ML20197G338
| ML20197G338 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/19/1984 |
| From: | GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20197F755 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8404170600 | |
| Download: ML20197G338 (3) | |
Text
/-if'f 2 0 g.WERNMENT A.CCOUh'IADIUTY PROJECT,
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,' hst t. te ic Pob:y 5tudies (202)234 0 190s Ove Stree:. NN.. Woshinoton D C. 20000 P3rch 19,1984
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Mr. Richard C. DeYoung Director, inspection and Inforcement U.S. Nuclear Regulatory Comission Washington, D.C.
20555
Dear Mr. DeYoung:
In the past several weeks, the Government Accountability Project (GAP) has had These workers and intensive dealings with whistleblowers in the Region IV area.
former workers come principly from two nuclear plant sites under construction--
Comanche Peak and L'aterford.
Although our findings, at this point, cannot even be categorized as preliminary" at either location, we have been extremely disturbed Further, we are disturbed by evidence of historical lack of oversight at both sites.
that the posture of the agency throughout the licensing hearings, and in its daily operation, reflects such a blatant and biased " pro-utility, regardless of the facts,"
attitude.
Today, we have filed a request, pursuant to 10 C.F.R. 2.206, regarding the Comanche In that request, we have asked the Comission for the following ir:nediate Peak site.
actions:
Require a comprehensive management audit of the Texas Utilities and 1.
Generating Company (TUGCO) officials by an independent management auditing fim to assess the c'ause of the continuing inability of TUGC0 and its contractors to implement an ecceptable design and con-struction program for the Comanche Peak site that meets the require-ments of 10 C.F.R. 50, Appendix B.
Require an independent design and construction verification program 2.
(IDVCP) to assess the integrity of the Comanche Peak site quality assurance (QA) program.
Suspend the Comanche Peak Construction Permit until the completion of 3.
the special NRC inspection and IDVCP, and an analysis of the results of those inspections which should include public participation, to deterrine the appropriateness of further audit or other requirements.
We sincerely believe that the only way to get the Comanche Peak site under ir:raediate control, and avoid any further destruction of documentation, and equally important, to restore the confidence of the workforce in the NRC, is for you to issue an imediate Stop Work Order on the site.
Finally, we believe that an appointment of a separate inspection team made up on Comission employees from the Office of Nuclear Reactor Regulation (NRR) and other regions is necessary to do an adequate and unbias probe 'into the extent of the QA design and hardware deficiencies at the Comanch site.
GW 20lA-85-59 a e
hr. F.it hcrd C. Moung brch 15,1SM
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As you may recall. GAP did an analysis of the generic defects and weaknesses in the NRC Inspection and Investigation Process which we presented to Congress in June,1983.
We have found that almost all of the defects we identified apply to Region IV.
Sum-marized below, those are:
A.
In its approach _ to whistleblowers. Reoion IV has:
1.
violated the confidentiality of whistleblowers, either directly or indirectly; 2.
narrowly defined issues raised by whistleblowers and failed to inspect beyond hardware examples the witness was able to identify specifically; 3.
failed to record interviews or take affidavits, particularly on the most significant issues being raised by whistleblowers; 4.
failed to ' include affidavits in the public reports when the statements contradicted the NRC's party-line on the problems at nuclear plants; 5
failed to keep pace with new whistleblower allegations in a timely manner; B.
In its approach to utilities, Reaion IV has:
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6.
conducted closed-door meetings with utility and contractor executives when investigating whistleblower allegations; 7.
provided advance warning to utilities about where and when Region IV was going to inspect hardware; 8.
relied on industry's technical conclusions without disclosure of sup-porting data and calculations for evaluation of whistleblower allegations; 9.
offered advance, informal review of decisions to the targets of Region IV investigations and inspections, thereby permitting utilities to escape accountability through informal, often-unenforced cormnitments 'not to do it again;"
1
- 10. reviewed and informally approved licensee practices before approved by corporate officials with QA responsibilities, thereby undercutting the employees who tried to carry out their duties objectively despite the pressure of management urgings that "it's all right with Region IV, so why are you holding this up?"
C.
In its approach to the Dublic, the NRC has:
- 11. attempted, as a knee-jerk reaction, to discredit critics--whether whistle-blowers, anti-nuclear organizations, or simply interested and concerned citizens--by questioning their motivations, patriotism, integrity, and technical competence to raise questions about public health and safety;
- 12. destroyed drafts of reports, significant tape recordings, created secret files, failed to admit the existence of documents requested under the Freedom of Infomation Act (F01A), and given confidentiality to utility l
h:rch 15,1914 h. 1.u N -c C. hicene
-3 executives in order to prevent the public from learning how inspectior, findings were covered up.
We are aware that there are currently internal investigations going on regarding the actions of Region IV employees.
We believe that r.any of our witnesses have information which will be relevant to those investigations.
A copy of this letter has been given to that office.
We also respectfully suggest that you consider instituting your own review and audit of the regulatory policies being implemented i'n your Region IV office.
We believe that a rigorous audit and inspection by other regional inspection and enforcement personnel i
would provide you with insight into the cause and the extent of the problems in that regior..
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Please notify me irxnediately concerning your decisions regarding Comanche Peak.
As you will note on Page 6 of the 2.205 request, the method by which GAP will handle the rest of its investigation will depend on the agency's response.
Thank you for your attention to this rsatter.
Sincerely.
6 MKJ fW1R ~
Citizens % r y-O e