ML20081C770
| ML20081C770 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/13/1984 |
| From: | Clewett J, Devine T GOVERNMENT ACCOUNTABILITY PROJECT, SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| OL, NUDOCS 8403150010 | |
| Download: ML20081C770 (1) | |
Text
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GOVERNMENT ACCOUNTABlUTY PROJECT g.
Institute for Pokey Studies L' W 1901 Que Street N w. Washington D.C. 20009 (202)234 9382
'84 mR 14 P3:41 March 13, 1984 Y,,..0 Y-
. q'C', EIT)G [,1.y Munzio J.
Palladino, Chairman td A -
Victor Gilinsky, Commiscioner Thomas Roberts, Commissioner
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James Asselstine, Commissioner 1.t Frederick Bernthal, Commissioner
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United States Nuclear Regulatory Commission 1717 H. Street, N.W.
Washington, D.C.
20055 Re:
In the Matter of Pacific Gas and Electric Comnany (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Nos. 50-27801 and 373OL
Dear CPairman Palladino and Members of the Commission:
The San Luis Obispo, California Mothers for Peace are deeply concerned over recent developments involving the Nuclear Regu)atory Commission (NRC) and the Diablo Canyon nuclear power plant.
The Mothers fear that the Commission will discard the terms of the 1981 order which has delayed operations for over two years, and will surrender the normal requirements of the Atomic Energy Act by permitting a facility to go critical in a quality indeterminate state.
The Mothers for Peace urge you to honor existing icgal requirements for Diablo Canyon.
The basis for their concerns are summarized below:
I.
SACRIFICING THE TERMS OF THE COMMISSION'S 1981 ORDER The Commission's 1981 Order required " satisfactory completion" of the following requirements, among others, before Diablo Canyon begins operations:
" performance of a suitable number of sample calculations related to each con-8403150010 840313 PDR ADOCK 05000275 G
Nuclear Regulatory Commission March 13, 1984 Page 2 tract to verify the adequacy of accuracy of the design process for affected safety-related structures, systems and components."
Based on staff reports from a January 31, 1984 public meeting in San Francisco, PG&E has failed to meet that test.
Management in the seismic design review replaced sophisticated calculations that rejected pipe supports, with simplified analyses that accepted the same suspect work.
Different versions existed for the same calculations log, which theoretically represented the record of work done in the seismic review.
Similarly, calculations were destroyed when they were inconsistent with predetermined results.
The situation became so bad that on January 31 the staff directed PG&E's lawyer to prepare a memorandum instructing all per-sonnel on-site not to destroy documents.
The result was (e).xtensive errors that had been identified in both preliminary and final support calcu-lations," according to the staff.
To illustrate, the staff only found three out of 12 design packages that had been successfully reviewed.
The.other nine all had some deficiency or error.
A 75% error rate is an unacceptable basis to run the: facility, consistent with public health and safety requirements.
Based on the staff's preliminary review, we may not know any more now whether Diablo Canyon can withstand an earthquake than we did in 1981.
Under the terms of the 1981 Order, that means the plant cannot operate.
In this context, the Mothers were horrified to O
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Nuclear Regulatory Commission March 13, 1984 Page 3 learn that the staff is considering recommending criticality anyway.
The staff's excuse at the February Commission briefing was to infer that despite the " errors," the pro-gram was 'Vithin the letter of the law" and that "the fundamental engineering that was applied was sound."
Finally, the staff explained that based on their limited sample it is too early to tell whether the structure of the plant is adequate.
The staff's premise is wrong:
PG&E and Bechtel trampled on fundamental engineering principles and-legal rsquirements.
Regardless of formal requirements, however, i
common sense dictates that under these circumstances the facility would not be turned on.
To test the significance l
of PG&E's " errors" in this manner would leave the citizens of California as guinea nigs to learn the effects of the utility's misconduct.
II.
FAILURE TO KEEP PACE WITH WHISTLEBLONING DISCLOSURES i
On January 31, 1984 whistleblowers from Diablo Canyon disclosed 170 allegations of quality assurance violations through the Mothers for Peace.
On March 2 the Mothers presented an additional 131 allegations through a cupplemental petition, filed by.the Mothers and seven national organisations.
To date the staff has not even completed its initial review of allegations from witnesses in the first pstition.
For the last week, counsel unsuccessfully has cought t'o schedule staff interviews.with new witnesses i
e L.
a
Nuclear Regulatory Commission March 13, 1984 Page 4 Counsel also has sought covered by subsequent allegations.
i for allegers unsuccessfully to schedule followup interv ews Unfortuately, a to review and rebut PG&E's responses.
The licensing vote is still scheduled for March 26.tion for Commission will be ignorant of relevant informa t h up with the vote, unless it waits for the staff to ca c I
these issues.
The whistleblower allegations disclosed by the 3
by sworn Mothers have been serious and documented, either They must be con-affidavits or by documentary evidence.
t b ut sidered for the staff to make accurate conclusions a o the quality assurance program at the plant.
the staff lost considerable cred-To illustrate, E Report ibility with the labor force when it published I This February 29 report found that a 1977 Nuclear 83-37.
audit condemning quality assurance Service Corporation (NSC)
- Further, violations at Diablo Canyon largely was in error.
llman the report concluded that the relevant contractor,,Pu Power Products, has corrected any violations that were yalidly reported by NSC.
Unfortunately, the staff exhibited tunnel vision While it talked extensively in preparing its findings.
with Fullm'an management representatives who rebutted the NSC findings, there is no reference to interviews with the NSC personnel who issued the findings in the first place.
4 e
Nuclear Regulatory Commission March 13, 1984 Page 5 The report accepted at face value Pullman's "reforus" of creatinq corrective procedures arid concluded that problems were
" resolved".
Unfortunately, since early January Pullman whistleblowers have been explaining to the NRC staff that the procedures were not implemented.
Pullman's former internal auditor described in detail why he resigned his position in frustration after over two years of unsuccessful efforts to transform Pullman QA paper commitments into reality.
It is inexcusable that the staff ignored this information and a barrage of similar allegations from eyewitnesses, and gave Pullraan a clean bill of health.
Employees are beginning to ask counsel "what difference it makes to t'alk with the NRC."
The Mothers hope that the staff will speak with these whistleblowers, in order to restore accuracy to the record.
Analyses currently are being prepared to demonstrate that the Pullman corrective action positions were based on falsified documents and false statements.
III.
DEFINING OUT THE MOTHERS POR PEACE PETITION PROM THE LICENSING DECISION Gn January 31, 1984 the Mothers for Peace petitioned the Conn.ission to defer any low power operating t
license decision until investigation and corrective action are completed for 170 whistleblower allegations.
On March 2 the Mothers and seven national organizations supplemented
Nuclear Regulatory Commincion March 13, 1984 Page 6 i
the petition with 131 new allegations.
To date, the Commission has ordered PG&E to respond to the first 170 allegations by March 29, three days after the Commission is scheduled to vote.
There has been no followup for the second set of allegations.
In affect,the Commission will not even require PG&E to answer the allegations before it votes on a license.
This schedule would make a mockery of the public petition process of the Atomic Energy Act.
IV*.
IGNORING THE ORGANIZATIONAL CAUSES OF THE QUALITY ASSURANCE BREAKDOWN After a.four month delay, the Office of Inves-tigations has just begun to pursue the allegations on the organizational causes for the QA breakdown -- records falsification and destruction, and retaliation against QA/QC personnel who tried to enforce legal requirements.
During this, delay the Department of Labor has nearly completed four reprisal investigations backing the employees in all findings to date.
As currently scheduled, however, the Commission will vote to let the plant go critcal without knowing whether PG&E has the organizational character and competence'to run a nuclear facility.
This also would ignore licensing requirements from the Commission's own regulations and precedents.
The Mothers for Peace urge the Commission to renew, l
l intensify and finish the dialogue ~with whistleblowers at e
.. *.s 11uclear Regulatory. Commission March 13, 1984 Page 7 Diablo Canyon.
The labor force may help to expose a decade long coverup before it is too late, if the Commission per-mits thera.
Counsel have continued to work closely with the l
labor force.
During the last week we have obtained over 100 new allegations, many of which demonstrate false i
statements in PG&E's recent denials of.any significant safety hazards.
The labor force has demonstrated that PG&E's 1983 positions and reassurances were not reliable.
There is no reason to have any more confidence in the 1984 version of the " stonewall syndrome" at Diablo Canyon.
Respectfully Submitted, b
.Jg/hn Clewe l
Yimad Thomas Devine Counsel for the Mothers for Peace
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