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Responds to to President Reagan Re Substandard Piping Fixtures,Unqualified Inspector Concern & Thoroughness of Licensee Insp to Determine Counterfeit Bolts.Nrc Issued NRC Bulletin 88-005 Concerning Problem
	ML20155E569
Person / Time
Site:	Seabrook
Issue date:	10/04/1988
From:	Murley T; Office of Nuclear Reactor Regulation
To:	Comley S; WE THE PEOPLE OF THE UNITED STATES (WE THE PEOPLE
Shared Package
ML20155E573	List: ML20155E569; ML20155E585; ML20155E598; ML20155E609; ML20155E620; ML20155E632; ML20155E650;
References
	IEB-87-002, IEB-87-2, IEB-88-055, IEB-88-55, NUDOCS 8810120345
	Download: ML20155E569 (13)
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Mr. Stephen B. Comley Executive Director We The People of the United States Box 277 Rowley, Massachusetts 01969

Dear Mr. Comley:

Your letter of August 15, 1988, to President Ronald Reagan expressing your concerns regarding Seabrook Station has been referred to me for response.

I share your concern about the potential use of substandard piping fixtures at nuclear power facilities. Therefore, NRC issued NRC Bulletin No. 88-05 and Supplements 1 and 2 thereto (copies enclosed) to infom applicants and licensees of this potential problem. The Seabrook Station licensee reviewed the Seabrook Station construction records in accordance with the requirements of the bulletin and supplements and detemined that 369 suspect fixtures were installed in the Seabrook Unit 1 plant. A report of the licensee's review was submitted to NRC i on August 25, 1988, and is currently being reviewed by the NRC staff. The i applicant must demonstrate to the satisfaction of the NRC staff that all of

hese suspect fixtures provide an acceptable level of quality and safety.

A second concern expressed in your letter was that an unqualified inspector had been used at Seabrook Station. An Authorized Nuclear Inspector (ANI) trainee was assigned to the Seabrook Station from May to December 1985. The NRC review detemined that the ANI trainee perfomed assignments in accordance with his assigned training program and that qualified ANIS had evaluated and '

monitored his training, progress, and inspection work. The NRC concluded that there was neither a noncompliance with the American Society of Mechanical Engineers ;

Code nor evidence of wrongdoing.

You also expressed a concern regardino the thoroughness of the licensee's inspection to detemine that "counterfeit" bolts were not built into Seabrook Station. The licensee's initial inspection, perfomed in response to NRC Bulletin No. 87-02 (copy enclosed), detemined that the fasteners used in .

Seabrook Station were acceptable. After that initial inspection, NRC issued ,

Supplements 1 and 2 (copies enclosed) to NRC Bulletin No. 87-02. These !

supplements requested and then clarified the request for additional infomation !

on the suppliers and manufacturers from whom the subject fasteners may have i

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Mr. Stephen B. Comley 2 w been purchased. The NRC reviewed the information submitted by the Seabrook Station licensee in response to Supplenents 1 and 2 to NRC Bulletin No. 87-02 and concluded that the actions taken by the licensee were both complete and ,

adequate and that the fasteners installed in Seabrook Station are acceptable for their intended uses. P Thank you for your interest in these matters.

Sincerely, Cristnat e ;;;oa bg I rank J. Miraglia,'

c: ( 1homas E. Murley, Director t Office of Nuclear Reactor Regulation t

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Enclosures:

L As stated i bCC:

Agency Liaison Room 91

The White House ;

J Washington, DC 20500 j

See previous concurrence ;

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- NRC8 88-05 UNITED STATES NUCLEAR REGULATORY COPNIS$!0N

. 0FFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 Pay 6,1988 I I

l l NRC BULLETIN N0. 88-05: NONCONFORMING MATERIALS SUPPLIED BY PIPING

! SUPPLIES INC. AT FOLS0M, NEW JERSEY AND WEST l 4 JERSEYMINUFACTURINGCOMPANYATWILLIAMST0WN, i l NEW JERSEY

Addressees

l All holders of operating licenses or construction pemits for nuclear power reactors, f

Puroose:

The purpose of this bulletin is to require that licensees submit infomation I regarding materials supplied by Piping Supplies, Incor (PSI) at Folsom, i

[

A New Jersey and West Jersey Manufacturin Jersey and to request thattake licensees 1)g Company that materials (WJM)p at W1111amstowr., New actions to assure .

l comply with ASME Code and design specification requirements or are suitable 1 for their intended service, or 2) replace such materials.

l Description of Circumstances:

I, The NRC has obtained copies of certified material test reports (CMTRs) for material su,tplied by PS! and WJM that contain false infomation about material

]

supplied to the nuclear industry. A number of CMTRs were apparently used to I '

certify that consnercial-grade, foreign steel meets the requirements of ASME Code Section !!!, Subarticle NCA-3800, by using a domestic forging company's letterhead. There was no evidence that PSI or WJM performed or had a subcon-tractor perfom the testing required by Section !!! to upgrade i5e consercially l produced steel for these falsified CMTRs. The information avaliable to date

indicates that WJM started supplying ASME Code components to the nuclear

! industry in 1976, both directly as well as through intemediaries, and that i

PSI started supplying ASME Code components to the nuclear industry directly

and threugh intermediaries in 1985. In addition, WJM held an ASME Quality System Certificate (QSC-385) as a mterial manufacturer from November 30, 1979

to November 30, 1985, i The NPC has concluded that there are potential generic safety implications at i facilities that either have received direct shipment of materials furnished by

] PSIorWJM(i.e.,pipefittingsandflanges)orreceivedpipingsubtssemblies and other components ' rem holders of ASME Certificates of Author 1 ration or

( other subcor. tractors which incorporated materials supplied by PSI or WJM.

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NRCB 88-05 May 6, 1988 Page 2 of 4 Actions Requested:

1. Review purchasing records for your facility and determine whether any WJM-or PSI-supplied ASME Code or ASTM materials have been furnished to your facility. The lists of purchasing and receiving companies given in Attachments 1 and 2 have been developed through the NRC's partial review of PSI and WJM documents. It is emphasized that the NRC has not reviewed all documents; therefore, the review of records should not be limited to the companies on these lists. The records review for PSI-supplied material should cover the period since January 1,1985. The WP review should cover the period since January 1,1976

2. For ASME Code and ASTM materials furnished by PSI or WJF that am either not yet installad in safety-related systems at your facility or are in-stalled in safety-related systems of plants under construction, the followin (perform action a and either action b or c) g artions are requested:

a. Provide a list of WJM- and PSI-supplied materials that are found not to be in conformance with the applicable code requirements or procure-ment specifications and identify the applications in which these materials are used or will be used. Include the material specifi-cation, the nature of the component (e.g., pipe flange), size and pressure rating; also indicate the chain of purchase, and either

b. Take actions that provide assurance that all received materials comply with ASME Code Section III, ASTM, and applicable procurement specifica-tion requirements, or that demonstrate that such materials am suitable for the interded service. For example, this program should inc hde specific verification that austenitic stainless steels have been received in a non-sensitized condition, or, ,

c. Replace all questionable fittings and flanges with materials that have been manufactured in full compliance with ASME Code Section !!!, ASTP, and the applicable procurement specification reouirements.

3. For ASME Code and ASIN materials furnished by WJM or PSI already installed in safety-related systems in operating plants, the following actions are requested:

a. Provide a list of the WJM- and PSI-supplied materials that are found not to be in conformance with the applicable code requirements or pro-curement specifications and identify the applications in which the '

materials are used. Include the material specification, the nature of the component (e.g., pipe flar ge), size, and pressure rating; also indicate the chain of purchase.

b. Take actions requested in 2b or 2c above. However, an evaluation should be undertaken prior to replacing questienable material in accordance with 2c above that considers the occupational radiation

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NRCB 88-05 May 6, 1988

( Page 3 of 4 exposure that would be received during the replacement process. This evaluation should be considered in developing the method and timing of material replacements,

c. Document and maintain for inspection a basis for continued plant operation if the procram requested in item 3b has not been completed within 120 days of the date of receipt of this bulletin.

4 For any PSI- or WJM-supplied materials having suspect CMTRs and used in systems that are not safety-related, take actions comensurate with the function to be performed.

~

5. Maintain for inspection the documentation of the specific actions taken for the identified materials.

6 For operating plants, all scheduled actions should be completed before a restart from the next major outage starting after 180 days from the date of receipt of this bulletin, For plants under construction all scheduled actions and the reporting required by 2 below should be completed prior J to the planned fuel load date. If any addressee cannot meet this schedule, they should justify to the NRC their proposed alternative schedule.

Reporting Requirements:

1. Provide a written report within 120 days of the date of receipt of this bulletin that either: l

a. States that no WJM- or PSI-supplied materials have been furnished for your facility for use in safety-related systems, if such is the case, j or 1 l

b. Provides the information requested in items 2a and 3a above that I indicates which materials have been found not to be in conformance l

. with the applicable code requirements or procurement specifications, confirms completion of other actions requested ir, items 2b or c. 3b and 4, and provides a schedule for coepleting any remaining actions.

2. Confirmation of completion of all scheduled actions shall be submitted to the NRC within 60 days of completion for operating plants and prior to the fuel load date for plants under construction.

, The written reports, required above, shall be addressed to the U.S. Nuclear Regulatory Comission ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affinnation under the provisions of Section 182a, Atomic Energy

Act of 1954, as amended. In addition, a copy shall be submitted to the appro-

priate Regional Administrator. -

( This requirement for information was approved by the Office of Management and Budget under clearance number 3150-0011.

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NRCB 88-05 May 6, 1988 Page 4 of 4 If you have any questions regarding this matter, please contact one of the technical contacts listed below or the Regional Adninistrator of the appro-priate NRC Regional Office.

r

'Tharles E. CRossi,%

Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Ray C111mberg, NRR l (301)492-3220 ,

i Ed Baker, NRR (301) 492-3221 i l

Attachments:

1. Table 1 - Known and Intended Recipients of Carbon Steel Materials furnished by PSI or WJM

2. Table 2 - Known and Intended Recipients of Stainless Steel Materials furnished by PSI or WJM

3. List of Recently Issued NRC Bulletins i

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Attachment I l NRCB 88-05 r May 6, 1988 Page 1 of 2

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TABLE 1 - KNOWN AND INTENDED RECIPIENTS OF CARBON STEEL MATERIALS FURNISHED BY PSI AND K1M Purchaser Receiving Company Nuclev Plant (if known)

Padnor Alloys Inc. Bechtel Power Corp. Pilgrim Capitol Pipe & Steel Bechtel Power Corp. Midland Pullman Power Products Pullman Power Products Palo Verde Pull.r.an Power Products Daniel Wolf Creek Pullman Power Products Cleveland Electric Perry Pullman Power Pr'sducts Bechtel Power Corp. South Texas Pullman Power Products Pullman Power San Onofre Pullman Power Products Pullman Power Vogtle Tyler Davison Bechtel Power Corp. Grand Gulf .

Osborne Brothers Welding Supply General Electric Perry HUB Incorporated Duke M er Oconee HUB Incorporated Bechtel Power Corp. Arkansas HUB Incorporated Bechtel Power Corp. WNP 2 Chicago Tube & Iron Omaha Public Power Fort Calhoun

, District

( Chicago Tube & Iron Comonwealth Edison Braidwood Chicago Tube & Iron Cherne Construction Co. Marble Hill 1 Chicago Tube & Iron Northern States Power --------- l Chiccgo Tube & Iron Consumer Power Palisades Dravo Corp. Dravo Corp. Seabrook l Joliet Yalves, Inc. Joliet Valves Inc. - - - ~ ~ - - 1 PcJunkin Bechtel Power Corp. San Onofre l Guyon Alloys Babcock & Wilcox ---------

ITT Grinnell ITT Grinnell --------

Guyon Alloys, Inc. Bechtel Power Corp. Limerick Guyon Alloys. Inc. Northeast Nuclear Energy Millstone Compar.y Guyon Alloys Inc. Bechtel c/o PP&L Susquehanna Guyon Alloys, Inc. Duke Power Catawba Guyon Alloys, Inc. Bechtel Power Corp. Hope Creek Guyon Alloy;, Inc. WNP-2 1 Guyon Alloys. Inc. Carolina Power & Light Rrunswick l Guyon Alloys. Inc. Baldwin Associates Clinton !

Guyon Alloys Inc. South Carolina Electric Y.C. Sumer 1 4

and Gas l Guyon Alloys Inc. Carolina Power & Light Shearon Harris Guyon Alloys, Inc. Gulf States River Rend Bellows ---------

! American Standard American Standard ---------

Louis P. Canuso Bechtel/Public Service Hope Creek i

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Attachment 1 NRCB 88-05 ,

May 6, 1988 Page 2 of 2 l

TABLE 1 - KNOWN AND INTENDED RECIPIENTS OF CARBON STEEL MATERIALS FURNISHED BY PSI AND WJM (continued)

Purchaser Receiving Comoany Nuclear Plant (if known)

Capitol Pipe 8 Steel Bechtel Hope Creek Gulfalloy Bechtel Power Corp. Palo Verde Public Service Electric and Gas PSE&G Sales.

Conax Conax Consolidated Power

Rechtel Power South Texas Consolidated Power

Duke Fower McGuire Consolidated Power

Boston Edison Pilgrim Consolidated Power

Niagara ".ohawk Nine Mile Point Consolidated Power

Philadelphia Electric Limerick Louis P. Canuso Bechtel Corp. Hope Creek Dubose Toledo Edison Davis-Besse Dubose Florida Power Crystal River Sequoyah Dubose Dubose TVA TVA Watts Bar . ,- )

Dubose PP&L Susquehanna -

Dubose SMUD Rancho Seco Dubose Rochester Gas & Electric Ginna Dubose Duke Power Oconte Dubose Power Authority State FitzPatrick of N.Y.

. Dubose South Carolina Electric ---------

l and Gas l

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Consolidated Power is also known as Consolidated Piping and Supply located in Bimingham, Alabama, Furlong, Pa., and Charlotte, N.C.

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( Attachment 2 NRCB 88-05 l 4 May 6, 1988 Page 1 of 1 TAPLE 2 - KNOWN AND INTENDED RECIPIENTS OF STAINLESS STEEL MATERIALS FURNISHED BY PS! AND IIJH Purchaser Receiving Company Nuclear Plant (if kncwn)

HUB Incorporated Bechtel Power Corp. Limerick !

Radnor Alloys Radnor Alloys ---------

Pullman Power Products Pullman Power ---------

Dravo Corp. nravo Corp. Seabrook Louis P. Canuso, Inc. Philadephia Electric Peach Bottom L. P. Canuso Inc. Rechtel Power Corp. ---------

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poner reetters.

65.C3 Detee-0sereted Valve Cassee 4/P?/M All heleers of Re i s petement I mese tetteces During Plant se cps for tues.

Treps' eats Due to lagre sser Switch lettlegs 87 02 Festeave festisq to efff/90 All twiders of OLt

$4plement 1 Setermine Ceaforusate ee cps fee outleer with Aeolitable %terial peser feetters, fpecificattees

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M.02 es pidly Propeteting Fettgue t/1/9s all holders of R s Cretts in Steen Ge*erster er cps for W.desigwd Twtel est16tP M P 794Cters w*th stees ps.oretors beving carten steel swooert plates.

48 01 Defects te w ittn e esse t/l/80 All helters of OLt Cirevit Seesters et cps fee outleet poner rootters.

4'.C2 Festenee testies to 11/6/87 All helters of 04:

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CL e OperetfP9 Lite *se CP e Construction Pereit UNITED STATES ,,%e 'eln'iTO,e i wiec j NUCLEAR REGULATORY COMMISc!ON ,

WASHINGTON, D.C. 20555 ,ee.,n i,e e e, 08FICIAL BUSWISS PENALTY FOR PRIVATE V58. 4300

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OMB No.: 3150-0011 NRCB 88-05, Supplement 1 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 June 15, 1988 NRC BULLETIN NO. 88-05, SUPPLEMENT 1: NONCONFORMING MATERIALS SUPPLIED BY PIPING SUPPLIES, INC. AT FOLSOM, NEW JERSEY AND WEST JERSEY MANUFACTURING COMPANY AT WILLIWSTOWN, NEW 1ERSEY Addressees: ,

All holders of operating licenses or construction pennits for nuclear power reactors.

Purpose:

The purpose of this supplement is to 1) provide additional infonnation con-cerning material supplied by Pipin Jersey Manufacturing Company, 2) (WJM)g reduce Supplies, Incorporated the scope of the requested(PSI) and West materials review to only flanges and fittings, 3) delineate actions licensees are requested to take to identify these materials and to determine whether the materials comply with ASME and ASTM design and material specifications, and 4) clarify what actiers licensees are requested to take once they identify material that does not comply with the above material specifications.

Description of Circumstances:

On June 10, 1988 the NRC staff was informed by Carolina Power & Light (CP&L) that the Shearon Harris Nuclear Plant had tested two flanges from their ware-house that had been supplied by WJM. The two flanges were identified as belonging to Heat No. 7218 SA-105 material. The CP&L test results did not match those reported on WJM's Certified Material Test Reports (CMTRs) and did not meet the tensile and yield strength requirements for SA-105 material.

Required minimum tensile strength is 70 KS! whereas the measured tensile strengths were 45 KS! and 46 KSI. The tensile strength reported on the CMTR was 77 KSI. Required minimum yield strength is 36 KS! whereas the measured yield strengths were 27 KS! and 31 KSI. The yield strength reported on the CMTR was SU KSt. Measured chemistry composition was also out of specification, ,

notably percent carbon was very low at 0.045 and manganese wcs measured at 0.32 "

(required range 0.6 to 1.05).

Bulletin 88-05 requires that all PSI and WJH supplied material be identified and that a detennination be made as to its suitability for the intended or

! ~-8804150106--- ,.

NRCB 88-05, Supplement 1 June 15, 1988 Page 2 of 3 actual application. This supplement narrows the scope of review from ASME and ASTM "materials" to ASME and ASTM fittings and flanges. In view of the recent verification that flanges which do not comply with ASME and ASTM speci-fications have.been supplied to the nuclear industry, the time frames for certain actions are also modified by this supplement.

Actions Requested:

The actions requested in Rulletin 88-05 remain in effect with the following additions:

1.

i Review of purchasing records may be reduced in scope from ASME and ASTM "materials" to ASME and ASTM "fittings and fijnges" and the review should be initiated and completed promptly.

2. The scope of paragraph 2 of Bulletin 88-05 is reduced from ASME and ASTM "materials" to ASME and ASTM "flanges and fittings." All other provisions of paragraph 2 of Bulletin 88-05 remain in effect.

3. The scope of paragraph 3 of Bulletin 88-05 is reduced from ASME and ASTM "materials" to ASME and AST?i "flanges and fittings." For ASME and ASIM flanges and fittings furnished by PSI or WJM already installed in safety-related systems in operating plants, the following actions are requested:

a. Commence appropriate testing of accessible flanges and fittings promptly to identify confomance of materials to ASME and ASTM material specifications. Test results for flanges and fittings reported to be from the same heat should be compared for consist-ency and for conformance to the ASME/ASTP specifications and to values listed on material CMTRs. Any deviation from the specifi-cation requires an appropriate analysis justifying continued operation,

b. If any inaccessible flanges or fittings are identified, an analysis must be perfomed justifying continued operation,

c. All other provisions of paragraph 3 of Bulletin 88-05 remain in effect.

4 l For flanges and fittings already identified as having been supplied by PS! or WJM, the actions requested in 3a and 3b above are to be completed within 30 days of receipt of this supplement. For flanges and fittings identified after receipt of this supplement, the actions requested in 3a and 3b above are to be completed within 30 days of identifying the flanges or fittings as being supplied by PS! and WJM.

~ 1/ Based on the discovery by CPAL of nonconfoming flanges and on NRC review cf records of WJM's production of numerous flanges purportedly from Heat No. 7218, licensees should specifically be alert to identify records for flanges from Heat No. 7218.

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NRCB 88-05 Supplement 1 June 15, 1988 Page 3 of 3

5. Addressees are requested to retain nonconforming materials until advised further by the NRC. Nonconforming materials should be segregated to ensure that they are not inadvertently used.

6. Addressees are encouraged to report the results of tests of PSI and WJM supplied flanges and fittings to the INPO Nuclear Network for dissemi-nation to the industry.

Reporting Requirements:

The reporting requirements of Bulletin 88-05 remain in effect with the following additiont:

1. The NRC Operations Center should be notified by telephone, 202-951-0550, of the need for analysis to justify continued operation as required in para-graphs 3a and 3b. Where the need for analysis to justify continued operation results in a requirement for a report under 10 CFR 50.7?, the notification to the Operations Center should be in accordance with the repor~ ting times re-quired by 10 CFR 50.72. If the need for analysis to justify continued operation would not result in a requirement for a report under 10 CFR 50.??,

the notification to the Operations Center should be made within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

2. Include the results of all tests of PSI or WJM materials in the written response to Bulletin 88-05.

2 The written reports required ebove sha.11 be addressed to the U.S. Nuclear Regulatory Comission ATTN: Document Control Desk, Washington, D.C. 20555, under oath or 6ffirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appro-

priate Regional Administrator.

This requirement for information was approved by the Office of Management and Budget under blanket clearance number 3150-0011. Comments on burden and dupli-

) ications should be directed to the Office of Management and Budget. Reports Management, Room 3208, New Executive Office Building Washington, D.C. 20503.

If you have any questions about this matter, please contact one of the technical contacts listed below or the Regional Administrator of the appropriate NRC regional office.

.df M harles . Rossi, Director i Division of Operational Events Assessment Office of Nuclear Reactor Resul::tien

Technical Contacts: Ray Cilimberg, NRR l (301)492-3220 l Ed Baker, NRR (301)492-3221

Attachment:

List of Recently Issued NRC Bulletins

, *i Attettent

'a WCS te M. $vpplement 1 Jwas ll. Itte LIST OF RfCt M T ll5UtB "

l Nec DVLLET!ts 5=Hetta pete of .

40, Susject fssveace issued to _

M 07 Pouer Oscillettens in 6/11/M All holders of OLs teiltag utter teetters (DWts) er cps for 8W88 M 04 Actieas to be Toten for 6/14/M All met 11tensees the fronsportatita of eethertled to

- Model no. Spot t.t anau fat tere.

Restegraphic Capesare 81stethwte, er Device operate restegeophtt tapelvre devttes or sovrte theaters.

87 02 Festener festtag to 6/10/M All holders of as

$spelement t Detemine Ceafecuente or cps for avtleer with Apetite61e F4terial p e er reetters. .

Spottftcettens M.Cl henconferstag Meterials S/4/M All holders of Rs Sve,1ted by Pietag Supplies. er cps fee avtleer lat. at Felsen. how Jersey peuer reetters.

and toest Jersey menefacturing Company at vt11temetown.

how Jersey M.04 Potential Safety.nelated S/l/M All holders of Rs P op less or cps for avtleer poser reetters.

45 03 meter.0perated Valee Cammen 4/f*/M All heleers of E s Supplement 1 Mode Failures Nring Plant er CDs for Dfes.

troostents thee te leproper Seiten Settlags 97 02 Fastener Testtag to 4/22/M All holders of R$

lepoloseat 1 Deteroine Confew te er cps for nucleer with 4epitteslo Nterial pouer reetters.

Specifttettoms M.C3 latesevate Latch tagetownt 3/10/M All holders of Rs ta NF A tyve Latching helays or cps for nuclear me%fectured by ement pouer roectors.

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NUCLEAR REGULATORY COMMISSION weses 3

WASHINGTON. D.C. 20555 eenwn w ea) 08FICIAL BusiNils PENAFTY FOR PRIVATE U$t. SXf i

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OMB No: 3100 0011 hRCS 88 05. Supplement 0 Uh!1ED STATES hbCLEAR RECULATORY COPE 15510N OFFICE OF NUCLEAR REACTOR REGULATICh WASHING 10h. 0.C. 20555 August 3. 1968 NRC BULLFT!!i h0. 88 05. $UPPLEhErit c: h0NC0hFORMING MATEklxL5 $UPPLIE0 BY PIPlhG SUPPLIES. Iht. AT FOL5CM. NEW JERSEY AND WEST JLkSEY MAhlFACTURlhG COMPANY Ai WILLIAMSTCkN. hEh wLkSEY Addressees:

All holders of operating licenses or construction permits for nuclear power reactors.

Purpose:

The purpost of this supplement is to (1) modify the schedule for actinris addressees were requested to perforr in Bulletin 88 05 and Supplerent 1 and (2) provide additional inforcation concerning materials supplied by Piping Supplies. Incorporated (PSI). West Jersey Manufacturing (WJM). .

and a recently identified affiliated company. Chews Landing Metal Manu.

j facturers Incorporated (CLM).

l' Description of Circumstances:

On July 22. 1956, the NRC staff met with representatives of the huclear Manage-l ment and Resources Counct) (huPARC) to discuss the status of licensees' actions J in response to Bulletin 88 05 and Supplement 1. During this meetirs huMARC presented information on licensee and NUMARC/ Electric Power Research Institute (EPRI) testing and evaluation methodology of PS!/WJM flanges. This inforzation was summarized in a letter to the NRC from NUPARC dated July 25. 1988 and a 3

detailed report and proposal was subsequently sutaitted on July 29. 1988

) (Attachr4nt 11.

Based on the reported seasurement and analytical results to date. the hkC has concluded that for full power licensets it is apprcpriate to suspend. terro- ,

rarily, the field measurements, testing, records review, and the preparatinn j of justifications for continued operations (JCOs) that were requested by Bu).

'l letin 88 05 and Supplement I until further notice. Addressees that have not received a full pcwer license are requested to continue the in situ testing and the records review. The time frames of interest recain as specified in 1

) the original 6ulletin. January 1.1976 to present. During the temporary '

suspension of the requestc0 activities the NRC will review the measurercrit ano test data and results of ar.& lysis performed ano cetermine the extent to i

f h%E03M89# . l M.

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hRC6 08 05, Supplen,ent 2 i August 3, 19CS Fege 3 of 3 If you have any qt.estions about this r.atter, please centact one of the technical contacts listed below or the Asgional Adtrinistrator of the appropriate NRC ,

regierial of fico. ,

^

8 l *- < M Charles L. Rosti, Director !

01 vision of Operational Ever.ts Assessment Office of huclear Reactor Regulation Technical Centacts: RayCilimberg,hkR ;

(001) 492 3260 Ls Laker, hRR (301) 4f2 3221 ;

l Att4chn.cr ts :

. ttr to hRC fc.l.LkARC, etc July 29, 19EE 1:. Froduct Ferrs Solo by LJM/Pil/ Chews Landing

3. huclear Plants Receiving Suspect Material

4. Purchasers Receiving Suspect Material !

5. List of Recently issued hkC liulletir.s l l

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^J Attachment No. 1 NRCB 88-05 Supplement 2 NUCLtAR MANAGIMINT AND Risove.;is COUNOlt August 3, 1988

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July 29, 1988 Mr. Thomas T. Martin Associate Director for Inspection and Techr.ical Assessment Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D. C. 20555

Dear Mr. Martin:

In a meeting held July 22 with NRC, NUMARC requested that utility activities relative to NRC Bulletin 88 05 and Supplement 1 be suspended. ,

This suspension request was based on a generic analysis provided to NRC by J NUMARC's letter of July 22. In the subject NRC meeting NUMARC also presented an analysis of utility and laboratory test data obtained to date. NUMARC's letter of July 25 to Dr. Thomas Murley formalized the request for suspension.

In that letter, NUMARC comitted to provide a written report to NRC reflecting the test data and conclusions presented in the July 22 meeting, and providing quantitative statistical evtluations relative to the conclusions presented at this meeting. That report is hatreby provided as an attachment.

As noted previously, the NUMARC laboratory testing program will be carried to completion even if utility test efforts are suspended. An update of the ..

attached report will be provided addressing conclusion of the NUMARC laboratory 1 testing program as well as inclusion of field test data not yet reflected.

We would like to reiterate the importance of timely action in your :

consideration of NUMARC's request for suspension. Utility resource i expenditures of major proportions are presently continuing without abatement.

Continuation of testing is not resource effective and, as documented in the attachment, would not be expected to result in additional insights. Moreover, in conjunction with the generic analysis previously provided, the attachment substantiates that no significant public hetith and safety concern is l

represented by this issue. ,

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NUMARC CENERIC TESTING PROGRAM

- PISPONSE TO NRC BULLETIN 88-05 INTERIM REPORT July 29,1988 Prepared By Bechtel National, Inc .

. San Francisco, California 94105 Prepared For Electric Power 3612 Hillview Avenue Palo Alto. California 94203 1

l ABST RACT The NRC Sulletin 88-05 addressed the alleged f alsification of certified Materiale Test Reporta (CMTRs) by two suppliers. WJM and PSI, of piping flanges and fittings. NUMARC, through the technical management of EPRI, developed a multifaceted program to assist utilities in addressing this bulletin. Laboratory testing of suspect material, the compilation of utility test data and analysis of that data are reported. These data show in general that, except for blind flanges, the suspect material meets tensile strength requirements and is satisfactory for ASME Code applications. The hardness testing results for the este sateriale exhibit a broad scatter band which would justify application of a testing tolerance band in comparison to the ASTN A370 conversion from hardnesa to tensile strength. The field and labcretory testing results both exhibit the same broad scatter band. A laboratory generated best fit curve is used to relate measured field hardnes e to tensile strength.

The field hardness test data for 1334 items show the asse scatter band as found in laboratory tests, and follows the same general bell shape hardness distribution a s laboratory hardne s s te st e. The similarity in shapes and the lack of bumps at either the low ends or the high ends of these laboratory and field histograms indicates that there is not a concern for low strength material or high strength saterial. Applying a best fit approach free laboratory hardness and tensile data to field hardness data results in an eette.te of strength. The b e s t fit approach to the field data indicates that the vast majority are acceptable. Based on the laboratory testing and entensive field testing, it is concluded there is no materiale problem, except possibly for seee blind flanges.

1 31(nd flanges and other components were addressed analytically in the NVKARC generic analysis report, and it was shown that in the majority of cases there would not be a stress concern even if strength in the order of 40 KS1 were to be sesumed.

This iriterim report concludes that the asterial has acceptable strength and except for some blind flat. gee is satisfactory for ASME Code applications. Th e continued use of these flanges and fittings does not present a safety problem.

Recomnendations are made for follow up activities.

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LIST OF ILLL'STRATIONS TABLES l Table 1 Summary of High Hardness Limits i i

Table 2 Summary of Stainless Steel Tests .

F ! CURE S a

Figure 1 Histogram of Laboratory Tensile Results Tigure 2 Equotip as SHN Compared to UTS and ASTM A370 ,

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Figur6 3 Best Fit Equotip Compared to UTS !

Figure 4 Histogram of Laboratory Hardness t

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Figure $ Histogram of Field Hardness '

1 Figure 6 Best Fit Data Applied to Field Hardness ,

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INTRODUCTION BACKCROUND The NRC issued Bulletin 88-05 regarding alleged f alsification of Certified Materials Test Reports (OfiRs) by West Jersey Manufacturing Co. (WJM) and Piping Systems, Inc. (PSI). Specific actions were required of utilities. Some of these could ef ficiently be addressed by a generic program. NVMARC initiated such a program. The NRC issued Supplement 1 to 88-05 subsequent to reports of two blind flanges having low tensile strength. The supplement required utilities to perforn field tests on identified installed WJM/ PSI items. Th e supplement also focused effort on piping flanges and fittings. The NUMARC program was modified to coordinate and standardine field testing methods and to compile utility generated data. Concurrently, the generic NUMARC laboratory testing program has been in progress.

NUMARC MUI.TIFACITED PROGRAM Because several actions were required by 88-05 which could be efficiently addressed in a generic manner, N1.HARC undertook the activities described herein as well as the testing and test data analysis which are the subject of this report.

A. Review of records to permit scope limitation.

B. Review of records to identify intermediate and secondary supply routes.

C. Interf ace with Authorised Inspection Agencies and the National Board of Boiler and Pressure Vessel Inspectors.

1 D. Generic stress analysis ef fittings and flanges.

E. Testing, data coepilation and evaluation.

CENERIC STRESS ANALYSIS

{ The generic stress anolysis has been completed, reviewed with and provided to the NRC. The analysis indicates that there is little concern for the stress )

integrity of the fittings or flanges even if the materials were of l substantially lower strength when compared to the attength requirements of i S A-10 5. This report was formally transmitted to the NRC by NUMARC on July 22, ]

1988. i The testing program is described in the following sections of this report.

NUMARC TISTING FROGRAM METHOD 3 This progrars contains two main elements: first, comprehensive laboratory testing of suspect itent contrieuted by utilities; and second, utility generated data of destructiv. laboratory tests and in situ tests of installed i suspect items. !

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best fit approach are discussed below subsequent to a brief analysis of the utility field data. The histogram of laboratory hardness data expressed in EQtl0T!P values is shown in Figure 4 ITTILITY TESTINO The utility-provided laboratory data is consistent with the generic program ,

test dets. The utili. ties have provided one set of data on a blind flange, West 7218, which is consistent with the two tests cited in 88-05 Supplement 1.

This data point is riot yet in the computer printout. Other than this, no i

substrength material has been reported based on tensile tests. These utilities have reported tensile strength for 108 iters. Eight iters slightly belev 70 KS! have been reported, ne remaining 101 values exceed 70 KSI. In ene case the utility engineer indicated there was a subsiae specimen removed from installed flange and was transverse to the primary working direction rather than parallel. These slightly low value s are readily explained by the tes t direction, and by published data which confirise that tensile test results from product testing may be as much as 10 percent below the minieue specified strength. None of these utilities reported strength values are a concern.

The utility generated hardness data is shewn in the histogram of Tigure 5.

This histogram has the sa-e general bell shape as the histogram of laboratory hardnese data. In simple terra, the bell shapes in both laboratory and field l histogress and the lack of buepe at the low hardness ends of the histograms '

indicate s tha t there is net a concern for low strength e.sterial. Wie means ,

that the vast majority of field iters veuld exceed 70 KS! if tested and that j the remainder would be within the expected tolersnee band. he conclusien is l that installed items are acceptable and do not present a material concern, j except fer seme blind flanges.

TIELD HARDSTSS TO TENS LE It is appropriste to co pare the best fit curves of laboratory hardness and tensile results and apply the results of that plot to the utility generated hardness data. Vhen this is done, refer to Figure 6, all itess are shown to be acceptable. It rust be realised that a best fit curve of field hardness should never be used to reject installed itees, because sece itens which fall below the line can be within the acceptable tolerance band. This is shown by the fact that the original data had nose acceptable iters below the best fit curve. The be s t fit curve ray be applied to warehouse items prior to installation, and should not be the sole justification for removal of installed itess. This curve increases the confidence that the installed itees are as initially intended to be. l BLIND TLANCES Th e be s t fit curve applied to field data, or a field hardness test tolerance does not elieinate the feet that there are data in the histogress (but not yet in the coeputer data base) whic5 indicates that blind flanges may be e concern f or strength reasons. However, the stress analyttest dets provnded to the NRC indicates that these substrength blinds are not a stress probles for service conditions.

1185e _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

there are objective reasons to use as is. The benefits of replacing installed high hardness items with acceptable welds and KAZ are sinikal. In contrast, the risks in any replacement are greater. The ALARA considerations also indicate that high hardness items not be replaced unless there is a plant unique overriding concern.

STAINLESS STEEL There is a relatively small amount of stainless steel installed, and very little in warehouses. To date, all tests performed on stainless steel have been acceptable. Approximately four dozen items have been tested. All tensile results are acceptable, all chemical analyses are acceptable and all sensitization tests are acceptable. Approximately 10 dozen magnetic checks were also acceptable. Only one of all these test results is slightly low; that is, one yield strength value was 28.5 KS! vs. 30.0 KSI, and this difference is insignificant. These test s are summarized in Table 2.

While the absolute number of test results is not as great as for carbon steel, the results indicate there is no concern.

CONOLUSIONS ,

The strength of SA 105 material and stainless steel items which were suspect is not a concern.

i RE 00K<E NDAT!0NS l

1. The test results to date indicate there is no concern for asterials and thus field testing may be suspended as there is suf ficient data for evaluation.

The generic stress analysis also indicates there is nb concern for plausible low strength asterials because it has been shown that even if f substrength materials were installed, the vast majority of these cases would be acceptable. Thus, it is appropriate to suspend document reviews 2

and field testing. ~

l 2. The laboratory program should be completed subject to constraints of 1 available material.

3. The existing utility generated data should be compiled and analysed in the i NUMARC program.

] 4. A sumnery report should be generated.

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) LABORATORY TENSILE RESULTS 45<

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0 i i i i i i- i i >60 >45 >70 >75 >to >85 390 l TENSILE STRENGTH (KSI) l i

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l FIG. 1 HISTOCRM OF j LAlcRATORY TENSILE l RESULTS l

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7/22/88 I FIC. 3 BEST FIT EQUOT!P VS TENS!LE STRENGTH l

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. I SA105 FIELD HARDNESS DATA Da= =5 d .

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<348 348- 364- 381- 396- 410- 424- 437- 45C- 463- 4't5- >486 363 380 395 409 423 436 449 462 474 486 HARDNESS CATEGORIES :

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?ABLE 1 SW4A.' .' 0F HIC.H HMtDNESS LlHITS l I

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BHN i SA 350 197 !

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SA 105 PRE 1972 N/A SA 105 POST 1972 187 l

ONLY IF QUENCHED 1

SA 234 WP,B-SUPPLEMENTARY 197 l

SA 181 N/A SA 182 F1 192 [

F2 192 l l F 11 207 l l F 22 207 t i

AWS D1.1 WELD & HAZ, HV280 265 !

l NACE MR-01 75 Rc22 237 !

l BASE METAL, WELDS, HAZ !

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Attachment 0 AF.C8 88 05. Supplement 2 !

August 3. 1988 Product Forms Sold By WJM/PS!/ Chews Landina l Flanges Palf Couplings full Couplings Plate kings Fenetration Plates SA516. GR70 .

Seal fictes 5A516. GR7g (Ftrryl' Socket held kozzles (CLM)

Long Orain Bess A162F11 t. F22 Radiograph Plugs (CLM)

Square bar 1018 Spacers Sarple Probes Class 1 -- $A312. T304 (Ferry) (CLM)

Guide Lugs SA240,1304 locket Welced Half Couplings Class 1 SA182. F304L (Vogtle)

$pecial hozzles Pipe Caps .. SA234 Lugs -. SA240. T304 (Palo Veroe)

Lugs - SA516. Gf,70 (Palo Verde)

Socket Weld Couplings Plate .. SA36 (Perry)

Special Boss A234. A105. A739 Bcits . SA193. GR87 (Confrentes/ Spain)

Ir.strueent Penetration End Plate SA516. GR70 (Perry) hanger Lugs $A516. GR70 (Orave/ Site unknown)

$cchet Welo bcss -- Class 1 SA18k, F316 (Seabrook) (CLM)

Transition Flece 5A105 (Vogtle)

Thermowells . A182 (Cravo/ Hunter /$1te unkncwn) (CLM)

Bar Stock - A105 (Dravo / Yellow Creek) (CLM)

I This is a cceplete list of all product forms identified during the NRC staff's review of available recoros.

2

$pecific r.uclear pcwer plants or customers are noted in cases where the precuct form appeared to be a unique or special order and not wice spread.

Indicates that material was sold by Chews Landing Metal Manufacturers Inc.

. si Attactsent 4 NRCE 60 05. Supplerent 2 August 5. 9f$

Purchasers Faceiving Sulcect Material I Barr . $aurcers. It!c.

M.W. k,ellogg (became 01 vision of Pulle.af.,

Lake Erie Iren & Metal Co,. Inc.

Liberty Equipment. Co.

Metal #11cws (listed as Eellows in Belletin)

' Power Piping Co.

Standarcs Fipe & Supply Co.. Inc.

Tioga Pipe Supply Co.. Inc.

Tylar Lawson (listto in error as Tyler Cavison in Bulletin)

I These pur basers are in audition tc those previously identifteo ano are known to have received raterial fer nuclear applications.

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SSINS No.: 6820 0MB No.: 31500011 NRC Compliance Bulletin 87-02 UNITED STATES NUCLEAR REGULATORY COPti!SSION

_ 0FFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 November 6, 1987 NRC COMPLIANCE BULLETIN NO. 87-02: FASTENER TESTING f0 DETERMINE CONFORMANCE WITH APPLICABLE MATERIAL SPECIFICATIONS Addres All holders of opertting licenses or construction permits for nuclear power reactors.

Purpose:

The purpose of this bulletin is to request that licensees 11 review their l receipt inspection requirements and internal controls for fasteners and

2) independently detennine, through testing, whether fasteners (studs, bolts, cap screws and nuts) in stores at their facilities meet required mechanical and chemical specification requirements.

Description of Circumstances:

Over the past year, some NRC procurement 'ispections have included the col-lection and testing of a small sample of fastener:1. This limited program was initiated in response to a concern by the Industrial Fastener Institute ,

over the potential use of inferior fasteners in military and industrial applications, including nuclear power plants. The results of NRC testing of fasteners obtained from San Onofre, Palo Verde and Rancho Seco indicates that 11 out of the 32 fasteners tested do not meet specification requirements for mechanical and/or chemical properties. Nine of the nonconforming bolts from Palo Verde and San Onofre were out of specification based on chemistry.

Five nonconforming bolts esme from Palo Verde and were all marked as SAE Grade 8 but were actually found to be SAE Grade 8.2. The four nonconfonning fasteners from San Onofre were slightly out of specification for nickel or 1 chromium. Two bolts from Rancho Seco with ASTN A193 B7 head markings were determined to have an average ultimate tensile strength of approximately M ksi inutead of the specified 125 ksi for ASTN A193 B7 bolting material.

The chemical analysis of these bolts indicated that they were medium carbon steel ma'.orial. Rancho Seco is still investigating the extent and safety significance of these substandard fnteners.

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NRC .h11ance Bulletin 87-02 November 6, 1987 Page 2 of 3 In a separate effort, Calvert Cliffs recently tested 1539 fasteners following their discovery that commercial grade fasteners had been used in safety-related applications. The test results indicated that 399 failed to meet specification requirenv.nts for mechanical and/or chemical properties. Based on evaluations perforced by Calvert Cliffs, the fasteners which did not meet specification would have still fulfilled their safety function.

Actions to be Taken:

The results of the limited testing described above have demonstrated the need to obtain additional information on the adequacy of fasteners used in nuclear power plants.

Within 60 days from the receipt of this bulletin, licensecs are requested to provide the following information concerning their receipt inspection and internal control procedures for fasteners and the results of independent testing of fasteners:

1. Describe a) the characteristics currently examined during receipt inspection of fasteners (i.e., head markings for grade and manufacturer symbols, review of certified material test report or certificate of conformance), and b) internal controls utilized during storage and issuance from stock to assure the appropriate use of fasteners.

2. Select a minitrum sample of ten (10) non-safety related fasteners (studs, bolts,and/orcapscrews),andten(10) safety-relatedfasteners(studs, bolts, and/or cap screws) from current, in use, stock. The sample is to be obtained by the licensee with the participation of an NRC inspectcr.

Fasteners procured to meet the following chemical and mechanical properties are of interest: A-193 grades B7, 88, and B16; SAE J4?9 orades 5 and 8; A-449; A-325 Types 1,2 or 3; A-354 grades BB, BC, BD; 4-490; A-320 LTN; A-307; A-563; or equivalent. .

3. For the selected sample of fasteners in item ?, include a sample of typical nuts that would be used with each fastener (one-for-one).

In particular, nuts purchased to the chemical and mechanical spect-fications of A-194 are of interest.

4. Chemical testing shall be performed on all samples. Mechanical testing shall be performed on each safety-related fastener. Hardness testing shall be performed on each nut and non-safety-related fastener. All testing shall be performed by a laboratory which the licensee has cuali-fled for this type of testing and appears on the licensee's approved vendor list. Testino performed shall be done in accordance with the reouirtments of the fastener's specification, grade, and class, and the test shall evaluate the ultimate tensile strength, hardness and chemical propert'es as required by the fastener's specification, grade, and class.

Each stople shall be tagged with the sample's ID number.

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Nkt Compliance Pulletin 87-02 November 6,1987 Page 3 of 3

5. The results of all tests, together with supportino information, are to i be reported to the NRC utilizing the format shown in Attachments 1 and '

2 of this bulletin. Include the namos and addresses of suppliers and manufact0rers of safety-related fasteners and, to the extent possible, of non-safety-related fasteners. For any fastener found out of specifica-tion, provide an evalJation of the safety significance including consider-ation of the most limiting application.

6. Based on the results of the testing and review of current procedures, describe any further actions being taken to assure that fasteners used in the plant meet the requisite specifications and requirements and that the operability of safety-related plant components is not affected.

The written reports shall be submitted to the appropriate Regional Administrator under oath or affirmation under provisions of Section 182a, Atomic Energy Act of 1954, as amended. Also, the original copy of the cover letters and a copy of the reports shall be transmitted to the U.S. Nuclear Regulatory Connission.

Document Control Desk, Washington, D.C., 20555 for reproduction and distribution.

This reouest for information was approved by the Office of Management and Budget under a blanket clearance number 31500011. Coninents on burden and duplication may be directed to the Office of Management and Budget. Reports Management, Room 3208, New Executive Office Building Washington, D.C., 20503.

. If you have any questions about this matter, please contact one of the technical cont 3 cts listed below or the Regional Administrator of the appropriate regional office.

hdl%($m' Charles E. Rossi, Director Division of Operational Events Assessment i

Office of Nuclear Reactor Regulation Technical Contacts: J. T. Conway, NRR (301)492-9740 E. T. Baker, NRR (301)492-4783 )

il. C. Harper, NRR (301) 492-4143 At.acnwnts:

1. Fastener Testing Data Sheet

1. Data Sumary l

3. List of Recently issued Bulletins I

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Attachment 1 Fastener Testing Data Sheet

Sample ID#

Fastener

Description:

Description of Sample Stock Location:

Material Specification as Documented by Licensee Records:

Head Parking (Specification and Manufacturer):

- Class / Procurement Level:

General Plant Application (e.g., Pressure Boundary. Structural)

Vendor:

On Requirements Imposed on Vendor: '

Licensee Representative:

Signature Date

The sample ID# shall have a prefix that contains the licensee facility init161s.

- If applicable, please provide an explanation for your classification system.

Attachment 2 ,.,-

Data Susanary Mechanical Analysis Chemical Analysis I 10# Hardness UTS 0.1% YS __C _Mn _P S Si ,

Mo Cr

,r

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1

! Note: UTS-ultimate tensile strenoth; YS-yield strength: C-carbon; Mn-Manganese; P-Phosphorous; S-Sulfur; Si-Silicon:

Mo-Molybdenum; Cr - Chromium.

3 l

The elements listed apply to ASTM A193 R7 or SA193 P7 material. The elements to be reported for other materials tested, shall confom to those reported in the applicable material specification. Properties four.d out of j specification shall he noted with an asterisk.

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aftachment3 NRC Compliance Bulletin 87-02 November 6,1987 LIST OF RECENTLY ISSUED RULLETINS Bulletin No. Subject Date of ~

Issuance Issued to 87-01 Thinning of Pipe Walls in 7/9/87 All licensees for Nuclear Power Plants nuclear power plants holding an OL or CP.

86-04 Defective Teletherapy Timer 10/29/86 All NRC licensees that May Not Teminate Dose authorized to use cobalt-60 teletherapy units.

86-03 Potential Failure of Multiple 10/8/86 ECCS Pumps Due to Single All facilities holding an OL or Failure of Air-Operated Valve CP.

in Minimum Flow Recirculation Line 86-0? Static "0" Ring Differential 7/18/86 All power reactor Fressure Switches facilities holding an OL or CP, 86-01 Minimum Flow Logic Problems 5/23/86 All GE BWR facilities That Could Disable RHR Pumps holding an OL or CP, 85-03 Motor-Operated Yalve Coreon 11/15/85 All power reactor Mode Failures During Plant Transients Due to Improper facilities holding Switch Settings an OL or CP.

. 85-02 Undervoltage Trip Attachments 11/5/85 All power reactor of Westinghouse 08-50 Type facilities holding )

Reactor Trip Breakers ;

an OL or CP. l 85-01 Steam Binding of Auxiliary l 10/29/85 Nuclear power Feedwater Pumps :

facilities and cps l listed in Attachment I 1 for action; all other nuclear power facilities for information.

I OL = Operating License i CP = Construction Pemit !

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OMB No.: 3150-0011 NRCB 87-02, Supplement 1 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION

, WASHINGTON, D.C. 20555 Spril 22, 1988 NRC BULLETIN NO. 87-02, SUPPLEMENT 1: FASTENER TESTING TO DETERMINE CONFORMANCE WITH APPLICABLE MATERIAL SPECIFICATIONS Addressees:

All holders of operating licenses or construction permits for , nuclear pcwer reactors.

Purpose:

The purpose of this supplement is to require addressees to submit additional infom3 tion on the source of fasteners purchased for use in nuclear power

'lants.

Description of Circumstances:

Item 5 of NRC Compliance Bulletin 87-0? requested that all holders of operating licenses or construction pemits for nuclear power reactors submit infonnation regarding the identity of the suppliers and ranufacturers of the safety-related and non-safety-related fasteners selected for testing. After further consider-ation, the NRC has detemined that it needs information regarding the identity of all vendors from which safety-related and non-safety-related fasteners have been obtained within the past 10 years, a reasonable period which will not put uMue burden on addressees. This infomation will assist the NRC in detemin-ing wn.0,r -"alear facility fasteners in use have been supplied in accordance with their intended use. In addition, this infonnation is needed so that the NRC can properly coordinate information with other government agencies con-cerned with problems identified in the quality of fasteners.

Action Required: .

Within 90 days from the receipt of this supplemental bulletin, addressees shall provide the following infarmation concerning the procurement of fasteners within the past 10 years:

I

1. A list of the suppliers and manufacturers from which safety-related i fasteners have been purchased, including addresses, and the type of fasteners purchased (i.e., the material specifications). For those i fastener purchases made fron fastener suppliers and/or original equipment manufacturers, any available information concerning the manufacturer or ,

sub-tier supplier of the fastener also should be provided, )

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NRCB 87-02, Supplement 1 April 22, 1988 Page 2 of ?

2. For non-safety-related fasteners the same infonnation as requested in item 1.

The written-reports requested above shall be addressed to the U.S. Nucitar Regulatory Comission, ATTN: Document Control Desk, Washington, DC 20555, under oath or affinnation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appro-priate Regional Administrator.

This requirement for infonnation was approved by the Office of Management and Budget und?r a blanket clearance number 3150-0011. Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Fxecutive Office Building, Washington, D.C. 20503.

If you have any questions about this matter, please contact one of the techni-cal contacts listed below or the Regional Administrator of the appropriate regional office.

i Yks f /L'Mf Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: J. T. Conway, NRR l (301) 492-0978 E. T. Baker, NRR (301) 492-3221

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Attachment:

List of Recently issued NPC Pulletins l

, s Attachment NRCB 87-02, Supplement 1 April 22, 1988 LIST OF RECENTLY ISSUED NP.C BlfLLETINS Bulletin . Date of No. Subfect Issuance Issued to 88-03 Inadequate Latch Engagement 3/10/88 All holders of OLs in HFA Type Latching Relays or cps for nuclear Manufactured by General power reactors.

Electric (GE1 Company 88-02 Rapidly Propagating Fatigue ?/5/88 All holders of OLs Cracks in Steam Generator or cps for W-designed Tubes nuclear podr reactors with steam generators having carbon steel support plates.

88-01 Defeccs in Westinghouse 2/5/88 All holders of OLs Circuit Breakers or cps for nuclear power reactors.

87-02 Fastener Testing to 11/6/87 All holders of OLs Determine Confomance or cps for nuclear with Applicable Material power reactors.

Specifications 87-01 Thinning of Pipe Walls in 7/9/87 All licensees for Nuclear Power Plants nuclear power plants holding an OL or CP.

86-04 Defective Teletherapy Tirrer 10/29/86 All NRC licensees That May Not Tenninate Oose authorized to use cobalt f0 teletherapy units.

86-03 Potential Failure of Multiple 10/8/86 All facilities ECCS Pumps Due to Single holding an OL or Failure of Air-0perated Valve CP.

in Minimum Flow Recirculation Li .e 86-07 Static "0" Ring Differential 7/18/86 All potter reactor Pressure Switches facilities holding an OL or CP.

86-01 Minimum Flow Loaic Preblems 5/23/86 All GE PWP facilities That Could Disable PPR Pumps holding an CL or CP.

OL = Operating License

CP = Construction Permit I

l

' ,. . l Attachment NRC8 87-02, Supplement 1 !

April 22,1988 ;

LIST OF RECENTLY ISSUED NRC PULLETINS Bulletin - Date of No. Subject Issuance issued to l 88-03 Inadequate Latch Engagement 3/10/88 All holders of OLs in HFA Type Latching Relays or cps for nuclear Manufactured by General power reactors.

Electric (GE) Company 88-02 Rapidly Propagating Fatigue ?/5/88 All holders of OLs Cracks in Steam Generator or cps for W-designed Tubes nuclear po 4r reactors with steam generators having carbon steel i support plates. j 88-01 Defects in Westinghouse 2/5/88 All holders of OLs Circuit Breakers or cps for nuclear power reactors.

87-02 Fastener Testing to 1)/6/87 All holders of OLs Determine Confomance or cps for nuclear with Applicable Material power reactors.

Specifications 87-01 Thinning of Pipe Walls in 7/9/87 All licensees for Nuclear Power Plants nuclear power plants holding an OL or CP.

86-04 Defective Teletherapy Tirer 10/29/86 All NRC licensees That May Not Tertninate Dose authorized to use cobalt-f0 teletherapy units.

86 03 Potential Failure of Multiple 10/8/86 All facilities ECCS Pumps Due to Single holding an OL or Failure of Air-Operated Yalve CP.

in Minimum Flow Recirculation Line 86-07 Static "0" Ring Differential 7/18/86 All power reactor Pressure Switches facilities holding an OL or CP.

86-01 Minimum Flw Logic Problems 5/23/86 All GE 2'!P facilities That Could Disable PPR Pumps holding an OL or CP.

OL = Operating License CP = Construction Permit

i s NRCB 87-02, Supplement 1 April 22, 1988 PeJe 2 of ? ,

2. For non-safety-related fasteners the same information as requested in item 1.

The written reports requested above shall be addressed to the U.a. Nuclear Regulatory Comission, ATTN: Document Control Desk, Washington, DC 20555, under oath or affinnation under the provisions of Set. tion 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appro-priate Regional Administrator.

This requirement for infomation was approved by the Office of Management and Budget under a blanket clearance number 3150-0011. Coments on burden and duplication may be directed to the Office of Management and Budget Reports Management, Room 3208, New Fxecutive Office Building, Washington, D.C. 20503.

If you have any questions about this matter, please contact one of the techni-cal contacts listed below or the Regional Administrator of the appropriate regional office.

Y u + 0.h's f k M f Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: J. T. Conway, NRR (301) 492-0978 E. T. Baker, NRR (301) 492-3221 Attachrent: List of Recently Issued NPC Pulletins -

l

OMB No.: 3150-0011 l NRCB 87-02, Supplement 2 !

l 1

UNITED STATES NUCLEAR REGULATORY CO WISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 June 10, 1988 NRC BULLETIN NO. 87-02, SUPPLEMENT 2: FASTENER TESTING TO DETERMINE CONFORMANCE WITH APPLICABLE MATERIAL SPECIFICATIONS 8.ddressees:

All holders of operating licenses or construction permits for nuclear power reactors. .

Purpose:

The purpose of this supplement is to clarify the type of information addressees were required to submit in response to Bulletin (17-02, Supplement 1 on the source of fasteners purchased for use in nuclear power plants.

Discussion:

The "action required" statement of Supplement 1 is revised in its entirety to clarify that the intent of Supplement I was to require addressees to provide a list of suppliers and manufacturers from which fasteners may have been pur-chased. Licensees are not required to contact subcontractors to obtain the requested information, nor are they required to submit data on fasteners sup-plied as part of an oriainal component. The type of fasteners for which vendor /

supplier names and addresses are requested is limited to ferrous fasteners 1/4 inch in diameter or greater.

Action Required:

Within 90 days from the receipt of Supplement 1 to Bulletin 87-02 (issued on A>ril 22, 1988). addressees shall prnvide the following information concerning t1e procurement of fasteners:

1. A list of the suppliers and manufacturers from which safety-related ferrous fasteners 1/4 inch in diameter or greater may have been purchased, within the past 10 years, including addresses. For those fasteners purchased from fastener suppliers and/or original equipment manufacturers, any available information that identifies the manufacturer or sub-tier supplier of the 88060903.0L 3n -

 ' , WJ NRCB 87-02, Supplement 2 June 10, 1988 Page 2 of 2 fasteners also should be provided.

plier Lists are the intended sources for this information. Approved Addressees are Vendor List or Qua not required to search purchase order files, contect subcontractors to obtain the Jnformation, or submit data on fasteners supplied as part of an original component. 2. For nonsafety-related fasteners the same information as requested in the first two sentences of item 1, above, except that a) the time of interest is for fasteners procured in tha last 5 years, and b) the search of avail-able records in this case should include purchase orders unless the licensee utilizes approved vendor lists or qualified supplier lists in procuring nonsafety-related fasteners. This information collection is under-stood to be on a best-effort basis. Further, addressees are not required to contact subcontractors to obtain the information or to submit data en fosteners supplied as part of an original component. The written reports requested above shall be addressed to the U.S. Nuclear Regulatory Comission, ATTN: Document Control Desk Washington, D.C. 20555, under, Act oath as of 1954, or amended. affirmation under the provisions of Section 182c, Atomic Energy priate Regional Administrator. In aodition, a copy shali be submitted to the appro-This requirement for information was approved by the Office of Management and Budget under a blanket clearance number 3150-0011. Coments on burden and duplication may be directed to the Office of Managemen, and Budget. Reports Management, Room 3208, New Executive Office Building, Washington, D.C., 20503. 1f you have any questions about this matter, please contact one of the technical contacts listed below or the Regional Administrator of the appropriate regional office. 1 ir c Division of Operational Events As:;essment Office of Nuclear Reactor Regulation Technical Contacts: J. T. Conway, NRR < (301) 492-0978 E. T. Baker, NRR (301)492-3221

Attachment:

List of Recently Issued NRC Bullet'ns i

                                                                                                                               - - - - -..-.,-a,

r-

    / 'A' s, Attachment NRCB 87-0?, Supplement ?

June 10, 1988 LIST OF RECENTLY ISSUED NRC BULLETINS Bulletin Date of No. Subject Issuance issued to 88-06 Actions to be Taken for 6/14/88 All NRC licensees the Transportation of authorized to Model No. Spec 2-T manufacture, Radiographic Exposure distribute, or Device operate radiographic exposure devices or source changers. 88-05 Nonconforming Materials 5/6/88 All holders of OLs Supplied by Piping Supplies, or cps for nuclear Inc. at Folsom, New Jersey power reactors. and West Jersey Manufacturing Company at Williamstown, New Jersey 88-04 Potential Safety-Related 5/5/88 Pump Loss All holders of Ols or cps for nuclear power reactors. 85-03, Motor-Operated Valve Correon 4/27/88 Supplement 1 All holders of Ols Mode Failures During Plant or cps for BWRs. l Transients Due to Improper ; Switch Settings ! 87-02, Fastener Testing to 4/22/88 Supplement 1 All holders of Ols Detemine Conformance - or cps for nuclear with Applicable Material power reactors. Specifications 88-03 Inadequate Latch Engagement 3/10/88 All holders of OLs in HFA Type Latching Relays or cps for nuclear Manufactured by General power reactors. Electric (GE) Company . 88-02 Rapidly Propagating Fatigue 2/5/88 All holders of Ols Cracks in Steam Generator or cps for W-designed Tubes nuclear power reactors with steam generators having carbon steel support plates. OL = Operating License CP = Construction Pemit

y',j,. .:.g

                              -                                                                                                                                                                       l
                                                             ,f                                          o                                   UNITED STATES                                rq      pR g

g NUCLEAR REGULATORY COMMISSION u j g wAsHWGTON, n. C. 20666 B ' EDO Princioal Correspoidence Control l k,,.....[g FROM DdE: 10/07/88 EDO CONTROL: 0003975 DOC DT: 08/15/08 FINAL, REPLY: Utephen B. Comley Wa The People of the United States (White House Referral 9/20/88) TO: President Reagan FOR SIGNATURE Oct ?* GRN ** CRC NO: 88-0848 a Murley DESC: ROUTING: CONCERNS OF CITIZENS AT OR NEAR SEABROOK NUCLEAR Russell

 ,'                                                      PLANT DATE: 09/26/88 ASSIGNED TO:                                                              CONTACT:                                          -
                                                                                                             -JRR      _ _ _ _

Murley SPECIAL INSTRUCTIONS OR REMARKS: QTE - G in onnel and, p es RETURN CORRE3PONDENCE, WORKSHEET WITH CC OF REPLY TO: AGENCY LIAISON ROOM 91 THE WHITE HOUSE j' WASHINGTON, DC 20500 NRR RECEIVED: SEPTEMBER 26, 1988 ACTION: DRPR:VARGA' NRR ROUTING: MURLEY/SNIEZEK MIRAGLIA CRU'ICHFIELD -- ' GILLESPIE mssaUaG ACTION DUE TO NRR DIRECTOR'S OFFIC BY haeszt. ygg e

;. s. o - OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-88-0848 LOGGING DATE: Sep 22 88 ACTION OFFICE: EDO AUTHOR. S.B. Comley AFFILIATION: MA (MASSACHUSETTS) LETTER DATE: Sep 20 88 FILE CODE: ID&R-5 Seabrook

SUBJECT:

Concerns of citizens at or near Seabrook nuclear plant - j ACTION: Direct Reply DISTRIBUTION: Docket SPECIAL HANDLING: None l NOTES: See SECY-88-0735 DATE DUE: Oct 6 88 SIGNA 1tRE: . DATE SIGNED: AFFILIATION: i Rec'd Off. E00 Dats 9'- SL 3-2T8' Tlms _ Yf$ er.. , LLo---UO3975

THE WHITE HOUSE OFFICE i REFERRAL j SEPTEMBER 20, 1988 1 TO: NUCLEAR REGULATORY COMMISSION ACTION REQUESTED: DIRECT REPLY, FURNISH INFO COFf a REMARKS: SEE ID 232780 AND 449871 DESCRIPTION OF INCOMING: ID: 611401 MEDIA: LETTER, DATED AUGUST 15, 1988 i l TO: PRESIDENT REAGAN FROM: MR. STEPHEN B. COMLEY EXECUTIVE DIRECTOR . WE THE PEOPLE OF THE UNITED STATES STOP CHERNOBYL HER ; BOX 277 ROWLEY MA 01969 ,

SUBJECT:

AGAINS ASKS TO DISCUSS CONCERNS OF CITIZENS l AT OR NEAR SEABROOK NUCLEAR PLANT; ALSO, THAT PEOPLE OF ROWLEY, MASSACHUSETTS SENT HIM PETITIONS AS THEIR CONCERN TO WHICH THEY'VE il NEVER RECEIVED A REPLY l PROMPT ACTION IS FSSENTIAL -- IF REQUIRED ACTION HAS NOT BEEN TAKEN WITHIN 9 WORKING DAYS OF RECEIPT, PLEASE TELEPHONE THE

UNDERSIGNED AT 456-7486.

l RETURN CORRESPONDENCE, WORKSHEET AND COPY OF RESPONSE (OR DRAFT) TO: AGENCY LIAISON, ROOM 91, THE WHITE HOUSE, 20500 I i i SALLY KELLEY DIRECTOR OF AGENCY LIAISON PRESIDENTIAL CORRESPONDENCE i

1011401/ io , q i WHITE HOUSE CORRESPONDENCE TRACKING WORKSHEET O O .OUTGolNG O H. INTERNAL O I . INCOMING ni:3,*gmaEfrM i / f,7 Name of Correspondent: " => / - # th L E V

UserCodes: (A) (B) (C) _. O MI Mall Report L'- ~ & su w ~ J Subject $ & As k & Lv>u WA" = W Yb /t Ke o #< kt.r.Ah- A q IJ L-{ % g 0nL + , % a n k 1' 2- ++r , v2 A=h w L1=_ k s w h & ' +_ Wr 'w w to A.s.es__e <

                                                                                                                       & m W.    '

I i ACTION DISPOSITION ROUTE TO: Tracking Type Completion Date of Date Action YYlMM/oo Response Code YYlM M/DD Office / Agency (Staff Name) Code bb _ ORIGINATOR I / Nb _ h AIIM /J { ' 20

Referral Note:

          /                                                                          $$ 160                              _          _

l I Referral Note: I I I I Referral Note: I I I I Referral Note: I I I I Referral Note: OtSPoSit;oN CODES: ACTON CODES: I . Info Copy only/No Action Necessery A . Aeleered C . Complet ed A . Appropriate Actu 8.Swspended R . Olroct ReMy wCopy 5

NoMpeclet Referrel C Comment 1tecommendetion D . Desm Response S . For SHpatwre F . Fvmith Fact Sheet X . leternm Revy to te weed es Encloovre FoR CJT00.N0 CoRMESPoNDENCE:

Type of Responte e intilsit of Signet

                                                                                /                                          Code . -A-Y                             competion Deie . Date of outgo 4ng

[ 0t 1b M2 7?b k4 9 87/ . Comments: Keep this worksheet attached to the original Incoming letter. Send all routing updates to Central Reference (Room 75, OEOB). Always return completed correspondence record to Central Files. Refer questions about the correspondence tracking system to Central Reference, ext. 2590, set

611401

9) '

                    #hhgh                                We The Pe ple cf the United States Stop ChernobylHere S      V n

(

      ,es                                                                                August 15, 1988 President Ronald Reagan The White House 1600 Pennsylvania Ave.

Washington, D. C. Dear Mr. President I am writing to you as a lifetime member of the Presidential Task Force and Inner Circle. I_have written to you in the_p_ast on the matter of nuclear _ power _.ip_this country, a n d. ,h av e_ s en,t,y.Qu i nf o rmat i on on

                                               + C i n Nutty!7 have also sent you information on inaim E prnM a== ia the Nuclear Requiatory                Commission's inability to regulate nuclear power plants adequately.                  A  recent     General       Accounting Office report (enclosed) substantiates the belist.of the people                                of the always       Town of properly Raulay, Nassachusetts, that the NRC does notand~ poor practices within the investigate. problems.with nuclear plants
             .aiency itself.              Two years ago, 80% of Rowley signed a petition (enelosed) asking you to undertake anstill                       investigation waiting for of  anthe
                                                                                                       ~ NRC's practices.           The_ people of Rowley are                    -~ ~ ~ ~ ~

acknowledgment of_their_.,rn uest. in I am the ownee and administrator of Sea View Nursing Home Rowley, dassa'ehusetts which"Ties just'outside'the Emergency

                               ~       ~

Preparedness Zone for the Seabrook, New Hampshire, Nuclear Power Plant. I fully agree with the State of Hassachusetts' conclusion that the population could not be evacuated in the event of a serious nuclear accident at the plant. I am also the Executive Director of We The People Inc. of the United States which is a non-profit organization established to educate the American public about nuclear power. Several years ago, regarding the Shoreham, New York, nuclear plant, you said you would not interfere with the state'A powers to decido if evacuation is possible in case of a nuclear accident. (enclossd) Now you are considering signing an executive order which would take that power away from the state of Massachusetts for Ithe commenities near the Seabrook, New Hampshire, nuclear plant. ' strongly urge you to avoid signing such an order. Apart from the fact that evacuation of those at communities Seabrook is etill Station

 -              impossible, there are seriouw safety matters                                                                     i under investigation by the NRC and others. Oae it the strong                                                      l possibility          that substandard piping fixtures 88-05,                were built   into the plant May 6, 1988), such (see enclosed dccumentation-NRC bullatan No. system compromises the health piping in the safety public.         These piping fixtures are currently foiling testing and could result in a serious accident at any of the 30 plants involved.

Another problem under investigation at Saabrook Station is the / inspection of important safety systems by an unqualified inspector. i (enclosed) Despite knowledge of the plant builders that he propar credentials to perform the work, thiswas inspector allowed did not have the to act in an inspectors' capacity for a year. Bos 217 Rowley, M A 01969,(508)948 7959 f

            $0 Coun St. Nymouth, M A 02361,(617) 74&9M0                                                                           !

I National Press Bldg.,14 A F. Sts., N.W., Washington, O C. 20045 Offke 5 A 6,3 Pless.nt St., Concord, NH 03301,(603) 228 9484

                                                                                    -. .                               .--...,-r

9 e' . Anothcr problem, also common to military equipment, is substandard Although the bolts which become malleable or shear off under stress. NRC claims that the utilities' inspection proves that these "counterfeit" bolts are not built into Seabrook Station, the inspection was very cursory and incomplete. For reascns of safety, and also to uphold the idea that the foderal government should not interfere in powers reserved to the states, I urge you to forego the executive order which would undermine Massachusetts' determination that evacuation around the Seabrook nuclear plant is impossible. Last October 26, at the gala event for you hostad by the Irner

        'Clicle, I gave you a l e tt e r ,(c o py o f 'l e tt e'r e n_c l_o s e d ), with informat_io_n ond_ asked you ,to meet with_m_e. I was trying to. convey _to you l

information we had about substandard materi_als, information which was not widely known at the time. I would still likefto meet with you because there is,additionallinformation.avai,lable.other than what.has now'been provided, and more will be forthcoming. Like the problem of

               ~
                                                                       ~

the substandard equipmsnt, the NRC also has t'he information we have about nuclear plant problems, but is doing nothing about it, except perhaps to covor it up. Lastly, the NRC people that we have been working with for the past two years are willing to meet with you privately to inform you of the corruption which has deliberately jeopardized the safety of the American people. These violations, I have been told, are just the soft underbelly of the nuclear industry and the NRC. I am sare you can understand the concern of these individuals over thu consequences of coming forward and, I am sure you can understand that these individuals will only come forward if there are some reasonable assurances that a full and fair investigation will unsue. ' I strongly believe that a full and fair investigation will uncover one of the biggest violations of the public trust this country has experienced. It is clear that, at this point in t'me, a large segment, if not a vast majority, of the American people have lost confidence in the ability of the Nuclear Regulatory Commission to protect their interest in health and safety over the financial interests of the large utility companies. An impartial investigation of the NRC will be a otep toward restoring the confidence of the public in its government. I know you have to be concerned about these matters, and I want to thank you for your consideration of them. Please let me know when it would be convenient for us to meet. S c ely, __g > /' b lf Sterpen B. Comley k> <% J Executive Director Ence GAO report, Rowley Petition, Shoreham comment, NRC Bulletin 88-05, Seahrook Allegations, Let+.er of Oct. 26, 1987

JulN d ,- We The Peop e. nc., of ti e I nited Statcr "STOP CHERNOBYL HERE" Pressden: R: .a:d Reagan The Th!:e H use

             *:. ' a sv ng:an,     DC

Dear Presiden:

Reagan: Fer the saf ety :! t'.e A. er!:a n pe:p;e, y:u . .s: see me. Tith my a::er .eys, I :an pr:ve tha; the L:::ar Regvla: cry Com-::s:: . 5 being run for nuclear.indus:ry interes:s wh: are pia :ng.:he lives :l miUion.: of Americans in icopar y. In;s has been confirmed to me priva:ely by high-ranking o!!icials within :he NRC. Fee the pa s: year and a ba:!, y:ur s:a ! r.as kep: me fr:m giving you 50 f;rst .and y in!:rt s:i: . Tnen yea r. ave it, ; anow you w!!! find .: alarming and s.o te !ing that you wi ! a:: qui:kty and ce::sively. Through my attorneys, I can prove : hat the NRC has broken the law knowing:y and has covered up its illegal actions consistently, enaMing the rm.aclear irdustry to get licenses for, wsaf e plants such a.: Seabrook in New Hampshire a .4 %shasm,,In,,Neer~ X,ory . a,,s, . .e e ? w .y . . s . .

          .!t is vitally important that you get this infoemation from me, row, to prevent pani: due to e.e unsaf e nuc' ear power plants.

My concern over the need to protect the A.merican people from the dangers e,!

  -       nuclear power plants has led rne to spend a yeu and a half of my time and mece than $160,000 of my money.                                                                                                  ;

On behalf c! n yse;f and fe o* : ::ened A ericans who are memce s cf Te the People !re., this "Te the Pecple" f.ag is paesented to you as a sy.mbc! of our uni:ed stand. As a e .:et :! ,:ve s Task F:r:e s. .:e .?!?, I have f ewnd you :: be a an :! ;

          ; :a: 5:re               :,::--;* e: :: * .a : .'s :g- 1 .: l1.:- :-                              :d. Tr.s is - 1:               j s .ee:e t a r. . - : - :: ..s.: .s : .a:                . . :, :   :.:     ace    .!    A.-er.:a        : 'o.c y 1. :

t g e a.er a :. : s t o ::.'e a r e p .g :: be pt::e::ed ! :m ;te da gers :.!

          *ue: car 7:+er.
          .Vr. Presider.: I kn0 * ?a: :3[t!'er,                  'h e :an end : .*se 0 &* j!*s. I am

r .i::td to :- s f.p:. I ask yes :: l:in me. l l

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     , f>O 8%M                           H+r men                                          No (k N )

Because:we care about Rowley and Y C...

       # //       f(,

We, the citizens of Rowley, Massachusetts appeal to you, Ronald Reagan, the Pn:sident of th to address the following concerns and recommendations that w, the undersigned, have regarding Regulatory Commission, a Federal Agency that has the ability to license the Seabrook Nu located in Seabrook, New Hampshire but involves various towns in Massachusetts herans, of the The reasons for our concerns are these: A. .Our children live two miles outside the ten mile radius but anend a regional school inside the radius. We have been told that we cannot be part of the evacuanon planning 'Ihis also applies residents of Sea View Nursing Home wbo are transferred to a hospital located inside the tan mile B. Regarding the Radiological Errgacy Response Man, Draft 3 4/86. Attachment 10.2 2 which "only those hospital patients and nursing home residents who are A~ mad r~dkally safe to mo to be evacuated. Those patients / residents which cannot be :vacuated should be sheltered in pla (A copy is enclosed.) la our opuuon this not only affects nursing home and bospital residents but it could affect an had an opermios and had a be shalaered in pa c. est day. C. We feel shot me Nacinar Ragulatory e m has boss maghemme in eat making thesnesives saralla

             ~ sad not calhas = or bains up on me is                       in our w . It sesem est esy have apresessed es anciser                   ri-r
  -            imemory very            u but eey have muc ameosessed me impet of es people est may not be ter po r or have emceens for saasty la o r ama.

Thus, we the em-s of Rowley, Massachusetts r+x -- -

A. That you set up a CW* to see if the Nuclear Regulseory Comosiasion is acang respomasbly in

  .            anpassemens and sayug that ihn sadmey and concuens ass being psoporty adesesed for newtey as well u peopae acrou this country.

B. That you ask for a morneorium on the start up of any acw muclear plaats awaiting licemees until and we can be assured that we have the full information back from Chernobyl to make a responsible

   -           decimon to whether we should continue thinbng that nucisar power is a safe alternative.

C. That you remind the Nuclear Regulatory Commismon that this is America not Reesta and they are hued by the people and are accountable to the peopae, not just the people in the nuclear imhistry. We were reminded on the 4th of July of what this country was founded for and we thank you for that. We are seeing that our fr~Anm of speech and freedom of choice is being excreised, bei drne ase= = esp ,me,we j tr7 aern +inmisha.r,pa sismr e ' ene.arnee cudree to sign er perones to sten se b heir et shmir chear.n. TMs is prua.My ese et she i

                                                                                            " and per resere seneremmes.

si : w ueses ese de in me.w - he eer . r spun s>cwtm s!G%f.D sWE tr==== n=== as r.w <*ws a-. r.w a -e e We have the responatality to see that this campaign is completed successfully and we need your help. Pubhc Breedeasedag in San Fremam recently did an intemew with nw as Direcscr of Secause we care a&ost Row YOU tur their "We The Peop4e" senes which identfAed thu issue with the Vietnam uprising where petit 6ons s

      . the war, not government ometals. Our system in Amenca is a good system if only we use it - p4 ease help us.

Wk

                           !F A T ANY T1MF YOU WOL !.DI.lKE FURTHl.R INFORM ATION OR AN l'PD ATE i >N TilK !%1 I . I'l l el M I'l i RI I T() WPlil ')R (' \! I ma:no.S si: A virw

                                                                                                                                                                                                                        ~
                                                            .                    THE WHITE HOl'SE

WWilMiTON , .

                                                                                                                                                                                                                   ;1. .kg.

i . - October 11, 1984 : L

Dear killt ,

I want ycu to knew c.! my apprecir. tion forfor yourmy

                                        .        continuing t'e.ntributions to and suppcrtYour leadership and ccurage h&ve Ada.in'istrr. tion.

beer. dwtvr=in:r.g f ceters ir the progress wr. hr.vt made in the.lart :iw years. i On a s.atter of particular concern td you anc! the

                      -           .               peopic cf Eastern icr.g Island, I wish to repeat                   '                                                                                               ..

Secretary Hede:1'c assurance to you thtt th.is Adminictration does not favor the impositior,of
Tederal Government authority over the objecticns ci state and 1ccal governments in matters .

regarding the adequacy ei ar e,morgency evt.cuatier. plan for a nucient power plar.t such as shcreham. Your ccncern for the safety of the people of Lcng

                                  -                 Island is parc= curs and shared by the. Secretary ar.d rae.

Thank you cgain for .your. support, .I Icek forvt.rd to wrXing with ',,cu in the yer:c ahead. , Sincerely, ,

                                                                    .   ..              .                         &                                  M dh 1

The Honcret.le utilit m Cuney House et hapresentativow k'ashingten, D.C. 20515 1 l l

                       '.i.:.                                                                 .

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                                             . __             .__            . _ _ _ _ _ _ . . _ _ . _ _ _ _            . _ . _ _ _ _ _ , . _ _ _ _ _ _ _ _ _ _ _ .                                  , , _ . _ _ _ - . _ _ l

Uniteo states uenerw accounuum vuac

 .GAO SPECIAL REPORT Office of Special s

Investigations

NOTICE: Further release of this document may not be in the best interests of the government for reasons stated herein. l l l 6 e w. t a ,

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B I l Unitd Statec General Accounting Omec

         )       Washington, D.C. 20548 Omee of Special Investigations April 22, 1988 The Honorable Lando W. Zech, Jr.

Chairman Nuclear Regulatory Commission Washington, D.C. 20555 )

Dear Mr. Chairman:

The U.S. General Accounting Of fice, of fice of Special Investigations, has investigated three matters bearing on the adequacy of th'e Nuclear Regulatory Commission's (NRC) investigative proceedings and practices. - Enclosed is our statement of findings. , i We have provided this report to the requestors: Chairman Morris K. Udall, Subcommittee on Energy and the Environment, House Committee on Interior and Insular Af f airs; Chairman John D. Dingell, subcommittee on oversight i and Investigations, House Committee on Energy and Commerce; Chai rman Philip R. Sharp, Subcomm.ittee on Energy and Power , House Committee. on Energy and Commerce; and Cong ressman Edward J. Markey, Committee on Energy and Comnerce, and

Committee 'on Interior and Insular Af f airs.

           -         As agreed by our requestors, we are providing a copy of the report to you as the Chairman of the NRC.

Should you have any questions regarding the content of this r e po r t , please contact me at (202) 272-5500. Sincerely yours, hO C hs& David C. Williams l Director f Enclosure 1 e

             $                                -  l pg .

J i

'I on June 22, 1987, four members of the U.S. House of
                                          ' Representatives requested that the U.S, General. Accounting of fice (GAo), of fice of Opecial Investigations, investigate three matters bearing on the adequacy of the Nuclear R?gulatory Commission's (NRC)                         investigative proceedings and practices, these members, Cong ressmen Morris K. Udall, Edward Specifically,ilip J.      Ma rkey , Ph                R. Shatp, and John D. Dingell, asktd that GAO do the following:
                                            --        Ascertain if the NRC Of fice of Inspector and Auditor (OI A) properly investigated and accurately reported on allegations relating to the inspection program at                                             Anthe              NRC        Comanche inspectorPeak at that Steam Electric Station (CPSES) .                             ~

Texas f acility charged that he had been harassed,

                              '                        intimidated, and pressured by his superiors to altsr or delete findings f rom his reports.                                                                ,
                                             --         Evaluate the thoroughness of oIA's investigation of an allegedly improper discussion between the. NRC's Executive
                             ^

Director for operations (EDO) and an official of the Tennessee Valley Authority (TVA) . . The discussion concerned a major NRC enforcement initiative focused on TVA.

                                             --          Determine if the NRC properly handled the question of
                                      -                  whether a regulated utility had- uncontrolled access to internal NRC documents. Tnese docaments concerned defects in a Louisiana nuclear plant and were found in the possession of the utility licensed to . construct that plant.
                        '                                 In follow-up meetings with the requestors, GAO                                                                       was asked Therefore, GAO to_ expand _the slop.e_of the wo rk as necessarvm reinvestigated certain portions of each of the three matters.

In summary, we have concluded on the basis of our

  -                                            investigation that the evidence does not support the allegations concerning the inspector at CPSES or the allegation of improper discussions between the EDO at the NRC and an of ficial of TVA.

However, as discussed in detail below, our work revealed a number of serious deficiencies in thet, co3dMct,_of these._investigAtfons by ~ the M . We ~ nave confu'ded't' hat the allegation concerning access by a-regulated utility to internal NRC documents was also 5 '* imprope rly handled.

s. _.

BACKGROUND The NRC is responsible for licensing and regulating nuclear f acilities and materials, and for conducting research in support of the licensing and regulatory process, as mandated by the Atomic Energy Act of 1954, as amended. OIA is the internal investigative arm of the NRC and is charged with investigating misconduct by HRC employees and verif ying the adequacy of NRC operations.

      . , _ _ . _ , _ . - . ~ _ _ . _                 . - _ . .    -

_ _ _ _ . , _ , - , . -.,.__,_--,_,.___,_,,...--_.-,_-,._.._____y,_,c__ , .,-_.

l l l j l ', l On April 9, 1987, during a hearing conducted by ed the to Senate Ccmmitte'e on Governmental Af f air s concerning internal the ne i 1cgislate an independent NRC inspector general, allegat ons curf aced that reflected on the adequacy of the NRC'sAfter House the Senate invostigative processes.Zech, Jr . , and f our membe rs of the U.S. view of the Choirman, Lando W.of Representatives called for an independent' re clicgations, in July 1987 GAO l

                                                                                                                                                  'l In response to the Cong ressmen's request, This report                                                                               I initiated an investigation of the three cases. incidents, the NRC's handling
     . includes the histories of the threegative anallskt of the NRC's of the matters, and GAO's disposition of the matters.                                                                    .

METBODOLOGY llowing :

                'GAO's investigation included a review of the fo l tions, the NRC's policy documents, applicab'le lawe, regu a I

and standards; relevant NRC investigative reports; d tters thousands of pages of transcribed interviews ancong

          --       relevant DIA case files                        ~

l pertinent NRC correspondence with various congressiona committees; and by the other related documents, such as the report prepared 7 Comanche Peak Report Review Group. ' i ws GAO supplemented its evaluation of documents - \s____~ with interv e-of individuals involved in the three matters. CASE la COMANCHE PEAK STEAM ELECTRIC STATION Results in Brief ' Although OIA's report might have reached the proper d ' conclusion with respect to allegations of harassment an intimidation of HRC Inspector Shannon Phillips, es. f Inspection GAO found Phillips' se rious problema_with_.QJA'_s investigativeEocess aflegations called into question the handling o 2

                                                , _ _ _ .   - -    _,,_-_,-__-__._____,_.-___-,.--..,_---,y                -

                                                        *r N

Y / Amona other things, GAO ho could have findings by HRC Region t IVi managersh__in, alleg ation s . e rgirwaeveral witnesse s

       'found that OIA             rspective to Phillips'                support the OI A Furthermore, GAO found insufficient evidenced to added       a needed                                                  with the sults were conduct of the OI A investigation er that the reinve incorrectly reported.

Background f NRC Region In March 1986, Shannon Phillips, an employee oAsselstine and IV in Texas, telephoned NRC Commissionernagement ~ James i of its Station. outlined allegations concerning Region h cting IV's mainsp Phillips serves as the Senior Resident Inspec at CPSES. Director of OIA, Asselstine reLarred the allegations to t e aGary Phillips' allegations were serious and warrani i trative leave onduct in the pending completion ofConnelly an investigation returned to her with of her c(O handling of an unrelated matter. 1986.) In agreement Mulley *o duties as head of OIA on March 28, Asselstine, Eddles assigned CIA Investigator GeorgeAdditionally lb ed . ,' conduct the '.nquiry.would be conducted under oathPhillips nnon and beundertrans, e on In March 19, 1986, Mulley interviewed . lowing oath. the interview, Phillips made the i 311egationst We ste rma n , 2/11 that made a statement about Inspection Report 84-3 Phillips considered threatening. tion d

              --       Westerman di~rected him to delete f rom draf t Inspeca Re port 85-07/05                                           i analysis that Phillips had performed at the d recThe analys former supervisor.

relating to the frequency of unresolved quality assurance issues. -r:0 c a "Se r t.* nspection ; Westerman had harassed and pressured himins Re po rt 85-07/05. was l

                 --      Region IV's data on NRC Form 766, Inspector's                       tistical       Re inaccurate.                                                            t system designed to capture, maintain, and re activities.

Westerman made improper statements for a regulator. 3 l O

l l Westerman directed him to destroy draf ts of Inspection Repvrts 85-07/05 and 85-13/09 because a Freedom of Information Act request had been received. ' Westerman had pressured and hsrassed him over technical differences ou draft Inspection Report 85-14/11. Westerman improperly handled the allegations of a consultant group working for the utility. Westerman had pressured, harassed, and intimidated him to change draf t Inspection Report 85-16/13. f Eric Johnson, a Region IV manager, criticized him for how he i had written a memorandum concerning possible. wrongdoing i relatirg to fire seals. , gj/ Johnaot. told the Senior Resident Insgetor at the Fort St. V:ain facility in Region IV not to write certain violations and to downg rade others. ~ Phillig s f urther claimed that his disag renment with Region IV mar agement's ht.'dling of his allegations resu}ted in his being harassed, inticidated, ano isolated by Regiun IV m:sangement. 1986, Mulley, with Between March 19, 1986, and November 26,staf f, investigated the the assistance of technical and support allegations and prepared a 47-page teport with attachmentsThe report, en d9 tailing the findings. to the Comanche Misconduct by Region IV Management With Respectissued on Hovember 26, 1986, as Peak jttemn ElectricThe Station, was report concerned the allegations made by OI A Re port 8 6-10. Pnillips and was divided into the following three issues: (1) Did Region IV management harass and intimidate inspectors to pressure them to downgrade or delete proposed inspection findings at CPSES7 (2) Was the Region IV Quality Assurance Inspection Program at CPSES inadequate? i (3) Was data documented in Region CV's NRC Form 766, Inspector's ! l Re po rt , ineccurate? In referent to the first allegation, the CIA report

                                            ?.>>' ficiings were downgraded or deleted f rom h

concluded that 'inspectie.i rs p cts ans ^. tat these changes we re made at t e draft - 2 / manf s a .1, Mulley's technical advisors direction of Res * ' : Va, .' higion IV management regarding questioned fhe e . + - r iver , 01A's __ investigall on f ailed _ certain inspect n o sv supFrvTso. . We ste rman , - to substantiat! .~ _ . - i 1

                                                                                                  ..-                              )

                                                                                                                \}N h

intentionally harassed or threa_tened_ Phi Qips in connection with h M E3Fngs. - The OI A report generally concluded that the second and third allegatier s were accurate, and reviews performed by the technical assistants we re used to buttress oIA's conclusions. In OIA Report 86-10 had considerable impact on the NRO.in Janua r e s po n se , 5 of a special review group comprised 6f senior NRC of ficials This to b address the specific issues raised in the OIA report. issued its te review group, the Comanche Peak Report Review Group,ing pty i report on March 12, 1987, which reflected the follow E conclusions: None of the draf t findings that had beepMa(dverse ed or ff deleted were significant in terms of apy ifect a -

Oos impact on plant safety. Region IV management acted appropriately in downgrading or deleting some of the inspectors' 34 draf t findingos however, part of the problem could have resulted f rom the Regional inspectors' , f ailure to fully develop the issues of concern. management shool,d have provided the inspectors with guidance to properly focus and develop these items, rather than deleting them.

           --       There were previous gaps ,in the Region IV Comanche Peak                                             -

Quality Assurance Inspection Program in relation to 1986 requirements, but the current augmented review and inspection ef fort at that location compensated for those gaps.

            --      The Form 766 data base was not used in making safety decicions, and its accuracy, completeness, and timeliness                                                 ,

4( we re not adequate for. many needs.

            --       Some f actors that came to light in the OIA investigation and its af te rmath might have implications for other facilities.

On April 9,1987, Mulley appeared before the Senate Committee on Governmental Af f airs and testified concerning the conduct of the Comanche Peak investigation (OIA Report 86-10). , In him testimony, Mulley assertec the following:

             --       He limited the scope of the Comanche Peak investigation                                                 l because of pressurt from EDO Victor Stello and OIA Director                                              l Sharon Connelly.
              --      Ris draf t of the OI A report was modified by Connelly as f ollows :

5

1 She removed tha conclusion that Region IV managers acted inappropriately to limit violations assessed and

              '                     that Phillips was harassed and intimidated in an ef fort to get him to downgrade or delete his inspection findings.

She focused the report on the technical' issues underlying the violations, an aYea ' outside the expertise of CIA. She removed quotations of Region IV personnel that substantiated the demonstrated the conclusions stated lax enforcement above and attitudes of Reglen IV manag eme nt . I

             --          .The decision to distribute the CIA report would make it                                           ,

extremely dif ficult to get NRC employees to cooper' ate in - < ongoing investigations. . ,

             --             Phillips tried to inform the NRC that Region IV                                                  -

l

          -                demonstrated an attitude of trying to help the util'ity obtain an operating license for Comanche Peak.                                                     ,
                         'On October 8,1987, the Senate Connittee on Environment and                                             i Fublic Works, Subcommittee on Nuclear Regulation, held hearings at which Mulley again ~ testified with reference to the Comanche i

Peak caca. ' At that heari'ng Mulley stated the ic11owingi l

              --              All of 'the f acts and information developed during the investigation were in the report.
               --             He disagr'eed with the OIA Director, Sharon Connelly, about
                           'the way in which 'the report was prepared, particularly the                                             i
                                                                                                                                    ]

overemphasis onychnical ^ issues, an areqi '. which.41A

                                                                                               ~
                       . Taqked esperrite,.      w i
              '--             He was more interested in the treatment of Phillips than he                                           f was about the technical validity of the inspection findings.                              ,
                                                                                                                           \

j

                --             He believed that Phillips had been harassed by Regio:t IV                      SkMD 7
                                                                                                                          )'         ,

4 management. The staf f of EDO Victor Stello was qualified to address YII M i - technical issues and decide the validity thereef. i g $ ,pbD j' i ) -- He disagreed with some of the changes Connelly mades

'                               hoke /er, he did not think that anything was wrong, illegal, or Simmoral" about what she did. The report                was different f rom the way he would have writtea it. Stello wanted the report out because he wanted a document with which to work.it In an effort to respond to the EDO, Mulley started to put together quickly.         He decided there.were certain issues 6

1

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'.,- . ._.. .           . - _ ,                       - - - . _ - . _ - . . - ....._-._---__-------.-.-_------.1

that, at the time,. did not need to be included in the report. No one attempted to alter the content of the r e po r t. , CAO's Investigative Analysis nves .igation of allegations that GAO determined th'at OI ' findings proposi _hy d NRC NRC managers in Region'I mishandccurates howeve r, the 1

                       . Inspector Shannon Phillip                                                                                                                  AA ,

investigative processgs}psed Weby OIA were questionag1_e. v p-In . support of the proposition that Phillips' findings had' f

                                                                                                                                                          / V been improperly altered or deleted, CIA                                                  -    Investigator Mulleyf o rme r Rec ion TV ma relied,.in'part, on statements by                                                                                       When Regi"on IV management had a lax enfor :ement attitude.
                      ' interviewed by GAO, however, this t sme individual said that the                                                                                               '.

OI A investigator misunderstood his naaning and that the point he - was trying to make was that there wer e philosophicalbe before it _dif f e renets about how well developed a finding mustReg.on IV managers Weste ,' should be cited as a violation. Johnson insisted that violations be cited only after the findingswhereas some i , we re f ully developed and suppor table, managers believed in citing violations and placing the bnrden of prcof on the utility to disprove them. In' contrast to his testimony of April 9, 1987, at the Senate hf J Committee on Governmental Af f airs hearing, Mulley told GAO that Ig it was only his ' opinion" that Phillips had been harassed and ph[d intimidated and that it might not have beeQone inteptionally. P( n Mulley could provide no direct support f or his-trolitentionTat 19 failing to (b 1$pd " Phil11ps had suf fered harassment or intimidation.Mulley uninttntionally f

                                                                                                                                                                      )Y gg/

interview other Region IV supervisors,GAO interviewed other NRC skewed the harassment question.

                 -        personnel who pravided, a hainneing perspective                                               f unction of_on      Phillips' regional

l allegations and .the prope r ove rsightPhillips stated he was being harassed and officials.

by his supervisors because his supervisors findings were advised critical that of the this was utility. However , Phillips' not the case. They stated Phillips f ailed to f ully develop his /h j findings and/or present them clearly in writing. GA0's review indicated that Mulley was correct in asserting $ OLA should not have focused its report on the technical issuee. , __ -3) fven with tecnnical assissante, oIA Aacked the expertise toIf OIA found a need

'                          resolve such issues in a competent f ashion.                                                                                            it I

to challenge the technical judgments of Region IV management, 7

                   -        should have employed NRC's established procedure for resolution ~ p).y M of dif feringp4fessionel-opinions.                             ~-                                                         7 l              -                                                      w-                                                                assertions      _that
                                           ,Tinally, GAO was unable to verify _Nn11*y's (1) he had been pressured tU-TTmit the scope and otherwise l

i expedite completion of his investigation cf the Phillips matter l 7 1

i l

                                                                                                                                     .                l 7        l and (2) his draf         t report had been substantially altered by                                                    1'<-        l Connelly.           Mulley   testified before ths Genate Committee op                                               4#

Environment and Public Works that although he mighthe have did not g(tg , disagreed with some of the changes to his report, A l think there was anything wrong with the changes made by th GAO r eviewed alI"' Director. pressure _ on Mulley concerning the report. review, and ; ($2 draf ts lavailable' of Mulley's report and interviewed thepr andiprl _ apprgwal-p ocess. No evidence was developed tothe review and editing ' aubstantiv c anges we re made durin , 48 a s. 74Wfrfo With regard to the distribution of Mulley's report, GA0 . found no basis to question the conduct of the EDQ who explained that the Commissionimportant management in addressing authorized the such matters, distribution as health to andassist NRC '. Witnesses told GA0 saf ety issues requiring immediate action.' l they were disturbed about the distribution of the reportcon i I level management of ficials Moreover, andnone to theof the principal witnesses witnesses.H b'een subjected to reprisals. ' '

                   ' identified in the OIA report or transcripts asked for or received a pledge of confidentiality f rom anyone in,0IA, and Mulley voiced                                                        e no objection to the release.                                                                                             e CASE 2:       IMPROPER TVA DISCUSSION Results in Brief GAO's investigation revealed that DIA did not thoroughly

investigate an alleged improper discussion between an Nnc i official and an official of the Tennessee Valley Authority l l concerning a major NRC enforcement initiative focused on TVA.

j

                    " OIA inadequately planned its investigation and f ailed toGA0                                                                    l 1 interview one of ths two parties to the conversation. learned
                       , investigation of this matter.

the NRC Although the conversation was investigated by CIA,A report of j

I does not prohibit or discourage such conversations.such con was required at the time of this incident. Background ! a member of TVA's Nuclear Safety l On December 19, 1985, Review Staff (NSRS) briefed NRC Commissioner NSRS'James position Asselstine on contrasted 4 l

!                        the condition of the Watts Bar Plant.

8 J l l

sharply with the TVA'r, prior certification to the NRC that theIn the briefing plant seve ral wastechnical ready for f uel in atteas loading. which they believed deficiencies existed, which indicated to them f undamental weaknesses in the Watts Bar quality assurance prog ram. NS5S' perception that the plant wa's not ready for f uel loading prompted the NRC to request that TVA of ficially By letter datedcertif y its position on NSRS' technical concerns. January (NRR) 3,1986, the NRC's Of fice of Nuclear in 10 CFR Reacto the quality assurance program met the. criteria outlinedThe NRC's Part 50, Appendix 8. response and 30 days for "information The on an item-by-item Director of HRR, basis supporting the TVA corporate position." . Harold Denton, subsequently ag reed to extend the with staf f and because the new head for of dutyTVA's nuclear until program,13, 1986. January Steve White, would not reportWhite responded to Denton of NRR with TVA's On March 20, 1966, position perception. and addressed each of the issues underlying the N for hand delivery by a TVA of ficial, he determined a need toWhite contacted hington, clarify one section of the letter.while he was enThe route and letter directed him t was D.C. , of fice where the change was incorporated. subsequently delivered to the NRC. on April 7,1986, Ben Hayes, Director of the NRC's Of fice of Investigations (0!), informed then-NRC Chairman Nunzio llo,Palladino had that NRC's Executive Director for Operations, Victor Ste been everheard discussing TVA's response to Denton's letter with Steve dispatched. White on or about the time that the TVA respnse wasOI is l allegations of intent,ional violations of regulations by At licensees ,. pe rmittees , applicants , contractors , and vendors .P the Chairman's request, Rayes informed her that NRC's Director of CIA, Sharon Connelly. the Stello-White conversation had been overheard b OIA Director Connelly decided to investigate the matter and assigned the case to fogan Keith Logan, interviewed thenHayes CIA's Assistant on April Director 11, 1986.

         ; for Investigations,
         / po Theint s :

transcript of the Hayes interview reveals the f allowin i OI was irvestigating a possible material f alse statement ~r prog r am made ir. rbruary 1985 by TVA's former nuclear ; manager. 9

                        '                            -    - _ . _ . _                 "'~F---~,..-

I investig ation. Denten l

            --         In the   course     of    OI's false statement was interviewed and advised that on or about March 20, 1986, while he, Taylor, and Stello were together in an NRC vehicle, Stello had a telephone                     conversation with White Appendix 8, matter.

about the 10 JrR Part 56 l Taylor, in a later discussion with Hayes, confirmed that the conversation had taken place and indicated that he was uncomfortable with the conversation.

              --        On April 7, 1986, Hayes advised Chairman Palladino about the                                        '

Stello-White conversation, > i The chairman indicated that he wanted Hayes to discuss the l matter with Connelly of OIA. - r

               --       Hayes ' informed Commissioner Asselstine about the Stello-White conversation in the event the issue came up in the Commissioner's forthcoming visit to TVA.               ,

Following Logan's interview of Hayes, nothing more occurred 1986. On that date, in the o! A investigation until June 6, Asselstine asked Connelly about the status-of the investigation e during a briefing 'she was making to the' Commission on unrelated In response, Connelly(erroneously stated that CIA activities.to the 'cenversation had been- intery14wed and the witnesses Fourthat days I stello would be interviewed within the next two weeks. y later, Connelly corre:ted the record to show that neither l witness had been interviewed, the case had been reas > i be interviewed on June 10, 1986. i Ward interviewed Denton on Jur.e 10, Taylor on June 16, and 30, 1986. On August 26, 1986, Ward telephoned an Stello on July , attorney Alcot, in'the NRC's Of fice of General Counsel, Sebasti ! Aloot stated that, based on the f acts as presented, there was no , apparent conflict of interest or impropriety on the part of ;

r Stello. l i Two days later, George Mulley, who in June 1986 had been l { appointed CIA's Assistant Director for Investigations, signedThe OIA } Report 46-30, and Connelly transmitted The report it to the Com discussed TVA's Appendix B response with White. j concluded, "There was no information developed during this , j! inquiry to substantiate any impropriety on the part of Stello The report wasg during his telephone conversation with White." \

correct in its conclusion; however, OIA's method of having b 10 1

4 hey failed reached such a determination was questionable imprope since r t to l'nterview the second party of the alleged conversation. in preparation for hisings, testimony On April 4, 1987, Mulleya wrote a long as it at memorandumthe Senate Committee explaining why theon Governmental investigation rtook e po rtas , heAf saw f no airs hear did to complete and why, in' reviewing the draf tMulley's h April to memorandum stated reason he wastonot interview involved Steve withWhite. this investigation during itht the e l July 1986 time f rame because of his preoccupation wAccordingly, the Comanche Peak and other -investigations.t explain why the Stello-

               . memorandum indicated, Mulley could no                                                   plete. .The  white report 4
       *      . White investigation had taken so long to com~

memorandum reported that Mulley reviewed the the stello-regarding

and "noted no conflictconversation; actions." the only point in dispute seemed to b propriety of...(Stello's)did not discern a need to interview ificant stated that *(Mulley)

(White) . . .because he would have provided no new sign ' info rmation regarding (Stello's) . . . actions.' GAo's Investigative Analysis i to l determine the propriety o'f the interaction ' betwee l principals and to evaluate the On thoroughness March 14,'1988, of theCIA NRC's s Office > investigation of the matter. to Misledd the i

      \' of                      Investigations issued a report' entitled Possible Willf ul Attempt by TVA Manag ement Plant                                                                                       986, I

NRC. made a material f alse statement in his March 20,1beyond the scope ' ~ certification letter to the NRC. , Because it wat "755 of the request made of GAO, GAO did not evaluate 1986, the OIHow _;. investigation or report. OI interviews that were relevant to White's March 20, j conversations with Stello and Denton. GA0 concluded that OIA's investigation of the allegedit w

            *I l

l improper conversation between Stello and White CIA f ailed to determine at was n t ' s uf f iciently_the r ::;h. h to l investigating, e.g., 'there was inadequate ef fort devoted 1 l determining the nature of what was said andFurthermore, the impact tenatic that t e I r conversation had on the actions of either party. OIA f ailed to pursue the investigation in a timely and The investigation should not have been initiated f the rule, sys i j manner. without a proposed plan of action and specificat onThis o was ! law, or regulation that might have been violated. 11 i s . - _

1 l

I evidenced during GAo's interviews of Wa rd, Mulley, and connelly since nLt one of them could provide a convincing justification inpr ope r f o r therr f ailure'to-ht.orf'iev-Whitr about, the allag v

                          /                   % .-                     \/

During GAO's interview of White, h.e denied having sought White statedor obtained improper pre-approval for TVA's position.that White the purp TVA's letter was fully responsive to the NRC's request.it White was his discu asserted that that led him to make a clarification in TVA's response. made contemporaneous notes of his conversations, which heThese 1 provided to GAO. diary for this period, add credence to his o.' "'rsion cials.of what transpired in his conversations with NRC When interviewed, Stello and Denton's transpiredaccountinofthe the events coincided telephonewith callsWhite's version of March 20, of whatWhite asserted that he was 1986. , not trying to discern if TVA's position was acceptable , but to assure himself that the letter White wastold fully GAoresponsive that his change to the toNRC's the l request for information. letter did not reflect a substantive change in TVA's posit but only served to clarify a detail that .Denton considered impo r tant . GAO was not able to develop any information indicating that stello, Denton, or other NRC of ficials coached White on what position TVA should adopt to assure f avorable action by the NRC. GAo learned in its interviews of Denton and

   \       Taylor that their discomfort with the stello-White conversation
          'was only because they felt White was               going around 1Aest in dealing
                                                          -~s-with Stello.

prohibits employee An NRC regulation actions that might (10 CFR 0735.49a) result in, or create the appearancel preferential treatment to any person or making a governmentUnder NRC policy i decision outside official channels.to the time f rame in question, GAo beli did not prohibit the type Untilofrecently, discussions the NRC that apparently policy with took l l P ace in this case. reference to this regulatory provision was permissive, 1987, as evidenced by the commentary of Chairman tech on July 10, whecein he stated "so long as it is understood that any staf f discussions do not constitute He f the staf urther f's formal stated in his judgment on"The commentary, the l merits of any issue." j agency views preliminary discussions and informr'. pre)im part of all concerned of the issues sur rounding a potential request for regulatory action." 1 l 12

                                                               ~        ~                                                                            ___

l Accordingly, GAO's investigation substantiated 1 l t l that NRC the Stello-White conversation at the time indid not contravena re evan regulations as applied question.

CASE 3: LEAK Or NRC DOCUMENTS . Results in Brief f GA0 concluded that the NRC did not properly address the internal i issue of whether a regulated utility had access to itsinvertijation of the matter wa d o.cume nt s . Commissioner Roberts' bu none of the A Kommissioners significant f actorseemed to havt.had an explaEfng why

                        ~
,              ve      ry   limited aporeci n. inn c
                                         , I't tI  ialTalit.

the matter was not property addressed was the failure of the NRC to refer the matter to OIA at theyet 3_a required by NRC g uid elir e,s . Dackground on June 8,1983, James Joosten, asent technical Richarddesistant DeYoungto , an then-NRC Commissioner Victor Gilinsky,d received f rom a free-NRC of ficial, documentation that he ha lance reporter regarding alleged DeYoung safety se'rved problems as Diractor with aofnuclear the powe r plant .in Louisiana. The memorandum NRC's Of fice of Inspection and Enforcement. h eporter's

               , transmitting the documentation called attention to t e rconc
               . ves'sel III plant.

at the Louisiana Powe r and Light Company's (LPLThe m .

              ' the . reporter that raised que stions about' possible collusionJoosten's mem between LPL and NRC inspectors.

DeYoung assure that the reporter's concerne be reviewed objectively. Joosten sent copies of his meanrandum and attachments to Steve Chestnutt, technical adviserCopies to Commissioner of the Thomas M. Roberts, and to other NRC officials. , Joosten memorandum we re publicly released by NRC three months l later pursuant to a Freedom of Information Act request. J l In March 1985, 01 Invettigator Bill Ward, while working on l an unrelated case, discovered a copy of the Joosten memorandum Attached j and attachments in an LPL file at the Waterfort plant. 1983, from to the material was a cover memorandum dated June 15, George White, a vice president of Middle South Utilities, theThe W e holding company for LPL. John cordaro, an executive of the company, and re i 3

                                     ---         - - - - - - , .   ,       .n------.--,   - - _ - . - . . . _ , . , - , . . -            . , - . .             ,   .,-.,.n--      . - . , . - , - , - - -

              " Attached is a memorandum which I have received f rom sources inside the Nuclear Regulatory Commission regarding Waterford Quality Assurance matters. This memo is for your information but I would hope that you limit its distribution to protect the source within the NRC."

on March 13, 1985, after conferring with his staff on what to do about the discovery, 01 Director Ben Hayes took a copy Following a of the documents discussion withto his then-NRC Chairman legal advisor on Palladino. what actions the discovery warranted, Palladino decided to make Commissioner Roberts aware of the matter. Palladino did so because the copy Hayes provided office file copy. appeared to have been duplicated f rom Roberts' Af ter obtaining the documents f rom Palladino, Roberts assembled his staf f and asked each member if he or she had leaked fj IA'gg, the documents. Roberts tape-recorded the staff interview. d,L ,' gj ), During the taped interview, none of Roberts' staff After acknowledged the meeting, L having given the documents to George White.staf f established that the&r Robe r t s ' Joosten cJ% t released to the public on September 23, 1983, pursuant to a Freedom of Information Act request. On March 14, 1985, Palladino sent a memorandum to Ben Hayes informing him that NRC's Reorganisation Plan No.1 of 1980 made it the responsibility of the individual Commissioners to supervise personnel in their immediate On of fices Marchand, 15, therefore, 1985, Hayes the matter was Roberts' to deal with. and Ward met with Roberts and his legal advisor, James M. Cutchin. At Roberts' . request for all documents related to the , jfk(- matter, Mayes turned over to his copies of the White memorandum q6' t' his discussions with Palladino. In his discussion with Hayes, Roberts made a remark thatthe 1 l Rayes and Ward interpreted as an expression of concern that matter might become an issue in Roberts' upcoming confirmation hearing. The matter did not arise in the June 18, 1985, confirmation hearing; however, it surf aced just prior to the Senate Committee on Governmental Af f airs hearing on April 9, 1987. On March 3V, 1987, White prepared an affidevit for the Senate Committee on Governmental Af f airs staf f. In it he stated the following under oaths

         --     The June 15, 1983, memorandum attached to the Joosten material and bearing what appears to be signed        his signature, by his was, in f act, dictated f rom Washington D.C.,
                                                                              -                                             l i

14 1

"~~

secretary, Peggy Balsamo, in New Orleans, and was not the type of memorandum he was accustomed to sending or Te n"iv ing . He had no recollection of preparing or dictating the memorandum or receiving the attachments thereto. l NRC He did not recall ever having had possession of interna documents or information regarding Waterford dle nueltarSouthplants that would not have ,been provided or lef t for Mid Utilities, or made available for the public in the normal cour se of business. ' l Ce did not recall ever having had a source or' havinghin heard of the a source NRC, .and he for didinternal NRC not consider anyore documents then or former ory information l employed by the NRC to be a source for such documents or inf o rmation. At the April 9, 1987, hearing, Senator John Glenn, the i of

    -    Committee Chairman, questioned Roberts about his investigat onRoberts how he had             Whitenotobtained_the questioned White          Joosten  materials.

about the matter but satisfied s himself each of them,that thathe was note.-minating one in his investigation his office wAt the ithout had hearing, leaked hrving dete rmined the source of the leak. Roberts testified h ! Falladino and Bayes Radigiven him. because he wasA'somewhat paranoid" and thought someone might be day af ter the hearing, Roberts notified out to get him. Senator Glenn that he had locate 6Senator the documents Glenn i forhe had , previously testified to nay1Tfft!WWed. subsequently ref erre consideration of possible criminal prosecution. an NRC management meeting was held inthe ' On April 14, 1987, i which the of fice of General The General Counsel was Counsel replied j t to requested Commissioners and their offices.that OIA had authority to investiga l the judgment of the Commission. During testir.ony before the Senate Committee on Environment lly and Public Works in October 1987, OIA Director Sharon Conne i i rs l was asked if, in cases of Connelly alleged respondedwrongdoing that shei by the C refer thethe thought matter to OIA orhad Commission not.determined that all such allegat ons were to be referred to OIA and, if not, to the FBI. <. 15

GAO's Investigative Analysis Without determining how NRC documents came into the possession of Middle South Utilities, GAO has been unable to ascertain whether any federal law or NRC regulation wat violated. In his af fidavit to the Senate Committee on Governmental Af f ai r s , Wh i t e d id n the June 15, 1983, memorandum that transmitted the materIII to LYL7- GAO interviewed White on January 29, 1988. In this interview, White "seemed to recall" that he had dictated the memorandum and stated that he employed words in it containing a certain amount of 'puf fery*

                      . des igned to imprean_his.upe riors. White stated that in
                       ~r e t r o spe ct, had he seen how the words looked on paper, he might
                               ~

not have signed the memorandum. White told GAO that he did not , <e remarber where or f rom whom he obtained the documents, except to \tb' say that it w3 Loot f ry = ecur.ca.w=S "ini n the. NRC . i Additionally, White advised GAO that no of ficial of LPL or Middle D South Utilities who was an addressee of his "confidential"

           -           memorandum acknowledged having received the materials.                                       g) fg ' ["'

GAO's investigation verified that no LPL or Middle South Utilities of ficial brought to the attention of the NRC an employee's assertion of the existence of a "sole" within the NRC. White's memorandum, no matter .how self-serving, demonstrated that a regulated utility secured unauthorised access

               '       to NRC documents. The ability to obtain such materials could
         -     s       impact on the NRC's enforcement program, licensing functions, and regulatory pr ocedures.

GA0 determined that Roberts did not concern himself with the , question of how White obtained the NRC documents, but only addressed the issue of whether someone on his personal etaf f eight have been the utility's avenue of accer s. In this instance, Roberts dismissed the leak implication by simply asking his small staf f if any of them provided the documente to the utility. By doing this, Roberts ignored the potential of a broader problem in that a utility official claimed to have a

                       ' source" within the NRC.

Chairman Palladino's referral of the matter to Roberts for handling did not oblige Roberts to adhere to relevant investigative standards. Palladino, like Roberte and the other commissioners, apparently believed that the referral and disposition of this matter was an exclusive delgation of 1 investigatory authority and discretion. An April 1- 1987, I opinion f rom the NRC's General Counsel appropriately points out the error in this assumption by distinguishing between the j ' f unctions of supervision and investigation. 16

4 Prior to the April 1987 Senate hearings, Roberts learned , that his handling of this matter would be subjected to scrutiny. 3 On the day prior' to his testimony, Roberts met with a former NRC General Counsel. In this meeting, Roberts advised the former NRC

                  -of ficial that he knew this issue would surf ace at the April 9, 1987, hearing.                                 ,

The less-than-professional handling of the matter by the

NRC, combined with Roberts' cursory investigative ef fort, might well have jeopardized any possibility for determining where or how White obtained the NRC ' documents.- When the issue first surf aced in 1985, a properly conducted investigation, including an interview of White, might have~ provided NRC with the identity of "the source within the NRC."

GAO'S INVESTIGATIVE OVERVIEW GA0 was advised by the requestors to expand the scope of its work as hecessary to cover unforseen but related matters that might develop. During the course of its investigation, GAO noted appar'ent problems with the NRC's investigative capability. The NRC and the .U.S. Department of Justice (DOJ) have failed to execute a Memorandum of Understanding governing the referral of possible criminal violations stemming f rom questionable actions of nuclear licenseen. Critics have cited such cases as the D.C. Cook, Three Mile Island, and Fermi cases as examples of the NRC being too cozy with the industry it is charged with r eg ul at'i ng . In each of these cases, allegations surf aced that , NRC of ficials engaged in actions that adversely af fected the

                   ' potential criminal prosecution of the concerned uti?.ity.

The Senate Committee on Governmental Af f airs hearings revealed deficiencies in the NRC's investigative programs and led ) the Committee to report, "0I A lacks authgIltye. competence and i nd e pe nd e nce ." GA0's analysis of the comanche. Peak matter ,, suggests that a supervisor-employee conflict was elevated to the highest levels of the NRC. The matter was raised to such levels because OI A f ailed to provide NRC management with a proper - i perspective on the matter under investmgation. In another instance, CIA f ailed to understand the basic issue that they were g investigating, thus they were unable to properly serve tha needs of the ageney. GA0 conducted a review of several closed CIA investigative case files. This review found that DIA routinely initiates investigations without first establishing a threshold ; Connelly acknowledged fo r acceptance. When interviewed b{aGAO I this to be true. Additionally, GAo rev,iew of CIA records f rom l 1984 to the present reflects that 01A s has not successfully presented a caae for criminal prosecutl'on. 17 l

 -                                                                                                                         l

l NRC manag ement is f aced with a probism in which its two ) primary investigative organisations, OI A and 01, demonstrate a mutual lack of trust, respect, and cooperation. This is evidenced by the 01 D! rector's involvement with the matters GAO i r ev i ewe d . The OI Director advised that when he learned of the ' alleged improper conversation between the EDO and a utility of ficial, he did not make a direct referral to CIA, but instead took the inf ormation to the Chairman. In the leak of the "sensitive" document matter, the OI Director stated he brought the information to the Chairman, not to OIA, because it concerned a Commissioner. Appropriately handled, both matters should have been referred to OIA for evaluation of wrongdoing.- OIA Director Connelly's statement that she is suspicious of .the nature of any investigative referral that she receives from oI f urther demonstrates the lack of cooperation between the two NRC investigative offices. J These three issues suggest a need for the NRC to evaluate its investigative capability. The IIRC should assure that its 1- investigators conduct their work in a competent manner using professional standards. Accurate , complete investigative findings are of ten of major importance to WRC management and the Department of Justice. When investigations focus on criminal matters, the NRC must assure that evidence is properly gathered, safguarded, and ref erred to the Department of Justice. The NRC should continue to support the Jt;tice Department throughout the investigative and adjudicatory period. The NRC should assure t'* that its two investigative of fices work together with a high ! level of coordination ar.d cooperatiori. Their respective missions H complement one another and of ten overlap considerably. This fact requires strong close professional relations. Lastly, the WRC l should develop and enforce a strong, clear policy directing the i manner in which investigations are initiated, conducted, and referred for judicial or management action that will assure independence and professionalism. ', The important mission and critical safety role of the NRC l' require that it possess a first-rate investigative capability l with resources that will assure the NRC's abality to perform its l f unction in a professional, competent manner. i l i j (600028) i () i t W p;r= 18

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Dear Mr. Comley:

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Dear killt ,

Dear Mr. Chairman:

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