ML20133C622

Responds to 831101 Request for Addl Info Re Issues Raised in Gap 830914 Petition Concerning Plant.Answers to Specified Questions Listed

ML20133C622
Person / Time
Site:	Catawba, 05000000
Issue date:	12/02/1983
From:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
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References
FOIA-84-722 2.206, NUDOCS 8507200540
Download: ML20133C622 (4)

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. 'i - . RER EDD 13553

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GdVERNMENT ACCOUNTADlLITY PROJECT . Tction - DeYounc_

Institute for Policy Studies .

(202) 234-C382 1901 Ove Street. N.W.. Washincton. O.C. 20000 ,

December 2,1983 ,

/Vo77 7?/El' Wg, corvimM Richard C. DeYoung Director, Office of Inspection 4 PFAOMU q -l and Enforcement United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. DeYoung:

This letter is in response to your November 1,1983 request for further information to assist you in understandine the significance of the issues raised by GAP in our September 14, 1983 Petition to the Commission about the Catawba Nuclear Power Plant.

This Petition was filed pursuant to 10 C.F.R. 2.205.

Your letter detailed four specific questions. My responses to those questions are illustrious, not compreherisive. However, I would be happy to meet with members of your staff to clarify other questions that they may have.

I have paraphrased your questions below, followed by my answers.

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1. O. Provide a list of critical reports by consultants.

A. The Catawba Power Plant has been the subject of several 'outside con-sultant inspections and investigati.cns in the past three years. The Manacement Analysis Corporation (MAC) reported issues in the Spring of 1982 which dealt only with the " technical concerns" of a croup of welding inspectors who complained tc upper-Duke Power Company- (DPC) management about a quality assurance implemer.tation breakdown, as well as harassment and intimidatien.

Your review ~of that report should include a full reacing of the transcript beine devel.oped in the Catawba Operating Licensing hear-ings before the Atomic Safety and Licensine Ecard ( ASLB) now being A

conducted in South Ca.rolina. ,

A review of the record will clarify that the MAC r.eport was limited ,

in scope from the enset and did not include ceneric issues raised by the welding inspectors. Specifically, your review should compare the_ technical concerns covered in the MAC report with the non-technical (generic) concerns detailed in the doc Non-Technical Welding Inspectors' Report.

-The hearing record (particularly testimony by Mr. Lewis Zwissler, Vice President of MAC) should provide illuminating information as to j the imposed scope of the MAC re-view. Further, testinony by DPC j 8507200540 850524 iR 7 ? PDR bY ,

[etem0er 2, iSE'

' e Ri fgrd C. DeYoung .

1. A. (continued) official r C. N. Alexander, will provide equivalent Testimony byinsight the into the alleged handling of the non-technical concerns. E3, also provides a h e welding inspectors, October 25 to December 1,19 re of their respective inquiries.

It is critical that the NRC re-open its review of the serious gene -

implications of such practices as failure to docu visors of i,dentified non-conforming conditions.

Another report is the Construction Project _ Ev l

using valuation methodology by the Institute for i t Nuclear s

Operations (INPO).

reports have been referred to by Catawba workers who)GAP inv have interviewed; however, GAP does not have a copy of their au

2. Q.

Provide further information from the Affidavit of the undersigned enable the NRC to evaluate these concerns.

Q. a)

Major hardware problems in the areas of hanger installatio electrical system, concrete, and HVAC equipment.

A. a)

Beginning in the late Spring and early Summer of 1983 gators facility.

conducted a preliminary. investigation of documentation (both DPC. and the NRC's) tors in all areas of construction.

The scope of our inquiry dealt only with The general allegationsconcerns con-AP preliminary quality and implementation of QA procedures.taine

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inquiry and documentation cross-references.

Specific areas of the Plant will be identified in w:rker A which GAP either has or will provide to the NRC.

Enclosed are copies of Affidavits .and scme testimony el in w

- presented Region II .

in recent weeks to "Insppction and E

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We expect a minimum of approximately 14 additional wo in the next f'ew v.onths.

b)

Details of incidents where DPC employees were toic not t Q. outsiders by DPC management, anc deteils of incidents of and intimidation.

This information has been provided in detail to ate theOIOf fic A. b) t.igation (01), and is now the subject of at least two investigations.

employees for thase* concern's to be

• handled by 01 inve 2 bf 79

Decem:v 2,15E3 l Richa rd 'C. DeYoung -

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2. A. b) (continued) ,

In short, we cons'ider our request for. an 01 investigation (pp. 41-45 of 2.206. Petition) granted.

Q. c) Specific information on workers contacted within Region II.

A. c) I have no further knowledce of whether or not this information was provided to either Region II or any other office of the NRC by these workers.

3. Q. Specific details concerning abuses of the R-2A form to legitipize construc-tion pushing ahead of QA/QC inspections.

A. The best evidence of the use or abuse of the R-2A form is contained in three sets of documents which we have reviewed. Our summary of these documents would abbreviate the necessary technical review required for adecuate evaluation. The NRC has the capability of conducting this

• • technical review, we do not.

In general explanation, however, R-2A's were used throughout the Plant to replace NCI forms. Although R-2 A's appear to have a legitimate purpose prior to the Fall of 1981, misuse becomes obvious during that time pe rio d. A study of the diaries , statements, pre-trial testimony, and hearing record of the welding QA inspectors details specific areas and incicents in which R-2A's allowed construction work to push forward withcut official QA/QC approvals.

One cood example of an on-going practice is described by Mr. Ec-McKenzie (testimony given November 30, 1983, ASLB hearing). Mr . Mc Ke nzie , 'n'el di n g Supervisor, testified that it was his belief and understanding that hard are components (in this case a piece of pipe which was identifiec as non-conforming by a QC inspector), remained in the control of constructi.on persennel until a (red tag NC:) was,. physically placed on the pipe. In the example described by Mr. McKenzie, he " raced" to cut out a bad piece of pipe already identified by a QC inspector before that inspector could return from the OA/QC office with a " red tag." Since R-2A's remain under the ::ntrei of construction, c:rrective acticns were n:t repaired te be docurented, and an indeterminate number of rcn-conforning conditions may have been corrected without tre icing or appr:priate reviews.

Numercus other examples of the submission of R-2A's insteac of NCI's and failure to trend R-2A's, and the disposi iening of R-2A's are ccniained in :ne workers statements' pretiously icen}tified. ,

Specific construction deficiencies in all ~of those. documents can only be considered illustrative. The NRC simply must perform or rec,uire an indeoendent analysis of the generic implications raised by these in-

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adepuate procedures and their implementation.

4. Q. Any information about Catawba v~endors not meeting regulatcry requirements.

A. See information provided in w:rker Affidavits (enclosed) and INPO report previously identified. Alth: ugh several DPC workers discussed the HVAC N/k

e ce-$e- : , i s: .

Rict.'a rc L.' De Young

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4. A. (continued) contractor generally, the most detaifed info,rmation is included in the Affidavits and. testimony previously discussed.

.In your. letter, you state that your staff will take "all reasonable Several steps of the to r.aintain in statements the confidentiality of. the sources of 'the information' ."

Enclosure 1 have been provide *d to the NRC staff under an express agreement of.confiden-tiality. We expect you to honor that agreement as well as your stated cortaitment in .

any respcnse to the Petition. .

We will continue to notify your office of relevant information when it is provided to fF.C Regien staff officers. ,

We would note for your information that a newspaper article which appeared in the

. November 27 editi1n of the Charlotte Observer contained a statement by an NRC Region That state-official which we consider inappropriate in light of your pending review.

ment, "We don't feel the allegations'have substance," is clearly inaccurate or your review is insincere. We hope that you and your staff will recognize the propriety of assuring the public that the review of the 2.206 Petition and worker information is thorough, competent, and not predetermined.

Thank you for your consideration in this matter.

Very truly yours, Uh b Billie Pirner Garde Citizens Clin.ic Director E?G:ce Encicsures: 1) Affidavit Witness A

'2) Affidavit Witness B '

3) Affidavit Ron McAfee 4

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