ML20125D742
| ML20125D742 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/24/1984 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20125D664 | List: |
| References | |
| FOIA-84-740 NUDOCS 8506120455 | |
| Download: ML20125D742 (11) | |
Text
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TESTIMONY OF NUNZIO J. PALLADINO
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. CHAIRMAN U. S. NUCLEAR REGULATORY COMMISSION BEFORE THE SUBCOMMITTEE ON ENERGY AND THE; ENVIRONMENT -
-COMMITTEE ON INTERIOR AND INSULAR AFFAIRS -
UNITED STATES HOUSE OF. REPRESENTATIVES ON DIABLO CANYON LICENSING CONCERNS JANUARY 24, 1984
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y,. $N.Ei.0CAEYCHTESTIUOHV (REv: set. 1/20/84 5:00 PM) iiR. CHAIRMAN AND MEMBERS OF THE SUBCOMMITTEE, WE AGAIN APPRECIATE THE OPPORTUNITY TO DISCUSS WITH YOU'THE ISSUES AND CONCERNS -
REGARDING THE STATUS OF THE LICENSING PROCESS FOR THE DIABLO C NYON NUCLEAR POWER PLANT. WE LAST DISCUSSED THESE MATTERS WITH MR. CHAIRMAN, IN YOUR YOU NEARLY A YEAR AGO ON MARCH 8, 1983.
LETTER TO,ME OF DECEMBER 20 0F LAST YEAR YOU IDENTIFIED AS YOUP,
'PARTICULAR CONCERN "THE STATUS OF THE LICENSING PROCESS AND THE RESULTS OF THE NRC'S REVIEW OF THE DIABLO CANYON DESIGN AND CONSTRUCTION." FIRST, I WILL DISCUSS THE STATUS OF THE DESIGN ,
VERIFICATION EFFORT; SECONDLY, THE ONGOING HEARING PROCESS; AND THIRDLY, THE MATTER OF ALLEGATIONS THAT HAVE BEEN RAISED IN RECENT MONTHS. THE COMMISSION STAFF HAS MADE CONSIDERABLE s
PROGRESS IN ADDRESSING AND RESOLVING THE QUESTIONS ASSOCIATED
._/ WITH DIABLO CANYON. I WOULD LIKE TO ADD, HOWEVER, THAT MANY OF --
THESE QUESTIONS ARE STILL BEFORE EITHER THE COMMISSION OR THE NRC'S APPEAL BOARD FOR DECISION, DESIGN VERIFICATION PROGRAM THE DESIGN VERIFICATION PROGRAM FOR DIABLO CANYON UNIT 1 HAS ESSENTIALLY BEEN COMPLETED. THE PROGRAM WAS ORDERED BY THE COMMISSION IN NOVEMBER OF 1981 WHEN WE SUSPENDED THE LOW POWER i)
~~
LICENSE FOR UNIT 1. IT INCLUDED THE VERIFICATION OF THE SEISMIC DESIGN, REFERRED TO AS PHASE I, AND THE NON-SEISMIC DESIG,N, REFERRED TO AS PHASE II. IT CONSISTED OF TWO COMPLEMENTARY
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EFF0FTF: THE INDEPENDENT DESIGN VERIFICATION EFFORT, CALLED
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( IDVP, WHICH WAS PERFORMED. UNDE,R THE DIRECTION OF AN INDEPENDENT ,
CONTRACTOR (TELEDYNE ENGINEERING SERVICES), AND THE INTERNAL TECHNICAL PROGRAM, CALLED THE ITP, WHICH WAS PERFORMED BY PACIFIC GAS AND ELECTRIC COMPANY WITH THE ASSISTANCE OF THE BECHTEL CORPORATION UNDER THE DIABLO CANYON PROJECT.
THE IDVP EFFORT, CONSISTED OF SEISMIC DESIGN VERIFICATION IN SELECTED AREAS AND NON-SEISMIC DESIGN VERIFICATION OF THREE MAJOR SAFETY-RELATED SYSTEMS. THE IDVP ALSO PERFORMED AN AUDIT OF DESIGN QUALITY ASSURANCE PROGRAMS AND THEIR IMPLEMENTATION. THE
~
PGaE EFFORT INCLUDED A VERIFICATION OF THE SEISMIC DESIGN OF ALL ,
' SAFETY-RELATED STRUCTURES, SYSTEMS, AND COMPONENTS; RESOLUTION OF CONCERNS IDENTIFIED BY THE IDVP; AND MODIFICATIONS TO THE PLANT AS NECESSARY.
SEMI-MONTHLY REPORTS ON THE STATUS OF BOTH THE IDVP AND PGBE PROGRAM WERE ISSUED. THESE REPORTS PARTICULARLY FOCUSED ON IDENTIFYING NEW CONCERNS. IN ADDITION, THE IDVP ISSUED IN EXCESS OF 60 INTERIM TECHNICAL REPORTS. REPORTS WERE ISSUED WHEN THE VERIFICATION OF A PARTICULAR ASPECT HAD BEEN SUFFICIENTLY COMPLETED TO ALLOW THE IDVP TO REACH A CONCLUSION. THE IDVP ISSUED A FINAL REPORT ON ITS EFFORTS IN SEGMENTS BETWEEN MAY AND ,,
OCTOBER 1983. THE FINAL REPORT INCLUDED AN EVALUATION OF ALL -
DESIGN ERRORS AND THE BASIC CAUSE FOR THESE ERRORS. AN ERROR DESIGNATION MEANS THAT A DESIGN CRITERION WAS NOT MET OR AN
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OPERATING LIMIT WOULD HAVE BEEN EXCEEDED. THE RESOLUTION OF AN f.
N ERROR REQUIRED A PHYSICAL' MODI.FICATION, A CHANGE IN OPERATING .
PROCEDURE, MORE REALISTIC CALCULATIONS, OR RETESTING. PG8E 15 SUED SEPARATE FINAL REPORTS FOR PHASE I IN SEPTEMBER 1982 AND PHASE II IN JUNE 1983. ALL REPORTS'WERE AMENDED THROUGH OCTOBEPJ 1983, DISTRIBUTED TO ALL PARTIES, AND RELEASED TO THE PUBLIC.
THE IDVP BASED ITS VERIFICATION ON INFORMATION TMAT HAD BEEN PROVIDED BY PG&E, THE INFORMATION WAS EVALUATED WITH RESPECT T,0 LICENh1NG CRITERI A AND COMMITMENTS IN THE FINAL SAFETY ANALYSIS REPORT AND IN OTHER LICENSING DOCUMENTS FOR DIABLO CANYON. IN EXCESS OF 300 ERRORS OR OPEN ITEMS WERE IDENTIFIED AND REVIEWED BY THE IDVP. BASED ON FURTHER INFORMATION PROVIDED BY PG8E AND
( .. ! THE INDEPENDENT ANALYSIS OF THE IDVP, ABOUT EIGHT PERCENT.0F. . _ _.
THESE CONCERNS WERE CLASSIFIED AS ER.RORS.
THE DESIGN VERIFICATION EFFORT BY THE IDVP AND PG8E RESULTED IN EXTENSIVE MODIFICATIONS TO THE PLANT. WHILE SOME OF THOSE CHANGES WERE DUE TO THE CONCERNS IDENTIFIED BY THE IDVP, THE MAJORITY WERE THE RESULT OF PG&E'S INTERNAL SEISMIC DESIGN .
VERIFICATION OF ALL SAFETY-RELATED STRUCTURES, SYSTEMS, AND COMPONENTS. IN MOST CASES WHERE A QUESTION AROSE REGARDING THE f
[ NEED FOR A MODIFICATION, THE PLANT WAS UPGRADED TO ENSURE THE __ ,
DESIGN BASES FOR THE PLANT WERE MET. SUCH MODIFICATIONS WERE 0FTEN MADE IN LIEU OF FURTHER ANALYSES AND EVALUATIONS. ,EvEN i
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THOUGH, ANOTHER ANALYSIS OR EVALUATION MIGHT HAVE PROVEN THE
( MODIFICATIONS UNNECESSARY. , ,
I.N MID-1983 THE DESIGN VERIFICATION EFFORTS WERE SUFFICIENTLY COMPLETED FOR OUR STAFF TO EVALUATE THE PROGRAM AND ITS FINDINGS.
THE INITIAL SEGMENT OF THE STAFF'S EVALUATION.WAS ISSUED ON AUGUST 5, 1983 AS SUPPLEMENT 18 TO THE SAFETY EVALUATION REPORT.
FURTHER STAFF EVALUATIONS AND RESOLUTION OF CONCERNS IDENTIFIED IN THE REPORT WERE SUBSEQUENTLY ISSUED ON OCTOBER 14 AND ON
- DECEMBER 23, 1983 AS SUPPLEMENTS 19 AND 20. FINAL STAFF ANALYSIS 0F MATTERS RELEVANT TO FULLPOWER OPERATION OF THE PLANT WILL BE FORTHCOMING.
( IHE NRC STAFF CONCLUDED IN SUPPLEMENT 18: (1) THAT THE IDVP HAD MET THE REQUIREMENTS AND OBJECTIVES OF THE DESIGN VERIFICATION
. EFFORT, (2) THAT THE DESIGN VERIFICATION EFFORTS BY THE IDVP AND PG8E HAD IDENTIFIED ALL SIGNIFICANT DESIGN DEFICIENCIES, AND (3)
THAT APPROPRIATE CORRECTIVE ACTIONS HAD BEEN AND WERE BEING TAKEN TO ENSURE THAT THE DESIGN OF DIABLO CANYON UNIT 1 CONFORMS TO THE LICENSING CRITERIA.
e e e LICENSING AND HEARING PROCESS - ,.
THE LICENSING REVIEW ACTIVITY IS FOLLOWING A THREE-STEP LICENSING f PROCESS. THIS PROCESS WAS PROPOSED BY PG8E AND APPROVED'5Y THE
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, MABLO CAliYON TESTIliONY 6- (REVISED 1/2078F5Tno P .- aa 4- .,,
COMMISSION IN DECEMBER 1982. IN THIS PROCESS THE REINSTATEMENT C,,', OF _THE LOW POWER LICENSE AND I,SSUANCE OF THE FULL POWER LICENSE ,
WERE~TO BE ACCOMPLISHED IN THE FOLLOWING STEPS:
STEP 1: A DECISION REGARDING THE LOADING 0F FUEL INTO THE' REACTOR' VESSEL AND PERFORMANCE 0F PRECRITICALITY:
TESTING. (THE REACTOR IS IN THE SUBCRITICAL CONDITION, AND THEREFORE NO FISSION PRODUCTS ARE GENERATED).. ,
STEP 2: A DECISION REGARDING CRITICALITY AND OPERATION AT A POWER LEVEL UP TO 5 PERCENT.'
/ STEP 3,: A DECISION REGARDING THE ISSUANCE OF THE FULL,
- ~
POWER LICENSE. -
AT AN OPEN MEETING ON OCTOBER 28, 1983 THE COMMISSION CONSIDERED THE MATTERS RELATED TO THE REINSTATEMENT OF THAT PORTION OF THE LOW POWER LI' CENSE THAT AUTHORIZED FUEL LOADING AND COLD SYSTEM TESTING. PRESENTATIONS WERE MADE BY OUR STAFF, PG8E, AND THE JOINT INTERVENORS. ON NOVEMBER 8 THE COMMISSION AUTHORIZED PG8E TO COMMENCE FUEL LOADING AND CERTAIN PRECRITICALITY TESTS (COLD SYSTEM TESTING). THIS DECISION ENCOMPASSED ONLY A PORTION OF THE ; ;
STEP 1 AUTHORIZATION. THE REMAINING ELEMENT OF PG8E'S .
PRECRITICALITY TESTING PROGRAM, THAT IS, HOT SYSTEM TESTING, WAS
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N._/ FULL STEP 1 AUTHORIZATION. . .
PG8E STARTED THE FUEL LOAD OPERATIONS ON NOVEMBER 15 FOLLOWING THE U. S. COURT OF APPEALS DENIAL OF A STAY REQUESTED BY THE JOINT-INTERVENORS. FUEL LOAD OPERATIONS WERE COMPLETED ON
-NOVEMBER 20 AND THE REACTOR VESSEL HEAD WAS BOLTED DOWN ON NOVEMBER 29. PGaE HAS NOW COMPLETED COLD SYSTEM TESTING.
ON JANUARY I4,198l4, PG&E REQUESTED AUTHORITY TO CONDUCT FURTHER PRECRITICALITY TESTING IN THE HOT SHUTDOWN AND HOT STANDBY CONDITION. SUCH ACTIVITIES ENCOMPASS THE REMAINDER OF STEP 1.
THE REACTOR WILL NOT BE PERMITTED TO ACHIEVE CRITICALITY AND
/ FISSION PRODUCTS WILL NOT BE GENERATED. SUCH OPERATION ALLOWS _m
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FURTHER TESTING OF SYSTEMS 'AND COMPO.NENTS AT ELEVATED '
I ., TEMPERATURES, INCLUDING, FOR EXAMPLE, A CHECK FOR THERMAL .
EXPANSION OF PIPING AND EQUIPMENT. PG&E HAS INFORMED US IT EXPECTS DIABLO CANYON UNIT 1 TO BE READY FOR SUCH TESTING ACTIVITIES THIS WEEK. WE HAVE ALSO BEFORE US A REQUEST BY PGaE TO IMPLEMENT STEP 2 0F THIS PROCESS, THAT IS, TO PERMIT CRITICALITY AND LOW POWER OPERATION. WE HAVE TENTATIVELY ,
SCHEDULED A MEETING FOR FEBRUARY 10TH TO DISCUSS THIS REQUEST WITH THE PARTIES TO THE LICENSING PROCEEDING . _ l REGARDING THE HEARING PROCESS, THE ATOMIC SAFETY AND LICENSING APPEAL BOARD CONDUCTED A HEARING ON THE REOPENED ISSUE OF DESIGN
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QUALITY ASSURANCE IN NOVEMBER OF LAST YEAR IN AVILA BEACH, CALIFORNIA. AT THE HEARING, EVIDENCE,0N A NUMBER OF ,
DESIGN-RELATED ISSUES WAS PRESENTED BY OUR STAFF, PG8E, GOVERNOR DEUKMEJIAN AND THE JOINT INTERVENORS. ALL PARTIES HAVE FILED PROPOSED FINDINGS WITH THE APPEAL BOARD AND A DECISION IS EXPECTED IN THE NEAR FUTURE. THE COMMISSION HAS NOT YET DECIDED
.WHETHER TO AWAIT THAT APPEAL BOARD DECISION BEFORE ADDRESSING PG8E'S REQUEST FOR AUTHORITY TO GO CRITICAL AND CONDUCT LOW POWER TESTS. AS A SEPARATE MATTER, THE APPEAL BOARD DENIED MOTIONS BY THE GOVERNOR AND THE JOINT INTERVENORS TO REOPEN THE HEARING ON CONSTRUCTION QUALITY ASSURANCE ISSUES. THE OPINION EXPLAINING THAT DECISION WAS ISSUED IN DECEMBER, APPEALED BY BOTH THE
~ GOVERNOR AND THE INTERVENORS, AND IS PR'ESENTLY UNDER CONSIDERATION BY THE COMMISSION. ,.
. . . . ~L' STATUS OF ALLEGATIONS
. FINALLY, 1 NOW WILL DISCUSS THE MATTER OF DESIGN AND CONSTRUCTION ALLEGATIONS THAT HAVE BEEN RAISED REGARDING THE DIABLO CANYON PLANT. AS OF THE END OF 1983, APPROXIMATELY 100 SEPARATE CONCERNS HAD BEEN IDENTIFIED. THE ALLEGATIONS WERE RECEIVED FROM A VARIETY OF SOURCES, INCLUDING PRIVATE CITIZENS, FORMER AND ;_
CURRENT WORKERS AT THE PLANT AND AT THE PGaE OFFICES, NEWS MEDIA, -
INTERVENORS, AND CONGRESSIONAL OFFICES. IN SOME CASES, THE SOURCE HAS REMAINED COMPLETELY ANONYMOUS; IN OTHERS THE SOURCE IS
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PUBLICLY 'DENTIFIED. ,
IN LIGHT OF THE NUMEROUS ALLEGATIONS, OUR STAFF ESTABLISHED AN ALLEGATION MANAGEMENT PROGRAM FOR DIABLO CANYON TO BETTER COORDINATE THE ACTIONS OF THE VARIOUS NRC 0FFICES. THE PROGRAM WILL PROVIDE A CLEARER UNDERSTANDING OF EACH ALLEGATION, A DETAILED TECHNICAL REVIEW OF THE APPROPRIATE AREA 0F THE ALLEGATION, AND ON-SITE INSPECTIONS AND DISCUSSIONS WITH THE ALLEGER AS NECESSARY. A STATUS OF THESE EFFORTS AS OF LATE
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DECEMBER WAS ISSUED AS SAFETY EVALUATION REPORT SUPPLEMENT 21. I WOULD NOTE THAT A SECOND PART OF THIS DOCUMENT WAS ISSUED WITH A LIMITED DISTRIBUTION IN ORDER TO PROTECT THE ANONYMITY OF SOME I. ALLEGERS AND TO ASSURE THAT NRC'S ONGOING INVESTIGATION EFFORTS
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WOULD NOT BE IMPEDED. -
WE ARE DETERMINED TO REVIEW AND EVALUATE EACH ALLEGATION AND TO RESOLVE EACH ALLEGATION INSOFAR AS IT IS RELEVANT TO PARTICUL/R STAGES OF OPERATION SUFFICIENTLY TO PROVIDE REASONABLE ASSURANCE OF SAFETY BEFORE AUTHORIZING EACH SUCH STAGE OF OPERATION.- MOST i
0F THE ALLEGATIONS HAVE BEEN EXAMINED IN SUFFICIENT DETAIL TO ALLOW THE NRC STAFF TO CONCLUDE THAT THEY DO NOT PRESENT A SIGNIFICANT SAFETY ISSUE OR REQUIRE FIXES OR REPRESENT A .
SUBSTANTIAL BREAKDOWN OF MANAGEMENT OR QUALITY CONTROL SYSTE,MS. ..
l THE STAFF NOTES, HOWEVER, THAT THESE'ARE THE ALLEGATIONS THAT WERE MOST AMENABLE TO RESOLUTION.
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I'.ANY OF THE REMAINING ALLEGATIONS HAVE EEEN PARTIALLY EXAMINED.
THEY INVOLVE MORE COMPLEX AND. DIFFICULT ISSUES. IN ADDITION, WE .
CONTINUE TO RECEIVE NEW ALLEGATIONS. THE STAFF HAS NOT YET DETERMINED WHETHER ANY SIGNIFICANT SAFETY ISSUE OR SUBSTANTIAL BREAKDOWN OF MANAGEMENT OR QUALITY CONTROL SYSTEMS WILL EMERGE FROM THE CONTINUING EVALUATION OF THE ALLEGATIONS. THESE ALLEGATIONS INVOLVE SUCH ISSUES AS SMALL BORE PIPING, ANCHOR BOLT
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' INSTALLATION, CONSTRUCTION RECORDS CONTROL, INSPECTOR QUALIFICATIONS AND HARASSMENT OF PERSONNEL. OUR STAFF HOPES TO COMPLETE ITS EXAMINATION OF MOST OF THESE ALLEGATIONS AND TO DRAW A CONCLUSION IN THE NEXT FEW WEEKS.
BASED ON THE ALLEGATIONS ALREADY REVIEWED, THE STAFF IDENTIFIED l SOME ACTIONS THAT IT BELIEVES SHOULD BE COMPLETED PRIOR.TO A... . _.
~
DECISION REGARDING AUTHORIZING CRITICALITY. SEVERAL OTHER ACTIONS HAVE BEEN IDENTIFIED FOR COMPLETION PRIOR TO AUTHORIZING OPERATION ABOVE 5 PERCENT POWER. THERE MAY BE ADDITIONAL ACTIONS IDENTIFIED AS THE STAFF COMPLETES ITS EXAMINATION. COMMISSION
. REVIEW OF THE STAFF ANALYSES AND RECOMMENDATIONS IS IN PROGRESS.
IN CLOSING, I WANT TO ASSURE YOU THAT, WHILE PG8E EXPECTS TO BE READYTOPROCEEDTOCRITICALITYSHORTLY,WEWILLNOTAdTHORIZE ANY SUCH ACTIVITY UNTIL WE ARE SATISFIED THAT THERE IS REASONABLE 2.
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ASSURANCE THAT THE HEALTH AND SAFETY OF THE PUBLIC IS ADEQUATELY, PROTECTED.
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The Honorable Nunzio Palladino Chairman United States Nuclear Regulatory Commission Was'hington, D.C. 20555
Dear Mr. Chairman:
Pursuant to the Committee's ongoing the inquiry Diab into the functioning 1: Canye Nuclear of the nuclear regulatcry process a the following informaticn:
Power Plant, I am writing to request Please summarize the status of the staf f 's inquiry into "
allegations ,that pipe support calculations were not l.
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performed in accord with the requirements of the NRCif any, will be modi -
Which piping systems, regulations.as a result of errors in the p'ipe support calculations?
inspectors at Diablo Canyon were 2.
It has been alleged thatinstructed that they should not inspect welds supplied by vendors, even in situations where the welds Has appeared defective on the basis of virual observations. .
the Commission established If such instructions whether were issued,such whatinstructions was the were issued?
purpose and did they constitute a violation of the Commission's QA requirements?
- 3. With respect to the findings of ongoing inquiries, SSER 21 evidence w (P. E-13,14) states that ... no direct by the interviewees concerning experiencing or knowing ...
andofthat any corner cutting, intimidation or harassment management was " responsive and supportive " of emplo ~j concerns.
that would cause the staff to change SSER 21's findings -
regarding harassment and intimidation?
into
- 4. What is the nature of ongoing investigations When did the allegations of intimidation and harassment?
(s Of fice of Investigations initiate its investigation inteHow this matter? will the investigation ce complete?
the task? When S40229037o g40222 hDRADOCK 03000275 PDR
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- 5. Does the Commission believe that PG&E fulfilled its
_) commitment to comply with the Commission's regulations .
pursuant to Appendix B of 10 CFR 50 in the design and construction of the Diablo Canyon powerplant?
- 6. Were the QA requirements committed to by PGEE vis-a-vis Diablo Canyon significantly different from requirements committed to by utilities that received construction permits in 1972? In 19757
- 7. Was full documentation demonstrating compliance with the
, Commission's QA requirements turned over to PG&E by Pullman Power Products and the Foley Company prior to issuance of the low power Operating License in September 1981?
- 8. Does PG&E'(as opposed to its contractors) possess now a comprehensive collection of the records (e.g. work
. packages) indicating that specific tasks (e.g. specific welds) were carried out in accordance with the NRC's quality assurance requirements? If not, when will such records be turned over to PG&E?
- 3. What specific rewcrk has been required at Diable Canyon as a result of inquiries, undertaken since Septender 1983, into allegations of f ailures to comply with desig. or
-s construction QA requirements? What is the time schedule for completing such work?
- 10. The following refers to the summary findings of tne Pullman audit of Pullman Power Products conducted by Nuclear Services Corporation (NSC) in 1977.
- a. What is the Commission's assessment of these findings?
- b. To what extent do these findings indicate significant . ,*
violations of the NRC's QA requirements?
- c. Please describe the nature of inquiries conducted , to '
, determine whether the'NSC findings were valid and if so, what the implications mi'ght be? Please provide all reports prepared by NRC staff and contractors in "
conjunction with the staff's assessment of NSC's - -
findings.
- d. The Pullman audit states on Page 22 under Item 10 that control of the welding process was inadequate in -~ )
several respects. During what pericd, if any, did such ,.
deficiencies' exist? If the deficiencies listed under Item 10 did exist, what is the basis for a
, determination that weld quality is that required by the Commission's regulations? Doess documentation exist to
, demonstrate the adequate resolution cf che alleged deficiencies listed under :te: 107
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- e. The, Pullman audit states on page 25 that "
. . . there is no confidence that welding done prior to early 1974 was ,
performed in accordance with welding specification requirements?" Does the Commission have documentation to refute this finding? If not, what is the basis for a finding that, for welds produced prior to early 1974, weld quality was that required by the Commission's*
regulations? ,
- f. ' Do the Commission's regulations require prompt reporting to the NRC of findings such as those listed in the NSC audit of Pullman Power Products? Did the failure to promptly report the NSC findings constitute a violation of the Commission's regulations?
I would appreciate receiving the Commission's response to the foregoing questions (including additional views of individual Commissioners) prior to April 1, 1984.
Thank you for your assistance.
Sincerely, T[f' MORRIS K. UDALL
. Chairman .. .,
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'jprics or THE . June 13, 1984 CHAIRMAN _
The Honorable Morris K. Udall Chaiman Comittee on Interior and Insular Affairs
- U.S. House of Representatives Washington, D.C. 20515
Dear Mr. Chairman:
PursuanttoydurFebruary 22, 1984 request for answers to ten questions related to the functioning of the nuclear regulatory process at the Diablo Canyon Nuclear Power Plant, I have enclosed our responses.
I trust that these answers are responsive to your questions.
Thank you for your interest. _ ,
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Sincerely,
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. T Nunzio Palladino Chairman
Enclosures:
As stated e
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QUESTION 1:' Please summarize the status of the staff's inquiry into allegations that pipe support calculations were not performed in accord with the requirements of the NRC regulations. Which piping systems, if any, will be modified as a result of errors in the pipe support calculations?
Answer.
l As a result of the Independent Design Verification Program (IDVP) the p ping and piping supports, both small bore (i.e., less than 2.5 inch diameter and 1 large bore were reviewed by Pacific Gas and Electric Company's (PG&E) Diablo CanyonProject(DCP). The results of that effort were reported in Supple-i ment 18 of the Safety Evaluation Report (SSER 18). Resolution of some issues identified were addressed in SSER 19 and SSER 20. In late 1983 a I number of allegations were made regarding the adequacy of design piping and !
piping supports, in particular for small bore piping. On March 19 of this year the NRC issued SSER 22 which summarized in Section 5.1 the status of i the staff evaluation of allegations on small bore piping as follows:
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! "The principal technical finding is that the analyses performed by '
!g ' computer for small bore piping supports have been detemined to have an unexpectedly large error rate, on the order of twenty percent as l
compared to ten or less percent that experience has shown is likely.
On the other hand the error rate in the hand calculations for small
- . bore piping supports was acceptably low. In light of these findings
- the staff will require that PG&E establish a program to review all j computer analyses for small bore piping supports."
l "In partial response to those staff findings the licensee has j reported the results of a review of approximately 130 small bore l
piping support computer analyses including the analyses in which the ,
. staff has previously identified errors. The licensee reported that, with errors corrected where necessary, all completed calculations
' showed final acceptability of the supports. The staff concluded a special inspection to evaluate the process used to re-review the small bore piping calculations packages."
"We found with minor exception, that the review process was compre-
! hensive, was being carried out by qualified individuals, and was conducted in a manner to assure that the results could be accepted
. with high confidence." ;,
" Analyses of the type and significance of the deficiencies seen to date has led the staff to conclude that, although the dt. sign QA program for the OPEG is not up to acceptable standards, the impact in terms of design adequacy, has not been significant." .
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" Based on the results of the staff's review to date and'the types of errors that have been identified it is very likely that modifica-tions, if any, would be minor and only to fully meet seismic criteria with little or no impact on ope,rability of systems under the full range.of plant operations. Since some piping support modifications are nomally required as a result of initial plant operation, due to unexpected thermal motions or operating require-ments of attached or supported equipment, there is sound logic in conducting the required calculations review during low power ope' ration so that any resulting modifications could be included in a -
orderly and consolidated program prior to . full power operation."
On March 26 and 27, 1984 the staff briefed the Comission on a number of issues related to the reinstatement of the suspended low power license.
Among other matters, the staff addressed the issue of small bore piping as presented in SSER 22 and stated above. At the meeting Mr. Isa Yin of the NRC staff informed the Comission of the results of his conclusions -
regarding inspection and audit activities he performed at the D.iablo Canyon c p, site and at the PG&E engineering offices in San Francisco. A copy of Mr.
3 Yin's. prepared statement at.the meeting is attached. He concluded that
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Diablo Canyon Unit I should not be permitted to go critical. and perform low power operations until his concerns have been appropriately addressed.
.We directed the staff to further review and evaluate these' matters and in particular address each of Mr. Yin's concerns. Furthermore, we requested the Advisory Comittee on Reactor Safeguards (ACRS)toreviewtheareaof
, disagreement and to provide us.with their evaluation by April 10, 1984. On
. April 5 - 7, 1984, the ACRS reviewed the technical issues arising from the Diablo Canyon licensee's design . control measures for small and large bore piping. During this review members of the NRC staff, including NRC Inspector Isa Yin, representatives of PG&E and of the IDVP organizations, and Mr. Charles Stokes, a member of the public, gave presentations. In a letter dated April 9,1984 (attached.) the ACRS provided their recomenda-tions on this and the additional coments of three members. The ACRS
'recomended that low power operation be permitted and that the several actions proposed by the NRC staff for completion before operation ab~ove five percent power will provid.e a suitable basis for considering operation at full power. At this time we do not consider the issue of small bore piping ,
and supports resolved. We have not determined that piping system modifica- -q tions, if any, will be required as a result of these efforts. ,,
The Comission approved a low power licenie for Diablo Canyon on April 19, 1984. .,
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9 QUESTION 2: It has been alleged that inspectors at Diablo Canyon were instructed that they should not inspect welds on materials supplied by vendors, even in situations where the welds appeared defective on the basis of visual observations. Has the Commission established whether such instructions were issued? If such instructions were issued, what was the.
purpose and did they constitute a violation of the t Commission's QA requirements?
- ANSWER.
' The staff has established that instructions were issued in an April 3,1980 memorandum to Pullman Power Products (PPP) stating, in part, that " Pullman need not report further test results on shop welds."
To put the memorandum in perspective, it is import' ant to understand wha.t was
- occurring at Diablo Canyon at the time. In late 1978, cracks were detected by visual inspection of pipe rupture restraint welds made by PPP in the
/, . ' Unit 1 pipeway structure. The welds in question involved high strength !
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alloy steel'not widely used. The. welds were in thick sections and thus ,
L highly restrained. The weld defects in question apparently displayed a
, delayed cracking phenomena which was not imediately noticeable at the time i of welding.. This is sometimes a problem with high strength alloy steel. On May 3,1979, PG&E issued a 10 CFR 50.55(e) construction deficiency report to -
the NRC.
> A substantial repair and testing program was initiated to identify the type, 1
cause and extent of the defects. The program included Ultrasonic Testing (UT) of a sampling of these Pullman high strength welds. Problems were fo0nd during the~ initial repair and testing program such that PG&E expanded I
- the program in order to form a data base to establish the adequacy of these welds. The repair program was a large scale effort well known to PG&E and i Pullman welding personnel. The effort was extensively reviewed by NRC. On
- December 9,1980, PG&E issued their final 10 CFR 50.55(e) report for Unit 1, I which sumarizes the background, scope and results of actions taken.
During the evaluation and repair of field welds, a parallel program to examine pipe rupture restraint vendor welded materials (shop welds) was
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implemented. Vendor welds made with the self-shielded, flux core process were found to be a particular problem. PG&E reviewed all joints where these electrodes had been used. Discrepancies were found and repairs were made.
i e i By April,1980, PG&E had sufficient data on the other types of shop weld
. defects to make an engineering evaluation and concluded that the type of j
(' indications found were not a problem. They consequently notified Pullman that they had enough data. '
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Taken in proper context, it would appear that the April 3,1980 memorandum
, was written with sufficient information to be understood by those involved in the large scale repair and test program. In fact, the April 3.1980 memorandum stated that PG&E believed that sufficient data on shop welds existed to preclude the need for Pullman welding inspectors to report further inspection findings on shop welds. ,
Some in Pullman appear to have been concerned that this April memorandum meant that unless the shop weld defects directly affected their work they
- were to ignore the defect. Over time, while the repair program was completed on Unit 1 and continued on Unit 2, confusion crept in and prompted
. PG&E to issue a July 26, 1982 letter to Pullman to clarify the intent of the April 3, 1980 memorandum.
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The July 26, 1982 letter states that unless a shop weld defect directly affects Pullman work, there is no need to address that defect because of the 1 extensive. engineering evaluation discussed above. The letter also sta.tes that shop weld defects not directly affecting Pullman's work should be reported separately and turned over to PG&E.
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- s. . To address the issue of whe'ther or not there were shop welds that were
- i ignored between April 3,1980 and July 26, 1982, the staff ~ interviewed six 4 welding inspectors. This' represents an estiniated 20 percent sample of weldin.g inspectors on site.during that interval. Five of the' interviewees were on site during this subject time frame. All of the interviewees stated that they were aware of PG&E's engineering evaluation which accepted all t
- shop welds. They also stated, however, that shop weld defects were reported '
.when noticed by issuing a DCN (Deficient Condition Notices) and that final walkdown packages included this infonnation.
2 i In sunnary, it is the staff's opinion.that the technical aspects of this
- = issue were handled properly and that PG&E's April 3,1980 memorandum was
- proper when taken in context. Later, confusion apparently spread so PG&E i responsibly responded to that confusion in their July 26, 1982 letter to Pullman.
l Finally, the April 3,1980 memorandum which included instructions to Pullman
- to not. report further results on shop welds did not violate the Connission's l QA requirements. .
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1 QUESTION 3: With' respect to the findings of ongoing inquiries, SSER 21
- i (P. E-13,14) states that "...no direct evidence was offered by the interviewees concerning experiencing or knowing of any corner cutting, intimidation or harassment..." and that management was " responsive and supportive".of employee <
concerns. Does the XRC now possess substantial evidence that would cause the staff to change SSER 21's findings .
regarding harassment and intimidation't ANSWER.
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Based on the staff work in this area it appears that a few individuals feel strongly that they have been directly intimidated. Some have offered specific and detailed reports in support of their allegation. These cases are complex. The staff could not readily tell whether the cases involve intimidation, proper exercise of managernent prerogatives, or just. poor consnunication. As appropriate, these few cases (eight total) are being addressed through the Department of Labor regulatory process, and/or review by the NRC Office of Investigations. A few additional individuals were
, xi concerned about intimidation but indicated their views stenened from events not directly related to their own experience, such as: general perceptions that the pressure was on to get the job done; rumors of the layof.f or firing of another. employee as a result of writing a nonconformance report; or, media reports of intimidation. The staff does not detect any widespread company attitude to suppress employee concerns or corrupt the overall effectiveness of the Quality Assurance Prof l ram. The staff also found in the conduct of the vast majority of personnel ' nterviews that employees were not i afraid to identify and deal with quality problems in a responsible manner.
l both within their own organizations and with the NRC.
The staff concludes that a widespread suppression problem does not exist at Diablo Canyon, however, the staff is concerned with employee perceptions in this area. Licensee management shtres this concern. The staff has' reviewed
- this subject with licensee management and notes that the licensee has undertaken steps to make improvements. This effort includes such actions as the development of video tape presentations for all existing and new
. employees regarding surfacing of quality concerns; an "800" telephone number for receiving quality concerns; and a system for receipt and resolution of concerns. The licensee's activities in this area will be monitored by the
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o QUESTION 4: What is the nature of ongoing investigations into allegations of intimidat on and harassment?
ANSWER.
OI presently has eight investigative matters involving, either singularly or collectively, intimidation, harassment, and threats. These investigations involve allegations of threats of physical harm; firing of individuals, transferring of persons who raise questions to other jobs; oral reprimands -
to persons who raise issues; directing quality. control inspectors to disre-gard violations on the grounds defects will be caught by other depart-ments; persons who have used the hotline to report concerns have been contacted by a construction superintendent and either told directly he did not like the person's complaint or questioning' the persons about their call giving them a definite chilling effect about using the hotline; and supervisors instructed not to discuss matters any further with management.
.. . QUESTION 4: When did the Office of Investigations initiate its investigation into this matte.r?
ANSWER'. .
The Office of Investigations became involved with the series of allegations
. ' referred to in the referenced letter as "this matter" in early December 1983. Initially, the Investigators listened to the testimony of one of the allegers to determine if any of his concerni came under 01's jurisdiction.
Following this interview,11 investigative matters involving Diablo Canyon were opened by the Office of Investigations.
As of March 23, 1984, the Office of investigations has 17 pending investiga-tive matters involving Diablo Canyon. In. addition, the Office of Investigations is just beginning a review of approximate 1 54 allegations that may fall under the Office of Investigations jurisdic ion. These allegations have to be further evaluated by 01 as to whether or not they should best be investigated by the Office of Investigations. , ;
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Q QUESTION 4: How many Investigators have been assigned to' the task?
ANSWER. ,
01 presently has two Investigators (01's total investigative compliment based in 01's Region V Field Office) assigned to investigating allegations against a vendor who supplied fabricated steel to Diablo Canyon. ' Assisting these two investigators is a Vendor Inspector specialist from Region IV and a Reactor Inspector, who is a metallurgist from Region V. Two 01 Investigators have been detailed initially for 90 days from OI's Region II office to work on the pending investigations at Diablo Canyon. The first of these two investigators reported to the 01 Region V Field Office on March 5, 1984. They began their work as a team at Diablo Canyon on March 12, 1984.
The majority of the 01 Field Office Director's time for Region V has been dedicated to supervising 01's investigative efforts concerning Diablo Canyon since early December 1983. - -
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QUESTION 4: When w'ill the investigation be complete?
ANSWER.
01 is addressing the numerous allegations as individual investigative matters and not as one investigation as most of these matters are not interrelated. Because of the number and variety of investigative matters involved, it is impossible to forecast a completion date with any degree of accuracy.
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QUESTION 5: Does the Comission believe that PG&E fulfilled its comitrent to comply with the Comission's regulations
- purs;ar.: to Appendix B of 10 CFR 50 in the design and constru: tion of the Diablo Canyon powerplant?
ANSWER.
The Commission believes that PG&E has sufficiently fulfilled its quality assurance comitments to allow restoration of the low power testing authorization. The Comission is aware that there have been instances of
. non-compliance with these comitments. The significance of this must be decided in reaching a decision on full power operation.
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QUESTION 6: Were the QA' requirements comitted to by PG&E vis-a-vis Diablo Canyon significantly different from requirements comitted to by utilities that received construction permits in 1972? In 1975? .
ANSWER.
The QA requirements comitted to by PG&E for the design and construction of Diablo Canyon generally reflected the evolving NRC regulations such that the
- PG&E comitments during 1972 were comparable to comitments of utilities that received construction permits in 1972.
Utilities whose Preliminary Safety Analysis Reports were reviewed after detailed NRC guidance on QA was issued in the 1973-1974 time period
- were required to comit to meet the guidance or provide specific detailed alter-natives. PG&E and other utilities with construction pemits issued be. fore the guidance were not required to comit to meet the guidance during the design and construction of their plants.
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- Guidance issued during this time period included the following " WASH" documents:
Design and Procure-(a) "ment Guidance Phaseon Quality Assurance of Nuclear Requirements Power Plants," June 7,1973During(WASH-1283) and
. Rev. 1, May 24, 1974 (b) " Guidance on Quality Assurance Requirements During the Operations Phase of Nuclear Power Plants," October 26, 1973 (WASH 1284).
i (c) " Guidance on Quality Assurance Requirements During the Construction 4 . Phase of Nuclear Power Plants," May 10, 1974 (WASH 1309).
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4 00ESTION 7: Was full documentation demonstrating compliance with th'e Commission's QA requirements turned over to PG&E by Pullman Power Products and the Foley Company prior to issuance of the low power Operating License in September 1981?
ANSWER.
No. Pullman Power Products and Foley had not turned over to PG&E all documents demonstrating compliance with the Commission's QA requirements-prior to issuance of the low power Operating License in September 1981, because they were still on site and performing work.
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2 QUESTION 8: Does PG&E (as opposed to its contractors possess now a comprehensive collection of the records e.g.workpackages) indicating that specific tasks (e.g. specific welds) were carried out in accordance with the NRC's quality assurance requirements? If not, when sill such records be turned over to PG&E?
ANSWER.
PG&E (as opposed to its contractors) does not now possess a comprehensive collection of the Unit I records indicating that all specific tasks were carried out in accordance with the NRC's quality assurance requirements.
. Some contractors who worked at Diablo Canyon have completed their contrac-tural requirements, but are no longer engaged in work at the site. Prior to their departure, PG&E took custody of all quality records generated by.-that contractor.
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PG&E does not currently have custody of all quality records generated by N- contractors currently engaged in quality related work at Diablo Canyon (Pullman and H. P. Foley). These Unit I records are in the process of being turned over to PG&E.
Prior to exceeding 5% power, all H.P. Foley and Pullman Power products quality related records will be turned over to PG&E with the exception that records for work in progress will be turned over within 60 days of work '
j completion.
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4 QUESTION 9: What specific rework has been required at Diablo Canyon as a result of inquiries, undertaken since September,1983, into allegations of failures to comply with design or construction Q.A. requirements? What is the time . schedule for completing such work?
ANSWER.
Post September 1983. review of allegations.and NRC inspection items concerning allegations has resulted in the following minor modifications and repairs:
- 1. PG&E review of small bore pipe support number 100-111, identified for NRC review by an alleger, resulted in a modification. The support provides restraint of the valve operator and the pipe at the valve. The modification was the addition of an axial restraint at the pipe tu prevent transfer of forces to the operator in the axial direction. This change'was made for consistency with Project standard practices even
( though analysis showed the change was not necessary to meet acceptance
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- 2. One 1/2 inch diameteh electrical raceway ' anchor bolt was replaced during the audit of concrete anchor bolt embedment. The original bolt was removed to verify, by physical measurement, the depth of embedment as indicated by ultrasonic measurement. The replacement bolt was fully embedded; however, engineering analysis would, in all probability, have -
shown qualification of the initial installation. Thirty-nine similar installations were analyzed and adequate safety factors were demon-strated as reported in PG&E letter DCL-84-059, dated February 16, 1984.
3 '. The NRC review of allegations related to electrical wire traceability led to the following change: Approximately eighty-four feet of
. Continental HTR wire, installed in the Control Room Positive Pressure Ventilation System was replaced. The wire was documented to be 4
qualified and of the proper type and color code, however traceability to the source (wire reel) was not established. This is discussed in PG&E letter DCL-84-066, dated February 17, 1984.
'4. Eighty ASTM A325 bolts were welded'to the Unit 1 containment fan cooler support structure in order to mount component cooling water pipe supports. Although these installations had been verified to be capable
. of meeting design. assumptions, the licensee elected to weld the support plates to the fan coolei supports; thus, removing the welded bolts from the support-loads. This was done to provide added assurance of pipe support adequacy throughout plant life.
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In addition to the above . listed items, the investigation of allegations has resulted in extensive records review and some engineering analysis and testing to demonstrate the acceptability of existing installations.
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QUESTION 10: The following refers to the sunnary findings of the Pullman audit of Pullman Power Products conducted by Nuclear Services Corporation (NSC) in 1977.
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(a) Wha't is the Commission't assessment of these findings?
- ' ANSWER.
The staff's: assessment is provided in the.following NRC Inspection Reports:
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- a. Report Nos. 50-275/83-37,50-323/83'-25; paragraph 44
- b. Report Nos. 50-275/83-34,50-323/83-24; paragraphs 4.a, 4.b and 4.c NRC' Inspection Report Nos. 50-275/83-37, 50-323/83-25 (paragraph 44) states, in part, the following:
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/'~' ' "Although, the NRC has . identified a potential violation (paragraph 17)
). ;, . during this inspection, regarding the qualification of Pullman visual welding inspectors, this item is of reduced significance since all but two of the inspectors'had adequate backgrounds and experience in the areas of welding or quality control. inspection. It does not appear that this problem was chronic or widespread.
It is the staff's opinion that.the NSC audit findings do not provide a basis for concluding that the Pullman-Kellogg Quality Assurance Program suffered a major breakdown during- the time period prior to the NSC audit. Furthermore, based on this significant sample of the most i important NSC findings .it is concluded that examination of the remaining
.- items is not warranted."
The staff's findings, documented in ORC Inspection Report Nos. 50-275/83-34, 50-323/83-24, did not identify any instances of regulatory noncompliance on programmatic quality assurance deficiencies.
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QUESTION 10(b): To what extent do these findings indicate significant violations of the NRC's QA requirements?
ANSWER.
NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25 identifies, in paragraph 17 and Appendix A, one violation regarding the qualification of Pullman visual welding inspectors. Paragraph 44 of that same report further states that "this item is of reduced significance since all but two of the inspectors had adequate backgrounds and experience in the areas of welding or quality control inspection. It does not appear that this problem was chronic or widespread."
Also, NRC Inspection Report Nos. 50-275/83-34,50-323/83-24 documents that no items of noncompliance or deviations were identified in the area of compliance with QA requirements. . .--
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OUESTION 10(c): Please describe the nature of inquiries conducted to determine whether the NSC findings were valid and if so, what the implications might be? Please provide all reports prepared by NRC staff and ~ contractors in conjunction with the staff's assessment of NSC's findings.
ANSWER.
The nature of the staff's inquiries and assessments are described in NRC Inspection Report Nos. 50-275/83-37, 50-323/83.-25 and 50-275/83-34, 50-323/83-24. Additionally, Attachment No.1 to NRC Inspection Report No. 50-275/83-37, 50-323/83-25 documents the work of an NRC consultant's (Parameter Incorporated) independent verification of field work and records for compliance with code rdquirements.
Based on the staff's inspection effort, as documented in the above ..__
referenced NRC inspection reports, the staff concluded that the Pullman Quality Assurance program did not suffer a major breakdown during the time period prior to the NSC aud.it.
The referenced NRC Inspection Reports 50-275/83-37, 50-323/83-25 and 50-275/83-34,50-323/83-24 are enclosed.
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- 17 QUESTION 10(d): The Pullman audit states on Page 22 under Item 10 that control of the welding process was inadequate in several respects. During what period, if any, did such deficiencies exist? If the deficiencies listed under Item 10 did exist, what is the basis for a determination that weld quality is that required by the Comission's regulations? Does-documentation exist to demonstrate the adequate resolution of the alleged deficiencies listed under Item 107 ANSWER.
The staff's assessment of the items referenced on page 22 under item 10 of the NSC Pullman audit are contained in NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25 paragraphs 34 and 18 through 30. One item, regarding welder BF (see second paragraph on page 23 of the NSC audit report) is addressed in paragraph 4.c of HRC Inspection Report Nos. ._
50-275/83-34,50-323/83-24. The basis for the staff's determinations are
- provided in these two inspection reports, wherein the staff concludes that
/ isolated welding discrepancies were identified and corrected by the Pullman
.(, welding program. However, the staff concluded that the aggregate of problem areas were not so pervasive as to support the NSC conclusion that "There is no confidence that welding done prior to early 1974 was performed in accor-dance with welding specification requirements."
The referenced NRC Inspection Reports, including Inspection Report 50-275/84-16, provide the basis for the staff's assessment and conclusions regarding the alleged deficiencies listed under Item 10 of the NSC Audit'
-Report. The documentation reviewed by the staff in forming this conclusion is identified in Inspection Report 50-275/84-16 and those documents exist at the Diablo Canyon site.
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QUESTION 10(e): The Pullman audit states on page.25 that "...there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification requirements?" Does the Commission have documentation to refute this finding? If not, what is the basis for a finding that, for welds produced prior to early 1974, weld quality was that required by the Commission's regulations?
ANSWER.- : .
The staff's documentation to refute the NSC finding is contained in NRC Inspection Reports No. 50-275/83-37, 50-323/83-25, and 50-275/83-34, 50-323/83-24. These reports clearly document the staff's basis and conclusions. Also, as a result of discussion at the March 26 Commission meeting, the staff reviewed the Pullman audits and the Pacific Gas and
' Electric Company audits done in the pre-1974 time period in more detail, The results are reported in Inspection Report 50-275/84-16 in which the staff confirms that.the audit program met the requirements of Appendix B.
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, \s, The documentation reviewed 'by the staff on forming their conclusion exists at the Diablo Canyon site. ,
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QUESTION 10(f): Do the Commission's regulations require prompt reporting to the NRC of findings such as those listed in the NSC audit of Pullman Power Products? Did the failure to promptly report the NSC findings constitute a violation of the Conmission's regulations? -
ANSWER.-
The question of the .reportability of the NSC audit is addressed in the attached " Director's Decision under 10 CFR 2.206" which was issued by the Director of the Office of Inspection and Enforcement. The decision is currently pending before the Commission for its possible review in accordance with the provisions of 10 CFR 2.206(c).
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February 8, 1984 _
HoWSE ADMMSTRATION a" "" em. .
muonmr nacionAi.wwer Mr. Nunzio J. Palladino, Chairman U.S. Nuclear. Regulatory Commission Washington, D.C. 20555
Dear Chairman Palladino:
I am writing to thank the Commission for its contributicon to a recent hearing considering issue;s relative to licensing: of the Diablo Canyon nuclear power plant, and to express my corntinued interest in licensing and safety of the. plant.
At the January 24 hearing, the Commission provided subsitantial reassurances to the Energy and the Enviroriment Subcommitttee in w several respects. Chief among those reassurances to recceive my support is the Commission's view that design quality asssurance issues under review by the Atomic Safety Licensing Apperal Board may be fundamental to adequacy in the design verificatiton process at the plant. Consistent with this view, I antici7 ate :that con-sideration of a full-power license for the plant shouldi occur after the Appeal Board has concluded its review of design QA iissues under a?pesil, and after the Commission has had the opportunitay to review the Board's decision in this regard.
In addition, I welcome the formation by Commission stafif of a.
coordinated, systematic program to evaluate the numeroms allegations which'have been raised regarding the adequacy of qualit3y assurance and construction efforts at the Diablo plant, In general, the NRC's efforts to ensure the safety of DYiablo are commendable. However, the January 24 hearing left unresolved several issues which I would like to bring to the Commission's : attention.
In order to ensure that Ealuation of allegations regar.tding construc-
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tion'. quality asruranc'e at the plant is both thorough andCommission applicable .. ,
to .a licensing decision, I recommend that -- prior to at
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decision regarding licensing of the plant for post-critilcality testing and full-power testing -- the Commission provide guidellines governing I -
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Mr. Nunzio J. Palladino Page Two February 8, 1984 the evaluation of those allegations. I recommend that those- guide-lines ensure that staff: a.) provide particular attention to both prospective and historic implications of quality assurance deficiencies; b.) evaluate specific findings and patterns which develop from those specific findings, and; c.) ensure that determinations regardEing both
regulatory compliance and safety significance are made during resolution of claims.
In addition, I remain con.cerned ov'er an apparent tendency of engineering and other staff in quality assurance programs at Diablo 1 to assume that wide margins of safety established by Commission -
construction criteria need not be adhered to in systems which -- in-the staff's view -- are not pivotal to safety. This practices was described in testimony given by Commission staff at the January 24 hearing. I remain concerned by the implications of such a practice, which supplants the Commission's established standards of regulatory compliance with a less precise, ad hoc standard of safety.
In establishing the NRC, Congress placed in the Commission's hands the responsibility to ensure the safe design and construction of nuclear facilities. Now, as then, I look to the Commission to ensure compliance with its procedures in an effort to ensure the safety of those who live and work near licensed nuclear power facilities. I commend the Commission's successful efforts to achieve these- ends, but exhort it to employ the full range of its abilities to ensure the safety and compliance of the Diablo Canyon plant with current regulations.
l Thank you for your consideration of this matter. I look forw:ard to your response.
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