View source for DD-85-07, Notice of Issuance of Director'S Decision DD-85-07,denying M Varricchio & B Garde 840928 Request for Action Re Allegations Concerning Improper Const Practices & Other Improper Plant Worker Conduct at Facility

{{Adams
| number = ML20127J147
| issue date = 05/17/1985
| title = Notice of Issuance of Director'S Decision DD-85-07,denying M Varricchio & B Garde 840928 Request for Action Re Allegations Concerning Improper Const Practices & Other Improper Plant Worker Conduct at Facility
| author name = Denton H
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name = 
| addressee affiliation = 
| docket = 05000483
| license number = 
| contact person = 
| case reference number = CON-2.206
| document report number = DD-85-07, DD-85-7, NUDOCS 8505210391
| package number = ML20127J090
| document type = FEDERAL REGISTER NOTICES, TEXT-CODE OF FEDERAL REGULATIONS
| page count = 2
}}

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7590-01 U. S. NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-483 UNION ELECTRIC COMPANY CALLAWAY 1 NOTICE OF ISSUANCE OF A DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby,given that the Director, Office of Nuclear Reactor Regulation, has issued a decision pursuant to 10 CFR 2.206 concerning a
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petition-filed by Billie Garde on behalf of the Concerned Citizens About Callaway and others.      The P'etitioner requested that the Commission suspend
             'the low-power-license for.Callaway Unit 1 pending an investigation of the
.             allegations set forth in the letter and the completion of any necessary reinspections of the plant as a result of problemsidentified during the I
investigation. The allegations concern primarily improper construction practices and other improper conduct by plant workers such as a drug or alcohol abuse,on site.
Upon consideration of the Petitioners' request, the staff has concluded that the Callaway facility has operated and may continue to operate without
[             endangering the public health and safety, and has thereby denied the Peti-tioners' request. The reasons for this decision are more fully explained in a " Director's: Decision under 10 CFR 2.206" (DD-85-07) issued today which is available for public inspection in the Comission's Public Document Room
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8505210391 e50517 3 Apocn o gon l :-..
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at 1717 H Street, N.W., Washington, D.C.          20555 and in the local public docu-ment room at the Fulton City Library, 709 Market Street, Fulton, Missouri 65251 and at the Olin Library of Washington University, Skinker and Lindell Boulevards, St. Louis, Missouri       63130.
A copy of the decision will be filed with the Secretary for Commission review in accordance with 10 CFR 2.206(c).          As provided in 10 CFR 2.206(c),
the decision will become the final action of the Commission 25 days after issuance, unless the Commission, on its own motion, takes review of the decision within that time.
Dated at Bethesda, Maryland, this 17th day of       flay    1985.
FOR THE NUCLEAR REGULATORY COMMISSION
                                                                /                    "
Harold R. Denton, Director Office of Nuclear Reactor Regulation N
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GOVERNMENT ACCOUNTADILIT( PROJECT                                          octxttco
        ~1555 Connecticut Avenue. N.W., Suite 202                                    N Woshington, D.C. 20036
        ,                                     28 September 1984                      (202)232-8550 84 OM -2 A9 d2 Honorable Nunzio Palladino, Chairman                  n.
Honorable James Asselstine, Commissioner Honorable Thomas Roberts, Commissioner Honorable Frederick Bernthal, Commissioner Honorable Lando Zeck, Commissioner              gnm r United States Nuclear Washington,           Regulatory Commissiopp]%'T NUMEER'mL FAC..f [7.
D.C. 20555                                                            .
Re:   Callaway Nuclear Power Plant, Unit 1                                '
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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.      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 local public interest and citizens groups seeking to ensure the                            l health and safety of their communities. The Citiz4n's Clinic is currently assisting several citizens groups in the Missouri area concerning the construction o'f the Callaway Nuclear Power Plant.
OnbehalfohtheConcernedCitizensAboutCallaway,anda number of present and former nuclear workers at the Callaway Nuclear Power Plant (CNPP), the Government Accountability Project l              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 appropriate re-inspection is performed to determine the extent of the problems raised by each allegation.
l l                    The Nuclear Regulatory Commission has a duty and a i              responsibility established by Congress to assure that the use of l              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 l              citizens can act when the citizens believe that the Nuclear Regulatory Commission has failed to honor its responsibilities.
Pursuant to 10 CFR 2.206 any person may request the Nuclear Regulatory Commission itself to take action as deemed appropriate to resolve unanswered questions about
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s 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 i              formerly been identified by the quality assurance program.
I 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 n            inaccessible. Nonetheless, it is critical that the extent of the il            problems be determined before the various parts of the plant become contaminated. Once lower power operation is underway, h               these hardware problems will be even les"s accessible and repair workwillbemorecostlyandgangerous.
The NRC's Region III has a history of some of the nuclear industry's worst problems: Midland, Marble Hill, Kerr-McGee Corp's Cimarron Plutonium Recycling Facility, Byron, and Zimmer.
These nuclearmanagement's to attract    power plants were crippled by'e attention     or to make too lateconomicaltoo little regulation 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 L                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 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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Callaway Nuclear Power Plant                      28 September 1984 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 power plants than.the occasional spot checks by NRC inspectors. NRC inspectors actually examine only_one to five percent of on-site construction. Thus, quality assurance is virtually left solely to the workers. For these reasons we
        ;  present.these allegations.
The following allegations have been complied from notarized affidavits by former workers. These allegations, gathered by GAP investigators during a six month investigation, reflect deficiencies in construction and quality control. The totallity
          ._of these deficiencies have serious implications regarding the
          -integrity of the managerial and administrative controls used to assure the safe operations of the Callaway NuclearrPower Plant.
: 1. Painters at Callaway have prepared thousands of welds in the Reactor Building for painting by-removing the rust-proofing from theiwelds. The rust-proofing was removed with grinders from these welds that had already been Quality Control inspected and approved. No measurements were made of the remaining weld metal or base metal. Since no re-inspection has been done, the quality and safety of thousands of welds in the Reactor Building is now indeterminate.
: 2. Welders have ground smooth the horizontal, the vertical ~and the floor panel welds of the Spent Fuel Pool, Transfer Canal and Cask Loading Pool. In the process', negligent welders removed weld metal and base metal.      As a result of this overgrinding, certain areas of these pools no longer meet thickness requirements. The integrity of the Spent Fuel Pool, Transfer Canal and Cask Loading Pool is questionable.
: 3. Furthermore, hasty and improper rework was done on the seam welds of the liner plates in the Spent Fuel Pool, Tran-sfer Canal, and Cask Loading Pool. These liner plates are defec-tive in that they are not exactly square. This defect made original _ welding difficult. The seam welds of the liner plates were reworked but because of time constraints, the welds were not sufficiently repaired.
                     '4. Weld metal joining the reinforcing ribs and the steel liner plates of the Containment Building has been eaten away by~ rust and corrosion. These welds located on the backside of.the steel liner plates were not rust-proofed. Corrosion covered the backside of these plates before they were encased in concrete.
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Callaway Nuclear Power Plant                        28 September 1984 Nuclear Regulatory Commission
: 5. Bad welds exist on pipehangers as well as on the embed plates that anchor the pipehangers.      These pipehangers and embeds are located near the f3,cor of the Reactor Building. They are difficult to reach due to the surrounding installed equip-ment.. The bad welds have excessive weld material, tiny ho es, and pockets 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 approved have been Quality Control inspected. Welds in difficult to reach areas, such as on unistruts, have been approved without the Quality Control inspector's examination.      There are also welds that have been approved without inspection located on the condensors in the Turbine Building.
: 7. Inexperienced and underqualified welders.were employed at Callaway. Union pipefitters and welders were not 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 a matter of weeks.              :
: 8. Furhhermore, the welder certification testing program allowed almost everyone who took the examination to pass.
Thus, the program permitted inadequate welders to weld safety related structures.
: 9. The welder certification testing program did not screen out these bad welders. It was apparent that it was set up
           'for the purpose of producing men to do the work rather than to risk slowing up production by withholding certification from bad welders. In fact, it was reported as common knowledge that the welding certification supervisor for several years would look the other way, and certify technically inadequate welders. He did this in exchange for the payment of bribe money. Workers who were unable to weld adequately graduated from this program.
: 10. Yet another technique used to pass welder-applicants was accomplished by allowing applicants to take the 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 as many as five times before an acceptable weld was produced.
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: 11. As a result of using this underqualified and inexperienced work force, much rework had to be done. The pipe hanger department suffered the most because the worst welders 4

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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 required by the' hanger department in later years.
                             ~ 12 . This mode of censtruction creates-many problems.
Once construction was complete, repair and rework was done on the lower. levels of the Control Building.two to three years later.
Some of the welds.could not be reached; some were covered with concrete. This rework weakens the metal because of the required reheating. The tensile strength is reduced and the metal becomes brittle.      In addition, the cost of each weld that has to be
               -reworked is doubled.
: 13.       Quality Control inspectors did not always maintain the necessary independence from the pressures of schedule and cost.- It was reported that. Quality Control inspectors would 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 impor6 ant 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.
: 15. Those Quality' Control personnel who attempted to be assertive in their positions have been subjected to
,              intimidation and harassment. It is reported that workers have dropped things from heights such'that the hardware dropped would land near the Quality Control inspectors. Quality Control inspectors have been splashed with concrete and with water, and i
one Quality Control inspector had his hand intentionally smashed with a vibrator by a workman.
: 16. Quality Control-issued " hold tags" often left i              workers idle for one or two days. ." Hold tags" indicate that L              there is a problem with the tagged item and all work on this item
[              should be stopped until the problem is resolved. Once the o              problem is resolved, a Quality Control inspector removes the' tag
[              and work can-continue on'the item. Often, a foreman or l-            . supervisor would eventually give the order to proceed with work L              and ignore the hold tags. Workers questioned the unexplained orders to proceed when the work had not been changed or been seen fixed. Either money was being wasted on non-problems or safety
              ' deficiencies.were being accepted.
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Callaway Nuclear Power Pladt                         28 September 1984
       . Nuclear Regulatory Commission
: 17. There was a shortage of Quality Control inspectors. One worker reports waiting six, ten hour days for a 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 related systems throughout the plant. Generic problems regarding the environmental qualification testing of this Class 1E electrical cable have been recognized and acknowledged by the NRC, Office of the Inspection and Enforcement. It is reported that this cable is literal,1y all over the plant.
: 19. Electrical cables were installed too early in construction operations. The cables have been exposed to the harsh environment of early construction and have been damaged during construction from hot metal and other elements thrown around during early construction.
: 20. Violations of electrical wire bend radius are reported. Eighty to eight-five percent of junction boxes are too 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. There are no protective cable jackets and static bleeder wires on ' cables feeding through the cabinets into the Control Room. Pr'otective cable jackets and half-wrapped, outside electrical interference deflector wire were removed in order to fit the cables through the undersized 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.
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 the required fire-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 6
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e-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 approximately one pound of reinforcing steel for every nine pounds of concrete.
: 26. Patchwork of the voids was very limited. The 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.
: 27. Defective bolts were used to install the embeds on concrete ceilings of the Control 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 to eight inches of water on the lower floor has been reported repeatedly. Possibly.there is debris clogging the pipes or the pipes are too small to handle the large volume of sater.
: 29. Pipehangers soiled with metal filings and dirt during the flood.of the Reactor Building on June 2, 1984 have not been. cleaned. These hangers were cleaned on their outer, easy to clean side, but were not cleaned inside the band which extends entirely around the pipe.                       The integrity of.the pipe will be jeopardized by these dirty hangers.
: 30. Construction drawings were not being updated and revised as necessary. For. instances, laborers cutting a trench to lay a pipe discovered a six-inch diameter pipe. There was no record of the pipe on the construction drawing.                                   The, identity of the pipe was unknown to the crew as well as to the supervisor.
: 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.
: 32. Poor construction resulted from engineering errors in 5005. construction drawings.                       5005 drawings were used for the installation of cable tray supports in the Control Building and the Auxiliary Building. As a result of the poor engineering, hangers were not centered properly on the embeds. The non-conformance report attributed the poor construction to craft error. .In fact, the error was due to the incorrect drawings 7
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Callaway Nuclear Power Plant                     28 September 1984 Nuclear Regulatory Commission issued by engineers. Quality Control approved this inaccurate 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.
: 34. The reliability of the on-site laboratory is challenged by inaccurate test results. During the flood of the Reactor Building of June 2, 1984 , fiberglass insulating blankets were soaked with borated water. Eighty-five blankets were removed and sent to the on-site laboratory to be tested for damage caused by the caustic acid. The on-site laboratory concluded that'the borated water soaked blankets did not need to be replaced. The strength of the blankets had in fact deteriorated such that they could be shredded by hand. The         .
blankets were ultimately found to be defect,1ve by the pressure of the workers and were replaced.
: 35. DosimeterswerbnotwornbyworkersintheReactor Building while fu41 was being loaded in the Reactor Core. SNUPPS Radiological Emergency Response Plan requires'that all personnel entering the controlled areas be issued thermoluminescent dosimeter badges. Most workers in the Reactor Building had not been issuedibadges nor had they been given the necessary 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 i               was administered. On July 4, 1984, there was such an act.
l               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 t
                "UE   -Have a nice day".
                         .. 37. The psychological test failed as a screen for employees, but served as a means of harassment. Workers were i
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

Callaway Nuclear Power Plant                      28 September 1984 Nuclear Regulatory Commission areas, that is, behind the fence.      Those who refused the test faced certain termination for lackHof 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.
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
        -disgrace to the construction industry.
: 40. There have been enormous amounts of cost overruns at the plant. There were excessive amounts of manpower on site.
Approximately 200 electricians were hired in late 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 demanding work schedule and missed a day of work were terminated.
A medical excuse, a death in ,the immediate family or a call to jury duty were the only acceptable excuses for any absence.
Bogus. medical excuses were available on site for three dollars.
Less work was done' during this manpower overload than previously_
in an eight hour day.
: 41. People were idle on the job site. Some slept at work; a few brought in alarm clocks to wake them up in time to go home.
: 42. Illegal drugs, alcohol, gambling and prostitution could be-found on the job site. In February of 1984,.seven Quality Control employees were fired for alleged drug use.
Please refer to the attached articles from the Kingdom Daily Star-Gazette. The Government Accountability would like information about the drug-related terminations and related developments at the Callaway Nuclear Power Plant, including but not limited to, the attached list of questions.
: 43. Workers were almost encouraged not to accomplish too much too quickly. One witness reports that he was physically threatened at work for working too hard. He told his foreman and it was taken as a joke. Other workers report that crews were eventually split up if they were working too fast.
: 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

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:                 Callaway Nuclear Power Plant                         28 September 1984
           .               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 require 6 for any job on site. Sometimes a worker wou'Id be idle for one or two days waiting for-such an assignment.       In the meantime,-the worker would appearfto be busy-or would.just sit'around until he was issued a work assignment.
4 5 .-   Cost overruns can also be attributed to the high i                       volume:of discarded materials. .For instance, one individual reports that over the' course of his employment as a dump truck driver, he dumped.several thousand pounds of welding rods.
Welding rods are very expensive; many companies control the rods 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 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
;                      -pounds in the barrel provided on site.
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: 46.      Barrels were provided on site for disposal.of welding rods. The barrels were filled with weldin@ rod stubs as well as unused welding rods. These barrels were later dumped in on-site landfills. Welding r'ods 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.
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47'. Many acts of sabotage-have also been reported.
The NRC, in its latest inspection reports, admits to eleven acts of malicious mischief regarding the destruction of electrical cables. Workers have found various items in pipes such as-l-                     scraps of steel wire, electrical cables, two by four inch wooden L                   ~ boards,'and welding rods. These pipes had to be cut open in
!                      order to remove the material.           It was generally understood by workers that these acts were done deliberately to slow up work l                      production.
: 48.       Although these construction and Quality Assurance i                    ~ problems would be serious under any circumstances, they are made l                    -more for the following reason.            The Nuclear Regulatory u                  : Commission, Region III has been violating its own rule regarding i                      on-site inspections. The construction inspection offices of the l                      NRC profess that all on site inspections by the NRC are to be
,                      unannounced to personnel on site.           Quite the contrary, many workers.have reported that employees on all levels were pre-notified by their foreman or general foreman of upcoming NRC
,                      inspections. Several days before the inspection, the job site l                      would be prepared for the NRC. Workers, who had not been l
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JCallaway 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 an,d a plan for resolving these open issues.          With the evi' Bence of recurring nature of quality assurance problems at this plant, a piece meal approach is inappropriate.       We look forward to your response.
Sincerely, f'
f&
Michele Varricchio Staff Associate M        W Billie Garde Director of Citizens Clinic
            -CC:
               ,NRC, Region III Missouri Public Service Commission-I 11

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i                                                                    ATTACHMENT
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* GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)
Please refer to the attached a'rticles frcm 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 enfo'rcement agency (or agencies) have been notified by Applicants'or its Contractors regarding this matter?
: 9. What, if any,~1aw enforcement agency (or agencies) have been involved in the investigation?
: 10. Has the investigation by law enforcement agency (or agencies) been completed.
: 11. If the investigation by law enforcement agency (or agencies) has not been completed, when is it expected to be completed?
: 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 be contacted.
: 13. How many (total) employees have been investigated to date by
                   - Applicants or its Contractors?
: 14. How; many employees have Applicants (or others) investigated to date who are with the following organizations:
(a)   Plant Operations; (b)   Quality Assurance (onsite);
(c)   Quality Assurance (other);

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* 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 ControlsSupervision or Management - .ASME; (f) Quality-Control Inspectors -- Nor.-ASME; (g) Quality-Control Inspectors -- ASME;
                                     .(h) Engineering; (i) _ Engineering Supervision or Management;-
(j) Construction; (k)    Construction Supervision or_ Management;
                                     -(l)     Building. Management;
                                     .(m)     Project Control / Procurement; (n) " Project Control / Procurement Supervision or Management; E                                      (o)    Project Management Control; (p)    Project Management Control Supervision or Management; (q)    Document _ Control Center;
_(r)     Document Control (Satellites);                                                                         :
(s)    Document Control (Other)
(t)_   Personnel or Employment personnel;:
                                     -(u); Personnel'or Employment Supervision or Management; (v) Security personnel; (w)    Security Supervision or Management;                                                                    ,
(x) Vendor personnel;-                                            "
(y) Vendor Supervision or Management;                                         '
: 15. Have all'of the. employees who were/are under. suspicion 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 y                                     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 employees been asked to take L                                     lie detector tests?
19.1What' form has this investigation take (personal interviews l                                     by-Applicants or their agents, personal interviews by law
:                                  -enforcement officials, written questions, lie detector L
                                   -tests, discussions with other employees, etc.) ? Give
['                                    specific-details, including what specific actions Applicants or its' Contractors have taken to confirm whether or not specific individuals have been involved in drug-related
;                                  -activities.
l                           R20.-What specific drugs have been found onsite?-
21.-If different from above, what specific drugs have been identified by employees (or others) as having been used p;                                    onsite?
2

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                                                                                    \
t GAP REQUESTS INFORMATION REGARDING' DRUG-RELATED TERMINATIONS            l AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)
: 22. (a)        Have Applicants' or others' investigations indicated or confirmed (specify which) that employees have used or have.been using drbgs onsite?
(b)     If the answer to (a) is yes, how many employees have been indicated or confirmed to have used drugs onsite?
Supply the total number , and answer for each organization listed in 14. preceding.
: 23. Have1 Applicants' or others' investigations indicated or con-firmed (specify'which) that drugs have been sold onsite by employees of Applicants or their agents (to include con-tractors, sub-contractors, vendors, etc.)?
: 24. Have Applicants' or others' investigations indicated or confirmed (specify which) that drugs are still being sold onsite?
: 25. What specific drugs have been identified by employees or others as have been sold onsite?
: 26. (a)        Have Applicants' or others' investigations indicated or confirmed (specify which) that anyone other than employees (of Applicsnts or their agents) have sold drugs onsite?
                  '(b )   If the answer to (a) is yes, supply complete details.
: 27. Have Applicants made any specific efforts to ascertain whether or not supervisory, or middle or upper management have been involved in:
(a)    taking drugs at CNPP?
(b)    selling drugs at CNPP?
: 28. If the answer to 27. is yes, supply specific details of what efforts Applicants or its Contractors have made.
: 29. (a)        Have Applicants or its Contractors made any effort to determine whether or not anyone in a supervisory position or in middle or upper management has ever
                ,         attempted to force or coerce other employees to take drugs?
(b)  .If the answer to (a) is no, why haven't they?
(c)    If the answer to (a) is no, do they have any plans to do so?
3
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p 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 each employee terminated if it was determined that he/she:
(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?
(g)    had ever sold drugs onsite?
(h)    had a conviction record for selling drugst (i)    had ever sold drugs o'nsite?
(j)    hadeverhsolddrugsoffsitwhichmayhavehadaneffect 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 all employees suspected of taking or selling drugs work 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.
4

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       . . GAP REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)
(c)   'If the. answer to (a) is no, give specific details of of Applicants' plans pnd the rationale for their~ actions in this regard.
(d)    If'the answer ^to (a) is yes:
(i)  list the specific buildings which have not yet been reinspected.
(ii) do Applicants plan-to reinspect the specific build-ings listed in . (1) 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) list the specific systems which have not yet been inspected.
(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 completed,7 (e)    If part ,of-the rationale for Applicants' decisions regarding reinspections is because of redundant and
                           ' independent inspections:
(i)  what' specific actions have Applicants taken to determine whether or not (for example) more than one QC inspector suspected of drug use or sale worked in one particular area or on one part-icular system? 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 Commission (NRC) regarding the drug-related
                         '; terminations and related developments at CNPP?
\
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    . o a
o        GAP. REQUESTS INFORMATION REGARDING DRUG-RELATED TERMINATIONS AND RELATED DEVELOPMENT AT CALLAWAY NUCLEAR POWER PLANT (CNPP)
(b)   If the answer to (a) is yes , supply the following information:
  ~
(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.
l 0
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    !b Vol.107, No. 277 DE
                                                                   - -      h.            , [ k m_           '
Saturday, April 28,1934
                                                                                                                                                     'k AdSD bus s
                                                                                                                                                                                                                            . Twenty Cents 12 pages U
    ! Fired employee files suit against nuke planf5s priiscelatrador ally hard to say what t Daniel officials) were told the others they had admitted drug chemicals when the plant begins operatind.                                         After morr than 12 anxious hours in the By MIKE ItEll1Y                               ~domg." Ilammock s.sid. "I guess they'd              usage at work to Damel officials, Sunder. As a technician for the quahty control divi. trailer, Danici othrials tegan inhviduti m-celal to the                               heard they had a priblem and figured the mcycr ar.d llammock said.                                       sion. Surviermeyer. 22, was pat *: C 15 an terviews. Stmdenncycr was the fourth rpes.
mgdom Daily Sun 4azette                      sooner they cuidd get some scapegoats up               "Itut af there was a drug probicm, they hour to keep records of those inspections.                              tumed and the fourth sugw nrht One of seven construction employees dis. front  and  humihate   them,    the souner the  should      have  handled  18 amither   way  " Sun.        Sundermeyer figured something was                             "I asked them if they cou:d show me why missed in Febnaary fran the Callaway Problem would disappear."                                      dermeyer      said. "They should   have brarrht    amiss Jan. 31. when       secunty officers   arut   a   they  were domg this to me." she said. "They fotmly nuclear poser plant for suspected          he two also take issue with Daniel's as-          the pohee department or somebody to actu- German shepherd barged mio the cramped, said they had mme substanual ev@nce, mirijuana um has ided 41.025,000 lawsuit scrtion that all work performed by the sev&n ally imd where the probiern is, instead of traller-home office 6he shared with llam- bid they wouldn't show me anythmg."
against her former emplo3cr.                    was remspected in February.                 .
Just pointing' at people and jeopardizing mock and about 25 others.                             ,          .         Daniel officials asked flammcek to take a .
CarneSundermeyer former plant tech-            "I've looked at miles of pipe there and - their future.                                                  The team had tried te sniff out contraband blood lot and a pdygrcph test. Il= re-Eician, charges that aniel International done documentation by the hundrrds," said '                   Wagoner confirmed the, firings in I"cbru.         there only fair days earlier. Both times, fussi Corp. unlawfully detained her for 12 lunirs llammock, who now works at a Nebraska ary after the Callaway Cohnty Sheriff's De.                            scarchers came tqi empty. Yet thay re-                          Daniel officials tedd him they had piado-durmg an investigation of dnig use among nuclear rJant. "There is no way they could                              launched an investigation into the . turned for a third search Fcb. 2.               ..               fraphs of it.ammock :smg dme,s at the '
employees, fired her without cause Feb. I have looked at it all m that period of time.                       nt.     .s                                    "This time, they held everytmdy in the plant. tlammock aded to see the photos.
and latried lxv in statements to employd,, .1 hey wouldn't have had a prayer." . .Mj, At-the tim.',' offkers expressed cercern trailer; they v onid not let.mytely l~ve,'t - tut offici-Is refu-rJ. . .. . , . .                                                   ,,
ment security dificials and the media.            Daniel officials have' declined comment thal drugs may have becn seized at the plant r ' St:ndcrmeyer said.*Each of us hadhq:4 "" flotherrestr:pcalmlpend;ng"furth rin ,
It      s Thurstay had placed the amount on the charges. De Greenville, S C.-based               without the knowledge of law enforcement our purses, empty our pockets."                                           vestigathm." On Feb. 8. D.tniel p vple that         rmeyer would be asking in her firm has consisterdly refused to ldentify the offsetals. Several days later, the drpartment                     After the scards wo kers weir taken one called item back in and fired them. They suit at nearly 12 million flowever, a spokes- fared workers.                         .
dropped the investigation when officials by nne into a separate room armi eiucstional.                             were told their allen ed drug uw wouli sud a
man for the Cole Gamty clerk said Fnday           Daniel is the prime contractor for the from Daniel and Union Flectric signed Otheiats askrd llammock vhether he harf. stum upon their renols as lung.9 they kept that the total amount in the suit was $2.85 bilhon nuclear power plant tring budt sworn statements saying drugs were not ever used dargs or rcen drugs being uscal at 4'Het, 31.025.000.                             .       near Ftdton by Union Electrie Co. of St.            found at the plant, according io Oief Depu. the plant. Ilammock rephed no.
armicrmeyer, of Jefferson Cit , is repre- IAuis.                        1                         ty Ken thshop.                                         Surutcrmeyer was aunt only ifshe'd scen                       Hut Dum sented by attorney llebert fly er, also of        On Feb. 21. Callaway project manager , llammock and Sundes meycr said they did others partaking of controlled substances. ta n farm,k rmever chart? s her record h..ss Jefferson Cd . TI:e sidt was ided in Cole C.C. W              r said Daniel officials had de-       not sw drugs used or confiscaint at the She also said "no.=                               g                        the dbmissals and by a v ntlen statement
*' Cotmty 0t         Court,                        termine througt: " corroborated witnesses plant. llamnmck added. however, that                                                                                         Danici sent to the ICmployment Fecurity Gar) liammock one of sit quality control and admissions ** of wmc employers that offers to share marijuana )<4nts were com-                              The events of the next day, Feh. 3, kd to Scryice of Cole Coimfy. Accordmg in the invrstus , futd her alleged drug use at the seven workers were te,mg drugs.                         num anuwig the several hiuntral iguahty             Sundernm s charge d md.witd cletain- lau. suit, the estatenwnt revt %rra Sun-Pl ant, has also retained itpler and mteixts       in separate interviews carher this month,        control employees, part af a 3,5mmember snnd Wien they anivemwk ana.nb dermeyer was charent hir masci..h. . .
to file a smylar synt_later this spnng.         Sunderneyer and llanmmck saki some of ct,astruction crew.                                                a supervisor awaited item and five others remit of an imc4tgation."
Iloth former workers mandain they were the seven had probatify used dnigs. Just be-                 As a quality nmtrol inspector,2Sycarold amt ordered thern to stay put.                                            Sunilctmeycr is collecting $105 a vitk in victmis of rarutom firmgs deugncd to deter fore the firmgs, whde lhe wven were closet-              Ilammock was pak! $12 90 an hour in inspect            **Execpt to go to the hathroorn, rudax!y un'mploymcid tenefits and teachmg acro-
, other employees from using drugs. "It's ro-      ed together m a plant trader, two employecs . Pipes that will carry air, water ami atlyer. was to D ove,"llammoct(sakt._                                              bics part-time.

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By JOHN E. YEAGER Staff uTiter 1m        atIon.
Wagener said the drug 1 vestiga.
Seven emp! ess in Danie! Inter- tion is cou complete, but the cone national's qukity eantro! division - Fanyhasano gomgdmgasannus ro                 =
some of them inspectors, were fired fo b                a             ' Pno*$8-recently from work at the Callaway Nuclear Plant for suspected mart- harmful to them, tret p:rticulativ Juana use, accoring to C.C. Wa- harmful to usin oursituadon (as the gener, Daniel's project manager.          contractorof a nuclearplant).We in Danfe! Inteata'! ant! is the prime supervision kup our eyes en 24 contractor for the nuclear plant, ye ue har cf mm smeum which is nearbg ccmpletion near           "#F " *I "" " ' ""
Reform                                    m a m puun a Wagener said Monday that the              Duri:gtheinvestiga!icr.,Wagener employees were fired for suspected said,the companylooked at people's dmg use away from the plant, and ud habus a-MW M q that on-site dmguse does not appear tatiens and s6cial hfe. He cecimed to to be ' widespread. No drugs were e.maa or, spes of me bmu-foted at the plant, he added. ,           gation, sayir.g "there could be some
                                   .                        . legal consequences come from a!!
                          "As far as we can.. . determine, this and it's best not to go into detail there has been very htue use on the . at this time."
job.We have had a repert that there ' Wagoner did say that, in general, wassomes!ip.tusagec thejoband " stat ue do is lock fer recp;e with mehavedeterminedthatsomeof the persosahty prette=s cr benavict peopleinvolved useit away from the problems - people ubo don't want job._We have chem the iastinn to work of who can't get alor.g with
    ,                 recorcs and c ecxed the actualwork the boss. We move these pecple c:
of t.ne mswtm an: r.ae rec ro_            doult the road regularly because we
                     ~fau'tv work," Wagoner said. He de.        don't need the kind of problems they cimed to say just how many of the - coc!d bring to the job. With a ] the fired employees were inspectors or state and federal agencies to protect to charactertze the exact nature of workers' rights it's better to find le-their' work, other than to note they gitimate ways of terminating a were " general construction inspec- worker before he gets to be a prob-tors."                                    lem."
* In 1t+ vears Waeoner has been Wagoner said the NuclearRegula-        ern* w.ager at ca amay oniv tory Commission is aware ci the one other enlevec W bedhW drug invesugation and the action          fe =w'ad am r.<e. he said.
taken by Daniel. "Dev know that           .*That p'erson was usmg marijuana wehavecheckedtheworkof thepeo" on thejob and be had other personal ele mvolva In fact,m this bus: ness problems. Hopefully, we catch them you have mspectors inspecting in-          (drug users) when they have behav-sputors and inspectors insvetkg for problems, when their mind is not those inspectors. And the NItC has right. We probably have more peo-insputers insputing insputors." pie showinr un uith haneove s than be said.                                  with drug probiems, and that's not Mike Cleary, a Union Electric acceptable either. I don't need any.
publici formationofficer,saidMon. thbg like that on my project," he day that Daniel officials brought the said.
matter to the utility's attention "two       Accordingto Wagoner,druguse at or three weeks ago" and told corn- the Callaway plant is not as severe
              -       pany officials of suspected drug use as it is at other plants where he has on the Callaway project. "UE told worked. Wagoner came to Callaway Danieltoinvestigate the matter and from the LC. Summer Nuclear
                    , they have been conducting an inves. Power Plant in South Carolina.
tigation since that time.1 con't know        "I've had a lot less reported here what they found, if anything. It than other places. In some of those h: c:'t r,c:: 2:7 repcrt pat," he etherplaces.IYe evenhad to useim-said.                                     dercover agents, but that has not No upper-level UE officials were been necessary here. I've also had available for comment Monday be-                 le tell me that drue ute here k * -g cause of the Presidents' Day holl-         n' = "+ i' melo be.
day. Capt. C.F. Holloway of the Call.      "We reahze tnat drug useis a part away County Sheriff's Department of society and that se are a slice of said on!y that the riewment had that pie. We continue to try and pre-
_heardrumescf aeurmyectiranon vent its use on the project and do ev.
at the olant but knew of no omgs er} thing me can without infrmgmg being found.He also said the depart- on a person's rights," he said.
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