ML20151Q311
| ML20151Q311 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1988 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20151P665 | List: |
| References | |
| FOIA-84-21, FOIA-88-A-4 NUDOCS 8804260412 | |
| Download: ML20151Q311 (1) | |
Text
.
w k .
i LIST ALLEGATIONS - PREDECISIONAL OR SENSITIVE ALLEGAT10h OR
- CONCERN NO. CHARACTER!ZATION 1 Passing Contraband i
2 18 Anti-Nuclear Demonstration '
QA/QC Allegations 19 23 Guard Qualification ,
QA Inspector concerns l 24 HPFoley NCR's Rejected Without Good Cause
! 53 59 Welder Qualification i i
60 Foley lost Cable Traceability 61 Foley Purchased Material Things from Unapproved Vendors 61a Lack of Doc a nt Control 62 H. P. Foley used unapproved drawing 63 Foley Lacks Adeouate Sanpling of Cable Pull Activities Ioley Has Lcst Material Traceability Upgrading of Non-64 Class 1 to Class 1 Grout Test Sampling Based on Specific Test Rather than Field Tests 65 Foley Documents Prior to 1980 Questioned-No Review Reevired 70 Prior to 9/1981 license issuance 71 Inadequate Response to Notice of Violation 73 Use and Sale of Drugs -
Selling of Drugs 81 83 Individual Fired for Whistle-Blowing 96 NRC Was Not Effective in Identifying Problems 101 Improper Anchor Bolt Spacing ("Hilti" rnd ' Red Head")
103 Qualification of Welders and Procedures -
Welding and Welding Program Concerns 8804260412 680419 B$MA 8 A-4 PDR
[0 $.@ d.g g I
l 2
. * ' ,. C. 19 83 l'El'0RAtiDUt1 FOR:
George Knighton,*.RR Member Diablo Canyon Allegation Management Program Staff FROM:
Themis P. Speis, Director Division of Safety Technology DIABLO CANY0ft AMERATIDils (N0s. 7, 9, and 48)
SUSJECT:
Per your request of November 30, 1983, please find attached responses to Allegations Numbers 7,,9, and 48. Responses to numbers 7 and 48 were
- prepared by RRAB and the response to number 9 was prepared by GIB.
D
- Themis P. Speis, Directcr Division of Safety Technology
Enclosures:
Allegations 7, 9, and 43
\
'\
DISTRIBUTIO$ '
Central Files , .
GIB Rdg DST c/f .
TSpeis FSchroeder FRowsome .
KKniel AThadani NAnderson FCoffman DThatcher 4mDt:asherm -
g
- 7. NavJ K D- "GP T:D FSchroeder T e' 12/c /83 /83 C
/
g ~
~Q q l 6
\\l' g 0.oof /b& M \ ,
f DST:RRAB DST
. . . . . . .:RRAQ/c
.D. S.T
. .r.DST:RR........\.. . . . .
DST:GIB DST:GIBigQ . DST:GIB.g ............ ......
- e,,,en ... . . . . . . . . . .i. . . . .............. . . .
. . fman,,,, , ,A,,,a,@n......,
Th ,hsr
,t;xn,t e.1.,,/',. .p,(a s h,k.. .. . .,F. {.gf
. .oh.. .. . . . ,. . .Nbe.ds.rs6
. ..Msa.c.t 3 .,
u.-o 12/g /83 12/t. 83
..........j.'........
12/7/83. . ' . . . .12/7.../83
. . . . .... ... . . ., .12
... . /c.'.{/83 12
... ./.".//..'
am> 12/.09/.83 . . . . . . . . . . . . . . . .........}.............
~
o'
- ,c.u.e : r. n, r.nc.n:o OFFiCI AL RECORD COPY
Task:
Allegation # 7 HRR-83-02
_AT S . No_. !
Characterizationi i i Interaction of Seismic Category 11 structures and equipment ,
Category I structures and equipment.
Implied Sionificance to Plant Design, Construction, orts Operation If P.G.&E. did not have a clear understanding Interaction of the scope of t and commitments to the NRC in the Seismically-Inducedl Systems t
Program (SISIP), then the misunderstanding might be significa Such a misunderstanding might affect the capability to saf operations. Mcwever, the shut down the plant following the , occurrence of a Hosgril event. tion degree of P.G.&E.'s understanding includes many details, criteria, Application of the target selection criteria, source ;
I identification criteria, application of source identification crite 1
source-target intera,ction criteria, application of the source-targetions, interaction criteria' analysis for the resol 0 tion of postulated intera i We and the resolutionn of , ostulated interactions by plant modificat ons have no basis to conclude that a misunderstanding exists.
Assessment _ of Safety Significance 1 f
At the request of the Advisory Committee on Reactord Safe P.G.&E. agreed to initiate a program to determine if seismic
' failure of r.on-seismically qualified equiprent and piping would ca ;
I
b
. . 2 .
t the plants f ron interactions with safety-related systems which could preven P.G.&E., f
- being safely shu,t down following the occurrence of a Hosgri event.
by letters dated May 7, May 27, July 1, July 15. August submitted draf ts of their proposed program to the NRC staf f ,
corrent. These drafts were reviewed and comments submitte These reviews are guidance for their use in improving their program.
described in Sections 2 through 5 of Supplement No.11 to the Safet Evaluation Report (NUREG 0675, Supp 11).
or. site audit of the* program activities (reported in The staff performed a Although we did r.ot include a Sections 6 and 7 respectively of Supp 11).
100% review of P.G.&E.'s target list, we sampled the target list.
By.a letter dated October h3,1983, P.G.&E. submitted an infor-on th,e status of their seismic systems interaction study within l
Included in the Inforration Report was the l containment qf Unit 1.
P.G.8E. has not yet completed preliminary status of their study of' Unit 2.
Howtee i its study of Unit 2 and the staff has not yet completed its review.
the staff has not yet identified any misunderstanding of the origin In fa::,
of the targets and comitments to the NRC in the P.G.8E. program.
l there has been even more detailed understandings attained and comitments made to the NRC.
Therefore, the extent to which we have corrinunicated with F.G.&
reasonable assurance that P.G.&E, understands the scope of the ta
-l t
l l
the comitments made by P.G.&E. to the staf f. The commitrants are documented in Section 8.2, Supplement 11 to NUREG 0675 (SER):
(a) "P.G.&E, will complete their program and any necessary plant modifications for eac'h unit prior to the issuance of any license authorizir; full-power operation of that unit."
(b) Region V, OIE, will verify "the completion of P.G.&E.'s program and the
- acceptability of any plant modifications."
(c) "P.G.&E, will ... provide for our information copies cf their final report of their program which will include an identificatic - ef all interactions postulated, all walkdown data, interaction resolutic .s and technical reports."
Based upon (a) the degree of understandings between the staff and P.G.&E.
which, includes many details documented in Supplement 11. M. REG-0675 and reinforced by extensive informal communication, and (b) the ongoing review ;
of preliminary results, we have no basis to conclude that P.G.&E.
misunderstands the scope of the targets'and their commitrents to the NRC.
Action Required:
No new action is required in response to this allegation. The ongoing review will continue to take steps to assure that no misur.derstandings occur which might be significant to the safe operation of Diablo Canyon.
1s_k:k Concern No. 9 ATS No.: N/A . BN No.: 83-17 tharacterization It is a board notification.
This is not an allegatich.
Board Notification No. 83-17 involves the testimony of a UC staff witness (J. Conran) in the Shoreham proceeding. In that testimonf. Mr. Conran expresses his concerns in two areas, namely systems interaction and safety classification. 'The first concern, systems interaction c:es have some potential generic implications due to the aspects which i volve the resolution of Unresched Safety Issue-USI A-17. The secc-d concern, safety classification is considered to be plant specific to Shoreham.
In r,esponse to the testimony of J. Conran, the staff (F. offman, A. Thedani, R. Vollmer, C. Rossi, and R. Mattson) addressed .both concerns. With respect to the systems interaction aspects, the staff stated: (t) the review of Shoreham agairist existing requirements provides reasonable assurance, pending the resolution of USI A-17, that the giant can be operated without undue risk to the health and safety of the public from potential adierse systems interactions; (b) the staff's program on A-17 is confirmatory in nature, and the staff continues to believe that reasonable progress :cward a timely resolution of the USI is being madet (c) additional plan:-specific systems interaction studies are not necessary as a predicate to 'icensing Shordam.
l l
~T* . .
i Irplied Significance to Plant Design, Cnnstruction and Operation a
Based on the testimony ,of J. Conran, it is concluded that he had concerns on Shoreham in the two areas highlighted. There is the possibility that there The would be simflar concerns on Diablo Canyon with respect to USI A-17.
other concerns were plant-specific to Shoreham.
Assessment of Safety Sionificance It is hard to assess the safety significance of Mr. Conran's concerns for Diablo Canyon because of some of the plant-specific aspects which are .
j discussed in his testimony. Furthermore, in the case of Diablo Canyon the staff has placed additional requirements on the applicant based on the results of the applicant's seismic systems interaction program. See also Allegation 48. .
Staff Position The staff position on the generic aspects of the Unresolved Safety Issue (A-17) is reflected in the staff's testimony in the Shoreham proceeding (Contention 7B). I l
a The staff position on the plant-specific aspects of systems interactions at i Diablo Canyon can be found in Allegation 48. :
Action Required None.
1
4 i.
Task:_
Allegation #48 '
i ATS. No._ RV 83A34 l
Characterization: ,
Status of Seismic Systems Interaction Study l
implied Significance to Plant Design Construction or Operation J
The allegation that the safety of fuel loading and operations cannot be >
l assured prior to ccepletion of the modifications from the seismic systems
' interaction study is .not significant to either fuel loading or operations, because:
(a) the completion of the modifications prior to fuel loading is not required for safety, and (b) the completion of the modificattor.s pri operations is required, and all indications are that the modification s
i be completed prior to operations. .
Assessment of Safety Significance:
i --
The staff has re-examined both the status of the seismic systems inter "The safety of study and the activities related to the allegation that:
i operations is not assured if fuel load and operation of the plant o
- j the seismic interaction study and associated modifications are corplete i !
During our re-examination we have assumed that "the study" is the Seismically Initiated Systems Interaction Study with all its aspects
-l Also, we l
including the criteria for postulating systems interactions.
l assumed that "operation of the plant" means thermal power greater th i
percent of design power.
i I
I l
-2~ , ,
itments Section 8.2, Supplement 11 to fiUREG 0675 (SER) states the i '
pertinent to this' allegation:
"P.G.&E. will complete their program and any necessary p (a) f any license authorizinc modifications for each unit prior to the issuance o full-power operation of that unit." am and the (b)
Region V, O!E, will verify "the completion of P.G.8E.'s p acceptability of any plant modifications."
hi final report will ).. provide for our information copies of t e r (c) "P.G.&E i of all inter. actions 7
of their program shich will include an identificat i
on and technical postulated, all walkdown data, interact. ion resolut ons, i reports."
t t will te l 7 The important point to note is that no power operation of auth*orized before the modifications are complete.
?itisr.otnecessai Although fuel. loading is important to safety G 8E. in other study ways before loadint to complete the modifications associated with the P. . t ha Fuel loading, and its completion, means that only ne fuel.
l Sustained fission has not occurred, f been positioned in the reactor.
in suf ficient a.munt to therefore, fission products do not exist in t'ne core i require decay heat removal, j
j d September 10, :
As additional safety precautions, P.G.&E. (in a letter date i nt during fue j
states that (a) no modifications will be made i i
~ - - - m. _
.3- .
loading, (b) during the period when the modifications are being cade the plant will be in modes 5 and 6 (cold shutdown and refuelir.;), (c) no modifications wil be made to those systems or portions of systems required by Technical Specif to be functional during the5e modes of operation, (d) post fuel-loading modifications will not be undertaken until the reactor vessel head shield are in place to provide protection of fuel from any modification activity, and (e) the modifications will be completed prior to the first reactor criticality.
h'ote that all such post fuel-loading work will be reviewed for the introduction of new' interactions innder P.G.&E. 's st:,dy.
The P.G.&E. study, as we accepted it, provides for 'ollow-on activities during These follow-power operations to remain alert for adverse systers interactions.
activities should not be confused with the completion of the modifications The fellow-on activities provide fo*
identif.ied during the pre-operating period.
responsiveness to those adverse systems interacticr.s that might be identified subsequently. ,
The staff review of the P.G.&E. reports provides en independent check of the P.G.&E. study. The staff review will provide assurance against adverse systems interactions from Hosgri events at Diablo Canyon and will consider the potential for generic implications from the findings of the P.G.8E. study.
- 4- , !
i .
d an informatien report on 13, 1983, P.G.&E, submitte By a letter dated October t dy within the centainment i
the status of theib seismic systems interact on su h
reliminary status o'. ,
l
' of Unit J. Included in the Ir. formation Report wal !
their study of Unit 2. However, neither P.G.&E. nor the l the staff has not yet completed its review. t ms interaction that i
staff has yet identified any seismically i induced sys eithin the a <
consists of a violation of the regulatory cirter a w sections of the Standard Review Plan (NUREG-0 ,
thorized only after ,
In sum.ary, we concluded that power operations should be It is not necessary to complete all all modifications are completed.
Precautions are being taken to assure modifications prior to fuel. loading. '
s associated with the i
that the fuel loading is not vulnerable to modifica P.G.aE. systems interactier.s study. and its assoc 1:.ted td not jeopardized by the seismic sytems interaction s u y activities. , .
Staff Position i tudy Based on our review of the P.G.&E. seismic systems interaction int description, a site visit to observe the conduct of theof the sys post walkdowns, the precautions being taken and the83, minor P.G.&E, natu fuel-loading modifications as described in i theto Septem taking letter, and the commitment to complete these modificatio l d d that it is not the reactor critical for the first tire, we conc ue loading fuel. We require necessary to complete all modifications prior to
. . 5- .
i to issuing that any necessary modifications for each unit te completed pr or f that unit.
.a license authorizing full-power operation o ActionRehuired The commitments No new action is required in resporse to this ellegation. i to be identified in Supplement 11 to NUPiG 0675 (SER), Section 8.2, ce G AE. seismic required actions from our previous licensing review of the P. .
systems interaction study. .
4 8 d
4 0
e 1
I i l l
, , ,, w.ie w s. .ca
/b 1 NUr' EAR REGULATORY COMMISSION i 1Dd.' 1I '
, r<AsMiNot ;N, o c. rosss -
, . November 7, 1983 NOTE FOR: Files FROM: Robert A. Purple, Deputy Director Division of Licensing SUBJE:T: TELEPHONE CALL FROM DR. HENRY NYERS, SUBCOMMITTEE ON ENERGY AND ENVIRONMENT As a followup to our meeting last Friday, Dr. Myers called me today to further discuss the infomation that he had on Diablo Canyon deficiencies.
He prefaced his conversation by stressing that he intended to give me this inforeation only on the condition that by Friday of this week, I would call him to tell him what has been done to follow up on the infomation. He expressed reluctance to convey the infomation to me since he .vas not confident that I would take the matter seriously and make a vigorous effort to get to the bottom of th'ings. He asked cm to identify who the single person was who was in charge of resolving all of the Diablo Canyon allegations and deteminin5 their significance. I told him that since the issues could involve construction deficiences, design centrol deficiencies and perhaps even matters for investigation of wrongdoing, the only single person in charge woul.d be the Executive Director for Operations. He noted that, since most of the items apoear to be related to construction defi-ciencies, he planned to call Jack Martin of Region V later today. (I subsecuently telephoned Mr. Martin's office, who was ur.available, 2nd relayed a sumary of the folicwing infomation to Tom' Bishop of his staff )
Dr. Myers did not wish to provide copies of the ifocuments to us that we had seen last Friday in his office. He preferred instead to orally identify the areas that j he believed the NRC should look into. I believe that he felt that by '
defining the areas in broad enough terms, the identity of the alleger would be more protected than if he gave us the documents. He warned me that by I passing this infomation on to me that I now shared a personal responsibility for protecting the identify of the alleger and that if, as a result of our invcstigation of these issues, the identity of the alleger is mcde known that the responsibility for that compromise rested with me. He then outlined the following nine areas of inquiry that he believes the NR; should investigate.
- 1. Review all new confomance reports concerning the purchase of material .
from non-approved vendors over the last 2 or 3 years. Check all - -
-N (, Q purchase orders against approved vendor lists.
f
%,38/5T- '
Q . '3 Qibccje,4-253i-HV'Hl% R ian'l
\ f I b5
.I.~ '
l I
. l f>iotetoFiles
-2 j
- 2. Review all NCR's vs DCN's and check the disposition thereof. Lcok at PG&E's DCN's vs the Foley and Pullman Companies' DCN's for discrepancles.
- 3. Provide a description of deviations over the past 2 years in DCN's and Mbl revisions thereto regarding the control room pressure and ventilation ;
system.
- 4. Request allof documentaticn from PG&E, Foley upgrading materials from non-essential toand Pullman regarding the_ db 4 3 essential. 1
- 5. Check documentation to establish Foley and Pullman record on .. :
certification of inspectors. Review NCR's against inspector control *b l prior to 1983. Note those NCR's and their. disposition.
l
- 6. Are there any NCR's on Redhead stud anchors? -
-. .. - 458 l
- 7. Review inspection reports and NCR's by Fol,ey and Pullman on testing 'of a l concrete and grout and the use of samples. ~~ " b k 1
- 8. Ask PG&E and Foley for all NCR's regarding wire traceability. Check work packages to determine if they clearly indicate the source of all Wires.
4b i
9.
Ask for documentation establishing wire cable termination and pull test __ a g !
and inspections performed per Appendix B. !
Mr. Myers' reiterated that he expected to hear from me within a few days with respect to the Agency's actions on these allegations.
.: a b* __
Robert A. Purple,3eputy Director Division of Licensing -
t 0
+9
- .. h
- , NUREG-0675LD Supplement No. 21 LIMITEDDISTRIBUTIONNO.19 Safety Evaluation Report
. relatec to the operation o" Diablo Canyon Nuclear Potuer P ant, Units ' and 2 Docket Nos. 50-275 and 50-323 Pacific Gas and Electric Company l
I l
U.S. Nuclear Regulatory ,
Commission Office of Nuclear Reactor Regulation December 1983
,e % 9, 6'
wmmmmmusemenen /7 ' o; f Q j% 2Cp3H=S ~- V 'I
~
. I t
l l
l I
I i
I l
i I
DIABLO CA'lY0ft l
(PREDECISIONAL OR SEtlSITIVE)
INDIVIDUAL ALLEGATIONS SUK'iARY SHEETS 5
12/19/83
a LIST
~
ALLEGATIONS - PREDECISIONAL OR SENSITIVE ALLEGATION OR CONCERU NO. CHARACT,ERIZATION 1 Dassing Contraband 2 Anti-Nuclear Denonstration IE CA/0C Allegations 19 Guard Qualification 23 CA In.tpector Concerns 24 HPFoley NCR's Rejected Without Good Cause 53 Welder Oualification 59 ~o ley lost Cable Traceability 60 Foley Purchased Haterial Thines from Unapproved Vendors 61 Lack of Document Control 613 H. P. Foley used unapproved drawing 62 Foley Lacks Adecuate Sar: ling of Cable Pull Activities 63 Foley Has I.est Material Traceability Upgrading of Non-Class 1 to Class 1 6' Gecut Test Sampling Based on Specific Test Rather than
~ield Tests 65 ~c'ey Documents Prior to 1980 Ouestiered-No Review Recuired Prior to 9/1981 license issuance 70 Inadeauate Response ~o Netice of Violation 71 Use and Sale of Drugs 73 Selling of a' rugs 81 Individual Fired for Whistle-Blowing 83 NRC Was Not Effective in Identifying Problems 96 Improper Anchor Bolt Soacing ("Hilti" and "Red Head")
101 Cualification of Welders and Procedures 103 kt1 ding and Welding Program Concerns
~
e e
i iii
- NTRODUCTION
?uring a . staff briefir; of the NRC Comrf ssion concerning the D'ablo Canyon Unit I readiness for fael loading on October 28, 1983, the Coenission, re-
- ognizing a significant number of allegations or concerns have been received, cirected the staff to oursue the outstanding issues to resolutien. Further, tne staff was reouested to provide a status report on these matters to the
- ommission prior to a decision on authorization of criticality and low power testing.
'ne staff has develooed two documents providing a status report on the silegations as of Decerter 19, 1983.
A SSER No. 21 (Attachment 1) which contains:
(a) A listing of all allegations or concerns, (b) A summary status report and assessment o' collective significance of the allegations, (c) and identification of issues requiring action prior to reactor criticality or exceeding five cercent power.
Included in an attachment to the SSER is an individual allegation status summary for those allegations or concerns which are resolved or, in the sta#f's opinion, 9ase very low potential for becoming a sicrificant safety C e r c e'n .
- 2. A limited distrubstion document, Attachment 2, Diablo Caeyon Predecisional or Sensitive Alle;ation Summaries, which contains the individual allegation status sumr. aries 'or those allegations or concerns which:
- a. Are sensitive issues which are the subject or current investigations, wherein public disclosure would not be appropriate.
- b. Involve allegations whose specific disclosure would cause a confidential i alleger to be identi#ied. '
- c. Involve alle;ations which have ,iust been received have not been examined by the staff to any significant degree, it was not immediately ascertainable from thk incoming document whethers confidentiality was recueste: by the alleger and for whether the oublic disclosure of the initiate or would. otherwise imoair the Comnission's ability te initiate or :onduct an investigation or inspection.
The preliminary findings of issues addressed in this limited distribution document have bee used by the staff in developing the overall assessrents contained in the SSER.
nis decurent is the I'mited distribution document and centains allegation !
status summaries that are current as of December 19, 1983. It is anticipated 09at additional allegations will continue to be received. The staf# will i
- eovide the Conmission an updated written status at six weeks intervals and !
will be prepared to pr: vide an oral status report at any time. l 1
-l
O! No. 05-82-005 Task: Allegation or Concern No. 2 ATS No: 05-82-006 BN No:
Cha racte-iza tien
' *n individual wr.o was involve: in tr.E Oiablo Blockade attemoted to purcnart C-4.
eplied Sionificana;_to Plant Design, Construction, or Operation Assessment of Safety Sionificance Tne investigation by 01 is completed. No direct connection was made with the plant site. Incuiry report in preparation.
Staff Position No infernation developed to make this matter of concern for the NRC. l Action Required No further action required by NRC.
3
?
-l i
. . Task: Allegati:n or Concern No.19 ATS No: 05-83-0C2 BN No:
Characteri:ation A'.leged falsification of background investigations of some contractor ecoloyees.
Imolied Significar:e to Plant Desien, Construction, or Ooeration s
Assessment o# Sa's:, Sionificance Field work by O! 'n orogress.
I Staff Position i
Further investigation must be done in order to determine the significance o' ;
the allegation.
Action Recuired C0mplete the invelt'gation.
1 i
l l
I l
5 ,
. ~ . - r , .n, -, , .--- - , , . ,,,,,,,,_,,.,,,,,.,,..,sn,.., .,,,-.,,_.,..,n-, . ,n_,. , , , , , . _ , . _ , . , , _, ._.-,.-n,,.. , ., - - , . ,,, - . ,,
-~
4 Task: Allegations or Concerns Nos. I4 ATS Nos. RV83A28, RV83A33, & RV83A52 BN No. NLA RV83A46 83-164 (10/27/83)-
t C.'a ra:t e ri:a ti on A site contra: tor (H. P. Foley (HPF)); (1) rejected nonconformance reports without justification, (2) was not :::umenting nonconformance reports . issued oy field inspe: tors, (3) has incorrect :-ocedures for veiding nonconformance reports, arc (4) incorrectly rejectec defective weld reports. This chara:teri:ation includes all of tre a::ove referencec allegations.
Ieolied St;m'ficance to Plant Desica. Construction, oe Ooeration i The site c:ntractor in question (H. F. Foley) has been responsible for instal-lation anc modification of electrical, civil and mechanica.1 design class 1
, safety systems and structures which a e necessary for the safe operation and shutdown of tne plant. Improper ha-c'ing of nonconforming conditions could cause const action quality to be ir:eterminate. ;
1 I
Assessment of Saf,ety Sionificance To assess t,e overall control of nc ::nformances, as ell as, the specific concerns tre staff; (1) reviewed ac:l':able HPF procedures, quality control' (CC) inspection reports and specifi: '.
9 -
, r,-.--.-. ,
-, ,y,w.,,. ,-n -, ,r---- ny.,-- ,- .--m- 3 , . .,, , _ - . ..v--,. p.--.,,e...ww.._.--e , + - - + em,m~--,,--+.,e
esponsive to the individuals :encerns and communicate with the inc'.' duals more effectively.
NCRs were found in the records which were voided before the QCP-3 was revised to procedurally allow the voicing. However, these were handled in t e same anre- as the formal procedural steps and all nad beer logged in the ecords as aving been e: iced. There ti: not appear to be any evidence of cove 'ng up the
.:iding.
~
ne staff's review of over three percent of all NCRs, *Rs, and other stecific inspection d::uments found that nonconformances were documented, anc roperly a ministered. Although proper'y administer ed, the staf f disagreed with the e .;inee-ing es:lution of ore Of the NCRs reviewed. Tne NCR concerre: stud
.elding. The Er.gineering dis;osition did not recogni:e that a materiai (which
-as not rece;ni:ed in the welc< ng procedure) was bei99 welded. This staff finding is ar. apparent violati:n. The licensee will be required to :erform expanded rev ews in this area.
i This activity will be monitored by the staff.
The action or eight NCRs/ irs were verified by the staff to have been completed oy field inspections. In addition, six work request-job packages we e i eviewec, verified the activity inspection reports examined and fou.'d satisfa: tory. Interviews with HPF personnel veri'ied snat they were 'am; liar
.ith ap:lica:le procedures.
ask Allegat'On or Concern No. 66 resulted from the report by a concerned 1
- itizen that a QC inspector's =ife indicated her hus:and had identifie: that '
i
- efective we': eports and tnat these were being wrong #vily rejectec :y HoF aragement. *he QC inspector -as interviewed by the staff and did r:t l
l 9
l l
-o,.--- - - , .,- , , , , , , , - , , - - , ...,- , , . - . , , , v . - ,, . . - , , - , , . - - - + , . -
Action Required Further action is planned rega* ing examinat':- of the named indivic.al's nonconformance and inspection reports. The s lff will monitor the a: itional licensee reviews, i
l 1
1 11
a .
There was no apparent wrongdoing in matters over which the NR: exercises regulatory jurisoiction.
The staff, however, is separately evaluating welders qualification through ne routine inspection program, in addition this area will be further examined in response to allegation or concern No.101.
13
t ,
scussions and interviews were held witr site personnel affiliated with e'ectrical cable re:eiving, installation, inspection and records. Inspactior erorts, cable pull car:s, design circuit schedule, termination cards and ene a.:it were examired. A field examination was made to check terminations, cable 1
natters, cable type and si:e, color-coding, circuit and conductor '
f:entift:ati:n. These iters were compa e: with cable cards and diagrams of '
- 9nections. Catie pull cards were che:ke- to assure cable reel numoers were
-e:orded.
T e licensee commits, in : e FSAR, to usi ; only cable with color coded jackets in safety-related circuits. Site persernel that were interviewed knew of no cases where noncolor- cced :able was use: in safety-related (S/R) circuits.
I e field examinati:n ar: ecords showe: tat only color-c0ded cable was used i in S/R circuits. i Tre licensee identified sixty-six circuits that had be'en upgraded from nonclass 1 to a class I category. *he staff exa-ired the circuitry related to the plant vent radiation monitoring circuits to assess traceability and quality of the uo;raded circuits. These records appeare: in order.
Re. ting, raceway installation, color cocir; and raceway indentifica tion were l
<e-ified as adequate by the staff. Cir:a' records were traceable to I me::urement and material release records w .ich provided objective evidence of O' ass 1 material and con:rol of installati:ns. Procurement receres contained
- e-tificate of conforman:e and certifiec test data attesting to the quality of
- a:les.
15
A Tast: Allegation c- Concern No. 60 ATS No.: RV83A57 BN No.:
Chara:terization A site contractor ( . P. Foley) has been purchasing material through unapproved vendcrs. '
Imol'ed Significar:e to Plant Design, Const uction, or Oce ation The sd te contracto- in question (H. P. Foley) has been resoonsible for ,
insta'lation anc m.:c'fication of electrica'1, civil, and ee:r.anical cesign class 1 sa'ety systems anc structures which are ne:essary for tte safe operation and shutc:wn of the plant and uncontrolled pur:hasing could lead to incorporation of ir.ferior materiais in these systems.
Assessment of Safety Significance 1
The staff insoectec the implementaion of toe H. P. Foley (HPF) QA Program to
]
verify compliance in regard to the qualification of vendors /supplers. Foley has 3 ssued nyer 12,000 purchase orders to over 160 suppliers. The staff l exami9ed the require ents and procedures relative to this area, as well as audits and an examination of a sample of about 20% of the su; pliers and a corresponding purcnase order. -
17
_#.,,..r_ r, - ,.. ~,.w_,_,, , . - , . . - . . - . , , . , , , ,c. . , .._.-.
l 1
Task: Allegation er Concern No. 61 ,
ATS No. RV83A57 BN No. N/A.
Characterization 1
There is a lack of cocument control in PG&E, H. P. Foley are probably Pullman, '
eelating to use of design change n:tices.
1 1
I .clied Significance to Design, Co struction, or Oat gn i The implied significance appears. t: te the concern that H. P Foley is performing work in the field to una:: roved design change r:t'ces or unapproved designs.
1 Assessment'of Safety Significance The staff examined PG&E, H. P. Foley, and Pullman Power Pr: ducts procedures providing document control instructions.
The licensee's procedure requires tnat only approved OCN's are transmitted to tne contractor, who controls DCNS in accordance with estafisned document control g rocedures, The staff also examined the licensee's crocedures that establish how Engineering initiates, ;rocesses, approves a-c documents design.
changes. Based upon t7e above exam' nations, the staff cons'ders that the procedures adequately specify docurent control requirements and design change Controis.
, 19
I l
i i 1
)
1 I
prior to being superseded. The staf# ,as unable to draw any conclusions as to )
i safety significance of this finding ar.c considers that the superseded and supersecing revisions should be furtner evaluated to determine adequacy of tne present system configuration. The DCN was closed, with work completed in November 1983.
'he staff also observed that revisions 1, 2, 3, 6, 9, 11, 12, 23, 25, 30, 32 anc 46 had no nork complete date entered en the index. These revisions neec to be evaluated to determine if the requi-ed work was accomplished in accordance with revision requirements. The staf' concludes that the PG&E site document control organi:ation has not acequately tracked the evolution of DCO-EE-446.
The alleger ecoressed the concern tnat a "bootleg" copy of Revision 61 of DCD-EE-446 went to the field for work :;t was never approved. The inspector examined revision 61 and coserved that work was authorized to oroceed on th4s revision (i.e. approved) by the Discipline Engineer on March 25, 1982 and by signature of a Group Leader / Supervisor on April 2,1983. However, even if Foley cocument control had issued this CCN to the field controlled document location and to the Foley Engineering organization, work did not proceed on this revision because PG&E had not issued a Work Request to initiate Foley work on this revision. Further, revision 61 did not involve any physical construction work in the field out me'eiy revised revision 52 verbage which .as not related to physical field construction, but which was related to engineering functions (design verification requirements) and procurement functions (deleting note on revision 52 requiring that General Construction purchased a switch and install oer Class 1E requirement). Revision 61 was cancelled on January 14, 1983. Revision 61 was annotated to the ef fect that 21
l l
The staff examined the manually (ept Foley log of DCN status and compared that i status to the status presented :y the August 30, 1983 cley letter. Item 1 of )
the letter identified 16 DCN's =31ch were listed as sucerseded by the c0mputer program. PG&E responded that 12 had not been superseced and this fact was in agreement with the manual Foley DCN index. Four DCNs were listed as sucerseded in the PG&E resconse but this status was not reflectec ir the manually entered Fcley DCN log. Item 2 of the A gust 30, 1983 letter listed a CCN which was sucoosedly su:ersefed by anothe- DCN. The manual Fuley .OCN log was ice-tified to be in error and Foley had erecneously logged that CCC-GE-795 had superceded DCO-EE-33. One Other instance (item 7 of the August 30, 1983 letter) was not correctly reflectea in the manual Foley DCN log. Thus, the staff deterrined that the Foley DCN log was not ccmpletely accurate.
The alleger ex:ressed the conce-9 tnat dif ferent revis'en 5s existed to 000-EE-406. Examination of P5&E anc Foley recorcs es:10'ished that ene Of the revisions 5s was dated 11/5/79 and was cancelled by a second revision 5 dated November 9, 1983, on November 15, 1983. The inspec' tor found no safety signi-cance to the existence of two revision 5s, especially since the first revision 1 5 was cancellec on issuance of ne second revision 5.
l Staff Position The staf f concluded that there a*e adequate procedures wrich specify the requirements for cocument contr:1 and that personnel a e generally famf *iar with the requirements with one esception to be corrected ey Foley.
23 i
i
A Task' Allegation or Concern No. 61a ATS No:
Characterization: 4 A site contractor (H. P. Foley) nas used an unapproved drawing as the basis for accepting field work.
Implied Si;nificance to Plant Desi;n, Construction, or Operation The site contractor (H. P. Foley) has been responsible for the installation and modification of electrical, civil and mechanical cesign class 1 safety systems and structures which are necessar.3 for the safe operation and shutdown :f the plant.
Assessment of Safety Significance ,
The alleger stated that an unapproved drawing (drawing 100) has been re'erenced on many.Scoport Inspection Work Sheets as a basis for accepting field .or(,
that drawing 100 had never been aporoved by PG&E, and that the drawing '.00 is still referenced on support inspection documentation with work still pe-formed to drawing 100 requirements. The staff examined the drawing No. 100 ard i
concluced that drawing No.100 was originally generated by the H. P. F:'ey ,
(HPF) Company on June 16, fl978, approved by H. P. Foley on June 17, li'3, and submitted to PG&E by H. P. Foley Engineering Disposition Request (EDR) No. 7595 25
-,-.--r--.,-- y-.-, . w ----
p w.H, . .m., ,_ , .,-y , .. ,., - - - , , . -, ,,- % ,. e
o e
c ,
Task: Allegation or Conce-n No. 62 ,
ATS No.: RV83A57 BN No.: EfA Characterization A site centractor (H. P. F0 ley) has not adequately performed sampling of cable pulling and termination or: gram.
Imolied Significance to Plant Design, Construction. or Operation Inadequate sampling of in-:cocess work could result in reduced assurance of cuality ecause orojected confidence levels are r.ot attained.
Assessmert to Safety Significance The staff reviewed the licensee's commitments as defined (QCPE-11, Cable and Wire Termination) and OCPE-10, (Power, Control arc Signal Wires) which required 10% inspection of terminations and cable pulling activities. In addition, CCP-3, (P-ocessing and Control of Nonconformances,) was reviewed and related to inspection findings. Discussions were held with s'te personnel associated with the cable pull, cable termination, inspection anc record keeping for these activities. Inspection recorts, logs, cable pull cards and termination cards, and one audit associated w'th these activities was also examined. A field examination of 53 circuits was made to verify the c;ality and configuration of 27
Staff Position The staff concludes that tae licensee sampl'ng inspection program f s in com-pliance with program comm't. ents and the sarole inspection, coupit:: with con-tinuity and circuit tests :rovide an adequate level of quality assrance.
A: tion Recutred
' sone I
l I
l 29 1
. e e reviewed to asce-tain the circumstances regarding the material acceptances l
- es: riced therein. In addition, examples of f abricated items (Beta shields and ince-e thermocouple circuits) incorporating the materials were discussed with licensee engineering personnel and examined in Unit 1 in oecer to obtain a
- ro:e perspective regarding their application.
- ) tre alleger) did represent acceptance of material for use in a class 1 ;
a::'f cation although the procurement was not originally class 1. In this i
nstance, the materici was not accompanied oy documentatior certifying (i .e., a i
- e-;'ficate of conformance) that it was the material ordered and therefore did !
1 r:: nave the full traceability usually requi ed of class 1 raterial. However, l l
'n ::nsidering aoplication of this material it appears that e licensee acted
- acer.ily in accepting its use without certifications. i l
1 Ine licensee stated incore thermocouple circuits were upgrade: to class 1. To assu e they met class I requirements the entire circuits f*:e the reactor head
- ::ntrol room were -eplaced by material purchased as class 1 and installed in at::-dance with quality controls. The staff reviewed the :ir:vit revisions and i s;ected installatf ors related to the upgracing of ten in: ore thermocouple l circuits to class 1 status.
l Tre staff concluded that traceability of the circuit pedigrees for the incere ermoccuple was avaiiable, all records substa'ntiated the cua'.ity of materials wa: : lass 1, and the rerouting of the- cables was installed te class 1 criteria.
l 31
- - - - e-- - , r- -mg,- y--,- . ,,--- --- , , -w ---,y q g- -
--g<- awwg -- - ~ , , - ,, g-
' ' Action Required None i
1 1
1 1
1 9
6 i
l 33
i l
t
(
t
-itled, "Stancard Test Method for Com;eessive Strength of Hydraulic Cement
- rtars."
i staf f review of the above documents indicates that the industry ASTM standarc est does not recuire the specimen be crepared from the same batch of grout
. sed by the craf tsmen in the field as lea; as the material used is of the same ype as the fiele material and is preparec and mixed in accordance with the
.+re interviewed. Both stated that they are not aware o' any grout specimens
- epared from a grout batch other than tre field process being used for base
- ' ate or other field grouting.
' ne (9) caily strength reports of tests :enducted by PG&E for the specimens
- epared by li. P. Foley were examined in the 1981 to 1983 time frame. Tne
-ecorts snow tr.at the majority of the specimens show a break stress of a: proximately 9000 psi which is above the required design strength of 5000 psi
':r premixed grouts.
~ ,e staf f's field inspection of completec grout pads and found no evidence of 1 y significant cracking or shrinkage :a any other conditions which woulc cause attitional concerns.
? sposition of NCRs was in accordance witn specifications and codes and s.andards. disoosition of a minor variation report (MVR) number C-1276 R1
.-ich documents lost daily strength re;;rts, is accept-as-is based on the
- evious history of premixed grouts at inis plant having nigher than design l
- .:sh strengths. The review was conducte: by PG&E research engineer.
l 35 !
l
Task: Allegati: or Concern No. 65 ATS No.- RV83A57 BN No.: N/A Cha racteri za tion A ajority of H. P. Foley quality assurance (QA) records have not been e.iewed 0.s document analjs s. QA recorc review checklists, whic9 indicate probiers, a *e to be cestr:yed. Records prio- to the 1981 licenstr; of Unit I are .:t receiving any m: e review regarcless of probable incons'stencies.
I clied Sionificance to Plant Desien, Construction, or C:eration I clications of ' . complete recorcs suggest a potential acverse impact u:0- an 3:e:uate turnove c' all recuire: .istorical documentat'On, to PG&E, ass:: dated with ouality-related activities.
Assessment of Sa'ety Significance Tne staf f reviewe: program elements, and evaluated the c:ntent of speci'i:
orocedures used t: establish necessary instructions for implementation.
Personal intervie s were conducted with the quality assu*ance department personnel and su:ervisors responsible for implementinn tne QA records pre;-am.
Paeticular emphas's was focused on the program requirements for review Of completed and ci:sec-out record packages associatec with civil, mechanica* and.
electrical quality work accomplished by Foley.
37
Staff ins;ection determined that tne Foley QA docu ent turnover group anc 3G&E are in the process of preparing a procedure to coordinate the review, packaging, transmittal, and indexing of QA records for turnover to PG&E. PG&E general construction (GC) QC has recently issued a cuality control instruction establishing a program for review of quality assurance records generated by
- --site :Det-actor's QA programs to perform a 100% administrative review an a
- 0'. randem sampling technical review of all Foley QA records. At tne ti e of
-is allegation, Foley QA has issued an internal instruction and an inte office e o icenti#ying only post-1981 records are to be -eviewed prior te turn:<e ,
5.csequent to the staff inspection, PG&E GC manager repcrted that a: tion will be taken to assure a quality review of all complete: QA records. Tne staff
- a luces that completed Foley QA records will be reviewed without excepit0n to a y time :eriod.
Sta'f oos' tion A: equate implementation of contra: tor and licensee ;roposed corrective action !
will resolve all of the stated allegations or con =e-ns. There is no evicence to support that any adverse impact on quality-related activities has occu-red cue to these programmatic concerns.
1 l
A;J i.on Re:uired 1 Regional followup of licensee commitments concernin; QA record revie, wii' Oe De-formed oy the routine inspection program.
39
t Task: Allegation No. 71 ATS No: RV-S3-A-0058 BN No: N/A Characterization As reported to Region V, NRC by a confidential sour:e, both contra:t and PG&E e-Oloyees are involved in the sale and use of drugs. (Note: This information ,
is directly related to the De: ember 6,1983, filing of 21 criminal :omolaints for the sale of drugs, against a former PG&E employee and contract: personnel at Diablo Canyon. As of Decemoer 22, 1983, 19 arrests have been ma:e. The licensee has terminated an additional 14 contractor eersonnel for s.spected involvement.
moliec Sicri#icanca to Cesic9, Const*uction or Oce at'en Based upon tne information received from the confidential source, t ere appears l l
at this time to be no impact upon the design, construction or operation of the l Plant.
Assessment of Safety Stanificance
'Jnable to determine at this time.
1 l Staff Position .
e l 41 l
Task: Allegatiou No. 73 ATS: No. RV-83-A-0061 EN No. N/A Characterization On Jiuvernber 21, 1981, M r . Al b e r t Walker of San 1.uts Obispo, CA reported to Region V by letter that there had been an increasing number of :n,3urses treate.d at local county hospi Lal rooms which involved Diablo Cazyon construction workers that (at the Lime of treatment) were reportedly under the influer.ce of alcohol or other drugs. Mr. Valker based his information upon an August 17, 1983 letter published in the Telegram-Tribune Newspaper. Mr.
Valker attached 4 copy of Linas article to 1.lb letter.
Implied Significance to Desige, Construction or Operation The licensee continues to evaluate those arrested on December 6,1983 to determine the impact (if any) upon the destan, construction or operation of the plant.
Assessment et Safety Significance The iscensee continues Lv e v.s t uste thow rre steil un Derenher ta, 1981 Lu determine the impart (i f any) upon the wafe construction el the plaut.
43 ;q
. i , Task: Allegation of Concern No. 81 -
ATS No: RV-83-A-063 BN No:
05-83-025 Characterization Allegations concernir; oipe supports by an ergf *ter formerly eroloyed'by PG&E may have been layed off for identifying safety concerns.
Implied Sionificance to Plant Desion, Constru:-ion, or Operatien Saf'ety concerns may be suppressed.
Assess ent of Safety 51;nificance Investigation is in paccess. Sufficient infc mation is not availble at this time to assess significance.
Staf f Position No assessment can be ace at this time.
Action Required Complete evaluation o' technical issues related to this concern, followed by further specific investigation into circumsta ces surrounding t915 allegation.
J 45
'I q
x
)
i
' -ask: Allegation or Concern No. 96 _
1 5 No.: RV83A063 EN No. N/A
". .aractt rization
- : roper anchor bolt spacing has been t.;se for Phillips and Hilti shell 1*: hors.
- lied Significance to Olant Design, C:-struction, or Ope-atien
.e close spacing of co9 crete anchor be*ts reduces the pullout ca:acity of the 1:5.or bolts due to inte-action of the :: : rete shear cones which educes the
- tsign margin, is sessment of Safety Sienificance a en a support or attach. ment plate is se:u-ed to a structure by several anchor
- ts, the bolts must be installed a mieirum distance f ron each otner in order
- preservs design margins. In additic , a minimum distance must ce maintaine:
', ' :m the edge of a wall or corner.
e staf f reviewed the licensee's design criteria for installation of anchor
- 'ts, test data and the centractors' i :'ementing pr ocedu*es (:oley and
- .'iman). !
l I
l 47 l
t .
allegations on.cenetrns nos. 25-and 61. Sufficient data is not available to _]
assess significanes at this time. ~,
Staff analysis of NRC cumulative anchor bol: inspection data at Dablo Canyon indicates a rejection rate of less than two .ecent. Accordingly, installation cua'ity is not censicered a significant safety conctern. This subject, however, ,
aill ::e reevaluate:: with the technical reviews being examined' under items 25 anc (1.
! Actien Reoutred The staff will review consultant test data and correlate it with ACI 349 criteria cetermine the applicability to 03&E anchor bolt spacing criteria. The Region V will ree; ire the licensee to perfo n further followup on anchor bolt installation as a ca-t of tne routine prograr and items 25 and 61, e
e 4
0 4
. I i
! 49 l
e
' Task: Allegation Or Concern No.-103 ;- i ATS No. BN No.
6 Characterization Deviations frcm the requirements by Pullman Power Products (PPP) of weld o-ocecure codes an: Dacific Gas _& Electric's (PG&E) contra:t specifications represents major b eakdowns in the P:P Quality Assurance ate Quality Contre'
' ~
program implementation. '
J I olied Significan:e to Design, Construction, or Operatio C.ality related we*cing requirements may h' ave been serious'y compromised resulting in an ac<erse impact'upon :ipe supports and pi e ructure restraints of safety related systems / components.
l 1
1 Assessment of Safety Significance 1
i Allegation has not, as yet, been accressed by the staf f.
.~.
. 1 Staff position i A staff position ca9not be provided at this time.
Action Requirj.
51
0
) 60 &
I I
i l
I l
l l
1 i
l l
l
es ' " * %,
Q ,o f 'p UNITED ST ATES *
\ * [,7 - /,
f NUCLE AR REGULATORY COMMISSION MSHINGTON. D.C. 20555
...,e August 16, 1984 i
Note to Guy Cunningham l
These are the two 2.206 decisions reoardina Diablo Canyon for your review.
Ste e Burns O!x ,
- ^MP'e,+u m 2e pH pg -
' /,jt.* E88:q['g
. UNITED STATES ,
.s
! .e [; NUCLEAR REGULATORY COMMISSION ,
3 g l wasmetoN. o. c. rosss \
\ ...* / ;
)
Docket No. 50-275 (10CFR2.206)
P.r. Thomas Devine, Director Government Accountability Project Institute for Policy Studies 1901 Que Stree , N.W..
Washington, D.C. 20009
Dear Mr. Devine:
This is in response to your various petitions filed pursuant to 10 CFR 2.206 on behalf of the San Luis Obispo Mothers for Peace recuesting the Comission to defer licensing actions on the Diablo Canyon Unit 1 facility. The Com cission referred your petition to me for action under 10 CFR 2.206 of the -
Comission's regulations.
I have considered the information cor.tained in your petition. Based on this information and that described in the enclosed "Director's Decision," I have determined that the actions you have requested are not warranted. Accord-ingly, I have denied your request.
A copy of this decision will be filed with the Secretary of the Comissior for its review in accordance with 10 CFR 2.206(c) of the Comission's itgu-lations. As provided by this regulation, the decisinn will constitute the final action of the Comission 25 days af ter the date of issuance of the decision unless the Comission, on its own motion, ir.stitutes a review of the decision within that time.
A copy of a notice, which is being filed with the Of fice of Federal Register for publication, is also enclosed.
Sincerely, Harold R. Der. on, Director Office of huclear Reacter Regulaticr-
Enclosures:
(1) Direttor's Decision (2) Notice
. e s
e >
Docket No. 50-275 (10 CFR 2.206)
Mr. Thomas Devine, Director Government Accour.tability Prcject !
Institute for Policy Studies ,
1901 Que Street, N.W., l Washington, D.C. 20009 3,/ 3
Dear Mr..Devine:
c This is in response to your varices petitions filed pursuant to 10 CFR 2.206 on behalf of the San Luis Obispe, Mothers for Peace requesting the Corr.ission ,
to defer licer. sing actions on the Diablo Canyon Unit I facility. The Com-mission referred your petiticn to me for action under 10 CFR 2.206 of the Commission's regulations.
I have cer.sidered the information containeo in your petition. Based on this inf ormation ar.d that described in the enclosed "Director's Decision," l' have determined that the actions ycc have requested are r.ct warranted. Ac cord-ingly, I have der.ied your recuest.
. A copy of this decision will be filed with the Secretary of the Ccmmission for its review in accordance with 10 CFR 2.206(c) of the Commission's regu- ,
lations. As provided by this regulation, the decisir n will constitute the '
final action of the Commissicn 25 days af ter the date of issuance of the decision unless the Commissicn, on its own motion, institutes a review of the decision within that tire.
A copy of a notice, which is being filed with the Office of Federal Register for publication, is also enclosed.
Sincerely, l l
Harold R. Denton, Director Office of Nuclear Reactor Regulation !
Enclosures:
(1) Director's Decision (2) Notice a I OFC : : : : : : :
N AP.E : : : : : : :
DATE : : : : : ,
[7590-01]
NUCLEAR REGULATORY COMMISSION
[ Docket No. 50-275)
PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon huclear Power Plant, Unit 1) ,
Issuance of a Director's Decision Under 10 CFR 2.206 -
Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued a decision concerning Petitions dated February 2, March 1, March 23, April 12, May 3, June 21, 2une 22, July 11, July 16,' and July 23, 1984 filed by the Government Accountability Project on behalf of the San Luis Obispo Mothers for Peace. The Petitioner requested that the
. Comissien defer all licensing decisions on the Diablo Canyon Nuclear Power Plant, Unit I until a number of specified actions were taken including, inter alia, c. comprehensive third-party reinspection of all safety-related equipment, an independent management audit and a fall investigation of questiens of harassment. The Petitioner alleged numerous vioiations of Comission requirements as the basis for its request. The petitions were referred to the Director, Office of Nuclear Reactor Regulation for treatment pursuant to 10 CFR 2.206 of the Comission's regulations and a final Director's Decision has been issued by the Director denying the Petitioner's request.
The reasons for this denial are explained in the "Director's Decisien under l 10 CFR 2.206" (00-84-20), which is available for inspection in the Com-a
4 mission's Public Documer.t Room,1717 H Street, N.W. , Washington, D.C. 20555 and at the Local Public Docunient Room at the Rctert E. Kennedy Library, California Polytechnic State University San Luis Obispo, California 93407.
A ccpy of the decisic wili be filed with 19e Secretary for Cornission review in a:cordance with 10 CFR 2.206(c). As prcvided in 10 CFR 2.206(c),
the decisior, will become the final action of the Comissin 25 days af ter issuance, ur.less the Commission, on its own motier., takes review of the decision within that time.
FOR THE NUCLEAR REG'JLATORY CO?NISSION d
Harold R. Der. ton, Director Office of Nuclear Reactor Regulation Dated at Eethesda, Maryland this day cf August 1984 I
! A 4
UNITED STATES OF AMERICA 0;-54-20 NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Harold R. Denton, Director In the Matter of -
)
) Docket No. 50-275 PAC:FIC GAS & ELECTRIC C0"PANY ) (10 CFR 2.206)
(Diablo Canyon Nuclear Fower Plant, )
Unit 1) )
DIRECTOR'S DECISION UNDER 10 CFR 2.206 By petition pursuant to 10 CFR 2.206 dated February 2,1984, ~hecas Devine of the Government Account 6bility Project (GAP) on beha',f of the San Luis Obispo Mothers for Peace requested that the Nuclear fegulatory Corrission defer any decision on whether to grant a low-power :;eratihg license to the Diablo Canyon Nuclear Power Plant, Unit i unti' a number of specified actions were taken.1/ Notice of receipt of the ;etitior was published in the Federal Register on March 13,1984 (49 FF 9517).
Petitions Recardinc Low-Power Operation The actions requested by GAP in its February petition includet:
- 1. Cocpletion of "a comprehensive, third party reinspection ;r: gram of all safety-related construction in the plant, with full t;thority by the independent organization to identify and impose cc rective action on any nonconforming condition..."
-1/ GAP's Petition was filed before the Commission. It was referred to the NRC Staff for action, as were all subsequently filed :etitions; sppplemental docucents dated March 1 March 23, April 12, May 3, June 21, Junt 22, July ll, July 16 and July 23, 1984 Trese petitions are addressed herein.
2
- 2) "An indepencert audit of design quality assurance, including the reliability of conclusions f rom remedial design verification programs imposed since 1981 such as the seismic design review";
- 3) development Of a full record on Pacific Gas & Electric Company's character and competence to operate the Diablo Canyon plant, including ,
a) c manage:4nt audit by an independent organization, b) a full insestigation and report by the t;RC Office of ,
Insestigations to determine the causes of construction and design QA violations at Diablo Canyon, including questions ,
of harassment, subordination of safety to cost concerns, '
destruction of records and deliberate violatiens of the Act;
- 4) a full program of public participation for selection and oversight l 1
of the independent organizations and creation of a public oversight coma.ittee with authority to obtain all requested inforration and to - l I
conduct legislative-style public oversight hearings. !
In support of its request, GAP identified sone 170 alleged violations of "legal requirements and relevant specifications", basec upon the affidavits and su;perting exhibits of six present or former employees at the Diablo Canyon site. The alleged vio'.ations involved breakdowns in 1
bc h constructior cgality assurance and cesign quality assurance (QA).
I l
- a In the construction area, a number of issues concerning the adequacy of welding were raised. These included problems with (1) qualifications of welders, welding procedures and welding inspectors; (2) control of welding equipment; (3) maintenance of welding material; (4) weld inspection program; and (5) welo repairs. Additional constructional problems were alleged in the areas of nondestructive examinations, hydrostatic tests cf piping, vendor QA, generic breakdowns in material ,
control, construction procedures and training for quality centrol (QC) inspectors, suspect inspection acceptance criteria, breakdowns in the '
system for disclosure of QA violations and in the organizational freedot of QC inspectors, harassment and retaliation of QC personnel. In the, area of design QA the petitioner described alleged violaticns in the areas of results f rom the seismic design review and design control.
Allegations were alst raised concerning design flaws in the residual heat removal system (EHR) of the emergency core cooling system (ECCS). !
4 Finally, GAP asserted that even if specific safety hazards were not created or specific regulations violated, the factusi pattern which they have described demonstrates that PG&E does not have the necessary character and competence to operate a nuclear power plant and that the allegations must be resolved prior to any low-power operating decision i because they concern issues which could be grounds for denying the license. I GAP filed supplements to its petitior, with additional allegations and 1 i supporting affidavits on fiarch 1,1984, itsrch 23, 1954 and April 12, 1
4
-- m, ,.,, -~.,-c, --__ -. ,.~-, -
m,w,.------ --,,-e. ---- --,y y .
4.
1984 GA0 was joined in its March 1, 1984 supplerental petition by six ether organizations. 2/ This petition submitted five additional affidavits anc interviews with nine present and fomer plant workers.
Additional, specific remedial actions were requested of the NRC based en this inferration. GAP requested that the reinspection of plant safety-relatec construction be preceded by a comprehensive review of all potential quality-related docursentation, an expansion of the sample prograr in the seismic design review to cover 100% of relevant, safety-related installations and implementation of definitive corrective ,
action to elininate a design flaw in the RHR pumps at Diablo Canyon.
The March 12, 1984 supplement provided twelve ad,ditional affidavits i,n support of previous allegations made in the February 2 and March 1 petitions.
. i On April 12, 1984, GAP filed a petition pursuant to 10 CFR 2.206 before l
the Comission alleging that the record before it for a decision on a low power license was inaccurate and requesting (1) provision for the Joint Intervenors to brief the Comission along with the NRC staf f; (2) assumption of responsibility by the Comission to conduct further f act-finding and oversee ongsing corrective action; (3) direction to the NRC staf f to provide transcripts of "whistleblower" interviews to the Atomic Safety & Licensing Appeal Board, and (4) initiation of an
- l 2/ Christic Institute, Critical Mass, Environmental Action, Friends of ;
the Earth, Fund for Constitutional Government, Greenpeace Pacific i Southwest and Nuclear Infomatior. and Resource Services. Their l participation is limited to the March 1,1984 petition.
l,
investigation by the Office of Inspector and Auditor into certain actions by the NRC staff. y NRC Staff Evaluatier, of A11ecations re: Diablo Canyon, During the co.rse of the independent design reverification program at Diablo Canyon f rom 1982 through early 1984, the Comission began to receive 611egations f rom a variety of sources concerning the design, construction and operation of the facility and the licensee's manage ent of these activities. As a result of the growing number of allegations the Comission directed the staff on October 28, 1923 to pursue all ,
allegations and concerns to resolution and requestec a status report on the investigation, inspection and evaluation efforts prior to its decision regarding authorization of criticality and low power testing.
In order to assure an adequate and coordinated respcnse to all alleca-tions received concerning 'the f acility, the ' staff developed the Diablo
, Canyen Allegation Mariagement Program (DCAMP), set forth in a documen; dated November 23, 1983.
Briefly, DCAM: provides for a systematic examination and analysis of l 1
- allegations and expressions of concern pertaining to d.nign, construction, operation and management of safety-related structures, systems and com-ponents at the Diablo Canyon plant. It provides for procedures to raintain
-3/ All alle5ations received in this Petition and subsequent ones which dealt wich alleged misconcuct by the NRC Staff have been referred to i the Of fice of Inspector ar.d Auditor for handling.
y 6-confidentiality where requested, confirmation with the alleger where possible and appropriate and preliminary assessrents of allegation significance and programmatic ir.plications prior to Comission consic-eration of licensing actions. Resolution of allegations may involve site inspections, technical reviews, interviews with site personnel and pdlic technical meetings.
The basic approach for each allegation was to determine if it represented significant new information which suggested that some safety-related structure, system or component necessary for sa#e operation would not perform its safety function, or whether it identified such weaknesses in licensee's management or quality assurance that plant safety was caltec into serious question. The Staff applied the fcilowing criteria as set l forth in SSER 22 for assessing which allegations and concerns required resolution prior to criticality and ascension above Si power:
- 1. Prior to criticality those allegations or concerns must be resolved ,
which offer specific new information, not previously available te the staff, and which appear to involve a discrepancy between design criteria, design, construction or operatier. of a safety-related ccaponent, system, or structure of such r.agnitude so as to cause the operability to be draven into question, in addition, sufficient technical infomation regarding these allegations or concerns is 1
not presently available tc the staff, or programs have not beer.
developed or implemented to assure that regulatory concerns related t'o reactor safety will be resolved prior tc criticality.
. . t
- 2. Prior to criticality those allegations or concerns must be resolved which of fer definitive new information, not previously available to the staff, and which indicate a potential, significant deficiency
,, in the licensee's management or quality assurance of safety-related activities. In addition, sufficient technical informatic' regarding these allegations or concerns is net presently available to tr.e staff, or programs have not been developed or implemented to !
assure that regulatory concerns related to reactor safety will be [
resolved prior te criticality. !
- 3. Prior to exceeding Si power those allegations or concerns must be resolved which offer specific new informatier., not previc. sly ;
available to the staf f, and which may reasonably be expected to involve sizeaole failures of systems that contain radioactivity or of the ECCS systems. In addition, sufficient technical it. formation regarding these allegations or concerns is not presently available to the staff, or programs have not been developed or implemented to assure that regulatory concerns related to reactor safety will ht. f I
resolved prior to exceeding Si power. l In %pplenents 21 and 22 to the Safety Evaluation Report for PME's appli- -
cation (ccpies of which are attached) for an operating license the staff !
t reported on the status of its investigation and evaluation under DCAMP of
[
1 103 and 219 allegations respectively it had received as of December 1983 j and March 9,1984, excluding those received under the 2.206 petitions. J
' l The Steff ccncluded that none of these allegations required resolution j I
I I
i e .
- rior to a reactor criticality decision, b t that 18 allegatior.: relating ,
to eight subject areas nee:ed te be resolvec prior to issuance t' a full-power license.
At a Comission meeting or. March 26, 1954, the staff indicated ttat it
- ad esalvated each allegatien in sufficient detail contained ir, tr.e r ebruary 2,1984 and Marct 1,1984 petitions to determine whethe- they were identical or similar to allegations al-eady dealt with, whether they l
represented a slightly different twist on an issue already dealt w'th or whether they were totally r,ew. Approximate'.y 75% of the issues in the I.206 petitions were founc to have been already addressed by tbt staff.
The remaining items were t: tally new or cor.tained insuf ficis.it 'r.f erma-tion f or review. The staff reviewed the tctally new issues aga'nst the criteria described above 1: detemine whether resolution of the allega-tien was necessary prior ic making a decisien on permitting rea:ter criticality. 'The staff cca.cluded that none of these items met the criteria for an issue whic". should be resolved prior to a decis or, on d
criticality. This conclution was confirred by the staff at the Co: Tai s- I sion eeeting on April 13,1984 (Tr. 44-45).
i l
On April 13, 1984, the Comission voted tc reinstate the operat'ng license to conduct low-po,er tests up to 5% of rated power for the Diablo i Car. yen Unit I f acility. CLI-84-5,19 f;RC (1984). In that :e:ision
! the Comission described tne DC/JiP prograr and the criteria use: to evaluate allegations to detemini. r final resolution wr.s necessary prior i n to reinstatement of the li:ense. The Co r'ssion concurred in ; e Staf f's I
.g.
conclusions that none of the allegations receised in the 2.206 petitions warranted imediate resolution and directed that evaluation of the alle- ,
gations under DCAMP should continue both to c:cument reviews completed to that time and to addresI those matters that need to be resolved prict to licensing at higher power levels.
In addition, the Comission reviewed the 5:ecific allegations and actions requested in GAP's April 12, 1984 petitior.. (slip. op, at 14-15), it j noted that GAP's allegations of false staterints by the NRC staff and 4 PG5E were based for the most part on its oc interpretations of the
, implications of various allegations and that other allegatiens were based
, on differences of opir. ion with members of the NRC staff. Again, the Comission concluded that nothing in GAP's A;ril 12th submittal required delay in reinstaterent of the Diablo Canycr. t.'r.it I low-power license.
1 l
Thus, GAP's request that the specific actions as described above be taken prior to issuance of a low-power license has been denied by the Comission's decision to reinstate the low-p:wer license. The NRC staff r.oncluded and the Comission agreed that evaluation and resolution of the allegations submitted by GAP in accordance with the DCAMP and the screening criteria is an apprcpriate and sufficient rethod for detert.ining that the Comission has reasonable assurance that the Diablo Canyon facility can be operated at low pcwer, and ultimately full p:>er, without undue risk to the j i !
public health and safety.
i l
l
.10 -
The NRC staff did contiude that certain issues must be satisfactorily resolved before Diablo Canyon could be permitted to operate above 51 ;
power. One of the issues related to the adequacy of stall-bore piping and piping supports which also encompassed some allegations submitted with the gap petitions.
On April 18, 1984, ar. Order Modifying License was issued to PGSE requiring completion of specific actions related to piping and supports before the licensee would be permitted to operate above Si power. 49 FR 18202 (April 27,1984).
Petitions Regarding Full Power Operation On May 3,1984, GAP filed a new petition on behalf of the San Luis Obispo Mothers for Peace requesting the Commission to defer any decision I
to permit the'Diablo Canyon facility to go above Si power until af ter "successful completion
- of certain specified actions. These actions consist of:
l
- 1) appointment and itplementation by an independent third party of l
corrective action required by the April 18th Order;
- 2) a comprehensive review of all "Pipe Support Design Tolerance Clarification" Fregram activities; a
l l
B .
3: full public participation in selection and oversight of independent organizations te carry out the first 2 items;
- 4) publication of a Construction Assessment Team (CAT) report by non-Regien V personnel and people not previously assigned to Diablo Canyon;
- 5) development of a full record on the character and competence of PG&E based on a management audit, reports of the NRC Office of Investigations and records of Department of Labor hearings; ,
, 6) Board Notification of transcripts of whistleblowers; ano 4
- 7) investigatien by the Office of Inspector and Auditor of alleged f alse staterents by the NRC staff.
l As the basis for its request GAP adopted by reference all the affidavits l
submitted in its earlier petitions described above. They asserted that l the information had not been "seriously reviewed, let alone resolved."
They also based their petition on transcripts of "witness" interviews l i
taken since April 3,1984, draf t reports on Diablo Canyon by NRC inspec-ter Mr. Yin, and six additional affidavits by a GAP representative and fcur current and former plant employees. In brief, these various docu-ments allege a widespread breakdown in quality assurance for design of large 'and small tore piping, and that PG&E has demoristrated such a lack i
l'
__ _ . - - - - . _ - _ . - - _ . - _ _ _ _ . _ _ ~ _ ,, - _ _ . _
of concern in this area through its practices at the pant and f alse and misleading staterents to the Concission prior to the lw.-power licensing vote that the Comission should not rely on PG&E revie,. and corrective actions for these problems. GAP also asserted that there is a widespread construction quality assurance breakdown as revealed tj Pullman Power Products' (a contractor) guidance documents, safety-re'.ated bolting and reactor coolant system welds and piping. Finally, GAP expressed dissatis-faction with the role of NRC staf f, particularly that of regional staff, .
i in reviewing alleged deficiencies and corrective actions at the Diablo Canyon facility.
On June 21. 1984, GAP submitted actitional allegations based upon 17 addivirnal witness statements in support of 1.he May 3 petition. 4/ 1 These statements alleged a breakdc tn in the reporting system for QA vio-laticas due to a campaign by management to get inspecters to stop using the formal reporting system, and not write up problems on "old work";
ineffective reinspection and corrective actions including those for cracked welds in the Component Coeling Water System (CCW); poor quality l l
materials and inadequate h1 Nstatic tests of piping.
{
The statements also include allegations of false staterents and records f alsification by PG&E, increasing reprisals and harassrent onsite as well as inadequate corrective actions, changing plant design through memoranda, inaccurate drawings and undersized weld design. GAP again i
I 4/
- Six of the witness staterents were provided only tc the Office of Investigaticn which subsequer.tly provided them to the NRC staff.
I
o e expressed dissatisfaction with tr.e manner in which the NRC staf f has been handling its allegations of CA breakdown and "cover-up" by PG5E.
On July 16, 1984, GAP filed an acditional petition before the Comissier requesting that a number of steps be taken before any comercial licens'r.;
decision on the Diablo Canyon plant. The actions requested including providing "suf ficient organizaticnal f reedom" to NRC inspector Mr. Yin, appointment of an organization otner than the Advisory Comittee on Rea:ter Safeguards (ACRS) to review the work by Mr. Yin and other NRC staff, e>:an-I sion of the NRC internal investigation it.to false statements by the sta'f, 1
l provision of a forum to. resolve the various allegatiens submitted by GP, a briefing by the Office of Insestigations on PGLE's character and com;etence and an explanation of why some "C000 licensing comitments" have been E:stponed for the Diablo Canyon f acili'cy. Two additional affidavits, including cne by GAP counsel, were submitted with the petition.
Discussion The NRC Staff has continued to examine all allegations concerning the '
Diablo Canyon facility received from GAP in its 2.206 petitions (and from elsewhere). All allegations are assessed against the screening criteria described above to deter.ine which allegations required resolution prior to full-power o;eration.
As stated in Supplement 26 to the Safety Evaluation Report, as of July E, 1
1984, 1404 allegations have been received although many are duplicates er I. T c:W\ -
V
variations on previous allt.gations. For tracking P. poses each allega-tion received has been assigned a number. To date, SE1 of all allega-tions are rescived arid docurented. Additionally, ap roximately 2'?O have been resolved and are in the process of baing docurented. The remaining allegations are as yet unreselved.
The allegatier.s have been anc continue to be resolved by nethods appropriate fer the individual allegation. Certain allegations have been assigned for resolution by NRC's Region V office, others to the Office of huclear Reactor Regulation. S/ Following appropriate screening by the staff a n.;rter of allegations have been submitted to, the licensee for evaluation. The licensee has been required to provide the results of their evaluations and identify any necessary corrective actions to the Staff in writing. The subsequent Staff evaluation of an allegation ther also considers the licensee's resporse and action. As of July 1, 1984, 177 allegations have been handlec in this manner. While 31 require additional staff or licensee action, none indicate a problem, individually or collectively, sufficient to preclude power ascension or full-power authorization. -
All allegations received f ror GAP have been evaluated against the screen-ing criteria. SER Supplerent No. 26 (which is attached) presents the 5/ The Office of Investigations has inquiries pencing on a nurber of allegations involving, among other things, potential false statements and persennel matters. Twenty-two of 121 allegations before 01 are rpsolved. In the Staff's view, those remaining did not recuire resolution prior te ft11-power operation.
resolution of those allegatiers which the staf f has deterrined in accordance with the screening criteria must be resolved prior to power ascension and full-power operation.
These allegations relate to the following subject areas: 1) operational limit f or CCW system; 2) repla:ement of welded hiah strength bolts; 3) as-built drawings for operations; 4) completion of systems interaction program and modifications; 5) evaluation of coating concerns; 6) piping and supports and related design issues; 7) RHR low flow alarm; and 8) bolted connections. The issues concerning piping and piping supports were the subject of a special NRC Peer Review Group. The review in the spring of 1984 resulted in seven license conditions requiring certain actions before operation above 5% power. The Review Group has examined the licensee's actions regarding the license conditions by means of system walkdowns and onsite inspections, audits and meetings with the licensee. A draf t report by the Review Group was issued on July 13th which found that these issues should not prevent operation of Diallo Canyon, Unit I at f ull power. The final report, af ter consideration of coments by NRC Inspector Mr. Yin and the ACRS, has been issued as SSER 25. A copy is attached. The various allegations received from GAP as part of its 2.206 petitions and in meetints and interviews on this subject have been specifically reviewed to deterTaine if the staff's evaluation ef forts have adequ.tely considered the concerns expressed.
The Staff has concluded that rcne of the allegations require any further l evaluation prior to full-power operation of Unit 1.
a l
,i .
GAP's July 16th petitier, described a number of steps which it believes the Comission should take before any licensing decision on the Diablo Canyon plant. As indicated above, the staff has concluded that no substantive issues remain unresolved which would preclude the requisite safety findings for isssance of a full power license for Diablo Canyon Unit I at this time. The Diablo Canyon Revie,, Group has concluded that the seven license conditions to be met before full power operation, which arose out of Mr. Yin's concerns, have been satisfied. The ACRS in its letter to the Comission dated July 16, 1984 has concurred in these Staff findings. (A copy of the letter is included in SSER 25.) With respect to GAP's request for a public forum to address material dispu,tes of f act, it has been clearly established that the holding of hearings in response to the filing of a 2.206 request is not required. Porter County Chapter of the Izaak Walton Leacue v. NRC, 606 F. 2d 1363 (D.C. Cir 1979);
People of the State of Illinois v. NRC, 591 F.2d 12 (7th Cir.1979). In ,
any event, as explained above and in the Staff's SSERS, we have concluded that there are no substantial safety issues remaining that would justify i
the initiation of a proceeding that would previde an opportunity for a hearing.
l With respect to GAP's request for a staff report regarding "postponement for approximately a year of PG&E compliance with some 6000 licensing comitments" the staff concludes that GAP has not provided any adequate basis for such a request. The matter of "6000 licensing comitments" i 1
was discussed at an NRC meeting with the licensee on July 2,1984 A l
- a j
4 i
transcript of the meeting was issued on July 11, 1984, as Board Notifi-cation 84-128. At the reeting the licensee inforced the staf f that a computerized quality cen-itments management data base is being dsveloped for internal use to track those comitments that are to be met throughout the life of the plant. At the time of the neeting the licensee had identified approxirately 6000 such quality comitments. As explained further on pages 104-106 of the meeting transcript and based on further discussions by the staff with the licensee, the data base will be routinely checked to assure that comitments are being ret on their prescribed schedule. The data base will be updated to include new comitments. ,
it is the steff's understanding that the two specific examples cited in GAP exhibit 2 are not ir.cluded in this comitment list because they did not exist at the tine of the meeting, because they are specific comit-ments to be met only once at a specific time and because they are not directly quality progra: related.
As indicated on page 105 cf the transcript, the staff has concluded that -
the licensee's comitmer.ts are to be met at the tires specified for such comitments and that no extensions of such commitment dates will be given without proper justification. The NRC has not waived at any time the requirements for any Diablo Canyon comitment, quality related or other, without proper bases.
s
4 - ,
Finally, Exhibit 2 at page 6 implies that the 6000 line items in the program necessitate repairs. While sone of these iters relate to specific systems, structures and components, many of ther relate to administrative and personnel tretters such as training and qualification, reporting, exercises and tests as set forth in the Teck.rical Specifi-cations. The need for repairs resultin; from the 6000 line items is expected to be rare.
In surrary, the "6000 license commitments" is not a list of open items but rather a tracking system for license commitments to be met through- .
out the life of the plant. As stated ir. recent SSERs, ir, particular ,a SSER 27, the staf f has evaluated those license commitrents that must be ret prior to issuance of a full power license an,enesent and has concluded they have been met.
Cenclusion -
The petitioner bases its request for relief on nunerous allegations of inadequate quality i:surante in design and constructicn; construction defects and harasscent and intimidation of QA/QC persennel. As discussed--
above, the NRC has established a progran to screen and to evaluate, to the safety significance and to resolve these allegaticns and has since 1983 spent thousar.ds of hours under that program investigating, inspecting and evaluating the concerns raised. In the Staff's view no issues remain unresolved which ir.dicate problems of s.ch a magnitude, either individually or collectively, that preclude authorization for power ascension testing and fu$1-power cperation. Therefore, petitioners req.est for specific
\1 s
,Y' 19 -
o e.
actions to be taken prior to a decision on full-power operation of the Diablo Canyon Unit 1 facility is denied. A copy of the decision will .be filed with the Secretary for the Comission's review in accordance with 10CFR2.206(c).
Harold R. Danton, Director Office of Nuclear Reactor Regul6 tion Dated at Bethesda, Maryland this day of August 1984 Attachments:
Supplemental Safety Evaluation Report Nos. 21, 22, 25 & 26 t
+
1 a
I a
i I
l '
i J
J
GO9EMMENT iCCOUNTADIUTY PROJECT Institute f or Pohey ' studies 1901 Que Stree N W., Woshington. D C 20009 (202) 2344 *G Janusry 9,1984 HAND-DEL!v! RED 9 January 1984 FREEDOM Of INFORMATION ACT REQUEST Director Office of Administration
[h.rA r 4- M U.S. Nuclear Regulatory Comission Ou. d / /O -P /
Washington 0.C. 20555 To Whom ]t May Concern:
Pursuant to the Freedom of Infonnation Act (FOIA), 5 U.S.C. 5552, the Government Accountability Project (GAP) of the Institute for Policy Studies, requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, sussnaries, interview reports, procedures, instructions, engineering analyses, draw-ings, files, graphs, charts, raps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, and any other cata compilations, interim and/or finsi reports, status reports, and any and all other records relevant to and/or generated in connection with the Safety Evaluation Report related to the operation of the Diablo Canyon Nuclear Power Plant, Units 1 and 2, NUREG-0675, Supplement M. 21 (December,1983)
( *SSER 21") . This includes, but is not limited to, any and all NRR regulations, calculations, and judgments used to evaluate any of the allegations referred to in SSER 21. We request that each responsive document be identified by the allega-tion number (s) to which it may relate.
If any of the material covered by this request has been destroyed and/or removed, please provide all surrounding documentation, including but not limited to a des-cription of the action (s) taken, relevant date(s), and justification (s) for the action (s).
GAP requests that fees be waived, because "finding information can be considered as primarily benefitting the general public " 5 U.S.C. $552(a)(4)(A). The Government Accountability Project is a non-profit, non ' partisan public interest organization concerned with honest and open government. Through legal representation. advice, national conferences, films, publications and public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups who seek to ensure the health and safety of their communities. The Citizens Clinic is currently assisting citizens groups in the California area concerning tne Diablo Canyon Nuclear Power Plant.
For any documents or portions that you deny due to a specific FO!A exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exe.nption is relevant to the document or portion of the document withheld. This index is required under
I l
Dire:tur of*diristration January 9,1984 i
. U.S.. Nuciea < Re991atory Comission i
Vaughn v. Rosen (1), 484 f.2d $20 (0.C.Cir.1973), cert denied, 415 U.S. 977 (1974).
We look forward to your response to this request.within ten days. I Very truly yours.
, /
. gy wav
l Billie ~ Pirner Garde l Citizens Clinic Director l l
BPG:me j 1
l l
l I
l 1
i l
I l
I l
m - - -- . _ . . . . . - . ._ .._.-.._ --.._-_ ._ . ~ . , . _ , _ . , . - . . . _ . . - ~ , . _ _ . - . . . . - . . , - . . _ . - - -!
U.S. NUCLEAh REOULATOMY COMMISSION anaagsten,wstt
,f. ~%s; sacf* n t Re t- ,fl,. $~, L I
~
'"' ~
! RESPONSE TO FREEDOM OF l '"'" k l " I e7.,
INFORMATION ACT (FOlA) REQUEST
(.e..e N0y23 m Docati asAmele le u i g #
g g (f .
so-a? 5 3 2 3
~
PART 1.-RECOADS RELE A.840 OA 180T LOCAftD 15ee checked bonesi No agency recore mAscs e the roovest have bear tocanJ No editeorW agerwy rocccm m.,b,ect to f$e renwest aw.e been located Aeoney rectros arb,ect to te west that are adentfas e Amendia 1717 M Svest. N w . waerevon, DC are apoeev e.mistn e for putnic recocton end copvmg e the NRC PWc Occumem taz=
Agency recoros svbeset to tu oovest ther a<e doetPed e Amendes b . N i b are to.ng e e.edet8e for pi.tv< cepece end copves e to 88aC % Ow Room.1717 H Street. % w , Washington. DC. e e iceoer under the @ A rderter sw reowester name r
The noterapnr.ary woon o te propenasis) that ia, agreed to eccect e a tomorcre crewwon uth a memtw of my staM e eca bece crede eve 4eeds te catsst resence and co,q et the NRC Pweec Document Room.1717 H Street. N W . Washavoc OC . e a fcader wr ee' the Fol A number and movester name Eroceed a reormeuce ce >c= vou may obtae eccess to and the chargea 'or coavn ecora reed e tre NRC Pvts.c Doewmeet Room.1717 H $treet. XNW.W Agency rectr'se a,bsect to to res,eet Fe enciceed Arv appl.cJt>e charge for coems cd the records provded and commt proceAree se noted e the corvrerne secuar f.ecords utvect to te w here been re' erred to anoeer Fedet egencYesi lor rewa are d. esc 1 reeoonse to vow in vw. er NAC e esecorse in the reowest. no h,rver acoce e be ng tau. on apoess innar dated PART H A-INFORM ATION WITNMELD FROM PUBLIC DISCLOSURE Cariain efomtre e re weeled records a be=T, enre+ead from put=.c decime/o cv%,4'1 to the SCI A esemptces descrted e are for the reescre states e Part H s core 8. C. and D. An, messed ponere of to dcr r mets for each onry pen of the NRC Putn=c Docut et Acom.1717 M Street. N
- Washegion. DC. e a fcdor to score e toeg e.nr.cd are tairs made e,edac4e for outAc repectue are coovq r e the Fot A m vmbe and roomter name h C .
&Y h a b / / h MM4L, g7 % % /
c ( 0xaa a & M.h4 '
~k$M 4
gG N e h w G , CA % +0 9.
cdrv>A(s & 3 y t' . ,
y'
. mew tvat.:>etC*os a sco, e is anno escoeOS D,
/
NEC FORM wJ -
l F2EEDOM Of INFORMATION ACT RESPONSE FOeA Nuwt Emisi @lh h eh oait MM 2 3 Ms7 g PART H 8 -aiPPLICABLE fatMXf MPTIONS Rectaros subysict to th, equest that are duecnbod e the enclosed A00endtes _
are bemg wethhe6d ri their entroty or m part unoer FOt A be and for de reasons set forth be6ow purwent to 5 U S C. 562tbl or o 10 R 9 Sial of NRC Reguistece
- 1. N merhPend adorfreton e propony desePos camrt to Enocwm Ortser 12366 itMwrT80N 11 2 The asWuud eform4 Don renates ada>y to 1%e etemsf portonned n,Les and procedures Of IdRC. IDEMPTION 2
- 3. TN asthhema eformaton e spec #caer ammer eted from sabic declosure by statute ndcated (DEMPTCN 3 I
Secison 141 146of the Atorruc trere Act w%ch croPWts the dectcevre of Aastreins Data or Formetty Reetncied Data 42 t,' $ C 2161-21661 sectge M7 of tre Atc %c Energy Act **sch proPdsts tre deClosw's of UnCLetoded Saf egt arcs Informator i42 U $ C. 2167L
- 4. TN esWund eformaton e a trade escret or corrr'wroer or feence e'ormaton that a being methheed to. the oescrust edicated (D.EM* TION di N cfcra stens e coredered to be ccrdcoebel taasess forcorwtervi eformaton 1
l N cfcymaten a coredered to be Cr%Ipre'ary adarreeton pursuant to 10 CFR 2 ?g>dHIL I i
T)e rifgreraton eres gwbr9tt'ed arti reEarned e cme from a foreegn sowrce smewant to 10 CFR 27J)d:(2L l 1
- 5. Ne susthhand eformaton gend 30 cNbet corests the ocen gridof ete-agency true escPange er of rtraagency recoros that are not rsedates throwgh cocowv otseg ingsten Oecso?wre of predececnaf riformatcc rveertweso esth the does esseit.al to the Oefeerf%e process Where recorth are methrend e ther er*troty, the f ac's tre ren%
monal ritorowson TM r r3,gregg cgsy cio pr=wmaret process of treanon agmevart no reasonate segregatse (DEMPTION 5# 'scival pornone becawe the reeeee of IPw facts acwed permst an l
- 6. TN arthhad etormaton e ener'eted trcr== puble ^*r** a r e becawse ets dec osu e mead reswit an a clearty we=3 W evesen of certonal prNecy IDEMPTIOes El
- 7. The eatbrand adormaten corsets of e'ves.9atory recoros comp 4ed for tre enforcemer t purposes ed a being == tend 8t:4 Pe reaecrsisi edoed IDEMPfiO* 71 e
W wov d eterfertaesth .* er'8cr: ament groceedeg becawee 11 could rTveel t*e scope. drecten, and toche of enfortement e** orts. ark
- ca cowed posessy anow gr m to tese acton to r%nd poteetans =*ongdoeg or a vcLaten of 8.8'C roow w ements from rwecgators (E.XEMPTION HAO Ducdoeure mowld corevivte m urinerva.ad evanam of personal p.macy 6DEMIPTiOes 7tCu i
TN ewormaton cceests of naves of revidwas arts arter eformaten the doctosure of mNch mo64d reveal cor tmas of cor# der'tel sources ID(MPTIOa, 7 Dii l PART lt C-DENYING OmCIALS i
Pu,rwm t in to C4t 9 9 arus/or 915 of M U $ a usser Rapase:rv Cew repdature, a 4 produ.e a,,n(
t
,he, es - or - e em ~
a,,
. n. - ,secer has been .e * ~deterwured dee , a,e the.emat tre onrd e ymaten,actubs
.ent .d - as ew eoese.r cso st, tre ine Orec,o,.
Opreson of fMes erg Recoros. Orfce er n a,s, tot any cones that may to accented to me becwirve Director for Operatiore flooi .
OtNYlevG OFFICIAt TTTLi rOF FICE RE'OROS OENsED APPtLLATE OFF* CIA-hA 1f)fidAl # '
$)
U d k hal)(dasZ u "
~
i 0
PART 110- APPEAL RIQHTS e r The W by each denyirig ofk:ist idertr d ~ i hrt ILC may be appeated to the Appenate OfficW identded in that sectxm. Any such appeat must be et
,,,tg and rnust be made wetNn E deys of receipt of thrs response. Appea!s rnust be addressed as appropnata to the Esoevtm Drector for Operatons or to the tt.atSery at aofenthe Cornrruseen.
" Ap0*at troen UenS.whiaar Regdatory W Decacn Cunrnisson, WasNngton, DC 20665, and shcnAd clearty state on the envelope and in the netter sinc co8 M aos ee,, a cm FOIA RESPONSE CONTINUATION L NUCLEAR REGULATORY CCMMISSION
c-+
Re: F0!A-84-21 APPENDIX fG (ILd J MM
- 1. Undated Legend for Justification, SSER 22 and 21. (30 pages)
- 2. Undated Sumary of Concerns expressed in interviews. (1 page)
- 3. Undated E7018 ' Stores" to "Red Issue". (1 page)
- 4. 4/19/77 Discrepancy Report. (45 pages)
- 5. 2/23/78 Engineering Standard for Concrete Expansion Anchors for Statis and Seismic Loading. (4 pages)
- 6. 9/15/78 Pullman Power Products. (2 pages)
- 7. 4/16/82 Attachment 5, PG&E Resolution Sheet. (39 pages)
- 8. 6/7/82 Ltr to PG&E from R. M. Polivka, subject: Project Sumary Report. (26 pages)
- 9. 6/11/82 Typical Arrangement of Raceway Support from Concrete Surface. (2pages) 10, 3/1/83 PG&E Design Criteria Memorandum. (36 pages) 11, 11/22/83 Note to C. Gaskin from George Knighton, subject: Diablo Canyon Allegation w/ attached allegation data form. (3 page)
- 12. 12/5/83 Ltr to Dennis Kirsh from W. O. Wade, subjec a Inspection Status Report, reference: Memo, D. Kirsh to d. Wade dated 30 November 1983. (9 pages)
- 13. 3/3/84 Allegation Data form. (1 page)
I Y
.. , , , , _ . - _ . . _ _ _ . . , . _ _ _ . . - . , , , - _ _ . , . _ _ . - . . , . . ,m _ . . _ . _
l fol$- 9 h ob l l Dandu kW)
APPENDIX N May be released in entirety.
Nuncer Date Subject
- 1. 6/13.485 Nonconformance Reprot (Foley Co.) - Re: Spec 8802 6.1 - QCP-SA (1Page)
- 2. 8/2/83 Nonconformance Report (Foley Co.) - Re: QCP-5A Rev. 9 Para 13.2.1 (2 Pages)
- 3. 9/6/83 Nonconformance Report (Foley Co.) - Re: QCP-5A - Quality Control Procedure for AWS Welding D1.1 (9 Pages)
- 4. 9/26/83 Engineering Disposition Request (Foley Co.) - Detail Versus Procedure 1
(1 Page) ,
- 5. 10/5/83 Transmittal (Foley Co.) 2 Pages
- 6. 10/5/83 Transmittal (Foley Co.) (2 Pages)
- 7. i 10/5/83 Transmittal (Foley Co.) (3 Pages) l i
- 8. 10/5/83 Nonconformance Report (Foley Co.) Re: QCP-17, Rev.1, Para ld (2 Pages) t
- 9. 10/7/83 fngineering ']1sposition Request (Foley Co.) Re: Structural Welding Reg;1remen te - (1 Page)
- 10. 10/7/83 Nork cafornvince Report - Re: QC Procedure for Stnactural Welding QCP-St (1 Page)
- 11. 10/7/83 Nonconfont.ince Report (Foley Co.) - Re: Welding AWS Dl .1 QCP-SA (5 Pages)
I
- 12. 10/7/83 Nonconfonnance Report (Foley Co.) - Re: QCP-6 Para 4.4; 4.5; 4.5.1; 4.5.2 (4 Pages)
- 13. 10/7/83 Engineering Disposition Request (Foley Co.) - Re: StnJctural Welding Requirements - (10 Pages) l
- 14. 10/13/83 Nonconformance Report (Foley Co.) - Re: QCP-5A Rev. 9. Para 13.2.1 (2 Pages)
Re: FOIA-84-21 (12th Partial)
APPENDIX 0 RELEASED RECORDS
- 1. Undated Memo for attached from Knighton, subject: Guidance for Preparation of Diablo Canyon Allegations Evaluation.
(4 pages)
)
- 2. 2/18/77 Station Construction Diablo Canyon Project, Pipe Hanger Tolerances, Attention: A.G. Walther from M. R. Tresler.
(2pages) l
- 3. 11/22/77 Diablo Canyon Project Engineering Office Special Instruction, title: "Design Questions submitted by Steam Generation Department. (2 pages) l
- 4. 8/12/78 BLD Subject- Procedure for Handling DP's. (3 pges) l c_v, _s7_
l I
l I
l
l 1
i Re: F01 A-84-21 i (12th Partial) ,
APPENDIX P RECORD ALREADY AVAILABLE IN PDR 1
- 1. 11/29/83 Memorandum for attached list from George W. Knighton, I subject: Guidance for Preparation of the Diablo Canyon l Allegation Evalution. Accession No. 8312090368. (7 l pages) '
l 1
l 1
l
Re: FOIA. 84-21 (12th Partial) -
APPENDIX _0 RECOROS TOTALLY WITHHELD - Exemption (5)
MUMBER DATE DESCRIPTION & EXEMPTION 1
Undated List - Allegations Predecisional or Sensitive. (1 page) 2 1/6/83 Official tra.qscript proceeding before Nuclear Regulatcry Comission entitled:
Nuclear Power Plant. "Staff Meeting Regarding Diablo Canyon (150 pages) 3 11/7/83 Note for Files from Robert A. Purple, subject: Telephone call from Dr. Henry Myers, Subcormittee on Energy and Environment. (2 pages) 4 12/1983 Safety Evaluation Report related to the operation of Diablo Canyon itaclear Power Plant, Units 1 and 2. (52 pages)
NUREG-0675LD, Supplanent No. 21.
5 12/9/83 Memo for George Knighton from Thants P. Speis, subject:
Diablo Canyon Canyon Allegation (Mys 7, 9, and 48). (11 pages) 6 8/16/84 Note to Guy regarding Cunningham Diablo Canyon. w/ attached 2.206 decisions (0 RAFT)
(25 pages)
_ _ _ _ - _ _ _ _ _ _ _ _ _