ML20210U549
| ML20210U549 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/10/1984 |
| From: | Maneatis G PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20210U520 | List:
|
| References | |
| FOIA-86-197 NUDOCS 8610100074 | |
| Download: ML20210U549 (6) | |
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C0!f4ENTS BY G. A. mNEATIS BEFORE THE NUCLEAR REGULATORY Cobt!ISSION February 10, 1984 Introduction Thank you,!!r. Chairman.
I am George Maneatis, Executive Vice President of Facilities and Electric Resources Development for Pacific Gas and Electric Company. With me today are Howard Friend of Bechtel, the LlaMo Canyon Project Completion Manager, Jim Schuyler, Vice President of Nuctear Power Generation, and Bruce Norton, our licensing attorney.
It's a pleasure for me and my colleagues to have this opportunity to provide you with a brief status report on Diablo Canyon and present our comments on SER Supplements 20 and 21.
Status of the Plant After you granted PGandE authority to load fuel and conduct precriticality cold system testing, we began fuel loading on November 15 and successfully completed cold system testing on December 10. We are currently making a final assessment of the plant's readiness for heatup and hot system testing. We expect to begin heatup in the next several days.
If our current schedules hold, we expect to be ready for initial criticality on March 1, 1984. On this basis, and assuming we receive timely action from the Commission on our request for full reinstatement of our low power license, we anticipate completion of low power testing and readiness for power ascension by the end of March,
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i Operator Experience and Training I would like now to discuss briefly the experience and qualifications of our licensed operators and our readiness to commence operations.
We have in place an aggressive program to provide well-trained operators for Diablo Canyon. Forty-three of our people hold Senior Operator Licenses and 16 hold Reactor Operator Licenses. Forty-two are assigned to shift operations as operators, foremen, or shift technical advisors. The remaining licensed personnel are assigned to the plant management staff in engineering, training, or supervisory positions. Twenty-two licensed staff operators are required for our current five shift rotation. Thus, the number of licensed operators substantially exceeds the regulatory required minimum.
Throughout the startup program the operators on each shift will be augmented by an individual experienced in large pressurized water reactor operation.
In addition, a 5-to-8 man plant startup engineering group will be on duty each shift when startup testing is in progress.
This group will be composed of-supervisory and engineering personnel. Finally, to assist further with startup operations, PGandE has contracted with Westinghouse to provide additional technical specialists including nuclear testing advisors, instrument and controls specialists, and plant chemistry specialists.
i Licensed operators at Diablo Canyon typically go through non-licensed and licensed training programs. The non-licensed program is designated to be i
completed in 30 months, although a person can complete it sooner if his experience and capabilities permit. The non-licensed program familiarizes our operators with power plant fundamentals, equipment, systems, watch standing practices, administrative controls, radiation protection, and other such topics. During this program, operators are in training one week out of five, and on shift the other four weeks. Portions of this program are accomplished on-shift, and other portions are conducted off-site at Company facilities.
After successful completion of the non-licensed or equivalent program, operators then begin the 12 to 13 month licensed program. Throughout this program the operator is in training on a full time basis. The program typically consists of 4 months of classrooom instruction on subjects such as reactor physics, thermodynamics, chemistry, and instrumentation and controls; 3 months of classroom instruction on plant systems and procedures; 4 months of operating practice, which includes 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of " hands on" simulator time; and a final 2 months of pre-licensing review. Thus at the time of licensing, a typical operator has 2 to 4 years of training.
Upon receipt of a license, an operator immediately enters the requalification program. During this process the operator is on a training shift one week out of each five. During each training shift the operator attends classes which review the material covered in the initial license training program. At the end of a year, the operator is given a requalification examination covering topics discussed during the year. This examination is comparable in scope to the NRC licensing examination.
In addition, each operator is given 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per year of hands on simulator time.
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The delays which Diablo Canyon has experienced have afforded most of our key personnel an excellent opportunity to observe the construction of the plant and to become intimately familiar with its systems and equipment. These people have participated in the preoperational testing program; one or more of the three hot functional testing programs; and the ongoing testing, maintenance, surveillance, and modification programs. Our operations personnel have also had the opportunity to obtain additional simulator experience beyond that required in the training programs I just described.
Licensed operators at Diablo Canyon typically have 200-300 hours of " hands-on" PWR simulator training at the Westinghouse Zion simulator in Illinois.
I should note that an On-site training facility, which will house a plant specific simulator, is in an advanced stage of construction at Diablo Canyon and should be fully operational this summer.
In sumnary, we have in place a licensed operator staff and training program which meet all applicable regulations and licensing criteria. We are confident that our operations staff is well trained to start up and operate Diablo Canyon in a safe and efficient manner.
Comments on SSER 20 and 21 i
i I would now like to comment on SER Supplements 20 and 21. With respect to i
Supplement 20, we have carefully reviewed it and find that it acct.rately f
characterizes the status and resolution of tre concerns identified in Supplenents 18 and 19. We agree that all itens required for initial criticality and low power testing--Step 2 of the three-step licensing process--have been satisfactorily resolved.
Further, we agree with the Staff 4
that the few remaining action items for Step 3 can be completed prior to full power authorization. Our schedule calls for completing the last of these items by the end of this month. These items involve only minor analyses or further documentation and will not affect systems or components necessary for low power testing. As such, they will not preclude or otherwise interfere with activities associated with low power testing.
With regard to supplement 21, this Commission is aware that the Staff has received numerous allegations regarding Diablo Canyon during the past 2 to 3 months. The Staff has established an orderly and comprehensive program to investigate all of these allegations. This program was explained to you on January 23rd. We are cooperating fully with the Staff in its investigative effort. PCand2 has also initiated a similar program to investigate those allegations which have been communicated to us in sufficient detail to allow a meaningful investigation. We are submitting a substantial amount of detailed information to the Staff on such topics as small bore piping, welding, inspector qualification, design control procedures and record retention.
It has always been, and will continue to be, PGandE's policy to examine and 3
evaluate all allegations. When questions or concerns are raised, regardless of their source, they will be investigated and resolved. We believe a k
substantial number of allegations have been and will be resolved as having little or no merit. Others have raised questions or concerns which are r
answerable and resolvable. We are unaware of any facts evolving from the allegations investigated to date which would preclude the safe operation of Diablo Canyon.
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Concluding Remarks As our actions over the last several years have amply demonstrated, PGandE has spared no effort to assure that Diablo Canyon is properly designed and constructed in compliance with its licensing requirements. We are confident that our operations staff is qualified to start up and operate Diablo Canyon safely. We hope that the Commission shares our view and will approve our request for full reinstatement of our low power license.
Thank you for the opportunity to present our comments.
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A934 PREPARED STATEMENT OF THOMAS DEVINE LEGAL DIRECTOR, GOVERNMENT ACCOUNTABILITY PROJECT OF THE INSTITUTE FOR POLICY STUDIES ON THE DIABLO CANYON NUCLEAR POWER PLANT before the NUCLEAR REGULATORY C0!NISSION February 10, 1984 ssE#sJ8 f.
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Thank you for the opportunity to appear today on behalf of the San Luis Obispo, California, Mothers for Peace.
I an Thomas Devine, Legal Director of the Government Accountability Project of the Institute for Policy Studies.
Since November 1983, GAP has been interviewing current and former employees from the Diablo Canyon nuclear power plant to investigate alleged design and construction quality assurance (QA) violatiens.
To date, my partner John Clewett I
and I have spoken with 30 current or former employees, about two-thirds of whom still work at the plant.
We have taken eight affidavits from these workers.
.In addition, we have reviewed and forwarded to the Nuclear Regulatory Commission (NRC) staff thousands of pages of documents that provide evidence for the allegations of Diablo Canyon whistleblowers.
Although we do not yet have all the details, our preliminary conclusions are clear:
in terms of quality assurance, Diablo Canyon equals the worst lemons in the nuclear industry.
It is clear that the scope and intensity of the quality assurance breakdown rank with those at Zimmer, Midland, and the Three Mile Island cleanup.
On February 2, 1984, through
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a petition under 10 CFR 2.206, the Mothers for Peace filed the first 170 allegations from GAP's ongoing investigation.
We hope to supplement that record in approximately a week with the results of GAP's most recent investigative efforts.
In the petition the Mothers for Peace requested that the Commission defer sny decision on whether to grant a low-power operating license to the Diablo Canyon Nuclear Power Plant i
(Diablo Canyon or DCPP) until completion of --
(1) a comprehensive, third party reinspection program of all safety-related construction in the plant, with full authority by the independent organization to identify and
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impose corrective action on any nonconforming condition that deviates from 10 CFR 50, Appendix B, the Final Safety Analysis Report (FSAR) or plant specifications, through implementation 5
of corrective action; (2) an independent audit of design quality assurance, including the reliability of conclusions from remedial design verification programs Unposed since 1981 such as the seismic design review; (3) development of a full factual record on Pacific Gas and Electric's (PG&E) character and competence to operate the Diablo Canyon nuclear power plant, including i
(a) a management audit by an independent organization, (b) publication of a report by the NRC Office of Investigations (OI) following a full investigation to determine the causes of construction and design QA violations at Diablo Canyon, including issues such as harassment and retaliation, subordination of quality assurance to cost and scheduling concerns, destruction of records and false state-ments, and deliberate violations of the Atomic Energy Act; and (4) a full program of public participation for the selection and oversight of independent organizations described in #1-3 above, including NRC review and approval of independent organ-izations from nominations submitted by either PG&E or any interested member of the public, and creation of a public over-sight committee consisting of equal representation by state and local representatives and the intervenors with the authority to obtain all requested information and to conduct legislative-l style public oversight hearings.
I.
CONSTRUCTION QUALITY ASSURANCE BREAKDOWN A.
Scope of the violations A sample of violations, alleged in affidavits from whistleblowers and confirmed by internal documents, include --
(1) uncontrolled welding and weld repairs, due to unqualified, incomplete or irrelevant procedures; (2) uncontrolled materials for important safety-related work, such as the use of common hardware metal that, when welded to sensitive nuclear-grade materials, could cause brittleness or corrosion; (3) uncontrolled installation of structural steel hardware due to incomplete procedcres that failed to cover all of the relevant work assignments, and purchase of the wrong size or shape hard-ware which was then chiseled into shape or otherwise forced to "make do" on an ad hoc basis; (4) suspect " approved" procedures, because the same procedures flunked laboratory tests, but were resubmitted up to three times until they " passed" --
meaning that the hardware in the field may not be any more reliable; (5) unreliable Nondestructive Examination results, due to unqualified procedures, references to procedures that weren't even issued when the examinations occurred, or manipula-tion of the results; (6) unreliable tests for the measurement of minimum valve thickness, due to unqualified procedures, use of inappropriate equipment which did not accurately measure all 1
-4 surfaces, and failure to include all of the relevant valves; (7) ineffective quality control for vendor-supplied equipment used to measure and test the adequacy of hardware generally; (8)
PG&E management orders not to inspect welds supplied by t
outside vendors, after contractor quality control personnel discovered repeated defects such aa cracks; (9) suspect qualifications for welders and weld inspectors, due to cheating on exams and poor training; (10) hydrostatic tests on piping that must be redone, because the first time they were conducted without QC oversight, consistent procedures, or the proper temperature and pressure to demonstrate that the pipes will hold; and (11) consistent management circumvention of reporting requirements to the NRC, from routine nonconformances to significant events, in the construction, engineering, and QA departments.
B.
Impact on the hardware The effects of the quality assurance breakdown on the plant's hardware have been dramatic.
Whistleblowers have described "truly abominable" vendor welds so ragged that they tear clothing; site weld backing bars that fall off when lightly l
tapped with a hammer; undocumented overwelding that increases f
the stress on piping and systems but has not been factored into engineering design calculations; crooked or loose beam clamps 4
that help support electrical cable trays; and numerous instances
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where the hardware is in different locations than specified on the plant's approved drawings, such as with the shims for base-l plates.
As one whistleblower told me on Tuesday, the best that can be said is that "they don't know what they've got out there."
.. t C.
Quick Fix" programs In theory the " Quick Fix" program, later renamed the Pipe Support Design Tolerance Clarification (PSDTC), is a field engineering correction action program.
In reality, whistle-blowers have convinced GAP that it is an uncontrolled, under-ground engineering program with the authority to casually overrule the approved design, and to substitute informal repairs for the legal quality assurance (QA) reporting and corrective action system.
It spans both the design and construction quality assurance breakdowns at Diablo Canyon.
2 Management only issued instructions defining the' Quick Fix program to a handful of the participating engineers, and to j
none of the QC inspectors affected by this extraordinary authority to veto the design.
Even then, the guidelines were deficient; they failed to disclose preconditions for PSDTC action, such as the scope of and extent of a PSDTC engineer's authority.
The Quick Fix program substituted for the normal noncon-formance reporting system throughout the design and construction i
QA process.
This could mask deficiencies from NRC audit and review.
The Quick Fix sheets demonstrate significant hardware problems and should be systematically reviewed by the staff.
4 The Quick Fix authority was abused.
It was used to f
completely redo the design of hangers, to delete hangers and l
to delete weld symbols, all without any engineering calculations.
The latter practice was the technique used to override QC in spectors.
In theory the Quick Fix determinations were sub-i jected to later engineering review.
But the reviews were J
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spotty at best, and management told Mr. Stokes that 98% of the i
PSDTC's in his group were approved.
To put the program in perspective, in an affidavit a Pullman quality control inspector described it as "one of the worce aspects of the whole system at Diablo Canyon."
D.
Causes of the quality assurance breakdown While the effects of the QA breakdown are complicated, the causes were simple:
the subordination of QA to construction.
Neither PG&E nor Pullman management had the commitment to enforce QA requirements.
QA management viewed itself as a support unit for the construction department, rather than an independent check on the quality of work performed by construction.
In fact, there was not even consistent agreement among site manage-ment whether there was a commitment to build the plant to 10 CFR 50, Appendix B.
j The QA breakdown permeated the organization at Diablo i
Canyon.
In some cases, such as welding threaded studs, the system of checks and balances broke down at avery stage successively for the same work, 4
i The management philosophy resulted in a loss of organiza-tional freedom for quality assurance personnel.
Management failed to provide copies, and even denied access to personnel j
seeking prcfessional codes and other necessary research materials.
Pullman QA management ordered inspectors to stop inspecting work after problems were identified, to stop issuing reports and to stop tracing where faulty procedures had been I
used.
Management enforced its restrictions on organizational freedom by retaliating against those who did not know their place.
Harassment, attempted intimidation, and personnel i
reprisals permeated the entire QA program, not just those activities concerning special processes.
The pattern extended i
within other departments as well, such as PG&E construction.
The harassment has been occurring at least since 1978, and has intensified during the last three months.
The methods include such tactics as physical threats by construction employees, threatened job actions, reprimands, denial of raises, isolation, and dismissal.
It is an understatement to conclude that there has been a " chilling effect" from the reprisal crisis at Diablo i
Canyon.
A quality assurance Ice Age would be more accurate.
1 Due to the pervasive repression, an unknown number of deficiencies have not been reported.
As a former auditor explained, "Those who persist in reporting the violations are I
dismissed, or harassed relentlessly until they resign, or give up and stop trying." A current QC inspector concluded, "One of the biggest threats to effective QC work at Pullman Power Products is the fact that inspectors know they can be fired for doing their jobs too well."
l The effects of the organizational breakdown have extended l
to falsification of records and destruction of documents.
Witnesses have indicated that these practices have occurred in the design, construction and quality assurance programs.
At best, management's approach to corrective action has 1
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been prospective only.
Whistleblowers repeatedly have confirmed
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.. 1 this phenomenon.
Old work, such as that covered in the 1977 Nuclear Services Corporation audit of Pullman, is left as is.
We do not believe that it is acceptable to "let bygones be bygones" and pledge to do it right in the future, when PG&E says the plant is done.
If anything, the violations may be intensifying.
To illustrate, on December 28, 1983, Pullman revised Procedure ESD 223 with respect to fillet weld sizes for pipe supports.
The procedure was modified to add two provisions:
"D.
For existing installations, welding which was performed but was not required as part of the design is acceptable.
E.
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existing installations, welding which was not performed but was required as part of the design is acceptable."
In other words, anything is now acceptable.
While this approach officially eliminated a nagging problem, it did not solve it.
These offenses could not have occurred.so systematically without negative leadership from management.
Although some of the safety allegations are debatable, a consistent pattern is clear:
management does not want to hear about these problems from workers; and is even more determined that no one else hears about them.
The tools for this philosophy are intimida-tion, retaliation, records falsification, and records destruction.
That is how problems remain covered up for 12 years.
The results are a plant whose quality is indeterminate, at best.
II.
DESIGN QUALITY ASSURANCE BREAKDOWN GAP began its Diablo Canyon investigation in response to an urgent request from the Mothers for Peace to speak with l
Mr. Charles Stokes before he left the area.
Until October 15, 1983, Mr. Stokes was an engineer in the seismic design review program.
Mr. Stokes and other engineers revealed a design quality assurance breakdown equally pervasive to its.construc-tion counterpart.
The effects include unreliable results from the seismic review, and an unreliable Emergency Core Cooling System (ECCS).
There also may have been generic breakdowns in document control, field modifications and the accuracy of design drawings.
As with construction quality assurance, engineers who seriously challenged the violations consistently lost their assignments or their jobs in reprisal.
The design QA breakdown is particularly significant, f
because the subject has been reviewed in licensing hearings.
To a great extent, the hearings did not include the allegations below.
This raises questions whether PG&E has fully disclosed all relevant material to the Atomic Safety and Licensing Appeal Board.
III.
NRC OVERSIGHT AND ENFORCEMENT GAP represents five whistleblowers for purposes of dis-closures to the Nuclear Regulatory Commission.
Based on experiences from these interviews, GAP investigators have developed respect for the diligence and intelligence of the NRC staff assigned to the case.
While we drastically disagree with some of the practices in the current inspection, we do not question that the disputes are in good faith, or that mistakes 4
are just that.
However, the Mothers for Peace and GAP must strongly protest practices which compromise the reliability of the record as the basis for a licensing decision.
A.
Failure to examine the organizational causes for the QA breakdown This case cries out for the full participation of the Office of Investigations (OI).
Unfortunately, to date 01 has not begun its job for the bulk of the relevant issues, including retaliation and records falsification / destruction.
In the meantine, the inspection team has openly discussed issues with PG&E and its contractors that fall under 01's jurisdiction.
This offers the potential targets of criminal investigation an opportunity to identify the relevant issues and perfect their defenses, all while OI waits on the sidelines.
Even worse, whistleblowers have informed GAP of records destruction following visits by the inspection team.
It would be premature to make any further licensing decisions until the allegations of retaliation and falsification are resolved.
These issues are directly relevant for any licensing decision.
Under 10 CFR 19.20 and 19.30, a license can be suspended or revoked for retaliation against employees.
See also Union Electric Company (Callaway Plant, Unit 1),ALAB-740, 17 NRC step op. at 2-3 (September 14, 1983).
Similary, false statements can be an independent grounds to deny an operating license.
Houston Lighting and Power Company (South Texas Project, Units 1 and 2), CLI-80-321, 12 NRC 281 (1980).
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Overall, a legally-valid operating license decision requires more than a narrow technical review of engineering i
decisions.
A license cannot be granted until the licensee has demonstrated through its construction program the necessary character and competence to run a nuclear plant. (Id.)
Based on the evidence obtained over the last three months, there is no basis for confidence that PG&E has met that 4
standard.
The answers will only be available after OI identifies the causes of the quality assurance breakdown at Diablo Canyon.
B.
Accepting prospective-only corrective action It would be most unfortunate if the staff's oversight mirrored this flaw in the licensee's program.
Unfortunately, that may have occurred.
To illustrate, in response to Allegation #93 by Mr. Charles Stokes, the staff accepted the Pullman explanation that the inspectors assumed a 45-60 degree j
weld angle if the information were not included on relevant The drawings and instructions to guide their inspections.
staff failed to disclose, however, that this practice only l
began on June 23, 1983, when an internal memorandum was issued after Mr. Stokes refused to accept a weld in the Quick Fix program otherwise.
In other words, the staff based its c
decision on facts only accurate for the last seven months.
The problem is that welds during the first 13% years of construction could be just as significant for public safety.
Again, the enforcement program is too narrow.
r C.
Advance disclosure of proposed violations In a January 31 public meeting at PG&E offices, the NRC warned PG&E that certain draf t proposed violations are barriers The staff then to recommending a low-power operating license.
distributed a handwritten draft copy of the proposed violations and offered the licensee a week to change the staff's mind.
GAP and the Mothers recognize the need to obtain all relevant facts prior to proposing violations.
Indeed, we seek to extend that principle to the licensing decision itself.
But offering draft violations to licensees for informal rebuttal is going too far.
Surely the Commission's policy not to release draft copies of inspection reports should apply to significant portions of the reports, such as the findings of illegality.
The draft violations are enclosed as Exhibit 1.
D.
Gag order on February 7, 1984 plant tour On February 7, 1984 GAP attorney John Clevett and a j
whistleblower accompanied a Commission representative on a Due to the objections of PG&E's attorney, the plant tour.
two citizen representatives were not permitted to speak to the Commission representative except in response to his As questions.
He did not have any of a substantive nature.
a result, the NRC missed an opportunity to observe significant I
evidence of the effects from QA violations.
The whistleblower had come prepared to point out examples of specific defective l
hardware and welds.
The Mothers for Peace request that another f
plant tour be scheduled when the whistleblower has the organiza-tional freedom within the NRC's program to identify safety hazards.
4 In conclusion, we believe that under these circumstances, any decision on a low-power operating license for Unit I would be premature.
If even a significant portion of the whistle-blower allegations are confirmed, the plant is not close to meeting Atomic Energy Act requirements.
Its quality would be indeterminate and its management untrustworthy.
Because PG&E already may have circumvented accountability in the last NRC remedial program, an improved structure of independent fact-finding and intensified public oversight is necessary to reestablish legitimacy and to obtain reliable results.
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