and correction of any work that does not meet the applicable specifications and requirements.
ITEM #22 Workers allege they have seen welders taking tests illegally at the Power site, with no supervision.
RESPONSE
CEI takes numerous steps as discussed below to ensure the validity of welding tests and the qualification of the welders. Additional assurance is provided by welding code requirements for in process and post process inspections and finally by a program for the proof testing of welds.
Throughout the construction process, all welders were subject to random inspections while performing field activities. Frcm these random inspections, all welders are subject to immediate retest if their workmanship is considered questionable.
These random inspections were in addition to code requirements for in process and post process inspections of welds. All safety related welding activities have been 100% visually inspected and accepted by certified inspectors. Additionally, safety class pressure boundary welds have received welding code specified nondestructive testing (NDE).
The type of NDE required by the various codes is dependent upon the type and service of the weld.
At the time of the NFC's Construction Assessment Team Audit in 1983, contractor programs required the welder candidates to read and sign test documentation and to sign in and out of the welding test.
Supervision of this prcgram was provided by Contractor Engineering /QC personnel. The test shops were also subject to CEI surveillances and audits. Based upon a recommendatien by the Construction Assessment Team for additional controls.
CEI implemented a " photo badge" system for all contractors.
Implementation of this system required that the welder candidates exhibit to the Test Director a signed, picture identificatico prict to being allowed to test.
The NRC r;ccived allcgotions ccrly in 1985 rcg0rding colder qualificcticn tests.
See allegation RIII-85-A-0065.
This allegation was found to be unsubstantiated, and was closed by the NRC in Inspection Report 85023 dated May 20, 1985.
ITEN #23 Workers allege they have seen contractors overloading jobs, while many workers just sat around for days doing nothing.
RESPONSE
Allegations about worker productivity do not relate to the quality of the Perry Nuclear Power Plant. This is a commercial item and does not raise any safety issues.
However. CEI has always maintained a close scrutiny of contractor activities, using CEI area teams which coordinated work in all parts of the plant. The high level of activity required careful planning and close supervision to minimize overcrevded conditions. With various contractors performing work in confined areas, overloading was not overlooked or tolerated. CEI's Contract Administration Section also required daily activity reports from ~he contractors and additional people could not be employed without justification. CEI's strong management commitment and involvement during the construction phase has maintained programs and direction which has provided for productivity at standard and above standard rates.
ITEM #24 Workers allege they have been approached by members of Local 744 and " asked if I wanted some cocaine."
RESPONSE
This item is addressed in the response to Item 21.
ITEM #25 Workers allege they turned the above information over to the FBI and have heard nothing since.
RESPONSE
No response to this item is possible by CEI.
ITEM #26 Workers allege they saw cen who " stayed loaded on cocaine the whole job".
RESPONSE
j This item was addressed in the response to Item 21.
l ITEM #27 The workers allege that foremen knew about men being stoned on cocaine because the men "did not hide it."
Yet there is no evidence that the foremen did anything at all in this regard.
RESPONSE
This item is addressed in the response to Item 21.
ITEM #28 I
Workers allege that uncertified welders would use the names of certified welders on welding jobs when the certified welders were not even on the site. The foreman at the plant site were the ones who approved and enecuraged such activity.
RESPONSE
As part of the weld fit up process required for safety-related welding, the certification of the welder is checked against a certification matriz. The welder cannot proceed if he is not certified for the welding process specified in the work package. Additionally, while a welder is performing the weld, quality assurance personnel monitor various welding parameters including identification of the certified welder.
Additionally as discussed in the response to Item #22, throughout the construction process, all welders were subject to random inspections while performing field activities. From these randem inspections, all welders are subject to immediate retest if their workmanship is considered questionable.
These random inspections were in addition to code requirements for in process and post process inspections of welds. All safety related welding activities have been 100% visually inspected and accepted by certified inspectors. Additionally, safety class pressure boundary welds have received welding code specified nondestructive testing (NDE). The type of NDE required by the various codes is dependent upon the type and service of the weld.
l ITEM #29 40,000 tons of reinforcement red was wrongly ordered and then sent to the scrap yard by truck.
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RESPONSE
This is a commercial issue and does not raise any safety issues.
CEI purchased rebar for specific installations and each bar was bent in accordance with design requirements.
In order to determine the placement location of each bar, the building, elevation, and bar number was assigned to each piece of rebar.
In 1981, 15 tons of rebar was scrapped because of design changes, damage, or loss of ident$fication tags which prevented CEI from identifying the locaticn in which the bar was supposed to be placed.
When this reber was scrapped, it was sold in accordance with CEI's program for scrap metal.
, ITEM #30 Insulation - 500 penetrations were installed wrong.
Sleeves should have been put on before insulation. Now this insulation will break up from the pipes moving back and forth.
RESPONSE
This allegation appears to be about radiation and fire barrier seals in pipe openings through walls. Generally these openings are filled with a silicone foam or high density elastomer.
In cases where pipe movement is
' 0 anticipated to be greater than the ability of the material to flex, a penetration sleeve is installed around the pipe. The sleeve provides a
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space for the pipe to move freely without damaging the barrier material.
The original engineering design requirements for penetration sleeves was based on pipe movement of an unsupported pipe. Subsequently, cases were identified by Engineering in which piping was anchored in place or otherwise had movement restricted. Engineering evaluated these situations on a case-by-case basis. Based upon this analysis, the design requirements l
were changed in October 1985 to eliminate the penetration sleeves where pipe movement was restricted. Thus, there are numerous cases where sleeves i
l are not required to be installed.
ITEM #31 Portions of the containment vessel are now susceptible [ sic] because the sprinkler system came on for undisclosed, accidental, or unknown reasons.
RESPONSE
Inadvertent operation of the containment spray system during preoperational testing was identified and investigated by CEI as documented in Condition Report 85-027.
The CEI investigation and the subsequent NRC review included a comprehensive inspection to identify equipment damage resulting from this event.
The minimal amount of equipment damage resulting from this event was documented and corrected. This event was reviewed by the NRC and closed in l
Inspection Report 85056 dated October 17, 1985.
ITEM #32 Power outage in the plant caused evacuation and cause of the outage is uncertain, j
RESPONSE
From time to time during construction and preoperational testing, isolated electrical outages have occurred which may have prevented or interrupted work in specific areas of the plant.
Emergency systems are installed to assure that lighting is available for the operation of the plant and for entry / exit to and fror the plant when normal lighting systems are not operable. When normal lighting systems fail to operate. It is normal practice to evacuate non-essential personnel from the specific areas involved until the normal lighting systems are restored.
Unplanned outages have been evaluated on a case-by-case basis to determine the cause of the outage. #
ITEM #33 The quality of the paint job at the plant site is not uniform.
In some areas of the plant the paint is already starting to come off. One can see this on the equipment hatch at the top of the unit. Other paint abould have been taken off but was not.
RESPONSE
The requirements for applying nuclear coatings are described in the engineering specification provided to the painting contractor. The specifications and implementing procedures also indicate the requirements for QC inspections.
These inspections verify that various requirements including uniform thickness is in accordance with the pre-established requirements.
Instances of coatings coming of f in limited areas are identified on nonconformance reports and are corrected.
Coating deficiencies on the equipment hatch were identified on December 26, 1985, and documented on nonconformance report CQCS 444. These deficiencies have been corrected and the nonconformance report has been closed.
The Perry Nuclear Plant also has a maintenance program which will be used throughout the life of the plant to identify and correct deterioration of paint including nuclear coatings.
ITEM #34 CEI negotiations with unions were in part responsible for bad feelings between unions.
Situation arose where carpenters were supposed to give orders to laborers.
This resulted in no one bringing cut boards to the appropriate local.
Thus CEI ha6 to permit the union to go back to their old way of doing things. This type of management caused waste, confusion, bad feeling, and a lack of concentration on meeting health and safety standards.
RESPONSE
This item raises commercisi issues and does not raise nuclear safety issues.
The only negotiation between CEI and building trade unions did not occur until late 1984, when the plant was virtually complete.
These negotiations
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were conducted at the international level of the union and did not affect the day-to-day activities at the job site.
i Carpenter helpers are laborers whose jcb is to assist the carpenters in the erection and dismantling of scaffold. These laborers have a foreman, but routinely accept directicn from the carpenters they are employed to assist.
Without this close cooperation, which has existed for many years throughout the country, scaffolding could not be ef ficiently erected utilizing the existing agreement between the Carpenters' Union and the Laborers' Union.
CEI has not taken any action which adversely af fected the working relationships between trades at the Per ry Nuclear Power Plant.
ITEM #35 Local 744 of the Boilermakers hired unqualified men under the direction of Louis Jewels, president of the local. to work at the Perry plant. They were paid journeyman wages but should have been paid apprentice wages.
Numerous workers have stated that this occurred because of corruption in Local 744 and the International. Numerous workers have stated that vast l
sections of the plant do not meet NRC standards because of this activity.
RESPONSE
The extensive quality assurance programs, welder testing and the defense in depth concept of performing work at the Perry Nuclear Pever Plant assure that work is completed in acccedance with applicable specifications and requirements.
See responses to items 21 and 22.
4 The quality programs utilized by the contractors assure that practices which would adversely affect the quality of the plant would be quickly detected. As an example, welders, including Boilermakers. sust pass certification tests in order to be employed by a contractor to perform welding. The union has no control over these tests because they are conducted by the contractor. After testing, all work performed by craftssen is inspected by qualified. certified quality assurance personnel who are also independent frcm the union. These quality programs ensure that the work meets NRC standards.
ITEM #36 A lot of voids existed in the bioshield wall. These were fixed. but not properly.
RESPONSE
CEI reported the presence of voids in the bioshield to the NRC in accordance with 10 CFR 50.55(e) on December 1.1981.
The analysis and corrective actions are documented on Deviation Analysis Report 074.
Methods approved by Engineering were develcped to locate the volds in the bioshield wall and high density material was used to make the repairs.
Each lot of the material used for filling the void was tested for density prior to being released to the field.
In addition, the grout material used in the repair was tested prior to installation.
These actions were sufficient to ensure that voids in the bioshield were detected and properly repaired. This item was reviewed by the NRC and closed out in Inspection Report 84002, dated March 27, 1984.
ITEM #37 Stealing is very widespread at the Perry plant.
Even CEI personnel are involved.
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- RESPONSE Theft is a commercial issue. CEI's strict policy on theft is stated in the Party Nuclear Power Plant Employee's Handbook. Theft of any sort from the project is grounds for immediate dismissal and denial of any future access to the plant. Within the last seven years, fif teen (15) individuals have been denied permanent access from the plant due to theft. To prevent stealing at the Perry Nuclear Power Plant security personnel perform inspections of lunch boxes, briefcases, and any other packages being removed from the Ferry Nuclear Power Plant. Thus. Perry Nuclear Power Plant officials have implemented strong measures to prevent this type of activity on plant property.
ITEM #38 The standard procedure regarding the way welding is done and inspected at Perry is not compliance with current NRC code.
RESPONSE
There is no " current NRC Code" for welding. Through the Code of Federal Regulations, the NRC endorses the nationally recognized codes which govern welding such as the American Society of Mechanical Engineers. The American National Standards Institute, and The American Welding Society. CEI described its compliance with these codes as they apply to different parts of the plant in PSAR Chapter 3.
The NRC evaluates CEI's program of management, administrative and quality controls to ensure they are sufficient to ensure compliance with these codes. In addition, organizations such as the ASME perform detailed reviews of contractors' programs for code implementation prior to certifying the contractor to perform work under the ASME code. The process used to award the ASME "N" stamp involves a thorough review of the controls the contractor will use to ensure requirements are fully iseptemented. CEI employs agents such as Hartford Steam Boiler to review code compliance programs for acceptability and monitor compliance using authorized inspectors.
nose provisions, along with the quality assurance program describro in response to earlier items, ensure that CEI is in compliance with appropriate welding codes.
ITTM #39 l
There were irregularities in the welding tests that were given at Perry.
Indications are that some men took the test for other men who were unqualified.
Some men tock a welding test that tock a day, while others were permitted to take as long as a week.
RESPONSE
l This item is addressed in part in the response to Item 22.
ne time allowed for tests depends on the type of welding techniques being used.
Some tests take longer to cocplete than others. For instance, the test for a 3/8" socket weld would take approximately four hours, while a 8" heavy wall weld may take as long as a week. Other parameters which affect the length of the test includat type of process, position, and equipment availability.
TTEM #40 The polar crane in Unit I rides on a support beam above the reactor.
The beam that the wheels of the polar crane ride on is defective. The besa that the track sits on is defective. This beam came into the plant in sections. The welds that were made in the plant are good welds. The welds on the beam that were made outside the plant or fabricated by vendors are bad. Thus the rail that the polar crane rides on is defective.
RESPONSE
On October 29, 1979, the Unit 1 Polar Crane Box Girder (PCBG) welds were rejected on Nonconformance Report 17-136 for various visual defects.
During the repair of these defects a small number of subsurface defects were uncovered and corrected.
In the second half of 1981, linear indications indicating a lack of fusion were uncovered in the Unit 2 PCBGs. CEI reported this deficiency to the NRC in accordance with 10 CFR 50.55(e) on February 26, 1982 as Deficiency Analysis Report 71.
An engineering evalustion concluded that the lack of fusion problem was limited to the Unit 2 PCBGs.
The basis for this conclusion was that the Unit 1 PCBGs were fabricated using welding parameters alt ewing heat input in the upper ranges of the welding procedure which assurec fusion.
In contrast, the Unit 2 PCBCs were welded at temperatures in the lower ranges which resulted in the lack of fusion observed in the Unit 2 beams.
To confirm this conclusion. CEI had inforrational Ultrasonic Examination (UT) performed on three (3) successive girder sections (2 different drawing types) on the same eajer strength welds in Unit 1 as were tested in Unit 2.
The results of the UT test confirred the conclusions of the engineering evaluation that the lack of fusion discontinuity was limited to the Unit 2 PCBC.
The NRC reviewed the corrective actions for the PCBCs and closed both Unit 1 and Unit 2 concerns in Inspection Reports 50-440/82-06 (DETP) and 50-441/82-06 (DETP) dated Ju?.y 2,1982.
This concern was further reviewed by the NRC as documented in Inspection Report 50-440/85078 dated January 9, 1986.
ITIM #41 QC inspectors were harassed and intiridated in an attempt to get them not to report QC violations.
RESPONSE
Throughout the Perry Project CEI management has encouraged the reporting o.
all QC concerns.
This policy was expressed through procedures, indoctrination and training, written and posted notices to workers, and other types of corrunic5 tion which emphasize the importance of reporting any safety concerns either to CEI or to the NRC. CEI takes quick action to investigste any inspectcr concerns of potential violations of procedures or other requirements. To further ensure thre quality assurance concerns are being addressed. CEI instituted a " Call for Quality" program in June 1984 This progr:m. t:hich is in additica to QA/QC program requirements. Provid;3 cil espicyees tith cn additional cechanir3 to discuro ec:ccens c2 o confidential basis. The " Call for Quality" program has investigated all concerna and has not identified any case in which a QC inspector was discouraged from reporting QC concerns.
ITEM #42 This harassment and intimidation of QC inspectors took place and affected the quality of inspection at the diesel generators of Unit 1. Unit 2. and the 620 Central complex.
RESPONSE
Several allegations were investigated in response to a Motion to Reopen the Atomic Safety Licensing Board (ASLB) Issue 3 record which was filed by Chio Citizens for Responsible Energy (OCRE) on November 30. 1983.
Some of the allegations related to inspection of equipment in the areas of the Unit 1 and 2 diesel generators and the 620' elevation of the Control Compier.
The results of CEI's investigation are discussed in detail in the Applicant's Response to the Motion to Reepen dated December 19, 1983. As indicated in the Applicant's response. CEI and the Contractor determined that the allegations were unfounded. The motion was dismissed by the ASLB by memorandum and order dated January 20. 1984. (LPB-84-3. 19 NRC 282 (1984)).
Af ter receiving this item, the " Call for Quality" Ombudsman interviewed CC inspectors who have performed inspections in the area of the Diesel Generators. The inspectors interviewed stated that they knew of no cases in which they were asked to accept substandard work and that they received adequate management support to resolve identified safety deficiencies.
CEI is not aware of any basis for the allegation described in this item. CEI ensures that all nonconformances are properly documented and that worker concerns are reported as described in response to Item 41.
ITEM f43 The main control room suffered from a serious lack in ternis of number of CC inspectors for the job. Due to the shortage of QC inspectors, the verification work that should have been done (regarding all electrical work power modulators, and instrumentation) was not done in the main control roca.
RESPONSE
The only concern identified by CEI that appears to be related was addrecced in August 1984 In response to an allegation the NRC reviewed the adequacy of Control Roon inspectien activities. An itae of nonceepliance 8400701 was issued because the fespection reports issued prfor to 1983 covering activities in the Control Poem did not specifically state which activities were inspected nor tFe secte of activity. An evaluation was perforced and re-inspections were cceducted as required to resolve discrepancies. A CEI audit of reports issued sirce 19E3 indicated that the reports did contain adequate detail regardirg activities inspected and the scope of activity.
This ites of noncompliance was closed by NRC Region III as documented in p
Inspection Report 85032 dated June 19. 1985.
The CEI Quality Assurance Program has strict management and administrative controls which ensure that all required quality inspections are performed and documented.
In addition. CEI has always used a system of hold points in work packages which require "in process" inspections. Review of Control Room documentation by the Nuclear Quality Assurance Department assures that all control room inspections have been performed.
ITEN #44 Due to overwork, the two QC inspectors were not allowed to see the computer room at elevation 638. The program was just not set up to deal with this.
RESPON5E The coeputer room located on the 638' elevation of the Control Complex is non-safety and falls outside the scope of the contractor Quality Control program. Although the contractor QA program is not required to perform inspections in this area, non-safety installations are inspected by the CEI Construction Quality Section.
There are no safety issues relativo to this ites.
ITEM #45 There are problems with emergency service water regarding pecker heads terminations. The vendor side is different from the Gilbert drawings.
The rotation for the motor is opposite to industry drawings.
The rotation for the motor is 99-100% different from Gilbert drawings. Workers say they feel it is 100% because they have never seen one that was correct. The concern of the workers is that they feel this situation could cause them to run backwards and "you would have a het reactor."
RESPONSE
The direction of rotation of three phase induction motors depends upon the phase sequence of the power cables to the motor.
It is not practical to mark the phase sequence on power cables or motor leads.
Therefore, standard industrial practice is to connect the power leads to the motor and check the direction of the rotation of the actor.
If the direction of rotation is incorrect. the power supply is disconnected and reconnected in the correct phase sequence. CEI perforced this standard practice for installing three phase induction motors, including the emergency service water pump motor, during the Initial Checkout and Run-in Testing.
Following this installation test, the power leads (Gilbert side) and motor leads (vendor side) are rarked and the drawings are revised to reflect the insts11ed condition. Additional assurance that pumps are rotating in the correct direction is obtained during precperational testir.g. During this testing, the perforr.ance characteristics of the pumps are checked against performance data supplied by the pump manufacturer. This process would quickly identify a pucp which rotated hackwards. sammene
o ITEN #46 In the containment vessel there are numerous and serious cracks in the first 60 feet of stainless steel clad. There are cracks in the other parts of the stainless steel clad, but the first 60 feet of the lower portion is omtresiely bed. This would be in the area of #1 ring and #2 ring. There are *a lot of cracks in the double bar around the first ring, the bottom of it."
RESPONSE
CEI's responses to items 2,14. 21. and 22 discuss how problems such as those described in this allegation would be prevented or appropriately detected and corrected.
CEI assumes that the ites relates to Deviation Analysis Reports 37 and 92.
DAR 37 pertains to sensitization of stainless steel cladding in the supression pool. DAR 92 concerns welds in the containment vessel. CEI reported these items to the NRC in accordance with 10 CFR 50.55(e). DAR 37 and 92 were reviewed by the NRC and closed respectively in Inspection Reports 85035 dated July 2.1985 and 83032 dated November 10. 1983.
ITEM #47 The welds in the fuel pools are bad. Do tests here. Look at the welds.
They are bad.
RESPONSI CEI's response to items 2.14, 21. and 22 also apply to this response.
The fuel pool welds were designed, performed, inspected and tested in accordance with design requirements and the applicable welding codes. Fuel pool welds were inspected by liquid penetrant tests. After erection and initial inspection, the leak chase channels were subjected to a pressure test. The balsace of the welds are subjected to vacuum box test. The final indication that the welds are seceptable is when the fuel pool is filled and the leak chase system is checked for water. There was no indication during the performance of these inspections and tests that these welds are deficient.
ITEM #48 The question was raised:
"Why did they fix the bad crane gridder (sic] in Unit 2 but not in Unit 11" It is alleged that the Unit 1 crane gridder
[ sic) is bad.
RESPONSE
This ites was addressed in the response to Item 40.
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SATUR' DAY, JUNE 15,19e5 3
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Lake County Nuke workers question plant safety they're reputalde "
canceled ier apare parta." SW sased By DOUG KDERNER Hespondiag ie Schlemmer's parte and ogsipment, she saW. mua sun wruer He FO S
eiVere 10 p ant auegatmas.shaw und meet the une mandards.:
- One et the largcas pump masars anything pierchasednew, M m itt Pt ath ) ti1 a o.e T=
ethuY - The Perry huden Pe.cr Ptaat recci.ed the nrd of b m the drywen area. =hach is located
. show said the heat-rda' test i
ps. uacat.: w.mi no.ne suct red shipments yc>terday maraang The tsaal too stupracata are in the contamment bu.Wmg below wm delayed a month bacm LA aita.m c. t 4. w is.s t. A m.t.
qated la be delivered aest week, accordag e M olfactalt the reactar tessel, faded shout a fire, wh6ch levelved sca4Entdlag and na5.atgrn.y w.JyeMs Jay W
~ A5 **"* 85 the f*d* are received they are checked Ier any dasvge nacoth ade and was M1 wad The to-the meter laanare h. M =as t
Pc:: y L n..: r.. rt.na.w mers th*t may have occurred during transportatten." said Wnalaam Kag.
P.g, W.,,g,g,Wedannni.y gag gud. Leethernepower meter.
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g4,g, g, theland Llectrw l'h a. ar tag Ce ga gepgg cwnwas a s.tx 3 s.c isoaising The fuel reds will he stared umul all are recteved. them the preceu of
. Whether warranues are la effect forman a -
pg s:A 4,i, et.4.,e, leaJangt ereacterwdibegh as met sagnahcant, she saad Egsip-
- There are a an==har el erames as A tbelasJ Licstrac 1Lanaat.nl The nudes power plaat is espected la he la operauma late this year anent ta itsed er replaced la any the plant stle and esas est reperled i
Ce ap.aen m a La.ubria$rsw.
Iu M L 8*rly ties rame, the und The plaat hu been lahow uiety deteck saad the aneg.t => ty under commarwctnea for le years, and Regarding een
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" Tham as a su t.w n rpriar.g tactae " a 42 aantal am.m.at ud pape e as cut savelves secrentag the temperature sesne wartaataes may have capired. Shaw med any warhe the saa1 and rc=cided rembaly, sut by weW la about548 degrees she sand driecta er saaety sharemanangs >
CEI ta the majurdy act vi the hasteries, u regated by the hudear
- F11ty percent cd the wendag as a
. Aay papecultang er wedding shh6ated la inderga CEI er the NRC C3e m awdearplaas..mant'El Regut tory C= ram wa
-buge" cr ase is driactave.
aceded la remove and replace the
-j( a werber has a cancern. they plans ta start up tage tha ycar
. Equapment some el shach is Shaw called Schicamer's matar was dame property -1 can should reaNy report k?
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Ohnenumer. e tna sa t u na orscstne isbca ged44medtram the state-ea* gate & laundry hat-basacally say what he sad is inac-Best Shaw saW emme warhers may l
Cashingtea. DC, s..d plaat Z,mmer plant Iba plant. Incated She pesaned out that Sct4mmer la curate. It was done property, leet seemething is wreeg ler any i
werkerslaid hasa cut el Cancina4u en tar Obe Raver, lawotved with a privase grung known ansessed by gnalsey asensrance."
auasber ai reaseae.
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- A Eles amet.ar na tie dr)=cu was ta he a audear power plaat but as the Government An==atabaAWy
. It la m.a if agasyment was tGeverament Accesals
<ty area near the reactar turned out is besag cuaverted tecsal tornaag Project, whldt has attempted le purctaned Irom the 21enmer piant. Project) makes a poemtle seek nacar abend two weeks aga The awtar had
. A heat test a the drywell area beach hessatag of adher m cna**
becansee it was desigend le he a people euty o seveeryear marranty that had that caeaned a fase tat meath cem-planta preuertaed-water reacter and
- Western Reserve Alliance has and esperad Omer plant enp apsmest aina tsaues te be attempted asa-Of Wessera Reserve annance, a Perry is a beehagealer gearea'.
contacted the N BC about the hasespared earrantes succesatu!?y. and tae canane at tae sett4eoctJhed mulety eaaa===*r Shaw sand. ~1 hase we have lashed allegeus tes mmerseM.
- Te rsettl and rennewe the W.
tadi.re cammet he aan ed The last grang. Show und. *1 don't at other plaats lhet haw been l
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' EXHIBIT C PO SOz 37 e PEmmy. CHe0 44001 e
TELEmMONE t2tes 259 3737 e A00me ss.10 CENtem moAo TPLS Serving The Best location on the Nation PERRY NUCLEAR POWER PLANT July 9, 1985 Mr. Donald L. Schlenwer c/o Western Peserve Alliance 19916 Macpolia Driw Cleveland, GI 44196
Dear Mr. Schlenwer:
vhrious press reports within the last few weks have quoted you as stating that you had knowledge of potential safety hazards at the Perry Ex: lear Power Plant.
n= mine of our commitment to the public health and safety, we inwatigate all allegaticos of potential safety problens and encourage all workers on site to identify such problers.
The new reports of pr statenunts provided few details concerning your allegaticos. So that we can obtain the information needed to fully examine the clained defects in the cxmstruction of the plant, please contact se as socn as possible. It is not necessary that you disclose the identity of workers who say have provided information to you, so long as the information about the claimed defect is specific enough that w may adequately investigate wtether such a defect is precent.
Very truly yours, N
A a2 T. A. Boss, call for Ou ity (216) 259-3737, ext. 5348 or (216) 259-2642 i
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EXHIBIT D Western Reserve Alliance 10916 Magnolia Drive Cleveland, Ohio 44106 July 17, 1985 Mr. T. A. Boss c/o Mr. Jay Silberg Shaw, Pittman, Potts & Trowbridge 1801 M Street, N.W.
Washington, D.C.
20036
Dear Mr. T. A. Boss:
Thank you for your letter of July 9, 1985, in which you requested that the Western Reserve Alliance (WRA) contact you as soon as possible so that the Cleveland Electric Illuminating Company (CEI) can obtain the information to fully examine the claimed defects in the construction.of the. Perry nuclear plants.
A number of years ago, the Western Reserve Alliance was contacted by a number of whistlemlowers from the Perry nuclear plants.
Since that time the number of whistleblowers has grown.
^
The workers have come from a number of different unions and many are in non-union capacities.
Due to the number of whistleblowers and the scope of their allegations, the Western Resterve Alliance began to work closely with the nationally recognized whistleblower organization, the Government Accountability Project (GAP).
The reason we did this was to offer these individuals access to protection of this organization whose scope and nature is to help whistleblowers.
The structure of WRA differs from the Government Accountability Project.
s We have turned the letter you sent to us over to the offices of GAP.
It is GAP who will respond to your letter.
We could point out numerous interesting facts to you, but we will only mention a few.
The reason for stating these are to show some of the reasons we are somewhat skeptical in regards to your sincerity.
In response to an extensive article in the Lake County News Herald on Sunday, January 9, 1983, regarding men with ties to organized crime who were working or'had worked at the Perry plants, CEI spokesman,J. Lge Bailey said, "We see no long-term threat to safety."
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We can tell you Mr. Bailey is wrong.
Additional organized union corruption at the Perry plants were revealed in the Senate Committee on Labor and Human Resources' staff report on union corruption.
(See, Chairman's 72-page staff report, July 30, 1984).
Witnesses have reported to us that CEI representatives received copies of WRA's testimony around midday at the Ohio Subcommittee Hearings on Emergency plans at the Perry Nuclear Plant which were held at Lakeland Community College (near the Perry plants) on July 9, 1985; the same day that you sent us two letters (one to Cleveland and one to Washington) which you mailed from Perry, Ohio.
The WRA testimony dealt extensively with organized crime activity at the Perry plants.
On June 15, 1985, in the Painesville Telegraph, a CEI spokesperson tried to discredit the WRA by saying we were not
" reputable."
It seems strange that CEI would a few weeks later ask this unreputable group for information about CEI's Perry plants.
Stranger still, in the same article, the CEI spokesperson tried to discredit workers' allegations and WRA by telling the public that the allegations could not be true because the Zimmer -
nuclear plant was designed to be a pressurized water reactor and Perry is a boiling water reactor.
This CEI statement, of course, is false and both are boiling water reactors.
Instead of going on to write volumes on why one should be skeptical about the sincerity of CEI, we have turned this letter over to GAP who will respond to you.
Sincerely, honald L LYtmauL.
Donald L.
Schlemmer Western Reserve Alliance i
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e EXHIBIT E t -
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EXilIBIT E GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecicut Avenue, N.W., Suite 202 (202)2324550 Washingron, D.C. 20036 July 17, 1985 Mr. T. A. Boss c/o Mr. Jay Silberg Shaw, Pittman, Potts & Trowbridge 1801 M Street, N.W.
Washington, D.C.
20036 Dear Mr. T. A.
Boss:
We are writing to you because we have been asked to respond to a letter you sent to the Western Reserve Alliance (WRA) dated July 9, 1985.
The Government Accountability Project (GAP) has been working with WRA for almost two years now because of a quantity of whistleblowers which have contacted that utility 1
consumer group.
We and they believe it would be best for the protection of the whistleblowers if we respond to the letter you sent to WRA.
Your letter and public comments by your spokespersons in recent news accounts raise a number of concerns.
I am glad that you made efforts to raise them with consumer utility groups directly and through the public media.
I agree with ycur appa-rent view that issues you raised are of definite public concern and require open and public discussion.
Since 1975 the Government Accountability Project has pro-vided legal and other assistance to those who " blow the whistle" on fraud, waste, mismanagement and health and safety standards.
During that time we have developed a methodology that might vary in particular circumstances, but which nevertheless remains fairly consistent.
First and foremost, we do not dictate for those who bring information to us, how that information will be used or where it will be taken.
Those decisione are made solely by those who have obtained the information.
If we are not willing to abide by the conditions imposed by the whistleblower, we will decline to use the information in any way.
In those cases where we are actually legally representing the potential whistleblower, we often have greater latitude in deciding how to proceed.
But, we are ethically bound to protect the client and to keep his or her interests very much in our mind.
Thus, the major factor weighing upon our discussions and other deliberations about what to do about and where to go with sensitive information about problems is your reputation among workers at the Perry plants.
If employees are afraid to risk going through the internal channels of CEI or the NRC, then we would indeed risk our own credibility by encouraging employees to
" walk the plank."
If we decide to legally represent the person
who brings information forward, we would violate our own profes-sional ethics by advising the client to use defective internal channels.
Furthermore, unless I have sufficient evidence that an "open door" is truly open or an office to deal with problems does not view the whistleblower as "the problem," I will not advise employees to pursue those internal procedures.
I also would want to know beforehand that the problems raised by the potential whistleblower would most likely be dealt with appropriately.
Frankly, the Western Reserve Alliance has indicated to us that you do not really have an "open door" policy.
Please do not think that we have made any determination about your quality assurance complaint procedures or systems.
Unfortunately, at this point we do not know enough about your organization to make a valid judgment.
Some employees have expressed doubts to us.
To allay their skepticism and our own reservations, we would need to hear from the employees who have tested your allegation procedures.
In fact, we would like to continue this dialogue with you and respectfully request that you allow us to speak with those who have reported problems to you publicly and openly through your system.
If the only employees to use the procedure are ones-who hava done so anonymously, we would appreciate very much if you would somehow convey to them our desire to speak with them anonymously about the allegations procedures and their experi-ences with them.
Meanwhile, we hope you will give us some infor-mation about the types of complaints that have come through your allegation channels and what the final disposition of alleged problems have been.
The numerous reports of organized crime activity at the Perry plants are most disturbing.
Also, you should know that recently we have started to receive more contacts from whistle-blowers from the Perry plants on direct basis.
WRA contacted GAP about two years ago.
At the time were were heavily involved in many cases around the country, especi-ally the Midland nuclear plant and the Zimmer nuclear plant.
We were not able to take on a full investigation of the Perry plants.
We agreed at that time to train a legal intern.
Since that time Donald L. Schlemmer has served in that capacity regard-ing the Perry plants.
Thank you in advance for your consideration of our requests.
Certainly we look forward to the possibility of working with you.
Sincerely, A % _._
Billie Pirner Garde Citizens Clinic Director.
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EXIIIBlT F i
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EXHIBIT F po som et a Psamy, omo 44ces a TnsemoNa tatet ase 3727 e AcomE55 90 CENTEm moAo Serving The Best location in the Nation PERMY NUCLEAM POWER PLANT Septecber 6, 1985 Donald L. Schlemer c/o Mestern Reserve Alliance 19916 lia Driw Cleve
, CR 44186
Dear Mr. Schlenmer:
Thank you for your letter of July 17, 1985, in response to my letter of July 9, 1985.
I am sure that you would agree that it is to everyone's benefit if unsafe ocnditions that my exist at the Perry mclear Power Plant be identified and corrected at the earliest time. It is for that reason that Cleveland Electric Illuednating coupeny instituted its ' call for @ality" progrm sore than a year ago.
The " Call for Quality" program encourages workers to contact us on a I
ocnfidential basis if they are aware of any conditions which they believe my
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affect the safety of the plant. The ocntact my be made through the " Call for Quality" hotline, form which are available at security posts, or by personally talking with the Perry Plant cet)udsnan. Exit interviews are also being conducted. Workers mntacting the " Call for Quality" program need not identify themselves. However, if the worker does provide his nee, the onbudsun will report back to him the results of the investigation.
l The " Call for Quality" organisation is a separate grcup directed by the Quality I
Audit thit Supervisor. It is independent of both the construction and operational quality organizations. The " Call for Quality" program handles all l
concerns brought to it on a confidential basis, in order to protect the identity of all those using the program and to encourage those who might otherwise be reluctant to bring their concerns forwrd.
While it is certainly possible that there my be see wrkers who for one reason or another do not wish to corrunicate their concerns to us directly, it serves no useful purpose for these concerns to be withheld from the " Call for Quality" program. As I stated in my letter to you, we are only interested in identifying any potential problers, and not in the identity of the workers who may have brought those pctential problems to the attention of Wester Reserve l
l Alliance. We will deal with all concerns in an appropriate manner. But even if someone should believe that a concern he or she has brought to us has not i
been dealt with appropriately, nothing will have been lost by disclosing the substance of the concern to the ' Call for (bality' program.
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Withholding inforretion identifying safety concerns frce those who are in a
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position to correct them can only result in plants that say be less safe than they otherwise might be. If you have been informed of concerns which may affect the safe operation of the Perry Plant, I would rtrengly urge that they be identified to the " Call for Quality" program or to the NRC at the earliest possible time.
Very truly yours,
+==
't T. A. Boss,rQ2udsman call for Qaality (216) 259-3737, est. 5348 or (216) 25fr-2647 cc: Billie Pirner Garde, Esquire Government Accountability Project 1555 connecticut Avenue, N. W.
suite 202 Hashington, C 29936 l.
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