ML20054E671
| ML20054E671 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/07/1982 |
| From: | Fleischaker D, Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, FLEISCHAKER, D.S., JOINT INTERVENORS - DIABLO CANYON |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20054E672 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8206140054 | |
| Download: ML20054E671 (19) | |
Text
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UNITED STATES OF AMERICA 0?$" '30 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APDEAL' BOARD y,,o:13
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY )
Docket Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclect Power
)
Plant, Units 1 and 2)
)
)
)
JOINT INTERVENORS' MOTION TO REOPEN THE RECORD Pursuant to 10 C.F.R. S 2.718 (j ), the SAN LUIS OBISPO MOTHERS FOR PEACE, SCENIC SHORELINE PRESERVATION CONFERENCE, INC., ECOLOGY ACTION CLUB, SANDRA SILVER, GORDON SILVER, ELIZABETH APPELBERG, and JOHN J. FORSTER (" Joint Intervenors")
hereby request the Atomic Safety and Licensing Appeal Board
(" Appeal Board") to reopen the record in the Diablo Canyon Nuclear Power Plant ("Diablo Canyon") licensing proceeding for the purpose of receiving significant new evidence of the recently established breakdowns in the Diablo Canyon Quality Assurance and Quality Control ("QA/QC") program.1/
For the reasons set forth herein and discussed in detail in the extensive accompanying 1/
" Quality Assurance" comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.
Quality assurance includes " Quality Control," which comprises those quality assurance actions related to the physical characteristics of a material, atructure, component, or system which provide a means to control the quality of the material, structure, component, or system to predetermined requirements.
8206140054 820607 PDR ADOCK 05000275 0
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affidavit of Richard B. Hubbard,2/ Joint Intervenors submit that these breakdowns constitute undeniable violations of the applicable Commission regulations and mandate an ordct by this Board (1) vacating the Atomic Safety and Licensing Board's
(" licensing board") July 17, 1981 findings approving the Diablo Canyon quality assurance program; (2) revoking the low power testing license approved by the licensing board in its July 17, 1981 decision; and (3) reopening the record for hearing and the submission of relevant evidence by all parties.
The standards applicable to a motion to reopen the record are well established.
Such a motion should be granted if (1) it concerns significant new information relevant to safety; (2) the new information, if considered originally, would have changed the result; and (3) the motion is timely.
In the Matter of Kansas Gas and Electric Co. et al. (Wolf Creek Generating Station, Unit 1), ALAB-462, 7 NRC 320, 328 (1978); In the Matter of Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAB-138, 6 AEC 520, 523 (1973);
id., ALAB-167, 6 AEC 1151-52 (1973).
Each of these criteria is satisfied in this case, and, accordingly, Joint Intervenors' motion to reopen the record should be granted.
2/
Mr. Hubbard is a Professional Quality Engineer with seventeen years' experience in the design, manufacture, construc-tion, and operation of nuclear power generation facilities, in-cluding eleven years' experience in responsible managerial posi-tions in the Nuclear Instrumentation Department, Atomic Power Equipment Department, and Nuclear Energy Control and Instrumenta-tion Department of the General Electric Company.
Since 1976, he has had substantial involvement in both the Diablo Canyon pro-ceeding, as a consultant to the Joint Intervenors and to the Gove. or of California. --..
s I
THE RECENTLY DISCLOSED EVIDENCE OF QA/QC BREAKDOWNS AT DIABLO CANYON CONSTITUTES SIGNIFICANT NEW INFORMATION RELEVANT TO SAFETY The new information upon which this motion is based is both significant and critical to safe operation of the Diablo Canyon facility.
In its July 17, 1981 Partial Initial Decision ("PID")
in this proceeding, the licensing board relied upon the mistaken assurancer of PGandE and NRC Staff witnesses in finding that:
The Diablo Canyon quality assurance programs for both the Design and Construction Phase and the Operations Phase have been and are in compliance with the requirements of 10 C.F.R. 50, Appendix B, and that the acceptable to the Board.3/ grams is implementation of both pro Based in part on that essential finding, the Board approved PGandE's low power testing license application for Unit 1, 1
and on September 22, 1981, after brief Commission review, the license was issued.
Within less than a week thereafter, however, and l
virtually on the eve of fuel loading, the first of what has l
now expanded to some 200 serious design errors at Diablo Canyon was revealed.
These errors, which are described and documented in detail by Richard Hubbard in the attached affidavit and exhibits, involve a broad range of systems, S!
PID, at 11. Although the Joint Intervenors submitted a detailed QA/QC contention in 1977 and sought discovery on the issue, the licensing board rejected the contention and denied any right to discovery.
Instead, it relied solely on brief PGandE and NRC Staff testimony during hearings on October 19, 1977..
s components, and equipment important to the safe operation of Diablo Canyon.
Moreover, they establish indisputably
-that there have been serious and widespread breakdowns in the Diablo Canyon Quality Assurance and Quality Control programs, breakdowns undetected by PGandE and NRC Staff inspectors for years and unknown to the licensing board at the time it explicitly found such programs acceptable.
Had Appendix B quality assurance criteria been properly implemented by PGandE at Diablo Canyon, serious errors of the type discovered on the eve of fuel loading and still-being identified today should have been detected and corrected.
According to Mr. Hubbard, given the succession of errors already disclosed, "further investigations will almost certainly reveal more errors."$/
In recognition of t
the serious implications of these design errors, the Commission, on November 19, 1981, suspended PGandE's low power test license for Diablo Canyon after only the initial fourteen errors had been revealed and ordered that an independent design verification program be instituted.E/
Since suspension of the license, 185 additional design and construction errors have been disclosed in biweekly status reports submitted by PGandE in response to the S/
Hubbard Affidavit, at 37.
E/
Order Suspending License, CLI-81-30 (November 19, 1981). i
r.
t f
Commission's Order.5/ Most recently, the quality assurance consultant hired by PGandE as part of the reverification 5/
As appears in the attached affidavit, at 33-34, the errors identified to date at Diablo Canyon fall into.
the following general groupings of QA/QC breakdowns and
' associated regulatory violations in design and construction:
a)
Hosgri report in the FSAR does not include most current Blume spectra; b)
Seismic spectra were not controlled by PG&E or Blume; c)
Preliminary and/or incorrect spectra have been used in qualification analyses for piping and equipment; I
d)
Electrical conduit supports installation not in compliance with the design criteria, and the design criteria may not.have been properly applied; e)
Shake-tested equipment may have lacked proper 3
specification concerning spectra, field location, i
and mounting; f)
Frequency calculations for electrical panels not correct; g)
Tank seismic evaluations incomplete; h)
Critical aspects of pump seismic evaluations not documented; i)
Discrepancies in HVAC calculations; j)
Lug stress for small bore piping did not address valve bypass stations, heavy valves, and equipment nozzle loads; j
k)
Spacing criteria for small bore piping did not address valve bypass stations, heavy valves, and equipment nozzle loads; l)
Piping analysis may result in overstress conditions because of layout, weights, and analytical models; m)
Design control of changes to building models without adequate explanation; and i
n)
Construction "as-built" not implemented in accordance with design documents.
-5_
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1 program -- R.F. Reedy, Inc. -- conducted a quality assurance program review and audit of PGandE and its principal seismic safety-related design service subcontractors who performed work prior to June 1, 1978.
The resulting conclusions by Reedy have established a shocking failure by PGandE to institute the QA/QC program control measures to which it committed in its license applicationa and which are required by Appendix B to 10 C.F.R. Part 50.
In his initial report issued in March 1982, Reedy stated his three principal conclusions as follows:
a)
The PG&E Quality Assurance program for design work was not adequate in areas of policy, procedures and implementation.
The Quality Assurance organization had insufficient program responsibility.
b)
A general weakness existed in internal and external interface and document
~
controls.
This cuestions whether appropriate desijn information was being exchanged and utilized by design groups and consultants.
One concern is if the latest Hosgri seismic data was inputted for design analysis.
l c)
The design verification program was not formalized and was inconsistently implemented and documented.
This included major gaps in design overviews of the design approach for mechanical and other equipment.1/
PGandE's failure to establish and^ implement an adequate QA/QC program is unquestionably a significant 2!
Quality Assurance Review and Audit Report, Phase I (March 8,1982) (emphasis added). +
i safety issue, particularly in this proceeding where the discovery of the Hosgri Fault after substantial construction of the facility had been completed necessitated a seismic reanalysis based on assumptions admittedly less conservative than would be utilized on other plants. This special safety significance is explained by Mr. Hubbard in the attached affidavit as follows:
First, PG&E, the Staff and the ACRS have relied upon allegedly superior QA/QC at Diablo Canyon to compensate for reduced convervatism -- reduced margins of safety --
in Diablo Canyon design and construction.
Such reliance is misplaced since massive breakdowns in QA/QC have been disclosed.
Second, the QA/QC breakdown at Diablo Canyon means that there is no basis for confidence that safety-related structures, systems, and components have been designed and constructed in accordance with regulatory requirements and PG&E's commitments in its CP and OL applications. Accordingly, not only is there no basis for using QA/QC to compensate for less conservative licensing assumptions, the widespread breakdowns in QA/QC preclude any finding that the plant, in fact, complies with regulatory requirements.
.1/
All of the foregoing new infor,mation -- the numerous design errors, the significance of those errors to safety at Piablo Canyon, and the findings, conclusions and implications of the Reedy Report -- is discussed in detail in the attached affidavit.
In addition. Mr. Hubbard explains the critical importance of quality assurance to nuclear safety generally, the evolution of the NRC quality i
assurance requirements and nuclear industry practices, the 1
E!
Hubbard Affidavit, at 12 (footnote omitted).
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specific deficiencies in the Diablo Canyon quality i
assurance program implementation, and the failures of PGandE and its seismic-safety-related design service subcontractors to establish required QA/QC programs for work performed prior to June 1, 1978.
Based on that i
- discussicn, Mr. Hubbard concludes that the QA/QC breakdowns at Diablo Canyon have resulted in violations of at least i
thirteen of the eighteen Appendix B QA/QC criteria and, j
more generally, that t
the significant new information set forth l
herein which has recently become available clearly demonstrates that PG&E and its maior subcontractors failed to develop and implement a QA/QC program during the design and construction of Diablo Canyon which complied with the NRC's regulatory requirements.
Indeed, nearly 200 examples j
i document PG&E's f ailure to provide a QA/QC program for. design and site activities in a timely fashion in compliance with the license application and the regulations for activities conducted prior and subsequent to the 1977 Board hearings. -Further, the result-of the mistaken assurances concerning the comprehensiveness of the Diablo Canyon QA program from PG&E and the NRC Staff is i
that the Board issued a seriously flawed i
decision.
The magnitude of significant design and construction discrepancies l
disclosed to date, and the widespread serious breakdown in management of the QA/QC t
program by PG&E and its major subcontractors vividly illustrate the substantial uncertainty in the actual quality level achieved in design, construction, and installation of all safety-related i
structures, systems, and components at Diablo Canyon.
A complete design verification and physical inspection of all t
l Diablo Canyon safety-related structures, systems, components, and other important safety features is now both necessary and prudent.
The results of such a design L f l
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review and site inspection-should be subject to the scrutiny of the Board and all parties proceeding.1/g Diablo Canyon licensing in the ongoin The NRC has long recognized that the " application of di,,sciplined engineering practices and thorough management and programmatic controls to the design, fabrication, construction, and operation of nuclear power plants is essential to the protection of public health and safety and of the environment."1E/
In light of the uncontrovertible evidence set forth in the Hubbard affidavit that such practices and controls have not been applied at Diablo Canyon, the licensing board's approval of QA/QC at the facility and of PGandE's low power testing license, application cannot stand, and the record in this proceeding must be reopened.
O' II THE RECENTLY DISCLOSED EVIDENCE OF QA/QC BREAKDOWNS AT DIABLO CANYON COMPEL DENIAL OF ANY LICENSE TO OPERATE THE FACILITY Pursuant to 10 C.F.R. 3 50.57 (a), the issuance of a low power test license for Diablo Canyon could not have been authorized by the licensing board in the absence of a finding that the QA/QC programs for the facility complied E!
Id. at 99-100 (emphasis added).
AE!
NUREG-0774, NRC 1980 Annual Report, at 69-70 (1980). -
with the eighteen criteria set forth in Appendix B to 10 C.F.R. Part 50.
The recent disclosure of widespread noncompliance with those :riteria as evidenced by numerous serious deficiencies in the Diablo Canyon QA/QC programs undeniably establishes that the majority of those criteria have not been complied with, and, thus, it underiaines an essential element of the legal and factual basis for the licensing board's authorization of low power licensing.
Therefore, such new information, had it been available to the licensing board originally, would necessarily have changed the result, and PGandE's application for a license would have been denied.
Indeed, as is discussed in the Hubbard affidavit, Harold Denton, Director of the Nuclear Reactor Regulation, openly acknowledged in an October 9, 1981 meeting with PGandE that the low power license would not have been issued had the design errors discovered at that time been known to the Staff prior to issuance of the license.11/ One month later, the Commission itself ruled in suspending the low power license that "had this information (regarding QA/QC design errors) been known to the Commission on or prior to September 22, 1981, Facility License No. DPR-76 would not have been issued."12/
11/ Meeting Transcript, at 117 (October 9,1981).
1/
CLI-81-30, at 3.,
The attached affi3avit demonstrates conclusively that a changed result is no mere matter of discretion but, rather, is compelled by the quality assurance breakdowns revealed.since last September.
As Mr. Hubbard explains:
The evidence documents that PG&E and its major subcontractors did not develop and implement by 1972 a l
QA/QC program in compliance with Part 50, Appendix B.
Rather, the evidence is clear that there were major QA/QC breakdowns in 1977-78, and that QA/QC breakdowns continued into 1979.
These breakdowns are not isolated or minor but include violations of at least thirteen of the eighteen Appendix B criteria including:
i)
Criterion 1, concerning the responsibility for the establishment and execution of the QA program.
ii)
Criterion 2, concerning establishing a QA program at the earliest practicable time.
i t
iii) Criterion 3, concerning design control measures.
iv)
Criterion 4, concerning procurement document control.
v)
Criterion 5, concerning documented instructions, procedures, and drawings.
vi)
Criterion 6, concerning control of documents.
vii) Criterion 7, concerning conformance of 1
purchased material, equipment, and services to procurement documents.
viii) Criterion 10, concerning control of inspection activities.
ix)
Criterion 11, concerning control of testing activities.
x)
Criterion 15, concerning control of nonconformances to prevent their inadvertent use or installation.
xi)
Criterion 16, concerning the identification and correction of conditions adverse to quality.
xii) Criterion 17, concerning maintenance of records for activities affecting quality.
xiii) Criterion 18, concerning QA program audits.13/
Moreover, because site QA/QC activities were covered by the same QA manual as the plainly deficient design quality assurance, the same or additional Appendix B criteria relevant to site QA/QC may also have been violated.
According to Hubbard:
[R]epeated QA program breakdowns have been identified in all areas subject to the NRC's narrow reinspection program, leading one to believe that site QA would also be found to be deficient if it were examined in detail.ll/
Without question, such widespread noncompliance is no mere detail which a licensing board may choose to ignore.
On the contrary, compliance with all applicable quality assurance criteria is an issue of critical importance.
As the Appeal Board noted in In the Matter of Consumers Power Company (Midland Plant, Units 1 and 2), ALAB-106, 6 AEC 182, 183 (1972), "[o]ne of the most significant elements of the Commission's ' defense-in-depth' approach to nuclear safety is its emphasis upon quality assurance And quality control in the construction of nuclear power plants."
13/ Hubbard Affidavit, at 10-11.
1$/
Id. at 11.._
Another Appeal Board in In the Matter of Duke Power Company (William B. McGuire Nuclear Stations, Units 1 and 2),
ALAB-128, 6 AEC 399, 410 (1973), observed that:
In an area as significant as quality assur'.nce, the recbrd should leave no doubt as to whether the applicant is in full compliance with applicable criteria and, if not, the basis upon which the regulatory staff authorizes any departure from such criteria.
See also In the Matter of Consumers Power Company (Midland Plant, Units 1 and 2), LBP 74-1, 8 AEC 584, 597-600 (1974);
In the Matter of Commonwealth Edison Company (Zion Nuclear Power Plant, Units 1 and 2), LBP-73-35, 6 AEC 861, 896 (1973).
Notwithstanding the obvious error of the licensing boards reliance upon mistaken assurances by PGandE and NRC Staff witnesses in 1977, its July 17, 1981 findings approving PGandE's quality assurance programs at Diablo Canyon still stand as the " law of the case," the low power test license issued based on those findings has not been i
revoked, and, because the record remains closed, the intervenors have no right to contest the validity either of l
those quality assurance findings or of the license authoriz.'d in reliance upon them.
Neither the public's interest in safety nor the legal right of intervenors to a hearing under ti:e Atomic Energy Act on all issues relevant to safety is served by allowing the~ licensing board's decision to stand in the face of overwhelming evidence, t
e summarized in the Hubbard affidavit, that the basis for such decision was clearly erroneous.
Accordingly, Joint Intervenors' motion to reopen the record must be granted.
III.
THIS MOTION TO RPOPEN THE RECORD IS TIMELY Without question, this motion to reopen has been timely filed.
Virtually all of the information relied upon has been disclosed only within the past eight months and subsequent to the licensing board's July 17, 1981 decision.
Indeed, much of the information discussed in the Hubbard affidavit has become available only within the past two to three months, including the compelling and highly critical findings and conclusions of R.F. Reedy after his review of the pre-1978 quality assurance programs of PGandE and its seismic-safety-related design service subcontractors.
Any claim, therefore, that this motion is urtimely should be rejected as frivolous.
CONCLUSION If ever a case warranted reopening of the record, it is this one.
The discovery during the eight months since the low power license was issued of some 200 serious flaws in the design of a facility for which near perfect design
/
I is essential. constitutes significant neu evidence which i
demands denial of an operating license.
If the legal i
standards for reopening are'to have practical meaning in any proceeding, this Board must conclude that they have j
been properly met in this case.
For the reasons stated above and in the accompanying Hubbard affidavit and attached exhibits, Joint Intervenors respectfully urge that this motion be granted and an order f
issued (1) vacating the licensing board's July 17, 1981 findings approving the Diablo Canyon quality assurance programs; (2) revoking the low power test license authorized by the licensing board in its July 17, 1981
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decision; and (3) reopening the record for hearing and the submission of relevant evidence by all parties.
DATED:
June 7, 1982 Respectfully submitted, JOEL REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
l Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 i
DAVID S. FLEISCHAKER, ESQ.
P.O. Box 1178 i
Oklahoma City, Oklahoma 73101 By:
(f( k h(YL f &
JOEL R.
REYROLDS f i
e M
DAVID S.
PLEISCHAKER Attorneys for Joint i
Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER i
, _ - _= -.-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of:
)
)
PACIFIC GAS & ELECTRIC COMPANY)
DOCKET Nos. 50-275 0.L.
(Diablo Canyon Nuclear
)
50-323'O.L.
Power Plant, Units 1 & 2)
)
)
Low Power Test License
)
CERTIFICATE OF SERVICE I hereby certify that on this 8th' day of June, 1982, I have l
served copies of the foregoing Joint Intervenors' Motion to Reopen the Record, by mailing them through the U.S.
- Mails, first-class, postage prepaid, to those person listed bel'ow and courtesy copies mailed to the Commissioners:
Thomas Moore, Esq.
Dr. W. Reed Johnson Chairman Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Dr. John H. Buck Docket & Service Section Atomic Safety & Licensing Office of the Secretary Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Dr. Glenn O.
Bright John F. Wolf, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory 3409 Shepherd Street Commission Chevy Chase, Maryland 20015 Washington, D.C.
20555 l
i
. Dr. Jerry Kline Joel Reynolds, Esq.
Atomic Safety & Licensing John'Phillips, Esq.
Board Panel Center for Law in The Public U.S. Nuclear Regulatory Interest Commission 10951 West Pico Boulevard Washington, D.C.
20555 Los Angeles, California 90064 Lawrence Chandler, Esq.
Gordon Silver Donald F. Hassell, Esq.
1760.Alisal Street George E. Johnson, Esq.
San'Luis Obispo, CA 93401 Bradley Jones Director - BETH 042 Bruce Norton, Esq.
U.S. Nuclear Regulatory 3216 N. Third Street Commission Suite 202 Washington, D.C.
20555 Phoenix, Arizona 85012 Mrs. Elizabeth Apfelberg Janice E. Kerr, Esq.
c/o Nancy Culver Lawrence Q. Garcia, Esq.
192 Luneta Drive California Public Utilities San Luis Obispo, CA 93401 Commission 5346 State Building Mr. Frederick Eissler 350 McAllister Street San Francisco, CA 94102 Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Arthur C. Gehr, Esq.
Santa Barbara, CA 93105 Snell & Wilmer 3100 Valley. Center Sandra A.
Silver Phoenix, Arizona 85073 1760 Alisal Street San Luis Obispo, CA 93401 MHB Technical Associates 1723 Hamilton Avenue Malcolm H.
Furbush, Esq.
Suite K j
Vice President and San Jose, California 95125 l
General Counsel Philip A. Crane, Esq.
Carl Neiburger i
l Douglas A. Oglesby Telegram Tribune
{
Pacific Gas & Electric Co.
Post Office Box 112 Room 3135 San Luis Obispo, CA 93402 77 Beale Street, P.O.
Box 7422 San Francisco, CA 94120 Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Byron S. Georgiou Kirkpatrick, Lockhart, Hill, Legal Affairs Secretary Christopher & Phillips Governor's Office 1900 M Street, N.W.
State Capitol Washington, D.C.
20036 Sacramento, California 95814 1
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- Victor Gilinsky, Nunzio J. Palladino Commissioner Chairman U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 James K. Asseltine, Thomas Roberts, Commissioner Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 John F. Ahearne, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555
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DAVID S.
FLMISCHAKElA Attorney for Petitioners San Luis Obispo Mothers for Peace, et al.
Post Offic TBox 1178 Oklahoma City, Oklahoma 73101 (405)235-8444 e