ML20079R142

Affidavit of R Hubbard Re Breakdowns in Design & Const Qa/ QC Program & Implementation.Util & NRC Did Not Include Significant Items in Const QA Review.Implementation of Qa/Qc Measures Unacceptable.Certificate of Svc Encl

ML20079R142
Person / Time
Site:	Diablo Canyon
Issue date:	06/15/1983
From:	Hubbard R CALIFORNIA, STATE OF
To:
Shared Package
ML20079R137	List: ML20079R134 ML20079R142
References
ISSUANCES-OL, NUDOCS 8306220052
Download: ML20079R142 (14)

Text

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

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) )

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)

AFFIDAVIT OF RICHARD B. HUBBARD STATE OF CALIFORNIA )

) ss.

CITY AND COUNTY OF LOS ANGELES )

The above being duly sworn, deposes and says:

I. INTRODUCTION

1. My name is Richard B. Hubbard. My professional cualifications and experience have been previous 1v submitted to this Board as part of my May 24, 1982 affidavit regarding breakdowns in the Diablo Canyon design and construction OA/OC program and its implementation. ,

2. In preparing this affidavit I have reviewed the document entitled " Response of Pacific Gas and Electric Company to Motions to Reopen the Record on Construction Ouality Assurance Filed by Joint Intervenors and Governor Deukmejian" dated May 31, 1983 and a similar document prepared by the NRC Staff dated June 6, 1983, entitled "NRC Staff's Response To Joint Intervenors' and Governor Deukmejian's Motions to Reopen the Record on Construction Quality Assurance."

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3. The purpose of this brief affidavit is twofold.

First, it is to set forth my evaluation of some of the events which have occurred since my May 6 declaration which I believe further substantiate the OA/OC deficiencies set forth in the Statements of Tennyson and Roam regarding H. P. Folev Company's l

welder qualifications, inspector cualifications, inspection

• adequacies, and independence of OA/OC personnel from j

l production as contrasted to quality pressures. Further, it is l

l to describe how the PG&E proposed corrective action measures ,

initiated in response to the identified Foley OA/OC breakdowns are in ny opinion inappropriatelv limited. Second, it is to describe my assessment of the results of the-Independent Design Verification Program's (IDVP's) limited Construction Quality Assurance (COA) review which indicate to me widespread l

failures in the Wismer and Becker OA/OC programs and its implementation which in my opin. ion raise substantial safety I

ouestions regarding the construction OA/OC process and the product of that process.

1 4 I believe that the new evidence provided by PG&E and the NRC further confirms my previous conclusions that PG&E and l

l its major subcontractors for Diablo Canyon failed to develop and implement a OA/OC program for construction activiti,es in l

l compliance with either the OA/nc regulatory recuirements or with l

l PG&E's own quality assurance policies.

2.

II. BREAKDOWNS IN FOLEY OA/OC PROCESS AND LIMITATIONS IN.P3&E'S PROPOSED CORRECTIVE ACTION MEASURES

5. PG&E's May 19, 1983 supplemental' response to the OA/OC violations identified by the NRC regarding construction work performed by H.P. Folev Company (Foley) substantiates a.

number of the OA/OC deficiencies set forth in the statements of

, Tennyson and Roam (see Attachment 2 of Exhibit 1,to PG&E's May 31, 1983 Response). PG&E now acknowledges that during the

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" big push" between January and March 1983 Foley, failed to properly train welders performing special procesdes which is

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contrary to the requirements of Criterion 4 of\ Appendix B, failed to train and qualifj an adequate number of OA/OC inspectors which is contrary to the requirements 6f Criterion 2 of Appendix B, t

failed to perform welding inspections in strict accordance with '

requirements which is contrary to Criterion 10 of Appendix B, and failed to assure that quality as independent from cost and schedule measures were properly established and implemented durino the bui.ldup in the workforce which is contrary to the requirements of Criterion 1 of Appendix B.

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6 As one result,of'the preceding breakdowns in OA/OC

' program development and implementation, Foley, at PG&E's reauest,

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conducted a complete reinsoection of structural steel fillet welds 3n,d determined that approximately 14% of the welds in the Nnit'l Fuel Handlino Building would have to be reworked in T, I

order to meet apolicable criteria. In addition, PG&E also identified as a result of Foley's initial 10% reinspection i audit of the Fuel Handling Building welds that over 8% of the

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welds, while not requiring rework, failed to fully satisfy the acceptance criteria. Thus, contrary..to Criterion 15 of Appendix B, it appears that the Foley QA/QC program failed to properly identify and disposition the nearly 22% of nonconforming welds.

7. For corrective action, PG&E now proposes that Foley

,. perform a 100% fillet weld reinspection in the hot shop and Unit 2, portion of the Fuel Handling Building, a 10% fillet weld reinspection in the Unit 1 Containment Annulus Structure for work performed from January 1983 to mid-March 1983 and a sampling of weld work including ventilation duct support modifications and electrical raceway support modifications accepted by three Foley inspectors who were found to be not suitably qualified. The

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preceding corrective action measures in my opinion do not provide y the necessary level of safety assurance as required by Criterion

'l 16 of Appendix B. In my opinion, sampling is no longer appropriate. Thus, all welding performed and inspected by Foley personnel during the 1983 big push should be 100% reinspected.

In addition, weld,ing work performed in.1982 should be included in N ( thereinspectionkprogramonasamplingbasistoconfirmthatthe i time period-when inadequate welding and weld inspection occurred was restricted to-Foley's 1983 activities. The preceding

. complete ' review is required since PG&E and Foley have failed to demonstrate /that the widespread welding deficiencies could be t

4 isolated to parti:ular types of welds, individual welders or

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P ,$nspe\ctors, or particular locations in the plant.1_/Further, a tabulation summarizing cll inspection and test activities ,'

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conducted by Fole0 OA/OC personnel during 1983 should be orepared, andia suitable sample of these> activities should be

/ \ lc reverified to. deterriine the extent to which the inadeduate '

inspection activit'les can be isolated to weld insee.ctions, t

g /, III. IDVP COA AUDIT FINDINGS IDENTIF$S!bNIFICANT

!t p' CUMULATIVE FAILURES TO COMPLY WITH SAFETY

. REOUIRUMENTS ,

/, 8. Both the NRC and PG&E appear to conclude that the 7 'T Ibsultelof the IDVP COA review indicate no findings of safety

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significance. I disaaree. First, in my opinion the COA findings indicate a widespread failure of the Wismer and Becker OA/OC program and its implementation. For example, thee checklists provided in Appendicies G1 and G2 of ITR-38 regarding Wismer and Becker provide clear evidence that a" substantial porti n of the

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OAprogramareasanditemsreviewe3{demonstratedsomede,qreeof nonicompliance as,shown by the following:

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1. Also see pages 43 to 45 of mv May 6 declaration l concerning PG&E's lack of aggressive corrective and preventative actions includina the failure to identify and correct the root causes within-the OA/OC process, which allowed the recently discovered discrecancies to occur and to remain undetected. 5 5.

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4 Observations Number Number Percent Unsatis- Observed Unsatis-a) OA Procram Assessment factory factory (i) Attributes Evaluated 18 80 22.5 (ii) Items Observed 573 2841 20.2 b) Verification of Physical Installation (i) Attributes Evaluated 21 45 46.7 (ii) Items Observed 1101 3176 34.7

9. Thus, rather than representing a low number of isolated discrepancies, the COA audit results indicate that for Wismer and Becker from 20 to over 45 percent of the areas evaluated and items observed failed to comply fully with requirements. Such a widespread failure to adequately control activities of a construction contractor clearly demonstrate both

,l a lack of comoliance with regulatorv measures and a potential for a significant safety hazard.2/

10. Second, the COA audits emphasis on reviewing OA/0C records and conducting visual examinations as contrasted to conducting tests or physical inspections almost assured the eventual finding that no single IDVP observation in and of itself would constitute a significant safety matter. This is l* true since in general the IDVP COA review fails to address

.- important attributes significant to safety. For example, the l IDVP COA review did not address such significant safety indications as might have been revealed by a Reynolds l 2. Also, see pages 40 to 43 of mv May 6 declaration

! regarding the need for discipline and detail which constitute a basic ingredient of a successful construction OA/DC program.

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probe nondestructive examination of concrete strength, by a repeat of radiographs of safety related welds or at least an l

independent review of previous radiographic film results, by an independent test of material composition to verify the accuracy '

of the original materiel certifications, and by an independent review of pre-ooerational test results and a repeat of selected

, portions of such tests. Such omissions of sionificant areas of product compliance are each serious weaknesses in the IDVP COA review. Thus, while Morrill of the NRC relies on the results of the various construction and pre-operational tests (Morrill Affidavit at p. 5), it is important to observe that neither the discrepancy inadvertently discovered by PG&E in the Pullman Company shop weld nor the degradation of piping systems previously pre-operationallv tested which might occur as a result of the ongoing plant modifications would have been detected by the IDVP COA review (see NRC, Attachment 1, PNO-V-83-21). Further, the IDVP COA in its examination of the reactor coolant system piping did not measure, and thus would not have detected, the less than minimum wall thickness of the piping (see NRC, Attachment 2, PNO-V-83-22) .

11. In summary, I conclude after reviewing the checklists provided in ITR's 36 and 38 that almost no single

= attribute (such as I mentioned in the preceding paragraph) which the NRC or PG&E would acknowledge as "significant" if not properly implemented was included in the COA reviews.

Further, the cumulative observations resultino from the COA review of Wismer and Becker indicate in my opinion a 7.

significant failure to develop and implement the reauired construction OA/OC measures.M

12. I declare under penalty of perjury that the foregoing is true and correct in all resoects and that if called as witness I coulo and would competentiv testify thereto.

_ _._ ~

, RICHARD B. HUBBARD Subscribed and sworn to before me this k day of d A/ , 1983.

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l i 3. The limited IDVP review of GF Atkinson identified in

( ITR-36 the following level of compliance with OA/OC program and l

physical installation requirements:

Observations Number Number Percent Unsatis- Observed Unsatis-

, a) OA Program Assessment factory factory l

l (i) Attributes Evaluated 3 90 3.3 1r (ii) Items Observed 8 1814 0.4 b) Verification of Physical Estallation (i) Attributes Evaluated 3 17 17.6 (ii) Items Observed 5 409 1.2 8.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

4 ,

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.

) 50-323 0.L.

. (Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing " Reply of Governor George Deukmejian to the Responses of the NRC Staff and PG&E Company to the Governor's Motion to Reopen the Record on Construction Quality Assurance" served on the following by U.S. Mail, first class, postage prepaid.

Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washing ton, D.C. 20555

. Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission

1717 H Strcet, N.W.

e Washing ton, D.C. 20555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washing ton, D.C. 20555 l

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i Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washing ton, D.C. 20555 Hon. John Ahearne, Commissioner ,

U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washing ton, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Hon. Thomas S. Moore, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. W. Reed Johnson Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Hon. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Judge John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 2.

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Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Leonard Bickwit, Esq.

Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence Chandler, Esq.

, Jack R. Goldberg, Esq.

Office of Executive Legal Director BETH 042

. U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washing ton, 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 3.

Gordon Silver Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401

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Joel R. Reynolds, Esq.

John Phillips, Esq.

Center for Law in the Public Interest 10951 West Pico Boulevard, Third Floor

Los Angeles, CA 90064 Bruce Norton, Esq.  !

r Norton, Burke, Berry & Junck l 2002 East Osborn P.O. Box 10569 Phoenix, AZ 85064 Philip A. Crane, Jr. , Esq.

Richard F. Locke, Esq.

Pacif.ic Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120 David S. Fleischaker, Esq.

P. O. Box 1178 Oklahoma City, OK 73101 Arthur C. Gehr, Esq.

Snell & Wilmer 3100 Valley Bank Center Phoenix, AZ 85073 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95125 Mr. Carl Neiberger Telegram Tribune P. O. Box 112

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• San Luis Obispo, CA 93402 e

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l Virginia and Gordon Bruno Pecho Ranch P.O. Box 6289 Los Osos, CA 93402 Nancy Culver 192 Luneta San Luis Obispo, CA 93401 DATED: June 17, 1983 '

c By _

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CHRISTINA L. NEAL 3580 Wilshire Boulevard 1 Suite 800 Los Angeles, California 90010 (213) 736-2102 h

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