ML20032E086
| ML20032E086 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/30/1981 |
| From: | Ellen Brown CALIFORNIA, STATE OF |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8111190621 | |
| Download: ML20032E086 (10) | |
Text
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tcher 30, 1981
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3y. c Nunzio J. Talladino h4,g S
6 U.S. 'Jaclear Regulatetry Cmmission Washington, D.C.
.20535
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y Daar 11 an Palladino:
1 I am N dting in reference to the recent dieclosures of design, construction, and quality assurance errors at the n!351o Canyon nucl e ?cver plant I ask that you and your fallow cccsission-ers 4 ediatuly order an independent audit of the earthquake protection and other safety-related features of this plant.
Your prc=pt action in this regard would : serve not only the wMare of California and its citizens, but it would also ha.in the test interests of the URC
?G&B and the MRC staff have in the past repeatedly asserted that M@lo Canyon =et all requisite safety stend;rds, The discimuras of vericus errara by FG&E at Diablo -~
drselosures rada within tha very week that you licensed operation of the plant -- have undc% mined the NRC's credibility.
As a con ~
sequenca, I cub =it that the public will simply not helleve the results of any audit parformed by R$E or the SRC.
Indeed, for such an investigation to be received with any credibility, it must to perfor=ed by a tean c.f truly indnpendent experts who have no stake., real or a,pparent,.in the eutcc=o Ah.linglv, I as enclosing with this letter a ucc:kahln propo:ral for an independent audit that fccusna on the quality of the actual design and constr,tetion of the Diablo Canyon p1=*
l l
Califcrnia's citizens have avery. reason to expact that the 'JEC l
now take swift and decisive regulatory action to protect their I
health and safety.
It is clear that the cccmission nada a riistaka last - M 2 in licansing Diablo Canyon.
I ask that ycn take action to rectify that sistake, and that you order an independent audit and revoke the 7G5E licenso for Icw pcvar testing.
l Sincerely, o
u gd 6
Gov *ruce Esclosure 9111190621 811030 PDR ADOCK 05000275 G
PDR Cc2
@ M M Onera
6 October 29, 198 DOCKETED uuu =
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MEMORANDUM
@% OCT 301981 > 75 0500cf theSeewy M 000bting& Servi:e Q TO:
Dr. Harold Denton Sand Ne N
FROM:
Counsel to Governor Brown 7 j _
Co RE:
Proposed Diablo Canyon Quality Verification Program Since late September 1981, a number of serious errors in seismic design have been discovered at Diablo Canyon.
These errors have primarily involved problems in the development, distribution, and use of design data by PG&E and its engineering services subcontractors.
These errors were discussed at Commission and Staff meetings in Washington and at recent meetings with PG&E in San Francisco, California.
As a result of these discussions and investigations, it is now clear that each error involved a failu~e of PG&E to implement properly the 18 qu3lity assurance criteria of 10 C.F.R. Part 50, Appendix B.
Because PG&E failed to implement a. Quality Assurance /
Quality Control ("QA/QC") 1/
program which satisfies Part 50, Appendix B, and because this failure led to serious errors, 2/
there is now substantial uncertainty in the actual quality level achieved in design and construction of safety-related structures, systems, and components at Diablo Canyon.
Thic uncertainty is heightened by the Staff's forthright statement, made in light of PG&E's QA/QC deficiencies and widely reported in the press,
-1/
" Quality Assurance" comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satis-4 factorily in service.
Quality assurar.ce includes " Quality Control," which comprises those qualitt assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to control the quality of the material, structure, component, or system to predetermined requirements.
-2/
The seriousness of these errors cannot be disputed.
- Indeed, Dr. Harold Denton stated that the low power license would not have been issued if there erros had been known to the Staff before the NRC issued the license.
See Oct. 9 Meeting Transcript, p.
117.
L
. that further analyses by. experts will doubtless reveal further errors.
3/
The substantial uncertainty which surrounds the actual quality level achieved in design and construction of Diablo Canyon is clearly unacceptable under the licensing standards of the NRC's regulations.
Governor Brown proposes, therefore, that the NRC immediately order that an independent quality verification program be undertaken and completed, prior to fuel loading at Diablo Canyon. 4/-
The independent audit program proposed herein is not unique.
-Indeed, it is similar in concept to the " outgoing product quality" audit programs now used by the nation's nuclear equipment manu-facturers.
In such an audit, an " outgoing product quality" index is obtained by reconducting the acceptance tests and inspections on an equipment item that was previously accepted by QA as ready for shipment.
The index is a useful management tool to confirm independently that the desired level of quality is actually being achieved.
The following general guidelines are suggested for an inde-pendent physical reinspection and design review of the Diablo Canyon QA/QC program for design, construction, and operation:
1.
Selection of an Independent Auditor:
After consultation with all parties in the Diablo Canyon proceeding, the NRC should select an experi-enced QA/QC consultant to conduct the review.
The consultant must not be an employee or contractor of PG&E, Westinghouse, or any other contractor havinc direct responsibility for the Diablo Canyon QA/QC program.
Attached hereto for your consideration is a list of firms which appear to have the technical capability to conduct the type of review described herein.
These fi..ns, of course, must be screened to assure that they have no real or apparent conflict of interest in this matter.
3/
For example, the Wall Street Journal on October 26, 1981, quoted a Staff spokesman as stating:
"Obviously, if one engine r can find a problem by accident, it is reasonable to assume that an army of engineers second-guessing every-thing can find many more."
-4/
This proposal is separate from the need for the NRC to take straightforward licensing-related action that addresses the fact that the NRC mistakenly issued the low power license to PG&E.
. 2.
Steering Committee:
The independent auditor should perform its services pursuant to the oversight of a Cteering Committee.
This Committee should be composed of four persons, each with expertise on quality assurance matters.
One each should be selected by PG&E, the Staff, the Governor, and the Joint Intervenors.
3.
Scope of Design Review and Physical Inspection:
The assessment of the Diablo Canyon QA/QC program by the independent auditor should include:
(a)
A review of QA/QC design records for, and a physical reinspection of, one electrical system (the reactor protection system is suggested) and two mechanical systems, in-cluding the scructural supports, chosen from among the emergency core cooling systems (the safety injection and the decay heat removal systems are suggested).
This revieu should cover:
(i) the designation of safety-related items to determine whether the systems, structures, and components have been properly classified; (ii) the esign verification records to assure the adequacy of design criteria bases, the adequacy of design implementation, includ-ing the internal and external transmittal, distribution, and use of design data, and j
j the consistency betveen the design docu-ments and the FFAR commitments; i
(iii) training and qualification records for l
l design, construction, and inspection personnel; (iv) records concerning the identification and control of installed material, parts and components; (v)
Mecords concerning the control of special
?
c:onstruction processes; i
(vi)
- r. cords concerning the adequacy of disposi-tion of non-conformances;
4-(vii) -records of corrective action measures and timely.closecuts; (viii) PG&E audit findings, follow-ups, and resolutions; (ix) equipment qualification records; (x) drawing change control procedures including implementation for field changes; (xi) comparison of "as-built" drawings to-actual plant configuration; (xii) receiving inspection and test results; (xiii) material certifications; (xiv) concrete strength where applicable; (xv) visual inspection of the systems, in-cluding welds; (xvi) cable identification and separation; (xvii) control panel functional test results; (xviii) verification of the torque cf bolts; (xix) non-destructive test record interpre-tations; (xx) the progran for control of materials, parts and components for non-safety grade portions of the systems; and (xxi) a determination of the adequacy of the PG&E and major contractors' QA/QC programs and their implementation based on all the above.
(b)
A comparison of the PG&E design and construction QA/QC program to NRC Regulatory Guides cited in the FSAR related to QA/QC 2ctivities.
(c)
A review of PG&E's operational QA/QC program, including:
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. (i) the qualification of the Diablo Canyon.
QA/QC staff; (ii) lthe availability of QC personnel on off-shifts; (iii) the availability of "as-built" drawings; (iv) the selection of replacement materials and parts for safety-related items; (v) the applicability of the QA/QC program to replacement electrical and instrumentation components, modules', and equipment; (vi) the handling and installation of replace-ment parts and materials for safety-related items; (vii) the program for procurement of non-safety.
related replacement materials and parts; and (viii) a comparison of the PG&E operation QA/QC program to NRC Regulatory Guides cited in the FSAR related to QA/QC activities.
The Governor'c consultants and councel are prepared to dic-cuss uith the Staff further details in pursuit of the foregoing proposal.
We believe that a satisfactory investigation of the errors at Diablo Canyon calls for a cooperative Federal-State working relationship between the NRC and California.
Both levels of government have vital interests that are at stake in bringing about a sound resolution of this matter.
ATTACHMENT LIST OF SEVERAL POTENTIAL CONSLLTANTS TO PERFORM INDEPENDENT QUALITY VERIFICATION REVIEW OF DIABLO' CANYON 1.
Energy, Inc.
P.
O.
Box 736 N
Idaho Falls, Ida!. s 83401-9) 2.
Gilbert Associa.ms, Inc.
"# 3,!3 OJ P.
O.
Box 1498 Reading,. Pennsylvania 19603 IM OCT 301981 > 75 0'20 Cf U:s Secretary 3.
Management Analysis Company
' Mg & Smia
- gagh 11100 Roselle Street
/
San Diego, California 92121 4.
Project Assistance Corp.
1 Whale Row New London, Connecticut 06320 5.
Qucdrex Corporation
~
1700 Dell Avenue Campbell,-California 95008 6.
Technodyne Engineering Co.
333 Market Street Suite 2735 San Francisco, California 94105 7.
Tejedine Eaginee ing Corp.
303 Bear Hill Rc_4 Watham, Massachusetts 02154 8.
Torrcf Pines (A Division of General Atomic Co.)
P.
O. Box 81608 San Diego, California 92138 9.
Universal Testing Laboratories, Inc.
579 Pompton Avenue Cedar Grove, New Jersey 07009 These are intended as suggestions only, not endorsements.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0,L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power Plant,
)
Units 1 and 2)
)
_)
CERTIFICATE OF SERVICE 1 hereby certify that a copy of the letter of Governor Brown 4
t
~
to Chairman Palladino, dated October 30, 1981, including the enclosure thereto, was served on uhe following by U.S. mail, first class, this 30th day of October, 1981, except as otherwise noted.
Nunzio J.
Palladino, Chairman
- Commissioner Victor Gilinsky
- e'<?m...
W (Q3 Commissioner Peter A.
Bradford fp j
Commissioner John F. Ahearne
- occg U
Commissioner Thomas Roberts
- e I.
007 O
U.
S. Nuclear Regulatory Con- 'esion 3
Washington, D.C.
20555 7;.
0lggy Mr. Thomas Moore, Chairman
\\)
.$hef Atomic Safety and Licensing Appeal Board MT4ur IG N
g U.S.
Nuclear Regulatory Ccmmission Washington, D.
C.
20555 mj 4 Dr. W.
Reed Johnson Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D.
C.
20555 Dr. John H.
Buck Atomic Safety and Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Chairman Atomic Safety and Licensing Appeal Panel
- 0. S.
Nuclear Regulatory Commission Washington, D.
C.
20555
T Looncrd Bickwit, E;q., Gentrcl Counsel o Office of General Counsel U.
S.
Nuclear Regulatory Commission Washir.gton, D.C.
20555 John F. Wolf, Esq., Chairman Atomic Safety and Licensing 30ard U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Mr. Glenn O.
Brigh t Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Dr. Jerry R.
Kline Atomic Safety and Licensing Board Panel U. S.
Nuclear Regulatory Commission Washington, D.
C.
20555 William J. Olmstead, Esq.
Edward G.
Ketchen, Esq.
Lucinda Low Swartz, Esq.
Office of Executive Legal Director BETH 042 U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Secre ta ry U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 ATTENTION:
Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E.
Kerr, Esq.
Public Utilities Commission 5246 State Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Beach, CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 J
l Mr. Gordon Silvar i
Mrs. Sandra A.
Silver 1760 Alisal Street San Luis Obispo, CA 93401 Joel R.
Reynolds, Esq.
i John Phillips, Esq..
Center for Law in the Public Interest 10951 West Pico Boulevard Third Floor Los Angeles, CA 90064 3
Bruce Norton, Esq.
Norton, Burke, Berry & Junck 4
3216 North Third Street - Suite 300 Phoenix, Arizona 85012 l
3 Philip A.
Crane, Jr.,
Esq.
Richard F.
Locke, Esq.
F.
Ronald Laupheimer, Esq.-
i Pacific Gas and Electric Company 1050 17th Street, N.W.
duite 1180 Washington, D.
C.
20036 David S.
Fleischaker, Esq.
P.O. Box 1178 i
Oklahoma City, Oklahoma 73101 Arthur C.
Gehr, Esq.
Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 1
Mr. Richard B.
Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K t
4 San Jose, CA 95125 i
l Mr. Carl Neiberger Telegram Tribune P. O.
Box 112 San Luis Obispo, CA 93402 Byron S.
Georgiou, Esq.
I Legal Af fairs Secretary Governor's Office State Capitol Sacramento, CA 95814 J
- Hand delivered.
/,
' Herbert H. Brown HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.
C.
20036 October 30, 1981 -.._-,...--.-. -. -.. -. -_-
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