ML20093E502
| ML20093E502 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/16/1984 |
| From: | Devine T GOVERNMENT ACCOUNTABILITY PROJECT, SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Asselstine J, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| OL, NUDOCS 8407170577 | |
| Download: ML20093E502 (101) | |
Text
. _ _ _
O GOVERNMENT ACCOUNTABILITY PROJECT Institute for Policy Studies 1901 Que Street. N.W., Washington. D.C. 20009 (202)234-9382 Cowi W July 16,1984 0:'d.C
'84 JUL 17 A8:28
,= : ; K Nunzio J. Palladino, Chairman f.0 ' ':MG & E Thomas Roberts, Comissioner N'"
James Asselstine, Comissioner Frederick Bernthal, Comissioner Lando Zech, Comissioner U.S. Nuclear Regulatory Comission 1717 H Street, N.W.
Washington, D.C. 20555 Re:
Diablo Canyon Nuclear Power Plant, Units 1 and 2 Docket Numbers 50-275 and 50-323 & 2 e (.1 J
Dear Comissioners:
Pursuant to 10 CFR 2.206, the San Luis Obispo, California Mothers for Peace (Mothers) petition the Comission to take six minimum steps legally necessary to assure public safety before any comercial licensing decision at the Diablo Canyon nuclear power plant. The. scope and basis for each item is sumarized within the request.
Specifically, before the commercial license vote the Mothers petition
, the Comission to --
(1) provide sufficient organizational freedom.for Inspector Isa Yin to return to the Diablo Canyon case and complete any further factfinding he believes necessary.
This step is necessary to honor the staff and the Comission's previous public-statements. Essentially, Mr. Yin agreed not to interfere with the low-power test vote if he were permitted to participate. in a full review and resolution of the most significant safety issues.
In effect, the staff -
reneged on.it:: part of the bargain. ~As Mr. ' Yin-stated in a news interview, "The crux of it is I wasn't allowed to fo The invest 1];ation has never really been.ca,llow.isp the. questions I had...
rried out."
See July 12, 1984 Washington Post news article, enclosed as Exhibit 1. ;
s.
%3 Ur. fortunately, the staff's-doublecrosFwas not a private affair. As
- recognized when his,1.nspectlon' findings ~were Ehe' basis for licensing condi-tions, the issues have the highest significan'es ~ f56 pub 1(ic safety, i
?'?
l The response from already-disillusioned,whistie5$wers was to boycott further interviews "until Mr'.' Yin decides the iEoces,s is -honest enough to merit his return... " See' ' July if61984 affidavit of' Charles Stokes, enclosed.as Exhibit 2, at TT.- In garticular,%he whistleblowers will not i
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play any more games about a plant tour with Region V, which will not agree to i
f change its groundrules and assure a reliable record.
Region V is currently under investigation by the Office of Inspector and Auditor (OIA) for alleged i
material. false statements at the last plant tour.
Part of this petition is for Mr. Yin to be assigned responsibility for any future plant tours. See July 10,1984 letter from Thomas Devine to Lewis Shollenberger, enclosed as Exhibit 3.
i (2) appoint an independent organization to replace the Advisory Committee on Reactor Safety to arbitrate the debate between Mr. Yin and the peer review team.
As seen after the July 11, 1984 meeting, the ACRS subcommittee assigned to this task had neither the desire nor willingness to seriously consider Mr.
Yin's technical concerns or to keep looking for any problems at.Diablo Canyon.
See July 16, 1984 affidavit of Thomas Devine enclosed as Exhibit 4, at 4-7.
Under those conditions, there is no legitimacy for any current ACRS recommenda-tions on Mr. Yin's concerns.
(3) expand the limited scope of the current DIA investigation into alleged material false statements by the staff, and permit OIA tomake findings of fact, and publicly release its report.
i It is heartening that DIA is investigating 16 allegations of misconduct such as false and/or misleading statements by the NRC staff in connection with the Commission's decision on low-power testing.
Unfortunately, OIA is inter-viewing all of the individual defendants but has not yet spoken with a single l
whistleblower. They represent both the witnesses closest to the evidence, and
, the victims of the staff's deception.
Surely in a criminal case the police would not merely interview the lawyer for the victim, and the defendants.
That is what is happening at the NRC, however.
Even worse, OIA is not permitted to make findings of fact on its own investigation. This restriction violates the minimum standards for any govern-ment investigation, a finding which OIA ironically made to the staff at Zimmer i
nearly three years ago.
Currently the ACRS has rejected any responsibility to determine whether a
Mr. Yin's investigation improperly was obstructed.
(Exhibit 4, supra.). This issue also must be addressed by OIA before the Commission can adequately assess Mr. Yin's current dissent, t
(4) provide a forum to resolve the 1050 outstanding material disputes of fact on issues significant to public safety.
It long has been Comission policy that public hearings are required for all material disputes of fact on issues significant to public safety.1/ At Diablo Canyon there are over 1000 such issues, introduced.in 46 affidavits aiid dozens of interview transcripts.
1/ Indeed, at October 1,1982 congressional hearings, the NRC General Counsel testified that "a formal adjudicatory hearing is required [by the Act] on issues on which there is a genuine issues of material fact.... For revocation of a license, it is not as clear.
For the Itcense itself, it seems to be clear." In response to questions from Congressman Ottinger, there was unanimous agreement-among the Commissioners in support of this interpretation.
L Page Threg There should be no question that the issues are sufficiently significant.
In addition to Mr. Stokes' concerns, the design allegations include such basic issues as routine design changes through memoranda; and operator drawings that still may be inaccurate, due to a management decision last December to stop reporting that deficiency.
The construction quality assurance (QA) allegations include the sa'e m
problems that led to a record $200,000 fine (Exhibit 5) at Zimmer; suspension of construction at Zimmer (Exhibit 6); and postponement of fuel loading at Waterford (Exhibit 7).
l At Diablo Canyon the Atomic State and Licensing Appeal Board has neither seen fit to reopen hearings, make findings on the disputed facts, or even address the specific alleged problems. Similarly, Region V has met'with whistleblowers to follow up on their original allegations just once since'the April 13 low-power test vote.
Region V has not conducted any interviews with whistleblowers for affidavits submitted since April 13 In June Region V did not even attempt to contact the alleger after Mr. Bishop was informed through counsel that 60%
of hydrostatic test results in Unit II failed due to over or underpressurizing, and a similar condition may well have existed in Unit I.
In short, neither the public nor the allegers have had any forum to resolve bitterly-disputed debates about the facts of serious safety issues.
Tae public and the whistleblowers have conscientiously attempted to work within the NRC's system.
In response to their painstaking efforts, the staff has responded with the equivalent of a form rejection letter.
This result is incompatible w'ith the due process clause of the Constitution.'
(5) conduct a detailed Cormnission briefing by the Office of Investiga-tions on issues relevant to determine corporate character and competence.
At a minimum, the OI briefing should include a public report whether reasonable assurance yet exists that the licensee has acted within the law on the following issues: destruction of documents during the seismic design review; material false statements in response to 1983-84 whistleblower allegations; falsification of records on-site since the April 13 low-power licensing vote; 1984 management instructions not to write quality assurance' reports; and harass-ment and intimidation against QA/QC personnel.
A public assessment is mandatory, because these issues all are material to any licensing decision. 2/
In some and NRC Safety Procedures, Hearings before the Subcommittee on Energy Conservation and Commerce Committee (October 1,1982), at 395. 'See also Duke Power Co.
(Catawba Nuclear Station, Units 1 and 2), DD-81-1,13 NRC 45-~46 (H81; Carolina Power and Light Co. (Shearon Harris Nuclear Power Plant, Units 1, 2, 3, and 4),
CLI-79-10,1C NRC 675, 676 (1979).
2_/
See Houston Lishting and Power Company (South Texas Project, Units 1 and 2),
CLI-F 3212, NRC 2El (1980).
For the relevance of retaliation to the licensing decision, see 10 CFR 50.7 and Union Electric Co. (Callaway Plant, Unit 1) ALAB-740,10 NRT T43, 366 (1983).
l l
, Pag 2 Four O
cases, as with Mr. Stokes, they have been languishing for nearly eight months.
(Exhibit 2, at 16-17). The issue of retaliation was just litigated at the Department of Labor for Mr. Steve Lockert, a QC inspector who challenged nearly the entire welding program at Diablo Canyon over a three-month period l'st fall before his December dismissal. Witnesses have informed OI that false statements, harassment and intimidation have intensified steadily without letup.
Management and craft intimidation has become uglier as the licensing vote nears and inspectors attempt to document the increasing violations.
On April 13 the Commission did not consider these issues.
Under the law, tha loophole in the licensing review must be filled before the final vote.
(6) orde" a public report from the staff explaining the basis and significance of its decision to permit postponement for approxi-ely a year of PG&E compliance with some 6,000 licensing commitments.
These commitments involve issues such as the post-Three Mile Island reforms and even include one of the licensing action items from Mr. Yin's inspection. They all involve minimum conditions necessary for issuance of the license.
But in some 6,000 cases the rules were waived when PG&E failed to comply. '(Exhibit 2, at 7-8).
It appears that it does not matter if PG&E meets its licencing conditions. The staff's routine response to failure has been to temporarily waive the rules.
In short, there is little public confidence left in the integrity of the NRC's licensing review, or the safety value of an NRC license for Diablo Cagyon.
Unless the Commission exercises leadership promptly, for the public the Diablo Canyon licen:e will not be worth the paper it is written on.
Respectfully' submitted, M 4 h lyc Thomas Devine Counsel Mothers for Peace 1
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Exhibit 1
_ A16 rw.e.v. /.ti tr. sw THE WASHINGTON POST NRC Engineer Resigns From Diablo Task Force Earlier this year, the' NRC staff By Dale Russakoff ~ '-
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rec.-aMad that the commission A' veteran Nuclear Regulatory issue a start-up license for Diablo.
Commission engineer has resigned llut in a staprise dissent on the day from a special federal investigation that the commission was scheduled of the controversial Diablo Canyon :to vote on the license, Yin an-nuclear power plant, complaining nounced that he had documented a that his superiors obstructed his " breakdown"in plant design proce-inquiry into extensive alleged de-dures involving structural supports sign flaws in the $4.1 billion Cali- :for miles of pipes essential to safety fornia facility.
and cooling systems.
The resignation of Isa Yin, a me-As a result, the comnussion cre-chanical engineer who has received ated a special investigative team?o several NRC awards, is significant review Yin's concerns, and assigned because his findings of design prob. him to take part in the case.
i lems at Diablo prompted tue com-
' However, according to an affida.
mission in April to call for the spe-vit filed yesterday at the NRC, Yin l
cia! Investigation as a precondition said it would " compromise his in-to licensing the plant.-
tegrity" to remain on the case. He "I'he crux ofit is I wasn't allowed said that he was not allowed to fol--
to follow up the questions I had," ' low up employe allegations of de, Yin said in a telephone interview.
sign errors, and that Vollmer al-Yin told an NRC technical panel lowed him only one and a half days' yesterday that the investigative to review key design records.
na %4st orJy three days review-The affidavit was filed by Thomas ing records even though they Devine, attorney for the Govern-needed "a few weeks." He said he ment Accountability Project, which was denied the time he needed to represents several " whistle blow-review design records.
ers"at the plant who had given Yin "The investigation has never re-evidence of several hundred alleged
- ally been carried out," Yin said.
design problems. It recounts a con-i Richard Vo!!mer, the NRC offi-versation between Devme and Yin '
cial in charge of the investigation, following Yin's resignation two i yesterday defended the proceedings weeks ago. Devine said Yin ap. I and denied interfering with Yin's - proved the affidavit as accurate.
inquiry. He said Yin was unable to Vollmer w iud that the in-review records because of his own vestigative team had spent only schedule conflicts.
three days reviewing design Vollmer said all other members records,' but he said this was l
of the investigative team, engineers enough time to determine that the l from NRC and the Energy Depart-
"I don't view our activity as giv j plant's design was sound.
ment, have concluded the plant is safe and ready for full-power oper-ing the matter short shrift," Voll-l ation.The NRCis scheduled to vote mer said. "If we had found some-i on the matter on July 26.
thing that led us to believe there Diablo has been one of the na-were inadequacies in the plant, we
, tion *, most controversial nuclear would have raised these, but we plants since the NRC discovered in didn't find them."
1981 that its builders accidentally Devme called Yin's concerns "ev-had reverwd the blueprints for the idence of an agency-wide cover-up" l
plant's two units. The foul-up meant of problems at Diablo,' asserting l
that the plant, located on the cen-that "the integrity of the govern-tral California coast 2.5 miles from ment is the issue." He said that he -
an earthquake fault, was vulnerable and other groups will press the,
toseismicstresses.Diablo'sowners NRC to reopen licensing hearings agreed to a major design overhaul.
based on Yin's concern.
gwmvevy Exhibit 2 s
AFFIDAVIT This statement is given freely and without inducement by..
Charles C. Stokes in response to the PG&E presentation to the NRC on July 2, 1984 in Bethesda, Maryland, on the seven licensing conditions resulting from Mr. Isa Yin's inspection of my allega-tions and other issues.
This affidavit also challenged the NRC staff's willingness to license the DiEblo Canyon plant despite significant, unresolved questions material to the license.
Through tactictincluding delay of compliance for some 6p00 licensing commitments; delay in investigating my allegations of dali documentdestrfetion; failure to provide necessary data to verify or rebut Pacific Gas and Electric's (PG&E) asserted conclusions; and obstruction of Mr. Yin's work, the staff has guaranteed that we will not adequately know whether Diablo Canyon is safe if the Comr.de" ?-
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fciy 30 on a commercial license.
This is intolerable, since I have learned of still more false or misleading
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information in PG&E's previous denials to the NRC of any signifi-cant problems at the plant.
Initially, at,the May 9 meeting between PG&E and the NRC, PG&E gave the staff a large volume of new information in response to the licensing action items:
This information was not supplied with the transcript, as is the usual procedure for attachment to the proceeding.
I would like to quote Mr. Knight on this issue from the end of the transcript.
l One last thing.
This just sudden /lyoccurred I
to me and I just want to say it for the record.
We have a pile here.
It's somewhere between 18 and 24 inches width of procedures that were provided, with regard to condition 6.
It is impractical to attach it to the transcript.
I gp
- - M do believe, however, that all other paper that has exchanged hands here today, the staff ques-tions, and some portions of the PG&E res'ponses that were given to us by slides or in writing, none have been made available to the reporter.
Is my understanding correct?
p $$$
The exception being these frocedures, and due to their size and quantity, I think it's impractical to attack $it to the transcript.
And I presume that any party who required further understanding of what was contained there could request that information.
466 On May 22, I told Mr. Knight that I needed the materials to prepare my analysis.
Project Manager Hans Scherling said to put the specifics of my request in writing.
On my behalf, Mr. Devine forwarded the request.
(Exhibit 1).
Since that time, Mr. Devine or I have called Mr. Scherling at least a dozen times about these documents.
We still have not been supplied with the information.
It appears that we will not receive it before the commissioners vote on the license for Diablo.
That vote will be based on an incomplete record that is unverifiable for the public, due to the fact I and the interventors have not been able to check the basis for PG&E's denials.
In other words, the NRC has said that we'll have to accept the results on blind faith.
I didn't know that was legal under the Atomic Energy Act.
I find it appalling that the same i
tactics are being used by the NRC as were used by PG&E to prevent my attempts to verify that the plant is safe before it operates.
After learning of the obstruction faced by Mr. Yin, however', at least I know I'm in good company.
The NRC gave the public the same runaround in reviewing the public record that it gave Mr.
Yin in reviewing the evidence, gP gy g
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NS 4 4 Last December 8, Mr. Bishop of Region V told me that the NRC does not have -- (1) sufficient manpower or (2) financial resources to ensure that one plant much less all those under construction are being built in compliance with the Codes, NRC M Regulatory Guides, or Final Safety Analysis Report (FSAR) fequire-ments.
He said that the NRC depends on concerned workers such as myself to let them know when a plant is being built incorrectly.
It is a terrible day when the allegers who risk their careers by raising these questions are prevented by the NRC from following through with the issue until it has been resolved.
In PG&E letter No. DCL-84-223 dated June 11, 1984, pages 1-6, Mr. Shipley states, Warping normal and warping shear stresses were present in only a few cases due to the preponderance of angle'and tube ' steel shapes that do not exhibit the warping phenomena."
(Emph::i Odded.)
ees Theemphasizedstatementisrfdiculous.
Any second-year civil engineering student who has taken a basic Strength of f
dM Materials course kncws that all shape,g undergo warping when subjected to torsional load.
The only accurate, professionally responsible statement which can be made is that closed sections exhibit a greater resistance to warping, because their torsional strength is greater than an open section.
(
The fact that angle steel (open section) is included in PG&E's response with with tube steel (closed section) creates two questions:
(1)
How were angles checked for torsion effects? and 1
(2)
Were angles reviewed for warping normal and warping shear stresses?
This information has not been made available to me.
On May 9, 1984, the NRC peer. review team received it.
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The July 2, 1984 transcript states on page 9 at line 16,
"[T]he review of small bore rigids and snubbers adjacent to anchors will include all cases other than will exclude decouple branch connections for piping qualified by span rules."
(Emphasis added).
l It is significant to know why these were omitted, if they exist.
I believe the argument by PG&E for omitting them was that 444 the span rule piping AQ( as defined was at temperatures less than 200" F.
This would leave an additional question:
Why would a snubber need to be used on such a low temperature line?
If snubbers do exist they should not have been excluded from the review.
On page 10 at line 11, Mr. Shipley announced completion of "the review of all the small bore analyzed pipe supports, a~nalyzed by camp..
.:.. __, as required by icenseh'ndition1andno o
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$65 physical modifications have resulted from these additional reviews."
1 l
PG&E and the staff have made it. impossible to provide specific responses, since I do not have access to any of these documents.
Therefore, neither has fulfilled its burden of proof to demonstrate the validity. of Mr. Shipley's assertion and the quality of the f
review process.
There are serious reasons not to take him on faith at face value.
Mr. Yin commented in April that the review would take six to nine months.
Instead, PG&E tried to redo in weeks the work that originally took two years.
n paga i f. i i r.a 24, Dr. Cloud states, "The next point is that there were several revisions of the seismic spectrum, the thermal operating modes and an aWSly revision of methodology -when the I
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project was formed.
This led to the piping and pipe supports being revised several times here in the design process.
The IDVP,
yfM came to the conclusion that this was a strength of the design."
On page 25 at line 12, he~added, "It was repeatedly found that outdated inputs and minor mathematical and modeling errors wer~e updated and subsequent revisions -(inaudible)' given~ calculation."
I must say I find it unbelievable to offer credit for not performing the design work correctly the first time it is even more unbelievable that Dr. Cloud can say that the errors were updated in subsequent revisions, since not only I but Mr. Yin and the rest of the staff have admitted the large number of errors found during this last review.
The NRC found even more errors in i
their audit of this last review.
I question whether or not the serious errors were found in light of the fact the NRC has only audited 21 of the 357 supports, of which only 191 were complete at the time of the audit.
On page 26, line 6, Mr. Vollmer informed Dr. Cloud, "It wasn't clear from what you just said exactly how you made the judgment that something generic was a deficiency."
On line 13 Dr. Cloud responded that 6 66 in order for [ps] to conclude that
[we] had a generic deficiency, it required that [we]
find the same item, either on a cost basis or at least in the number of, in the number of i
repeated. instances and that we, we felt that we must conclude that it would be possible if that item were represented in the, the degree that, that it appeared to be that, that it would be possible for licensing criteria to be exceeded.
Mr. Vollmer queried on line 25, "So, that the deficiency would not likely lead to a violation of licensing criteria, then
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it wouldn't necessarily be pursued?- Ong page 27, line 5, Dr.
Cloud responded further:
"If, in our judgment, we concluded that, that based upon the reviews that we made, if we felt that there was no chance that licensing criteria would be exceeded, then as far as we were concerned, it was essentially irrelevant unless, there was some (inaudible) consideration where it coupled with something else and we carefully considered that."
(Emphasis added).
I include this narrative between Mr. Vollmer and Dr. Cloud for several reasons:
(1)
I agree with Mr. Vollmer's first comment on page 26, line 6, that it wasn't clear, nor is it clear If aten d what pd means after Dr. Cloud's evasive answers.
(2)
Following 646 this narrative I had more questions than before.
I wondered who the (we) and (us) were to which Dr. Cloud referred and what the (somethina else) was at the end of this statement.
Dr. Cloud's subsequent statements on page 28, line 12, illustrate the lack of independence in the IDVP better than any allegation.
We, in the, in the, in describing a given question as an error, we, we, we learned, I
we learned very quickly early on in the, in the progress of this program to be very careful about how we characterized the given issue.
It is obvious that PG&E controlled completely this portion of the " Independent" Design Verification Program.
How much more of it did PG&E control, for example at Teledyne, Westinghouse, and other IDVP contractors.
On page 65 at line 23, Mr. Skidmore states that "a quality problem report tracking system was developed in the quality 6 63
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assurance department to address timely closure of quality assurance findings and departmental and contractor quality (inaudible) reports.
This system developed to demonstrate the (inaudible) commitments made previously to the NRC prioritizes (the) outstanding quality problem reports and establishes estimated completion dates."
on j
page 65 at line 12, he added, "To date we've identified some 6,000 quality commitments to be (inaudible).."
(Emphasis added).
On page 78,. line 11, Mr. Vollmer asked, "I was wondering exactly, if you could give me an idea of what type of commitments there are.
It sounds like a rather large number."
On line 20, Mr. Skidmore answered, "They're commitments that we've made through various licensing submittals.over the years, j
commitments made in the transcript of hearings, FSAR Chapter 17."
j At line 24 he added, "These are line items."
On page 19 at line 3, Mr. Vollmer asks, "Not quality attributes 486 or something like that? Thefearelineitemsthatyouneedto (5MPhMSIS AbDD) i meet the requirements of the plant."V 2r. Skidmore's response?
t 466
" Yeah."
This narrative is quite important, to say the least.
It appears that the NRC has granted extensions on the time to meet their requirements.
These requirements are necessary for the plant to be safe.
An example of one such item is on page 5 of the Draft SSER for License Condition 2.C. (ll), Item I, given to the ACRS l
on July 6, 1984.
"A re-analysis will be performed for those supports, whete the effects of self-weight excitations has not been considered.
PGEE committed to complete this program by October 1, 1984."
(Emphasis added).
Another example even more serious is on page 3 of the same document, License Condition 2.C
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$D.3 (11), item 4.
"To resolve this concern, PG&E proposed to undertake a program to qualify the piping system supports for loads obtained with the gaps ignored in the thermal analyses.
This program will
- be undertaken only for the piping $Qth service above 200* F during normal and upset conditions. 3The program will be completed 60 i
by the end of the first refueling outage and may result in some support modifications."
I would like to say that my allegations include the use of gaps incorrectly to pass failing systems (both pipe and pipe supports).
Mr. Yin found this to be true and his findings i
became one of the seven licensing items the Commissioners required the review to look into.
Now the NRC Par even recommended waiving
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that licensing requirement for a year which the plant operates, Can ]ses l
before requiring PG&E to comply.
imagine 6,000 line items such as the one above?
In reality there are many thousand more repairs needed than 4000.
Each line item represents many individual def9* led 1
problems.
The one line item sle&eyetr above on gaps covers 11 piping dAS systems, involving many supports.
i On page 4 of the proposed SSER for Licensing Condition 2.C. (11),
j item 1, I found one reason for Mr. Yin's comments on the NRC review.
't During the audit of 21 supports out of 191 which had been reviewed, i
the NRC found " deficiencies due to lack of proper documentation,"
and " deficiencies related to some calculational errors were identified regarding assumptions of member properties and geometry l
input in STRUDL computer code."
(Emphasis added).
These are the same things they were supposed to be looking for in,this review.
The things they were to catch.
I am troubled by the NRC's use of the word assumption above.
No assumptions should be made as to M
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member properties or geometry.
These must be hard, cold factual i
data, not assumptions.
This casts serious doubt as to what PG&E has not done during this review, as well as the staff's standards.
On page 1 under Background and Origin of Concerns to License Condition 2.C.(ll), items 2 and 3, it is stated that "the Diablo Canyon Plant was initially designed for a 0.2 g peak ground acceleration seismic event which was called the Design Earthquake (DE) and a 0.4 g peak ground acceleration seismic event which was called the Double Design Earthquake (DDE). "
(Emphasis added).
"The proximity of'the Hosgri fault resulted in the site's peak ground acceleration for a postulated seismic event increasing to the 0.75 g level."
(Emphasis added).
1 I find it absurd for any engineer to believe that the original
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supperts which were designed with a 1.4 Factor of Safety (F.S.) Dead i
Load (D.L.) and 1.7 F.S. Live Load to be able to take twice the l
load and the additional stresses from warping (up to 50% of the j
allowable amount) without more modification than PG&E has made on Unit I since the 1981 verification program began.
For any competent, objective engineer, the question would not be whether I
the modifications are necessary, but how and where. I myself, who I
worked at the plant, finditevenmorerfdiculoustobelievethe M
changes were#necessary.
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At the ACRS subcommittee meeting on Wednesday, July 11, 1984, I i
requested that Mr. Voller follow up on several issues for which l
the discussion had jogged my memory.
These were first discussed on December 8, 1983, at the Diablo site, with the NRC wtaff team, then headed by Mr. Bishop of Region V, which included Mr. Yin.
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des should note these particular issues were not assigned to Mr. Yin for review.
To my knowledge, due to the lack of a meeting transcript, I inadvertently failed to raise them again in affidavits.
I requested Mr. Vollmer to ask PG&E several questions about these issues, at the meeting.
Therefore, I will put the allegations in writing.
The first of my concerns involves the placement of rigid supports near elbows.
Two cases come to mind --
(1)
A branch line being subjected to ax'ial buckling, or tensile stress.
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From the NRC and PG&E documents, it is impossible to tell if NRC or PG&E looked.at this potential problem.
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fo 4ff I am concerned about the 15,000 feet of pipe qualified.soty by OOS span rule.
(Reference page 5 of IDVP re-evaluation in proposed i
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(d5 SSER).
This appears to have been overlooked.
The second concern is placement through the construction tolerance of six inches for the location of a pipe support on dL piping.
This factor must be considered in combination with special support configurationf.
But the pipe stress group had SWAwh ddS separated the two Saetors when we received them at the pipe 6M support group.
As a result, they improperly were considered in isolation.
I am aware of this happening at least once because I corrected it:
cd57 Wau.ce_3 y, L -
ci iJ Greution Y or Y or Z.
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This pair of supports are usually shown on the stress isometric drawings as being at the same location.
It is a special case where the pipe must be seismically restrained but allowed to move for thermal reasons.
It is possible by using the six-inch construction tolerance to place the snubber (see above) on the op-posite side of the rigid restraint.
As a result, when the pipe moves, the snubber clamp binds on the rigid restraint, either causing the restraint to fail or the pipe to overstress.
This is also applica-ble to a spring-can and a rigid restraint in the lateral direction.
r Issues which the ACRS discussed on Friday, July 13, 1984, involve the radial expansion of large bore lines.
There is a construction tolerance of 1/16-inch on a side with a 1/6-inch tol-erance, for a total gap of 3/16-inch maximum.
Many of the large bore lines, such as Main Steam, Residual Heat Removal (RHR), and Reactor Coolant System (RCS), which are subjected to high pressure and temperature, will expand more than the 3/16-inch maximum (zero-
$0$
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inch possible) and bind up in the support, rather than slide M
through as intended.
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The approximate expansion of this line can be one inch.
This
$46 line will grow in length and diameter roughly at the same uniform rate.
It will therefore lock up at approximately only one inch of the axial growth.
It still has three inches more to go.
I estimated four inches movement as a conservative assumption in Figure 4, because at the meeting on Friday Mr. Shipley admitted movements of six inches in some lines.
Two possibilities are likely.
thepipestrongerthafthesupport-supportfails, (1)
(2) as support stronger than pipe - pipe fails.
Continuing with the ACRS subcommittee on Wednesday, July ll, 1984, I agree with Mr. Yin concerning the adequacy of the stress walkdown.
It is only partly acceptable.
The typical industry practice, including Bechtel, is to decide what the clearance should be between the lines in the walked-down and stationery items, such as building steel, and non-stationery items, such as other pipe.
Usually this clearance is one-inch, two-inch, three-inch, etc.
It is determined based on the thermal and seismic envelope of move-ments which the line can deflect.
The program at Diablo only accounted for the thermal clearance.
It did not include the seismic clearance.
Checking thermal clearance was important to ensure that the pipe and supports function and move as designed, but so far no program has checked the lateral clearance necessary to prevent the
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e pipes from slapping against each other and being damaged during an earthquake.
I also agree with Mr. Yin in that the sample of PSDTC's (Pipe Support Design Tolerance Clarification) reviewed by the NRC team was inadequate.
It was so inadequate that it was pathetic.
It only comprised 4 3 out of the 15,000 PSTDC's written.
Further, PG&E only reviewed 2,000 of these 15,000 Quick Fixes.
See page seven, License Condition 2.C.(ll), item 6.
PG&E's tiny sample was illegal.
It is impossible on the basis of screening 2,000 Quick Fixes out of 15,000 and then only looking at 43 in-depth, to determine that "all design changes and modifications have been resolved and documented in an appro priate manner," as theoretically is now required for the license AG in action item 6.
On page 5 of the proposed SSER for Licensing Condition 2.C.
(11), item 7, it is stateg " rovided this minimum radius is present, the American Welding Society Dl.1 requirement regarding the size of the weld effective throat in flare bevel welds to steel tubing as sp.ecified by PG&E on their drawings is acceptable."
Dr. Hartzman, who gave this dissertation, and I discussed this statement and I found out that he had only read my affidavits and the responses of PG&E.
He had been told that the piece of tube which we had obtained was only one 20-foot pice, and that no more existed.
I asked him if he had looked at the purchase order or traced tnis steel back to the documentation, using the -
number which was on the steel.
He said no.
PG&E's reassurance is not persuasive, in light of its state-d?d?$
' I M
h ment the last time I made the allegation.
In PG&E letter No.
DCL-84-083 (February 29, 1984), response to Question 2a " Tube Steel Radius", PG&E stated,# Pullman purchase orders indicate that e5 material shall be domestically manufactured, as required by the j
contract.
PG&E has researched all structural steel mill certifi-i cates to determine origin and have confirmed that no Japanese tube steel has been received.
A simple purchase of a small amount (3,000 feet) of Canadian tube steel has been used; however, the manufacturing was in accordance with U.S. requirements."
]
Recently a worker at the plant who was aware of my allega-tions that foreign steel was being used at Diablo despite contract
[
and FSAR requirements for domestic steel, brought me a piece of i
fn*MP l
plate which had a 4+ewee on it.
A few days later he brought me 4 66 the documentation on this steel, including a, letter dated March 11, 1983, from PG&E to Foley Co. and Pullman Power Products.
This letter states that "whenever domestic supplies cannot meet i
PGEE's material quality requirements or required delivery date, PG&E will, upon approved request, provide authorization to (Seeattachmentf)N purchase foreign material."
The documentation on the plate indicates that 50 sheets of 1" X 4' X 8' carbon steel was ordered.
Field requisition -
purchase order - receiving report states under H6, " materials shall be domestically manufactured."- The Mill Test Certificate 4
. indicates that the steel originally came from the Pohang Iron and Steel Co., Ltd., located at "5 Dong Chon Dong Pohang City Kyeong Sang 2d Do Kore", which I think means South Korea.
The inspection report indicates the vendor Ducommun steel and that item A was on i
hold due to a foreign manufacturer, and that.a DR (Discrepancy
\\
dd8 i
W Report) is in frogress.
The DR simply states that the vendor has 446 failed to comply with the special requirements of our purchase AMML order.
No 2r 551 ;..J for its.use is indicated; however, on the inspection report a note says " Item A released per memo from s
PG&E 2-7-84."
The documentation is stamped Class I material.
i I question why this was not reported to the NRC on February 29, 1984.
The documentation for this steel is enclosed as Attachment f.
The steel will be submitted at a later date fol-6 69 lowing a metaIurgical examination.
In closing I would like to say for myself and all the allegers requested by GAP, that we regret having to boycott l
further interviews with the NRC technical staff.
At this time i
we have not seen sufficient evidence that the NRC personnel are 4
committed to doing their jobs.
We all have been betrayed by the NRC.
Ecmc cf us uho were anonymous have had our identities divulged to PG&E.
We have been threatened and fired for doing E
our jobs and attempting to ensure the public's safety by pursuing t
the construction and design deficiencies existing at Diablo.
See 1
the text of an open letter we published last Friday in the San Luis Obispo newspaper, enclosed as Attachment We will continue any discussions which are possible with Mr.
Yin, the Office of Investigation or the Department of Justice.
j 1
If Mr. Yin decides the process is honest enough to merit his return, l
then we will reconsider as well.
I wnnid like to finish the discussio,n which.was started last December 8, 1983, at Diablo with the Office of Investigation, i
l before it opened a case.
At that time there was a lot of interest l
- in the destruction of documents at Diablo but no action.
That was 4e ~)
16 -
\\
nearly eight months ago.
This was.not an issue that could be resolved by the technical staff.
It involved potentially criminal acts during the last " reform", by the same organizations whose statements of fact again are being accepted at face value by the NRC.
I have read the above~16-page affidavit, and it is true, accurate and complete to the best of my knowledge and belief.
/
Md Charles Stokes DISTRICT OF COLbMBIA Su ribed nd sw rn to be%se metids lh_b
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su g gyg g My Commicion Expires E "/ _"
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GOVERNMENT ACCOUNTABILITY PROJECT institute for Pohcy Studies 1901 Que Street. N.W.. Washington. D.C. 20009 (202)234 9382 May 31, 1984 Mr. Hans Schierling U.S. Nuclear Regulatory Commission Washington, D.C.
Dear Mr. Schierling:
Enclosed are copies of two.af.fidavits which were promised at our May 21, 1984 meeting.
Please excuse my 4
oversight in not meeting you at the airport before your departure from San Luis Obispo, California.
Also enclosed.is the list of additional reference materials which Mr. Stokes needs to complete his evalu-ation of the licensee's corrective action on Mr. Yin's findings.
As you will recall, the May 9.,
1984 transcript identifies this information, which is part of the trans-i cript and available upon public request.
As you will also recall, on May 21 Mr. Stokes requested the data.
]
You asked that he put the specifics in writing.
We de-layed sending this list until a legal intern forwarded additional materials available at the Public Document 3
Room, which reduced the number of items in the attached enclosure.
Third, have you obtained approval from co nsel for Mr. Stokes to review necessary non-public materials under Mr. Yin's supervision, as he offered at the May 21 meetina?
You will recall that Mr. Yin explained that he has fol-lowed this procedure successfu1Jy in other chses.
Fur-ther, the Office of Investigations already has made an identical agreement for GAP witnesses at Diablo Canyon.
As a result, I assume that counsel's approval is a for-mality.
But it should be obtained before Mr. Yin's re-i turn, so that Mr. Stokes can complete his research.
1 Fourth, the witness from May 21 wants to receive and review his transcript as soon as possible.
He also requests the opportunity to swear under oath to the ac-curacy of his statements and to receive a copy of his transcript.
Finally, I have nearly completed extensive pre-3 parations with the May 21 witness,ixes that raise sign,ficant and several others 4
to organize data on Unit I Quick F engineering concerns.
On May 21 this.was Mr. Vollmer's request.
The uitnecses request the opportunity to meet
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with Mr. Yin and any other team members to continue the disclosures.
On May 21 you estimated that the team would return in approximately two weeks.
I will call your of-fice tomorrow to follow up on this letter.
Sine rely, Thomas Devine Legal Director Enclosures 1
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i DOCUMENTS LIST REFERENCED AT MAY 9, 1984 NRC-PG&E MEETING The May9, 1984 transcript pages where these doc-ments are referenced are in parentheses after each item.
1.
Criterion M-9.
(p.52) 2.
Project engineering construction procedure PEI-12.
(p.201) 3.
"Last three procedures written for control of DP's within engineering." (p.217) 4.
ESD-223. (p.218) 5.
GC-PI-17. (p.220) 6.
I-37. (p.220) 7.
I-40.
(p. 220) 8.
D-16. (p.220) 9.
All of the procedures referenced by Mr. Tressler on
- p. 227 for items already referenced in #1-8 above.
10.
The 19-21 inches of procedures referenced by Mr.
Knight pages 247-248, except for items already referenced in #1-9 above.
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l PAczric aAs Ann mLmeraza courAn-r
@6W3 245 peARRET STREET. SAN FRANCISCO.CAUFORNIA $4104. foll) 783-4211. TwX 930 372 4687 March 11, 1983
-HOWARD P. FOLEY COMPANY
. Attention:
A..E. Moses PULLMAN POWR PRd' DUCTS '
A8tention:
J. W. Ryan The following is clarification of the Pacific Gas an,d Eler.tric's Foreign Supplier and Material curement Policy.
Whenever domestic suppliers cannot meet P E E's material quality requiremants
(
or required delivery dates. PEE will, upon approved request, provide A.
authorizatien t: purchase foreign material. ~
When critical schedules, dictate, verbal authorization can be obtained for purchases of foreign material from the responsible Resident Engineer. These requests should be routed through the site Expediting Department so that the appropriate innediate action is obtained.
This authorization must be followed with a written request and the appropriate PEE authorized signattere obtained.
This action complies with the required PEE policy to justify and document all purchases of foreign material If there are.any further. questions regarding this subject, please contact the responsible Resident Engineer.
l Reply requested: No j
KA011ver:k1h cc:
J. Arnold M. Mores F. Russell l
W. Coley R. McInerney J. Hoch C. Rood K. Oliver J. Shryock E. Meyer:
P. Heilman J. Manning n.
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PULLMAN POWER PRODUCTS REO.-
7177 12-20-83
"** 2 o f 2 c/o Pacific Gas & Electric Co.
NO. F - 7177-14423 couer trRus snarPlwc iERMs Diablo Canyon Power Plant JOs cost cooE:
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compliance with this Purel)ase Order or specifics tions.
i3 CertiTicate of Compliance 'shall be traceable to our Purchase Order and Ilese No.
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codition, a copy shall accompany each shipment.
Q.A. Dept.
In C
Any nonconformance to the requirement of the Purchase Order will be considered just cause for return of meterials without cost to buyer.
f6 Haterials shall be dossestid' lly saanufactured.
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FitlO REQUl!! TION - PURCHASE ORhtR - RttflYlNC REPORY Joe NJ.
DATE SM E T SHIPPlNG ADDRESS: PU E EN POWER PRODU qS b8~
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as5 COUNT TERMS SHIPPING IERMS Diablo Canyon PnWer Plant R.R.-
Joe COST CODE:
SURCONTRACT FOB L.A.
7 Miles North of A'vila Beach, C _[3424,
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DATE DRDERED:
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- 1. Vendor Quality Assurance Program -
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l L OS ANGELES l3/41 l l l 8 Tatus.gto DAYS. NET 30 DAYS DUCOMMUN METALS '"*',$E INDICAHO. ^- 55 P.O. BOX 2117 T.A. p.o.s.smer:No point sAME As acetrt:No wu LOS ANGELES, CA. 90051 ATTN: ACCOUNTS PAYABLE I 4890 SO. E ALAMEDA ST.' atwi toi. . LOS ANGELES, CA. 90054 . file 2.'f9656 LOS ANGELES, CA. 90074
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TEST NO. YlELO STRENGTH TENSILE STRENGTH ELONG HARDNESS BEND A 26 B7836 G3911 46600 93500 61. 85.HRB T PASS PA' 60.[ 85.HR / T PASS PA l 85.HRB 92000 45800 [ 92000 / 57 77760* G4761 43800 l 46800 93500 56.- 86.HRB
Pullmas Povver Psoducts CIIANGE "A" fillB R[tul51IIIll - FURCHAst ORDER - RittlfillC RE FORI see no. past sus e e snerrs= aoone ss: PULI.HAN PONER PRODUCTS 3/13/84 aa.1 6f I c/o Pacific Gas s, Elect.ric Co. 7177 14423 M-I-7177 a.a.- isisco : eraus suirrian Iia C ~ ~ ~~~ Diablo Canyon Power Plant Jaa 'a5' m : ""a" a 7 M i le s Nor t.li o f Avila Beacli,_.CA_9 3 4 2.4.. via \\ ~ vaanoa: Ducommon T wa si 4 r ne si s or e n e n e s s ". 4890 S. Alameda Street P.O. Box 3f'.7 g Los Angeles, CA 90051 l,{,! Avila Deaclu CA 93424 I ,,r, l '. : l Pa8 unii ..a i e (ttistal nao/6. otSta'r'80" m , This change is written to reflect an increase in/pl dict hs t-
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8 b= %# 8 8R&=4 %=7 8 8 8 y/7 0 DUCOMMUN METALS CO. ~ LSE AN!ELES DIV!St%N SAN DIEGO CFFICE art 2ONA DIVISION 30150. 20 n ST P*.CENat AZ t$Os MON.O M u A 2513 CAulNO DE.L As0 SOUTH. SAN DIEGO. CA 32100 I t002) 275 *471 Giel 297 6s10 014)477 3141 9 BERKELEY DIVISION KENT DIVISION ) 2300 7m STREET. SEmKELEY. CA 94710 a212 SO.196tn STREET. KENT WA 90031 (415) es1. taro (20s) 872-7230 .Y PULLPAN POWER PRODS-C/O P G E E DIAEL'O CNYN PWR PL 7 MILES NORTH OF AVILA BEACH AVILA BEACH, CALIF 93424 mMTrTY CUSToutA 3 OACEA NuuSEM PACxsNG LAST & INv04c1 NuuSER TYPE Of AEPOAT g $5,35" LBS F7177-14423 004118 02 ACTUAL rumoocwTa sPEemcATa
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TEST REPORT y/$ DUCOMMUN METALS CO. LOS ANGELES DIVISION SAN DIEGO OFFICE ARIZONA OlVISION l 08 "' I ' 3 2$15 CAumo OE AC SCI.fm. SAN DatGO. cA Br108 act so. 2ean sT. p cEM43. AZ 6308 tect) 275-6471 4714) 297 4 410 (714) 477 3141 BERKELEY DIYlSION KENT DIVISION 8212 so. tsein STREET. KENT WA 90031 2580 7tn STREET. BERREEv. CA 94710 (41s) 8451a20 (20s) 872 7230 ) PULLMAN POWER PRODS C/O P G S E DI'AELO CNYN PWR PL 7 MILES NORTH OF AVILA BEACH AVILA BEACH, CALIF 93424 WTITV CusTCMER 3 CaCEA NuugER PACxmo ust 4 mvosCE NuwsEA TYPE OF AEPORT 5,350 Les F7177-14423 004118 02 ACTUAL EALAA CESCRIPTaoM sPECl#ICATom P9COUCmG WILL " HOT ROLLED CAP. BON STEEL PLATE ASTM-A36 POHANG IRON & STEFL CO .-3 6 5_0 PCS 48 X 96 ' ROM 10 PLATES MECHANICAL PROPERTIES s no=G m s acc.AasA nAacNess seno caAm set uACao wicao mT.OnA= uT muussa TsunER Tausett sTara.am Ps vi Lo sTnagcTn Ps KGMMZ KGMM Test coanosion '77128 45.4 29.1 26
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TEST REPORT yp[$ e DUCOMMUN METALS CO. LOS ANGELE3 DIVISION SAN DIEGO OFFICE ARl2DNA DIVISION 20130. 2em sT. eNCENiz. A2 tsc34
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' :t. as sa.g' l.lf W Pullman Pcw;r Prcducts C:rporcticn $\\ 3 SCtI e ? i FIELD WAREHOUSE REQUl21 TION av5??.u.Z -_? @.- LINE SPEC. 2 - k ~ b 2 O DATE C M 1SO NO. DETAILDWG.NO 8DN 3 ._ DDR. NO. ~ ACT. NO. 9 \\ 7 9 ~ PAGE NO. I OF l cue.ut Tv l gggyg;TY C NT gg ITEM DESCRIPTION P.O. NO. ITE O HEAT NO. hk i F\\141 R.'S \\" x 4" 4 W/Olt /dd_wout /{//E; I _ gig L.. C S-A 3 C-j l /-. - PW lcu~ss. T-. %R, Iv7A72i2. AL. ..V.h ..,_b.Y_ _ _ . t 's .. A - t r. FOREMEN Q A A*8 AOVED f. Enc..t w.cwAL ( Y ~ a 1 FILLio st COPt -CA COPY - WA AEHOU*.C COPY - ACLD ENGINEEPING OCPY - 4
e w_ L San Luis Obispo Telegraph-Tribune, July 13, 1984 i _AN OPEN LETTER TO OUR FELLOW WORKERS AT DIABLO CANYON AND THE COMMUNITY SAN LUIS OBISPO: We are Diablo Canyon workers (both former and present) who view our jobs seriously, obeyed the law and are paying too big a price for it. We signed on at Diablo to do a' job but we ran into several problems. We are mostly. in Quality Control and engineering (some call us whistleblowers, others call us allegaters). As " persons performing q.a. functions," federal law (10 CFR 50 Appendix B) requires us to have " sufficient organizational freedom to identify quality problems; to initiate, recommend, or provide solutions, and to verify implementation of solutions"... that is the law. That is what we have to do if we are doing our jobs right. There are people who have tried to keep us from doing our jobs. Instead of congratulations, here is a list of some of our rewards for trying to make Diablo safe to operate. 1. Transfers to meaningless positions when PG8E or one of the contractors didn't like our DCNs (Discrepancy Condition Notices) and Hold Tags. 2. Laid-off if we tried to keep the operations to code. 3. Fired if we didn't sign of f something that wasn't up to code. 4 Slashed tires if someone in the craft resented their work not being acct.;ted. 5 Water and other things dropped on us if we asked embarrassing questions. Everyone at Diablo should be able to be proud... the Owners, the Crafts, the NRC. We are the ones whose job it is to make sure everyone can be proud. i The challenges and responsibilities of our jobs are as dear to us as they are-to most employees at the plant. We responded to the best of our ability. When there were problems, we voiced our concerns through proper internal channels and we voiced them in professional ways. Our signatures on the Quality Control Documents are our professional stamps of approval. We refuse to turn a blind eye to possible problems. We don't always know the answers but we have the right and the Duty to ask questions and see those questions through to their resolution. We are the first line of defense against accidents and we cannot afford even a little accident at Diablo. If the design i is good, then the pride and the professionalism of the Craft, the Engineers and the Inspectors is what is going to make this a quality job. When many of our concerns about construction were bypassed and the work " accepted as is", we took our concerns to the contractors' Quality Assurance Management, and then to the QA Management for the Owner, and finally to the NRC. All alon Their main concerns were for the " paperwork". g the way, we were rebuffed. .. it had to be right... but the problems in the field didn't seem to get their attention. NORE
y q Finally, some concerned citizens listened to us. They helped us get the attention of the NRC and PG&E. It is costing a lot of money and is taking a lot of time. A acorrective action" program is being implemented to address some of the issues we have raised. There are more to be addressed and we hope they will be. As quality-oriented craftsmen, engineers, inspectors and auditors, we want to see our professions survive and prosper properly and safely in any industry we serve. We live next to this plant. We know some of our fellow workers and ex-workers at Diablo do not understand our motives... Ours are no different than theirs: We want to do our jobs and do them well. Quality in one's work speaks for itself. Our diligence has benefitted all workers at the plant. The plant will be safer and the improvements documented. Politics should not play a part in the construction of Diablo. All of us who are sending this letter to you are professionals interested in doing a professional job. Being pro-nuclear or anti-nuclear is irrelevant and insulting. We are there to do a good job and to assure compliance with the Codes and Regulations necessary for the safe construction and operation of the plant. This letter comes to you unsigned at this time because of the many ramifica-tions to our lives when some of our identities have become known or suspected. If you would like further information or a formal presentation, call or write: Consumers Organized for Defense of Energy Safety P.O. Box 1664 San Luis Obispo, California 93406 Phone: 544-7295 or 543-9445 It is now more important than ever before that a hearing be held in San Luis Obispo so that the workers' allegatic1s mentioned above may be { heard before licensing. Write or call: Congressman Morris Udall Interior and Insular Affairs Committee 1324 Longworth HOB Washington, DC 20515 Phone: 202/224-3121 asking for this hearing. ,.,.n-,-- - - ~ ~, - + -,, ~ - - - -., -
h,. ,.~L.- I - Exhibit 3 GOVERNMENT ACCOUNTADILITY PROJECT Institute for Policy Studies 1901 Que Street. N.W., Washington, D.C. 20009 (202)234 9382 l July 10, 1984 Mr. Lewis W. Shollenberger Regional Counsel Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 i
Dear Mr. Shollenberger:
i Mr. Parks has communicated responses from six out of seven potential participants in the Diablo Canyon plant tour. After hear-ing the terms of fered by Region V, all six witnesses indicated their refusal to participate in any Region V plant tour of Diablo Canyon under any groundrules. Mr. Parks did convince the witnesses, however, to particpate in a plant tour controlled by Mr. Isa Yin. The stated that if Mr. Yin were responsible for the,whistleblowers tour, there would not be any preconditions for their particpation. They are con fida - * 'h*' 'ngistics could be worked out with him in good = a ;' f aith. I am confident that Mr. Yin would agree to participate, since he previously has suggested that whistleblowers should take him on a plant tour af ter a future series of interviews. Unfortunately, Mr. Vollmer of the Office of Nuclear Reactor Regulation (:NRR) views with witnesses.has not allowed Mr. Yin to conduct further inter-Hopefully, you can clear up this obstruction to Region V's stated goals 'of finding and correcting any remaining safety problems at Diablo Canyon. The six whistleblowers essentially offered a common reason for their refusal to participate in any plant tours sponsored by Region V. They are not willing to risk their careers or otherwise cooperate with a coverup. They have sound reasons not to trust Region V's stated goals. First, at the April 13 criticality vote, Region V Administrator Jack Martin's reassurances to the Commission contradicted the " Problem Description" written less than 48 hours before by his inspector Dennis Kirsch. As you know, the Office of Inspector and Auditor (OIA) is investigatina whether Mr. Martin made false and misleading statements to the Commissioners in reporting the results of the plant tour. -~
h PCg3 Two I ~ Second, the whistleblowers are puzzled that Region V refuses to take modest steps that would prevent the new tour from repeating the j controvers.ies of the last one. The witnesses had requested that -- (1) the ensuing NRC report on the plant tour include photographs of the hardware problems identified, and (2) the report include observa-tions recorded by the NRC inspector on-the-spot to confirm the condi-tion of the hardware. The whistleblowers whom GAP represents made these requests for one reason -- to produce an accurate record of what they pointed out to Region V, free from controversy. On behalf of Region V, you refused. Instead, you offered the whistIeblowers still another ride .on the dog and pony show. No thanks. Sincerely, ,r \\J LAM Thomas Devine h k -{ ]2 4. l t e 0 0 ~. - - -,. .r-y ,a-.
) g am... - Exhibit 4 ? AFFIDAVIT My name is Thomas Devine. I am the legal director of the Government Accountability Project (GAP). This affidavit is submitted to fill several holes in the public record concerning (1) the resignf! tion of Nuclear Regulatory Ccmmission (NRC) inspector Isa Yin from the peer review team assessing the Diablo Canyon nuclear power plant; and (2) proceedings by a subcommittee of the Advisory Committee on Reactor Safety (ACRS) on the peer review team's report. The former issue is relevant to determine the adequacy and integrity of the peer review program, both within the NRC team and within the NRC management. The latter issue is relevant to determine whether the ACRS is an appropriate body to draw conclusions on issues raised by Mr. Yin's dissent. I. EVENTS SURROUNDING GAP DISCLOSURE OF YIN RESIGNATION 1. On Monday, June 25, I telephoned Mr. Yin at his office, in an attmept to schedule appointments for witnesses who would only present their evidence if Mr. Yin participated in the l sessions. At that time, he told me he was about to submit his resignation from the Diablo Canyon case, because management in ( the Office of Nuclear Reactor Regulation (NRR) had asked him to compromise his integrity. He was about to meet with the Region III administrator o,n the issue, however, and instructed me to call back in the morning. 2. I spoke with Mr. Yin the following morning and took nearly all the notes that were contained in my July 11, 1984 affidavit. The call is referenced in the affidavit as having occurred in the evening. I made that change at Mr. Yin's direction when he later TO
3 s confirmed *%$9154 the accuracy of my draft' statement. It was the only inaccuracy he had suggested. The timing error by Mr. Yin and myself was a good faith mistake, because we did have an evening conversation around the same time. Upon further reflection, however, I can pinpoint the referenced discussion in the morning, because I had to excuse myself. temporarily from an interview at the Office of Inspector and Auditor (OIA) to follow Mr. Yin's instruction on the proper time to' return his call. 3. After disenrssing the problem, GAP staff members reached a policy consensus that we should first seek Mr. Yin's return to the case, so that'significant evidence Trom GAP clients would be disclosed an:1 proherly reviewed. We decided that this approach was far preferable to creating a scandal. If we could not obtain* the necessary organizational freedom for Mr. Yin to do the job, go public with the information. ) only t * ?"1A wa l 10 4. IinformoriMr.Yinofourflannedeffortstoseekhis j return to the job; he had not requested any assistance. When I told him of GAP's initiative, ha' thanked me. He said he could l only return to finish the job if he were freed from interference by NRR. t' l 5. Frism Thursday, June 28 through Thursday, July 5, Ms. Billie Garde of GAP and I att W ted'ho work within the system at i r the NRC. EitherMs.GardeorIspokewjthNRCofficialsWilliam Dircks, Executive Director fot Operations: Harold Denton, head of ,,$ ) {hasis+d ~ p fo emp certain points: (1) NRR; and Richard Vo11mdr of NRh What happened.to Mr. Yin' was unacceptable! (2) We were not calling at Mr. Yin's request; it was at' GAP'r,'i itiative. (3) Mr. Yin was the only shred of credibility left on;the staff for whistle 8 l(, 7
1 d -3 79 blowers. (4) We wanted to convince the NRC to lot its system work, rather than to attack it. Top NRC managemont received repeated notice that our goal was for Mr. Yin to receive sufficient organi-zationalfroodomfromschedulingpressures)hathecouldrevios q all necessary evidence, and that he would agroo to return to the caso. Top NRC staff management also roccived repeated notice that GAP would attack the system if management didn't lot it work. OnJuly5,Mr.Vollfdh informod mo that he would agroo to another California trip where the whistleblowers could talk to anyono else on the poor review team except Mr. Yin. I repeated those terms back to Mr. Vollmer and confirmed that it was his decision not to permit Mr. Yin to speak further with whistleblowers. 6. As one of the stops to follow up on this convorsation, I wroto a draft affidavit from my notes of conversations when Mr. Yin revealad his concerns. I took this action, because it was clear that further discussions woro futile; NRC management had barred the witnensos from the only inspector in whom they had confidence. That evening I road tho affidavit to Mr. Yin in Ohio, where he was on assignment. He confirmed the accuracy but roquanted that I nond it to his offico in Chicago beforo making any legal filing. He explained that the proper approach would be for him to review its accuracy at work and show the draft affidavit to hib regional administrator James Koppler. I agrood and offered to doloto anything that was inaccurato or that ho felt could hurt his carcor. 7. On Monday, July 9, at 5:25 p.m., after informing me that ho and Mr. Koppler had reviewod the draft affidavit, Mr. Yin asked metochangoonowor[,from" morning"to"ovaning",andrecalled
-~ ~, ~ TD the evening conversation. As discussed above, I mistakenly agreed to the change. I asked Mr. Yin several times if there were any other language that should be changed, and he said no. 8. I was neve'r aware during any conversation that Mr. Yin had been drinking, nor did he ever mention having had a drink. I only contact'ed Mr. Yin after hours when -he was out on assignment during normal iorking hours. In each instance, I began by asking if it were too late-or an inconvenient time to call. 9. GAP has not played any games with the government on this issue.. Unfortunately, the same cannot be said for the NRC. We made every attempt to work within the NRC system before attacking it. Unfortunately, top NRC rdanagement apparently made a decision 1D that it was preferable to be criticized for obstructing Mr. Yin,d44tk than to let him see the evidence. This type of high-level, inten-tional coverup is most disillusioning and already has significantly affected public confidence in the integrity of the NRC. II. ACRS SUBC05D1ITTEE DELIBERATIONS On Wednesday, July 12, after the court reporter left the room, the ACRS subcommittee centinued with a discussion that was not transcribed. 'The contents are highly significant to assess l whether the ACRS is an appropriate choice to judge Mr. Yin's professional dissent. Many topics were discussed, but the following are;part cularly' relevant. The firct thp'ic of' discussion was whE her to permit Mr. L ' 10. l Yin to speak at the full ACRs meeting oni.Filday. Subcommittee x members were concerned that<no'one could'p'eedict what Mr. Yin 's .- s wou'ld say..They expressed concern that he was ev'en' more'" polarized" T,0 ~ 3 ,s a w
t, TO than the last time and had said he did not " trust" the staff. [ The subcommittee chair suggested that the group summarize Mr. Yin's dissent in writing, and conclude that "after careful review etc. etc. we did not find it persuasive." Another member caution-ed that endorsing Mr. Yin's concerns would be the same as saying there had been "a massive conspiracy by the NRC to cover up." While he would not say that, he was afraid that others would think the subcommittee was part of it if Mr. Yin were not permitted to speak. The group decided to give Mr. Yin around 15 minutes to summarize his points.- Then a subcommittee member asked what would happen if Mr. Yin wouldn't come. The chair responded that they l could have Mr. Yin ordered to appear on Friday. This discussion raises questions whether the ACRS subcommittee was more interested in public appearances than public safety. 1 . tb 11. The subcommittee did not dpscuss the specifics of Mr. Yin's dissent, the peer review team's defenses, or Pacific Gas and Electric's (PG&E) defenses. One participant even suggested that the questioning of PG&E that day had been inappropriate. He said that it was not appropriate for a committee of their " stature" to be " nitpicking" about " nuts and bolts". This 02 # perspective suggests that the subcommittee sees not find it appropriate to examine the details behind the general conclusions 4 in the conflict between Mr. Yin's position and Mr. Vollmer's whether the job should be considered done. Mr. Yin's point is that the details reveal bad symptoms that must be investigated ~ further. As a result, the subcommittee's unwillingness to make decisions based on the specifics disqualifies the ACRS from any meaningful role as judge of the dissent. O
T4) i 12. Another participant stated that Mr. Yin's problem appeared to be that the breadth of his investigation was sharply r0 limited by Mr. Volfer. Either he or another member parentheti-cally asked how Mr. Yin could be expected to find the smoking gun if it was in a locked drawer and he wasn't allowed to have the key. The subcommittee chair emphasized that any issus like that were not part of their responsibility. This suggests that the Commission must still institute a response to determine whether Mr. Vollmer improperly obstructed Mr. Yin from reviewing necessary information. 13. A participant said that he had not seen any smoking guns, but there were a number of problems and he had to wonder if it were not the tip of the iceburg. Among other responses, the subcommittee chair said the problem was that Diablo Canyon had been looked at too much. He thought that the problems the i NRC found and made them fix at Diablo Canyon probably exist at least ten times that level at other plants. His conclusion was, i "You don't find them if you don't look." Another subcommittee member wondered what they would find if they looked at Brown's Ferry. His question was met with general laughter. Another subcommittee member wondered what would happen if they looked at Indian Point. There was even more laughter. Soon after, the subcommittee unanimously agreed that Mr. Yin's concerns should not' preclude licensing. This discussion suggests that the ACRS subcommittee does not want to look beyond the surface at Diablo i Canyon, because there might be more violations of law. This perspective disqualifies the ACRS subcommittee.from any_further role at Diablo Canyon.
i -7_ T8 P 14. At the July 11 full ACRS meeting, in my public comments l I mistakenly criticized the staff for permitting PG&E to conduct l a sample review on a licensing action item, when a 100% review l l was required. In fact, PGSE had performed the full review. This error must be corrected immediately by withdrawing the criticism.W [_ m Isnm&. M.1% Thomas Devine GISTRICT OF COLbMBIA
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.0 ptc <. g w w. w.: g ) u 4, o, UNITED STATES Exhibit 5 E,*n h NUCLEAR REGULATORY COMMISSION U ' Q{.,'/ Js wasmtacion. o. c. :osa 3 e .(.. .f.bl - f e 9 - V.. ). t;ih / 2 %,......f NOV 24 561 Docket No. 50-158 Construction Permit No. CPPR-88 EA 82-12 Cincinnati Gas and Elect.ric Company ATTN: Mr. W. H. Dickhoner President 139 fest 4th Street Cincinnati, CH 4b201 Gentiemen: This refers to the investiaation conducted by Recien III during tre period Janucry 12.c ]ct:ter 9, ;El, of con:.truction at.tivities at the W: 'i. Z iT. e r Neciitar Feuer Station. The details of that investigation are otscribed in k Reg on III investigation report Nc. 50-358/81-13. The viciations descriced in Aptencix A t; this letter are cross referenced to that recort in accordanct with A,.cerdix B to this letter. The insesti;ction was initiated as a esult of allegations made :o the M?.C Dy a Quality Co..trn; Inspector wns formerly worMd at the Zirace sfte red by the Gcserr cnt.4cccJnt?.0ility Dr0 ject of the Institute for Dolicy Studies (a non-cever-nt-2 sycy; an der.alf i f '4. Thens-cppl.icat2. The -esui i cf the c r C. . m.icnie revn=1 : wicts.c.rcad brseedy r. p y-e cualitt. h5 sur:... e. % : c.. c :. b ;cShcEd cy nuCerou3 exam 0les of nonCc?DiianCE Witn t%Eive of tne eigmaen c'4e-ent criteria for a cuality assurance progrca as set forth in 10 CFR 50, Append'x B. The cause of Ine breckde.c was~ycur failure to exercise adec:. ate c..rsight and control of your principal centractors to.com you had delegated the work cf establishir.g and executing quality assurance progra 5. 'ce thereby failed to fulfill ycur vital rescensibility as desc-itec in Criterio, I of 10 CCR 50, Ap end;x 2, to assere the execution of a cuality assurance progru. The pctential safety ccncern cf your quality assurance progra.? OrM:ccm was dbcussec during an enforcement conference a. cur Region 111 cffice in Glen Eliyn, Illinois, on August 5, 1981, attended by you and me.:.btrs of your staff and tne NRC Region III staff. Two of tae violations (Items A and B of Appendix A of this letter) are of particular concern to us because of the very essential role they play i; the executicn of an effective cuality assurance orogram. These two violations relate to false records and to harassment / intimidation of quality contrcl inspectcrs. With regard to fa!se records, the exacples we identified raise serious questions as to the a:curacj cf quclity records at the site. Ou'r concern in this area ~ served as a majcr fccter in requiring the concuct of a confirmation program to be completed by you to furnish evidence of plant quality. CERTIF!EO "AI!.
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' _~... - ~ :. ; :n.
1 1. F l. Cincinnati Gas and Electric 2-Company Because the NRC inspection program is a sampling program, the importance of accurate quality records cannot be overemphasized. Accordingly, we have addressed this matter as a separate violation and assessed a separate civil l i penalty for it. 4 1 With regard to harassment / intimidation of quality control inspectors, we have also addressed tais matter as a separate violation and assessed a separate civil l penalty for it. We' determined that your construction contractor took some action to stop the water dousing of quality control inspectors; however, those actions did not stop the activity. Harassment / intimidation of quality control inspectors is clearly a barrier to effective implementation of a quality assurance prcgraa and results in loss of the organizational independence described in Criterion I of 10 CFR 50, Appendix B. The importance of this matter is reflected in the recent amendment (Public Law 96-295, June 30, 1980) to the Atomic Energy Act of 1954, which added Section 235 relating to protection of nuclear inspectors such as your quality control inspectors. ? The impact of the identified quality assurance deficiencies on the actual construction has yet to be determined. Limited independent neasurements were performed by the NP.C in selected areas of concern in an attempt to characterize the actual safety significance of these deficiencies. Although a few problems j requiring corrective acticn were identified (i.e., four unacceptably installeo pipe hangers), the majority of the NRC independent measurements did nct dis-close h:rdware proclems. Ho.::ver, recognizing that significant construction deficiencies could Pave resulted from the cuality assurance problems identified during t h 9 r-ig.ti:n, the NRC has requirec the establishment of a cocpre-i hensive quality confirmation program to determine the quality of plant systems important to nuclear safety. The NRC will confirm the adequacy of the program i and may make acditiona'. independent verifications. Deficiencies identified by these programs will require resolution prior to issuance of an Operating License. Notwithstanding the fact that serious construction deficiencies have not been identified, in order to emphasize the need for licensees to have complete and accurate records, to maintain a work atmosphere where quality assurance persennel are not harassed or intimidated, and to assure implementation of an effective quality assurance program which identifies and corrects construction e deficiencies, we propose to impose civil penalties in the cumulative amount of 1 ~ Two Hundred Thousand Dollars for the matters in the Notice of Violation. We expect that this penalty will result in an adequate deterrent against future ~ similar violations by you and other licensees'of plants under construction. Some of the examples in the Notice of Violation occurred subsequent to the issuance of the revised enforcement policy and some prior to that time. In j arriving at the amount of the proposed civil penalties we have exercised dis-cretion, considered changes in the enforcement policy and considered the amount-of the civil penalties that have been issued to licensees of other plants under i - construction as well as the numoer of examples found of each violation and 'when they occurred. We have for convenience ano clarity categorized the items in
- the Notice of Violatien at the Severity Levels described in accordance with the Interim Enforcement Policy puolisned in the Federal Reaister, 45 FR 66754 (October 7, 1980).
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s. ~ Cincinnati Gas and Electric 3-Company The results of this investiga. tion and our review of your 10 CFR 50, Appendix B, noncompliance history reveal an additional matter which is of significant concern to us. This matter concerns inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979 with thi-teen of the eighteen cifferent criteria of Appendix B to 10 CFR 50. During our Systematic Assessment of Licensee Performance review on December 16, 1980, we expressed concern with your relatively poor performance in this area. This poor history of compliance with 10 CFR 50, Appendix B, when considered with the recent findings of the investigation indicates that your corrective actions only addressed individual problems and not underlying programmatic causai facters. Conseq;ently, we request that you review your history of noncompliance with 10 CFR 50, Appendix B, for the past two years and in your response to this letter provide these steps you have taken to address and correct.tne uncerlying programmatic causal facters related to the noncompliances. You are required to respond to the Notice of Violation and in' preparing your response you should follow the instructions in Appendix A. You should give particular attention to those acticns designed to assure continuing cccpliance with NRC requirements. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforce-ment action is appropriate. In accercance with 'Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code cf :ederal Regulations, a copy of this letter and the c.vicsure will r.a w cte m w. %:C Public Document Rocm. The responses directed by this letter and the enclosed Appendix A are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, / '/ y C/<& M-RichardC.MYoung,frector Office ofrInspection and Enforcement J
Enclosures:
1. Appendix A - Notice of Violation and l Proposed Imposition of Civil Penalties l 2. Appendix B - Cross
References:
l Noncompliances to Report Details cc: See next page w ---n-
Cincinnati Gas and Electric 4-Company ec w/ enc 1: - E. A. Borgmann, Senior Vice President, Engineering Services and Electric Production J. R. Schott, Plant Superintendent DMB/Occument Contro! Desk (RIOS) Resident inspector, RIII Haroic W. Kchn, Power $iting Commission Citizens Against a' Radioactive Environment Helen W. Evans, State of Ohio Thomas Applegate Louis Clark. Director, GAP Institute for Policy Studies + 6 e e S (. "
o Appendix A NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES i Cincinnati Gas and Electric Company Docket No. 50-353 Km. H. Zimmer Nuclear Power Station Constructicn Permit No. CPPR-88 EA 82-12 As a result of the investigation conducted at the Wm. H. Zimmer Nuclear Power Station in Musccs, Ohio, on January 12 - October 9,1981, tne violations listeo below with multiple examples were identified. The numerous examples of the violations demonstrate your failure to exercise adequate oversight and control of your principal contractors, to whom you had delegated the work of estab-lishing and executing cuality assurance programs, and thereby fulfill your responsibility of assuring the effective execution of a quality assurance program. Your failure manifested itself in a widespread breakdown in the implementatien of your quality assurance program and caused the NRC to require an extensive quality confirmation program to provide confidence that safety-related structures, systems, and components will perform satisfactorily in service. Included in tne breakdown were findings we cy. side-be particu-larly disturbing relating to false records and haransc. nt a,.. ihtion of quality control inspectors. Because of the significance of not having complete and accurate records, not maintainirc a werk st 1oschere wnere cuality assurance personnel are not harasseu or inumicatec, and not assuring implementation of an effective quality assurance program which identifies and corrects construction defi-ciencies, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the Nuclear Regulatory Commission proposes to impose civil penaities pursucnt to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, and 10 CFR 2.205 in the amounts set forth for the violations listed below. A. 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality." Contrary to the above, records were identified that did not furnish evidence of activities affecting quality in that they were false. Examples of false records are as follows: 1. Isometric drawings, weld inspection records, or other records did not furnish evidence of tne actual piping components installed in the 11 pipelines in the diesel generator cooling water, starting air N and fuel oil systems, in that the heat numbers recorded on the drawings or weld inspection recc 's did not match the heat numbers or color coding marked on the re=pective components. The 11 pipe-lines were:
f ? Appendix A (Continued) 1DG28AB1 1DGCSAA3/4 IDG28AE1 1DG27AB1 1DGF6AA1/2' IDG25AC2 1DG01ABl IDGCSBA3/4 1DG11AA3 1DGF2AAl/2 1DGF6BA1/2 2. initiated as evicer. cec by the following:The Kaiser Mo he original entry for a report (CN-4309) initiated by a QC a. Inspector on January 7. 1981, relating to oeficient weld fit up was obiiteratec ey tne use of wnite correction fluio'and there was no ot:;er recora of this report in the Noncompliance Report (NR) system. b. The origir.a! entry far a recart (CM-5212) initiatsd by a CC Inspector on February 3, 1981, and relating to violation of a hold tag was ocliterated by the use of white correction fluid and there '.:as no other record of this report in the NR system. A repo: t (MRC-0001) initiated by a QC Insoector on February 11 c. 1981, r, elating to excessi/e weld weave was not assigned a number and there was no other record of tnis report in the NR system. 3. Written statet.Ents as to planned actions '.<hich '<.ere made to ju --- --- E-1661 (soiced 11/11/2C), E 1552 (ecided 11/1'f50), and E-2i65 (,oiced 6/30/80) were not gaven., KEN lH votsi D 12 4 U h*Codr N rf $ U f N A 5-t 4. Written statemer.ts relating to the availability of records which were made to justify voiding reports E-1777 (voided 4/30/79) and E-5108 (voided 6/20/80) were false. 5. voided (2/27/81) ard ccpies deleteo frcm the NR s direction of the Kaiser QA Manager. This is a Severity Level III violation (Supplement II). p-(Civil Penalty - 550,030). B. ' performing quality assurance functions shall have suff independence frca cost and schedule."izational freedom to iden ... organ-The Wm. H. Zimmer QA Manual, Section 1.2.3 describes QC Inspectors as members of QAD (Quality Assurance Division) and Section 1.2.4 states, in part, "QAD has been assigned sufficient... organizational freedom to identify quality problems..."
Appendix A (Continued) ~ -3~ \\ i Contrary to the above, QC Inspectors did not have sufficient to identify quality problems and were not sufficiently independ om from cost and schedule. QC Inspectors were: The results of interviews indicate that some ent visors; (b) not always(a) harassed by construction workers and super-The following are examples of insufficient freedom of QC including insufficient freedom from cost and schedule rs. between Summer 1978 and March 11, 1981: , which occurred 1. Five whe".-QC Inspectors interviewed executed ir the performance of inspection duties) by construction p ' o other QC Inspectors made similar statements. ersonnel. A QC Inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were re-assigned by QC management because of complaints by cons personnel. 3. Two QC Inspectors executed signed sworn statements whe claimed they had been harassed by being searched for y security personnel at the request of construction supervisor personnel. One other QC Inspector made a similar statement. 4 A QC Inspector executed a signed sworn statement wherein h claimed the QA Manager had threatened to fire him after con- ~ struction personnel ccmolained he had used a magnifying gla __.., ; aspect a weld when in fact he was using a mirror and either device was an acceptable tool. 5. A QC Inspector executed a signed sworn statement wherein claimed he was struck by a stream of water from a fire extin-guisher while performing an inspection. 6. A QC Inspector executed a signed sworn statement wherein h claimed he was threatened with booily harm by a construction person if he did not pass a weld. 7. A Lead QC Inspector executed a signed sworn statement wh claimed: e He was accused by the QA Manager for holding up a concre a. pour when in fact the delay was caused by the concrete trucks being late. b. \\ Construction management frequently approached QC Inspe and challenged their inspection findings and questioned thei judgement.
m c Appendix A (Continued) 4-not reject, and we are here to get this plant c. 1 8. cTaimed he was relieved of his inspection d tinued to submit legitimate nonconformance reports over constru tion mana hangers. gement objections for deficient welds on pipe support QC Inspectors to not write anything to make Kaise 9. A Or Inspector executed a signed sworn statement wherein he c' imed he was told by QA management to accept inspected items ist were unacceptable. (Civil Penalty -.is is a Severity Level III violation (Supplement II). 550,000). 10 CFR 50, Appendix B permits for nuclear po,wer plants to documentCriterion II requires ho with the requirements of Appendix B for all ac quality of safety related structures, systems, and components and implement that program in accordance with those documents contractors did not adequately document and assurance crogen to comply with the requirements of Appencix 5 as evider.ced uy tne following examples: 1. forming items shall be reviewed and accepted, or reworked in accordance with documented procedures.", repaired Kaiser Procedure QACMI G-4, " Nonconforming Material Centrol " provides detailed instructions for the review and disposition of reports (Nonconformance Reports) of nonconforming items. Contrary to the provisions of QACMI G-4, the sample of NRs re indicate significant deficiencies with the nonconformance r system in the areas of voiding of reports, not entering reports into the system, improper dispositioning of reports, and incomplet files. The deficiencies identified were as follows: perly voided in that records used to justify t a. not provide evidence necessary for proper voiding. voided 1/24/80, NR-E-2237 voided (NR-E-2233 12/19/79) 9 e ,-.-y
4 Appendix A (Contiiued) . b. weld had been erroneously closed (not er trative error. (NR-E-2996 closed 3/17/81) (ystem welds had heon incorrectly di c. s r NR-E-233G closed 11/13/80, NR-E-2596 closed 4/16/80) d. Eive~ reports had been voided by personnel other tha'n QA Manager. (CN-5122 voided 1/2/81. CH-5476 voideo 2 CN-5477 voided 2/27/81, CN-5479 voided 2/27/81, C 12/02/80) e items were removed from a NR without e. (NR-E-2456 voided 6/30/80) on. f. and/or copies of the reports had not bee Site Dccument Center: ~ CN-4389 CN-4930 CN-4957 CN-4931 CH-4958 CN-4955 CN-4S59 CN-4955 CN-5122 2. 10 :EC ;0 Aapendix B, Criterion XVI states, in part shall ce e,stablished to assure that conditions ad "f'easures such as... deviations... and nonconformance are promp and corrected." e The Wm. H. Zimmer QA Manual, Section 15.2.2 states responsible for identifying and reporting ncnconfernances in "HJK is receiving inspection, construction, or testing activities whi h are delegated te HJK Quality Assurance Procedures to ass c nonconforming items are conspicuously marked to prevent the inadvertent use or installation." AWS Code 01.1-1972, weld quality and address slag, weld profiles, blowhole n s for and undercut. , porosity, AISC, Seventh Edition (1969), Page 4.113 requires 1/2 inch radius for re entrant corners. minimum not identified and corrected: Contrary to the above, the fol ons were beams described in Item C.4 below: Based on en in a.
~ h Appendix A (Continued) (1) 4 veral,walds on nine beams did not conform with AWS t able slag, weld profiles, blowholes, porosit undercut. (2) Five beams did not conform with AISC recuirements that the re entrant corners were notched, creating potential stress risers, instead of being rounded with required radii. (3) Four beams, two of which had unacceptable welds as described in Item C.2.a:(1) above, did not conform with design document. design documents in that they were not b. Based on an inspection of about 100 cable tray hangers in the Cable Spreading Room, four did not conform with AWS D1.1 1972 requirements in that the welds contained unaccept-able slag, weld profiles, blowholes, porosity, and/or undercut. 3. 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to qua such as... deviations...and nonconformances are promptly identif and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetiti on." ""&ndur>, contractors 7ha,.;. 'ii. I:n.mer QA Manual, Section and subcontractor: could result in significant conditions adverse t ASME Code, Section 111-1971 in part, "...a gap of approximately 1/16 in. shall be provided between the end of the pipe and the bottom of the socket before welding." Articles NA-4130(a), NA-4420, NA-4510, NA-4442. Winter 1972 Addenda NA-4451, NS-4230, and NB-3661.5(b) require, in pa,rtNB-4122, inspections for pipe fitup, weld procedure in process t traceability, and welder qualifications..., weld filler metal nonconforming conditions that had not been co had not been taken to preclude their repetition:
w \\ ~.. 9 j Appendix A (Continued) Licensee records indicate that the socket engagement (fitup a. for more than 439 socket welds was not verified in with ASME Code, Section 111-1971 and the condition was not corrected in that the correctiveEd action was not commensurate with the ASME Code. date back to 1979. The welds b. Licensee records indicate that the in process inspections for more than 22 welds in the diesel generator cooling water, starting air, and fuel oil piping systenis were not performed by Kaiser in accordance with ASME Code. Section III-1971 Edition, Article NB-3661.5(b), et al., and the condition was not corrected in that the corrective action was not commensurate with the ASME Code. The welds date back to 1978. Five licensee QA audits (audit performed 8/8-9/[4 no c. number, and Audit Nos. 78/07, 78/09, 78/10, 80/04) of Sarga,t & Lundy identified repetitive problems concernin S&L not performing certain design calculations, reviews,g and verifications and action was not taken to preclude repetition. 4. shall be established for the identification and co materials... These measures shall assure that identification of the iu r ic m *,tained..." "H.J. Kaiser Company procedures provide that wit H. J. Kaiser Company jurisdiction the icentification of items vill be maintained by the method specified on the drawings as heat nu.-ber, cart number, serial number, or other approp,riate such This identificatien may be on the item or on records mcans. traceable to the item. out fabrication, erection, and installation.The identification is maint is maintained and usable in the operation and maintenance p The identification Contrary to the abcVe, based on an inspection by NRC inspectors located in the Blue Switchgear Room and th the identification of the material in nine of those beams maintained to enaole verification of quality. 5. shall be established to assure that applicable ments and the design basis...are translated into... drawings.. quire-The Wm. H. Zimmer FSAR, Section 8, provides the design basis for electrical cable separation that includes the following: e
~ Appendix A (Co.itinued) ~. Associated cables (Green / White, Blue / White, and Yellow / White from more than one Division cannot be routed in the same raceway. (FSAR Paragraph 8.3.1.13.2) Vertical separation of three feet or more must be maintained between cables from different Divisions. (FSAR Paragraph 8.3.1.11.2.1.d) Instrument the'same rac(eway with power and control cables. low-l 8.3.1.12.1.3) (FSAR Paragraph The Wm. H. Zimmer QA Manual, Section 3.3.2. states "Cox.pos i te... drawings are prepared, translating the design conce, pts into, layouts of structures, systems, and components necessary for the construction of the plant." Contrary to the above, as of March 1981, the FSAR design basis for electrical cable separation had not been translated into drawings and this resulted in the following cable installation deficiencies in the Cable Spreading Room: Associated Cable (Yellow / White No. RF05'_ for Division 1 a. was routed in the sar.e raceway)(two-inch conduit ano Cla Sleeve No. 79) as Associated Cable (Blue / White)_No. R Division 2. Also, Associated Cable No. RE053 was routed so that in places there was only h vertical separation of fcur inchee between it and esoles in Blue Trav No-2072C for Division 2. b. Instrument Cable IGreen) Ne. WS714_ and others for Di were routed in the same raceway (Tray Nc. 46388) as Asso-ciated Control Cables (Yellov/ Whit.e and Blue / White) for Divisions 1 and 2. This deficiency was due, in part, to a design which specified the installation of a Green Instrument Tray (No. 3094K1 inside a White Control Tray [No. 4G383). Many Ass'ociated Cables from all three Divisions were routed c. in the same raceway IWhite Tray Nn. Table (Graan/!/hi+=L No. TI816.(Blue /Ubi+=3,No. TI , and d. Associated Cables Division 1 were rou(Yellow / White) No. TI942 and 3_o. T1043 No. RK4627) as Associated Cables (Blue / White) No. TI80 Two. TI760 for Division 2. ~ ~ ~ Many Associated _ Cables (Yellow / White) for Division 1 were e. Associated Cables (Blue / White) for Division 2. routed i O J
Appendix A (Continued). 6. 10 CFR 50, Appendix B, Criterion III states, in part, " Design control measures shall be applied tc...the delineation of acceptance criteria for inspections and tests." The Wm. H. Zimmer QA Manual, Section 3.13.1 states, in part, " Design control measures also apply to delineation of acceptable criteria for inspections and tests." Weld acceptance criteria are required by the ASME Code, Section 111-1971 Edition and the AW3 01.1-1972 Code. Contrary to the above: The weld acceptance criteria used by H. J. Kaiser Company a. from July 1980 to January 1981 were not applied to weld inspections during that period in that the weld acceptance criteria for such items as the drywell support steel were deleted. b. The acceptance criteria for Vold 55H (isometric drawing PSK-1WS-32) performed on Service Water System Line No. 1WS17A18 by H. J. P.aiser Company in November 1979 were not applied in that they were designated as not applicable. 7. 10 CFR 50, Appendix B, Criterion XI states, in part, " Test results shall be evaluated to assure that test requirements have been satisfied." Tha km I'.mrer Q^. Manual, Section 11.1 states, in part, " Test programs to assure that essential components, systems, and struc-tures will perfora satisfactorily in service are planned and performed in accordance with written precedures and instructions at vendor shops and at the construction site." ASME Section III-1971 Edition, Winter 1972 Addenda, Aopendix IX, Paragraph IX-3334.4 stctes, in part, "The shim thickness shall ba selected so that the total thickness being radiographed under the penetrameter is the same as the total weld thickness..." M. W. Fellogg Co. (pipe manufacturer and agency performing the prefabricated pipe weld radiography in question) Radiographic Procedure No. ES-414, dated September 26, 1972, Paragraph 4.1.8, states, "Wherever required, shims shall be used to produce a total thickness under the penetrameter equal to the nominal thickness of the base metal plus the height of the crown or reinforcement ~" l Contrary to the above, the licensee's review of 187 radiographs did not assure that test requirements were satisfied in that the licensee failed to detect that the penetrameter shimming was insufficient to satisfy the requirements of M. W. Kellogg Procedure i
~ e Appendix A (Continued) - 10 No. ES-414 or the ASME Code. This deficiency was identified during ^ the NRC review of approximately 800 radiographs involving 206 pre-fabricated pipe welds in such systems as main steam, feedwater, and diesel generator support systems. 8. 10 CFR 50, Appendix B, Criterion III states, in part, "These measures [ design control] shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled...The design control measures shall provide for verifying or checking the adequacy of design." The Wm. H. Zimmer QA Manual, Section 3.4 states, in part, " Design reviews are conducted to assure that the appropriate cuality standards are specifled and included in design documents." The Wm. H. Zimmer QA Manual, Section 3.6 states, " Measures are established to assure that any deviations from the applicable standards are controlled." The Wm. H. Zimmer QA Manual, Section 3.11.2 states, in part, "At S&L, design verification reviews are performed...." The Wm. H. Zimmer ESAR Section 8.3.3.1.1 states that cable ampacity is based on IPCEA Publication No. P-46-426. An additional limita ' tion on cable a:pacity as stated in Secticn S.3.3.1.3 is tnat "the summation of the cross-sectional areas of the cables shall not G.i i.L tray usable cross-sectional area or two layers exceeu of cables, whichever is larger, but not to exceed 60?. of tne ~ cross-scctinal area in any care." AWS D1.1-1972 Code, Section 3.6.4, states, "For building and tubular structures, undercut shall be no more than 0.01 inch deep wnen its direction is transverse to primary tensile stress in the part the.t is undercut, nor more than 1/32 inch for all other situations." Contrary to the above: As of. March 1981, design control measures had not been a. established to assure that deviations from design conditions (quality standards) identified by Sargent & Lundy engineers were controlled. For example, Sargent & Lundy noted on a calculation sheet dated December 27, 1979, that the design thermal leading for two power cable _s (VC016 and VC073) in j Yellow Tray No. 1057A woulo allow the cables to be thermally l overloaded and no program existed to control those design deviatina<. y v 3 ,.y.-- --r,. ,w-
c ~ Appendix A (Continued) 11 - b. As of March 1981, design control measures had not been established by Sargent & Lundy to provide for verifying or checking the adequacy of the design for the thermal loading of power cable sleeves and the physical weight loading of I cable trays. As of March 1951, the cable ampacity design by Sargent & c. Lundy was not based on IPCEA P-46-426 and the FSAR limit on cross sectional area. d. As of March 1981, the design allowable undercut on cable tray hanger welds was not based on AWS D1.1-1972 Code (appro-priate quality standard). The design undercut was instead based on Sargent & Lundy Specification H-2713, Supplement 7, 4 Sargent & Lundy Standard EB-117, and H. J. Kaiser Procedure SPPM No. 4.6, " Visual Examination," Revision 8, Paragraph 5.2.9, ailowed up to 1/16 inch undercut. 9. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be estab-1 lished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity." i The Wm. H. Zimmer QA Manual, Section 10.1.2 states, in part, 1 " Inspections are performed in accordance with written precedures which include requirements for check lists and other. appropriate oo...;crtation of the inspections and tests performed." AWS D1.1-1972 Code, Section 3.10.1, requires work to be completed and accepted before painting. i Contrary to the above: As of March 19S1, a QC insper ion progrzm had not been estab-a. lished to require verification of separaticn of electrical cables routed free. the Cable Spreading Room to the Control Room. An example of a nonconforming condition that should have been identified by such a program was Blue Cables RIl03 i and_CM111_that had been routed into Tray Riser (Green) No. 3025A, which extended-from Tray (Blue) No. 2077A in the ~ Cable-Spreading Room.to the Control Room. b. The programs established'for in pencess and final inspections of welds on 180 cable tray hangers located in the Cable Spreading Room were not executed as required in the luiS Specifically, the final weld inspections 01.1-1972 Code. were made after the welds were~p,ai.nted (Galvanox). f 9 6 =m.- e .= .<---.y -e e ---.v+-
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c.7, t Appendix A (Continutd) ~ .[12-r 10. 10 CFR 50, Apl.endix B, Criterion V states, in part, " Activities i affecting qual'ty shall be prescribed by documented instructions, procedures, or hawings, of a type appropriate to the circumstances procedures, or drawings."and.shall be accomplished in accor The Wm. H. Zimmer QA Manual, Section 5. of the facility are accomplished in accordance with written instructio'ns, procedures, and drawings which prescribe acceptable methods of carrying out those activities." The Wm. H. Zimmer QA Manual, Section 3.12 states, in part, " changes... including field changes, are subject to design change control measures commensurate with those applied to the original design." Contrary to the above: Kaiser Procedure QACl1I G-14, "Surveill'ance Reports," (SR) was a. not appropriate to the circumstances in that it allowed in process nonconformances which constitute field changes to be dispositioned within 30 days without being subjected to the original design.to design control measures commen Examples of nonconformances so dispositioned were identified,in SRs F-2899, F-2903, and h. V.ci ct I'rscedure QACMI G-14 was not followed in that S F-2909, F-307n F-3071,_E:-3R2,.E-3073,F-307.4,E-3075. 'f-3076, L-3083. and F-7019 were not dispositioned within 1 30 days and were not transferred to Nonconformance Reports as required by Paragraph 5 of QACMI G-14. 11. 10 CFR 50, Apoendix B, Criterion VII scates, in part, "The 1 effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee...." The Wm. H. Zimmer QA Manual, Section 7.3.1 states, in part, "As part of the vendor selection process S&L makes an independent bid evaluation." evaluation of the bidders' QA program,s as a part of thei Contrary to the above, as of March 1981, neither the licensee nor designee (Sargent & Lundy) had assessed the effectiveness of the control of quality by vendors vho had supplied structural beams. Specifically, evaluations of the vendor (U.S. Steel , Supply,.EBI Steel e assurance programs for control of mill certMications andvchs structural beams were not performed. j 7
~. e Appendix A (Continued) 12. 10 CFR 50, Appendix B, Criterion XVII states, in part aff.ecting quality. records shall be maintained to furnish evidenc " Sufficient work performance, and... include closely related dat qualifications of personnel, procedures, and equipment." The Wm. H. Zimmer QA Manual, Section 17.1.4 states, in pa " Documentation of all performance surveillance includes p identification and qualification e date of performance, person or or,ganization monitoredprocedure, typ and corrective action if required.". , results Control Steel Erection Report, which was a g monitoring in process steel erection, did not identify closely related data such as weld procedure numbers, types of weld material, welder identification, and specific welds inspected 13. 10 CFR 50, Appendix B, Criterion XVIII states, in part cut to verify comoliance with all aspects of th "A com-program and to determine the effectiveness of the program "suranc The Wm. H. Zimmer QA Manual, Section 18.1 states audits of S&L, HJK...to verifyDivision conducts a com in part, "QA the quality assurance program." compliance with all aspects of QA Division did not perform an audit of the nonconformacce program. This is e Severity level II violation (Supplement II) (Civil Penalty - 5100,000). Company is hereby required to submit to this crc date of this Notice a written statement or explanation of the alleged violation: i lation if admitted; (3) the corrective steps which have be f results achieved; (4 further violations; a)nd (5) the date when full complia the corrective steps which will be taken to avoid ( and the Any statement or explanacion may incorporate by specific referenc giving page and paragraph numbers) the provisions of your qu e (e.g., tion program and your actions in response to our Immediate Acti April 8, 1981. i m-Consideration may be given to extending the response time - on Letter of for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitte~d under oath or affi rmation. i i i a r- ,e, a ,-+,--.-.-s
C App:ndix A (Continu d) 14 - - 2.201, Cincinnati Gas and Electric Company may of the civil penalties in whole or in part by a written ans Cincinnati Gas and Electric Company fail to answer within'the time spe Should this office will issue an Order imposing the civil penalties in the amcunt proposed above. Should Cincinnati Gas and Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) snow other reasons wny the penalties shoulo not be im-posed. such answer may request remission or mitigation of the answer in accordance with 10 CFR 2.205 should be set forth separately fro Any the statement or explanation in reply pursuant to 10 CFR 2.201 incorporate by specific reference (e.g., giving page and paragraph nu but may to avoid repetition. Cincinnati Gas and Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties. determined in accoraance with the applicable provis this matter may be referred to the Attorney General, and the penalties unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. FOR THE NUCLEAR REGULATORY COMMISSION / mr RichardC.Defocng,Difector Office of Insp ction and Enforcement Dated at Bethesda, Maryland this 24 day of November 1981 4 .e.
9 . =. //- / 2 10. I UNIYEDSTATESOFAMERICA 'fi E W " m m " " 3 NUCLEAR REGULATORY COMMISSION L'g,jEJE:. Exhibit 6 COMMISSIONERS: ~ Nunz[oJ.Palladino, Chairman 12 NG'l 12 P4 :50 5!ictor Gilinsky John F. Ahearne Thomas M. Roberts 21..... :. James K. Asselstine E - ". -n f'cy^" ) , SERVED NOV121982 In the Matter of ) ) CINCINNATI GAS & ELECTRIC COMPANY ) Docket No. 50-358 Construction Permit No. CPPR-88 (William H. Zimmer Nuclear EA 82-129 PowerStation) -) I ORDER TO SHOW CAUSE AND ORDER IMMEDIATELY SUSPENDING CONSTRUCTION (CLI-82-33) I. j The Cincinnati Gas and Electric Company (CG&E) holds-Construction Permit No. CPPR-88 which was issued by the Commission in 1972. The permit authorizes the ccnstruction of the William H. Zinner Nuclear Power Station Unit 1, a boiling water reactor to be used for the' commercial generation of i electric power. The Zimmer plant is located on tne licensee's site in Moscow, Ohio. A. Initial Ident*fic: tion of QA Problems In early 1981 the.NRC conducted an investigation into allegations made by present and former Zimmer site employees and by the Government Accounta-bility Prcject. The NRC investigation revealed a widespread breakdown in CG&E's management of the Zimmer project as evidenced by numerous examples of non-compliance wic t.,6;se sf the eighteen quality assurance Criteria of _@B1}14h M R ,,v--7% 2Pg. w-
s (
- c Appendix B to 10 CFR Part 50.
Consequently, CG&E paid a civil penalty of $200,000 for the failure to implement an acceptable quality assurance program, false quality assurance documents, and intimidation and harassment of quality control inspectors. (See Notice of Violation and Proposed Imposition of Civil Penalties, dated November 24,1981 and Investigation Report No. 50-358/81-13.) In addition CG&E agreed to take actions to correct / identi ied QA failures and prevent their recurrence and to determine quality of completed construction work. l l. Actions to Correct Identified QA Failures and Prevent Recurrence A meeting was conducted by Region III on March 31, 1981, and the utility I j agreed to implement tgn actions to correct quality assurance failures identified during the January - March 1981 investigation and to preclude their recurrence. These actions included: (1) increasing the-size and technical expertise of the CG&E QA organization; (2) taking action to assure independence and separation of,the QA/QC function performed by Kaiser from the l ccnstruction function; (3) conducting 1007, reinspections of the quality control (QC) inspections performed after that date by Kaiser and other con-tractors; (4) reviewing for adequacy, and revising as appropriate, all QC inspection procedures; (5) training QA/QC personnel on new and revised procedures; (6) reviewing for adequacy, and revising as appropriate, the procedures governing the identification, reporting, and resolution of deviations from codes and Final Safety Analysis Report (FSAR) statements; (7) reviewing for edequacy the procedures governing nonconformance - reporting and justifying the disposition of each voided nonconformance p -,.e- ,,..,n., .-n..,e ,-,n.n.
~ ' I report; (8) establishing an adequate program for control of QA and QC records; (9) performing a 100% review of all future surveillance and non-conformance reports writt'en by contractor personnel; and (10) reviewing and revising the CG&E audit program so that it included technical audits of construction work and more comprehensive and effective programmatic audits. These commitments were confirmed in an Immediate Action Letter to the licensee on April 8, 1981. 2. Actions to Determine Ouality of Completed Construction Work \\ Following the identification in 1981 of significant quality assurance problems and related management breakdowns, CG&E agreed to establish a com-prehensive program to,, determine the quality of the completed construction work. The Ouality Confirmation Program (QCP) was submitted to the NRC by the licensee on August 21, 1951. The QCP addressed problems identified by the investigation in the following areas: (1) structural steel; (2) weld quality; (3) trace-i ability of heat numbers on piping; (4) socket weld fitup; (5) radiographs; 4 (6) electrical cable separation; (7) nonconformance reports; (8) design t control and verification; (9) design document changes; (10) subcontractor-QA programs; and (11) audits. 3. Results of Actions Taken by the Licensee to Determine the Quality of Completed Construction Work t Many construction deficiencies have been identified by the licensee during the conduct of the QCP and other quality reviews and reported to
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l l 4-the NRC pursuant to 10 CFR 50.55(e) which could have been prevented or identified in a timely manner by the licensee and its contractors had ther.e l been a properly managed QA program. Major construction deficiencies identified to date by the quality reviews are listed in order of identification and include the following: delds performed using an unqualified welding procedure for welds greater 'l than 0.864 inches. Unauthorized stamping of fittings and use of "high-stress" stamps. ASME structural weld and welder qualification deficiencies. ~ Welds performed and welders not qualified for weld thickness range per ASME requirements. Approxir.ately 2400 feet'of small bore piping identified with questionable heat treatment. Walder qualifications with a substantial number of documentation discrepancies. Carbon steel weld rod may have been used for a portion of several stainless steel recirculation line welds. 9
,7 / ~ t t l ElectricalLeable tray installation and inspection deficiencies. Hangers installed for the control rod drive system are of indeterminate quality. Both weld and radiograph quality deficiencies for sacrificial shield ~ welds and radiograph deficiencies identified for the containment monorail and the ventilation-stack. Deficiencies in the.H. J. Kaiser procurement program for structural steel and other ma'terials. f Inadequate ~ des'ign control by Sargent & Lundy (architect engineer) for elect.rical separatione ,c Inadequate weld preparation prior to radiography (rlpples rot removed) which caused masking of discontinuities in so:ne welds. P,eactor control, reactor protection, and neutron monitoring panels, , including field,iastalled wiring do not, in some cases, conform to design drawings with regard to cable separation. /. - Inade'quate engagement of " gamma plugs'.' in large-bore piping and lack of heat number traceabilitf of the "gdrea plugs." (During radiography of a pipe weld, a gamma source is sometir.es inserted through a small j 4 e ..[. ,m,.
( ). hole in the side of the pipe. After radiography the hole is plugged to provide a pressure boundary.) Inadequate inspection program and installation procedures for " Nelson stud" installation for cable tray hangers. Concrete and steel coating program not in accordance with the QA iProgram and the Sargent & Lundy specification requirements. Design changes made to the Fire Protection System piping in the cable spreading room in 1979 were inadequately controlled. The Sargent & Lundy (architect engineer) dynamic stress analysis of small bore piping is questionable. Cable separation problem with regard to division separation between non-essential cables being bundled with essential cables of different. divisions. Pipe support installation procedures did not contain seismic clearance criteria between pipe supports and cable trays or conduit and associated supports as required by the specification. These deficiencies represent 'those which the staff considers most significant. There wire additional 10 CFR 50.55(e) reports made by the licensee and the licensee has identified a large number of e 4
,o s b i 17 ~ nonconformances (which could reflect" construction or other types of . - - s deficiencies). As of Septemter 30, 1982 the licensee's continuing quality i confirmationprogram}eviews ad identified approximately 4,200 nonconfonnances of which about 800 have been "dispositioned", i.e., the licensee had made a determination as to resolution. (Inspection Report No. 50-358/82-12, report pending.) The large number of noncomformance reports and the significance of the matters being identified corroborate the staff's 1981 finding of significant breakdown in the licensee's quality assurance program. \\ B. Findinas Subsecuent to Licensee Actions Taken to Correct 0A Failures and Prevent Recurrence Since the Indediate Action Letter was issued on April 8,1981 and quality assurance and management deficiencies were brought to the attention of the licensee, hardware and programmatic QA/QC problems have been identified by the NRC and the National Board of Boiler and Pressure Vessel Inspectors. These problems are discussed in the following paragraphs and indicate the licensee and the constructor are still having difficulty implementing satisfactory QA/QC programs: During'an inspectkon con'du' ted the latter part of 1981 and the early c partof1982(Inspecti6hsReportNo. 50-358/82-01, issued on June 24, 1982),three items'of noncompliance were identified. The findings con- ^- cerr:d (1) tije fe.ilure to clearly establish.and document the authorities 7 i 1 and duties of all QA Department. personnel, (2) the failure to provide i 4 -.LE-
( ! adequate certification of qualifications of all QA Departi. int personnel, s and-(3) the failure to provide adequate procedures. The licensee failed to adequately address the provisions of Regulatory Guide 1.58 (ANSI N45.2.6-1978) concerning personnel in the QA Department. Additionally, inadequately qualified personnel were reviewing and approving quality d proc 9 ures controlling electrical activities, which contained deficiencies. T Fur.thermore, as a result of the licensee reviews it was revealed that some weld ~ inspectors involved in the QCP Task I, Structural Steel, were not adequately certified and the task was stopped. The' task was restarted following upgrade of the-inspectors through training provided by additional certified weld inspectors. During an ;re.nmion conducted in March end April 1982 (Inspection Report No. 50-358/82-05, issued on July 1, 1982) two items of noncompliance were identified. The findings concerned the lack of implementai:fon and timeli-ness of co~rrective actions add the failure to adequately review and document potentially reportable matters. During an inspection conducted in Ap'ril, May, and June of 1982 (Inspection Report No. 50-358/82-06, issued on November 2,1982) two items of noncom-pliance were identified. The findings concerned (1) the performance of quality activities required.of the welding engineers by inadequately qualified clerks and. (2) the failure to _ perform required calibrations e + r .a
~ I .g. during a critical quality activity, Induction Heating Stress Improvement (INSI) program. A recent inspection conducted during June and July of 1982 (Inspection Report No. 50-358/82-10, report pending) identified a number of sign-ficant concerns. These concerns were discussed with the licensee on July 9, July 15, August 15, and October 19, 1982. Four significant items of concern (potential ite'ms of noncompliance) were identified: (1) the inadequate control and documentation of welder qualifications; (2) the failure to take corrective actions following the identification of inadequate records to support welder qualifications; (3) the unauthorized correction, supplementation, and alteration of quality records; and (4) the failure to follow procedures controlling weld filler metal control, logging and control of requests for information/ evaluation, and imposition of e reporting requirements'on contractors. The NRC findings concerning welder qualifications resulted in the requalification of approximately 100 active onsite welders and the need for the licensee to develop a program to evaluate the previous work of the welders whose qualifications were not adequately documented. An inspection was conducted following notificaticn of the Region III Office that a CG&E Stop Work Order (SWO) had been initiated on August 5, 1982, pertaining to Catalytic, Inc. (CI) activities in the area of the contr'ol rod drive system hangers and supports. CI is a contractor of the licensee performing construction work .--,n-,,
including rework activities identi ~ied by the QCP program. During this inspection conducted during August and September of 1982 (Inspection Report No. 50-358/82-13, report pending), significant concerns were identified regarding the implementation of CG&E's quality assurance program and its management program established to control and monitor the activities of Catalytic, Inc. (CI). Theconcernsinvolvedtheareasof(1)thedescriptionoforganization i and functional interfaces, (2) training of CI personnel, (3) design control measures, (4) procedure content and implementation, (5) document control, (6) inspection and surveillance activities, (7) nonconforming conditions, (8) corrective actions, (9) records, and (10) audits. The findings were discussed with the licensee an August 12, September 10 and 17, and October 13, 1982. As a result of the inspection findings and subsequent discussions with the licensee, Stop Work Orders were issued by the licensee, stopping all essential work by CI on'0ctober 11, 1982, pending resolution of the programmatic problems identified by the NRC and licensee reviews. The licensee has initiated Stop Work Orders in addition to those affecting CI due to inadequate quality assurance in the areas cf application of coatings (October 12,1982), electrical cable installa-tion (October 12,1982), and special process procedures (November 1, 1982). The Stop Work Orders involve ongoing activities. The Novem-ber 1,1982 Stop Work Order involved procedures not meeting require-ments notwithstanding that the procedures had been specifically 9 y . --------,,---i w--- my---
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I - reviewed by CG&E for adequacy subsequent to the issuance of the l April 8,1981 Immediate Action Letter. Additionally, during the week of October 10, 1982, the Authorized Nuclear Inspector (ANI) for the N-stamp holder (H. J. Kaiser) recalled ASME work packages then being used in the field because of the per-formance of ASME code work (hanger attachment removal and piping cutouts) was outside the approved QA Program procedures. The ASME code work was being controlled and perfonned utilizing an H. J. Kaiser administrative memo which bypassed the ANI's required involve-ment in the code activities. The NRC was apprised of the required l corrective actions during a meeting involving CG8E and H. J. Kaiser on October 15, 1982. The corrective actions taken aryd planned were considered acceptable by the Authorized Nuclear Inspector, e i The National Board of Boiler and Pressure Vessel Inspectors, at the request of the State of Ohio, have been onsite since March 1,1982. The National Board has issued three interim reports documenting { findings regarding ASME code activities. The Natio,nal Board findings include deficiencies in the following areas regarding on-going ASME code activities: design control, procurement, procedures, special processes, nonconforming conditions, and corrective action:. The findings are generally consistent with past and present NRC
- findings, i
f v .2c, _.,..
( > C. Rework Activities As a result of the information obtained from the licensee's reviews of plant quality, the licensee is proceeding, prior to completion of the relevant QCP tasks, to initiate rework activities. A major example of rework activities is the area of structural steel welding. The feinspection and rework of structural steel welds located in a number okareasoftheplanthavebeeninprocessforanumberofmonths. Approximately 70 percent of the structural welds are being reworked to make the welds acceptable. In the case of these welds, rework is being undertaken prior to the completion of the quality reviews to detemine the acceptability of all structural steel welds and beam / hanger P materials. The rework of these welds prematurely may result in the addition of new weld material over unacceptable weld material or beam / hanger materials. Following completion of the quality reviews unac-ceptable areas may require additional rework activities. This approach to rework activities indicates a lack of a comprehensive management program to address rework activities and the safety impact of those activities on the facility. III. The foregoing information indicates that:
- 1) the Zimmer facility has been constructed without an adequate quality assurance (QA) program to govern construction and to mo'nitor its quality, resulting in the construction of a facility which currently is of indeterminate quality;
- 2) substantial efforts are underway to determine the quality of past const'ruction activities and numerous construction deficiencies have been
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g identified and are continuing to be identified such that both ~ reanalysis and rework will be required to bring the facility into conformance with the application and regulatory standards on the basis of which the construction permit was originally issued; and 3) rework of deficiencies identified by the Quality Confirmation Program (QCP) has been undertaken prior to completion of other relevant QCP tasks and other reviews, resulting in the potential for additional reworking of the same item if j further deficiencies are found, as has been the case, by the quality reviews. Consequently, the NRC presently lacks reasonable assurance that the Zimer plant is being constructed in conformance with the terms s of its construction permit and 10 CFR Part 50, App ndix B, and that there is adequate management control over the Zimer project to. ensure that NRC requirements are being met. ~ The verificat~ ion of the facility's quality and appropriate actions t: :::- ::t I:ft:f r.cies in construction are of utmost importance to the public health and safety should the licensee receive a license to operate the facility. Moreover, the licensee must be in a position to assure that its construction activities have been properly carried out in accordance with Comission requirements, as the Comission inspectors are not able to personally verify every individual aspect of construction that may impact on safety. In view of the importance to safety of construction verification and corrective actions and the past pattern of quality assurance deficiencies, the Comission has concluded that safety-related construction, including rework activities, should be / suspended until there is reasonable assurance that future construction _ activities will be appropriately managed to' assure that rework activities and all other construction activities will be conducted in e
g i accordance with 10 CFR Part 50, Appendix B, and other Comission j requirements. The Comission has further determined that in light of the foregoing considerations the public health, safety and interest require suspension of construction, effective imediately pending fyrtherauthorization. IV. Accordingly, pursuant to sections 103, 1611, 182 and 186 of the Atomic Energy Act of 1954, as amended, and the Comission's regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORDERED THAT: i A. Effective immediately, safety-related construction activities, including rework of identified deficient construction, shall be suspended. B. The licensee shall show cause why safety-related constructicn l activities, including reworking activities, should.not remain ~ suspended until the 1,icensee: (1) Has obtained an independent review of its management of the Zimer project, including its quality assurance program and its quality verification program, to determine measures needed to ensure that construction of the Zimer plant can be completed in conformance with the Comission's regulations and construction permit. (a) The independent organization conducting this review shall be knowledgeable in QA/QC matters and nuclear plant construction and shall be acceptable to the Regional Administrator. The independent organization shall make
(. \\ recomendations to the licensee regarding necessary steps to ensure that the construction of the facility can be completed in conformance with the Comission's regulations and the construction permit. A copy of the independent organization's recomendations and all exchan~as of correspondence, including drafts, between the independent organization and CG&E shall be submitted to the Regional Administrator at the same time as they s are submitted to the licensee. In' making recomendations, the independent organization shall consider at a minimum the following alternatives for ma'n'agement of the Zimer project and shall weigh the E advantages and disadvantages of each alternative: p. Strengthening the present CG&E organization. 2. Creation of an organizational structure where the construction management of the project is conducted by an experienced outside organization reporting to the chief executive officer of CG&E. 3. Creation of an organizational structure where the quality assurance program is conducted by an I experienced outsioe organization reporting to the i chief executive officer of CG&E. l 4.. Creation of an organizational structure with both quality assurance and construction project management conducted by an experienced outside
k i i organization reporting to the chief executive / officer of CG&E. / (b) The licensee shall submit to the Regional Administrator the licensee's recomended course of action on the basis of this independent review. In evaluating the f T recomendations of the independent organization, the licensee shall address why it selected particular alternatives and rejected others., The licensee's recomendations and its schedule for implementation of those recommendations shall be subject to approval by the Regional Administrator. (2) Followiiig the Regional Administrator's approval in accordance with section IV B(1)(b), (a) Has submitted to the Regional Administrator an updated comprehensive plan to verify the quality of construction of the Zimdier facility and the Regional Administrator of NRC Region III has approved such plan. In preparing this updated comprehensive plan, the licensee shall review the ongoing Quality Confirmation Program to determine whether its scope and depth should be expanded in light of the hardware and programmatic problems identified to date. The updated plan shall include an audit by a qualified cutside organization, which did not perform the activities being audited, to verify the adequacy of the quality of construction; and ,y
(, 1 (b) Has submitted to the Regional Administrator a comprehen-sive plan, based on the results of the verification program, for the continuation of construction, including reworking activities, and the Regional Administrator has confirmed in writing that there is reasonable assurance that construction will proceed in an orderly manner and will be conducted in accordance with the requirements of the Commission's regulations and the Construction Permit No. CPPR-88. 1 (3) The Regional Administrator may relax all or part of the E
- r.ditir.s of section IV.B for resumption of specified construction activities, provided such activities can be conducted in accordance with the Comission's regulations and the provisions 6f the construction permit.
V. Within 25 days of the date of this order, the licensee may show cause why the actions described in section IV should not be ordered by filing a written answer under oath or affirmation that sets forth the matters of l fact and law on which the licensee relies. Asprovidedin10CFR2.202(d), the licensee may answer by consenting to the order proposed in section IV i of this order to show cause. Upon the licensee's consent, the terms of l I
j section IV.B of this order will become effective. Alternatively, the licensee may request a hearing on this order within 25 days after' the issuance of this order. Any request for a hearing or answer to this order shall be submitted to the Secretary, U.S. Nuclear Regulatory Cpmmission, Washington,D.C. 20555. A copy of the request or answer s' hall also be sent to the Director, Office of Inspection and Enforcement, and to the Executive Legal Director at the same address, and to the Regional Administrator, NRC Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137. A request for a hearing shall not stay the immediate effectiveness of section IV.A of this Order. If the licensee rWquests a hearing on this order, the Commission will issue ar ceder designating the time and place of hearing. If a hearing is held, the issues to be considered at such a hearing shall be whether the facts set forth in sections II and III of this order are true and whether' this order shouldie sustained. Commissioners Ahearne and Roberts dissent from this decision. Their dissenting views are attached. It is so ORDERED. For the Commission . -; g-,g ngang >, A f.i 'N,, pJ f John C. Hdyle Acting Secretary of the Commission s.' .d..*,.,..;; *
- Dated at Washington, D.C.
l this 12th day of November,1982. ---, ~~ r-- .v,
~ ( i D'ISSENTING VIEWS OF COMMISSIONER AHEARNE I agree with both the substance and the direction for change described in this order. However, I would have simply issued a show Cause Order and would not have made it imme-diately effective. \\ S 0 eo e O e 9 1 O g e 9 6 e, .--n---- .,.--n ~, - - -- - - - -. + -w
-_=- -_ - ( DISSENTING VIEW OF COMMISSIONER ROBERTS I disagree with the action taken by the Commission majority on several grounds. First, I believe the Comission's action in imediately . suspending construction at the Zimer facility is precipitous. Earlier this year, Cincinnati Gas and Electric Company (CG&E) made substantial changesinitsmanagementstructureinorde*rtomanagemoreeffectively construction activities and to monitor more carefully quality assurance pro, grams. Despite the fact that this new organizational structure is relatively untested, the Comission is now suspending effective imediately all construction and corrective actions at the site. Addi-tionally, the NRC Staff admits that CG&E's enhanced Quality Confirmation Program (QCP) and large quality control staff is effectively identifying existing constructio problems. Moreover, to the extent that actual cer.strletter, deficier.cies have been found, CG&E's management has demon-strated its willingness to take strong remedial actions by' issuing stop work orders in those areas where construction deficiencies 'have been found. In*a plant that is approximately 98 percent complete, the Commission is requiring the relatively few remaining construction activities and the o'ngoing corrective actions necessitated by the QCP to l-stop immediately while additional organizational changes are imple-mented. i Second, I believe the Comission's action does not comport with its own l practice. In Licensees Authorized to Possess... Special Nuclear Materials, CLI-77-3, 5 NRC 16, 20 (1977), the Comission said that "[alvailable.information must demonstrate the need for [such] emergency
2 ( actions and the insufficiency of less drastic measures" (emphasis added). See also Consumers Power Co. (Midland Plant, Units 1 & 2), CLI-73-38, 6 AEC 1082, 1083 (1973). I believe that, in this case, some of the less drastic alternstives proposed by the Staff would be adequate to resolve the problems at this faci,lity. For example, the Comission could send CG&E a letter indicating that at this time the Comission does not have sufficient infermation to conclude that Zimer has been constructed in substantial conformance with the construction permit. The Comission could request the provision of information on the part of CG&Ewhich,ifavailable,wouldprovidetheCommissjonwiththeneces-sary assurance. See 10 CFR 50.54(f). Third, in the absence of willfulness, the Commission may suspend con-struction effective linmediately in accordance with Section 9b of the b Admints:r:::ve Pr::edures Act and the Commission's regulations only if the Comission finds that the public health, safety, or interest re-quires such action. I do not believe that the concerns listed in the Commission's Order show that "the public health and safety requires imme-diate suspension of all construction and corrective actions at the Zimmer site. Indeed, Mr. James Keppler, the Region III Administrator, has stated that CG&E's QCP has been successful in identifying existing construction problems. Transeript of Public Meeting on the Status of Zimer, October 28, 1982 at 5. Additionally, most of the NRC inspection findings arising out of the QCP point to administrative or procedural deficiencies, rather.than to actual material or construction errors. I While the NRC's level of confidence in the ade'quacy of the plant [ _,m-_ - ~. - -
3 construction nas been reduced, it has not been shown by the NRC that problems exist which require imediate resolution to protect the public health and safety. Moreover, I do not believe this action is in the public interest. I I am also concerned that the Order has been approved without considera-i tion for the Applicant's proposal to correct management and c:nstruction f j problems. That proposal, outlined in a letter to the Comissioners J dat,ed November 10, 1982, contained all of the essential elements approved by this Order. Specifically, the proposal calls for obtaining new project management, stopping all rework on quality confirmation matters, and an independent third party review to confirm the acceptability of selected safety systems. In view of the voluntary agreement by CG&E to l such drastic measurer, I feel that this Order is primarily punitive in I natur* M % 1 H Liv to correct problems in the interest of public health and safety. J Finally, I disagree with the tomission's Order because of the potential t for delay inherent in this procedure. CG&E has an absolute right to a hearing on the Comission's Order. If CG&E avails itself of this right, f-then other " interested persons" will be entitled to demand a hearing. Once started, the hearing would be difficult to bring to an expeditious i close. Even if the Staff and CG&E were to reach agreement on the corrective actions to be taken, litigation of the requirements imposed by the Comission Order would continue. Consumers Power Co. (Midland Plant, Units 1&2),ALAB-315,3NRC101(1976); Dairyland Power Cooperative (LacrosseSoilingWaterReactor),L8P-81-7,13NRC257, 264-65(1981). i
.g ~ 6l. - [, 7 UNITED STATES gwc-.a {$ NUCLEAR REGULATORY COMMISSION Exhibit 7 wasMINGTON. D. C.20SSS J W o..< o June 13, 1984 DocketNo.50-38l, s Mr. J. M. Cain president & Chief Executive Officer Louisiana Power and Light Company 317 Baronne Street ~ New Orleans, Louisiana 70160
Dear Mr. Cain:
SUBJECT:
WATERFORD 3 REVIEW r On April 2,1984, the staff began an intenjive review effort lar ) conducted onsite, designed to complete those issues necessary ' staff to reach its licensing decision on Waterford Unit 3 ey !c. practices at the facility. covered a number of :reas including alle These issues As we indicated to you, tae staff wbuld promptly notify you of issues that could potentially affect the safe operation of tne plant. potential safety implications for which we requ j a ave It should be noted that they are being provided to your before rmation. staff publication of its SSER which will document its assessme significance of these and all of the other issues examined. in the enclosure represent an extensive staff audit of informati The issues to the plant.
- F on related i
As a result, you are rtauested to propose a program and schedule i detailed and thorough assessment of the concerns. or a of issuance of an operating license for Waterford 3. i eration should include and address the cause of each This program plan problems i on j i l l i
s ~ l 3 June 13, 1984 Mr. J. M. Cain Mr, R. S. Leddick i Vice President - Nuclear Operations Louisiana Powpr & Light Company i 142 Delaronde Street New Orleans, Louisiana 70174 W.-Malcolm Stevenson, Esq. Regional Administrator - Region IV U. 5. Nuclear Regulatory Comission Monroe & Leman 1432 Whitney Building - -6t1 Ryan Plaza Drive New Orleans, Louisiana 70130 Suite 1000 i Arlington, Texas 76012 Mr. E. Blake Carole H. Burstein, Esq. Shaw, Pittman, Potts and Trowbridge 445 Walnut Street 1800 M Street, NW Washington, DC 20036 New Orleans, Louisiana 70118 i; l Mr. Gary L. Groesch 2257 Eayou Road'- . New Orleans, Louisiana 70119 / Mr. F. J. Drumond ij Project Manager ' Nuclear Louis 4*na Power and Light Company g l ; 142 Deiaronde Street l Net: Orlet :, L:fi:hr.: 70174 i l Mr. K. W. Cook Nuclear Support and Licensing Manager Louisian Power & Light Company 142 Delarende Street New Orleans, Louisiana 70174 i 4 \\' Luke Fontana, Esq. 824 Esplanade Avenue New Orleans, Louisiana 70116 J( Stephen M. Irving, Esq. 535 North 6th Street l Baton Rouge, Louisiana 70802 Residpnt Inspector /Waterford NPS P. O. Box 822 Killona, Louisiana 70066 Mr. Jack Fsger Middle South Services, Inc. P. O. Box 61000 l New Orleans, Louisiana 70161 n. .-n--_,_
.s.-
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nnu.usunc .(' POTENTIAL SAFETY IMPLICATIONS 1. Inspection Personnel Issues As a part of the NRC staff's review, the credentials of quality assurance and quality control inspectors were examined. Included in this effort were the verification of previous job experience and qualifications and certification of personnel as inspectors. j The following items were found: _.2.5. - (1) NRC reviewed inspector certifications for 37 of the 100 Mercury QC inspectors, includ.ing certifications for all Level III personnel. Twelve inspecto.r certifications were found questionable due to insufficient education or experience. (2) The certification records of 38 Tompkins-Be'ckwith (T-B) QC inspectors were selected at random and reviewed.. Fourteen inspector certifications were found. questionable due to insu~ fficient education or experience.. i (3) A 30% sample by the staff of inscector certifications of the Mercury QC work force revealed t1at no verification of past employment was documented. A sample by the staff of inspector certifications of the Tompkins-Beckwith QC work foreg produced e'-*- - -"1 ts. i i The safety significance of these findings is that unqualified inspectors ma' have inspected :;afety-related systems, thereby rendering verification y i of the quality of these systems indeterminant. LP&L shall: (1) verify the professional credentials of 100% of the site QA/QC personnel, including supervisors and managers, inspectors founc unqualified, and (3[2) reinspect the work performed by J verify the proper certification of the remaining site QA/QC personnel to
- ANSI N45.2.6-1973.
i 2.' Missino N1 Instrument Line Documentation The staff examined the documentation concerning installation of safety-related N1 instrument lines. Part of that review dealt with the' situation where there is a change of design classification for systems, As a result of the staff review it was determined that comunications t l between LP&L and Ebasco prompted a revision to be written by Ebasco to an i LP&L drawing to clarify the " class break" for N1 instrument lines. The revision imposed ASME Class requirements for all installations between the process pipin! and the instruments for instrument lines installed efte* Ar-il 7,19.2. Prior to the revision a class break was defined to show the location where ASME class stopped and ANSI B31.1 applied. Although ANSI B31.1 does not relat'e to records retention, 10 CFR 50 Appendix B does require special process controls, traceability, installation and inspection records. Therefore, for locally mounted N1 in.etruments, even though they were installed prior to April 7,1982,
2 these records could not be located. Examples of the instruments lines with no supporting installation and inspection records for zones classified as ANSI B31.1 are LT-SI-0305B; LT-SI-0305D; PS-CH-0224X; PS-CH '0224Y and PS-CH-0224Z. Examples of the type of deficient data are weld ' reports, welder , identification, weld filler material, base material and weld inspection i results. The NRC staff concluded that base'd'upon the lack of qual'ity recor~ds,.for i ~ instrumentation installation to B31.1 the requirements of 10 CFR 50, Appendix B and the related other QA program elements may not have been complied with. The lack of documentation to demonstrate the quality of installation of these safety related lines calls into question the acceptability of these installed components. ~"' ~ LP&L shall; (l') Provide' the mis's'ln~g documentation required by 10 CFR 50 Appendix B for the B31.1 instrumentation for local mounted instruments; (2) Review other design changes and documentation for all safety-related N1 instrumentation systems to assure all system installations were properly documented and inspected; and (3) If the documentation cannot be located, action must be taken to assure affected porti'ons of safety-ele.ted system comp 12 with NRC requirements. 3. Instrumentation Expansion loop Separation As a part of its review of NCRs the staff identified a concern in NCR W3-7702. This NCR was written as a result of Mercury DCR Package 1782. Drawing 172-L-012-C Revision 4 had a handwritten note on it identifying two lines DPR-RC-9116 SMB (HP) and DPT-RC-9116 SMA (HP) where the , separation criteria had been violated. The violation occurs where these instrument lines from different trains leave the tube tracks and form an expansion loop before returning to the continuation of the tube track, Lack of separation could result in failure of redundant lines that could i l prevent a safety function. LP&L shall correct the separation criteria violation found in System l 52A. They shall also provide a program for review of other safety-related systems for se necessary corrective actions.paration criteria violations and take the 4 Lower Tier Corrective Actions Are Not Being Uporaded to NCRs The staff reviewed the Corrective Action system to verify if lower tier corrective action documents were being properly upgraded to NCRs as required by 10 CFR Part 50, Appendix B Criteria XV and XVI. Specifically the staff looked at a number of Field Change Requests (FCRs). Design ChangeNotices(DCNs),andEngineeringDeficiencyNotices(EDNs) selected h
I from printguts of safety-related equipment and systems document issuance logs..The selected documents were reviewed for content and basis for issuance (i.e. before the fact design change or after the fact nonconformance),. Finally a walkdown was performed to verify proper identification and chan . -.. Tompkins-Beckwith (T-B)ge control completion. In addition - Discrepancy Notices (DNs) were reviewed. As a result of its review the std{.f.ound that the following flisueJ. Field Change Requests - Sixty-three FCRs and 21 revisions to FCRs a. were evaluated. It appears as another 4 reflected conditions.though 35 should have been NCRs and that may have warranted an NCR. The j list below provides examples of FCRs that should have been NCRs. F-MP-1818 F-AS-1631 F-AS-3698 F-E-3D89 F-AS-3648 F-MP-2138 F-AS-2338 F-MP-2151-F-MP-1434 F-E-2288 b. Design Change Notices C Fourteei DCNs and 5 revisions to DCNs were l reviewed. It appears as though 4 of those should have been upgraded to NCRs. Listed below are examples of these. DCN-703 an'd Revision 1 DCN-1C-478 DCN-ME-3D DCN-E-79D It appears as though the problems identified in DCN-703 are related. to FCR-MP-2138 and may have been reportable under 10 CFR Parts 21 or 50.55(e). Engineering' Discrepancy Notice (EDNs) - Seventy-six EDNs were c. reviewed for proper identifisation and control. Of those 76, it appears as though 51 of those should have been NCRs. Examples of t these are listed below. EDN-EC-1476 EDN-E-1548 EDN-EC-15D2 EDN-EC-1479 l In addition during the review, another 35 were " voided" with no action taken. The voiding action was performed by a clerk. l Examples of voided EDNs are as follows: EDN-EC-0630 EDN-EC-1175 EDN-EC-1176 EDN-EC-1140
h.'.. o l l d. Tompkins-Beckwith - The staff reviewed a sample of the handling of in, formation requests and Discrepancy Notices by Ebasco. As a result of that review it appeared that a number of these items should have been upgraded to NCRs. Examples of these are listed below. W-6519 W-5755 W-6183 W-742 i W-6322 W-5917 W-3656* W-381- - i W-1876 W-5824* l W-4112 W-5047 ~~ W-5692 W-5416 W-6243 W-5916 W-6349 W-2105 W-728 W-4968* W-4648* W-4969* The asterisked (*) items al1 related to incorrect heat numbers being entered incorrectly or clerical error's being made on rod slips. In summary, the staff found'that thelA program requirements for i nonconformance identification, control and proper action do not appear to have been complied with. Lpid i;..;; :=,1= all FCRs, DCNs EDNs, and T-B DNs to as ure that proper corrective action was taken, including an adequate review by QA. This action shall include the steps required by 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and for Construction Deficiency Reporting,50.55(e). i Also included in this review shall be the examination of improper voiding of all other design changes or discrepancies notices that affected safety-related systems or that were misclassified as non-safety related. l 5. Vendor Documentation - Conditional Releases As a part of the staff review of the QA program, the staff evaluated the Ebasco vendor QA program. In assessing this program the staff specifically looked at the ieceipt inspection program, and the conditional release system. . As a result of its' evaluation, the staff found certain deficiencies with the handling of conditional certification of equipment (C of E) for Combustion Engineering supplied equipment. For example, one conditional C of E for the reactor vessel and internals was issued because as-butit dra is p, uterial certifications, and the fabrication plans had not been i forwarded.when the equipment was delivered to LpAL in 1976. The missing documents were sent to Ebasco sometime in 1978, according to the Ebasco l quality records supervisor, but were apparently lost prior to being placed in the Ebasco document control system. The conditional i l.
0 L. certification of equipment was found when a check of all files was made in Apri.1 or May 1984. The missing documents have been requested from CE, and a,tieficiency report was issued and placed on a master deficiency list. This problem has existed since July 20, 1976. . -~ The safety significance of this is that problems with the vendor QA records could affect installed safety related equipment. LP&L shall examine their records and determina..it,all conditional certificati.ons of equipment have been identified, Ta'v'fewed, and promptly resolved. ' 6. Dispositionir.o of Nonconformance and Discrepancy Reports The staff conducted a review of Ebasco nonconformance reports (NCRs) randomly selected from the Ebasco QA vault and the NCR tracking system. The selected NCRs were reviewed for content, compliance with procedures. accuracy, completeness of the disposition and final closure. Of the NCRs reviewed it is the staff's judgement 'that approximately one third contained ouestionable dispositions. Other NCRs were found still open. The implied safety significance is that improperly dispositioned NCRs or lack of NCR closure could place the qisality of installation in question. For example, Ebasco NCR W3-5564 identifies that welds were painted before the final weld inspection was performed. The NCR was closid out with a letter stating that 'the final inspection will be performed tb inspect only for undersizing and lack of weld material where installation drawing calls for weld material. No paint was to be removed therefore the inspector could not inspect for welding defects. The NCRs reviewed by the staff dealt with a wide variety of issues. The following is a list of example Ebasco NCRs that the staff feels contain questionable dispositions or exceeded closure time requirements. Ebasco W3 NCRs NCR-7139 NCR-7177 NCR-3912 NCR-7182 NCR-5563-NCR-7181 NCR-7184 NCR-6159 NCR-6723 NRC-3919 NCR-7547 NCR-6221 NCR-1650 NCR-6511 NCR-6623 NCR-4219 NCR-5586 NCR-7432 NCR-7180 NCR-4137 NCR-6165 NCR-4088 NCR-7099 NCR-6786 NCR-6597 NCR-7533 NCR-7179 NCR-7140 NCR-5565 The staff also found similar type problems related to Mercury NCRs in that the dispositions were questionable; supporting documentation could not be located; rework ap' pears to have not been accomplished; NCRs were not processed; a sufficient basis was not provided; and closure basis l was inadequate. 1
L-The following NCRs fall into these categories: _Mercufy NCRs 180 420 528 568 625 255 429 540 591 656 - 268 438 554 594 658 363 487 560 595 380 491 565--- - 614 Additionally during this review the staff found problems with Ebasco I discrepancy reports (DRs) in that it appears some DRs should have been elevated to NCRs; closure references were incorrect or inappropriate; closure action was improper; documentation was inaccurate; closure was via a DR, should have been an NCR; disposition failed to address the discrepancy; and the disposition of "use-as-is" had insufficient basis. ... ~ The following DRs fall into these categori'es: Ebasco DRs Related to Turnover Packages Q2-CS-1C-27 BD-1C-1143 Q2/3-FY/)C-!!! Q1-RC-LWS-RC-2 Q2-SI-1C-89 LW3-RC-29 QMC-APO-P47E Q2-LW3-51-10F/E CH-1C-342 CC-1C-6 The staff concludes that some Ebasco and Mercury NCRs and Ebasco DRs were questionably dispositioned and that !?&L shall (1) Propose a program that assures that all NCRs and URs are appropriately upgraded and adequately dispositioned and corrSctive action completed, and
- (2) correct any problem detected.
7. _ Backfill Soil Densities i The staff found that records are missing for the in-place density test of backfill in Area 5 (first 5' starting at Elevation -41.25'). These documents are important because the seismic response of the plant is a j function of the soil densities.. LP&L shall (1) Conduct a review of all soil packages for completeness and technical adequacy and locate all records and provide closure on technical questions, or (2) conduct a review of all soil packages for t completeness and technical adequacy and where soil volumes cannot be verified by records as meeting criteria, perform and document actual soil conditions by utilizing penetration tests or other methods, or (3) Justify by analysis that the soil volumes with missing records, or l j technical problems as defined after the records review, are not critical l in the structural capability of the plant under seismic loads. __1__,______
-7. 8. Visual Examination of Shop Welds During Hydrostatic Testing The staff's review of hydrostatic tests conducted by Tompkins-Beckwith 1 (T-B) for their installed ASME Class 1 and Class 2 piping systems found a lack of proof of the visual inspection of all shop welds during the - e.. tests. Inspection of all welds for leakage is required by the ASME Code and is essential to ensure the structural integrity of the piping system. LP&L shall provide documented evf4_en.se.that shop welds were indee? inspected during the hydro tests. If the appropriate inspection i*- documents do not exist or cannot be located, LP&L shall submit a statement attesting to shop weld inspection by the responsible personnel i' of LP&L or Ebasco who had witnessed the hydro tests. g. Welder Certification I The staff reviewed the records for the installation of the supports for i certain of the instrumentation cabinets in the Reactor Containment Building'(RCB). -The review included an ' examination of procurement i records for the support material, weld rod control documents, welder l certification records, and,QC inspect,fon records. Based on the staff review it appears that documentation is missing,on the support welds and it is not cler.r that the welders were certified fnr ?119 the weld. positions used. Thus the quality of the supports for tne instrument cabinets are indetenninant. l LP&L shall attempt to locate the missing documents and determine if the welders were appropriately certified. If the documentation cannot be located, appropriate action must be taken to assure the quality of the i cabinet supports. 20. Inspector Qualifications (J. A.' Jones'and Fegles) The NRC staff reviewed the qualification and certifications of QC inspectors in the civil /structu.ral area. The review included the qualifications of four Ebasco inspectors, five J. A. Jones inspectors and eight Fegles inspectors. The inspector qualifications were compared against the requirements of ANSI N45.2.6 and the contractor's procedures. The staff found that four of the five J. A. Jones inspectors and two of the eight Fegles inspectors failed to meet the applicable certification requirements related to relevant experience. Since these inspectors were involved in the inspection of safety-related activities, the fact that they may not have been qualified to perform such inspections, renders the quality of the inspected construction activities as indeterminant. e ,----,,-_,,.,,,-,,,,,,-.,__.---,-------y,,--- -__,-,,,-----,,----.,-.....--w-. - -,, + -. _ - - -. - - -. _, _ - -, -., -,, -.,. -,, _,,
a 3 i i LP&L shall review all inspector qualifications and certifications for J. A. Jones and Fegles against the project requirements and provide the inforniation in such a form that each requirement is clearly shown to have been met by each inspector. If an inspector is found to not meet the qualification requirements, the licensee shall then review the records to determine the inspections made by the unqualified individuals . and provide a statement on the impact of the deficiencies noted on the j safety of the project. l 11. Cadwelding i I The staff reviewed the Cadweld activities related to the deficiencies identified in NCR-W3-6234. The staff is concerned that the applicant has provided only limited data (in other than the raw form) to the NRC on the statistics of the Cadweld testing program conducted during construction. l The data provided stated that for the base mat 3,673 splices were made l with 81 tests run, showing an average strength of 95,397 psi with a range of 60,750 - 107,051 psi. For the entire project the applicant has stated that 14,293 splices were made of which 591 were tested with 6 of those failing to meet tensile requirements. It is noted that the above NCR has been reopened as a result of the CATinspection and all issues have not been resolved. l ~~ LFAL shall provide the Caldweld data for the project in s'uch a fonn that it can be readily compared to the acceptance criteria used for the i Waterford 3 project. This will require breaking down the Cadweld data l by building or structural element such as the base mat. NPIS walls that { are not part of RAB or FHB, containment in'.trior structures etc. Additionally, the data should be broken down by test program type (production or sister), bar size, bar position and cadwelder. Data shall be provided in each category on total splices made, visual i 4 rejects, production tests and failures, and sister tests and failures. Data shall also be provided on welder qualification and requalification . including dates. Based on discussions with LP&L representatives the NRC staff has been informed that efforts in this area are underway, but this information is needed for staff review. 12. Main Steamline Framing Restraints As part of the NRC staff's review, the installation and inspection of the nain steamline framing restraints above the steam generators was examined to determine if the as-built drawings reflect the actual installation. The NRC staff found no problems with as-built conditions. but found that several bolted connections had not been inspected (or documented) for the framing. The failure to perform (or document) the inspections render the quality of these framing restraints as indeterminant. m+m s---ym -,,r------=e-&-v--vw--'3-'+-c'--'ee-'---gen,---wT47"""T*--""- - - * -
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i '. .. I i 3 Based on discussions with LP&L representatives the staff was informed that the subject inspections are in progress. LP&L shall complete the inspdtions of the restraints and make the documentation of such inspections available to the staff. .13.. Missing NCRs During the NRC's review of Ebasc.q'.p..ECR Processing System the car (index file of NCRs was examined and the'5ttff noted that there are missing reports in the consecutively numbered NCRs. Specifically W3-27, 814, 859, 981,1053,1102,1109,1228,1349, and 1438 are missing from your card index file. Others were also noted to be missing from the Ebasco QA vault. LP&L shall (1) obtain the missing NCRs, explain why these NCRs were not maintained in the filing system, review them fo'r proper voiding, and (2) assure that when an issue is raised to an NCR, it is then . properly filed fo.r tracking and closure.'. 14. J. A. Jones $ceed Letters and EIRs During the Ebasco QA review of J. A. Jones speed letters and engineering it.f:-. ti:n rguests, several items that could affect plant safety were read. 8 tted en its. sample of these actions, the staff do'es not expect that any of these items will significantly affect plant safety. Nevertheless, the applicant should complete the 6ctions identified in these reviews and issues raised shall be resolved promptly. 15. Welding of "D" _ Level Majerial Inside Containment I The staff reviewed the welding of "D" level material for containment l attachments. The containment spray system structural component welds were chosen for specific detailed review. The welds on the containment spray piping supports were checked for weld rod traceability and welder identification and certification..The applicant was unable to produce the documrintation sought for the staff review. I The applicant shall (1)(' locate the documentation and verify the adequacy of the information, or 2) perform a material analysis and NDE work, or (3)reworkthewelds. The staf.f shall be promptly informed of the applicant's approach and the documentation shall be made available for staff review. a e 4 e A
l s .. }.- 10 - I' 16. Surveys and Exit Interviews of QA Personnel In a m morandum dated January 3,1984 R. 5. Leddick, LP&L Vice i Presid;ent for Nuclear Operations, directed that the LP&L Quality Assurance (QA) personnel conduct interviews of the on-site contractor l QA personnel to elicit any concerns the contractor staff may have ....regarding the quality of construction of Waterford Unit 3. That memorandum also indicated that exit interviews would be similarly conducted with the contractor personne1* prior to their leaving the l Waterford 3 project. A total of 407 such interviews were conducted / beginning in January 1984. Individual responses were sent to the specific employee (s) who raised the concern. Exit interviews with the contractor QA employees (resigned, transferred. l orterminated)beganonJanuary 16, 1984. A compilation of the concerns j raised during those interviews were forwarded for followup on May 22,1984.* i The NRC staff rev.iewed all of the questionaire forins and responses to the questions identified by the LP&L QA staff. In some cases, the NRC review identified additional potential issues, beyond those identified by LPAL, and responses that/did not a6 dress the intent of the concerns. Nevertheless, the staff found that the majority of the concerns raised are being or have been addressed as part of all of the other NRC review afferts c:secietad with Waterford 3. i As a result of the staff review, it is not evident that the survey and exit interviews have been vigorously pursued by LP&L to investigate i the issues raised for safety significance, root cause, and generic implications. For example, the exit interviews began in January and are continuing. However, the process of reviewing the content of .l those interviews did not begin until late May 1984 For some of the j interviews, additional information should have been obtained from the l . person interviewed but the interviewers did not indicate on the form i whether or not they sought additional facts. Finally for a number of areas, issues or potential problems were acknowledged but it is not clear that any followup action occurred. t The NRC staff is concerned that the LP&L program to investigate issues i does not prompt 1 and thoroughly examine the specific areas and the l programatic imp ications of them. Other successful programs have utilized independently staffed groups to assess each issue raised and
- formally report to senior utility management on their findings and
. recommended corrective actions. These elements are not evident in the LPSL process. As a result, LP&L should develop and implement a formal pro laram fcr handling issues raised by individuals. One of the first tas s to be dealt w' th by the program should be the review of the responses previously provided to the QA survey and during the exit interviews. m.
~ 11 - 17. QC Verification of Expansion Anchor Characteristics. A review of Mercury Construction Procedure SP-666, Revision 8 " Drilled-In Expansion Type Anchors in Concrete for Category I Structures," revealed that it does not require QC verification of many . characteristics necessary to ensure proper installation of concrete . expansion anchors. These characteristics include: Spacing between adjacent anchorY ~ ~ Spacing between'an anchor and the edge of a concrete surface Spacing between an anchor and an embedded plate Minimum anchor embedment depth Grouting of unused / abandoned holes in the concrete Mounting plate size Size of holes in mounting plates and hole distanca from plate edges Although most of the above characteristics are addressed in Section 6.1 " installation," they are not. included within Section 6.2 " Inspection," as items requiring QC verification. In addition, QC Inspection Report Form 277A, Rev. May 1982, " Equipment Installation (Anchors)." does not list these attributes as inspection pbints. 'Therefore, Procedure SP-666 should be revised to include til necessary inspection attrib ~utes, and a reinspection program should be. initiated. This pr: gram should be of sufficient size and scope to indicate whether these concrete anchors, in general, are able to perform their intended function. Detailed results should be made available to the NRC staff for review. 18. Documentation of k'alkdowns of Non-Safety Related Equipment A review of the design-and evalu'ation of the non-safety instrument afr piping, tubing, and th~eir supports indicated that the general recommendations of Regulatory Guide 1.29, " Seismic Design Classification" i were considered. This non-safety equipment is ins ~talled in areas with safety related equipmentsisuch as the containment and auxiliary building -areas. From the information provided reintive<to this system, it is apparent that the potential ~ for system failure was considered in the design. Also a number of-procedures and controls"were implemented to further assure that thesa non-safety related components would not affect safety related equipment. However, the followup documentation of the final walkdowns, did not. list the reviewed equipment in detail and therefore it could not be concluded that the instrument air piping and tubing l (and their supports) ha'd -been adequately ~ addressed regarding potential physical damage to safety-related equipment. +r y t
,s Therefore, documentation should be provided that clearly shows what equipment was reviewed during the walkdowns and on what bases it was concit/ded that the installation was acceptable. 19. Water in Basemat Instrumentation Conduit . In examining the safety significance of the allegations, the NRC staff performed system walkdowns as a means of verifying the as-built conditions. During one of those walkdown!, the staff noted that there was water in an electrical conduTt"that penetrated the basemat. If the seals in that conduit should fail there is a potential direct path for ground water to flood the auxiliary building basement. LP&L should review all conduit that penetrates the basemat and terminates above the top of the basemat to assure that these potential direct access paths of water are properly sealed.
- 20. _ Construction Materials Testino (CMT) Personnel.0"11fication Records 1
~# The Inquiry Te'am' effort' includeia~ review of the disposition of the generic problem identified during the LP&L Task Force verification relative to CEO Construction Testing-(GEO) documentation for personnel-qualifications in the area of CMT.- The utility should conduct a review of supporting documentation for GEO corrective action stated in Attachment 6 of NCR W3-F7-116 (Ebasco W3-6487). This review should focus on the identification of CMT personnel placed in GEO Categories 1, 2 or 3 who were apparently qualified solely on written statements by other individuals attesting to the individuals training and qualifications. For such individuals, the applicant should pursue.any new information or evaluations which could provide further assurance in support of the actual past work experience and training referenced by the written statements.
- 21. ' LP&L OA Construction System Status and Transfer Reviews The Inquiry Team assessment of the Ebasco QA disposition of LP&L QA Construction documentation and walk-through hardware findings for a sample of the sixty-seven systems transferred to LP&L operations resulted in NRC questions on the adequacy of Ebasco and LP&L QA Construction disposition of those findings. As a result of the NRC questions LP&L and Ebasco QA initiated a review to ensure that all LP&L QA Construction findings were adequately dispositioned.
Ebasco ~ 43B9,46C,ASE,46H,55A,59,69B,72f?,72A,and91E}wheretheLP&L36-1, 36-QA had identified 15 systems or subsystems (Nos.18-3 findings may not have been properly digositioned during the transfer of these systems to LP&L operations. j
e - 13 Based cn the above, LP&L is requested to complete the review of all significant LPAL status and transfer review findings, such as undersized welds'and other hardware walk-through and documentation findings. This review should ensure that these findings have be.cn properly closed out or identified to LP&L operations for their closecut. For any LP&L open findings not properly identified on the status or transfer letters to LP&L operations, LP&L should determine whether this condition adversely affected the testing conducted fpr g se systems.. 22. Welder Qualifications (Mercury) and Filler Material Control (Site Wide) The staff reviewed inprocess weld records for the installation of instrumentation systems by Mercury Company. Systems reviewed included Reactor Coolant, Safety Injection Component Cooling Wa'ter, Main Steam, Main Feed, and Charging Water. The staff selected welders from these 'e records and reviewed their qualifications.to the welding process used [k during the time frame.of actual welding. j ~ Based on the staff's review it appears that some Mercury welders were
- j. >
l not qualified. Problems included: wpiders not qualified to the correct welding procedure; velders qualified for a specific process,. even though they were not tested for that process; and actual dates on qualification records appeared questionable, the welder may have welded pr k r t:, bai..; tasted. The staff concludes that there are. questions i relative to the Mercury welder qualification status. Also during this review the staff evaluated the controls being used to control filler material. The staff found that the requirements for "rebaking" of low hydrogen electrodes did not meet the requirement of the ASME and AWS Codes. The Codes require low hydrogen electrodes to be rebaked at temperatures of 450' to 800*F for two hours. The site practice for all site contractors was to rebake at 200*F for eight hours. Justification for this C. ode deviation has not been provided by 1 LP&L. l LP&L shall (1) Attempt to ocate the missing documentation and determine i if the welders were properly qualified, or (2) If the documentation to support proper qualification cannot be located, LP&L shall propose a program to assure the quality of all welds performed by questionably qualified welders. LF&L shall also provide engineering justification for the allowance of "rebake" temperatures and holding times that differ from the requiraments of the ASME and AWS Codes. l S em 7-r 8"" '-'"Y- - ^ - - ' ' - ' - - - " ' - - * - " ' " - ' " - -
- 14 _ A ProcFam Breakdown Between Ebasco and Mercury Q 23. The staff review included evaluation of the implementation of the QA programs of LPAL, Ebasco, and Mercury. The staff performed a followup on the previous 1982 NRC review that resulted in NRC enforcement action and a civil penalty. The most recent staff review indicated that LP&L, i - Ebasco, and Mercury did not followup on the corrective action commitments made to the NRC. Additionally LP&L, Ebasco, and Mercury failed to audit the entire QA- ~ - program as required (LP&L only performed one-third of their scheduled audits for a five year pe'riod). The audits that were conducted identified some problems, however the required corrective actions were not completed. Management audits, performed by outside consultants. f)\\ -h identified problems and concerns that LP&L also failed to take {j / jf' corrective action on. The results of the NRC task forbe effort indicate that an overall breakdown of the QA program occurred. Most problems identified by the NRC had been previously identified by the QA programs of LP&L, Ebasco, and Mercury. But the failute to dete'rmine root cause and the lack of ccrrective action allowed the problem to persist. ~ LP&L shall provide an assessment of the overall QA progradand determine the cause of the breakdown, together with corrective action to prevent recurrence. This overall assessment is necessary to provide assurance that the QA program can function adequately wher. the plant proceeds into operations. L 4 - - - - -}}