ML20087A488

Suppl 1 to 840214 Motion to Augment Or,In Alternative,To Reopen Record.Provides Addl Explanantion of Allegations Re Design & Design QA Deficiencies from Transcript of 840125 Meeting.Certificate of Svc Encl

ML20087A488
Person / Time
Site:	Diablo Canyon
Issue date:	03/01/1984
From:	Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
OL, NUDOCS 8403080118
Download: ML20087A488 (15)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIg I9NR -7 A10 :45 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

)

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

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

)

JOINT INTERVENORS' SUPPLEMENT TO FEBRUARY 14, 1984 MOTION TO AUGMENT-OR, IN THE ALTERNATIVE, TO REOPEN THE RECORD Pursuant to the February 23, 1984 Order of this Appeal Board, the Joint Intervenors hereby supplement their 4

February 14, 1984 Motion to Augment or, in the Alternative, to Reopen the Record. Specifically, this supplement relates to the l- recently released transcript of the January 25, 1984 meeting i

between former Diablo Canyon engineer Charles Stokes and j

representatives of the NRC Staff.

Previously incorporated by reference in the Joint Intervenors' February 14th motion, the transcript reveals a l

number of new and highly significant allegations of design and I design quality assurance deficiencies at Diablo Canyon. In l-addition, it provides further support for and explanation of some of the allegations contained in Mr. Stokes' two affidavits 8403080118 840301 $DRADOCK 05000275 PDR -

()/I) i j

- l submitted as attachments to the Joint Intervenors' motion.

Simply stated, the January 25, 1984 transcript contains 1

additional significant new information that undermines still j

!' . I further the confidence in the design of Diablo Canyon that is an j essential precondition to issuance of an operating license.1/

Given the bulk of the transcript and the extensive l I

amount of evidence contained in it, a reiteration here of_all of j

the significant information is neither possible nor necessary.  ;

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As with each of.the attachments to the motion, the transcript

- must be viewed in its entirety as documentation in support of dugmentation and reopening of the record, rather than selecting only discrete portions for consideration. However, some of the principal quality assurance-related deficiencies described by Mr. Stokes are included below to illustrate the nature and significance of the problems remaining at Diablo Canyon, both in the design process and in'the design product. Among the L deficiencies alleged by Mr. Stokes are the following:

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-- In 1983 a management representative from San

Francisco, Mr. Dan Curtis, refused to answer numerota A! The questionable practices described by Mr. Stokes in his Janua.y 25th meeting with the NRC Staff include noncompli-ance with applicable codes, deliberate destruction of documents

' in violation of normal industry practices, intentional nondis-

. closure and cover-up of design deficiencies, manipulation of calculations (i.e., elimination'of eccentricities), excessive work hours, retaliatory tranLfers of engineers, excessive-

_ production pressure, unavailability or lack of access to necessary documentation and manuals, inadequate training, improper or misleading' test procedures, disregard and exceedence of vendor load ratings for bolts, intimidation of engineers to i discourage questioning of design practices,'and misrepresenta-

j. tions!to the NRC.

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questions and challenges from site engineers who believed that Document 049243 was not a conservative basis for the seismic redesign program. Management's inability to defend its program internally suggests that the licensee may have deliberately misinformed the NRC staff on Eecember 15, 1983 that Document 049243 is conservative under professional engineering standards. (Tr. 13-14.)

-- Management did not freely distribute professional codes that supposedly paralleled computer analyses relied on by engineers in the seismic dem review. In some cases the only reference materials t 'ide the engineers were the computer analyses. That is improper, as management effectively conceded in the fall of 1983 tnrough instructions that the computer analysis was merely a guide and not meant to replace the professional codes.

Unfortunately, the program had officially been completed when management disclosed the non-binding nature of the l computer analysis. (Tr . 16-17, 120-21.)

-- The M-9 computer analysis for angles omitted the relevant provision of the American Institute of Steel Construction ("AISC") code for allowable bending stress, l contrary to licensing commitments. Management officials stopped engineers from using that section of the code, because compliance required angles to be cut out and replaced with tube steel, or at least reinforced through braces. (Tr. 15-21.)

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-- Management imposed inconsistent standards for modifications in the seismic design review: as the number of modifications approached the Ifmits beyond which PGandE had committed to expand the sample, management refused to fix deficiencies, even if obvious and more severe than those previously corrected. Instead, engineers conducting the first round of calculations were told to make assumptions contrary to fact, such as restraints that did not exist. (Tr. 23-24.)

-- Bechtel issued out-of-date computer STRUDL manuals to engineers in the seismic design review. Inexplicably, the office at Diablo Canyon was not on the route slip for updated materials on the computer, and even after that defic:lency was corrected the materials consistently were outdated. The manual provides backup information to engineers who wanted to check or go beyond the program.

(Tr. 27, 29.)

-- Engineers in the stress group relied on outdated seismic data that was necessary for their calculations. It took up to six months to receive updates, by which time the newly-arriving material was out-of-date. (Tr. 29.)

-- Bechtel's computer program did not have an adequate

" memory" for engineers to conduct full analyses of complex hangers. As a result, engineers had to ignore relevant factors as the worst case scenarios for force on the support frame. (Tr. 27, 29, 38-39.)

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-- There was no consistent procedure or criterion to guide engineers who checked calculations in the seismic design review: they could check whatever they wanted through any method. (Tr . 31-3 2. )

-- After the NRC obtained certain work packages at Mr. Stokes' suggestion on December 8, 1983, management directed a purge of relevant files to remove any evidence of previously destroyed or censored work by engineers who failed hangers but were later overruled. (Tr. 41, 81-82.)

-- When assumptions or loads were changed for preliminary calculations on pipe supports that previously had failed, typically no one redid or checked the entire calculation. This step was necessary to determine that the new combination of variables in its entirety would support a conclusion to pass the pipe support. In Mr. Stokes' judgment, this allowed hangers to pass which should have failed. '(Tr. 50-51.)

-- Mr. Leo Mangoba, the Bechtel official who supervised engineers in the pipe support group, approved the seismic review calculations en masse over several days l without studying and properly reviewing the work.

l Mr. Mangoba did not even get to the calculations until a few days before the end of the program. Supposedly Mr. Mangoba's approval was one of the checks and balances on the quality of the calculations, but it was pro forma.

(Tr. 52.)

-- Management did not have necessary documents from vendors and manufacturers to guide calculations on required supports for vendor purchases such as valves. The omission helps to explain why engineers based their analysis on "past experience" at other plants brought in from previous jobs. (Tr. 54-55.)

-- Management at Diablo Canyon did not send drawing details and support conditions to valve manufacturers and other vendors for approval. The vendor's review and approval is necessary to assure that the component is being used as intended. This omission was unique in Mr. Stokes' experience in the nuclear industry. It represents more necessary information that was missing from the seismic design review program. (Tr. 55.)

-- Management's production schedule for the seismic design review made it impossible for engineers to think clearly, let alone produce consistently high-quality calculations. For extended periods, they were instructed to complete 1.5 hangers per day on a schedule of seven days

.and 84-120 hours per week. (Tr. 62-63, 89-91.)

t

-- In some instances engineers approved hangers solely on the basis of conclusions in file 049243 for similar pipe supports, without any independent evaluation. This was known as the " cookbook" approach. (Tr. 75-76, 91.)

-- Early in the seismic design review, management instructed engineers to check a blank on the form that the calculation results would not affect the Final Safety L1

Analysis Report ("FSAR"), despite the engineers' protests that they did not know what was in the FSAR. Eventually, blank forms were just xeroxed with the "X" filled in and distributed to the engineers for their calculations. The only way the engineer could ensure accuracy was by whiting-out what was already there. (Tr. 96-97.)

-- Engineering calculations that called for field modifications were altered after cc,mplaints from construction, without the knowledge or approval of the originator. Tampering with calculations in this manner was highly improper. (Tr. 98A. ) The significance is that in an unknown number of cases, corrective action required on the basis of documented engineering analysis was informally circumvented. The basis for revising the modifications is unknown.

-- Multiple. engineers independently produced preliminary calculations on the same hangers. Besides being wasteful, this practice gave management the option to throw out the calculations that-failed hangers and keep those that passed. (Tr.99-100.)

-- Management officials overruled engineers who attempted to calculate the effects and stresses of torsional loads, created when pipe supports were twisted to tighten them during installation. This is an obsolete technique in the nuclear industry, and according to a former engineer in the seismic design review, it is hardly ever used unless totally qualified by structural

calculations. Engineers were told not to calculate for torsion and were overruled when they did. The stated reason was that "the hanger wou a fail." (Tr. 103-04, 123.)

-- Engineers on-site had to wait up to a week to obtain information on the telephone from San Francisco that normally would be on the drawings and was necessary to draw engineering conclusions. (Tr . 110-11. ) Combined with scheduling requirements, this system created pressure on engineers without the benefit of data on which they normally would rely.

-- There was no system or procedure to verify the accuracy of design information received on the telephone from the San Francisco offices. In the absence of any such procedures, the data was unverifiable despite engineers' doubts about its accuracy in some cases. (TR. 111-12.)

-- The initial records for hanger calculations later l covered by the seismic design review are totally unprofessional and unacceptable due to the~ inadequate

! underlying documentation, as well as the lack of signatures and evidence of a checker or other approval for the great majority of calculations. The records are so deficient that the seismic design review must be expanded from a sample to cover 100% of relevant hardware. Reliance on a sample assumed the existence of a comprehensive, if questionable, base of professional engineering calculations. In Mr. Stokes' professional judgment, such a t

base did.not exist. The plant cannot be licensed on the basis of a sample base of minimally-acceptable engineering calculations. Crr. 113-15.)

--- At the time of Mr. Stokes' departure, plant operators did not have access to a centralized document center with all information necessary to respond to conditions in the plant. This could compromise operators' ability to make all decisions from the control room in an emergency. CTr. 115-16.)

-- Mr. Stokes reported errors in the M-9 computer analysis, which incorrectly instructed engineers to consider small-bore baseplates and non-computer analysed piping lines.as rigid. In fact, the baseplates and lines are flexible. The assumption was inconsistent with other

' instructions to calculate displacement for the bolts on the baseplate. Crr. 138-41.)

-- Engineers in the seismic design review did not have I written procedures to guide their use of the STRUDL computer program. As Mr. Stokes explained, "All we had was the form handbook of a STRUDEL [ sic] program minus the pertinent information such as the model load points." Crr .

146-47.)

-- Similar to the experience of Mr. Stokes and others in the pipe support group, engineers in the stress trailer were transferred after challenging suspect changes -- such as eliminating eccentricities -- in the models for the seismic design review calculations. The reluctant g

engineers were replaced by personnel who cooperated with questionable manipulation of models. In fact, there were considerably more personnel shifts in the stress group than the pipe support group. (Tr . 151. )

-- Contrary to management assertions at the December 15, 1983 meeting with NRC staff, the calculations that replaced those rejecting pipe supports were not more refined and sophisticated. In fact, the opposite was true:

less sophisticated analysis was used. The models for subsequent calculations eliminated the unique eccentricities relevant for particular pipe supports.

Tr 85-86, 152-53.)

These allegations cannot be reconciled with the testimony offered to this Board in Nov' ember 1983 by PGandE, the NRC Staff, and the IDVP. Nor can they be reconciled with a finding of reasonable assurance that Diablo Canyon has been designed in compliance with the Commission's regulations. The i

design practices described by Mr. Stokes are not only unprofessional, but highly questionable in terms of reliability or acceptability under the various design codes. Moreover, they are practices apparently adopted and imposed with the knowledge and sanction of PGandE management in an effort to expedite the redesign process and minimize the disclosure of errors.

Many of Mr. Stokes' allegations of deficient design i

practices have already been verified by the NRC Staff and, in some instances, confirmed by PGandE. Further, his charge of l

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retaliation by PGandE for his attempts to document nonconfor-mances has been investigated and confirmed by the U.S.

Department of Labor. His testimony as a whole must, therefore, be given considerable weight by this Board in its review of Joint Intervenors' motion and the extensive documentation upon which it is based. Because of the implications of his charges for the entire design process and for the completely unacceptable attitude of PGandE management and supervisors, his testimony must not be viewed in its narrowest sense, but with due consideration for the generic significance of the deficiencies described. If Mr. Stokes' statements at the January 25, 1984 meeting with the Staff are as accurate as his earlier allegations have proven to be, then PGandE has a lot of explaining to do.

The only adequate forum in which that explanation can be adequately tested is the hearing process reopened by this l

Board last year on the issue of design. Discovery and cross-examination provide the only means to explore disputed matters of fact. Because the evidence submitted to this Board on l February 14th and supplemented with the January 25, 1984 L transcript undermines much of the testimony received by the Board last November, further hearings are plainly required.

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Accordingly, for the reasons stated above and in the Joint Intervenors' February 14th motion and attached exhibits (including the January 25th transcript), Joint Intervenors respectfully request that this motion be granted.

Dated: March 1, 1984 Respectfully submitted, JOEL R. REYNOLDS, ESQ.

JOHN R. PHILLIPS, ESQ.

ERIC HAVIAN, ESQ.

Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.

P. O. Box 1178 Oklahoma City, OK 73101 By e EL R. RjE?dLDS Attorneys for Joint Inter-venors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APPELBERG JOHN J. FORSTER i

3 e

• 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 O.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that on this 1st day of March, 1984, I have served copies of the foregoing JOINT INTERVENORS' SUPPLEMENT TO FEBRUARY 14, 1984 MOTION TO AUGMENT OR, IN THE ALTERNATIVE, TO REOPEN THE RECORD, mailing them through the U.S. mails, first class, postage prepaid.

• Thomas S. Moore, Chairman *Dr. W. Reed Johnson Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission. Commission Washington, D.C. 20555 Washington, D.C. 20555

• Dr. John H. Buck Docket and Service Branch Atomic Safety & Licensing Office of the Secretary Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Lawrence Chandler, Esq.

Office of the Executive Legal Director - BETH 042 U.S. Nuclear. Regulatory Commission Washington, D.C. 20555 L

• Malcolm H. Furbush, Esq.

Vice' President & General Counsel Philip A. Crane, Esq.

Pacific Gas & Electric Company 77 Beale Street, Room 3135 San Francisco, CA 94120 Mr. Fredrick Eissler.

Scenic Shoreline Preservation Conference, Inc.

4623 More Mesa Drive Santa Barbara,,CA 93105 Janic'e E. Kerr, Esq.

Lawrence Q. Garcia, Esq.

J. Calvin Simpson, Esq.

California Public Utilities Commission 5246 McAllister Jtreet San Francisco, CA 94102 John Van de Kamp, Attorney General Andrea Sheridan Ordin, Chief Attorney General Michael J. Strumwasser, Special Counsel to the

' Attorney General -

State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, CA 90010 David S. Fle~1schaker, Esq.

Post Office Box 1178 Oklahoma. City, 0,K 73101 E' chard Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San:JocQ,CA'.95125 Arthur:C. Gehr, Esq. '

Snell'& Wilmer 3100 Valley Center 1 Phoenix,-AZ' 85073 )

• Bruce Norton, Esq.

Norton,cBurke,sBerry & French, P.C.

2002 E..Osborn -

Phoenix, AZ 85064 Maurice Axelrad, Esq.

Lowenstein, Newman, Reis,&'Axelraa, P.C.

1025 Connecticut. Avenue,-N.W.

Washington, D.C.;[20036

~

Virginia and Gordon Bruno I Pecho: Ranch ' -

-Post Office Box 6289 Los-Osos, CA ,.93402

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L.' ..

Sandra and Gordon Silver 1760 Alisal Street San Luis Obispo, CA 93401 Hancy Culver 192 Luneta San Luis Obispo, CA 93402 Carl Neiburger Telegram Tribune Post Office Box 112 San Luis Obispo, CA 93402 Betsy Umhoffer 1493 Southwood San Luis Obispo, CA 93401 t$$d 17C40C/b q Christina Concepcion

• Delivered via Express Mail.

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