ML20076B576

Requests Issuance of Final Statement Clearing Rl Cloud Associates from Allegations of Wrongdoing in Preparation of Preliminary Rept,Seismic Verification Program, Per NRC Investigation Results in NUREG-0862,Issue 3

ML20076B576
Person / Time
Site:	Diablo Canyon
Issue date:	08/24/1982
From:	Cloud R ROBERT L. CLOUD ASSOCIATES, INC.
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20076B440	List: ML20076B576 ML20076M077
References
FOIA-83-130 NUDOCS 8208010014
Download: ML20076B576 (3)

Text

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ac atRT -L. CLOU D ASSOCI ATts, INC. -

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113 i;'45VI 8;51TY AVENUE L E *

• Et EY. C A!.IrCR*if A 3 4 710 E 415 ) 8 419 2 9 6 August 24, 1982 Dr. Nunzio Palladino Chairman U. S. Nuclear Regulatory Commission

Dear Dr. Palladino,

In November of 1981, the U. S. Nuclear Regulatory Commission requested that an investigation be conducted into the circumstances surrounding the development of the " Preliminary Report, Seismic Clcud and Associates, Inc.

Verification Program", prepared by R. L. This investigation was for the' Pacific' Gas and Electric Company.

conducted during December of 1981 and January of 1982, and the results were reported in Nureg - 0862, Icsue 3, February 1982

" Inspection Report of ' Preliminary Report, Seismic Reverification Program' at Diablo Canyon Nuclear Power Plant, Units 1 and 2" This investigation was requested as a result of allegations that PGandE edited reports prepared by our company in a manncr favorable to PGandE. The NRC investigation determined clearly and that all that there was no creiudicial editing of our report,

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2 changes to the rTort were mace of engineers in our company on clie basis of documented engineering work which had been compiled in a Log Book at the time the report in question was written and edited.

The purpose of my letter today is to request that a statement be issued from the U.S. N.R.C. Commissione'r's office declaring that

.this matter has been investigated in depth, and that no imoroorie-ties were Iound, and that the work in question was performed in a prordssional manner.

The investigation was the most rigorous review of an engineering report I have ever witnessed or have been involved in during my 25 years of engineering experience including 12 years in commercial

- nuclear work and 7 years in Naval Reactor activities. The disposi-

- tion of 345- comments on the report in question wasThose crosscomments correlated from different sources and studies individually.

that had the potential for resulting in a change in meaning or a Specific favorable change in presentation were studied in depth. This docu-documentation was requested for each substantial change. .

mentation had been organized into a Log Book. It was readily available and was the basic reason the investigators were able to come to a positive conclusion. There were 2 exceptions out of the ge wp,s s

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d 345 comment resolutions, however a study of these exceptions shows them to be differences in interpretation between the investigators and our engineers. There was a documented. basis for all changes.

It'is also noted that intervenor engineers and attorneys were present during these reviews. They took so no exception to the find-far as I know.

,ings at the time, nor have they since, The investigation was called for, in part, as a result of a misunderstanding regarding the existence of a draft report that developed at a meeting with the NRC staff on November 3, 1981.

The cccurrence of this misunderstanding and the fact that it was not corrected was clearly an unfortunate event. But on a factual basis it was not important. The reason it was factually unitportant can be seen from my own presentation at that meeting. In my presen-tation which was given just previous to the misunderstanding, I prese,ted first the results of our preliminary work. Second, I stated that in order for our company to properly verify the seismic work a new approach was necessary. Then, I presented calculationsa new verifi- -

cation program based upon performance of independent for a sample of all seismic work. In effect, the preliminary report was rendered moot relative to the verification ~ program and has .

remained so. The new program has and is being carried out essen-tially unchanged, notwithstanding all the events that have occurred since. I believe the record shows it is much more thorough than verification programs conducted in other plants.

The fact that an investigation was felt necessary, and that it was conducted at all, casts a serious shadow on the professional reputation of both myself and our company. The fact _ thai _our connany ~

sustained such a rigorous investigation with no aaverse findings is ~

important. In addition to infEring o.ur reputation, these events

-MTliad and' no doubt will cont'inue to have an adverse effect on our business.

It will be in the best interest of all concerned for the Commission to provide a final statement on the conclusions of the investigation. I hope y N e able to respond in a positive' manner to thi~s request.

- V urs truly, Robert L. Cloud cc: See Attachment ,

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cc: Cocmissioner Gilinsky Conaissioner Ahearne Cocaissioner Roberts Cor.missioner Asselstine

fr. George Maneatis F.r. Earold Denton

r . Robert Engelken Dr. William Cooper Mr. David Fleischaker, Esq.

Mr. Joel Reynolds, Esq.

Mr. Herberr Brown, Esq.

Mr.' Bruce Norton, Esq. -

Mr. Arthur Gehr, Esq.

Mr. Roy Fray o.-M S

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