ML20093H670
| ML20093H670 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/11/1984 |
| From: | Garde B GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Asselstine J, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| CON-#484-495 OL, NUDOCS 8410160346 | |
| Download: ML20093H670 (12) | |
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b GOVERNMENT ACCOUNTABluTY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 recy itn Washington, D.C. 20036
'MC (202)232-8550 14 00T 15 P3' :05 Octo'ber 11, 1984
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The Honorable Nunzio Palladino
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The Honorable James Asseltine The Honorable Thomas Roberts
'h hh 6 The Honorable Frederick Bernthal The Honorable Lando Zeck U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Commissioners:
During the past few days, the Government Accountability Project
(" GAP") has uncovered devastating evidence that reveals the ex-tent of quality assurance ( "QA " ) breakdowns at the Comanche Peak plant.
This evidence results from a ccmbination of information compiled from both wi.tnesses and documents made public through the Atomic Safety and Licenaing Board ("ASLB") hearings, other Commission documents, and information developed through GAP's own sources of information.
The evidence establishes that since 1977, Texas Utilities Genera-ting Company ("TUGCO") has totally disregarded every step of its construction procedures and quality control ("QC") procedures.
This is most dramatically demonstrated through the evidence related to the installation of the stainless steel liner plates.
Since 1977, workers have been losing their jobs to bring the magnitude of the liner plates' problem to the attention of the Nuclear Regulatory Commission ("NRC").
Yet, not once, has one inspector or investigator (including those from the Office of Investigation ( "OI") or the Technical Review Team ("TRT") even bothered to look.st the procedures, documentation or physical con-dition of the stainless steel liner plates.
Taxpayers are now being required to spend over a million dollars on an NRC " super review team" to allegedly find the extent of the QC breakdown.
The NRC's failure on the liner plates constitutes gross abuse of the public trust.
We are asking Congress to request an investigation by the Government Accounting Office ( "GAO ")
into the breakdown in the NRC's regulatory program which has permitted this $3 billion plant to arrive on the eve of fuel loading with no one being able to explain how every single step of the process has failed.
After our experiences with Zimmer, Midland, Diablo Canyon, TMI g!PPo88Poiss80g TSO3
Commiccion:ro i
P'ge Two Clean-up and Waterford, we thought that there was no amount of ig-norance on the part of the NRC that would surprise us.
We were wrong' At the recent Commission meeting on Callaway, GAP was criticized for not bringing information to the NRC until the license decision.
Although we strongly dispute your decision to not allow GAP repre-sentatives to explain the lateness of the allegations, lot this letter serve as official notice that:
1.
There are hundreds of allegations of QA/QC breakdown in design, ponstruction, pre-operational testing, documentation, etc. which GAP has provided to the NRC through OI and the TRT about Comanche Peak.
2.
Neither OI nor the TRT have done an adequate job of investigating or reviewing any of the allegations to date.
(See September 27, 1984 letter to Darrell Eisenhut, attached as Exhibit 1.)
3.
There has been no effort on the part of either the TRT, Region IV or OI to probe the cause of the QA/QC breakdown.
(See Exhibit 2.)
If the staff cannot or will not do an adequate job investigating allegations, then the problems that result from a dissatisfied and disgusted public and disenchanted workers are the responsibility of this Commission.
We strongly urge you to hold a briefing on the staff's ongoing activities at Comanche Peak now.
We will ne happy to provide you with any documentation and/or wit-nesses you desire to substantiate the concerns listed above.
Sincerely, hh A
Billie Pirner Garde Citizens Clinic Director BPG:me Attachments
SERVICE LIST 4
Mr. M. D. Spence Mr. James E. Cummins President Resident Inspector / Comanche Peak Texas Utilities Generating Company Nuclear Power Station 400 North Olive Street, L.B. 81 c/o U.S. Nuclear Regulatory Dallas, Texas 75201 Commission Post Office Box 38 Nicholas S. Reynolds, Esquire Glen Rose, Texas 76043 Bishop, Liberman, Cook, Purcell & Reynolds.
Mr. John T. Collins 1200 Seventeenth Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C.
20036 Region IV 611 Ryan Plaza Drive Robert A. Wooldridge, Esquire Suite 1000 Worsham, Forsythe, Sampels Arlington, Texas 76011
& Wooldridge 2001 Bryan Tower, Suite ?!00 Mr. Lanny Alan Sinkin Dallas, Texas 75201 114 West Seventh, Suite 220 Austin, Texas 78701 Mr. Homer C. Schmidt Manager - Nuclear Services Mr. B. R. Clements Texas Utilities Generating Company Vice President Nuclear Skyway Tower Texas Utilities Generating Company 400 North Olive Street, L.B. 81 Skyway Tower Dallas, Texas 75201 400 North Olive, Street, L.B. 81 Mr. H. R. Rock Dallas, Texas 75201 Gibbs and Hill, Inc.
William A. Burchette, Esquire 393 Seventh Avenue 1200 New Hampshire Avenue, N.W.
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New York, New York 10001 Suite 420 Washington, D.C.
20036 Mr. A. T. Parker Westinghouse Electric Corporation David R. Pigott, Esquire Post Office Box 355 Orrick, Herrington & Sutcliffe Pittsburgh, Pennsylvania 15230 600 Montgomery Street San Francisco, California 94111 Renea Hicks, Esquire Assistant Attorney General Anthony Z. Roisman, Esquire Environmental Protection Division Trial Lawyers for Public Justice Post Office Box 12548, Capitol Station 2000 P Street, N.W.
Austin, Texas 78711 Suite 611 Washington, D.C.
20036 Mrs. Juanita Ellis President Citizens Association for Sound Energy 1426 South Polk Dallas, Texas 75224
. Ms. Nancy H. Williams CYGNA 101 California Street j
San Francisco, California 94111
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Exhibit 1 i
GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Awnue. N.W.. Suite 202 Washington. D.C. 20036 (20-2)2324550 September 26, 1984 Mr. Darrell G. Eisenhut Director Division of Licensing Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Eisenhut:
Recently, you provided to M. D. Spence, President of Texas Utilities Electric Company (TVEC), a request for further information regarding several items under review by the Technical Review Team (TRT) that have potential safety significance.
It is my understanding that these items were also dis-cussed with TUEC at a pub 1ic meeting in Bethesda last week.
After reviewing your letter of September 13, 1984, and the transcript of the September 18 meeting, it is apparent that there are vital unanswered questions about both the methodology by which the TRT is resolving issues that are brought to their attention by allegers, and the ndequacy of the depth to which the TRT is looking at specific issues.
Your letter states that further background information regarding the issues identified in the September 13 letter and, presumably, the other items being reviewed by the TRT, will be published in a Supplement to a Safety Evaluation Report (SSER) which "will document the overall TRT's assessment of the significance of the issues examined." (September 13, 1984 letter from D.
Eisenhut to M. D. Spence.)
The Government Accountability Project (GAP) believes that any assess-ment of the overall significance should be publicly disclosed prior to the issuance of the SSER.
Frankly, we think that there is significant evidence available to our investigators that the TRT, other members of your staff, and Region IV inspectors have fallen short of the in-depth inquiry' which would provide the basis of the adequacy of any overall assessment.
a N
s Mr. Darrell G. Eisenhut -
s September 26, 1984
'Page Two Further, we believe that your request-from TUEC.for additional infor-mation through "a program and schedule for completing a detailed and thorough, assessment of the issues identified" falls short of the obviously necessary requirement for comprehensive programs to identify the full scope'of the technical deficiencies listed in the letter. We note that in your request that a program plan "should address the root cause of each problem identified and its generic implication on safety-related systems,' programs or areas," as well as the collective significance of_ these deficiencies." However,youhaver?ot required that TUEC's proposed response must first include an identific~ t' ion of a
the extent of-the identified problem.
This " backward look" is critical to any meaningful assessment of the adequacy of a TUEC "get well" program.
Further, we do not understand the instruction to TUEC to submit a response which addresses those items listed in your September 13, 1984, letter in the face of the large volume of outstanding items, yet to be identified, s and the findings of the Quality Assurance / Quality Control (QA/QC) team.
It appears to us that your direction to TUEC was vague and inappropriate, at this time.
It neither ordered a reinspection commensurate with the level of deficiencies discovered, nor simply informed TUEC of some of the TRT's findings.
We note that all of the identified problems in this letter were first identified by former employees at the Comanche Peak site, yet in no case that we are aware of, has the TRT re-contacted that employee with its findings to get further direction or guidance, or clarifying information regarding the specific confirmed item. A good example of this is the finding under Test Program Areas; Prereouisite Testing (Section III(c).)
Your request for addi-t tional information stated tha' af ter a review of the Final Safety Analysis t
Report (FSAR) commitments, appropriate procedures, records, and interviews, the l
following problem wa,s identified:
The' review of test recoNd:; revealed that craft personnel were signing to verify-initial conditions for tests in violation of startup Administrative Procedure-21, en '
titled:
" Conduct of Testing" (CP-SAP-21).
This procedure requires this function to-be performed by System Test Engineers (STE). Startup management had issued a memoran-dum improperly authorizing craft personnel to perform l
these verifications on ' selected tests.
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Mr. Darrell G. Eisenhut September 26, 1984 Page Three Your letter than apparently instructs TUEC to:
(1) rescind the startup memorandum (STM-83084); and (2) ensure that no other memoranda are issued which are in conflict with approved procedures.
After going over this finding with the allegers, we discovered several things which your report did not discover and does not address.
Fi rst,
the memorandum (STM-83084) which the TRT has identified, was not the beginning of the problem which permitted unqualified personnel to perform prerequisite tests.
The memorandum, in fact, placed a limitation on the tests which un-qualified craft personnel were allowed to perform.
Prior to the issuance of the memorandum, there had been n_o controls on the craft personnel performing verification tests.
A more detailed explanation has been provided to the TRT once, and a random review of prerequisite tests performed prior to the issu-ance of STM-83084 would have demonstrated that prerequisite tests were performed almost exclusively by unqualified personnel.
Your requirement for TUEC to rescind the memorandum in conflict with CP-SAP-21 is totally ii1 adequate to determine the consequences of an unknown majority of prerequisite testing done by unqualified people.
Another example of the inadequate approach being taken by the TRT and other branches of your agency is the handling of problems identified in the electrical / instrumentation area.
Your September 13 Request for Additional Information identifies five problems with electrical cable terminations, butt splices inside panels and vendor-installed terminal lugs.
It also requires certain procedural or re-inspection requirements for each of the problems.
A cursory review of the corrective actions indicates that those actions are totally inadequate.
For example, the TRT discovered that electrical QC inspectors interviewed did not even know that Inspection Reports (IR's) were supposed to include verification of witnesses to installation of certain " nuclear heat shrinkable cable insulation sleeves." The solution for this identified problem was only to improve training, daily procedures'and to make sure that the problem does not happen in the future.
' Mr. Darrell G. Eisenhut September 26, 1984 Page Four The TRT failed to state that all electrical cables are installed, and all inspections are.already performed. The corrective action for the future is' essentially meaningless in this case.
Further, the TRT failed to discover that this problem had been identified previously by electrical QC inspectors on NCR's, as well as in discussions with Quality Engineers (QE) who had written the inadequate procedures in the first place.
Perhaps this can be explained by the fact that the TRT did not interview the electrical QC inspectors who in-itially identified the problem.
The September 13 letter also inappropriately places with TUEC the responsibility to give the NRC assurance that all the QC inspections which required witnessing "for butt splices have been performed and properly docu-mented," and verifying that the ' butt splices are properly identified on the appropriate drawings and are physically identified within the appropriate pa nel s. " Your letter did not even require that the methodology TUEC uses to reach its assurance be reviewed prior to the work being done, nor does your letter specify that the assurances will come frcm a review of 100 percent of the affected inspections.
Additionally, the TRT mentions a lack of splice qualification require-ments.
As you know, the lack of qualification requirements is an extremely significant deficiency.
In some cases, the lack of qualification requirements for electrical cable has resulted in the requirement for cables to be replaced.
Your suggestion to TUEC that the development of adequate installation and in-spection procedures for future wire splicing materials is grossly insufficient.
The first step of any review should be to ascertain those cables which have splices and all circuits affected by those splices.
We note that without any idea of the extent of the problem, Mr.
Youngblood of your office, has already judged that the use of wire splices inside control panels is acceptable.
(See September 14, 1984, letter to M. D.
Spence from B. J. Youngblood,
Subject:
Acceptability of Updated FSAR Commit-ment on the Use of IEEE-Std-420 for Comanche Peak Steam Electric Station (Units 1 and 2).)
i Mr. Darrell G. Eisenhut September 26, 1984 Page Five We believe this microcosm of activity by your office is indicative of the approach being taken on serious technical and hardware deficiencies at the Comanche Peak plant.
Apparently, the commitment to erase the problems is more important than the more prudent approach of first determining the extent of the problem, and the' ascertaining whether a solution is acceptable.
By n
separate letter today, we have requested under the Freedom of Information Act (F0IA), all material available to Mr. Youngbloo,d which he used as a basis for the staff's evaluation report on wire splices.
We also note that no QC inspectors who identified the splice qualifi-cation problem were contacted by the TRT.
In another technical-related problem, we note that the TRT found cable terminations which did not agree with their location on the drawings.
Your response is to require TUEC to do an "as built walkdown" of the locations of all safety-related and a.ssociated terminations in the control room panels and in the termination cabinets in the cable spreading room.
This assumes that there is a set of, drawings that is, in fact, accurate. We do not believe that to be the case. 'We do believe that the requirement will amount to an NRC instructed update of electrical drawings instead of a documented reinspection.
This is particularly likely given the lack of specicivity in your request for a reinspection--such as your failure to set what level of nonconformances is an unacceptable level, and what the original scope of the inspection should be.
The final electrical problem identified in the TRT's September 13 report reveals incredible failure to expand the scope of the TRT's own review when problems are discovered.
The issue, improperly closed NCR's on vendor-installed terminal lugs, should have demonstrated again that the vendor inspection program at Comanche Peak has significant problems.
Evidence available to us indicates that the flaw applies to NCR's on all vendor-installed components.
Even more significant than the improperly dispositioned alled c n ts fro QC rev e rn os uct
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exemption from the final quality document review.
The TRT report drew conclusions about electrical equipment separation
Mr. Darrell G. Eisenhut September-26, 1984 Page Six violations, but failed to explain what standard was violated--ES 100 or Nu Reg Guide 1.75.
Without specifying what the minimum separation requirements are, it is impossible for either TUEC or the public to ascertain what the TRT is _ talking about. Without such clarification, it is a meaningless exercise to attempt to evaluate TUEC's analysis justifying their violations.
The language of the entire section is an argument in the abstract, since the fundamental issue--the separation criteria which is approved by the NRC--is not identified.
It is also appropriate to note that this item was also brought to the attention of the TRT by a former employee, and that employee has never been subsequently contacted for clarification of this issue.
There are numerous other examples of significant findings which we believe are not adequately addressed by scope or corrective ac, tion request.
In summary, the' TRT's update report provides the following insights into the million dolla,r effort launched by your office:
1.
It has continued to take a piecemeal approach to the increasing number of identified problems.
2.
It fails to provide any assurance that problems other than those identified by the whistleblowers, inter-venors, or others will be independently found.
3.
There is no attempt made to qualify the percentage of deficiencies discovered.
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4 No " backward look" is being required to examine completed systems which have been installed with the use of inaccurate documentation, unclear pro-cedures, or unqualified craftsmen or inspectors.
Your review team is to be commended for their diligent pursuit of a mammoth number of deficiencies which have accumulated over the last seven years.
Unfortunately, their ability to do a comprehensive job is being i
Mr. Darrell G.. Eisenhut September 26, 1984 Page Seven hampered by a methodology which fails to incorporate the best information available--that of those employees, quality control inspectors, and engineers who know the scope, extent, and root cause of the problems they brougnt to the attention of the NRC.
It is unfortunate that your agency cannot rise above the mistaken im-pression that only NRC investigators, inspector.s and engineers are able to identify and evaluate serious deficiencies.
GAP's concern continues to be that your TRT will conclude with a compendium of over 1,000 allegations from current sources, with a matched set of 1,000 resolutions advanced by TUEC and endorsed by the NRC.
That scenario does very little to answer the ultimate questions about management competence, quality assurance breakdowns, documentation chaos, and indeterminate systems, structures, and components throughout this plant.
As you are aware,' I was not able to attend the TRT b[iefing last week because of the ongoing harassment and intimidation hearings in Ft. Worth.
After a review of the recent IE, 01 and other NRR reports, ircluding this TRT report, I respectfully request to meet with you and Mr. Ippilito at your earliest conveiance.
Sincerely, Eh bG 4
Billie Pirner Garde Citizens Clinic Director B'G :me cc: Service List 9
DallasTimes Erak?
WEDNESDAY SEPTEMBER 19,'1984 8 Sections 25 Cc Comanche probe caled NRC action inac.ec ua':e 6 on n ant By JACK BOOTH I' "
"'""M*/_ of a f.,an.
ca" ec. weak eensmg board Tuesday blasted the Nuclear Regulatory Commission staff for conducting what he said COMANCHE - From Page One were inadequate investigations into allegations of harassment of sponsible fpr providing the board mspectors at the Comanche Peak with the information it needs to nuclear plant.
make that decision.
In 1. s.trongly worded statement Stuart Treby, an attorney for during licensing hearings in Fort the NRC representing the com-Worth, Peter Bloch: head of the mission at the hearing, told Bloch U S. Atomic Safety and Licensing that the text of the NRC reports Board, said none of the NRC re-might not have reflected all the ports on harassment had been the work that went into them.
product of "true investigations."
Bloch's impromptu statements He said NRC officials failed to followed the first portion of testi-
'p* many by former quality control ask probing or detailed questions, g inspector Cory Allen, a key wit-neglected to look for inconsisten-cies in statements and made no at-
.. ness whose identity had been tempt to compare testimony with
'. shielded until last week because plant records.
he was fearful he would not be "There was no thrust for the able to get a job in the nuclear truth; there was no tracking down industry if he voluntarily testified of all leads," Bloch said. "They in the hearings.
seem to be a series of interviews."
Allen took the stand after the '
The board Bloch heads is the board issued a subpoena that agency that ultimately will grant forced him to testify. He then de-or deny a license for the plant to tailed alleged instances of intimi-operate. The commission is re-dation, starting the day he was hired, that he said gradually See COMANCIIE on Page 15 prompted him to overlook con-struction defects out of fear of be '
I ing fired..
After Allen's testimony w'as in-i terrupted by a short recess, Bloch made his criticisms of the NRC's investgations. He said later that l
he had been surprised that so l
many of the details of Allen's alle.
gations had not been covered in an in'erview conducted previously by the NRC.
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9 DALLAS TIMES HERALD Wednesday. Sept.19.1984 A-15 1
"They did not get a lot of what he had to any." Bloch said. "We have been asking questions in the course of the hearings which are Utility supervisors have not ad-the result of looking for inconsis-dressed Allen's charges in testimo-tencies in testimony and asking ny, because the testimony was
, for documents to fill the gaps. We made publie just Tuesday. But the rM.ws have testified that no check what's been said against su documents that exist. We just general pattern of harassment ex-don't see that process reflected in isted, despite " isolated instances" of intimidation.
any of the NRC investigative Utility officials also have 5
reports.
charged that a few disgruntled in-
"It creates a problem of having confidence in the investigative re-spectors were responsible for all the complaints about intimidation.
ports," he said.
Allen testified that he thought he Bloch added, however, that the had been singled out by'supervi-NRC had yet to release 22 investi-sors as a " leader of the pack," but gative reports, many dealing with he claimed that his views also harassment, and he had no way of were held sby many other knowing how thorough they i
inspectors.
Bloch was also critical of a 1979
- After asking several detailed were.
WRC inspection report mentioned questions about procedures during i
l earlier in the day.
training classes. Allen said he was i,
in testimony' port,'the NRC'Inspec-called into the office of the quality 16 that re lors said they had not invesugated control supervisor and questioned an allegation that quality control intensively about his motivations.
He said he was told, in essence, personnel had engaged in fre-quent cover ups of problerna. The that the procedures were none of report merely said the investiga-his business.
fors "did not investigatfthe al-Once on the job, Allen said there were numerous unstances in j
leged ' lots' of (quality control) co-verup because of the lack of which his immediate supervssor, Harry Wilhams, a focus of intimi-specif/..."
dation charges aired in the hear-Blodn said that statament was typical of an NRC failure to not ings, often seemed to side with construction workers in frequent i
ciceely examine such allegations.
He noted that only one quality disputes about whether inspectors I
control inspector had been 1 iter-were being too picky.
Allen said he decided to over-viewed, even though others may look major problems after an inci-have been aware of the problem if dent in which Brandt overruled it had been as widespread as him on what appeared to be a bla-charged.
tant attempt by workers to de-Allen worked at the plant as a ceive the inspectors..
quality controlinspector from eer-In that instance, Allen testified.
ly 1982 until the end of last year.
workers stuffed a cigarette filter He said he sensed that inspectors into a tube leading to a paint were not appreciated during his first day on the job, when Tom sprayer just before an inspector was due to exarnine the spray for Brandt, a high-level quality con-evidence of water or oil contami-trol supervisor, told him.he did
". nation. After the inspector had not appreciate inspectors who left. the workens would remove thought they were engineers.
the filter because it otherwisc i
l would quickly pg up the kne.
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