ML20214L372

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Partially Withheld Memo Forwarding Evaluation of Gap Late Allegations Re Safety Deficiencies Affecting Operation of Plant at Power Levels Greater than 5%.Full Power License Should Be Issued on 841017
ML20214L372
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/17/1984
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Asselstine
NRC COMMISSION (OCM)
Shared Package
ML20214L071 List:
References
FOIA-84-901 NUDOCS 8705290288
Download: ML20214L372 (10)


Text

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yg ,n FROM: William J. Dircks, Executive Director for Operations GCunningham

SUBJECT:

CALLAWAY - LATE ALLEGATIONS AND READINESS TO PROCEED 8EYOND LOW POWER OPERATION During the October 4,1984, Comission meeting authorizing the staff to issue a full power operating license amendment, you requested to be advised of (1) the staff's evaluation of the late allegations about the Callaway plant provided to the Commission by a Government Accountability Project (GAP) letter dated September 28, 1984, and (2) the staff's acceptance of the Callaway plant readiness to proceed beyond low power operation.

The staff's evaluation of the GAP allegations is provided in Enclosure I. The staff utilized the criteria outlined in SECY 84-249A " Late Allegations",

dated August 31, 1984, in their review and assessment of the 48 allegations provided by GAP. Based on the information provided, the staff review determined that there are no allegations which would affect the Callaway plant's ability to operate safely at power levels greater than five percent.

The staff's evaluation of the Callaway plant operating experience is provided in Enclosure II. For this evaluation we considered the number and nature of licensee events, operating crew personnel actions in response to events, management and supervisory control of normal and off-normal operating condi-tions and events, conduct of shift turnovers, operator knowledge of procedures, plant conditions and control room alarm conditions. Additionally, consideration was given to attitudes and professionalism of personnel, and readiness of equipment. Region III has concluded that the Callaway operating crews have gained sufficient experience through the low power testing and mode changes by the different crews such that they are now ready to proceed to power levels greater than five percent.

NRR will be issuing a full power license to Callaway on Wednesday, October 17th, or shortly thereaf ter.

(Signed) William J.Dircks, William J. Dircks Executive Director for Operations

Enclosures:

Late Allegations Evaluation I.

II. Callaway Plant Operating Experience pgg p g cc:

TRANSMITTED VIA 5520 'B 3 '

Seenextpageb MINOR REVISIONS MADE BY REHM 10/17/84

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g3 DATE :10/16/84 :10/0 /84 : toi nld :  :  :  :

Ng 8705290288 870526 PDR FDIA VARRICC87-901 PDR OCT 19 M

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. Comissioner Asselstine 2 cc w/ enclosures:

Chairman Palladino Comissioner Roberts Comissioner Bernthal Comissioner Zech SECY OPE OGC .

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, ENCLOSURE I LATE ALLEGATIONS EVALUATION At 1:00 p.m. CDT on October 5, 1984, a telephone conference was held with representatives of Region III, I&E, and NRR, to review and assess the 48 allegations filed by the Government Accountability Project (GAP). For this review the staff utilized the criteria outlined in Policy Issue -

" Late Allegations," SECY 84-249A, dated August 31, 1984. The purpose of the review was to determine which allegations, if any, would require resolution prior to the Callaway Plant being authorized to exceed five percent reactor power.

The criteria utilized requires a substantive review of each allegation to det' ermine whether the allegation is reasonable and soun'ds competent and I whether the allegation represents a significant safety issue or management concern.

The review placed the allegations in the seven categories identified below:

Categorization of GAP Allegations A. Allegations that do not fall within the NRC area of responsibility - __

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B. Generic GAP issues -

C. Nonsafety-related issues l

D. Issues describing conditions which are not code violations and, therefore, are acceptable E. Issues previously addressed and closed out in inspection reports, 50.55(e) l reports, hearings, or old allegations -

l F. Issues requiring inspection G.

l The review determined, based on the information provided by GAP, that there were no allegations which offered specific new information, not previously known to staff, which would reasonably be expected to involve sizeable failures of systems that contain radioactivity or of the ECCS systems; therefore, staff detennined there are no allegations which would affect the Callaway Plant's ability to operate safely at power levels greater than five percent.

The staff has had personal discussion or telephone conversations with represen-tatives of GAP on October 4, 5, and 8,11,12,15,1984, for the purpose of obtaining the affidavits which GAP relied upon to prepare the allegationt.

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. We plan to complete resolution of all the issues, in a timely manner, and to document the results in inspection report 84-45. Additionally, we plan to continue to pursue actions to obtain the affidavits from GAP.

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. i ENCLOSURE II -

CALLAWAY PLANT OPERATING EXPERIENCE' Region III initiated an augmented inspection program (AIP) at the Callaway Plant on August 29, 1984, when the plant first entered operational Mode 3 (HotStandby). In addition to the Callaway senior resident inspectors, the program utilizes other Region III resident inspectors and regional based inspectors. The program was implemented to provide Region III with additional onsite inspection of operational activities during Mode 3, initial startup and power ascension to better assess the licensee's personnel and plant readiness L

for full power operation.

The AIP has provided coverage on portions of all shifts on a seven day schedule ,

and will remain in effect until such time as we are satisfied with the licensee's

] operating experience.

I The AIP inspectors observed attentiveness of operators and their responsiveness to plant parameters and plant conditions, that plant evolutions and testing are planned and properly authorized, procedures are used and followed, equipment status changes are appropriately documented and communicated to appropriate shift personnel, that operating conditions of plant equipment are effectively 3

-monitored and corrective action is initiated, as required, and that control  !

room activities are conducted in a professional-manner. I j

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- Evaluation of the licensee's operating experience from entering Mode 3 (Hot j Standby) to the initial approach to criticality (Mode 2) indicates that:

l The operators were aware of and complied with technical specifications, l that plant operating and administrative procedures were utilized and adhered to, and that plant temperatures during heatups and cooldowns were closely monitored and plotted.

Shift supervisors held detailed briefings of crews prior to changing plant lineups or equipment status. The shift technical and operating shift advisors were integrated into these briefings.

Activities involving starting or stopping major plant equipment were communicated within the control room and announced over the plant loud speakers.

The response to technical questions presented to personnel by NRC inspectors indicated that both supervisors and operators had good working knowledge of plant status, technical specification and procedures. The shift crew's performance during plant evolutions demonstrated the crew's ability l l

to effectively operate the plant.  !

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The operators' response (s) to abnormal conditions and alarms demonstrated a I

good working knowledge of plant systems and procedures. Operators were attentive to alarms and initiated appropriate technical specification action and surveillance requirements. Initial operator response and recovery 2

actions in response to abnormal conditions were appropriate and performed in a professional manner.

Shift turnovers were performed in a very detailed and professional manner, and included a review of logs, control room panel walkdowns and detailed discussions of past, current and planned activities.

Shift personnel frequently referred to plant procedures and drawings during the processing of work requests and temporary modifications. Test and surveillance procedures were properly authorized and scheduled. Plant incidents and reportable events were appropriately documented and communicated.

Evaluation of the licensee's operating experience during the initial approach to criticality (Mode 2), on October 1,1984, startup and core physics testing and during operations at power levels below five percent as of October 15, 1984, indicate that:

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l Plant procedures, including operating, administrative and test procedures l utilized during operational mode changes, startup testing activities, and routine and non-routine events are generally well written, contain adequate detail and are understood and followed by shift crews.

Shift crews are knowledgeable of system details and plant status and demonstrate a disciplined approach to plant operations.

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w Shift turnovers are detailed and professional, and include log reviews, control room panel walkdowns and detailed discussion of plant conditions, testing in progress, and discussions of past, current, and planned l

activities.

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In. response to NRC questions the shift crews demonstrated a good knowledge  !

of plant systems and technical specifications which indicates adequate training, knowledge, attitude and ability to operate the plant safely )

I during all plant operating modes.

After issuance of the low power license, Region III became increasingly-concerned with the incidence of Licensee Event Reports, several of which involved personnel error. Since the Enforcement Conference with licensee management on August 20, 1984, the frequency of licensee events involving personnel errors has decreased. Factors which may have contr1buted to the reduction of personnel errors include the licensee's restriction of personnel access in the control room, assignment of the Superintendent of. Operation and assistants on shift as shift coordinators, removal of certain administrative functions from the control room, implementation of a 4 shift,12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift rotation schedule to reduce the number of shift turnovers and provide additional personnel on shift, and a series of meetings conducted with plant personnel emphasizing the need to reduce personnel errors. Additionally,  ;

1 Region III's augmented inspection program was implemented on August 29, 1984. l 4

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During the Enforcement Conference, the licensee agreed to develop a program which would give them and the NRC staff confidence that the operating crews are ready to commence power ascension and operate the plant at full power. On September 10, 1984, the licensee submitted a plan to accomplish additional operating evolutions, which was acceptable to Region III. These evolutions have been completed satisfactorily.

Based on the results of the augmented inspection program, the reduced frequency of personnel errors at the Callaway plant, and the licensee's successful completion of additional operating evolutions, we conclude that the licensee has demonstrated that they can operate the Callaway plant safely at all power levels.

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MRNMENT ACCOUNTADILITY PROJECT d555 Connecticut Avenue, N.W., Suite 202 Washingron, D.C. 20036 (202)232-8550 Honorable Nunzio Palladino, Chairman Honorable James Asselstine, Commissioner Honorable; Thomas Roberts, Commissioner .

Honorable Frederick Bernthal, Commissioner Honorable Lando Zeck, Commissioner United States Nuclear Regulatory Commission Washington, D.C. 20555 Re: Callaway Nuclear Power Plant, Unit 1

-authorized by NRC Operating License No. NFP-25

Dear Commissioners:

The Government Accountability Project (GAP) is a non-profit, non-partisan public interest organization concerned with honest and open government. i Through legal representation, advice, na-tional conferences, films, publications and public outreach, the .!

project promotes whistleblowers as agents of government account-ability. Through its Citizens Clinic, GAP offers assistance to 1

local public interest and citizens groups s.eeking-to ensure the l health and safety of their communities. The Citizen's Clinic is 'i currently assisting several citizens groups in the Missouri area concerning the construction i

of the Callaway Nuclear Power Plant.

.On behalf of'the Concerned Citizens About Callaway, and a number of present Nuclear Poder Plantand former nuclear workers at the Callaway (CNPP), the Covernment Accountability Project requests that Nuclear Regulatory Commission (NRC)' take immediate action regarding the allegations below. We request that the low power license be suspended until such time that each.of the-specific allegations listed below is investigated and that i appropriate re-inspection is performed to determine the extent of the problems raised by each allegation. ,

The Nuclear Regulatory Commission has a duty and-a responsibility established by Congress to assure.that the use of nuclear material as in the operation of nuclear. power plants is carried out with proper regard and provision for the protection of public health and safety and of the environment, the safeguarding of nuclear materials and facilities from theft and sabotage, and safe transport and disposal of nuclear materials-and waste.

Federal regulations also establishes measures by which hMMM

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citizens can act when the citizezis believe that the Nuclear.

Regulatory Commission has failed to honor its responsibili. ties.

Pursuant to 10 CPR 2.206 any person may request the Nuclear Regulatory Commission itself to take action as deemed appropriate to resolve unanswered questions about the safety of a particular

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Callaway Nuclear Power Plant 28 September 1984 Nuclear Regulatory Commission We believe that the Callaway Nuclear Power Plant is not ready for low power operation. Serious allegations have been brought to our attention as a result of the breakdown in the quality assurance program. As defined in 10CFR50 Appendix B, I, the quality assurance functions are those of (a) assuring that an appropriate quality assurance program is established'and effectively executed and (b) verifying, such as by checking,

- auditing, and inspection, that activities affecting the safety-related functions have been correctly performed. The quality assurance program at Callaway has not been executed effectively as required. Former and present Callaway workers have sought our assistance in presenting evidence of inadequacies in activities affecting safety related functions. These inadequacies have not formerly been identified by the quality assurance program.

A majority of the serious hardware problems are located in the Fuel building, Control building and Reactor building. At this late stage in construction, many of the problems are inaccessible. Nonetheless, it is critical that the extent of the problems be determined before the various parts of the plant become contaminated. Once lower power operation is underway, these hardware problems will be even less accessible and repair work will be more costly and dangerous.

The NRC's Region III has a history of some of the nuclear industry's worst problems: Midland, Marble Hill, Kerr-McGee Corps Cimarron Plutonium Recycling Facility, Byron, and Zimmer.

These nuclear power plants were crippled by'.too little regulation to attract management's attention or too late to make economical rework possible. Victory Gilinsky, a former member of the NRC, has asserted that without a doubt the NRC should have been more forceful with inspection and enforcement on the history of these Region III projects.

We are requesting the NRC to conduct an honest, open, and good faith investigation of the safety issues presented here.

Anything less than this standard of investigation would indicate that the quality assurance breakdown extends to the NRC itself.

At that point, quality assurance is carried by those on' site alone, but the history of workers at Callaway is grim.

One case is immediately called to mind, that of Bill Smart.

Bill Smart is a former ironworker and foreman at the Callaway )

Nuclear Power Plant. His case is a well known one of how he blew '

the whistle about poor construction practices. As a result of his whistle blowing he was fired. The law protecting whistle blowers has since changed, and construction workers are now i protected from such retaliation. But the effect of his '

termination was already in place. His firing has had a chilling effect on the willingness of other Callaway workers to report 2

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28 September 1984 Callaway Nuclear Power Plant Nuclear Regulatory Commission suspected defects in workmanship to the Nuclear Regulatory Commission. The value of whistleblowers is immeasurable.

Project workers are in a much better position to see shipshod and potentially unsound building practices at nuclear power plants.

~ Workers can do more to guarantee the sound construction practices at nuclear NRC powerinspectors plants than the occasional actually spotone checks by NRC inspectors. Thus,examine only quality assurance to is five percent of on-site construction. For these reasons we virtually left solely to the workers.

present these allegations.

The following allegations have Thesebeen compliedgathered allegations, from notarized by GAP affidavits by former workers.

investigators during a six month investigation, reflectThe totallity deficiencies in construction and quality control.

of these deficiencies have serious implications regarding the integrity of the managerial and administrative con $rols-used to assure the safe operations of the Callaway Nuclear Power Plant.

1.

Painters at Callaway I have prepared thousands of welds in the Reactor Building for painting by The rust-proofing wasremoving removedthewithrust-pv3 I V8 jpA proofing from the: welds. grinders from these welds that had already inspected and approved. No measurements

.Sincewere made of the has d'Ni q- no re-inspection remaining been done, weld metal or base metal.the quality and safety of thousands o Reactor Building is now indeterminate.

2. Welders have ground smooth the horizontal, the vertical and the floor panel welds of the Spent Fuel Pool,In the process, neg g

Transfer Canal and Cask Loading Pool. As a result of this fyd welders removed weld metal and base metal.

peb l ggM( overgrinding, certain areas of these pools no longer meetThe integrity thickness requirements.

Transfer Canal and Cask Loading Pool is questionable.

3. Furthermore, hasty and improper rework was done on

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the seam welds of the liner plates in the Spent Fuel Pool, Tran-These lin

[py/ sfer Canal, and Cask Loading Pool. This defect made NphA f tive in that they are not exactly square.The seam welds of the liner plates gq 99 original welding difficult.were reworked but because of time constraints, the sufficiently repaired.

4.

Weld metal joining the reinforcing ribs and the pdb r steel liner plates of the Containment Building has been eatenThese l@3rdigi l0f away by rust and linercorrosion.

plates were not rust-proofed. Corrosion

,4,q j of the steel the backside of these plates before they were encased in R

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Callaway Nuclear Power Plant 28 September 1984 Nuclear Regulatory Commission F, # 5. Bad welds exist on pipehangers as well as on the

! Fb 4,ih embed plates that anchor the pipehangers. These pipehangers and p embeds are located near the floor of the Reactor Building. They gg are difficult to reach due to the surrounding installed equip-4 I M[d and pockets 1

ment. The bad welds have excessive weld material, tiny holes, on the surface; some of the welds are actually incomplete. No rework has been done,on these faulty welds.

6. Not all welds that have been Quality Control A approved have been Quality Control inspected. Welds in difficult

,9 to reach areas, such as on unistruts, have been approved without

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b , the Quality Control inspector's examination. ' There are also welds th e h m g approved without inspection located on the j

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condens.gra_in the Turoine sullding. p _jpfgp(.

7. Inexperienced and underqualified welders were

,() f employed at Callaway. Union pipefitters and welders were not

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' [fp hired by Daniels International because there was a shortage of skilled welders. As a result, a welder training program was established. The program was very brief, and it was commonly referred to as a program which produced " instant welders" Journeymen welders generally spend several years developing the

, expertise required for welding. This program produced welders in i

1 a matter of weeks.

Furthermore, the welder certification testing

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program allowed almost everyone who took the examination to pass.

Thus, the program permitted inadequate welders to weld safety related structures.

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9. The welder certification testing program did not

\, screen out these bad welders.

It was apparent that it was set up j gt0 for the purpose of producing men to do the work rather than to Fg .

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riskslowingupproductionbywithholdingcertificationfrombad;u welders. In fact, it was reported as common knowledge that the

!, gbj welding certification supervisor for several years would look the 7 gv other way, and certify technically inadequate welders. He did

} this in exchance for & payment of bribe money,/ Workers who jL were unable to weld adequately graduated from This program. '

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10. Yet another technique used to pass welder-applicants was accomplished"by allowing applicants to take the d

test as many times as was necessary. If an applicant failed, the test was not considered as as a " test" but rather merely as practice. Welder-applicants took the test j before an acceptable weld was produced. Co/c.as per*J many

/f as five times j 11. As a result of using this underqualified and g, , inexperienced work force, much rework had to be done. The pipe V hanger department suffered the most because the worst welders i

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Callaway Nuclear Power Plant 28 September 1984 Nuclear Regulatory Commission were often relegated to pipehanger welding. Many of these weld-ers were hired during the construction of the Control Building.

Pipehangers and supports were slapped in by these inexperienced welders to keep the construction of the Building on schedule. A lot of shoddy work was done, and duplicate work was re the hanger department in later years. NO SAf/y7 8 61 &quig d by//'IdFQ

12. This mode of construction creates many problems.

i g Once construction was complete, repair and rework was done on the

[p lower levels of the Control Building two to three years later.

hd Some of the welds could not be reached; some were covered with Sh '9freheating. . concrete.

This rework weakens O The tensile strengththe metal because is reduced and the of the required metal becomes k

\ ( Nr_eworkedbrittle. E n addition, is doubled the cost of each weld that has to be ] e r //4

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/t' cum y;pg g y, h9 Quality Control inspectors did not always maintain the necessary independence from the pressures of schedule and g6 cost. It was reported that Quality control inspectors would Af sometimes approve without inspection welds located in hard to reach areas. These areas are exactly the places where it-is more difficult to do welding, and therefore, more important to inspect for poor welds.

14. Quality control inspectors were known to favor their friends. They would inspect to a lesser standard than they were required. _

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/ be assertive in their positions have been subjected toThose Quality Control pe f intimidation and harassment. It is reported that workers have dropped things from heights such that the hardware dropped would OL i

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land near the Quality Control inspectors. Quality Control inspectors have been splashed with concrete and with water, and gi one Quality Control inspector had his hand intentionally smashed {

with a vibrator by a workman.  ;

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~k' 16. Quality Control-issued "hol'd tags" often left workers idle for one or two days. " Hold tags" indicate that t i

[dt'5g there is a problem with the tagged item and all work on this item

, should be stopped until the. problem is resolved. Once the i dod pr blem is resolved, a Quality Control inspector removes the tag and work can continue on the item. _often, a foreman or {

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_ supervisor would eventually give the order to proceed with work g iannre the hold __t Ca s. Workers questioned the unexpT6Tned orders to proceed when the work had not been changed or been seen i i

fixed. Either money was being wasted on non-problems or safety deficiencies were being accepted.

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Callaway Nuclear Power Pla6t 28 September.1984 Nuclear Regulatory Commission

} 17. There was a shortage of Quality Control C q inspectors. Oneworkerreportswaitingsix,tenhourdaysfor]adAf M t-) Quality Control inspector. During this delay, the worker was not permitted to move onto a new work assignment.

18. Deficient electrical cable has been used on safety pd ga related systems throughout the plant. Generic problems regarding the environmental qualification testing of this Class 1E 9 electrical cable have been recognized and acknowledged by the NRC, Office of the Inspection and Enforcement. It is reported that this cable is literally all over the plant.
19. Electrical cables were installed too early in

[ construction operations.

(jp The cables have been exposed to the V l harsh environment of early construction and have been damaged during construction from hot metal and other elements thrown around during early construction.

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20. Violations of electrical wire bend radius are reported. Eighty to eight-five percent of junction boxes are too h small through the Auxiliary Building and the Control Building.

Because these junction boxes are undersized, wires,which ' feed in and out of the boxes are overstressed. *

21. Th,ere are no protective cable jackets and static bleeder wires on cables feeding through the cabinets into the

\gt1 Control Room. Prbtective cable jackets and half-wrapped, outside hb electrical interference fit the cables deflector through the wire were undersized removed in order to cabinets.

22. High voltage splicers frequently are submerged under water in eight foot deep concrete man holes. These man holes, built for high voltage splicers, have no drainage system.

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Water collects in the man holes submerging the electrical cables until the water eventually evaporates.

23. Insufficient fire proofing has been installed on these high voltage splicers. These splicers have only one-third ktherequiredfire-proofing.
24. The use of vibrators was an ineffective means of spreading concrete. Vibrators did not settle all of the concrete. Throughout the pours, the density of the concrete and the high volume of reinforcing steel created problems with the flow of the concrete. Pockets of air were created around the reinforcement bars. Voids remain in the concrete.
25. The only attempt to test the concrete for voids was the visual inspection. Visual inspection, as the only means

- used to detect voids, reveals only those voids which are apparent

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, '.' l Callaway Nuclear Power Plant 28 September 1984 Nuclear Regulatory Commission on the surface of the concrete. Sound testing is not an effective means of detecting voids because of the high volume of reinforcing steel used. For instance in the base mat of the Containment Building, there was approx,imately one pound of reinforcing steel for every nine pounds of concrete.

26. Patchwork of the voids was very limited.

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)rebar prevented cement finishers from reaching some of the more extensive voids. Thus, grouting was done only in those areas that the finishers could reach.

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concrete ceilings Defective bolts were of the Control used to install the embeds on Building. .

These embeds were not installed at the time of the concrete pours of the ceilings as planned.

Instead, these plates were placed with expansion bolts.

Some of the expansion bolts used were " Redheads". " Redheads" have been found by many construction companies to be defective.

28. Drainage in the Auxiliary Building is poor. Six i to eight repeatedly.inches of water on the lower floor has been reported Possibly there is debris clogging the, pipes or the pipes are too small to handle the large volume of water.

29.

Pipehangers soiled with metal filings and dirt during the been cleaned. flood of the Reactor Building on June 2, 1984 have not clean side, but were not cleaned inside the band which extendsThes entirely around the pipe.

jeopardized by these dirty hangers.The integrity of the pipe will be 30.

revised as necessary. Construction drawings were not being updated and l For instances, laborers cutting a trench l to lay a pipe discovered a six-inch diameter pipe. There was no record of the pipe on the construction drawing.

the pipe was unknown to the crew as well as to the supervisor.The identity of

31. Construction drawings were defective. A concrete column was poured according to the construction drawings. It was later discovered that this column was too high to meet the necessary connecting beam. The concrete column had to be entirely removed.

Construction of the column was haulted for three months thereafter, while the drawings were being corrected.

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l in 5005 construction drawings. Poor construction 5005 drawingsresulted fromfor were used engineering the errors installation the AuxiliaryofBuilding.

cable tray supports in the Control Building and hangers were not centered properly on the embeds.As a The result of the poor engineeri non-conformance error. In fact, report attributed the poor construction to craft the error was due to the incorrect drawings

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/ Callaway Nuclear Power Plant 28 September 1984 Nuclear Regulatory Commission i issued by engineers. Quality Control approved this inaccurate I construction and accepted "as is". "As is" approval did not reflect appropriate engineering review.

33. Undocumented rework was performed on the Transfer Tube. Under cover at night two boilermakers welders and two helpers removed a piece of this stainless steel tube in order to do repair work within the tube. This work was done without any paper or documentation and without any Quality Control inspection. j
34. Thereliabilityoftheon-sktelaboratoryis challenged by inaccurate test results. During the flood of the Reactor Building of June 2, 1984 , fiberglass insulating blankets l 1

were soaked with borated water. Eighty-five blankets were removed and sent to the on-site laboratory _to_be tested for j

damage caused by the caustic acia. The on-site laboratory -

j- concluded that the borated water soaked blankets did not need to i be replaced. The strength of the blankets had in fact i deteriorated such that they could be shredded by hand._ The

'j blankets were ultimately found to be defective by the pressure of the workers and were replaced.

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35. Dosimeters wer'e not worn by workers in the Reactor 4

Building while fuel was being loaded in the Reactor Core. SNUPPS i Radiological Emergency Response Plan requires that all personnel

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entering the controlled areas be issued thermoluminescent i dosimeter badges. Most workers in the Re actor Building had not r

been issued badges nor had they be.en given the necessary i

radiation protection training. Without radiation detection badges, it was impossible for anyone to determine the level of exposure to radiation while working in the Reactor.

36. Psychological testing conducted in late 1983 and early 1984 failed to remove the potentially bad elements from the work site. Acts of sabotage have occurred since the examination was administered. On July 4, 1984, there was such an act.

Breakers in the Motor Control Room in the Auxiliary Building were shut off. It has been reported that in connection with the circuit breaker shut off, a voice announced over the communications system at'the plant, "UE - Have a nice fourth of July". For the following days, craft workers made a joke about "UE - Have a nice day".

37. The psychological test failed as a screen for employees, but served as a means of harassment. Workers were coerced into taking the test. Everyone on site was given an opportunity to take the test. The test was not required although non-tested employees who had been on site for less than three continuous years of service could not be employed in restricted 8
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Callaway Nuclear Power Plant 28 September 1984 l

Nuclear Regulator Commission fixture. This fixture could have been hung by one man in one hour.

Much of the delay was due to the lack of work assignments.

Work assignments were required for any job on site. Sometimes a 4

worker assignment.

would be idle for one or two days waiting for such an- ,

i In the meantime, the. worker would appear to be busy or would just sit around until he was issued a work assignment.

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45. Cost overruns can also be attributed to the high t

volume of discarded materials. For instance, one individual ,

j reports that over the course of his employment as a dump truck driver, he dumped several thousand pounds of welding rods.

l' Welding rods are very expensive; many companies control the rods 4

when the rods are issued to the welders as well as when they are returned. 'Daniels, on the contrary, only controlled these rods when they were issued to workers. It is reported by one worker

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that he has seen, on several occasions, welders take out ten pounds of welding rods in the morning, not use any of the ten-

] pounds of rods during the day, and later dispose of the ten j pounds in the barrel provided on site.

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46. Barrels were provided on site for disposal of i welding rods. The barrels were filled with welding rod stubs as 1

well as unused welding rods. These barrels were later dumped in on-site landfills,. Welding rods were prohibited in the landfill.

It was also against regulations for workers to dump their garbage from home in the landfill, but this was routinely ignored. Many people, including the general supervisor, would bring garbage from home and dump it in this landfill.

j 47.

Many acts of sabotage have also been reported.

The NRC, in its latest inspection reports, admits to eleven acts j

of malicious mischief regarding the destruction of electrical cables. Workers have found various items in pipes such as j

scraps of steel wire, electrical cables, two by four inch wooden boards, and welding rods.- These pipes had to be cut open in '.

order to remove the material. It was generally understrod by i

workers production.

that these acts were done deliberately to slow wp work

48. Although these construction and Quality Assurance problems would be serious under any circumstances, they are made.

more for the following reason. The Nuclear Regulatory j commission, Region III has been violating its own rule regarding on-site inspections. The construction inspection offices of the NRC profess that all on site inspections by the NRC are to be i

unannounced to personnel on site. Quite the contrary, many l

workers have reported that employees on all levels were pre-i notified inspections.

by their foreman or general foreman of upcoming NRC would be prepared for the NRC.

Several days before the inspection, the job site Workers, who had not been 1

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-Callaway Nuclear Power Plant 28 September 1984

Nuclear Regulatory Commission

! areas, that is, behind the fence. Those who refused the test l

faced certain termination for lack of work opportunity.

38. The psychological test, the Minnesota Multiphasic Personality Inventory is a test intended for psychological diag-nosis. There is no pass or fail standards.for a diagnostic test..

At the Callaway site, a pass / fail system was imposed on the test. j J

Infact, several dozen employees were terminated because they '

,- failed to pass the test.

39. The general attitude of workers about construction operations at the Callaway Nuclear Power Plant'is that it is a t

disgrace to the construction industry. '

. ~40. There have been enormous amounts of cost overruns i at the' plant. There were excessive amounts of manpower on site.

1 Approximately 200 electricians were hired in~1 ate 1983. Despite this almost one-third increase in manpower, there had been no

, increase in the work assignments. In general, the plant was

] overwhelmed with manpower. Seven, ten to twelve' hour shifts became mandatory. Employees who could not maintain-this l demanding work schedule and missed a day of work wpre terminated.

J A medical excuse, a death in the immediate family or a call to j jury duty were the only acceptable excuses for any absence.-

' Bogus medical excuses were available on site'for three dollars.

Less work was don'e during this manpower overload than previously'  ;

in an eight hour day.

j

41. People were idle on the job site. Some slept at i j

work; home.

a few brought in alarm clocks to wake them up in time to go '

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42. Illegal drugs, alcohol, gambling and prostitution __

could be found on the job site. In February of 1984, seve l Quality Control employees were fired for alleged drug use.gj / ([)__ f,  %

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i Please refer to the attached articles from the Kingdom Dail) '" /

{ Star-Gazette. The Government Accountability would like --

) information about the drug-related terminations and related '

developments at the Callaway Nuclear Power Plant, including but. j i not limited to, the attached list of questions.

j 43. Workers were almost encouraged not to accomplish l 1 too much too quickly. One witness reports that he was physically

threatened at work for working too hard. He told his foreman and I it was taken as a joke. Other workers report that crews were eventually split up if they were working too-fast.

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{ 44. Poor management was another cause of the cost

overruns at the plant. For instances, it is reported that two electricians spent eight hours hanging one electrical light

} . 9 l

Callaway Nuclear Power Plant 28 September 1984 Nuclear Regulatory Commission directly informed, would know of an upcoming inspection when they were taken off of their regular job assignment and put onto a clean up crew. This prenotification weakens the NRC inspection process itself and raises serious doubts about the reliability of the staff conclusions concerning the quality and safety of the plant.

In conclusion, we reiterate our request for the following relief: we request that the low power license be suspended until

. such time that each of the specific allegations listed above is investigated and that appropriate re-inspection is performed to determine the extent of the problems raised by each allegation.

We have included allegations regarding waste and cost overruns, because this letter will also be received by the Missouri Public Service Commission. These allegations reflect an indifferent attitude that prevails on all levels of employment at the Callaway Nuclear Power Plant. We believe that. ultimately this attitude affects the safety related functions of the plant.

We will be glad to discuss the allegations and a plan for resolving these open issues. With the evidence of' recurring nature'of quality assurance problems at this plant, a piece meal approach is inappropriate. We look forward to your response.

Sincerely, l

f' d' M Michele arricchio Staff Associate

%Lt p/

Billie Garde Director of Citizens Clinic CC:

NRC, Region III ,

i Missouri Public Service Commission

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ATTACHMENT o  :

GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP) ,

Please refer to the attached articles from the KINGDOM DAILY SUN GAZETTE 2/21/84.

1. When was the investigation into drug use at CNPP initiated by Applicants or its Contractors?
2. Who specifically (name, title, organization, authority)-

instigated the investigations?

3. Why was the investigation into drug use at CNPP initiated?
4. What was the specific event which triggered the investiga-tions? Give complete details.
5. What is the status of the investigation at this time?
6. If the investigation is not complete, when is it expected to
be completed?
7. What has been done with the drugs confiscated by Applicants or its Contractors? .,
8. What law enforcement agency (or agencies) have been notified by Applicants'or its Contractors regarding this matter?

, 9. What, if any, law enforcement agency (or agencies) have been 4

involved in the investigation?

i

10. Has the investigation by law enforcement agency (or agencies) been completed.
11. If the investigation by law enforcenent agency (or agencies) has not been completed, when is it expected to be completed?

4

12. Supply the name(s) of the individual (s) with law enforce-ment agency (or agencies) who have been involved in the  !

' investigation and information as to how and where such  ;

individual (s) can he contacted.

13. How many (total) employees have been investigated to date by i Applicants or its Contractors?

I

14. How many employees have Applicants (or others) investigated to date who are with the following organizations: i I

(a) Plant Operations; i (b) Quality Assurance (onsite);

! (c) Quality Assurance (other);

1 l

. s GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)

(d) Quality Control Supervision or Management -- Non-ASME; (e) Quality Control Supervision or Management -- ASME; (f) Quality Control Inspectors -- Non-ASME; (g) Quality Control Inspectors -- ASME; (h) Engineering; (i) Engineering Supervision or Management; (j) Construction; (k) Construction Supervision or Management; (1) Building Management; (m) Project Control / Procurement; (n) Project Control / Procurement Supervision or Management; (o) Project Management Control; , .

(p) Project Management Control Supervision or Management; (q) Document Control Center;

, (r) Document Control (Satellites);

l (s) Document Control (Other) l (t) Personnel or Employment personnel; (u) Personnel or Employment Supervision or Management; (v) Security personnel; l (w) Security Supervision or Management; l (x) Vendor personnel; ,

! (y) Vendor Supervision or Management; i 15. Have all of the employees'who were/are under suspicion i or who have been accused by others of taking or selling drugs been in'terviewed personally?

l 16. Have all of the employees who were/are under suspicion or who have been accused by others of taking or selling drugs been ' asked to take lie detector tests?

17. Have any supervisory employees been asked to take lie detector tests?
18. Have any upper management einployees been asked to take lie detector tests? _
19. What form has this investigation take (personal interviews l by Applicants or their agents, personal interviews by law enforcement officials, written questions, lie detector tests, discussions with other employees, etc.)? Give specific details, including what specific actions Applicants or its Contractors have taken to confirm whether or not i specific individuals have been involved in drug-related I activities.
20. What specific drugs have been found onsite?
21. If different from above, what specific drugs have been l identified by employees (or others) as having been used l onsite? l 2

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GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS

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i AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR ~ POWER PLANTi(CNPP) 1- 22. (a) Have Applicants' or others investigations' indicated-l i

or confirmed (specify which) that employees have used or have been using drugs onsite?

! (b) If the answer to- (a) is yes, how many employees.have L been indicated or confirmed-to:have used drugs onsite?

Supply the total number , and answer for each organization listed in 14. preceding. '

4

23. Have Applicants' or others' investigations. indicated or con-firmed (specify which) that drugs have been sold onsite by employees of Applicants or their agents (to includeLeon-j-

1 tractors, sub-contractors, vendors, etc.)?

24. Have Applicants' or others' investigations indicated or-confirmed (specify which) that drugs are still.being. sold onsite?

l

25. What specific drugs have been identified by employees or-1 others as have been sold onsite?

l 26. (a) Have Applicants' o'r others' investigation indicated j or confirmed (specify which) that anyone other.than '

employees (of Applicants or their agents)fhave sold

+

drugs onsite?

1[ (b) If the answer to (a) is yes, supply complete details. .

j

27. Have Applicants made any specific efforts to ascertain whether or not supervisory, or middle or upper management.
have been involved in
1 1

(a) taking drugs at CNPP?

(b) selling drugs at CNPP?

4

28. If the answer to 27. is yes, supply specific details.of-

~

J

] what efforts Applicants or its Contractors have made.

I

29. (a) Have Applicants or its Contractors made any effort to.

l determine whether or not anyone in a supervisory -

[j position or in middle or upper management has ever attempted to force or coerce other employees to take 4 drugs?

(b) If the answer to (a) is no, why haven't they?

i, -r j (c) If the answer to (a) is no, do they have any_ plans i to do so? 73

, ;t = l ; . . .

. GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)

(d) If the answer to (a) is yes, what have been the results of such efforts? Provide specific details.

30. Was he/she:

each employee terminated if it was determined that (a) 'had ever taken drugs?

(b) had ever been picked up for possession of drugs?

(c) had a conviction record for possession of drugs?

(d) had ever taken drugs onsite? ,

(e) had ever taken drugs offsite which may have had an effect on such employee's work?

(f) had ever sold drugs?

l (g) had ever sold drugs onsite? "

(h) hadaconvictionrecordforsellingdrugsh-(i) had ever. sold drugs o'nsite?

(j) had every sold drugs offsit which may have had an effect on the work of other employees at CNPP?

31.

How many employees have been terminated to date who were with the' organizations listed in 14. preceding. >

32. (a) Have Applicants reinspected or do they plan to re--

inspect the specific buildings and/or systems on which drugs work all employees suspected of taking or selling or have worked?

(b) If the answer to (a) is yes:

(i) list the specific buildings which have already been reinspected, and indicate the extent and status of such reinspections.

(ii) list the specific systems which have already been '

reinspected, and indicate the extent and status of such reinspections.

(iii) supply specific details, by building and bv system regarding the results of such reinspections.

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\\, GAP REQUESTS INFORMATION REGARDING' DRUG-RELATED' TERMINATION u -

s AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)

(c) HIf.the?qn.swer to (a). is'no, give, specific details.of of Appliennts' plans and the rationale.for their actions in this' regard.

,s (d) If the answer to (a)'is'yes:

(i) list the specific buildings which have not yet been reinspected.

(ii) do Applicants plan to reinspectKthe specific build-ings listed in -(i) above? If-not, why not? If so when are such reinspections. expected to be begun, and when are such reinspections expected to be

, completed? \

(iii) listinspected.

the specific systems which have not yet been (iv) do Applicants plan.to reinspect the specific systems listed in (iii) above? If not, why not?

If so, when 'are such reinspections expected-to be begun, and when are such.reinspections expected to be completedJ s i (e) If part~pf the rationa e for Applicants' decisions regarding reinspections is because of redundant,and independent inspVctions:

(i) what specific actions have-Applicants taken to ddtermine whether or not'(for example) more than one QC inspector suspected of drug use or sale workedLin one particular area or on one part-icul'ar system? s Give complete details.

(ii) for each system on which an employee sus-pected of taking;or selling drugs works or has worked, list the categories (such as field.

engineers, equipment manufacturers, other'QC

' inspectors, Authorized Nuclear Inspectors,:etc.)

on which' Applicants are' relying for such're--

dundent and independent inspections.

33. - (a) Have Applicants or Contractors contacted the Nuclear Regulatory Com.nission (NRC) regarding the drug-related terminations'and related developments at CNPP?

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. . 4 e s GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)

' 8UPPl y the following irfo ma on (i) Who specifically with the NRC was contacted, and who specifically with Applicants contacted the (ii) What has the response of the NRC been? Give full and specific details.

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