ML20023D138

Advises That at Howard & SS Marello Do Not Object to Selection of CF Braun to Conduct Third Party Investigation of Charges Against Zack Co,Subj to Listed Conditions.Related Info Encl

ML20023D138
Person / Time
Site:	LaSalle, 05000000
Issue date:	08/13/1982
From:	Devine T GOVERNMENT ACCOUNTABILITY PROJECT
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20023A480	List: ML20023D030 ML20023D031 ML20023D032 ML20023D033 ML20023D034 ML20023D035 ML20023D036 ML20023D038 ML20023D039 ML20023D042 ML20023D046 ML20023D055 ML20023D066 ML20023D138 ML20023D140 ML20023D145 ML20023D146 ML20023D147 ML20023D172 ML20023D181 ML20023D188 ML20023D191 ML20023D196 ML20023D209 ML20023D213 ML20023D214
References
FOIA-82-366 NUDOCS 8305190292
Download: ML20023D138 (16)

Text

_.__

e i.to . .- .

GOVEANMENT ACCOUNTABILITY PROJECT institute for Policy Studies 1901 Que Street. N.W. Washington, D.C 20009 (202)234 9382

. August 13, 1982 Mr. James Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

On behalf of Mr. Howard, Ms. Harello and myself, thank you.for the opportunity to participate in the August 11, 1982 meeting in which Commonwealth Edison Company (" CECO") proposed C.F. Braun and Co.

("Braun") to conduct the independent investigation and corrective action program on the design implications at LaSalle from the charge.s against the zack Company. Your action to invite public participation at the meeting, and to solicit public comments, was a healthy step. It adds legitimacy to the third-party investigation.

We commend your initiative. Mr. Davis informed me that the enc-losed comments on behalf of Mr. Howard and Ms. Marello could be delivered on Monday, August 16, 1982.

Since the meeting, GAP has communicated with technical experts, public interest organizations, and the Atomic Industrial Forum to obtai'n references. We also read all references to Braun in the Nuclear I Regulatory Commission ("NRC") Public Documents. Room ("PDR"). .On the basis of this review, Mr. Howard and Ms. Marelle do not object to Braun"as the' organization to conduct the third party investigation.

They suggest, however, that the NRC impose the following conditions:

1. Final approval should await an NRC verification review of Braun's qualifications. This may already have been provided through the NRC vendor inspection program. As became obvious at the August 11 meeting, CECO.knows almost nothing about Braun beyond compliments from unidentified General Electric ("GE") officials. There was no independent verification of Braun's record. That is much too casual a Basis to select an organization for such a significant job.

To illustrate, the CECO selection process would not have' met the standards. utilities and contractors traditionally follow for selections to Approved Vendors Lists ("AVLs"). AVL selection generally follows a thorough review of the vendor's Quality Assurance manual, and a plant ~

survey to see if the manual has been implemented in fact.

8305190292 830311 sLeesmm~ ~ ~ ~ ~a a#-

PDR FOIA dE PRENDER82-366 PDR {// dej /8JL fp(

t. .

Further, our research at the Public Documents Room uncovered relevant information not included in Braun's August 11 slide show.

First, a PDR computer printout added significant information about Braun's own corporate structure. Braun's parent company is Santa Fe International, a wholly owned subsidiary of Kuwait Petroleum Corporation. (Exhibit 1) Second, the PDR computer listed 879 design drawings prepared for GE by Braun. Third, the 1979 NRC Annual Report referenced Braun's application to participate in the Commission's design standardization program. (Exhibit 2) . Fourth, the PDR contains several references to Braun as constructor of the Bailly nuclear station.

(Exhibits 3a-d).

Unless there is another C.F. Braun, these omissions raise questions whether the firm was completely forthright in its August 11 presentation.

The NRC should identify and verify the quality of all Braun's previous nuclear-related work'. Region III should also check.to see whether Santa Fe International or the Kuwait Petroleum Corporation has done business with CECO. CECO was satisfie@ to take GE's word for Braun's track record. CECO officials at the August 11 meeting were' satisfied to rely on their memories to verify Braun's financial independence. That is not good enough.

2. The charter should require that Braun officials schedule at least one meeting with Mr. Howard, Ms..Marello, Mr. Perry, Mr. Grant and Mr.~Cioni during the initial review of Zack. Quality Assurance

("QA") On August 11, Braun immediately responded "No" to an inqu,iry records.

whether it p1'anned to work with the Zack whistleblowers.

That was practically the only answer that Braun could provide without hesitation during the entire meeting. It raises questions how Braun knew that particular answer when they knew so little else. It also raises questibns about Braun's independence from CECO.

Braun needs the expertise of the Zack wh'istleblowers to properly' resolve the public safety questions about Zack's impact on safe

. operations.at LaSalle. At first a Braun official' stated t.he whistle-blowers' input is' unnecessary, 'since' the inspection effort 'will be so comprehensive that thorough documentation reviews would be duplicative.

When questioned about the practicality of comprehensive inspections, I

however, he contradicted himself and said that priorities could be determined through documentation review. No group of individuals is better qualified to assist with the initial records review than the Zack whistleblowers. Braun's unwillingness to work with them raises questions whether it will intentionally or inadvertantly miss relevant problems that Mr. Howard and the others could pinpoint.

3. The charter should hold Braun responsible to directly investigate and draw conclusions.for all Zack-related work at LaSalle.

On August 11, CECO reported that it had continued to investigate the Zack allegations and was almost done. CECO officials added that they hoped Braun would not duplicate their efforts. ,

Braun must duplicate all of CECO's prior investigative work, or this exercise is little better than a public relations gimmick. The point of the third-party program.ig an.. independent investigation, not

.- - an audit of the paperwork from Commonwealth Edison's own probe. ~

This flaw threatens the legitimacy ~of the entire effort.

4. The NRC should receive all Braun interim and final work products simultaneously with Commonwealth Edison. At the meeting CECO explained that it would receive advance copiss of everything Braun prepares, and would then forward everything without editing.

If CECO is not going to change the documents, it does not need an advance copy. It merely needs time to study them.before responding to NRC inquiries. Further, if the NRC receives copies of Braun's work at the same time as CECO, there will be no opportunities for mischief such aa the Cloud Associates / Pacific Gas and Electric scandal at Diablo Canyon. This suggestion is necessary to structurally guarantee Braun's independence from CECO editing or' censorship.

5. The charter should ensure that CECO cannot dismiss Braun from the project without prior notice to the NRC and an NRC-sponsored public meeting to justify the decision. Further, the NRC should make it clear that the licensing conditions will not be met for LaSalle if the NRC does not approve any such dismissal. The bottom line is that CECO selected Braun, is paying Braun's fee and can fire Braun. As a result,

- even if Braun previously.were independent of CECO, it will not be in the contaxt of this project. The current effort is the one that counts for LaSalle. This effort must remain independent through completion.

6. The charter should' require that Braun subcontract any servic'es for which its direct personnel are not qualified. Proof of quali-fications should be provided for every task in Braun's LaSalle contract. On August- ll, Braun admitted that no one on the tentative LaSalle team had experience in relevant fabrication or component testing, although its QC inspectors should be qualified for those. areas.

Braun also admitted that it had no, previous experience with contracts where the mission involved taking , apart and inspecting previously-completed work.

~

In short, the'LaSalle' contract.is a fresh challenge' for Braun. It is impossible to predict all the potential tasks that may arise, or whether Braun's direct staff is qualified to respond to each possibility.

7. The charter should require Braun's proposed methodology to l disclose relevant selection criteria and size of the samples for l inspections and testing. It is impossible to have confidence in the I

results of an independent inspection and testing program if the selec-tion criteria and size of the sample is a mystery.

8 The charter should require Braun to provide calculations demonstrating that it is possible to adequately complete its work during any proposed time frame for the contract. This is necessary to maintain credibility that Braun has not been hired to conduct a '

" rush job". To illustrate, on August 11 it became clear that it may well be physically impossible for Braun to inspect all the relevant hangers and ductwork by September 15, supposedly the target date for

~=- = - _ . . .- . _. -- ._ __

v .

._ 4_

completing-the affort. Although CECO explained that Braun could work as long as it takes, there should be some basis to verify whether the phoposed timetable for the project is realistic.

9. The charter should require Braun to support its proposed \

methodology through references to established professional codes (ASTM, ASME, ANSI, etc.). This will insure that Braun's methodology is a product of professional standards, rather than CECO's timetable for operations. For example, on August 11, Braun was not sure whether zinc paint affects accessibility for QC inspections. Braun should. cite to the relevant code when it answers this question through its inspection plan, since the issue could significantly affect the reliability of Braun inspection results.

10. The charter should require that Braun report to the NRC any safety-related information it unccvers during the project. For_ example, the specific mission is to verify that Zack material.s and work match the design. But the investigation may reveal information not taken into account in the original design.

While Braun should not necessarily expand the scope of its own

• ~ effort in that event, the charter should guarantee full disclosure

~

to the NRC.

Mr. Howard, Ms. Marello and I accept your invitation and will look forward to participating in the next meeting on. August 24.

Sincerely, Thomas Devine -

Legal Director me 9

srw--w--e-w -- __m__- __e - . -- - v-

u -

..:_...y.. .

~--.s'.>

D .

A Exhibit 1

-]0'3/.E c . .

tiCN : --* z2 0468 _

DATE:, v'i21' P- f. L L - U. T t '

~SY'#. INFORMS THAT SANT A F E INTL CORP .'APENT COMPANY OF CF BRAU I,' CD HAS BECOME WHOLLY OWNED 50BSIDIARY OF KUWAIT PETROLEUM L5':

CORP.CF BRAUN a CO WILL CONTINUE TD DO BUSINESS UNDER bRAur, L4: . NAME A-SAME MGT.

FICHE: 11305:302-11305:301

.PF_: TOPRP-EECCFB-C-811214 Rfel: HAA55 W F ANo!: DIC.' FORD A E .

R601: NORP REFAFFIL: 10P-EECCFB AAa;: .

EECCFF PACKAGE: 81121a-8112220a58 D .

J.

a002,5E B6 ACh: 's03290160 JA r- ~40309 rc.

X;; m PAGEi:

22.6.4pkDS AMdND 9 TO SAR IN REEPON5E '] NRC 790'24 - ~;

DISCUS $1NG PRELItIfMbY DESIGN APPRDVAL E).TEtaiIOf..

2. E: 6?.230:067-03230:2'2 PFL: ADOCK-5000532-6-?9C309

_ ?DR.

Dt.T : 50532A -

ANat: SUICE C W-R64.: NORD 4Ac : EECCFB -

PACT.60E: 790309-7903290165.*-

OT.,ER : 7903290165 D .

Pat.< AGE: ?81226-?901020181 D .

500 ' , ; ;.?

2.: i, ' /81227001*

7bii1E D1.: .L DTC: GTti

' AGES: 5 L1: COMMENTS ON PROPOSED SPENT FUEL 5 ORAGE REG 5.5UGGEST3

_2: INCLUSION OF ACCEPTABLE DOSE CRITERIA. REQUESTS REA5CN FOR L3: LIMITING SPENT FUEL STORAGE TO 20 YEARS.

FCHE: 34159:259-94159:263 '

PR-- 72-43FR46305-781115 ~

L: ?R-72 FR4: 43FR45309 Rhol: STANFORD R E L A*1 '1FP \

AA41:

--~.-- . E,ECCFB

-..., ,,....,.o.,

f// 4/9 2. g

,. - - .w Exhibit,2 797 j[gg 44gg, gag ]

'h k lI i 95 -

' F I 5 l

' 1

,' g i

-  ;} H-Four procedu'ral options are available (see 1976 l uldh ..a1 out of-reactor hot loop testing by CE NRC Annual Report, p. 36, for details) to applicants eO ued th2 important role of flow-induced vibration

ha control rods in the guide-tube wear problem. for standardization Nof nuclear power . plants: "'f i vibration and, hence, the wear, was reduced by " Reference Systems" (approved design used repeatedly d;'; fi reasing some of the guide-tube coolant (water) by reference), " Duplicate Plants" (approved design for ti i i !.

v. Two fuel assembly modifications were designed several identical plants), " License to Manu- 1 Ea l reduce the coolant flow. One involved inserting a facture"(approved design for manufacture of identical h" r p!  ;

ned cylinder in the top of the guide tube. The sec- units at the central location), and " Replicate Plants"' h 1 involved reducing the size and number of flow (reuse of recently approved custom design). h h

-es in the bottom of the guide tube. Both modifica- Since June 1973, when applications were first ac-u, in limited number, are being tested in currently trating cores to confirm the loop test results.

cepted which included a standardization option, the standardization program has realized s'u bstantial pro- M f Ilt lIM L.

the NRC has closely followed the analyses and gress. Overall, approximately two-thirds of the ap-  !! ll h

k. W eriments performed by CE and is in substantial eemen.t with the vendor that the results point to plications received in the 1974-1978 time frame have employed one or more options of the standardization D4y  ;

itrol rod flow induced vibration as the principal program. See Table 3 for a listing of the status of ap-i ! [ .I

' C .

tor in guide-tube wear. Therefore, design modifica- plications.

! ns intended to alter flow in the guide tubes were R app

• In August 1978, the Commission approved a number of changes to the program to' encourage its ex.

N{

(,

[ied f tp ag _ gn th Panded use, as well as to incorporate both industry ;g it they will mitigate the wear problem. Approval of p

7 and regulatory changes introduced since the program 7 y

- her design modification as a final solution to the

! ablem will be contingent upon the results of further was first announced in 1972. The revised pmgram }4,1 g; ado ed a good many such changes, some of which are  :

I t-ef-reactor experiments and examination of the idified assemblies which are currently subject to in-as f ws: y  :

l ict:r operations. (1) The term of holders of all new preliminary design Wi, ,'

' Th' -topportunitytoevaluatetheperformanceof approvals (PDAs) for reference system designs was k N j ';

, guide tubes after reactor operations occur- extended from three to five years. Holders of all

!' N'.

,n 3du 4 the Millstone Unit 2 refueling outage in the issued PDAs were given the opportunity to extend ring cf 1979. Subsequent to the Millstone 2 refuel- them to a full 5-yearterm. - - --

b g, thi St. Luele Unit No.1 (Florida) and the Calvert (2) Final . design approvals (FDAs) for reference

%as: i, iffs Unit No.1 (i"aryland) also provided evidence a thm performance of.the sleeved guide tubes. These system designs were eligible for reference in ap- ;y' specti:ns indicate that the sleeving modification has plications for construction permits. Two types of if ,

FDAs were established. The first, denoted FDA-1, a p' rf:rmed well as an interim solution to mitigate the aide-tube wear but that it does not eliminate the can be referenced from the time it is docketed to 3 41 l .use cf the wear'. (During the October-November y' ears after expiration of the FDA on.which it is based. The second, denoted FDA.2, can be h' fj

' E9 refu. ling outage Calvert Cliffs Unit 2 was - [ C '

heduled to undergo inspections of modifications referenced from the time it is docketed to 5 years ,'

.ade as interim solutions to guide tube wear.) after it is approved. i

i I

The NRC staff will continue to maintain close (3) A qualification review was devised to permit the ...

uson with representatives of the licensees and ven- duplicated plant concept to be used in a manner i Q

< 3rs en thisissue and any related problems. Approvals similar to the reference system concept. In this N Mi am been granted to allow operaton of the CE plants regard, five-year preliminary du icate design ', "q .I

' i a cycle. specific basis with the stainless steel inserts. approvals (PDDAs) and final du licate design p [y i il preposed programs have been reviewed prior to *pprovals (FDDAs) were established which can be , pi Aing teti:n at any facility, and the staff has required used in new applications for construction permits g;

ut til inspection programs continue to be submitted .

In a manner similar to the use of PDAs and FDAs j;

! ar review well in advance or refueling shutdowns. under the reference system concept.  ;

'!:t

'(4) A qualification review was defined for replicate L ,h

'IlOCRESS IN STANDARDIZATION p; plants and the period for replication was establish- ,

The NRC believes that standardization of the design ed as 3 years after publication of the base plant

• P,i i'j

- pc!=r power plants is in the interest of public Safety Evaluation Report.

• id safety, and of effective and efficient regula-

? h 9'  ?

is, the NRC is committed to the support and (5) A 5-year period of design approval was established

[i" .d use of standardization within the Commis- for manufacturinglicenses and an uppper limit of a

• n.

. s rrgulatory activities. 10 units was established. y h.

j

= __ _

oN

=

96

~ '

Table 3, Standardization Applications

. (as of August 31,1979) ,

PROJECT APPLICANT DOCKET DATE COMMENTS Reference Systems Nuclear Island Ceneral Electric 7/30/73 Nuclear Island, PDA 1 CESAR-238(NI)

(Preliminary Design Approval) issued 12/22n5 Turbine island C F. Braun 12/21/74 Turbine Island Matched

-.9 C F BRAUN SSAR TO CESSAR 238(NI). PDA-5 Issued

. SMn6 .

Nuclear Steam Supply System (NSSS)

BSAR-205 Babcock & Wilcox 3/Oln6 PDA-12 issued 5/31n8 BSAR-241 Babcock k Wilcox 5/14/74 (withdrawn)

CESSAR Combustion Engineering 12/19/73 PDA-2 issued 12/31175 CASSAR Ceneral Atomic 2l05n5' Review suspended at request of appli-cant. .

CESSAR-238 Ceneral Electrie 10/16/75 PDA-10 issued 3/10/77 CESSAR-251 CNal Electric 2/14/75 PDA-9 issued'3/31n7

.w, .v a ..n5.. 7/31 . m . :.:. w. .= . PDA-7 issued 12/30n6 -- g.m RESAR-3S . ...CWesinghobie'y;:

. ..- e. , Westinghouse

.RESAR'41 *.TI."h.. .12/31175.p ., ";; . g Ji ;

y

-- - - - - A 311/74 : ' TX-Q: PDA.3 issued -

RESAR-414 Westinghouse 12/30/76 PDA-13 issued 11/14/78 Balance of Plant (BOP) .

BOPSSARIBSAR-205 Muor Power 10/31/77 BOP matched to BSAR-205

'BOPSSAR/RESAR-4'l Muor Power 1127/76 'PDA-ll' issued 8/17U7 BOP matched to RESAR 41 ESSAR/BSAR-205 Ebasco 5/19/78 BOP matched to BSAR 205

~

ESSARICESSAR Ebasco 2/02n8 BOP matched to CESSAR ESSAR/RESAR-414 Ebasco 11/23/77 BOP matched to RESA.R-414 CAISSAR/BSAR-205 Cubert Commonwealth 8/21n8 BOP matched Ao BSAR-205 CAISSARICESSAR C0bert Commonwealth S/21n8 BOP matched to CESSAR CAISSAR RESAR-414 Cilbert Commonwealth 8/21n8 BOP matched to RESAR-414 CIBBSSAR Cibbs k Hill 5/10n7 BOP matched to RESAR-414 SWESSAR/BSAR-205 Stone & Webster 12/22/75 BOP matched to BSAR-205 SWESSARICESSAR Stone & Webster 10/21n4 BOP matched to CESSAR PDA-6 issued 8/16/76 SWESSAR/RESAR-3S Stone & Webster 10/02n5 BOP matched to RESAR-3S BPDA-8 issued 3/31177 .

SWESSAR/RESAR-41 Stone & Webster 6/28/74 BOP matched to RESAR-41 PDA-4 issued 5/05/76

- - - . - - - + - - ,

i G

= 97 ';

\:.

l t

MOJECT

• APPLICANT DOCKET DATE COMMENTS .

Utuity Applications Using Reference Systems -

Cherokee 1,2&3 Duke Power . 5/24n4 References CESSAR. CP issued 12/30/77 9 Perkins 1,2&3 ' Duke Power 5/24/74 References CESSAR  !

h South Texas 1&R Houston Light and Power Co. 7/05/74 References RESAR-41 cps issued 12/22n5 .

WPPSS 3k5 ~ Washington Public Power 8/02/74 References CESSAR Supply System cps issued 4/11n8 j Palo Verde 1,2&3 Arizona Public Servios 10/M n4 References CESSAR. cps issued 05/25/76 i

Hartsville 1,2,3&4 Tennesee Valley Authority 11/22/74 References CESSAR.238(NI) i cps issued 05/09/77 J Pal 2 Verde 4&5 . 03/31n8 References CESSAR .

Arizonafublic Service ,

Black Fox 1&2 Public Service of Oklahoma 12/2'l/75 References CESSAR.238 (NSSS)

Phipps Bend 1&2 Tennessee Valley Authority ll/07n5 References CESSAR.38 cps issued 1/16/78 (NI)

Erie 1&2 Ohio Edison Co. 3/01/77 References BSAR.205 Yellow Creek 1&2 Tennessee Valley Authority 3/16/76 References CESSAR Duplicate ?lants Byron 1&2 Commonwealth Edison 9/20/73

_ Two units at each of two sites.

cps issued 12/31/75 l

Br:Idwood 1&2 .

skee 1,2&3 Duke Power 5/24/74 Three units at each of two sites. Also

- . . . . . a. ,

--- . - - - . - - . ,.. 7eferencerCESSAR. Cherokee cps -- . ---

..2 Issued 121.30 2 W .j.f .y a. ,,.g.,n7,_2.

.--.~~--'-;. .,.- . T.3j; .- f,*,,, trong.1:_w

, j.. . .. u. . . *2. .

SNUPPS - Five units at four sites.~ .

Wolf Creek Kansas Cas & Electric Co. 5/17174 CP issued 5/17177 Kansas City Power & Light . .

Call:wa'y 1&E Union Electric 6/21/74 cps issued 4/14/76

Tyrone 1 Northern 3tates Power 6/21174 cps issued 12/2757 Sterline Rochester Cas & Electric 6/21/74 CP issued 9/01/77 WNP Koshkonong 1&2 Wisconsin Electric Power 8/09/74 Initially submitted under duplicate plant option with intent for as many as Madison Cas & Electric six total units at three sites. Utility's Wisconsin Power & Light change in plans led to removal from Wisconsin Public Service . standardization program by staff. Review discontinued because of site problems License to Manufacture Floating Nuclear Offshore Power Systems 7/05n3 Entire plant design Pl!.nt (FNP) 1-8 Replication Jrmesport I&2 Long Island Lighting 9/06!74 Replicates Millstone 3 Mirble Hill 1&2 Public Service of Indiana 9/17/75 Replicates Byron 1&2

" w England I&2 New England Powee & Light 9/09/76 Replicates Scabrook I&2 ,,- -

4 Verde 4&5 Arizona Public Service 3/31/78 Replicates Palo Verde 1,2&3 Hr.ven 1 Wisconsin Electric Power 4405/78 Replicates Koshkonong 1&2

- - * - ~

w--+c ne- - - - - -

9 y---y- - - - -- , ,, --

98 4

Staff studies (NUREC.0427) have shown that the ' reviews and providing comments on the studies and NRC standardization program is about at the break- assessments being performed under the International even point, that is, the staff resources spent on the Nuclear Fuel Cycle Evaluation (INFCE) program. In review of standardization plants and design approval its reviews and comments, the staff focused on the applications is about equivalent to the resources that potential licensability of these reactor types and would have been used if only custom plants had been associated fuel cycles, with respect to safety and safe-involved. To the extent that utilities reference approv. guards concerns and environmental acceptability.

ed designs in the future, the balance will become more Based on advanced reactor licensing experience and and more favorable for the standardization program. Preliminary safety documents supplied by DOE, the On the other hand, should the staff be requested to staff prepared its initial comments on alternative reac-review additional PDA's and new applications that do tors and fuel cycles and forwarded them to DOE in not reference PDA's, FDA's, or ML's (Manufacturing June 1979. These initial findings are summarized in Licenses), the use of standardization to reduce the use the first of a series of reports to Congress published in of staff resources would not be realized. October 1979.

Staff studies also.have revealed that use of the stan-dardization options have not, to date, resulted in a reduction of schedules. These studies show that the Clinch River Breeder Reactor potential exists for significant schedule reductions only '

when there is preapproval of the Nuclear Steam SuP- The status of the staff review of the Clinch River ply System (NSSS), the Balance of Plant (BOP), and Breeder Reactor remained' inactive throughout the year and will remain so pending enactment of legisla-the site, the three review areas that separately can tion clarifying the status of the facility.

define the critical path. Thus, a strong incentive exists .

for pursuing site approvals via the Early Site Review Program, since approved PDAs now exist for the NSss and BOP portions of the plant. Utility-related matters ~ Fast Flux Test Facility of the application, such as the quality assurance pro-gram or the financial qualifications, generally do not . The Fast Flux' Test Facility (FFTF) is a major control the overall review schedule.

LMFBR test facility which, with a power of 400 megawatts (thermal), will provide an intense field of m ,Jrogram actions _ completed .during fiscal year 1979 _ __ fast neutrons for.irradiatingipels And rpaterials in con-g~ _iscliidedi'(aStehaing B~alaWof-PIst PDAsWa'~~iecilodVdtlPadvhh6ed' "feactor research and~dsW

' U C=s_1-~ full 3~yei~r termi(b) extending six PDAs to a full 5-year 3 i 7. ment. ,The. facility,;which is located about 10 miles .n term based upon a completeness rsYiew; and (c) issu ' ' north of"Richland, Washington,' is owned by the " -

ing a PDA for RESAR-414. Additional reviews and Department of Energy (DOE) and is not subject to policy initiatives were temporarily suspended in' April- licensing by the NRC. An NBC' staff safety review was 1979 as a result of the TMI.2 accident. Staff resources performed, however under~ terms of an interagency were re-directed to high priority activities associated agreement with DOE. The staff completed the major

, with the, accident-related studies. part of its review effort and, in August 1978, issued its Safety Evaluation Report (NUREG-0358). A supple-ment to the SER (NUREG-0358, Supplement No.1)

ADVANCED NUCLEAR POWER PLANTS was issued in May 1979. Sodium filling of one second-ary sodium loop took place in July 1978. Fuel loading On April 7,1977, President Carter issued a state- was expected in October 1979. Prior to full power ment on Nuclear Power Policy which restated the role operation, now scheduled for early 1980, a series of that nuclear energy was to have in the total energy tests was to be performed to determine whether prospects of the country. The President's policy would natural circulation is a visble method of removing defer ' Indefinitely the commercial reprocessing and decay heat as predicted by analyses.

recycling of plutonium produced in nuclear power The Advisory Committee on Reactor Safeguards reactors, restructure the U.S. breeder reactor program (ACRS) was extensively involved in the review of to give high priority to alternative designs, and defer ~

FFTF and meetings addressing that rcview were held the time when breeder reactors are to be commer- in July, August, September and November 1978. The cialized. ACRS concluded that the startup and operation of the During this reporting period, the NRC has con- FFTF is acceptable, prodded that due regard is given

, tinued its participation in the review and assessment of to NRC consequences of certain low probability a variety of reactor types and fuel cycles being con- accidents, and other specified matters. DOE is sidered by the Department of Energy (DOE) as part of presently evaluating the NRC staff recommendations

. the Nonprolifercation Alternative Systems Assessment regarding containment adequacy for low probability -

Program (NASAP); it also continuei , erforming accidents.

. a: -- - . - - . _ _ , _

- Exhibit 3A

. - 6 s

e COMMERCIAL NUCLEAR-POWER PIMTS

/

Edition No.13

. ..._; ,a .. N - >.7  :. . _ . ; .: .NUS Corporation. Research Place, Rockville, MD 20850 Cover Photo: Comanche Peak Steam Electric Station. Units .

1 & 2 under construction near Glen Rose, TX, operated by Texas Utilities Generating Company and jointly owned by Dallas Power & Light Co., Texas Electric Service Co., Texas

, Power & Light Co., Texas Municipal Power Agency and Brazos Electric Power Cooperative.

january 1981 Additional copics SS each

./

_ /'

m

. N:rth;rn Indirna Publi2 N rth:rn St tis Pcwer Co.

Service Co.

4

~

r Nuclear Unit Bailly Montice!!o Prairie Prairie Island.1 Island-2 Location 12 miles NE 30 miles NW 40 miles SE 40 miles SE Cary Minneapolis Minneapolis Minneapolis St:te Indiana Minnesota Minnesota Minnesota Type BWR BWR PWR PWR C pacity,Mw Net 660 536 520 520 Containment Typesbg Type 4g Type 2e Type 2c Cooling Tower

~

Towers Towers Towers (Natural) (Mechanical) (Mechanical) (Mcchanical)

Ructor Supplier CE GE Westinghouse Westinghouse Turbine-Gen. Mir. CE 'G E - Westinghouse Westinghouse Engineer S & !. ,

Bechtel FPI FPI

^

,w.. ,nstructogg

_ 7. r-,-,.Braim -- j: . z _ ,4-.--..;-- Bechter . , -' Utility .-

,s.......

, .UIility'

.- pq--- -

.,.,::.NRC Docket No. - c so-367 TS ~ ' ' - - 50-263' 50-282 50-306 -

Announced 12-66 4-8-66 2 3-67 6 27-67 i Applied to NRC 8 28-70 8-12-66 4 7-67 8-30-67 C:nstr ;n Permit 5-2-74 6-19-67 6 25-68 6-25-68 Op: rating License 9-8-70 8 9-73 10-29-74 Critical First Time 12-10 70 12-1-73 12-17-74 C:mmercial Operation 1989 6-30-71 12-16-73 12 21-74 C;nstruction Progress <5% 11-79 ' Completed Completed Completed N:tes No atack Turnkey

(

34

7 . .-

Exhibit 3B -

} ,. -

, , x --

\ .

7... >ev

,e

, 's-

,e...

~

2,w .e . ~ ~e t, _ x ser.sous :::

Report No. 50-367/78-01

/

Docket No. 50-367 License No.'CPPR-104 Licensee:/ Northern Indiana Public Service Company

' 5256 Hohman Avenue Hammond, Indiana 46325 Facility Name: Bailly Generating Station Nuclear I - '

, Inspection At: Bailly Site, Porter, Indiana Inspection Conducted: March 9 and 10, 1978 _

Inspectors:

<&.r ~

H. S. Phillips .

.3NO/78 J. E. Konkl p .3/ 30! [

Approved By: D. W. ayes Chief 3 30)78 Projects Section h Inspection Summary Inspection on March 9 and 10,1978 (Report No. 50-367/78-01)

Areas Inspected: Storage, maintenance and protection of materials and equipment; site preparation procedures and records; Review of commitments to Regulatory Guides. The inspection involved 28 inspector-hours onsite by two NRC inspectors.

Results: Of the three areas inspected no apparent items of noncompliance were identified in two areas; one apparent item of noncompliance was identified in one area (deficiency - failure to properly store and protect three of twenty-two main steam line pieces.

l 2 .

. 4 +.-. --_ e =.p- ~ x. L AQ.x _. ,g %

_ _ g;wh~ $^

f .-

_m

. f.gr s on s ca,n_e a e c .d T:.5

- Principal Licensee Employees

• R. J. Bohn, Manager Nuclear Staf f

• E. Kritzer, Jr., Sr. QA Engineer

• J. W. Dunn, Nuclear Staff Engineer

• • C. A. Carlisle, General QA Engineer C. F. Braun

• J. S. Fiedler, Project QA Engineer

• D. K. Maxwell, Site QC Supervisor  ;

• M. R. Williams QA Records Engineer

• denotes those present at the exit interview.

• • telephone interview.

Licensee Action on Previous Inspection Findings

~

(Closed) Unresolved matter (50-367/77-06) - This matter concerned the use of penetrameters during the radiographing of, veld joints which have differing thicknesses of metal. Current practice is to -

use two penetrameters rather than one.-

(Closed) Unresolved matter (50-367/77-05) - Sargeant & Lundy letter dated November 30, 1977 regarding Field Change Request No. 8. resolved this' matter which concerned design tolerances .as related to B-Pile weld

~

joints .

Functional or Program Areas Inspected knspection results are discussed in the following Sections.

O b

mm -

M.

/

h .

Y S

_ r . _ _ . .

Q ssee2 r* Ping, was was the only item received December 27 1977.

.' per Level C requirementsstored Jr. -thf.s area a,nd wasThis improper storage as recor.

report.

atored ded in Section II of'thisVisual in The RIII inspector selected th

_ #15,16 and 24.and reviewed the shipping reco dree cf twe Receiving inspection records h dr s on han by the Quality Control inspectocompleted r.

a been by and Engineering dated December Corporationcontained The package also

, and G rom Associated Piping Su

. 19, 1977.

205 AG 923. Rev 15. Purchase e received under

. E. Purchase Order, Orders T-2350 an (3) Identification of aMateri l .

s. Parts and Components The inspector found that all i properly identified and were records. s ea iltems inspected were y traced to pertinent inspected.No items of noncompliance we t i

2.

Site Preparation re ideatified in the above areas The inspector reviewed

\

to determine requirementsthe PSAR, QA manuals and sp Nuclearaccomplished.

Staff was interview e In addition d the Manager ecifications of the NIP previously SCo the excavation work in toacco Calumet review d Trucking excavation Company had activiti ss placement waswork was performed on July-Sept r ance with Specification T-2984 periormed ember 1974. .

This characteristics of the sitenecessary to d.eological ate because of the gNo blastin must be removed in the area.

building. located and approximately where thecigh reactor buildir.g will b. An e

1

a. t (8) more feet under the waste rad

! RA Im h enting Procedures '

of detailed procedures; howeverThe nature of the not merit the development found in Specification T-2984 control of ground water was ou. Division 1 and 2, a procedural statem Also the tlined in this specificatio n.

l t

y l 6 I

l .

i > ~.

h 1

a 1 .

~

.. h

.a - - - '

s

.'y t z - Exhibit 3C G .j .

.I -

.u IG' 7 ':

• SECTION 11 s

! Prep,a red By G. F. Maxwell

~

Reviewed By R. L. Spessard, Chief

- Engineering Support 'Section 1 diana Public

- 1.

Review of Audit Records - Audits Conducted By Northern In .

Service Co. (NIPSCO), Bailly Unit 1 including The inspector reviewed the NIPSCO audit reports, the a.

supportive correspondance and documentation related to following NIPSCO audit reports:

22, 1978; a follow-up l (1) Audit report No. 2116, date Marchaudit of various pro

@@ \

requiring revision, identified in audit report 2100.

(2)

Audit report No. 2100, date July 7,1977; a C. F. Braun ~ ~

. and Company quality-system audit.

25-26-1977; a Sargent (3) Audit report No. 2107,'date October

.6,Lundy QA Program audit.

29, 1977; a vendor sur-(4) Audit report No. 2095, date Aprilveillance to determi control, relative to C. F. Braun and Company.

25-27, 1977; a G. E.

(5), Audit report No. 2088, date AprilSan Jose audit of G curement.

' 15, 1977; a Sargent &

(6) Audit report No. 2082, date March ~

Lundy QA Program implementation audit.

20-21, 1975; a final Audit report No. 2078, date December (7) inspection and documentation review of the first lot of J

recirculation piping shipped to site - Pullman-Kellogg, Williamsport, PA.

25, 1976; a surveil-

~

(S) Audit report No. 2068, date Octoberexamination of rec rculation i lance of Liquid Penetrant piping and of weld preparation for in service Ultrasen c Exacination - Pullman-Kellogg, Williamsport, PA.

I -

. . _ m'e ~~ se

,W '

f

,r-ss i1 - "

E I

n A

}

• 'p

)

• Exhibit 3D __

..- .f Northern Indiana Public Servica Company e

$ OW<u l 5265 Nahmen A.onw l Hans.nmt wow as2s lT

(& July 2f,,1978

. M.sn'one

. . .csot=t.oesus.o=s

~,

R. F. Heishman, Chief Branch a

ctor Construction ac Engineering Support S. Nuclear Regulatory Commission, Region III 9 Roosevelt Road e n Ellyn, Illinois 60137

'e: Northern Indiana Public Service Company '

Bailly Generating Station Nuclear 1 .

Docket 50-367 3 ear Mr. Heishman: i f 50-367/78-02, f The following is Northern Indiana Public Service identified in the NRC Inspector's Report Company's resolut the Notice of Violation 26, 1978. Items A and C are which was enclosed with your letter of ' June i

infractions; item B is a deficiency.

N1PSCO's Nuclear Staff has prepared,a draft hichof a procedure

'A. (1) that addresses the requirements of 10CFR50.55(e), w is currently being circulated internally for comments.

i 'A(1) will termi .

.The issuance of the procedure referenced n (2) nate further' noncompliance.

Full compliance is anticipated with the issuance and distri-d in A(1). Issuance and (3) 15, 1978.

/

.bution of the procedure referencedistribution will be complet f

B.1 (1) C. F. Braun, as Construction Manager, has responsibility maintaining site records. d on site currentlyTheare those fernished by the*NSS General Electric Company pro-

• for the H-pile material. hich is currently .

vides a quarterly listing of Quality records w ds l used as an interim systematic index of NSSS QualityWe recor The H-pile material certifications are indexed. ble for

' on site.

recognir.e that the above described system is not suita the duration of the project. .

JUL 2 71978 t

T3173 FEh gec h'[. .

/3'/kprMrt  !

. fsr F% < A n

/pdf.e, EA dos %

~

/o: M & e.s $ hop p /ea.

'$dy/4<f A4dx&<An 4.sv>4 e - & p a se.

O; $/' .det'ssoh's' o.ed o., A wee 7As & 6eoas yft *s s% ds y +- A 47 YA sdat A hpai, ta oficJs

~

on 3% 'Ys* -

fagea&: $seesp/st if f wrM4<.d4 d A' AfrJ4J7 Me 's c 4 4 indyeada it .cevaa g Ace. $4c-g'ycre S 1 of #< /4ffe. 44c/e'ca. L dig .

Acue f i.J n<N Ae sena h64 d<:4. f A'* p t ..

p >re. L d a e cl m) d9 a twcL iS M >4 . s .<-

sh A

! oAlcJs i4 $/en EHys, Z Aeaafy . raas-j

~

ks idyf*' Y dn<es au Je( q f f #fke6 " 4 .

m y .r* *: .

.,#.. . .> .4.y. . , .. . .

. . . . n.

A>r9ris fse/s {ensscrLew.......dy t.

,rrik

$.5 E M #Y Jw& .o.u a y m p =a.

. b"& A .

g,,. .,rk,A f g

[ m<rra

.ZE gacAs d.,+j<<r,sre n ; y- a m ~ -g s

.,4 h - f 9 a; .

,,,s < a <

Pv 4 Gossant Jr.

,&u .;ic wa.a*- a b ;% . W$,0.L,c q.gs 4 k3

' : - . . . -. . - -. . . . . . _ _ _ _ _ , , . . _ , . . ._ __ 3_ .

( heet' .

. seuJ p

~

d+ e #c-

/, , j , 4wue. f K<-

p Aat &}=a c w u un g A .W'M s f =as f m.ht~' .

""'dA & r*' 4.A s,,,s t p _ t KM .

np4# prat ~Pwspw.c a,ed. M= 4y < f 444 7' # k 4 yE.

g {,,,waag fk.'s

~

& " Amr wuri sl. .x depst % </f~ S"2 R * -

l -b L L p p u I,s. -

NWW $b eb ly &es., N p ,c. S M M y w 4:6&L &A*fA W p4 OM4,,'t b g 82 94< A f f u &'

1. . <a. A y.a.:  % ;zy_t 4 at~ Aa p.<p=h pu- .4 A s%M wL m ,4,- eA :9,dd% ** L

&* 5 ' 4k =w :

4 ~12d fa,r~,; E n; fan. AA94 '

l 4e zjw < b'. r A w ,. ; on e  ?"=M t A

sw ,. ,. . - . ., m

.....,...,.....v.. ,,, . , . .. , . , , s. .. .. .. .

s., .

. t i. ,

s ' .

? ' .W . ,;,;' '. *.l.. . + %[ *

• f k,;' . ' l . ,.. . ;. >. .

f ~.*C y' '. 71. ' .:'s ..

' 8. .fld &. E p.egizur: u4 /ta c

_4 HJf nu 14.~. fmas ~ h '

p.e w  ;,

m. . . . .

l7.Q. dl .

. R.. d de r E n m.n. J # d A ' W 3..t *

%4 ,,, '.g ,, ,R <.

ss x l _. -[g. ev _

&.ac.i 3 <Wa*c.o}

b

'_ [.]'4,x x pha<s de a4%M 4, d K ,

\ *., )4(.n &slapre.-slm-f L& 4se vs . 9, 8 p.

BlL,,'

' l' 71 '<s 4 a ems ~uh &. b p u,i<de p -,a6 ~ .;

g^ .

.y. .

..r

t. >h & ayg ceaec puu J-y

. {~ '

mke A Kur,J mou .

, _ ... .. . . .. . a.

~ ..

.~ ~ YM

, ).f;

[FS *l M' M JI4dde.g so.=eM .

.'-z.

.t

. if .

h !d_ . . \.:

k 4 lM%g

• \

\. p.>

,l e

$8ne. /-

- '. . . ,. . n -

. .? 'h... 4 ,

• '~.

,u

s. 1 ^

~. .V . .' ; . * <. .: 1 9. . N :; g

. ~ '. . ..

-y..

;.5 . :. .g.. . .;;. , .'.

.:..? . .: y. 3...

.i: ,. c. ...;.

. :.,,.;..q 1

,:.'p?-

.e'., ..

• j ;.1, ,_. . . . ._ . .zy,s , t'.

, . r..; .. .. . ..g

<.y-.p. . , , ,':-y'.'. , :.i %..9, . 4 . . _:. f,;f _. . . . .'. .

r:. . s.;. , -q_ _ l. .,

.. ',f: . , y, '.; , . ' _ . _ . . ,- ..*

.. . . s. . : 4. . . m. .. ,. . y ?g.. ,; f .,.,; 9,"..:'.. :.. .~

, y, ., . . . . . - - * ~;,r.;

. n,*_

~ ?;;;~ ; ._.%.

2, ' ' .. e !

Q y  ?

• .

• s **. .

.* .. . p ." . ' ) ,'

.'.~

l ,.... -

l .

.b . .

(' .. . * . . *,.,*4.,,

, . , ;y.

.. . .7*

l.

.=

.Athedi;,s -.f.adh. . ..

. ~ * ,y, g*;

. },'!'.l . , ' .q;s .l' .:' *. * . *?f 1, ,,_.,'t..

.6 .% .. . .

~

t .t* sah .f*^',, . ,

' , , '. W:*. .: ; "_ ' .i.W . .. .  ;, *,.

r*

,*.f.', .' :'d*'**f% ' - ,,[-

@ .,a==.g ,

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

~.

. ~

e t i 4 . A n.( k b d i ~

7, $M

[. N . M4,, T , . . .

j La ,

^j

.; .: 3 2, s ' & -

. s

. y:.-)?

f ' ... .

T...deo w k"* i.' . + ,

.~

f fdf. e  % T, 8 ,

. - - . _ _ _ _ _ - - . - .