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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217H6231999-10-18018 October 1999 Discusses Completion of Licensing Action for GL 98-01 & Suppl 1, Yr 2000 Readiness of Computer Sys at Npps, to All Holders of Operating Licenses for NPPs ML20217J4331999-10-15015 October 1999 Forwards Insp Rept 50-461/99-19 on 990913-17.One Violation Re Individual Failure to Follow Radiation Protection Procedures When Accessing High Radiation Area Noted & Being Treated as Noncited Violation ML20217H6251999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for MR Kahn,Aj Mclaughlin,De Montgomery & Kr Murphy Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC from 396 Encl.Proprietary Info Withheld ML20217H6341999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for Kh Curran,Lm Gerlach,Rc Weber & Bt Rhodes Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC Form 396 Encl.Proprietary Info Withheld ML20217F4301999-10-14014 October 1999 Responds to 991012 Rai,Based on 991001 Telcon Re Suppl to Request for TS Change to Revise MCPR Safety Limit & Add Approved Siemens Topical Rept for LaSalle County Station, Unit 1 ML20217D3191999-10-12012 October 1999 Submits Request for Addl Info Re Licensee 990707 Proposed License Amend to Revise Min Critical Power Ratio.Listed Questions Were Discussed with Util in 991001 Telcon U-603280, Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p)1999-10-12012 October 1999 Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p) ML20217C0871999-10-11011 October 1999 Forwards Proprietary Attachment Inadvertently Omitted from Encl 2 to Submitting Responses to NRC RAI Re License Transfer Application for Plant.Proprietary Encl Withheld U-603276, Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included1999-10-0808 October 1999 Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included ML20217C1671999-10-0808 October 1999 Provides Suppl to RAI for Approval of Unreviewed Safety Question Re Assessment of Certain safety-related Concrete Block Walls at LaSalle County Station,Units 1 & 2 U-603279, Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld1999-10-0707 October 1999 Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld U-603275, Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station1999-10-0707 October 1999 Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station ML20217A7601999-10-0606 October 1999 Forwards Insp Repts 50-373/99-15 & 50-374/99-15 on 990729-0916.One Violation of NRC Requirements Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20212M0931999-10-0404 October 1999 Refers to 990922-23 Meeting Conducted by Region II at LaSalle Nuclear Power Station.Purpose of Visit,To Meet with Licensee Risk Mgt Staff to Discuss Util Initiatives in Risk Area & to Establish Dialog Between SRAs & Risk Mgt Staff 05000373/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl1999-10-0404 October 1999 Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl ML20217A7361999-10-0101 October 1999 Forwards Insp Repts 50-461/99-14 & 50-461/98-12 on 990729-0908.Two Violations Identified,One Re Failure to Place Control Switch in Proper Position to Identify Piece of out-of-svc Equipment & Being Treated as NCVs ML20217A9881999-10-0101 October 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20217J1251999-09-30030 September 1999 Refers to Investigation 3-1997-040 Conducted from 971028- 980921 & Forwards Nov.Investigations Determined That During Jan 1997,supervisor Qv Dept Discriminated Against Qv Inspector in Retaliation for Inspector Contacts with NRC ML20217J1421999-09-30030 September 1999 Refers to Investigation 3-97-040 Conducted from 971028- 980921 & Forwards Nov.Investigation Concluded That Recipient Engaged in Deliberate Misconduct in That Recipient Discriminated Againt Qv Inspector for Having Contacted NRC ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20217A6201999-09-30030 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC Feedback on Any Planned Insps Which May Conflict with Plant Activities.Plant Issue Matrix & Insp Plan Encl ML20212E7171999-09-22022 September 1999 Forwards RAI Re Requesting Approval of License Amend to Use Different Methodology & Acceptance Criteria for Reassessment of Certain Masonry Walls Subjected to Transient HELB Pressurization Loads ML20212G6751999-09-22022 September 1999 Forwards Comment Submitted to NRC by Environ Law & Policy Ctr Re Proposed License Transfer for Clinton Power Station U-603272, Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl1999-09-22022 September 1999 Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl ML20212G6981999-09-20020 September 1999 Requests That NRC Reject Proposed License Transfer for Clinton Power Station & That NRC State That Public Interest in Safe Nuclear Power Industry Will Not Be Subordinated to Interest in Maximizing Profit by Limiting Liability U-603225, Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl1999-09-20020 September 1999 Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl 05000374/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl1999-09-20020 September 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl ML20212C0591999-09-17017 September 1999 Informs That NRC Reviewed Licensee Justifications for Deviations from NEDO-31558 & Determined That Justifications acceptable.Post-accident Neutron Flux Monitoring Instrumentation Acceptable Alternative to Reg Guide 1.97 ML20217H3421999-09-17017 September 1999 Forwards Request for Addl Info Re Licensee 990723 Application for License Transfer & Conforming Administrative License Amend.Response Requested within 20 Days of Receipt of Ltr 05000461/LER-1996-010, Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events1999-09-13013 September 1999 Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events ML20212A3581999-09-13013 September 1999 Confirms That Fuel MCPR Data for LaSalle County Station,Unit 1,Cyle 9,sent by Ltr Meets Condition 2,as Stated in 970509 NRC Ltr ML20211Q9911999-09-10010 September 1999 Informs That License SOP-4048-4,for Wp Sly May Be Terminated Due to Individual Retiring ML20212A1141999-09-10010 September 1999 Forwards RAI Re Licensee 990519 Amend Request,Which Proposed to Relocate Chemistry TSs from TS to licensee-controlled Documents.Response Requested by 990930,so That Amend May Be Issued to Support Upcoming Unit 1 Refueling Outage U-603269, Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed1999-09-10010 September 1999 Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed 05000461/LER-1999-011, Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments1999-09-10010 September 1999 Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments ML20211Q2671999-09-0808 September 1999 Informs That NRC Tentatively re-scheduled Initial Licensing Exams for License Operator License Applicants During Weeks of June 5 & 12,2000.Validation of Exams Will Occur at Station During Weeks of May 15,2000 ML20211P2211999-09-0808 September 1999 Forwards Insp Repts 50-373/99-14 & 50-374/99-14 on 990809- 13.No Violations Noted.Insp Concluded That Emergency Preparedness Program Maintained in Good State of Operational Readiness ML20212A8571999-09-0707 September 1999 Informs That Proprietary Document, Power Uprate SAR for LaSalle County Station,Units 1 & 2, Rev 2,Class III, NEDC-32701P,submitted in ,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20211Q6861999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Plant License Applicants During Wks of 001113 & 20. Validation of Exam Will Occur at Station During Wk of 001023 05000374/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl1999-09-0303 September 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl ML20211M1151999-08-31031 August 1999 Requests That Following Eleven Individuals Take BWR Gfes of Written Operator Licensing Exam to Be Administered on 991006 ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211G1831999-08-27027 August 1999 Provides Addl Clarification of Proposed Refueling Practices Under Proposed Core Alterations Definition Re 990813 Application for Amend to TS ML20211F8731999-08-25025 August 1999 Forwards Insp Repts 50-373/99-13 & 50-374/99-13 on 990804-06 & 09-11.No Violations Noted.Fire Protection Program Strengths Includes Low Number of Fire Protection Impairments & Excellent Control of Transient Combustibles U-603229, Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl1999-08-25025 August 1999 Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl U-603258, Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage1999-08-23023 August 1999 Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage ML20211D2201999-08-23023 August 1999 Confirms 990817 Telcon with J Neuschwanger & D Mcneil Re Arrangements Made for NRC to Inspect Licensed Operator Requalification Program at Plant U-603243, Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.71999-08-23023 August 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.7 ML20211B0871999-08-20020 August 1999 Responds to J Hopkins Inquiry Re Application for Order Consenting to License Transfer & Approving Conforming Administrative License Amend Filed by Ilpr & Amergen Energy Co on 990723 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217H6341999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for Kh Curran,Lm Gerlach,Rc Weber & Bt Rhodes Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC Form 396 Encl.Proprietary Info Withheld ML20217H6251999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for MR Kahn,Aj Mclaughlin,De Montgomery & Kr Murphy Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC from 396 Encl.Proprietary Info Withheld ML20217F4301999-10-14014 October 1999 Responds to 991012 Rai,Based on 991001 Telcon Re Suppl to Request for TS Change to Revise MCPR Safety Limit & Add Approved Siemens Topical Rept for LaSalle County Station, Unit 1 U-603280, Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p)1999-10-12012 October 1999 Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p) ML20217C0871999-10-11011 October 1999 Forwards Proprietary Attachment Inadvertently Omitted from Encl 2 to Submitting Responses to NRC RAI Re License Transfer Application for Plant.Proprietary Encl Withheld U-603276, Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included1999-10-0808 October 1999 Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included ML20217C1671999-10-0808 October 1999 Provides Suppl to RAI for Approval of Unreviewed Safety Question Re Assessment of Certain safety-related Concrete Block Walls at LaSalle County Station,Units 1 & 2 U-603275, Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station1999-10-0707 October 1999 Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station U-603279, Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld1999-10-0707 October 1999 Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld 05000373/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl1999-10-0404 October 1999 Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr U-603272, Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl1999-09-22022 September 1999 Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl ML20212G6981999-09-20020 September 1999 Requests That NRC Reject Proposed License Transfer for Clinton Power Station & That NRC State That Public Interest in Safe Nuclear Power Industry Will Not Be Subordinated to Interest in Maximizing Profit by Limiting Liability U-603225, Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl1999-09-20020 September 1999 Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl 05000374/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl1999-09-20020 September 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl 05000461/LER-1996-010, Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events1999-09-13013 September 1999 Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events U-603269, Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed1999-09-10010 September 1999 Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed 05000461/LER-1999-011, Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments1999-09-10010 September 1999 Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments ML20211Q9911999-09-10010 September 1999 Informs That License SOP-4048-4,for Wp Sly May Be Terminated Due to Individual Retiring 05000374/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl1999-09-0303 September 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl ML20211M1151999-08-31031 August 1999 Requests That Following Eleven Individuals Take BWR Gfes of Written Operator Licensing Exam to Be Administered on 991006 ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211G1831999-08-27027 August 1999 Provides Addl Clarification of Proposed Refueling Practices Under Proposed Core Alterations Definition Re 990813 Application for Amend to TS U-603229, Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl1999-08-25025 August 1999 Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl U-603243, Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.71999-08-23023 August 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.7 U-603258, Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage1999-08-23023 August 1999 Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage ML20211B0871999-08-20020 August 1999 Responds to J Hopkins Inquiry Re Application for Order Consenting to License Transfer & Approving Conforming Administrative License Amend Filed by Ilpr & Amergen Energy Co on 990723 U-603259, Provides Notification That Cl Kreidler Has Resigned Position with Util,Effective 990818.License Status Should Be Changed to Expired1999-08-19019 August 1999 Provides Notification That Cl Kreidler Has Resigned Position with Util,Effective 990818.License Status Should Be Changed to Expired U-603253, Notifies NRC That Je Smith,License SOP-30819-1,has Resigned from Position with Ilpr Effective 990813.Status of License Should Be Changed to Expired,Effective 9908131999-08-16016 August 1999 Notifies NRC That Je Smith,License SOP-30819-1,has Resigned from Position with Ilpr Effective 990813.Status of License Should Be Changed to Expired,Effective 990813 U-603250, Notifies NRC That Ma Freihofer (License SOP-31296-1) Has Resigned from Position with Illinois Power Effective 990729 & License Status Should Be Changed to Expired Effective 9907291999-08-10010 August 1999 Notifies NRC That Ma Freihofer (License SOP-31296-1) Has Resigned from Position with Illinois Power Effective 990729 & License Status Should Be Changed to Expired Effective 990729 U-603249, Notifies NRC That He Bouska (License SOP-3055-1) Has Resigned from Position with Illnois Power Effective 990809. & License Status Should Be Changed to Expired Effective 9908091999-08-10010 August 1999 Notifies NRC That He Bouska (License SOP-3055-1) Has Resigned from Position with Illnois Power Effective 990809. & License Status Should Be Changed to Expired Effective 990809 ML20210N2961999-08-0909 August 1999 Forwards Form of Nuclear Decommissioning Master Trust Agreement,Per CPS Application for License Transfer & Conforming Administrative License Amend U-603248, Requests Unrestricted License for Kc Scott,License SOP-31532.Scott Has Successfully Completed Facility Licensee Requirements to Be Licensed as Operator/Senior Operator Per 10CFR551999-08-0606 August 1999 Requests Unrestricted License for Kc Scott,License SOP-31532.Scott Has Successfully Completed Facility Licensee Requirements to Be Licensed as Operator/Senior Operator Per 10CFR55 ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed U-603236, Forwards Revised Data Point Ref File Sheets for Clinton Power Station Computer Points That Input to ERDS1999-08-0202 August 1999 Forwards Revised Data Point Ref File Sheets for Clinton Power Station Computer Points That Input to ERDS ML20210J0541999-07-30030 July 1999 Forwards Three Original Signature Pages of Gr Rainey for Application for License Transfer & Conforming Administrative License Amend, for NRC Files U-603178, Forwards Four ASME Section XI Relief Requests Re Performance of non-destructive Exams for First 120-month Inservice Insp for CPS1999-07-29029 July 1999 Forwards Four ASME Section XI Relief Requests Re Performance of non-destructive Exams for First 120-month Inservice Insp for CPS U-603237, Informs That Util Will Provide Response to fire-related Questions One & Two of NRC RAI Re CPS Ipeee,By 0001311999-07-28028 July 1999 Informs That Util Will Provide Response to fire-related Questions One & Two of NRC RAI Re CPS Ipeee,By 000131 U-603240, Forwards Clinton Power Station semi-annual Fitness for Duty Rept for Period Ending 990630,IAW 10CFR26.711999-07-27027 July 1999 Forwards Clinton Power Station semi-annual Fitness for Duty Rept for Period Ending 990630,IAW 10CFR26.71 U-603235, Forwards Application for License Transfer & Conforming Administrative License Amend for OL NPF-62.Proprietary & Nonproprietary Asset Purchase Agreement Encl.Proprietary Info Withheld,Per 10CFR2.7901999-07-23023 July 1999 Forwards Application for License Transfer & Conforming Administrative License Amend for OL NPF-62.Proprietary & Nonproprietary Asset Purchase Agreement Encl.Proprietary Info Withheld,Per 10CFR2.790 05000373/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed1999-07-23023 July 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed ML20209E1211999-07-14014 July 1999 Submits mid-cycle Rev of COLR IAW LaSalle County Tech Spec 6.6.A.6.d.Rev to COLR Was Necessary Due to Implementation of TS Change Approved by Ltr Dtd 990212,which Changed Turbine Stop Valve & Turbine Control Valve Scram ML20209E0341999-07-0909 July 1999 Provides NRC with Siemens Power Corp (SPC) Fuel & GE Fuel MCPR Data for LaSalle Unit 1 Cycle 9.LaSalle Unit 1 Is Currently Scheduled to Start Cycle 9 in 991101 ML20209G3901999-07-0909 July 1999 Informs NRC of Status of Commitments & Requests NRC Concurrence for Use of ASME Section III App F Acceptance Criteria to Permanently Qualify Units 1 & 2 Penetrations M-49 & M-50 ML20210C1521999-07-0909 July 1999 Forwards Post-Outage (90 Day) Summary Rept for ISI Examinations & Repair/Replacement Activities Conducted from Beginning of First Insp Period of Second ten-yr Insp Interval Through L2R07 Refueling Outage ML20209E0361999-07-0808 July 1999 Forwards LaSalle County Station Unit 2 Cycle 8 Startup Test Rept Summary,Iaw TS NPF-18,Section 6.6.A.1.Startup Test Program Was Satisfactorily Completed on 990501 U-603231, Forwards Summary of Status of Plan for Excellence (Pee) Initiatives & Clinton Power Station (CPS) 1999 Business Plan.Encl Documents Provide Status & Disposition for Actions Not Completed to Date1999-07-0707 July 1999 Forwards Summary of Status of Plan for Excellence (Pee) Initiatives & Clinton Power Station (CPS) 1999 Business Plan.Encl Documents Provide Status & Disposition for Actions Not Completed to Date U-603214, Forwards Results of Analysis Performed on Recently Completed Vendor Contracts,Per GL 83-28, Required Actions Based on Generic Implications of Salem ATWS Events1999-07-0606 July 1999 Forwards Results of Analysis Performed on Recently Completed Vendor Contracts,Per GL 83-28, Required Actions Based on Generic Implications of Salem ATWS Events 1999-09-30
[Table view] Category:PUBLIC ENTITY/CITIZEN/ORGANIZATION/MEDIA TO NRC
MONTHYEARML20056A2931990-07-30030 July 1990 Forwards Endorsements 51 & 32 to Nelia Policy NF-261 & Maelu Policy MF-121,respectivley ML19325E9801989-11-0101 November 1989 Requests That Author Name Be Placed on Distribution List Re Schedule of Hearing in Alchemie Case.W/Certificate of Svc. Served on 891101 ML20247F8061989-07-0505 July 1989 FOIA Request for Documentation Re Incidents of Drug &/Or Alcohol Abuse During Past Five Yrs Amoung Employees or Contractors ML20247E6951989-06-27027 June 1989 Advises That Newly Formed Environ Conservation Organization Intends to Oppose Any Util Actions That Might Impact Negatively on Future Operability of Facility ML20247H3631989-06-26026 June 1989 Advises of Formation of Resources Conservation Organization. New Group Intends to Oppose Any Util Actions That Might Impact Negatively on Future Facility Operability.Ad Rossin Will Serve as Organization Coordinator ML20245B3981989-05-0808 May 1989 Discusses Technical & Safety Concerns Re Flow & Pressure Drop Calculations for RWCU & Feedwater & Condensate Sample Panels at Plant ML20245B4081989-03-10010 March 1989 Requests Response to 881014 & 890119 & 23 Ltrs Re Technical & Safety Concerns at Plant ML20244B0011989-03-0808 March 1989 Lists Facts to Consider for Action to Fix or Close GE Reactors Once & for All ML20245B4091989-01-23023 January 1989 Refers to Re Corrosion Inhibitors in Closed Water Sys at Plant.Last Sentence on First Page of Ltr Should Be Changed to Read One Example Is Loss of Air Cooling to Shutdown Board Rooms at Sequoyah ML20245B4101989-01-19019 January 1989 Requests That Jg Partlow Pursue Completion of Engineering Assignment of ED Buggs at Plant Concerning Corrosion Inhibitors for Closed Water Sys.Draft Engineering Rept Recommending Corrosion Inhibitors for Closed Water Sys Encl ML20206D8951988-10-15015 October 1988 Expresses Opinion That Plants Should Remain Closed Until Converted to Alternative Fuel Source ML20245B4121988-10-14014 October 1988 Informs of Several Technical Concerns Expressed While at Util & Requests That Jg Partlow Pursue Resolution of Listed Concerns ML20206D9711988-09-0808 September 1988 Forwards Ltrs Exchanged Between NRC & Author in 1984 Re Problems in Commercial Nuclear Power Field & Change in Federal Regulations to Allow Senior Reactor Operator to Deviate from Tech Specs in Emergency ML20206D9451988-08-12012 August 1988 Annotated Ltr Expressing Appreciation for Reply to & Assurance in Response to Concerns Pertaining to Operation of Ref Plants ML20245D6611988-08-0808 August 1988 Submits Listed Comments in Response to Re Safety Practice to Schedule Nuclear Plant Operating & Maint Personnel for 16 H Shifts &/Or Excessive Overtime ML20206E0281988-07-0707 July 1988 Advises That Nuclear Industry Overlooked Most Important Lesson Resulting from TMI Accident,To Wit,That Station Operator/Mgt Official Stationed in Control Room Would Have Prevented Accident ML20151X9371988-07-0101 July 1988 FOIA Request for Le Phillips 880407 Memo to Ma Ring ML20150A7961988-06-30030 June 1988 Comments on Util 880616 Request to Suspend Antitrust License Condition.Economic Advantages for Util Owning Nuclear Power Plants Have Failed to Materialize ML20155B6651988-06-16016 June 1988 FOIA Request for plant-specific Documents Re Fire Protection Requirements,Insp repts,hardware-specific Deficiencies & NRC Communications W/Util ML20206E0361988-04-29029 April 1988 Opines That 10CFR50.54(x) & (Y) Superfluous & Dangerous.Nrc Should Instruct Operators Not to Depart from Tech Specs in Emergency.Author Resume Detailing Experience in Commercial Nuclear Power Field Encl ML20155A7431988-02-24024 February 1988 Discusses Safety Problems at Comm Ed Nuclear Power Plants Re Risking Fuel Meltdown by Turning Off Safety Sys as Directed by Util Policy in Emergency If Core Cooling Is Adequate. Vice President Instruction Encl ML20148G9001988-02-0101 February 1988 FOIA Request for Documents Re 10CFR50,App R Insps & Enforcements ML20206E0431988-01-29029 January 1988 Expresses Concern Re Two Hazardous Practices at Ref Plants, Including Risking Meltdown by Authorizing Operators to Turn Off Nuclear Plant Safety Sys During Emergency ML20149G1051987-12-18018 December 1987 Opposes NRC Reduction at TMI-2.Reducing Staff Prior to Completion of Core Removal Inappropriate & Misguided Move. Recent Shutdown of Oyster Creek for Incident Re Destruction of Data Decreases Util Standing W/Local Residents ML17303A6161987-09-30030 September 1987 Forwards Scenario Review for Rancho Seco Emergency Preparedness Exercise,871104. Incomplete Scenario Provided for Review.Plant data,in-plant Chemistry & Radiological Data & Controller Info to Support Fire Drill Missing Elements ML20235T7341987-09-0101 September 1987 Requests That EIS Documents Re Meltdown Prepared by Impartial Sources Be Made Available to Public.Observation of Plant Life Indicates Level of Contamination of General Environ Causing Widespread Severe Damage ML20238B7731987-08-0707 August 1987 FOIA Request for Records Explaining Status of Listed LERs Omitted from List,Previously Received from Nrc,Of LERs Filed by Commercial Nuclear Power Plant Licensees for Operating Year 1986 ML20238E0261987-07-15015 July 1987 Responds to Recipient 870528 Response to Bg Strout Re Maine Yankee & Pilgrim.Author Distressed by NRC Answers & Requests Addl Response to Listed Questions ML20235L7061987-07-0808 July 1987 Opposes Util Application for Amends to Licenses,Allowing New Ownership & Financing Arrangement.Nshc Should Not Be Made W/O Public Hearings on Serious Financial Qualifications Questions ML20235K0421987-07-0202 July 1987 FOIA Request for List of All Licensed Reactor Operators & Senior Reactor Operators for Facilities ML20235F7451987-06-30030 June 1987 FOIA Request for Documents Re Safeteam Programs Being Used at Listed Facilities ML20215L4871987-06-23023 June 1987 Urges NRC Not to Approve Comm Ed Request for Amend of Any OL Re Braidwood 1 & 2 & Not to Determine No Significant Hazard Exists W/O First Holding Adjudicatory Hearings on Serious Financial Qualifications Issues ML20215L5051987-06-23023 June 1987 Provides Brief Updated Rept on Status of Comm Ed Proposal Before State of Il Commerce Commission to Restructure Ownership & Other Financial Arrangements Re Facilities.Urges NRC Not to Make Finding Prior to Hearing ML20215D6371987-06-12012 June 1987 Forwards Reply to Responses from NRC & B&W Owners Group. NRC Response Evidences No Independent Review of B&W Claims. Commission Urged to Take Personal Jurisdiction of Petition to Ensure That Latest Commitment Not Frustrated ML20236H1481987-05-30030 May 1987 Discusses Varga Reply to 870428 Mailgram Re Proof That LOCA Could Not Occur in Reactor Core at Plants.Evidence in Files of Repeated AEC & NRC Repression & Ignorance of Legitimate ACRS Concerns Cited.Congressional Hearings Requested ML20215K8391987-04-22022 April 1987 Opposes Licensing of Facilities for All the Same Old Reasons ML20214E2281987-04-16016 April 1987 FOIA Request for PRAs for Listed Plants Be Placed in PDR ML20214L0951987-03-13013 March 1987 Comments on Proposed Rule 10CFR50 Re Mod of Safety Rules to Enable Facilities to Startup Operation.Opposes Rule Due to Result of NRC Abdicating Responsibility as Protector of Safety of Populations Exposed to Radiation During Accidents ML20236D9381987-03-0404 March 1987 Partially Withheld Ltr Discussing Nuclear Power Industry Problems as Encountered During 6 Yrs of Employment at Limerick.Shoreham, & Hope Creek.Demotions & Terminations for Reporting Safety Concerns Described ML20215K8531987-02-24024 February 1987 Advises That Nassau County Board of Cooperative Educational Svcs Has Not Entered Into Any Agreement W/Lilco to Have Salisbury Campus Used for Relocation Facility in Event of Radiological Emergency ML20207T2381987-02-18018 February 1987 FOIA Request for Rept on Odds of Large Radioactive Release at Us Commercial Nuclear Reactors,Including Surry,Peach Bottom,Sequoyah,Grand Gulf & Zion ML20236D1281987-02-15015 February 1987 Forwards Preliminary Investigation of Worker Allegations About Safety of Plant Conducted by Gap in 1986.Investigation Revealed Enough Info to Raise Serious Questions Re Const Quality.Petition Per 2.206 Forthcoming ML20211B6601987-01-0505 January 1987 FOIA Request for Documents Re Allegations,Investigations, Fines,Convictions & Other Dispositions of Cases in Which Operators of Listed Facilities Charged W/Violating Federal whistle-blowing Statutes ML20207Q0971986-12-29029 December 1986 FOIA Request for Documents Re Util Proposed Reduction of EPZ at Seabrook,Changes to Containment at GE Plants, Including Pilgrim & Vermont Yankee & Insp of Pilgrim 1 Since Shutdown in Apr ML20215K9121986-11-26026 November 1986 Requests Opinion of Fairness of Shoreham Proceeding ML20212D7651986-11-12012 November 1986 Expresses Safety Concerns Re Containment Pressure Boundary, Based on 850916 Sser ML20210S9971986-10-0202 October 1986 Requests Change in Facility Svc List Address to Ref Address. Related Correspondence ML20215K9561986-09-22022 September 1986 Supports Licensing of Facility Due to Close NRC Scrutiny of Const & Operation ML20213C7931986-09-12012 September 1986 FOIA Request for Documents Re Western Piping & Engineering Pipe Clamps Furnished to Perry 1 & 2 & Van Meter 820607, 0721,0818 & 840125 Complaints to NRC Re Design Deficiencies at River Bend ML20211C5631986-09-12012 September 1986 FOIA Request for Three Classes of Documents Re Use of Western Piping & Engineering Clamps at Perry Nuclear Power Plant & All Complaints/Correspondence Involving Deficiency Complaint at River Bend Plant 1990-07-30
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GOVERNMENT ACCOUNTABILITY PROJECT <
Institute for Policy Studies 1901 Que Street, N.W., Washington. D.C. 20009 h^) (202)234-9382 July 26, 1982 The Honorable Nunzio J. Palladino Chairman -
U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Chairman Palladino:
On behalf of our clients, Mr. Albert T. Howard and Ms. Sharon Marello, the Government Accountability Project (" GAP") of the Institute for Policy Studies requests that the Nuclear Regulatory Commission ("NRC") conduct a full investigation of the enclosed evidence before permitting full power operation of the LaSalle Nuclear Power . Station _(Unit I) in LaSalle County, Illinois.
We requesn that the Comission's Office of Investigations ("OI") replace Region III ("RIII") in its ongoing investigation of LaSalle and the Zack Company, to which the enclosed evidencT pertains.
s We further request that the Commissioners direct the office of Inspector and Auditor ("OIA") to investigate the performance of RIII's Office of Inspection and Enforcement. More specifically, we believe that RIII's oversight of LaSalle was inadequate in three arcas--
(1) failure to act for three months on serious evidence of tr a Quality Assurance ("QA") breakdown and possible ' criminal falsification at LaSalle's Heating, Ventillating and Air Conditioning ("HVAC") contractor,'the Za'ck Company, on the ,,
eve'of ' full power operations at LaSalle despite urgent and then-independent requests from Mr. Howard and GAP; (2) failure to uncover the Zack QA breakdown during its ongoing regulatory program; and i (3) failure to honor commitments made last November to correct RIII investigative deficiencies confirmed by OIA l Report, Special Inquiry re Adequacy of IE Investigation 50-358/80-9 at the William H. Zimmer Nuclear Power Plant (August 7, 1981).
Our action is based on the investigation our organization has conducted cver the past five months, from March 1982 to date, as well as on evidence Mr. Howard, Ms. Marello and other witnesses have presented to us regarding the Region III LaSalle investigation. Enclosed as Attachment 1-8 is a packet containing Mr. Howard's affidavit and 44 exhibits Ms. Marello's t
affidavit; an affidavit from Mr. Charles Grant III; and six memoranda 8305190097 830311 PDR FOIA PRENDER82-366 PDR
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[ ~The Honorable Nunzio J. Palladino July 26, 1982 summarizing . verification interviews. conducted by our staff. The interviews.
confirm the personal integrity of Mr. Howard and Ms. Marello, as well as the substance of their allegations. All witnesses except for personal references are former or current Zack employees. Our evidence directly challenges the credibility of Region .III's July 19 recommendation for a full power license.
a GAP is a non-profit, non-partisan public interest organization that assists federal cnd corporate employees who report illegal, wasteful or improper activities by their agencies or organizations. GAP also monitors govern-mental reforms, offers its expertise about personnel issues to Executive Branch offices and agencies, responds to Congressional requests for analysis of issues related to accountable government and disseminates significant information about problems to appropriate places within the governnent.
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our review of the recently issued IaSalle Report (Inspection Report No.
50-373/82-35 (July 19,1982)) reveals more deference to utility timetables than Region III has demonstrated in the past, particularly at the Zimmer station in Moscow, Ohio. Although we have had only one week to review, analyze and study Region III's report, it clearly suffers from serious omissions. This type of investigation leaves the public less realistically ~
assured than if no investigation: had SFen conducted at all.
Specifically, . the report ignored the evidence on Zack presented by Mr. Howard nearly three months ago, on May 3,1982. . Second, Region III totally ignored significant issues _that dealt with the causes of the Quality Assu,rance deficiencies at LaSalle, such as retaliation and manipulation of the QA program through short-staffing, conflicts of interest, and advance warning l of QA inspections.
Our review of the allegations actually covered indicates that the LaSalle investigation relied far too heavily on the utility's paperwork, while ,
foregoing witness interviews and independent hardware tests. We discovered that Region III investigators failed to take sworn statements from key
witnesses who had not already provided' affidavits to GAP or the Illinois State Attorney General's office. GAP had already worked closely with some of these witnesses. Our decision not to take affidavits from these
-- ' employees was a gesture of good faith toward Region III; unfortunately,
.it was not returned.
We also found a disturbing manipulation of the allegations by omitting key facts, thus making it easier to reject the charges. Issues presented by conscientious workers were consistently rejected on the basis of suspect utility paperwork or " independent" tests that were, in fact, controlled by the utility. Further, and most seriously; the NRC's Region III office has
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t once again failed to independently explore the full extent of the problems at a nuclear power plant before dismissing the examples as insufficient by themselves to pose a public health and safety threat.
1 The Nuclear Regulatory Commission has often promised to improve the dependability and quality of its investigations; however, the flaws of the i
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, The Honorable Nunzio J. Palladino ' July 26, 1982 e
LaSalle probe confirm. that NRC probes continue to rely bn the utility's good faith and paperwork. It is very clear that whenever there was a conflict between eyewitnesses and utility paperwork, the paperwork won.
Unfortunately_the affidavits and evidence.provided by.our clients reveal that the paperwork for the' LaSalle site cannot be trusted.
The LaSalle investigation represents a major setback in the NRC's outreach effort to nuclear plant employees. No longer in good conscience can we recommend to nuclear workers that they speak to the NRC without counsel present. Mr. Howard, who was speaking for the fired Zack employees, had irreversible. personal damage. Although as spokesman for the- group Mr. Howard went to the Regional NRC office on the first work day after the entire QA department was dismissed .and talked to eight investigators, notcone.
informed him that he and his colleagues had only 30 days to file an appeal-for relief under 48 U.S.C. 95851 to the Department of Labor. As a result, their legal rights to administrative relief were sacrificed. -
Region III also publicly misrepresented his disclosure in an attempt to justify its own initial inaction. This is intolerable.
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I. ZACK ALLEGATIONS .
. Background - - -
In the fall of 1981 the Zack Company, a Heating, Ventillating and Air Conditioning ("HVAC") contractor, hired Ms. Marello, Mr. Howard, and a number of other individuals to establish a Quality Assurance Documentation Control office. Their assignment was to insure that the Zack Company had a Docu-
. mentation Department that complied with 10 C.F.R. 50, Appendix B, the American National Standards Institute (" ANSI") codes, and the contract ,,
specifications of their various clients in nuclear business. Their specific assignment was .to control .the documentation -- purchase orders ("P.O. 's") ,
material certifications ("certs"), material traceability records ("M.T.R.")
and certificates of conformance ("C.C.") . This involved the monitoring of over 3000 purchase order " packages." ' Each package represented the proof of quality for up to thousands of items used to construct the Clinton, LaSalle or Midland nuclear power stations.
Mr. Howard was hired as the Documentation Control Room Supervisor. Ms. Marello was a clerk. They, and the three or four other Documentation Control Room employees were allowed -- in fact assigned -- to investigate documents con-tained in Zack's files. Their task was to verify the accuracy, or identify the -inaccuracies to the purchase order packages. This task gave them free access to the Zack files, and also placed them in a good position to observe the " paperwork trail" of Zack's nuclear documents.
In six and a half to seven months, Ms. Marello and Mr. Howard discovered and challenged a quality assurance breakdown that leaves reliability of HVAC systems, and the overall QA programs at three nuclear plant sites in serious N
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The Honorable Nunzio J. Palladino July 26, 1982
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question. Their experiences reflect a contractor operati'hg for years without regard for the Atomic Energy Act, and consequently the publ'iq health'and saf e ty. \
'Ihey discovered documentation that had altered specifications, some with
" white out," missing certifications, purchase ord'ers with 'no ASTM specifi-cations, purchase orders changed to reflect correct quality assurance .
approval, and adhesive stickers with questionable authenticity, used to modify documentation and reflect the correct standards. They also uncovered top-level Zack management attempts to convince vendors - with some success --
to provide inaccurate quality and traceability certifications after-the-fact.
Both Mr. Howard and Ms. Marello worked in the Document Control Room at the Zack headquarters. Although they received no formalized Quality Assurance training, they, and th'e rest of the QA department, did become familiar with the various codes, contract specifications, and regulations that allegedly governed their work.
Unfortunately they suffered a pattern of harassment and attempted intimidation.
The pressure increased as Zack strove unsuccessfully to meet unrealistic time demands imposed by Commonwealth Edition ("Com Ed"), which wanted the paperwork resolved to avoid licensing delays at i_t,s,LaSalle site. The_ tension became so severe that Ms. Marello was eventually hospitalized.
Last August Zack had notified the utilities of a potential nonconfoming condition under 10 C.F.R. 850.55(e), due to inadequate and inaccurate quality and identification records on vendor purchases. They also attached. a Cor-rective Action Report (" CAR") plan which outlined Zack's intention to identify, analyze and correct all the paperwork problems at the compaqy headquarters.
This CAR also outlined the steps Zack would take to insure that the proper individuals responsible for this were appropriately disciplined..
As pressure mounted to have the LaSalle nuclear plant load fuel, the QA ..
department at Zack fell under greater pressure to close out nonconfomance reports ("NCRs") that detailed the Zack QA documentation deficiencies at LaSalle. Mr. Howard refused to provide a final report to Com Ed. On March 1, Zack suumitted 99 remaining NCRs to Com Ed. Zack warned it was unlikely l that necessary documentation to correct deficiencies could be obtained.
This frank admission did not deter the utility and NRC rush to begin operations at LaSalle. Com Ed received permis,sion to load fuel.
On April 13 and 15, 1982 Mr. Howard, acting as a spokesman for the entire Zack Quality Assurance department, had contacted an individual in the Consumers Power Company's Midland Project Quality Assurance department.
l This individual had represented to Mr. Howard and other members of the department that they should feel free to bring any allegations or problems at Zack to Midland's internal grievance system. Ho also guaranteed them confidentiality and protection from losing their jobs.
On April 18, 19 and 20, an audit team from Consumers and the Bechtel Corpor-ation arrived in the Chicago office. The QA department anticipated a complete i
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9' The Honorable Nunzio J. Palladino 5- July 26, 1982 investigation and professional support for its effort. However, their anticipation was belied as naive. On April 30 the entire department was dismissed, allegedly due to an office reorganization.
On May 3, 1982, the first working day following the purge, Mr. Howard began a series of contacts with Region III. He provided specific allegations about LaSalle and to a lesser extent Midland and Clinton, evidence and his offer of full cooperation with an NRC investigation. However, nothing happened.
After 2 months, when Mr. Howard and the others realized the NRC was not going to respond to their allegations, which had cost them their jobs, they took their information to the press and then to GAP.
Specific Allegations The three affidavits, exhibits and supporting verification memoranda evidence specific allegations about Zack.'s QA documentation and utility oversight.
Certain issues pertain to the fundamental of Zack's QA program-
- 1) Absence of any formal Quality Assurance Documentation Program--
Until Ms. Marello, Mr. Howard and othm were hired in the fall of 1981 to honor corrective action commitments entrer was no QA formal program for documents.
As a result, they were in an uncoptrolled state, ,i_.e.,' a mess. Documents were piled on the floor. (Attachment 1 3, at 1-2; Att. 3, at 1; Att. 8, at 4-5) . ,
- 2) Inadequate qualifications of personnel performing significant roles-- Individuals without any previous nuclear experience were assigned to make decisions requiring engineering judgment, as well as detailed know-ledge of professional codes and legal requirments for QA documentation. They received these assignments despite protesting that they were, not qualified to make such significant decisions. The qualifications deficiencies extended to the Zack auditors. .( Att. 1, at 1-2, Att. 2, at 3-4; Att. 3, at 2-3; Att. 8, at 5, 11-19). .
- 3) Missing documentation and discrepancies in welder qualifications records- 'Ib illustrate, an October 23 Interim Report found 25 discrepancies in a partial review of welding qualifications records for the LaSalle site.
(Att. 2, at 7; Att. 8, at 13) .
I l 4) Inadequate training for QA personnel-- Despite repeated requests l for comprehensive training, Zack only offered informal guidance and self-study materials. To illustrate the quality of the training, Zack President Christine DeZutel and her husband were trained "in accordance with the Zack Company Quality Assurance Training Program" on the basis of one hour's instruction from a Zack executive in NRC regulations and professional QA standards. The company finally proposed a formal training program shortly
! . 2/"Att." All references to Attachment 8 incorporate the relevant '
accompanying exhibits.
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The Honorable Nunzio J. Palladino July 26, 1982
\ before -it dismissed the entire QA documentation . staff. (Att. 21, at 2:
Att.~2, at 2-3; Att. 3, at 2-3; Att. 4, at 1;-and Att. 8, at 5, 18-19, 24).
N A second category of allegations concern incomplete. Zack QA documentation--
-5) Missing records due to inadequate document control-- Both unauthorized management personnel, and even the owner's dog, had access to Zack' QA records and Pu'rchase Orders. As a result, records were lost or' chewed up. (Att. 1, at . 3 ; Att. 2, at 5; and Att. 3, at 1) .
- 6) Absence of required quality verification on documents that could be retrieved-- This ranged from missing signatures to missing required test data, specifications, and certifications to professional codes. (Att. 1, at.
2-3; Att. 3, at 2; Att. 8, at 4-5, 18) .
7)- Lack of proper identification titrough compliance with material traceability requirements-- This led to problems such as lack of required traceability for some 114,000 hexheads, bolts, nuts and similar items.
Similarly, certain steel beams could not be traced with certainty, although indications are that they come from Argentina. (Att. 8, at 17-18, 21-22) .
A third category of allegation concerns widespread falsification and improper modifications of Zack QA documents during the corrective action program for
- 8) Improper alteration of QA records through stickers containing. ,
signatures of questionable authenticity (Att. 2, at 3; Att. 3, at 2; Att. 8,_
at~14-15).
- 9) Improper alteration of QA records through whiting-out previous information in order to create the appearance of compliance with legal "
at 15) .
requirements (Att.- 1, at 2; Att. ,
( [. 8,LCt')
- 10) Improper requests by Zack management for vendors to supply uriavail-able information or to inaccurately upgrade quality documentation-- Some .
vendors, such as U.S. Steel, refused to participate in the improprieties.
l other vendors cooperated to the letter of the request, even retyping the spelling errors in model certification letters supplied by Zack. Another
, vendor returned a blank form for Zack to fill in as needed. (Att. 2, at 7; l- Att. 3, at 2: Att. 8, at 16, 25-6).
A fourth category of allegations involves deficiencies in Zack's program for purchases ' rom its Approved Vendors List-l l 11) Failure to distinguish between commercial and nuclear purchases on Purchase Orders-- Since items purchased for nuclear use have much stricter quality verification requirements than those purchased for commercial use, this omission led to the improper upgrading program described above. (Att. 2, at 2; Att. 8, at 18).
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- 12) Unqualified vendors on the AVL-- This occurred due to-the absence of necessary surveillance of vendor QA programs. (Att. 3, at 2-3; Att. 8,.at-15-16). -
- 13) Failure to remove unqualified vendors from the AVL-- Even if Zack determined a vendor were unqualified, tha: did not guarantee the vendor's removal from the AVL. For example, Zack received approximately 38 Purchase Orders from the Delta Screw Company during the period it'was " removed" from the AVL. (Att. 8, uat 18) . ,
A fifth area of allegations concerns the attitude of Zack management. It was incompatible with the Quality Assurance criteria of 10 C.F.R. Part 50, Appendix B-- -
- 14) Management awareness of QA breakdown-- Zack management was painfully aware of the problem. As the company conceded, "There has been a breakdown of the
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qualityassuranceprogramasrelatedtocriterions/ sic]VI-Documents Control, and VII - Control of purchased material, equipment and services...."
(Att. 8, at 6). The company promised reform and training to the QA staff.
But the commitments were not honored. Instead, Zack management scapegoated the staff for problems created by its own neglect. (Att. 2, at 6-7; Att. 3, at 3; Att. 8, at 10, 21-5) .
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- 15) Harassment, attempted intimidation and retaliation against QA staff--
All current and former Zack employees wM tere contacted confirmed this allegation. . The , tactics , included dismissal threats, severe personal abuse, accusations of petty misconduct, and eventually dismissal of the entire QA documentation staff through a pretextual_ reorganization. (See Att. 1-8, generally). .
- 16) Bad faith progress reports to the utilities--
Zack disguised its misconduct through false reassurances' to its utility customers. To illustrate, the company reported to Midland on a
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partial review of some 2,900 purchase orders'. Although the review was less "
- than half complete, the Zack President characterized it as a " total document l , audit." (Att. 1, at 2; Att. 2, at 3; Att. 3, at 2, Att. 8, at 6, 10, and I
Exhibit 43S) . .
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- 17) Failure to adequately discipline those responsible for records falsifica tio n-- The company promised its utility clients to identify and take apppropriate action against the guilty parties. Although the responsible
! executive was identified, the " appropriate disciplinary action" consisted of a paperwork demotion and additional training. (Att. 8, at 4, 6-7).
- 18) Surrender to unrealistic utility deadlines-- Zack was under intense pressure f rom its utility clients, in particular Com Ed, to rush the quality verification of its purchases. Rather than defend the integrity of its QA reform program, Zack succumbed and attempted to produce a " rush job." That is why the company pressured employees to work overtime and perform tasks l' for which, they weren't qualified. There wasn't time to do the job properly.
(When the QA staff refused to sign off on unacceptable records, management personnel did it themselves.) (Att. 1, at 3; Att. 2, at 4 ; Att. 3, at 1; Att. 4, at 2; Att. 8, at 7-6, 22).
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The Honorable Nunzio 'J. Palladino July 26, 1932 N
A final category of allegations involves the utilities themselves. Zack could not have persisted for' years in its misconduct without utility complicity--
- had) Utility knowledge of the QA breakdown- There can bgno question '
- that the utilities have been aware of the Zack breakdown.M company was the subject of previous requests to stop shipping nonconforming material, as well' as previous severe enforcement action 'at Midland, whose owner Consumers Power.even loaned a contract employee to help straighten out Zack's QA records deficiencies. (See Att. 2 and 8, generally). At LaSalle, ' Zack ' informed -
Commonwealth Edison that it could not supply adequate information to properly correct 69 of 99 QA nonconformances. (Att. 8, Exhibit 43S)..
- f4g) Utility complicity kith the ongoing breakdown-- When formally.
notified of Zack's miseries, the QA management for the utilities and, their contractors failed to face up' to their responsibilities. Instead, Com Ed--
pressured for a rush job in the corrective action program. At Midland, the contractor Bechtel was satisfied if it were " highly probable" that Zack ,
ordered - the correct mat.::ial. The Midland QA program responded to Zack's QA effort with an effort to rewrite the'QA rules. Even before the effort was completed, the Midland QA management decided that "in virtually all cases, .
- material is acceptable or will be deamed acceptable." (Att. 8, Exhibit 29, at 3). .That philosophy cannot coexist _with the Atomic Energy Act. (Att. 1,
, at 4 ; Att. 2, at 4-5; Att. 3, at 2-3; Att. '8, at 9-12,; 14, 20) .
I A pf) ' Utility complicity with retaliation- In desperation, Mr. Howard
[and another Zack QA employee, Mr. Ronald Perry,' disclosed the QA deficiencies to of ficials at LaSalle and Midland.- In each case the discussions.were sup--
- posed to be confidential. In each case,' the Zack employees were soon subjected -
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to recrimination and harassment, suggesting that the confidences were not honored. In Mr. Howard's case, the entire QA staff was dismissed within two
- 3. weeks of his disclosure -to the Midland QA Manager.
i 3DS) Inaccurate public denials by utilities of the Zack deficiences-- -
To illustrate, a Commonwealth Edison spokesman stated in a Chicago television [t -
interview that the Zack records were reviewed thoroughly by its Architect /.
Engineer Sargent and Lundy. In fact, an internal January 1982 Surveillance Report at LaSalle revealed Sargent and Lundy had-
... deleted the requirements for submitting on site contractor documentation (such as Zack's) to S & L for review. This review is now the responsibility of the Zack Company....
Based on this change, S s 'L's letter accepting Zack's docu-mentation is no longer required.
(Att. 8, at 11).
Contrary to the conclusions of the implicated organizations, the deficiencies summarized above are too serious to ignore or even to glance at superficially. ,
- As a Zack report conclu,ded, only 94 of 374 material packages sent to LaSalle '
were correct and accept <rble._ Mine were judged "No Good for LaSalle." (Em-phasis in original.) (Att. 8, at 7) . In some cases, it is too late for the I
o
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/ The Honorable Nunzio J. Palladino " July 26, 1982:
4.;
,17 vendors to supply verification information.on purchases,"made in 1978 or
- earlier.- The records simply aren't retained that long. (Att. 1,'at 2).
. -Nor can the NRC . accept Zack's work "as is" and permit any plant to operate with quality in an in' etermina'te s' tate.' ' As RIII Administrator James Keppler
~
d
- i. stated with respect t6 the Zimmer station, the utility would have to " rip out" i and replace critical components that lack adequate quality records.' ("On-Time -
Start-Up for Zimmer Plant Still Doubted by NRC Official," The Cincinnati Enquirer, p. D-5 (June 30, 1982). To_ illustrate the impact at LaSalle, it '
would magnify the danger and expense to rip out already installed items after the plant begins operations.
II. INADEQUATE NRC-INVESTIGATIVE OVERSIGHT
Background
l On December 8,1980, on behalf of Mr. Thomas Applegate, GAP charged that a RIII-E investigation violated. basic investigative standards through failure to speak with relevant witnesses; failure to take affidavits from key witnesses; exces-( sive reliance on utility paperwork to c.esolve allegations instead of conducting
'; necessary independent laboratory tests on the hardware; failure to investigate s
sufficiently to determine the causes of confirmed inadequacies; inaccurately summarizing employee allegations, with the effect of shrinking the allegations into insignificance;. and on-balance exonerations despite confirmation of specific problems, before learning tha full scope of the' deficiencies.
) Last -November-18, OIA released its August 7 report, which backed GAP's l charges.
l-In an October. 8,1981 memorandum to Chairman Palladino, Office of Inspector.
+and Auditor'(OIA) Director James Cummings observed that the probe Applegate -
and GAP challenged "did not satisfy...~ generally. accepted investigative standards of other Government agencies.. .. Fundamentals basic to all in-vestigations were simply not observed in this' instance." Cummings cited inadequate documentation highlighted by the total absence of interview reports, as well as the failure to pursue obvious leads. He surmised that serious-
, quality assurance welding problems the NRC uncovered last summer might have-i been exposed years ago if IE probes had been "sufficiently comprehensive ~to
. identify this issue 'in a timely manner."
i L In a November 16, 1981 letter to Congressman Morris K. Udall (D.-Ariz.),
l Chairman of the House Energy and Environment Subcommittee, you backed the L OIA criticisms. You concluded that the shortcomings in the Zimmer investi-gation " reveal a generic problem" with IE oversight. You pledged to consider
- ' the,"necessary internal reforms" for NRC probes to reach a level " consistent l' with fundamental standards that govern investigations by any agency."
In November Congressional testimony, NRC Executive Director for Operations William Dircks reaffirmed the commitment and pledged to deemphasize reliance l
I i
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The, Honorable Nunzio J'. Palladino July 26, 1982' on utility pape tQ.le increasing' reliance on witnesses and even a new NRC mobile laboratory testing unit. '-'
With respect to the LaSalle and Zack ailegations, RIII failed to honor this
, ' Mpledge.
- 1. s. . e s. .
To illustrate, the NRC response to the Zack allegations at LaSalle was.
reluctant, at best. On June 2,1982 GAP passed along ' the allegation of a vindicated Zack whistleblower from Midland that a Zack supervisor had confirmed the same abuses at LaSalle. The whistleblower, Mr. Dean Dartey, complained that RIII had refuped to investigate his allegations due to lack of specificity. Had RIII fol' lowed its normal practice of checking d5ficient purchase orders at one site that had also been sent to other utilities (see, e,.g., IE Rep. No. 50-358/81-13), the NRC would have learned that illegalities in Zack-supplied Midland purchases were repeated at LaSalle. (Att. 5).
Similarly, GAP made three attempts to convince RIII to pu'rsue evidence of mis-
~
conduct by Zack at'LaSalle. Mr. Howard made another half dozen attempts to convince RIII to investigate his May 3,1982 disclosure, and evidence, all without success.
In a July 19, 1982 letter to com Ed, Ad_ministrator James Keppler rationalized the omission by stating the Howard allegations applied primarily to LaSalle and had been deemed too general by the staff. As Mr.'Howard rebutted:
'Ihe NRC description in its LaSalle report ol our d meeting is absolutely false. I. spoke -in great detail and said my findings -
applied to all three sites. I emphasized problems at LaSalle more than Midland. I left my records with the staff that day,-
and more the next day.
- - Similarly, the July 19, 1982 RIII investigative report on LaSalle (IE Report
,No. 50-373/82-35) bears striking similarities to the Zimmer effort rejected
~
! last year at OIA.] The only major difference is that this year RIII is talking
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l to more witnesses before it relies on utility paperwork to reject their
( charges out of hand. That is particularly. inappropriate when the same investigative report found falsification of paperwork on-site, a finding further confirmed by massive amounts of falsified Zack records relied on at j LaSalle.
- j. -
Specifically, GAP charged that RIII-
- failed to take sworn statements from witnesses who had not already provided affidavits to GAP .
- totally ignored issues that dealt with the causes of QA deficiencies at LaSalle, such as retaliation, fear of which prevented almost half of witnesses contacted from speaking to the NRC; and manipulation of the QA program through short-staffing, conflicts of interest, and advance warnings of QA inspections;
[_ __ _ . , _ _ _ - . _ _ _ , . . - - .
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. i s, '.
4 .
A The Honorable Nunzio'J.' Palladino July 26, 1982.
/4
.N **reaefined the issues it did cover by omitting key facts, such as the location of. alleged deficiencies, making it easier to reject the charges;
~
- rejected witnesses' . allegations on' the basis of " independent" 4
tests in fact controlled by the utility, as well as suspect -
paperwork;
~ ~
- manipulated the evidence by failing to include key facts in. the report - such as its finding that approximately half of reinforce-ment bars were damaged - while concluding the plant is safe;
- looked at woefully inadequate test. samples on site, such as --
reinforcement bars on 9 drawings out of over 7000 relevant documents, or three mortar cores when literally tens of thousands of mortar blocks were suspect; and
- failed to independently learn the full extent of problems that j
were confirmed, before it dismissed those examples as insufficient
- by themselves to pose a public safety threat.
The differences between old and new NRC' investigations are cosmetic, at best.
s i
In short, the RIII investigative report on LaSalle was.a final opportunity to clear up serious-safety questions before' the plant began operation. .The
) ,
report . failed to answer the questions adequately at a critical' moment. .We are not contending that the LaSalle plant is unsafe. .On'the basis of this 4
-report, however,- the Comission cannot reasonably . assure the public that it is.. As a' result, Region III's Office of Inspection and Enforcement should be i
replaced .in the ongoing investigative effort on LaSalle and Zack.. OIA should investigate RIII's . actions in permitting the situation to develop this far.
Most significantly, the rush to begin operations. at LaSalle should be halted
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until all the safety issues can be investigated thoroughly and resolved with "
realistic confidence.
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Our request for this drastic action is not intended as an attack on individual RIII L investigators, or Regional Administrator James Keppler. Mr. Keppler has-i attempted to upgrade investigative techniques. He.also has taken the ' lead in tough public statements to improve utility QA efforts. Unfortunately, the l performance has not matched the promises or the rhetoric. The Commission-
. must take strong action to uphold -its ' regulatory mandate and to honor its l public commitments.
I-Sincerely,
- AO R __
THOMAS DEVINE BILLE GARDE **
. Legal Director Director, Citizens Clinic for '
Accountable Government Enclosures TD/BG/my i
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