ML20087G769

Discusses Dispute Between Plant Workers & Util Re Slander Suit.Identification of Relevant Issues,Establishing Accountability for Inaccurate Util Statements & Fixing Hardware from QA Breakdown Not Yet Possible

ML20087G769
Person / Time
Site:	Diablo Canyon
Issue date:	03/19/1984
From:	Devine T GOVERNMENT ACCOUNTABILITY PROJECT, SAN LUIS OBISPO MOTHERS FOR PEACE
To:	Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM)
References
NUDOCS 8403200133
Download: ML20087G769 (20)

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GOVERNMENT ACCOUNTADIUTY PROJECT Institute for Policy Studies %h[g0 1901 Que Street, N.W., Washington. D.C. 20009 (202)234-9382

'84 WR 19 A8I02

, March 19, 1984 Nunzio J. Palladino, Chairman Victor Gilinsky, Commissioner Thomas Roberts, Commissioner mm 2 James Asselstine, Commissioner Frederick Bernthal, Commissioner In h "

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

Wasnington, D.C. 20555 -

Dear Commissioners:

On behalf of the Mothers for Peace, the Government Accountability Proj ect (GAP) commends the staff for renewing the dialogue with employees from the Diablo Canyon nuclear power-plant. On Thursday and Friday representatives of Region V, the Office of Investiga-tions (OI), and the Office of Nuclear Reactor Regulation (NRR) made commitments and/or arrangements for interviews,with court reporters or other formal documentation of the record created by the meetings.

The whistleblowers include previous witnesses who raised allegations chat will be covered by SSER 22, as well as the staff's recent licens-ing affidavits. Other witnesses are the authors of affidavits both from the Mothers' January 31 and a coalition's March 2, 1984 petitions under 10 CFR 2.206. Still other whistleblowers represent new witnesses with highly significant, additional allegations. Counsel has obtained over 100 allegations daring the past two weeks and is formalizing a further petition. Consistent with the urgency of the Commission's review schedule, however, the witnesses are meeting first with the staff as the highest priority.

Counsel is gratified that the staff has recognized the seriousness of the issues raised by these witnesses; the attempt to arrange initial and followup interviews began two weeks ago. We hope that SSER 22 does not draw conclusions for previous allegations without followup interviews, because the allegers have been available.since they made the charges in January. The Mothers are particularly relieved that the Office of Investigations has begun communications with the i relevant whistleblowers, nearly four months after initial receipt of the evidence. The process the staff has renewed and begun could lead to development of an accurate, reliable record for the Commission to make its low power operating license decision.

Unfortunately, a reliable record does not yet exist. The Mothers believe that the uniform chorus of denials by PG&E over the last month ~ <

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of any significant problems are a bluff, consisting largel'y of asserted conclusions without citations or support on the record. The whistleblowers believe that in an alarming number of instances the denials represent material false statements, because internal corporate documents or eyewitness accounts directly contradict PG&E's assertions.

The most dramatic evidence of material false statements concerns the 1977 Nuclear Services. Corporation (NSC) audit of PG&E's contractor Pullman. Here the new evidence is significant for statements in both the draft and final versions of IE Report 83-37. With the whistle-blowers' assistance, many of the severe errors in IE Report 83-37 can be corrected. To illustrate the nature of the alleged false statements on the NSC audit, whistleblowers have .

evidence or can testify that during the mid-1970's PG&E fully realized--

1. the existence of generic deficiencies in the Pullman quality assurance program;

2. the possible effect of the QA violations described by NSC on the plant's hardware; and

3. the relevance of the NSC findings for licensing hearings then about to begin.

Among other issues to be discussed are 1983 PG&E statemente on previous QA standards. The statements directly contradict internal records from the mid-1970's. Unfortunately, the staff previously had taken the 1983 version at face value.

3 The inaccurate responses accepted in IE Report 83-37 on the Pullman audit mirror false, misleading and/or incomplete statements in the I numerous 1984 letters sent by PG&E to the NRC staff.' Witnesses are prepared to call PG&E's bluff with respect to welding symbols and the seismic design review, as well as other Pullman QA violations from 1977-1984.

-f Some of the disclosures from new witnesses cast doubt upon PG&E's public reassurances about the sound condition of the plant. For example, '

a March 7, 1984 affidavit, enclosed as Exhibit 1, describes a breach 2

of c~ontainment integrity at the end of February, when one of the main containment4 hirlock doors blew open. Workers were sucked from outside into the inside of the containment by the force. Maintenance crews explained that the hinges for the 14 year old door.were. worn out before the plant began operation. Under the plant's-safety technical specifi-cations those' flaws'should have been caught by a surveillance program prior to fuel loading.

Another new isene has policy implications for the-Commission's whistleblower protection regulations under 10 CFR 50.7. On January 4,-1984

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PG&E introduced its own version of Big Brother -- the " Behavior Observation Prog.~am" for supervisors to determine the psychological

" fitness for duty" of employees with security clearances. It is enclosed as Exhibit 2. Among the "five criteria for nuclear behavior reliability" is " hostility towards authority," one of whose examples is described as follows - " Refuses to take orders, challenges supervisor's authority, ... is extremely critical of the company." Each of those responses could represent activity protected under 42 USC 5851 and

'10 CFR 50.7, if the employee is challenging illegal activity. The discovery of this new program coincides with lawsuits filed by three Diablo Canyon employees for slander and invasion of privacy connected with psychological evaluations. (See March 16, 1984 news article, enclosed as Exhibit 3.) The Mothers believe that the Commission should scrutinize this PG&E program to insure that the license prohibits all forms of psychological abuses directed against legally-protected freedom of speech.

On balance, despite the barrage of allegations and confirnation, Diablo Canyon has not been fixed. A March 6, 1984 PG&E letter, I enclosed as Exhibit 4, describes the totality of repairs and modifica-tions due to allegations since September 1983: 1) modification of one pipe support; 2) replacement of one half inch anchor bolt; 3) re-placement of 84 feet of electrical wire; and 4) installation of a ,

safeguard to isolate the effects of a fire in the control room.

In short, there is a long way to go towards identifying all the 3

relevant issues; correcting and establishing accountability for any inaccurate PG&E statements in its recent barrage of denials; and

, fixing the hardware effected by the QA breakdown. Counsel.is at the disposal of the Commission staff to expeditiously fulfill those require-ments. Whistleblowers represented by GAP have indicated their willing-ness to cooperate fully with the staff. The Mothers, GAP and the witnesses all support the Commission's stated position that no licensing decisions will be made until all significant safety questions are resolved. We welcome the opportunity to help achieve that-goal without further delay.

Sincerely,

1. - h t- 75 Thomas Devine Counsel for the Mothers for Peace 4

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Exhibit 1 AFF7 DAVIT My name i. - I am submitting this affi-davit freely and voluntarily without any threats, induce-ments or coercion, to Mr. Thomas Devine, who has identified himself to me as the legal director of the Government Accountability Project. I am a security access guard at the Diablo Canyon nuclear power plant. This statament evidences two reasons why I am concerned that Diablo Canyon is not ready to go critical and begin low-power oper-ations- 1) the suspect condition of the plant, illustrated by widespread pipe leaks during the hot function tests and a breach of containment Lategrity within the last two weeks when a door blew e$h and sucked nearby workers into the containment.; and 2) a systematic organizational break-down within the security forcas at the plant, caused by-pervasive mismanagement and harassment that has thoroughly demoralized already overworked security guards, and illus-trated by an incident around three to four weeks ago where a religious protester penetrated inside the perimeter and into protected areas.

I am also concerned that the Nuclear Regulatory Com-mission (NRC) does not appear to be reacting to these problems on-site; and that the public has not been able to learn of these incidents otherwise through the media. The public should not remain ignorant.of what is happening at Diablo Canyon. The consequences cculd be too serious.

For the last months I have worked for Pinkerton Security at Diablo Canyon as a security access control officer.

Previously I have served in the. Marines f I believe that I.

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) have a good record and have earned professional respect as a security officer at Diablo Canyon. During my employ- )

ment I have not been formally (or informally) disciplined for any misconduct or other problems, except once for

_ . - ~_ . As a result,none of my allegations are .

motivated by " sour grapes." I simply am concerned, as a resident and eyewitness, that Diablo Canyon may nct be ready to operate.

I. CONDITION OF THE PLANT

1. Shortly after noon on Friday, February 24, the integrity og,,the, containment was bree.ched when an airlock door b Ik: vff at the 140 foot level of the main contain-ment in U nit I. All access to the containment is through this entry, which consists of two pressurized airlock I

doors that can only be opened one at a time. After the 3 first door is closed, employees have to wait in a space between the doors while the second one is opened.

On:.the morning of the ;O;tt, '.was on duty as a security access guard. Since there were too many psople coming in and out, ( had to back them up. Two employees got stuck l inside the airlock when the doors didn't open. reported the incident to r e. sergeant,and a PG&E crew arrived around 20 minutes later.. The workers who had.been stuck were drenched with sweat because temperatures are high during hot functional testing.

' Around 45 minutes later-the incident happened again; this time four to five guys were stuck inside. Again it taok around 20 minutes for the PG&E crew to arrive. Shortly afterward was transferred to another post.

When returned to the containment access door in early afternoon, >

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was at w . The crews described to me in detail what had

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happened. The' feent door to the afriock blew o' pen when InNd some employees opened the back door. There was a tremendous pressure, described to me by employees who were there as like a hurricane. Two fire watches standing near the

outside were sucked, clear through.the girlock. A security officer was pulled toward the containment from around 15 feet outside the doory but. held onto wooden scaffolding at the entrance. A foreman similarly was sucked in but .

{ successfully grabbed onto. a door jam. A chair in the entry-way flew into the containment at chest level. The outer door itself, which weighs several hundred pounds, swung open as if on a spring, according to witnesses.

Pacific Gas and , Electric (PG&E) officials Mielke and Thornberry came by to survey the damage. Maintenance employees told me that to repair it they would probably have to borrow parts.from Unit II. 'They explained that the doors are 15 years old and aren't made any more.

2. Maintenance workers described the cause of the

, accident to =e as shear hinges on the door which were already worn out from overuse. This concerns me, because the plant has not yet started operation. If the mainte-nance workers were correct, all safety-related doors should be rechecked to see if they are worn out before the plant goes critical.

3. I am concerned at the absence of any visible NRC presence or known response to the containment door accident.

The incident was widely known;'everyone was talking about it by the end of the day. The estimates on-site were that the NRC would fine PG&E $50,000 - $100,000,but no one saw the NRC around to take a report. Nor has the-incident been 4

discussed in any of PG&E's public reassurances.about Diablo Canyon's.. readiness to operata. I hope that a covsr up is not in progress.

4. At least twice during the last week and a-half,

the containment area has been closed off; due to bad air- .

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when there was less than the minknum amount of oxygen, and release of fumes from paint as the pipes heat up during hot functional testing. Once the containment area was closed off for a whole das A foreman working in containment told me that the heat from the pipes was releasing toxic acetone, dn; to the type of paint which had been applied. Security guards no longer are regularlyfpermitted to go into the containment, although general construction security used to be posted insidef de ar8 N" 8 "'N'

5. There are so many pipe leaks .in the hot functional tests that crews are working constantly to fix them; with some areas closed off continuously and water everywhere you look. In particular, I have observed this condition C>

1 -7 c r at the 85 foot level in the turbine l building, the southeast side just north of door 129. This week I saw two new leaks at the 145' foot level, east pene-tration area by door 365, between the turbine building and the containment in the piping penetration area. I hope l that the NRC is aware of all these leaks, either throughsc.42r its own investigators or through PG&E reports. The inten-sive rate of leakage appears inconsistent with PG&E's reassurances about the sound condition of the plant.

II. SECURITY BREAKDOWN

6. Around three to four weeks ago a religious pro-tester breached extensive security around the perimeter and reached a yard that is inside the main protected areas.

After climbing two fences and entering around gate 11, the protester sat down and started chanting before he was _.

arrested. It was about S:30 or f:00 A.M. on a Monday,ik/44, From the spot he reached, the protester could not enter the reactor. But he did have. access to vital areas, such

, as the condensate tanks and a pipe gallery on the lower side of the northeast yard,had he chosen to continue. I '

believe that-this_was a major breach of security,because

supposedly demonstraters have been- trying to breach the

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perimeter for yaars without success. This would mean that our security force is weakest just at the time it should bo most effective -- as the plant is about to go critical. If a religious chanter could get that far, I wonder what a professional terrorist.could.do? Helicopters and dogs were used unsuccessfully in efforts to stop this protester.

I am concerned that the public has remained ignorant of the security breach; it was the major news of the day on-site.

I hope that PG&E properly reported the incident to the NRC. A licensee of an operating plant has to report such a security breach to the NRC within an hour as a significant event under 10 CFR 50.72.

7. The breach of perimeter incident illustrates a generic breakdown over the last six months for security on-site. Tnose of us who have maintained pride in our work

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think that our job as securi.ty}rtWhas.become

/of C/JSC4#4tt Jtrstn1 an embarrassment.

W Guards often do not 4eek at t,he X-ray phete; on individuals who pass through the security machines. Similarly, because there are 4h#e Nany patdowns, guards lose their concentration 44 . . - _

and effectiveness m 'y just gotet through the motions. I have observed and reported suspected security breaches in s4MCN the field, without seeing may evidence of response.

8. Part of the reason for the deteriorating quality of security is overwork. Security work demands continuous concentration to be effective. Last August we went from eight hour days to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days, without a second break.

I believe that decision represents mismanagement, because

, many guards can not maintain necessary alertness for -such long periods. The types of security breaches and errers ~ ~'

described above hardly ever occurred when we were on eight hour shifts before last August. ~ *

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9. Another major cause for the security breakdown '

is poor morale among the guards, due to management harass-

ment that has reached the point of an adversary relationship where officers are more concerned about job threats from supervisors than security threats from protesters. There is an intensive dismissal rate on-site. The solution to l personnel deficiencias routinely is to immediately fire .

the officer, instead of providing needed training or re-training.

10. Another program def ciency is that management has not informed us what we can and cannot do with respect to protesters. For example, we were taught how to dse fire hoses but not told when we could use them.

11. Another cause of the unreliable security system may be an unreliable canputer system which over the last several months has erroneouslypermitted around a dozen holders of expired key cards to cass through security. The computer showed a green light, when it should have flashed red.

12. I have been forced to go outside our system, '

because there is nowhere to work within Pinkerton's system and guards are afraid to raise serious, legitimate questions,

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1 because we are afraid of getting fired.

Raising issues of security or morale problems typically leads to a response I

such as, "If you don't like it, you can go on down the road" (or "say goodbye"). -

13. It is a punishable offense to raise problems out-side the chain of command. That means-a guard can only dissent to the sergeant initially. Blowing the whistle directly to a PG&E security shift supervisor leads to a written reprimand with a warning on the first offense, and.

is grounds for dismissal the secchd offense. The restriction means that constructive efforts to discuss-problems often lead to threats'from sergeants, instead of solutions.

I have read the above six page affidavit, and it is 1 true, accurate and complete to the best of my knowledge and l belief.- U w . m l

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o State of California County of San Luis-Obispo f

. .=":-7, being duly sworn, deposes and says:

That he has read the attached six page affidavit, and to the best'of his knowle~dge and belief,'it i's true and accurate and complete.

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T, ,," K .- 2 Subscribed and sworn to before me on March 7,1984, d/A &+&

Effle 196Dermott, Notary Public in and for said state i OFFICIAL SEAL l EFFIE MC DERMOTT q NOTAirt ruSUC - CAUFC ANIA

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' . Exhibit 2 ren isTR A -cowpawy urts f..

• prom oi ioa or NUCLhAR PLANT OPERATIONS l - ' - u-

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Ft'.c No. 71C.2 - _

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s evener Behavioral Observacion Program -

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Letter No. 84000046 o**"~t .: .

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January 4, 1984 .

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TO: ALL SUPERVISORS.0F PERSONNEL CLEARED FOR UNESCORTE'D ACCESS

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TO THE DIABLO CANYON POWER PLAN:

The attached outlinezdescribes'the NRC requirement for maintaining a program of 'tehaiicral ~ observation,of allf employe_es granted unescorted security access at tha Diablo Canyon Power Plant. .

Although we already have the framework of such a program in effect in existing ~ personnel practicas; and accident prev'ention rules, i.e. ,

supervisors take action when en; employee is 'not " fit for duty", it ~

is necessary that we acconolish the following~ steps .to bring us' into '

full. compliance with NPr -squirements:

Supervisors 'of employees with unescor'ted secbrity access must

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submit docume'ntation'that thsy-have maintained " continuous observation" of their employees during 1983.? This should be completed en the attached (form, using the information in the attached outline and returned to R. G. Todaro by February 29, ' '

1984. s s .

2. To supplement the written instructions and to further develop supervisory abilities in this area, we will. bi providing on site behavioral observation training during'the first quarter of 19.84 for all Diabid' Canyon supervisors of1 employees with unescorted ~ security access.1 Alternative training will be ar-

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ranged -for off site supervisors. , , s Please direct any. questions:to Bria'n[Jalbert,. Employee Assistance Counselor, extension 3191. c s

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BNJalbert(69-3191):dli  :

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EEHAVIORD m RVATIO.; PROGRA*4 SCOPE It is a matter of PGandE Company policy as well as our committment to the .

i NRC that specif.ic measures be taken to insure the. behavioral reliability of employees granted unescorted security access. In addition to the al-ready familiar pre-employment psychological screening process, the NRC requires that we maintain a ' program _of continuous ' behavioral observation of those individuals granted unescorted security access. Specifically, the reouirement has three elements:

1. That all individuals with unescorted security access be observed during the course of their employment for any -indication of unreliable /untrust-worthy behavior or emotional instability. .

2. That the Behavioral Observation Program, include documentation on -an

annual basis.

3. That supervisors receive training in recognizing unusual behavior.

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PURPOSE As an important part of our committment to the government, to the community -

and to our employees and their families that safe operation of the Plant i;,-

our highest priority, the purpose of the Behavioral Observation Program is to insure a high standard of employee reliaoility. It is based on the pre-mise that an unreliable person in any position could jeopardize the personal.

safet'y of others as well as the pnysical integrity of the Plant.

As outlined in NUREG 0758, several facts have demonstrated the need 'for a be-havioral reliability program:

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1. Over a ceriod of time, internal and external stresscrs can affect changes-in an employee's. job perf'ormance and reliability. -

2. Incidents related .to emoloyee unreliability have already occurred in nu-clear environments.

3. The public is demanding plant safety and safeguards.

While the formal establishment of a Behavioral Observation Program is a new conceot for Diablo Canyon, in effect what it does i.s . provide an effecti.ve means of enabling supervisors to implement PGandE guidelines of fitness for duty. Accident Prevention Rule lib states:

"Any employee in charge having reasonable grounds to l suspect that 'an emolcyee under his ~ jurisdiction .is .  :

4 either mentally or physically _ unfitted for the work 3 assigned, shall' prohibit such emo!oyee from working .

p until satisfactory medical _ -or other evidence indica- ,

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' ting his- fitness is secured."

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. icnavioral Observat1on Progrca  : age 2 ,

Thus, the NRC's requirement for a Behavioral Observation Program is a for-malization of PGandE guidelines already in effect.

SERAVIORAL RELIABILITY CRITERIA .

NUREG 2076 presents the results of research conducted by the Edison Electric Institute and Assessment Design, Inc. to establish criteria.for determining behavioral unreliability and emotional instability. Five criteria for _ be-

'. havioral unreliability were established: .

1. Hostility towards authority .

2. Irresponsibility '

3. Defensive incompetence

4. Psychopathology

5. Reaction to accumulated stress Specific behaviors for each of these five criteria are listed in Attachment A.

The list provides examples of how unreliable behavior might be manifested on the job. The list is by no means exhaustive, and any one of the behaviors taken alone generally does not imply unreliability. The listing does not take irto account important variables such as quantity, intensity or duration of behavior. The criteria are job related behavioral patterns that a supervisor-can observe.

It is the change from typical to atypical behavior that may indicate behavioral unreliability or emotional instability. A supervisor's responsibility in be-havioral observation is to know how his/her emolayees tyoically behave and cer-form and then to be able to identify wnen chances occur in tneir benavior. The benavioral criteria in Attacnment A serve as guidelines for this.

TRAINING FOR SUPERVISORS Curing the first quarter of 1984 we will be conducting training sessions for all supervisors with responsibility for employees with unescorted security access.

The purpose of this training will be:

1. To help supervisors become more familiar with their role and responsibilities.

2. To help supervisors to identify and describe behavioral unreliability or emotional instability.

3. To help supervisors approach and talk to employees whose behavior:is ques-tionable.

4. To teach suoervisors the administrat've steps necessary when. behavioral unreliability is observed.

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5:navioral Observation Program 00CU'iENTATION It is an NRC reouirement that we maintain annual written verification tnat supervisors have observed for signs of behavioral Tounreliability accomolishon thethe this, part -

of emolayees granted unescorted security access.

attached form has been developed.

INSTRUCTIONS TO SUPERVISORS READ BEFORE FILLING OUT THE FORM

1. Time Period Covered

a. Where apolicable, the intent is to cover the entire calendar year, January 1 - December 31. For each employee, fill in the dates'during which you have supervised and had direct observation of the ercloyee.

b. The dates should be adjusted accordingly for employees who have nQt had unescorted access at Diablo Canyon for the entire year.

c. For emnloyees who have had multiple supervisors during the year, department heads- should coordinate with the supervisors to insure coverage for the entire oeriod of, emoloyment during the year.

2. As a supervisor, you will have to exercise judgement as to whether an -

d unreliable or untrustworthy behavior."

isolated incident constitutes Using the guidelines in Attachment A will help you to identify trends versus isolated incidents. For example, if an employee missed a single deadline or made a mistake on the job, such an isolated incident may have little significance, but when such behaviors become repeated this may indicate a change in behavior toward unreliability or untrustworthi- -

ness. . .

3. Sign and date the form. .

4. Return form to Security Supervisor for further processing.

5. Please direct any questions to Employee Assistance Counselor-Brian Jalbert, extension 3191..  :

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. FIVE CRITERIA FOR NUCLEAR EEHAVIORAL UNRELIAEILITY

1. Hostility Toward Authority Includes behaviors such as:

- Exhibits fits of temper, argues or fights with others, screams or swears when questioned.

.- - Refuses to take orders, challenges supervisor's authority, shows arrogance, is extremely critical toward the Company. .

- Refuses to comply with established procedures and safety precautions, bends-rules.

- Overreacts to real or imagined criticism.

- Displays rigidity or inflexibility, becomes agitated if work routines are interfered with.

- Attempts to perform all operating activities alone.

- Refuses to accept help from others.

- Argues about established policies and procedures.

2. Irresconsibility Includes behaviors such as:

- Takes action without thinking.

. - Shows questionable judgement on the spur of the moment.

Plays frequent pranks.

- Shows little concern for disciolinary thrdats. laughs off errors or reprimands.

Is often tardy or absent.

Denies mistakes.

- Operates equioment carelessly.

- Is frequently sloopy or fails to complete work.

Ignores : time limits er procedures. -

- Creates excitement when bored on the job.

Lies about work issues. .

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. - Engeges in theft.or sabo age', lies or cneats, commits acts cf var.:alisc.

- Pro'vides incorrect or inaccurate information when ouestioned.

- Refuses to offer expertise to others, tries to eIstablish self as "excert" by with holding ooerating information from others. .

Sleeps on the job.

- Displays'a low boredom tolerance that results in a lac,k of vigilance.

Defensive Incomoetence 3.

- Refuses to enter contaminated areas when appropriate to enter. ' .

- Worries excessively about radiation overexpos'ure. ,

- Covers up mistakes to conceal lack of system comprehension. .

- Displays excessive timidity on the job.

Fails to inform others of relevant information.

- Is ' reluctant to act without direct orders or explicit instruction.

Tries to fake or bluff when uninformed.

4. Reaction to Stress _

Includes behaviors such as:

- Responds inappropriately to critical or emergency situations, becomes indecisive or incapacitated, disappears from the work scene when-faced

with a crisis. .

- Startles or cries easily.

- Loses the ability to discriminate the problem and the action needed, treats normal situation's as crises, freezes, becomes indecisive'or in-capacitated, forgets important or obvi'ous things. ~

- Shows deteriorating performance.

- Displays. unusual physical signs of nervousness such as sweating, tremors, hesitation.

- .Comolains excessively about oressures'outside of work such as-family or finances. ~

- Abuses or is dependent uoon chemicals, alcohol or other drugs, i

- Memory loss.

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.' 5'. Emotional and Personal Non-Adacatabili y Includes behaviors such as:

- Displays recurrent mood swings from extreme euphoria to extreme decression.  !

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- ' Chronic fatique, insomnia or appetite changes. ,

- . Extreme suspiciousness.

- Demonstrates an excessive need for acproval or hesitates to act without direct instructions. .

- Tends toward social isolation or withdrawa-l.

- Displays a lack of attention to personal appearance. ,

Is reluctant or refuses to work as a member of a team.

- Appears disoriented, has a loss of memory or shows a marked decline in intellectual functioning.

- Disolays a delayed reaction time.

Shows no emotion at all.

- Has an inability to perform job tasks as a result of medical or physical symptions. ,

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- Sees or hears things that do not exist.

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Makes suicidal threats.

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- Has difficulty comprehending or responding to qu5stions, jumps from topic

.to topic in speech' .

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.O N SAN LUIS OBISP0 COUNTY (CALIF.) TELEGRAM-TRIBUNE, FRIDAY, MARCH 16,1984 A3 Diablo workers file slander suit By Tom Fulks .

discharged as the result of evaluations by Some of the 500 yes or no questions given Staff Writer Behaviordyne psychologists that the men were workers to determine psychological makeup

" psychologically unfit and mentally unstable." included:

Three Diablo Canyon nuclear power plant The men expected the evaluations would "My sex life is satisfactory."

workers are claiming Pacific Gas ud Electric remain private, due to the confidential nature of "I am very seldom troubled by constipation."

Co. slandered them by telling their co-workers doctor-patient relationships, according to the "I do not always tell the truth."

the men are mentally unfit. complaints. "My soul sometimes leaves my body."

Jack Doody, Larry Brindle and Harold Wil- PG&E and Pullman violated the privacy "I do not read every editorial in the newspa-Ilams filed separate complaints this week in interests 'of the men, the complaint said, by per every day."

Superior Court. publicly disseminating the evaluations and an- "I would like to be a :lorist."

All claim they were fired from their jobs as nouncing the findings over the loudspeaker. "I believe in the second coming of Christ."

the result of psychological evaluations conducted The n(en claim that action caused them "Someone has it in for me."

by the Behaviordyne Psychological Corp. "humillr.tlon, mortification and shame," and "I have never indulged in any unusual sex.

& three men were employed by the Pull- that they suffered loss of reputation. practices."

man Power Products company, also named in The sufts say the psychologists prepared Brown said the tests are given to workers to the suit, when they were fired in 1983. " negligent, false and incorrect evaluations of the determine individual personality traits. She said All have since been rehired and given back psychological fitness" of the fired workers. . the questions are arranged in a manner to detect wages by Pullman, according to PG&E spokes- Behaviordyne, PG&E and Pullman also were if a person is consistent with answers.

woman Suzanne G. Brown. negligent, the suits claim, in failing to "investi- Those who fail the test are determined to be' Behaviordyne was hired by PG&E to evaluate gate the false, damaging and incorrect chatges" risks in high security areas, Brown said. "We '

the mentsl fitness of em91oyees who work in the against the men, and in falling to keep accurate have to have stable people in there."

plant's high security art. .,, Brown said. personnel records and falling to correct them. Brown said the three men who filed the The three men claim personal injury, inter- The suits also said Behaviordyne, PG&E and complaints failed the original psychological ference with their privacy interests, negligence, Pullman slandered the men by announcing they tests, but were given a chance to have their owrf slander, libel and wrongful discharge. were being fired. psychologists examine them. All three did.

The complaints claim Behaviordyne released W announcement was heard by hundreds of Brown said since the later test results con-the results of confidential psychological tests to Diablo Canyou workers, the suits claim, who fJcted with the originals, a third psychologist PG&E officials, who then said over a loudspeak- allegedly knew " security risk"in fact meant the was called in for an opinion.

er system at the plant that all three had been men failed to pass the psychological tests and The final opinion cleared the three men as f fired because they were security risks. Interviews. security risks and all were hired back, Brown Brown said the claim of the men's dismissal The complaints say many of the workers at said.

being announced over the loudspeaker system is Diablo Canyon had taken the same tests, which She said PG&E attorneys have not seen the j

false. gave them special knowledge of the testing complaint and will have no response until they The suits say the men were wrongfully procedures and results. do.

Exhibit 4 D

COPV PACIFIC OAS AND ELE C T RIC C O MPANY 77 BE ALE STREET, SAN FR ANCISCO, CALIFORNI A 94106 TELEPHONE (415) 781 4211 i

March 6, 1984

PGandE Letter No.

DCL-84-094 Mr. John B. Martin, Regional Administrator

' U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210

Walnut Creek, CA 94596-5368 Re

Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit i Nodifications, Repairs and Equipment Changes Resn1 ting From Allegations .

Dear Mr. Martin:

On March 4,1984, NRC Region Y requested that PGandE provide, by March 6th, a description of Diablo Canyon modifications, repairs, and equipment changes which haveofresulted September 1983. from the allegations investigation accomplished since To respond to this requast in the time available, Project Supervision in the Engineering, Construction and Licensing organizations has reviewed project activities and material prepared for submittal in response to allegations.

The results of this review are enclosed.

PGandE believes this review has identified all items related to the NRC request; however, should additional items be identified NRC Region V will be notified.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, J. O. Schuyler by T. A. Moulia Enclosure cc: T. W. Bishop D. G. Eissnhut -

H. E. Schier11ng Service List i

. . _ . . _ _ _ _ , _ - . - . _ _ _ . - . . ~ , _ . . . - , - , . , .__

.~. . - . - - . . . - . . - - . . . - . - . - - - . - - .. .. .. --.

l PGandE Letter No.: DCL-84-094 ENCLOSURE MODIFICATIONS, REPAIRS, OR EQUIPMENT CHANGES FROM ALLEGATIONS REVIEW PERFORMED SINCE SEPTEMBER 1983 i

Post Septenber 1983 review of allegations and NRC inspection itens concerning allegations has resulted in the following ninor modifications and repairs.

1. PGAE review of small bore pipe support number 100-111, identified for NRC review by Mr. C. Stokes, resulted .in a minor .nodification. The support provides restraint of the valve operator and the pipe at the valve. The modification was the addition of an axial restraint at the pipe to prevent transfer of forces to the operator in the axial direction. This

! change was nade for consistency with Project standard practices even though analysis showed the change was not necessary to neet acceptance criteria.

2. One 1/2 inch dianeter electrical raceway anchor bolt was replaced during the audit of concrete anchor bolts embednent. The original bolt was renoved to verify, by physical measurenent, the depth of enbednent as indicated by ultrasonic neasurement. The replacenent bolt was fully enbedded; however, engineering analysis would, in all probability, have l shown qualification of the initial installation. Thirty-nine sinflar installations were analyzed and adequate safety factors were demonstrated

, as reported in PGandE letter DCL-84-059, dated February 16, 1984.

t

3. The NRC review of allegations related to electrical wire traceability led

, to t.he following changss:

a) Approximately eighty-four feet of Continental HTR wire, installed in i the Control Roan Positive Pressure Ventilation Systen was replaced.

The wire was docunented to be qualified and of the proper type and color code, however traceability to the source (wire reel) was not established. This is discussed in PGandE letter DCL-84-066, dated February 17,1964. i b) Installation of a redundant isolation contact on the negative lead of '

Unit 1 RHk pumps and charging pumps control :frcuits, as specified by a Design Change Notice, had not been perfomed. This design change was nade to assure that a fire in the Control Roon would not affect l control of this equi l Auxiliary Building. pnent fron the Hot Shutdown panel in theAll similar desig l and proper installation verified. This discrepancy was-docunented in PGandE NCR DCI-RE-83-N008.

In addition to the above listed itens, the investigation of allegations has resulted in extensive records review and some engineering analysis and testing to denonstrate the acceptability of-existing installations.

j 0518d/0005K

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