ML20211P630
| ML20211P630 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/21/1985 |
| From: | Connelly S, Mulley G NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML20211P508 | List: |
| References | |
| NUDOCS 8607230318 | |
| Download: ML20211P630 (221) | |
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REPORT OF INVESTIGATION TITLE: DIAnw CANYW - AUKATIWS T MISCWWCT BY E M N shis mform tion shouid not be included m the N : a l l Occument Raom or mcorporated in any other file system. . i Subsequent to appropnate review andfor actior' the document is subject to thedescritto provisions. - inal report submitted for review / action B. ,Pending report submitted for:n.enfaction. l* C. _Information of officialinterest, no action equired. D. _ Return to 01A in desenbe2 time _ ( daysl. . E. Return v:s ma 1 TO BE OPENED Bf ADDRESSEE CNLY. F[No reproduction el at: acted document permitted. N [ CAUTION l1 ) Recuts:s for theesclossre of the attached document (s) i l PREPARED BY: Geo A. Mulley, Jr. "' Investigator, OIA a"2 Auito'- a - -~ TA*fM"/Ch' 'g'
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APPROVED BY: Sharon R. Connelly DATE: /' '/> I l l Director, OIA . p l r l I OFFICE OF INSPECTOR & AUDITOR l U.S. NUCLEAR REGULATORY COMMISSION l - FREEDOM OF INFORMATION/ PRIVACY ACT EXEMPTION .@.)..(5)& (7) (A) 1 0FFICIAL USE ONLY 8607230318 860711 i PDR COMMS NRCC CORRESPONDENCE PDR
1 s t s BACKGROUND In September 1984, Comissioner Zech received a letter from an alleger con-cerning the licensing of the Diablo Canyon Nuclear Power Plant (Diablo Canyon). While the letter raised several issues, the alleger was specifically concerned with confidentiality for allegers and feedback to allegers. In response to Comission interest, these two areas were addressed as systemic issues in our May 1985 audit report entitled " Review of NRC's Allegation Management System." In November 1984, OIA contacted the alleger to obtain additional infonnation regarding his concerns with Diablo Canyon. We were referred by the alleger to Thomas Devine, the Legal Counsel for the Government Accountability Project (GAP). As a result of infonnation from Devine which indicated a breakdown of NRC's allegation management system for Diablo Canyon, OIA conducted a review of allegation management for Diablo Canyon. We reviewed 10 CFR 2.206 Petitions, affidavits, and other documents submitted to the NRC between January 1984 and May 1985 for allegations of misconduct by NRC employees. Where necessary, we followed up with interviews of allegers to obtain additional details surrounding particular allegations or concerns. We then
.s.
examined applicable documentation and had discussions with appropriate NRC , officials in an attempt to follow-up on the alleger's concerns. The results of this review are being documented in an OIA report entitled " Review of Allegations Management for Diablo Canyon." As a result of OIA's record reviews and interviews of allegers, six instances were identified where John B. Martin, Regional Administrator, Region V NRC, allegedly made false or misleading statements during testimony to the Comission. DIA reviewed these six allegations and determined that these specific instances of alleged wrongdoing warranted investigation. Our inves-tigation into these allegations of false or misleading statements by the Region V Administrator is documented below. Sumary Allegation 1: On March 26, 1984, the Region V Regional Administrator made a false or misleading statement to the Comission regarding the use of ANSI N45.2.6 as the applicable standard for Non Destructive Examination (NDE) personnel. On March 26, 1984, during testimony before the Comission (excerpts at Attach-ment 1), Martin, in reply to a request from Comissioner Asselstine, stated:
"The second one is interesting. It's a very forceful statement that a
[ sic] non-destructive examination personnel were not qualified properly, l in accordance with ANSI-N45.2.6. This is true. ANSI-N45.2.6 is not the applicable standard. The applicable standard is what? , SNT-TCIA (Reply by Bishop)
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s Which the very same alleger includes in the package later, a letter from
. him.saying they were qualified adequately to that one. So this is one thal we feel is adequately resolved at this point."
OIA found that the comments by the Regional Administrator were in response to coments in a March 23, 1984, GAP submittal to the Comission (excerpts at Attachment 2) which contained allegations concerning Diablo Canyon. An issue raised by GAP in this submittal was the NRC staff relied on false statements as the basis to reject alleger's concerns. The second example offered by GAP in support of this allegation was the Pullman Power Products Corporation (Pullman) and Pacific Gas and Electric Company (PG&E) contention that "Non-destructive Examination (NDE) personnel have been qualified since at least 1974 under the requirements of the relevant professional code, the American National Standards Institute (ANSI). Specifically, PG&E claims to have met the standards in ANSI N 45.2.6." GAP argued that this contention was false. DIA reviewed documentation concerning the comitment by Pullman Power Products Corporation (Pullman) to ANSI. Our review determined that NDE personnel were not required to be qualified to ANSI N45.2.6. The applicable standard for NDE personnel was ASNT Recomended Practice No. SNT-TC-1A (excerpts at Attach-ment 3). OIA reviewed the transcript of the testimony before the Comission concerning Diablo Canyon that was held during the morning of March 27,1984(excerptsat Attachment 4). In response to the coments by Martin on March 26, 1984, John Clewett, an attorney for GAP, stated:
"it seems that the staff is trying to avoid the witnesses and avoid the issues. I think you can see that throughout the staff's response. I don't have time and I won't try to take your time to go into any great detail, but one single example of that is in our letter which we dated the 23rd, one of the specific points that refers to a material false statement by PG&E has to do with qualifications of quality control personnel.
"Now because of the haste with which this was put together, this letter refers to these as nondestructive examination personnel. In fact, as you.
can see by' going back to the actual materials and in particular, the affidavit of Stephen [ sic] Lockert, the question is not the NDE personnel but it is the quality control inspectors. PG&E said in its letter, DCL-84-082,thatPullmanPowerProductscanqualified[ sic]allofitsQC inspectors, that they were all certified to ANSI N45.2.6. This rebuts that in considerable detail.
"The staff which said that they had read all of these materials reviewed the letter and focused on the fact that it erroneously said NDE personnel and said they don't have to meet ANSI N45.2.6. So as far as we are concerned this issue is closed. Well, the issue is not closed because regardless of the fact that there was a typo or a 'thinko' perhaps in writing this up, the issue still remains."
During testimony on the afternoon of March 27, 1984 (excerpts at A tach-ment 5), Martin responded to Clewett's rebuttal by stating: f
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- "And the other business about the factually incorrect statement about the nondestructive examination personnel I'm not sure how we are supposed to deal with 'thinkos' or ' typos' or whatever in letters. We dealt with what was written, not with what they may have intended, and really that's all I have to say.",
In view their Marchof the above coments. OIA reviewed the second exampleincited bletter to the Comissio 23, 1984, support of their contention that the NRC relied on false statements by the licensee to ' reject alleger concerns. The second example, which is entitled
" Qualifications of quality control personnel," briefly outlines GAP's belief that the licensee provided false statements to the NRC concerning the qualifi-cation of quality control inspectors. In this section of the letter, GAP writes that NDE inspectors are not qualified in accordance with ANSI N45.2.6, as claimed by PG&E and Pullman. Attached to the March 23, 1984, letter is an affidavit of Steven Lockert (excerpts at Attachment 6). In his affidavit Lockert discusses in detail his " knowledge of false and misleading statements made by the Pacific Gas and Electric Company (PG&E) to the Nuclear Regulatory Comission in recent investigations concerning construction Quality Assurance." The first subject discussed was " Qualification of Pullman' Quality Control Inspectors" and "PG&E's assertion that Pullman Power Products has Quality Control inspectors certified to ANSI N45.2.6 requirements." Lockert asserts that "PG8E has alleged that the Pullman inspectors are certified to ANSI N45.2.6 requirements. This statement is totally false." Lockert then provides detailed information in support of his contention Pullman quality control inspectors were not certified to ANSI N45.2.6 requirements.
OIA reviewed Region V Inspection Report 83-37, dated February 29, 1984 (excerpts at Attachment 7), and found that Item Number 17 of the inspection report documents the results of NRC's examination of the procedures for qualification and certification of NDE and inspection personnel that were in Pullman's program before September 1977. The inspector checked two olant procedures ESD-235, " Nondestructive Examination Personnel Qualification and Certification Procedure," (September 25,1973) and ESD-237, " Quality Assurance inspector Training Program" (February 26,1984). According to Pullman, the requirements for qualification and certification of field inspectors were
- added in ESD-237 on September 25, 1973, to reflect the requirements of ANSI N45.2.6 which had just been published. The NRC inspection determined that in virtually all the cases examined by NRC, welding Quality Assurance Inspectors began performing their duties without fulfilling the specified requirements and without completing the training required by ESD-237. The failure to assure that Quality Assurance Inspectors were qualified and certi-fled in accordance with the Pullman quality procedures was considered an apparent item of noncompliance. The NRC inspector concluded that while NDE personnel were properly certified prior to perfonning nondestructive examina-tions, Pullman welding inspection personnel performed inspections prior to being certified.
In PG&E letter, DCL-84-082, dated February 29,1984(Attachment 8),PG&E provided Martin with documentation of Pullman quality control welding inspector qualification. The enclosure to the letter stated that in February 1974 Pullman procedure ESD-237 was issued and approved and was fully implemented by June 1974. Procedure ESD-237 complied with ANSI N45.2.6 with the exception of establishing inspector levels. In 1982, procedure ESD-237
was modified to include identification of inspector levels as a result of a PG8E audit and a contract specification change which required full compliance with ANSI N45.2.6. Joh'n 8. Martin, Regional Administrator, Region V, when interviewed (Attach-l ment 9) stated that the applicable qualification standard for NDE personnel is * ' SNT-TC-1A while ANSI-N45.2.6 is the applicable standard for quality control inspectors. The second item in the March 23, 1984, GAP letter to the Comission,.to which Martin was referring when he made the comment ~ on March 26, 1984, alleged that "NDE" personnel were not qualified under ANSI N45.2.6 as claimed by PG8E. Consequently, Martin claimed his response was I correct when he addressed that allegation by stating to the Commission that NDE personnel have to meet only the standards of SNT-TC-1A. The point he was trying to make when he made the coment was that GAP's allegation was I factually wrong. i Martin then discussed his reply to the rebuttal made by John Clewett before the Comission on the morning of March 27, 1984. During testimony before the Comission on the afternoon of March 27, 1984 Martin responded to the Clewett l rebuttal by stating, in part, that Region V " dealt with what was written, not with what they may have intended." Martin stated that he was given no notice by the Comission when the morning session of the March 27, 1984, Comission meeting recessed for lunch that he would be required to respond to Clewett's ) remarks when the meeting reconvened. Martin had only a vague recollection of.
- what Clewett had said, and he had not taken detailed notes. In fact Martin was still uncertain about the point GAP was trying to make. When Martin was J called to respond to Clewett's remarks, he had no intention of trying to l
i portray that Region V had completed a thorough examination of the March 23, 1984, GAP letter. Additionally, Martin did not want to react to Clewett's morning corrnents and further evaluate GAP's March 23, 1984, submittal on the spur of the moment. As stated in the transcript, he wanted to take a closer ! look at what Clewett and GAP had to say before commenting further on the allegations. By way of additional explanation, Martin stated Region V received the GAP letter on Friday evening, March 23, 1984. During the weekend between March 23 l and 26, 1984, Region V read the GAP letter to get a " sense" if GAP was raising-l any substantially different issues from the ones Region V had already investi-
- gated. This purpose was accomplished by reviewing the issues outlined in the cover letter and reading through the attachments. Region V did not study the attachments to the letter and did not evaluate the merits of individual allegations other than to detennine if they were similar to previous GAP allegations and submittals or were new allegations of such impact to warrant resolution prior to low power operation.
Conclusion \ OIA's review of documentation concerning Pullman's comitment to ANSI dis ' l
- closed that NDE personnel were not required to be qualified to ANSI-N45.2.6.
The applicable standard for NDE personnel was ANST Recommended Practice No. SNT-TC-1A. Consequently, we found that Martin was factually accurate in his statement to the Commission regarding the qualification of NDE_ personnel. l l t 1 L- -
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( 5 I OIA believes, however, that the issue raised by GAP in its March 23, 1984 submittal was alleged false statements by PG&E concerning the qualification of qual.ity control inspectors - not just NDE personnel. This was the issue discussed in Lockert's affidavit which was attached to the GAP submittal and in Region V Inspection Report 83-37 which identified PG8E's failure to assure that welding inspectors were qualified and certified in accordance with procedural requirements. Additionally, the comments made by Clewett to the Commission on March 27, 1984, further clarified that the GAP concern pertained to PG&E false statements to the NRC regarding the qualifications of quality control personnel. Therefore, we believe that Martin's testimony on March 27, 1984, that "we dealt with what was written, not with what they may have intended, and really that's all I have to say" did not provide a straightforward answer to Commissioner Asselstine's original question concerning the allegations raised in tne March 23, 1984, GAP submittal. Allegation 2: On March 27, 1984, the Region V Regional Administrator made a false or misleading statement to Commissioner Gilinsky regarding close-out interviews with allegers. According to GAP the Regional Administrator implied there were several follow-up interviews with an alleger, when in actuality there had been only initial interviews. Furthermore, Martin allegedly stated to Commissioner Gilinsky that follow-up interviews had been conducted with , allegers subsequent to Region V's resolution of the issues. OIA reviewed the Conmission transcript for the afternoon of March 27, 1984 (excerpts at Attachment 10). Starting on page 270, Commissioner Gilinsky stated:
"Well, let's see. I think what the man from GAP was saying was not that no effort had been made to talk to these people, but I think he was saying that no contact had been made subsequent to your resolution of the issues."
Or. page 271 Martin replied to Commissioner Gilinsky by stating:
"That's what I'm saying, that that's not true in all cases. So it's just' not a true statement."
"Another assertion was made that no effort was made to get ahold of Mr. Hudson. Well, that's not true. On the slide I passed out to you yesterday, we had talked to him for at least nine hours involving several people at several different times."
"So to paint the picture that we made no effort to talk to the man or plumb him for his concerns is just not true."
March 27, 1984, Commission OIA also reviewed testimony the transcript of John Clewett, of thefor an attorney morning GAP (excerpts at Attachment 11). It was to Clewett's comments that Martin was responding in the statements
( ) 6 i quoted a.bove. On pages 264-267 of the March 27, 1984 Comission transcript, Clewett stated in part that:
"In listening to the presentation of the staff yesterday there were a large number of times when I restrained ntyself from jumping up and saying, 'No, that is not right.' But there was one point in particular that I think is important to clarify to the Comission. (emphasisadded)
"That'is on the question of whether the staff has made an effort to get back in touch with the original allegers to see whether the staff's resolution is adequate. They have not made any effort whatsoever....
"So it seems as though rather than living up to the policy that they take credit for in SSER 21 and now in SSER 22 of trying to get back with the original allegers....
"I would urge the Comission before doing anything in this case to at a minimum... read the affidavit of Harold Hudson because he was the internal -
auditer [ sic] for a period of two and a half years for Pullman Power Products. He knows more than any other individual alive I am sure, the nature of the NSC audit of Pullman and what it means....
"The staff made no effort whatsoever to get a hold of him and his affi-davit is very interesting in that regard because he explains the initiative that he took to discuss the quality assurance breakdown at Pullman and the fact that the staff at that point was apparently preparing report 83-37 that didn't mention to him at all that this was underway. They didn't ask him any questions about that nor did they get back to him on any of the issues he brought up that were very similar to this."
OIA reviewed the November 14, 1983, letter sent to Comissioner Gilinsky by Hudson (excerpts at Attachment 12). In this letter Hudson raised numerous allegations concerning the failure of the licensee and Pullman Power Products to meet required codes for welding. Additionally, Hudson discussed some of l his observations concerning the 1977 Nuclear Services Corporation (NSC) audit . of Pullman. Hudson stated that "The discrepancies identified in DR #4713 and this report verify the Nuclear Services Corporation conclusions." OIA reviewed the January 31, 1984, affidavit of Harold Hudson that was received by Region V on February 3,1984 (excerpts at Attachment 13). In his introductory remarks, Hudson writes "The basic lesson I learned is that the conclusions of a Nuclear Service Corporation audit of Pullman are more true today than when first published in 1977." Hudson then discussed in detail his concerns with Pullman's quality assurance / quality control program. OIA reviewed Region V Inspection Report 50-275/83-37, which was signed on February 29, 1984 (excerpts at Attachment 7). Inspection 83-37 was "a special, unannounced inspection by regional-based inspectors to perform an 4-depth review of selected fincings contained in an audit of the Pullman Power Products Quality Assurance Program conducted by Nuclear Services
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Corporation (NSC), during August-September 1977." j . . .
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' OIA reviewed NUREG-0675 Supplement No. 22 (SSER 22) which was published in March 1984 (excerpts at Attachment 14). On page A-4-68.1, allegation number 68 is characterized " Nuclear Services Corporation (NSC) conducted an audit of Pullman Power Products, the prime piping contractor at Diablo Canyon, in 1977. The audit findings implied a breakdown in the programatic aspects of Pullman's QA program." The allegations discussed under allegation number 68 are the same concerns that Hudson raised in his report to Comissioner Gilinsky and his January 31, 1984 affidavit. Action 'equired r on this allegation was "No further action required on this allegation -- refer to SSER 21 and NRC inspection report 50-275/83-37 dated February 29, 1984." On pages A.4-103 to A.4-103.19 under ATS Number RV-83-A-0074, 21 allegations are characterized " Multiple allegations associated with a failure of the licensee and Pullman Power Products to meet required codes and standards for welding pipe supports and pipe whip restraints." ATS Number RV-83-A-0074 also states th:t the allegations were received in a 35 page letter from the alleger to an NRC Comissioner. The issues discussed under ATS Number RV-83-A-0074, were allegations contained in Hudson's November 14, 1983, letter to Comissioner Gilinsky.
OIA reviewed the March 22, 1984, affidavit of Harold Hudson referred to in Clewett's testimony (Attachment 15). The affidavit was Attachment 2 to the March 23, 1984, GAP letter to the Comission. In that affidavit, Hudson discusses the three reports he submitted to the NRC between November 1983 and January 1984, concerning the quality assurance breakdown at Pullman Power Products. Hudson also discussed three interviews he had with Region V to disclose quality assurance violations. Hudson stated that these quality assurance violations complemented the issues in the NSC audit, but were not irientical to those being researched by the staff for Inspection Report 83-37. I:udson further stated he told the staff that as Pullman's internal auditor he had thoroughly researched the 1977 NSC audit and that NSC was right. Hudson also referred to his January 31, 1984, affidavit he provided to Region V in which he discussed in detail his concerns with Pullman Power Products quality assurance and confinned the accuracy.of the NSC audit of Pullman. Hudson esserted in his March 22, 1984, affidavit that the NRC failed to discuss the NSC audit with him to clarify the issues he raised, and that the NRC did not discuss with him the contents of Inspection Report 83-37, which was the staff - evaluation of the 1977 NSC audit, to determine if his concerns with the NSC 4.udit were appropriately addressed in the inspection report. Hudson asserted that the NRC was incorrect in its findings in Inspection Report 83-37 and that he "could have easily set them straight." Hudson also stated that "Any statement that the NRC staff followed up with me personally after I first raised n1y charges would be totally false. I have no idea what the NRC staff did to resolve my allegations, other than to have PG&E respond to some in letters." OIA also reviewed the policy statement in SSER 22 (excerpts at Attachment 14) referenced by Clewett in this March 27, 1984, testimony before the Comission. SSER 22 states: l
" Feedback from Allecers: When practical the staff attempted te discuss with the alleger the approach and findings of the staff's evaluation t
related to their allegation. The purpose was to assure that the staff l properly understood the concern and to demonstrate how the staff dealt l with the concerns."
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- 8 . DIA reviewed the M rch 26, 1984, testimony before the Comission (excerpts at Attachment 16) concerning Diablo Canyon. During this hearing, the Regional Administrator and other members of the Region Y staff discussed receipt of a package from GAP on March 23, 1984, containing additional allegations. The Regional Administrator and the staff testified before the Comission that they had read the entire package and all the supporting material. The March 22, 1934, Hudson affidavit referred to by Clewett during his statements to the Comission was Attachment 2 to the March 23, 1984, GAP submission 'to the NRC.
John B. krtin, when interviewed (Attachment 9) stated it was his under-standing that Clewett had two concerns: 1) Region Y was not conducting close-out interviews with allegers, and 2) Region V made no effort whatscaver to interview Harold Hudson (Attachment 10). Martin pointed out that page 270 of the transcript of the March 27, 1984, transcript documents his reply to Clewett's assertion that Region V was not conducting close-out interviews of allegers. Martin stated that when he refuted this assertion he.had in mind the close-out.dnterview that Region V conducted of Martin used this as an example to the Comission' that Region V had conducted close-out interviews in some, but not in all, cases. Martin stated he had the same thought in mind when he responded to Comissioner Gilinsky's question ccncerning whether Region Y was conducting close-out interviews by stating that Clewett's assertion was not true in all cases. Martin stated that his testimony on page 271 of the March 27, 1984, transcript was in rebuttal to what he considered to be the second issue raised by Clewett, i.e., Region V had made no effort to interview Hudson. Martin responded to this "other assertion" by stating that Region V had interviewed Hudson on several occasions to gather his concerns. Martin stated he did not intend for this coment to imply nor did he consider it to imply that Region V had conducted close-out interviews with Hudson. I Martin comented that he was not prepared on the afternoon of March 27, 1984, to formally reply to Clewett's earlier coments. Martin's coments to the Comission were meant to convey the thought that GAP had made a sweeping allegation concerning the lack of close-out interviews that was not true in all cases. DIA reviewed a schedule prepared by Region V which listed meetings between the Region and allegers (Attachment 17). The list includes one close-out inter-view by Region V prior to March 26, 1984. That close-out interview was conducted by Samuel Reyno14s, Lead Reactor Engineer, Region I, at Diablo Canyon with Samuel D. Reynolds, Lead Reactor Engineer, Reaion I. NRC. when interviewed (Attachment 18) stated that .
'an alleger, participated in a tour of Diablo Canyon to identify his concerns.
pointed out some U-brackets that were used to support fubing. The U-brackets were so small and fragile that xhey were difficult to install without bending. Reynolds told 31though he was technically correct in.his concern, the
. agreed and the issue was droppeJf. Other issue had no significance.
than possibly this incident, Reynolds conducted no close-out interviews of allegers concerning Diablo Canyon allegations. l F' - - * * - ---.wie,-,c--.%_ _m.- ,, , m; -; _ _ , ,,g_ 49 g 7
I y Conclusion Clewett's complaint to the Comission was Region V was not getting back with original allegers to ascertain whether the NRC resolution of their concerns was adequate. In support of his complaint, Clewett used the staff's handling of Harold Hudson's allegations. Clewett asserted that although Hudson took the initiative to bring to the staff's attention on several occasions his support of.the NSC audit and his concerns with the quality assurance breakdown at Pullman Power Products, the staff did not discuss with Hudson their resolu-tion of these allegations, i.e., SSER 22 and Inspection Report 83-37. Additionally, DIA believes that any misunderstanding of Clewett's complaint should have been clarified by the staff's recent review of the March 22, 1984, affidavit of Hudson in which Hudson complained that Region V had not discussed resolution of allegations with him and by the acknowledgements by Clewett and Hudson that Region V had conducted initial interviews of Hudson. Additionally, Comissioner Gilinsky further clarified the issue by his coment to the Regional Administrator that "I think what the man from GAP was saying was not that no effort had been made to talk to these people, but I think he was saying that no contact had been made subsequent to your resolution of the issues." In light of the above, Martin was inaccurate when he stated to the Comission that riewett's,-assertion was not true and "we spent hours and hours and hours, with for example, doing just that." .Except for one brief "close-out" interview conducted o^ CIA could find no record of any close-out interviews of allegers by Region Y prior to April 1984 to discuss resolution of allegations. Additionally, Martin did not directly address Comissioner Gilinsky's question. Martin discussed Region V's initial interviews of Hudson and not Clewett's assertion that Region V did not conduct a close-out interview of Hudson. DIA also noted that the Diablo Canyon Allegation Program (DCAMP) includes as one of its elements " Feedback to the alleger, where possible, for further assurance that evaluations accurately address concerns." Inasmuch as Region V officials met' with Hudson on three occasions during the time SSER 22 and - Inspection Report 83-37 were being prepared, OIA believes it would have been appropriate to discuss with Hudson portions of those reports that concerned Region V's resolution of his allegations. Allegation 3: On March 26, 1984, the Region V Regional Administrator, was 3 resent when a Region V official made a false statement to the Comission that ae had not been provided supporting material by GAP for an allegation con-cerning hydrostatic test records. OIA reviewed the March 26, 1984 Comission transcript of Thomas Bishop, the Region V official (excerpts at Attachment 19). Starting on page 10 Bishop stated:
"That leaves the remaining Items 4 and 5 on your handout, which we have entitled, Totally New Issues, Insufficient Information Given.-
"Giving you an example of some of those...
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i . j 10 "Other problems relate to hydrostatic test records, missing data. When we go back into these supporting material, which is provided in the petition, we find a statement that the supporting material is not attached and will be provided later. The note is dated February 2nd, '84 and we have not yet been provided that additional supporting material, to rqy knowledge." OIA reviewed the GAP February 2, 1984, 10 CFR 2.206 petition (excerpts at Attachment 20). Included in the petition is an affidavit by Harold Hudson in which he discusses his concerns with an alleged breakdown in quality assurance for hydrostatic tests. The affidavit indicates that Pullman Power Products Internal Audit 106 concerning Hudson's examination of hydrostatic tests was attached as Exhibit 4. However, at Exhibit 4 is a note which stated:
"2-2-84 Exhibit 4 is not attached, and will be provided later.
John Clewett" OIA reviewed a letter dated March 2,1984, from John Clewett, GAP, to Mr. Thomas Bishop Division Director, U.S. NRC, Region V (Attachment 21). Enclosed with the letter was Exhibit 4 to Hudson's January 31, 1984, affi-davit. This letter was received by Region V on March 5,1984 OIA reviewed the Region V allegation file and learned that Region V assigned allegation numbers 228-232 to Hudson's concerns about Pullman hydrostatic testing (Attachment 22A-E). These numbers were assigned by a Region V tecnnical reviewer on April 12, 1984. There is no indication that Exhibit 4 was used to fonnat the allegations investigated by Region V. Only infomation provided in the texts of Hudson affidavits was quoted. Thomas Bishop, fonnerly Director, Division of Reactor Safety and Projects, region V, when interviewed (excerpts at Attachment 23) stated that he quali-fied his coment to the Comissioners with the phrase "to sqy knowledge." At - the time of his statement, he was not personally aware that the material in question had, in fact, been received by Region V. Region V subsequently made an effort to reconstruct what had happened to the exhibit after it was received by the Region on March 5, 1984. Bishop was on travel that day. Apparently, the 17 enclosures to the March 1, 1984, GAP 10 CFR 2.206 Petition, plus the questioned " Exhibit 4 to Attachment 2" laid around the office for a few days. Someone, it is not clear who, then reproduced the first 17 enclosures; however, the original " Exhibit 4 to Attachment 2" was not received by Bishop. That document was finally retrieved from the original package which ended up in the office of the Region V Legal Counsel. John B. Martin, when interviewed (Attachment 9) commented that to the best of his knowledge, the statement made by Thomas Bishop was accurate. Martin noted that Bishop himself qualified his statement to the Comission with the phrase
to ray knowledge." Martin was personally aware that GAP had raise ~d the issue of hydrostatic test records in its 10 CFR 2.206 Petition dated February 2, 1984. However, Region Y had not had sufficient time before the March 26, 1984, Commission meeting to review the issue in detail. Additionally, Martin was aware that GAP's February 2, 1984, 2.206 Petition was missing an
( 33 attachment; however, he was not aware that the missing exhibit had been received by Region Y prior to the March 26, 1984 Comission meeting. Martin comented he had no reason to believe Bishop intended to mislead the Comission by his comment. Martin also noted that, in his opinion, Bishop's coment was not meant as a criticism of GAP. It was just a factual statement that, to the best of his knowledge, Region V had not yet received all the infonnation from GAP. Additionally, the allegation about hydrostatic test records was not being ignored by Region V. OIA reviewed the handout provided by Region Y to the Comission during testi-many on March 26,1984(Attachment 24). The hydrostatic test records issue was one of 66 items categorized as totally new issues by Region V. Conclusion OIA determined that Bishop's statement to the Comission on March 26, 1984, that he had not been provided supporting material by GAP for an allegation concerning the hydrostatic test records was false. The supporting material in question was received by Region V on March 5, 1984, as an enclosure to a GAP letter addressed to Bishop. However, OIA did not establish that the statement was intentionally false. It was noted that the hydrostatic test records issue was one of 66 issues categorized by Region V to the Comission as " Totally New Issues" contained in the February 2 and March 1,1984, GAP 10 CFR 2.206 Petitions. Region V spent about one week going through the allegations in these petitions and was prepared to discuss the issues on March 26, 1984. OIA believes that since Region V elected to highlight the hydrostatic test records issue as an example of the 66 totally new issues raised by GAP and to coment that supporting material had not been provided, then Region V should have been more conscientious to ensure that the information provided to the Comission was accurate. Allegation 4: On April 13, 1984, the Region V, Regional Administrator, made a
.wse or misleading statement to the Comission regarding deficiencies noted during an April 11, 1984, Diablo Canyon plant tour.
On April 13, 1984, in reply to a request from Comissioner Asselstine to provide an update of Region V activities concerning Diablo Canyon allegations, hartin stated the following regarding an April 11, 1984, Diablo Canyon plant tour (excerpts at Attachment 25):
"Although the GAP letter says they pointed out I bel;ieve eight deficien-cies, we noted down the deficiencies, this was Wednesday, and yesterday, the staff looked at each of these and has concluded, at least pre-liminarily, that none of them violate any requirements.
"So at this point we have no new specific safety issues that look like they are of immediate concern for purposes of this decision."
07A found that on April 11, 1984, an NRC inspector escorted three allegers through the Diablo Canyon Nuclear Power Plant so the allegers cottl'd identify certain alleged deficiencies. During the plant tour, the NRC inspector took down, nearly verbatim, the allegers' statements of concern. These were the allegers' statement of the problem, not the NRC inspector's observations or cuoclosions. The NRC inspector did not write down any potential code
- - -~~ D
J ( 12
\
violations and did not identify any significant discrepancies (example at Attachment 26). DIA reviewed an April 17, 1984, affidavit by Richard D. Parks, a GAP witness who took part in the April 11, 1984, planttour(Attachment 27). The five Problem Descriptions contained in the affidavit are copied from the mport
)
prepared by the NRC inspector. (For example, Item I in the Parks'. affidavit is almost identical to the Item Description in Attachment 26.) However, 1 Park's affidavit contains Code Violations that are not listed in the NRC inspector's mport. Following the plant tour, the NRC inspector pointed out seven discrepancies to PG8E. The day after the tour PG8E provided Region V with a draft response to thesevenissues(Attachment 28). PG8E considered the discrepancies to be of minimal significance. DIA reviewed Inspection Report 50-275/84-20(Attachment 29)whichdocumented Region V's assessment of the alleged deficiencies. This inspection resulted in no items of noncompliance or deviations being identified. Conclusion DIA believes the Regional Administrator was accurate in his statement to the - Commission that "at least preliminarily, that none of them violate any requirements." It appears that the only indication of code violations for the alleged deficiencies was the affidavit by the GAP witness who took part in the plant tour. Allegation 5: On March 19, 1984, the Regional Administrator, Region V, made a false and misleading statement to the Comission when he said that, "in every cese it (welding problems) appears to have been resolved." GAP alleged when Martin made this statement to the Comission he was aware that the allegation of welding inspectors not being qualified to ANSI N45.2.6 had not been resolved. DIA reviewed M:rtin's testimony before the Comission on March 19, 1984 (excerpts at Attachment 30), and learned that Martin's statement was in response to a question by Comissioner Asselstine "but I guess what I was concerned about was sqy impression that NSC had very little confidence in the Pullman welding work that was done in those early years; that is, prior to November 1973, and what I'm wondering is what you did in the inspections to reach the conclusion that you reached on that." Comissioner Asselstine's concern was with the seven areas identified in the 1977 NSC audit of Pullman Power Products concerning problems with welding. Comissioner Asselstine wanted to know how Region V resolved these problems in Region V Inspection Report 83-37, dated February 29, 1984. In responding to Comissioner Asselstine's question, Martin stated (Attach-m:nt 30): ..
"Let's look at that. I think snaybe what we should do is look at the final inspection report that we sent down. And I wonder, would it be okay to perhaps go on with the briefing and come back to that in a minute, as soon as we find that paragraph...
k 4
. 13 Because our conclusion was that that was just not a reasonable finding to make, and we have the details in the inspection report and I can go over it with you in a minute or two...
"I think I can answer your question now about the early 1974 report.
It's Item 30 in our final inspection report of the Pullman audit. And the issue was the NSC finding listed about seven areas where problems existed in welding and then drew the conclusion that therefore, there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification requirements. It's a very alanning finding...
"We did a detailed inspection on each of these seven items and what we have come to find out was the NSC audit finding was not based on anything they did; it was based on a review of Pullman internal audits where Pullman had done some 183 internal audits during that time period...
"That's what we discuss in here; is the detailed resolution of each one.
And in every case it appears to have been resolved...
"So I find that the finding itself was based on simply a catalogue of what the company found in their internal audit program, and which each item by itself isn't terribly significant, and there are problems. "
OIA reviewed Region V Inspection Report 83-37 (excerpts at Attachment 31) and noted that Item 30 discussed NSC Audit Finding 10o and concluded that "the inspector notes that isolated instances of problem areas were identified and corrected by the Pullman welding inspectors." It was also noted that welder inspector qualification was not one of the seven problem areas outlined by NSC in Finding 100 of their audit; therefore, Item 30 of the Region V inspection report did not discuss the problem with welder inspector qualification. Welder inspector qualification was revicwed in Item 17 of the inspection report. The fact that a problem existed with welder inspector qualification was discussed by Martin during his March 19, 1984, testimony. Martin stated, "We did find one open item concerning qualification of inspectors that is
- still open that we have some additional work to do."
Conclusion OIA believes the Regional Administrator was not misleading on his statement to the Comission. Martin accurately responded to a specific question by Comissioner Asselstine by referring to Region V Inspection Report 83-37. In that inspection, Region V determined that Pullman's resolution of each of the seven problem areas identified during the NSC audit was adequate. This was the conclusion that Martin was relating to Commissioner Asselstine in his coment "in every case it appears to have been resolved." Allegation 6: On March 19, 1984, the Regional Administrator, Region V, made a false and misleading statement to the Comission when he said, in reference to whether the contractor had corrected problems at Diablo Canyon, tifat "when there have been lapses they seem to have corrected themselves...there were problems that tended to get found by the quality and management systems that are set up to do that sort of thing." It was alleged that when these state-ments were made, the Regional Administrator was aware that a January 31, 1984, j l l l
- k 14 .I '. affidavit by Harold Hudson questioned the adequacy of the contractor ,
corrective action program. l l OIA reviewed k rtin's testimony before the Commission on March 19, 1984 i (Attachment 32), and learned that his coments referred to the results of Region Y's inquiry into the initial 219 allegations made by GAP concerning Diablo Canyon. These allegations did not include those contained in Hudson's January 31, 1984, affidavit, which was part of a February 2, 1984, 10 CFR 1 Petitions submitted by GAP, nor those contained in other petitions submitted I in February and krch 1984. Martin's coments concerned the technical issues already reviewed by Region V and were his general impressions of the effectiveness of the contractor in identifying and correcting problems. N rtin did not state that the contractor had identified and corrected all problems. Nrtin sumarized his observations to the Comission by stating "So I think the bottom line is that we have reasonable confidence that the Licensee and their contractors acted responsibly over the years, and that at least in the first 219 allegations we haven't found anything that constitutes significant coment in the quality of the as-constructed plant." Conclusion OIA believes the Regional Administrator's statements to the Comission were neither false nor misleading. The coments were the perceptions of Region V after investigating the initial 219 allegations made against the contractor. 1 i l
.- . - -. = __ .
t , ATTACHMENTS
- 1. Excerpts of Testimony re Diablo Canyon, dated March 26, 1984. ,
- 2. GAP Letter, dated March 23, 1984.
- 3. ANST Reconnended Practice No. SNT-TC-1A. <
- 4. Excerpts of Testimony re Diablo Canyon, dated March 27, 1984. ,
- 5. Excerpts of Testimony re Diablo Canyon, dated March 27, 1984.
- 6. Excerpts of Affidavit by Steven Lockert.
- 7. Excerpts of Region V Inspection Report 83-37, dated Tebruary 29, 1984.
- 8. PG&E Letter DCL-84-082, dated February 29, 1984. .
- 9. Report of Interview, John 8. Martin, dated September 10, 1985. .
- 10. Excerpts of Testimony re Diablo Canyon, dated March 27, 1984.
- 11. Excerpts of Testimony re Diablo Canyon, dated March 27, 1984.
- 12. Excerpts of Letter to Victor Gilinsky, dated November 14, 1983.
- 13. Excerpts of Affidavit of Harold Hudson,
- 14. Excerpts of SSER 22, dated March 1984.
i 15. Excerpts of Affidavit of Harold Hudson.
- 16. Excerpts of Testimony re Diablo Canyo :: dated Mardi 26, 1984.
- 17. List of Meetings with Allegers.
- 18. Report of Interview, Samuel D. Reynolds, dated September 23, 1985.
- 19. Excerpts of Testimony re Diablo Canyon, dated March 26, 1984.
- 20. Excerpts of GAP 10 CFR 2.206 Petition, dated February 2,1984.
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- 21. GAP Letter, dated March 2, 1984.
22A-E. Problem Statements 228-232, dated April 12, 1984.
- 23. Excerpts from Report of Interview, Thomas Bishop, dated July 16,1984.
- 24. Status of Allegations re Diablo Canyon, dated March 26, 1984.
- 25. Excerpts of Testimony re Diablo Canyon, dated April 13, 1984.
- 26. kroblem Statement, dated April 11, 1984.
- 27. Excerpts of Affidavit of Richard D. Parks.
- 28. 'PG8E Draft Response.
- 29. Region V Inspection Report 84-20, dated June 11, 1984.
- 30. Excerpts of Testimony re Diablo Canyon, dated March 19, 1984.
- 31. Excerpts of Region V Inspection 83-37, dated February 29, 1984.
- 32. Excerpts of Testimony re Diablo Canyon dated March 19, 1984.
t e e f O O
I j
, 1 syl,cyl 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3
DISCUSSION /POSSIBLE VOTE ON DIABLO CANYON CRITICALITY 3 AND LOW POWER OPERATION 4
.e 8 Public Meeting 8 Nuclear Regulatory Commission 1717 H Street, N.W.
7 Room 1130 Washington, D.C. 8 Monday, March 26, 1984 9 10
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The Commission met, pursuant to notice, at 11 , 2:05 p.m. COM*4ISSIONERS PRESENT: 13 NUN IO PALLADINO, Chairman of the Commission I4 VICTOR GILINSKY, Member JAMES ASSELSTINE, Member 15 THOMAS ROBERTS, Member FREDERICK BERNTHAL, Member 16 . STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: H. PLAINE S. CHILK f W. DIRCKS l . H. DENTON ! D. EISENilUT J. K"IGHT
- 3. JACKSON J. MARTIN T. BISHOP
.?.~. DEVINE ~
!. YIN AUDIENCE SPEAKERS:
i g L. CHANDLER ATTACHMENT 1
. { I 6 1165 1 in SECY 84-101 and SECY 84-104. And then, when we .
2 get to it, repeating additional recommendations. 3 That's how we would like to proceed, if that is 4 satisfactory to you. 5 CHAIRMAN PALLADINO: Any objections? 6 (No response.) 7 Bill, why don't we proceed? 8 MR. MARTIN: On the allegations, I would like to 9 use, as a point of departure, just a very brief review of 10 what we talked about last Monday and then discuss the 11 allegations that we did not cover last Monday and discuss 12 some new ones that we received last Friday. 13 To review briefly, as of last Monday, we had 14 considered the first 219 allegations, which included all that 15 we had received except for two petitions. One was received 16 on February 2nd and the other one, a supolement to it, on 17 !! arch 1st. 18 The conclusion we drew on the first 219 was 19 based on a very thorough review of the #irst 170 or so, with 20 particular emahasis on two noints. First is the technical 21 problem. And secondly, is it reflective of any manacement 22 or quality problems. After we did the first 170 or so, and n 23 thought we had a oretty good handle on the management 24 situation, as well as a pretty good feel on the first 170 or 25 180 specific items, we got somewhat more discretionary on the
. \ ) y 1-lb6 .
I remaining 130 or co.
' And we discussed that last week.
2 So as we ended, we thougnt we had dealt properly 3 with the first 219 items. But we had not gone through the 4 next 300 or so items, that were contained in the two 5 petitions received on February 2nd and March 1st. We are 6 prepared to speak to those today. We spent the last week 7 or ten days going through those and comparine them to the 8 screening criteria that we talked about last week, and they 8 are included in SSER-22. 10 In addition, we received another batch of allegation s 11 at close of business on Friday. I am not sure how many are 12 in there. We haven't -- they were not numbered verv well and is it -- you know, they didn't have all of the enclosures 14 delivered to us. But we have read the entire package and 15 _ there is some number, on the order of 150 or 200 or something 16 like that. 17 We have read the entire package and we think we 18 can give you an informed opinion of now they stack against 19 the screening critoria. 20 I would like Tom to do that now, and then I have ' ! 21 a couple of comments to make on the submittal that we received 22 last Friday, that I think the Commission should have the 23 Staff perspective on, on the submittal. 24 MR. BISHOP: This document came to REcion V offices 25 shortlybeforeclosingti.Eeoniriday. We did snent Friday
( 8
, )
11b7
'1 . evening and Saturday and an unfortunate Sunday reviewing the 2
new document, the contents of which I can get to in a , 3 minute. 4 That was one of the two additional packets we 5 looked at since we have last met. The other two packages 6 were the 2.206 submittal, dated February 2nd and the sunclemen t 7 to that submittal, dated March 1st. 8 Let me take those first. Gnd tl 9 10 11 12 la 14 15
- 16 17 18 19 20 21 22 23 24 ~
25 1
14 I i ) g6 1 problem. 3 So the bottom line is, of the 318 we have looked 3 at, about 3/4ths of them, and the remaining 1/4th we have 4 reviewed for significance in reference to a criticality 5 decision. And it is the Staff's recommendation that there a is nothing there which warrants an immediate holdup to the 1 7 process.
& CHAIRMAN PALLADINO: Can I ask, does this 318 9 include the 219 that --
10 MR. BISHOP: No. Many of them are the same. 11 CHAIRMAN PALLADINO: So these are over and above 12 the 219 that you looked at in depth? 13 MR. BISHOP: That's correct. Many of the documenta 14 provided in the petition are the same documents that we 15 received earlier through other processes. So that's why,
'S there's such a large number, which are the same enclosed.
17 MR. MARTIN: Mr. Chairman, there is some overlap. 18 Some of these 318 are identical to the 219. In fact, about 19 half of them or so, Items number 1 and 2, for example. 20 CHAIRMAN PALLADINO: Yes. Aside from the overlap, 21 I was trying to get a feel for whether or not 219 was in Z2 the 318. 23 MR. HARTIN: No, they are not. 24 MR. BISHOP: In addition to this, I-mentioned 25 a new set of material, which the Staff received, Region V
) 15
. (
!pb7 1 Staff received Friday night at closing time. I believe it 2 _ was docketed here in Washington Monday morning. You have the 3 cover letter associated with that. It's about three inches 4 worth of supporting material.
5 We have only had two-and-a-half days to look into 8 that. But we have spent that time going through reading 7 that document and reading all the supporting material. And a we do note, again, some similarity with previous issues 9 here and there. Others -- other issues are' identifying what 10 they contend are inaccuracies in submittals made to the Staff 11 by the utility. 12 The forwarding letter is very direct and specific, 13 calling these falsifications and such. When you go back to 14 the supporting document, the affidavits, it appears that the 15 individual provides examples and then concludes, based on his 16 differing opinion of the situation that the submittal made 17 by the utility is false or inaccurate or misleading. . 18 We did not have the time to do an exhaustive 19 analysis of that. But one thing we do note is that we made 20 much less reliance on the utility's submittals than the . 21 document tends to imply. Now most of the utility's submittal.s N_ 22 came very late in the game. Whereas our efforts to examine 23 and investigate these allegations started many months ago, 24 and continued for many months. - 25 Would you like to add anything specific in l l t ,
I 16 2pb8 l reference to the letter? 2 MR. MARTIN: No, I don't think so. Other than 3 our assessment in reading through it. Since it was so 4 diffuse, we didn't number the items. But in reading through 5 it, I think we came up with about the same proportion; 6 roughly 3/4ths of the items in there we have seem before, 7 dealt with one way or another. And there was about 1/4th 8 of it or so that were new items. But not the sorts of things 9 that look like they needed to be dealt with right now. 10 That's our impression. And I think that's about 11 as much as we can tell you on the statistics of the thing. 12 That's what we've done since we talked last week. And -- 13 is to go through and categorize and screen these things. 14 And we have concluded that none of the new ones appear to
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15 be the sort of thing that needs to be done prior to a 16 decision. . 17 We either have enough background on it or it' 18 isn't relevant. Or even if true, would not pose a significant nd 2. 19 problem. 20 21 22 23 24 25
o 17
'31bl -
5
)
I A couple of other wrinkles on this new submittal, 2 that I find most mettlesome, are direct charges that a the Staff closed the books on this whole process over the 4 last couple of weeks and refused to meet with anybody, refused 5
.to take any new information. This was made, very exnlicitly 6
and very forcefully, in a letter that we received Friday 7 and the Staff position is t' hat that is absolutely not true. 8 But our posture has been that we have been willing to meet with people at any time. As a matter of fact, even 10 confirmed that in a telegram on the 15th of March. Our II residents have been available to meet with ceoole at any j 12 time, as has OI. So I think any impressions that the 13 Commission may gain, that the Staff was resistant or unwilling I' to meet, is just not true. And if you are interested, I 15
, could pass out copies of a telegram that we sent several 16 days before last Monday's meeting, exnressing our desire 17 to meet and even recommending a time and olace. ,
18 CHAIRMAN PALLADINO: Why don't you let us have 19 . copies. 20 MR. tiARTIN: All right. - l 21 l CHAIRMAN PALLADINO: Were there any examples in 22 this list from the GAP package, that would give us a better 23 feel for what is involved? 24 MR. MARTIN: Well, I had one other cemment to make, 25 and that is in the letter it is stated in a couple of different
' ( ) l 31)2- . .
18 I places that the Staff approach to dealings with these ! 3 allegations was to spear the alleger or trash the alleger. 8 That again, I find very objectionable, in that we have tried 4, very hard, from the beginning, to in no way deal with the 8
. ~ allegations by, attacking or discrediting.the alleger.
6 And I think you will find, in a reading or even 7 a casual reading of any of the writeuos that we have done 8 on these allegations, there's not even a hint of that. Nor 9 has there been, in nress statement s or face to face discussion s 10 with people. I don't believe in doing that and we haven't 11 done it. 12 So these are a couple of observations that I'd 13 like to make. We could go through the Friday letter, to 14 the~ degree to which you would think worthwhile. I am 15 prepared to go through, oh, the seven or so items that were 16 offered up as evidence of false statements. 17 . COMMISSIONER BERNTHAL: Jack, I think it would 18 w be worthwhile to go through some of the issues that were 19 raised and essentially cerhans repeat the presentation, as it 20 is appropriate to do so, from this morning's closed meetinc, 21 although leaving aside the florid exchange of rhetoric in this 22 case. 23 There were two or three questions that ~ narticularly 24 might have called into question the integrity of the Licensee 25 or its agents, at some point. And it seems to me it would
-- 6"g7"'w-"mv"- " ' - - - ' = ' ' * - - --
' I 31b3 - 19 I-be worthwhile to go through that, for the public record.
8 and indicate just how your analysis came out on that. 8 COMMISSIONER ASSELSTINE: Yes, I think it would 4 be useful to go through the seven items in particular. 4 MR. MARTIN: I can speak to them. -
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4 MR. ASSELSTINE: Yes, discuss the extent to which 7 you have information that addresses each of those now. 8 MR. MARTIN: But we haven't done a definitive 9 examination, but I can tell you what we have done and why 10 we come out the way we do. If we look at the first one,
- 11 the issue here is that in our inspection report of the i 12 ,
NSC Pullman Report, back in 1978, we made the -- ' 13 CHAIRMAN PALLADINO: Jack, they can't hear you. ' 14 MR. MARTIN: Okay. 15 We made the observation the first item involves j 16 a taking issue with one of these several items that we looked 17 into in the NSC audit of Pullman. You'll recall that our l t 18 approach there was to look at the NSC audit of Pullman and 19 look at Pullman's response and PG&E's resoonse and see 20 if all the records we could find shed any light on whether 21 . the PG&E and Pullman responses were properly done. 22 In this case, the issue was made that the insoector 23 found that the 90 day welder log was found comnkete and had 24 no voids in it. This letter points out that somehow we 25 were hoodwinked and references, as an internal Pullman
. - _ _ _ _ _ . . ~ .
I l 31 n
' .4 ' .. l 20 3
memorandum, that itself coints out there was a void in the Ice, I l This is true, at the time we did the insnection. We did ! 3 not see any voids in the log, because it had been reconstructed, 4 . subsequently. 5 This is pointed out in SSER-22. We dealt with this j t 6 at some length in Item 103. Se I guess the lone and short 7 of it is we have a considerable amount of background in this l 8 Item Number 1 and we did not find any irregularities, either 9 in the technical question at hand or in the way we handled gl 10 this, nathough the inspector looking into the NSC audit 11 apparently d2dn't pick it uo, another insrector ooerating i 12 independently did. So it is covered in the document that we t i 13 gave to you last Monday. i 14 i CHAIRMAN PALLADINO: Jack, are we sure that all 15 the welds, orlor to 1974, were covered by the audit by 16 our inspectors? ' 1 17 MR.' MARTIN: I'm not sure I understand. l 18 CHAIF. MAN PALLADINO: Well, there is a cuestirr as
.I 19 8 to whether or not the welding nad been crecerly dene, nrior ,
20 to 1974. Are ce u speaking to a different issue? l 21 MF. VARTIN: No, I'm speaking to a very s ecific 22 Item Number : - Dage three of this GA? letter. Ic's a 23 very narr:s =_e, h a vi no. to do with the 90 dav. welder l_o ,c . 24 Cli A: T.MA'. PALLADINO: All richt. I'll ccme back 25 to the other cuesticn later.
k f 2b 23
..b 5 1 MR. MARTIN: The second one is interestina. It's 2
a very forceful statement that a non-destructive examination 3 personnel were not qualified properly, in accordance with 4 NSI-N45.2.6. This is true. ANSI-N45.2.6 is'not the 5 ap licable standard. The apolicable standard is what? 6 MR. EISHOP: SNT-TClA. 7 MR. MARTIN: Which the very same allecer includes 8 in the package later, a letter from him saying they were . 9 qualified adequately to that one. So this is one that 10 we feel is adecuately resolved at this ooint. 11 Item number 3 lists a form which we have cooies 12 of, if you would like to look at it. It may helo explain 13 the problem -- where, in qualifying somebody for these 14 l magnetic particle examinations, the way it is normally done 15 i 15 it consists of three tests and you get a grade on each test , l 16 and then a component or comcosite score at the end. . , 17 The sheet of paper the alleger reviewed did not i 18
' ave earn c f the individual test sc:res.
It O n ! ,. :ncluded d 19 the composite score. And that's alleged to be falsification.l 20 Well, we don't know if there's any oroblem with that or nct. ' 21 l l We just ha te.m ' t rone back and looked into that rec:rd. We 22 have a ceny of the record. It was included in the racka:e. I 23 Eu: I guess that's cne that I'd say we just don't . 24 , know whether -- it would accear that that's a reccrd keerinc 25 problem, of questionable significance.
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)
. . 22 31b6 1
CHAIRMAN PALLADINO: Do you clan to look into it 2 further? 3 MR. !!ARTIN: Yes. Here is a conv. I only have 4 one, but it might be worth just nassing it ar'und o to see 6 what I mean. 6 21R . BISHOP: I can elaborate on that carticular 7 instance. This was part of our later review, so you macht not 8 be aware of it, Jack. In this particular case, we did 9 select that individual as an example of one that we wanted 10 to examine, and that is also addressed in SSER-22 allegation, 11 I believe it's 121 or 122, where we confirm that this 12 fellow s qualifications were adequate. e 13 We were able to do two things. One, we had a 14 the utility eroduce the individual test secres to fill in' 15 the blank. And two, from our own inspector's comcutation, 16 we got an overall score of 98. And he couldn't have . 17 possibly failed any of the individual three scores. A 18 failure would be less than 70 nercent. based :n the sar.le .:i 19 I work that we looked at. ; 20 MR. ::ARTIN: Item number 4 isanissueastcwhetneb 21 I inspections actually occurred. This is one where theallecerf 22 cla'ims that reccrds showed that 314 .a; carticle insnecticns ' 23 were dcne by a single individual in fcur days, which represen s 24 i 78 tests per day, and that that's impcssible, so it nust have 25 g been faked. i 1 r - --
g
~ 23 I
31b7 l 1 1 Documents provided with this package certainly l 2 _ don't support that. I couldn't tell anything from the 3 ! documents, as to whether the inspections were done by the 4 same oerson, or even the time period involved. So that's one 5 that we'll have to look into further. i 6 Certainly, the information rresented did not , i 7 corroborate a croblem. Now there nav be, we just haven't 8 looked into it. 8 The fifth one is rewriting history through ,- 10 backdating letters. That is a case where it's alleged that 11 someone backdated a letter concerning the qualifications of 12 certain individu/1s. 13 The exhibits provided certainly don't substantiate i 14 that. They a re just simply cocies of the letters with the j 15 date on it. And we can't tell whether it's backdated or not. 16 In any e vent, the records show that the man was qualified to 17 do his job several months befor.e the letter. So it would IO acpear, in any event, whether the .e:tsr ir questi:n tas i 3 19 backdated or not, that it didn't have .uch to do with the 20 individuals qualification. 21 So here again, there's nc c r. lusive evidence j 22 presented in the package or.e way cr the other. Eut ever if l 23 It ci ;ld true, it doesn't apoear to be a techniral problem. 24 be a mancement problem. I
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l 25 COM.*4ISSIONER BERSTHAL: I assume that you will, at
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/ m2m2 GOVERNMENT ACCOUNTADIUTY PROJECT a,. %.e.
wot owe kreet M w..verungeon. Dt 20000 84 Mt 26 A828 kl,:.'d}*[Matth23,M8a
** *er guatio J. Palladino, Chairman ;
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p victor 0111nsky, Commissioner Ng M Thomas Roberts, Commissioner James Asselstine, Commissioner Frederick Bernthal, Commissioner - '~' JD-4.I.3.do : l D. S. Nuclear Regulatory Commission Z tl li d m. Street, N.W. Washington, D. C. 20555 C /o.J/er Mc[unaa. . .
Dear Commissioners:
[gws's u Q On behalf of the Mothers for Peace, this submission formally presents 12 additional affidavits in. support of their March 1,1964 i petition to defer any further licensing decisions on the Diablo Canyon nuclear power plant, until completion of a comprehensive reinspection, management audit, and audit of design verification efforts to date.. The 12 affidavits represent the views in the ofGovernment six current and six former. Accountability employees, out of 47 interviewed Project's ongoing investigation to date. In the .treh 1 p'etition si:i national organizations joined the Mothers for Peace. Due to time constraints, there has not yet been sufficient If the
- opportunity to review this disclosure with those parties. Commission o review the issues, counsel will organize .them into 215 new allegations, es well as significant supporting documentation for previous charges.
TM 215 allegations include 51 charges of falsified documents, including 32 cases of material false statements in documents reviewed by the staff prior to its March 19, 1984 recommendation to let the plant go ' critical. . .
'Seven of the 12 witnesses have . submitted previous affidavits.
f
- They are supplementing the record, because the staff refused their repeated requests for followup interviews to raise additional issues, and expose false or misleading statements in,1984 PG & E rebuttals to the NRC. In one case, the staff had never even bothered to make initial contact with a witness who disclosed severe hardware effects
- from ongoing Quality As'surance (QA) violations.
The staff'i aloof posture over the last month explains why the Commission wfIl vote Monday on the basis of a record that is delibe-rately incomplete and deviates severely from reality. The staff refused to receive evidenceThe thatstaff'swouldmisconduct have rendered untenable its violates.the. Ms.rch 19 recommendation. Com=ission's own claimed policies, abdicates its public trust, and reneses on commitments made to employees who risked -- and-in some
. cases sacrificed - their careers in an attempt to uphold their Unfortunately, professional ethics and defend the public safety.
9403260364 940323 PDR ADOCK 05000275 .; e von ~ ATTACHMENT 2
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The analysis below sue = arises the the staff wasn't interested. staff's recent deception to the whistleblowers and the Com=1ssion as well as a few illustrative highlights from the evidence the staff didn't want to bear. The affidavits are enclosed as attachments - 1 through 12. BACEORomtD; , , 1 in
-The NRC staff recommendation is bared on a significant shiftThe staff decided
- Commission policy toward the nuclear labor force.to adopt *be comun serious publie safety conceras, instead of seriously investigating ~
In November abeir evidence and eyewitness assounts of illegality. 1981 the NRC announced to the Udall Committee that. the agency would work more closely with nuclear workers especially to doublecheck to assure the the quality accuracy of of utility records and statements On March 19, 19 $4 the staff announced that in the construction. future they would only comunit to reading whistleblower affidavits and allegations. The NRC is reneging on its commitment, because the workers at Diablo Canyon exposed more serious The staff problems explainedthan the itsCommission reluctancewas to able or willing to address. deal with 130 employee charges raised on March 2,Asbecause a re'sult, it would the take two to three months to. resolve NRC will not even commit.to talk with them except at whim. the issues. , The new policy represents a break NRC Traditionally, with tradition, inspectorsas havewellused as the. the agency's formal position. intensity and flow of employee allegations as a rough indi I, In 1982 at Zimmer, when the allegations came l the plant's condition.in faster than the staff could investigate, the Commission wisely suspended c'onstruction to learn the full effects of a quality assurance breakdown. By contrast, when the employee reports of quality assurance (QA) violations and shoddy hardware at Diablo Canyon came in faster than the NRC could investigate, .the staff decided to. stop talking to
. employees. Instead, the staff accepted at face value the utility denials th'at anything is wrong.
-The staff justified its refusal to stop pursuing new evidence by trashing the whistleblowers. In effect, the NBC officials told the Commission that it wasn't worth the time and money to talk with witnesses anymore. This was a shameful tactic that has cost the NBC its credibility with the nuclear labor force. Government Account-ability Proj ect (GAP).immediately recommended to its clients that they should..no longer communicate with the NRC, except pursuant to subpoena. The reason is tha.t it is not in their best interest to co-All clients have agreed enthusiastically.
operate with a coverup. Some explained that they would not have talked further with the NRC in sny event after what happened.
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( 3 The staff relied on false statements -- both its own to the Commission, and PG&E's to the steff -- as the basis to reject employee charges. Last Monday the staff assured the. Commissioners that a program of followup interviews with whistleblowers In theory, these had verified the interviews accuracy of the inspectors' findings. would assure that the NRC understood the issues prior to resolution, Unfortunately , i i and would help catch any inaccuracies in PG&E's . responses. the staff did not meet with the whistleblowers again',"except' -in isolated Over a two week period prior to the Commission During thatvote, period the instances. staff refused to speak with the whistleblowers. GAP explained with increasing urgency that the employees had found numerous, significant false statements in the FG&E answers to theThe staf whistleblowers' original charges. time to talk with the employees until after the March 19 m worthy of further interviews. A review of .just a few highlights from the evidence on that the 19 March staff refused to consider leads to only one. conclusion: the staff tarnished its own credibility, not the whistleblowers' .- II. EVICENCE OF MATERIAL FALSE STATEMENTS The evidence summarized below-illustrates a much Some larger
~
of the problem statements at false or misleading statements. Diablo Canyon: are false by omission; i.e., they don't include facts that would
, Other statements flatly contradict internal
~c hange the conclusion. Still others are so incomplete that they are l records at the plant. GAP has obtained evidence of false statements on the seismic. design review; construction . quality assurance for the Fullman; l meaningless.
Atkinson and Foley contractors; and inaccurate weld symbols on drawings throughout Diablo Casyon, that effectively left. the w a foreign . language. The seven examples below highlight false statements concerning the quality of work by the Fullman Corporation at Diablo Canyon back to 1972, the period when critical safety equipment was first installed. The false statements were contained in internal files reviewed What.vere by the the NRC, or in letters received by t,he NRC during February.As a result, the context, the staff accepted the data at face value. Com=1ssion has been, duped again.
- 1) 90 day welders log .
' "The I In Report 83-37 the staff drew the following conel.usion: '
inspector examined.the 90 day' welders log and found that no voidThe existed between 8/72 and 12/72." (NSC) audit was
, for a finding that a Nuclear Services CorporationSomehow the NRC was ho wrong on that point. internal Fullman memorandum on the same subject conclude _
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December, 1972." (Attachment 2, p. 8 .)
. 2) Qualifications of quality control personnel (NDE)
Pullman and POSE contend that " Nondestructive Examination" personnel have Been qualifiec since'at least 1974 under the
~
reouirements Standmeda of the relevant professional specifically, code, the American NationalPG&E claims to have met the sta
. Institute (A_N5I .
NDE personnel conduct the x-rays, magnetic particle, in ANSI N 45. . . ultrasonic and other tests to learn the quality of the hardware. In fact, an internal May 13, 1975 Pullman '(then called W.W.~Kelloggi memorandum revealed, "It should be noted that it is virtually impossible to comply totally to N 45 2.6 because of experience requirements. We cannot hire personnel to meet the experience requirements based for the salary scale we offer." (Id. , Exhibitio.) As late as July 30, 1982 Pullman QA/QC Managerhas HaroTd not stated Kafner in writing rejected that an intern with the following comment: "P.G.E.
- Pullman must comply with ANSI N 45.2.6....we are not in violation of PoE(Id. , Exhibit 9 spec ifications or our own procedures ESD 235 and 237."
In other words, even by 1982 reality had not caught -up with the
" official" record. How much confidence can the public have in test On October 13, results from Pullman's bargain basement NDE' staff?
1977 Pullman's QA Manager explained what N.S.C. concluded after looking at the files: "N.S.C. felt that personnel should have had more' prior l experience spection. before training and qualification for N.D.E. or field in-T opinion." .
- 3) Backup data for NDE cualifications -
.Ihe staff accepted at face,value PG&E and Fu11 man's claim that l
adequate backup data exists to demonstrate that NDE personnel are qualified based on training and experience. In fact, a September 22, 1977 Pullman corporate review of 95 inspector and NDE files found " generic records(Id., deficiencies" for data to prove experience and qualifications. Exhibit'11) Reviewing the file for Pullman's NDE supervisor His -- records the leader say of the pregram - . reveals the magnitude of the bluff. he passed the-three Magnetic Particle exams with flying colors -- a
- score of 985. But records on the three "specific exams record , [and) " the There following results for the supervisor:
are no grades recorded for his performance on individual tests. - (Id., Exhibit 12) - .
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MERIC N SOCIETY < T Or = l e Y+i I NONDESTRUCTIV,.E< TESTING . 2 n$F i I
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TH'S DOCUMENT 15 INTENDED A5 A GU'DE6f N E F OC EN MOYEF S TO EST ABUSH THE'E OWN WR.TTEN FRACTICE FOE THE QUAUFi-CATION AND CEfiiFiC ATsON OF THEiE NDT FEE SONNEL IT 15 _. , ' w f. . *g ., . . NOT INTENDED TO BE USED AS A STPsCT SPECM ATION.',t. g , pg '
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l t , , b AMERICAN SOCIETY FOR NONDESTRUCTIVE TESTING
' Recommended Practice No. SNT-TC-1A
- June 1975 Edition i
FOREWORD The recommended practia contained herem establishes the general framework for a qualiRestion and certiScatim program. In add. tion, the document provides reme-rnended educational, experience, and tramms requirements for the diferent test methods. Supplementary documents include quesbon and answer lists which may be used in mmposing examinations for nondestructrve testas personnel Inquisies related to this recommended practxe should be directed to the Chairman of t6e Personnel Quali6 cation Division, attention of the Teanxml Dusetor, at the following address: The American Society for Nondestructive Testing 914 Chicago Avenue Evanston, Illinois 60202
=.
Copyright? 1975 by the American Society for Nondestructive Testing
' 914 Chicago Avenue, Evanston, Illinois 60202 Printed in the U.S.A.
t l O O T--_2_--_-" ____ - - - - _ _ . _ . _ _ _ _ __
}
D - CONTENTS PERSONNEL QUALIFICATION AND CERTIFICATION IN NONDESTRUCTVE TESTING 4 Scope 4 pennitions 4 Nondestructive Test Methods 4 Levels of Qualification . 5 Written Proctice 5 Education, Training and Experience
,- 6 Table 6.2.1A Recommended Training and Experience ~
Minimum Levels 7 Training Progroms .
~'
- 7 Examinations 10 Certification O -
io T r-ia='i a RECOMMENDED TRAINING COURSES 11 Radiographic Testing Method 15 Recommended Training References /Rodiographie 16 Magnetic Particle Method
- 18 Recommended Training References /Mognetic Particle 19 Ultrasonic Testing Method -
21 Recommended Training References / Ultrasonic 22 Liquid Penetrant Testing 23 Recommended Training References / Liquid Penetrant 24 Eddy Current Testing 26 Recommended Training References / Eddy Current 27 Neutron Radiographic Testing 31 Recommended Training References /Neutren Radiography 32 Leak Testing Method 35 Recommended Trainir.g References / Leak Testing O W O P 7- -
)
1 Recommended Practice No. SNT-TC-1A I PERSONNEL QUALIFICATION AND CERTIFICATION I IN NONDESTRUCTIVE TESTING ,
- c. Certafymg Agency-M smployer of the per-
- 1. SCOPE
/ . sonnel being certfSed. .
~
1.1 It is recogmzed that the effectiveness of nonde- d. Recommended Practice-A set of guidelines to
- * ~rtructive applications depends upon the capabili- assist the unployer in developing uniform ' pro-ties of the persons who are responsible for, and cedures for the quali6 cation and arti6 cation of carry out nondestructive testing (NDT). %is Rec.
ommended Practice has been prepared to establish nondestructive testing personnel to satisfy his specsSe requirements. g guidelines for the qualiScation and certaScotion of e. Employer-%e corporate or private entity nondestructive testing personnel whose speciSc which employs personnel for wages or salary. kbs require appropriate knowledge of the techni-cal principles underlying the nondestructive tests I Tr*inint-%e program developed to impart the they perform, witness, monitor, or evaluate. knowledge and skills -ary for qualiScation. 1.2 nis document provides guidelines for the estab-lihent of a qualiScation and artiScation pro. C' *' 3. NONDESTRUCTIVE TEST METHODS 1.3 These guidelines have been developed by the 3.1 QualiScation and cert 2Scotion of nondestructive testing personnel in accordance with this Recom.- American Society for Nondestructive Testing to mended Practice shall be applicable to each of the aid employers in recognizing the essential facton to be considered in qualifying employees engaged foHowing methods-in any of the test methods listed in Par. 3. *- a i Eraph Tndng (RD It is recognized that these guidelines may not be ape Pa n h g (@ 1.4 I
**** "'* " "E appropriate for certain applications. In developing his written practice as required by Par. 5, the em- "'. ui Penetrant Tsung W
- e. y unen Tuting MT) ployer shad review the detailed recommendations presented berein, and shat modify thern as neces- . e rn adi graphie Testm, g (NRT)
- g. Ieak Teshng (LT) sary to meet his particular needs.
- 2. DEFINITIONS f Terms included in this document are deEned as
- 4. LEVELS OF QUALIFICATION '
2.1 'n-re shall be three basic levels of qualiScation. 4.1 I"U *5: These levels may be further subdivided by the
- a. QualiBeation: Skill, training, and enerience re. employer to acknowledge that additional levels of quired for persennel to properly perform the skills and responsibility :,sy be ricassary for spe- g duties of a speciSc job. ciBe NDT applications.
w
- b. Certacation-Written testimony of qualiSca- In the process of being quali6ed and certiRed to at 4.2 tion.
June 1975 Edsfion l b
. least NDT Le- e indMdual shaB be consid- ments b accordance s applicable quality e d a Tramee. .ainee shad work along with o *=ta dn. omrt: Sed individual and skD not conduct bdepen-datly "Y '"' ""' Pat say rwult of a hst, " 6. EDUCATION, TRAINING AND g wrsa a esport of met seselm. - EXPERIENCE 4J De three basic leveh of q uam ,,, as g,3 61 Personnel considered for outilantion h neede-k"'8: senssive moths abaB have =ma-t edad= .
- a. NDT LEVEL I-An NDT Invel I bdividual trainkg and esperience to answe understandas shad be gnahA A to properly perform speciSc of the principles and procedures of those areas of calibrations, specise tests, and speciSc evalua- testag in which they are being exasidered for ear.
tions accordmg to written instructions and to re- tiscation. ; cord the resulto Be shad receive the =====ary 8.2 To be e==dA-ed for certiScotion, a ranAdate guidance or supemsion froun a certiSed NITT abD andsfy m of & foDowhg crimda for b 3"n1 D oe IU in&ndual. applicable NDT level. Documented training and/ I
- b. NDT LEVEL H-An NIyr Isvel U individual or expenence gamed h pooftnons and activities l shaB be quahSed to set up and calibrate equip- equivalent to those of Isvel D or Ievel In prior '
ment and to interpret and evaluate results with to es+=bhahment of the employer's written practice respect to applicable codes, standards, and spec- and a artsScotion program in accordance with IScations. He shnB be thoroughly f=mthat with this document shaB be -dAmd as satisfymg the the scope and limitations of tk method and criterin of Par. 611 and 6.3. shad exercise assigned responsibility for on-tk- Gil NDT IAvels I sad E job training and guidance of trainees and NDT Table 611A lists the recommended minimum level I personnel. He shad be able to prepare traming and supedance factors to be considered written instmetions, and to organize and report by b employer h mublishing wdtten practices edestmetzvolesting investigations. for quaBScation of Isvel I and I4 vel D indmd-
- c. NITT LEVEL IH-An NDT Isvel DI individu- unis. He experience factor in months is based on
. ~
.- al shad be capable of and responsible for estab- a normal 40-hour work week (175 hours per lishing techniques; interpreting code, stan. month). %% work : performed in excess of a dards and spenScations; and designating the 44 hour week, credit may be based on total hours.
particular test method and technique to be Records substantiating 'qualiSatier shad be kept on either a monthly or hourly basis. h used. He shad be responsible for the complete NDT operation he is qualised for and assigned 8.3 To be considered for certiscation as a I.evel HI, to, and shall be espable of evaluating results in tk cand2date shad satisfy one of the foBowing terms of existing codes, standards, and speaS- education and experience criteria: cations. He shad have sufScient practical back-8.3.1 NDT W HI ground in applicable materials, fabncation, and
- a. Graduate of a four-year aare&ted engineen.ng
/or product technology to establish techniques r science coBege or university with a degree in and to assist the design engineer in establishing acceptance criteria where none are otherwise Engineering or Science plus one year s expen-ence in n ndestructive testing in an assignment available. It is desirable that he have general C mparable to that df an NDT Level H in the familiarity with other commonly used NDT 8pphcaMe test method.
methods. He shad be responsible for the train. ing and examination of NDT Ievel I and 14 vel Note: If the coGege or unfoerrify degree is ie-H personnel for certiScation. %e actual admin- aued in nonderfructive testing, the one year's istration of training and grading of examina- experience requirement may be reduced to sfr tions may be delegated to a duly selected rep- months. resentative of the ' level III indiddual and s b. Completion with a passing grade of at least two recorded. years of engineering or science study at an ae-credited university, college, or technical school plus two years' crperience as a certiSed NDT
- 5. WRITTEN PRACTICE Level n in the applicable test method.
5.1 The employer shad establish a written practice for the control and administration of NDT person-
- c. T ur years, experience as a certiSed NDT 14v-nel training, examination, and certiScation. el II in the applicable testing method.
- d. When the individual is qualiSed by examina.
5.2 The employer's written practice should reflect the n, ea e re@ements may be partiaDy
' guidelines referenced in Par.1.
replaced by experience as a rertiSed NDT Lev-
) 5.3 The employer's written practice shad describe the responsibility of each level of certiacation for de-el H in other methods listed in Par. 3 of this Recommended Practice as deSned in the em-termaung the acceptability of materials or compo. player's written practica June 1975 EdSon 5
136 . MNe 3 g UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 DISCUSSION /POSSIBLE VOTE OM DIABLO CANYON CRITICALITY AND LOW POWER OPERATION . 4 (Continued) 1 5 Public Meeting 6 Nuclear Regulatory Commission 1717 H Street, Northwest 7 Room 1130 Washington, D. C. 8 . Tuesday, March 27, 1984 9 10 The Commission met in open session, pursuant to 11 adj ournq.ent , at 9:00 a. m., Nunzio J. Palladino, Cha.irman of 12 the Commission, presiding. 4 13 COMl1ISSIONERS PRECFNT: 14 NUNZIO P'ALLADINO, Chairman of the Commission VICTOR GILINSKY, Member of the Commission 15 JAMES ASSELSTINE, Member of the Commission THOMAS ROBERTS, Member of the Commission 16 FRIDERICK BERNTHAL, Member of the Commission 17 STAFF & PRESENTERS SEATED AT COMt!ISSION TABLE: 18 H. PLAINE W. MAGEE 19 W. DIRCKS D. EISENHUT 20 E. CASE J. KNIGHT 21 R. JACKSON H. THOMPSON 22 I. YIN 1 J. CLEWETT , 23 AUDIENCE SPEAKERS: 24 J. MARTIN 25 ATTACHMENT 4
T l26'2
- i
)
1 can address the order and see whether it is in shape enough 8 where we might possibly affirm it today. That would be my 8 suggestion. - 4 COMMISSIONER BERNTHAL: I think that is a pretty 5
. fast track in view of the fact that one or two Commissioners 8
yesterday expressed the desire to have some time to, I guess, I prepare statements or collect thoughts between the end of our a deliberations and the time that we vote. CHAIRMAN PALLADINO: We have had the additional time. I am guided by what you would like to do. I don't know 11 that it is necessarily a fast track. We have had the draft 12 orders and I have some comments and I am sure everyone else 13 has some comments. 14 COMMISSIONER BERNTHAL: I am trying to be realistic. 15 Maybe we can do it this afternoon.
- 16 CHAIRMAN PALLADINO
- Well, let's try it. If we get to a point where a significant revision is needed on the 18 order, if at least we have voted in principle, then we can 19 proceed to revise the order.
20 COMMISSIONER BERNTHAL: Are we not going to take 21 any time then in between end of deliberations and vote? 22 CHAIRMAN PALLADINO: I don't know when the delibera-23 tions end. I don't even know when they start. _ 24 COMMISSIONER BERNTHAL: Whenever they end. 25 CRAIRMAN PALLADINO: I was going to come back and n.pm---,----- -..-,.,-,ey-,-- - -
263
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*1 ask if we are prepared to vote on general principle. Then 8
after that, we can either put in a period of time and then I 3 come back and see where we stand on the order and that period 4 of time might also be useful for cross-talk Commissioner-to-8 C6mmissioner on aspects of the order. e j COMMISSIONER BERNTHAL: It wasn't clear to me i i 7 either that we had resolved -- we have heard the staff and 8 Mr. Yin, but we hadn't resolved exactly how we are going to 8 deal with that concern, have we? 10 COMMISSIONER ASSELSTINE: That is a big question, II I think, in my mind. CHAIRMAN PALLADINO: It is my understanding that 13 the staff including Mr. Yin are going to continue to address 14 the analyses that need to be made, further analyses, and out u of that may or may not come hardware' changes and the proposal 16 to the staff is that low power operation not be held up, 17 ' that they could be done after low power operation. Isa said 18 that he would prefer the other way around. I think that is an approach to the resolution that I understand. 20 COMMISSIONER BERNTHAL: That is the proposal of the 21 staff, yes. CHAIRMAN PALLADINO: Why don't we at least get GAP
~
23 up here and give them three minutes and then we yill see 24 where we are. . 25 MR. CLEWETT: Hello. My name is John Clewett. I am
264 b .- ! )
*1 . !
i an attorney working with the Government Accountability Project. s Thank you for letting me address you for a couple of minutes. 3 In listening to the presentation of -the staff 4 yesterday there were a large number of times when I restrained 5 myself from jumping up and saying, "No, that is not right." 6 - But there was one point in particular that I think is important 7 to clarify to the Commission. 8 That is on the , question of whether the staff has 9 made an effort *to get back in touch with the original 10 allegers to see whether the staff's resolution is adequate. 11 They have not made any effort whatsoever. 12 Just to clarify the efforts, the unsuccessful efforts, 13 that GAP made to talk the Region V staff into meeting with the 14 original allegers again, I know that Tom Devine of GAP. and 15 Tom Bishop of Revion V also had some negotiations, but in 16 particular for my part, I called Louis Shollenberger, 17 the regional counsel for Region V, on March 8th to ask when 18 they were going to be meeting with the original allegers again 19 because I could tell on the 19th When the staff was going to 20 be recommending action to you all was coming up soon, and I 21 knew that they had made no effort to date to contact GAP 22 or to directly contact any of the original allegers, so I 23 - called Mr. Shellenberger and asked him what plans Region V had 24 for meeting with these people. 25 He said, "Well, I don't know. I am not really sure i l
. 265
)
'I that I know one way or another, but I will get back to you 2 soon." So four days later on the 12th when he had not called 8
me back, I called him again and reminded of the fact that the 4 staff takes credit for this policy of meeting with the . 5 original allegers.
- At that point he again said that he didn't know what the plans were but that he would back to me in the near I
future. So two days later on the 14th, I called him again t because I had not heard from him. 10 At point he said, "Well, if you can bring two of II the people up tomorrow afternoon to Malnut Creek," which is 12 "
... we a four and a half hour drive from San Luis Obispo, 13 I told him that both of these people will meet with them."
14 He said, worked, that that was a practical impossibility.
!$ I said, "Well, why "Well, you just ought to be flexible."
16 can't you come down to the San Luis Obispo area to talk with 17 these people again like you did when you talked with them at la Region V would first?" He categorically refused to do that. 19 not do that. 20 So I checked with these people just to make 21 sure that they were going to work tomorrow and didn't feel 22 like calling in sick at the last minute or somethine and they 23 said that it was not possible for them to meet { So I called 24 Mr. Shollenberger again to tell him that. 25 Apparently he sent me a telegram saying that they
!.,- (lgz T h ug hamn - 'T Dbl 44$ 28 /f ,
i were eager to meet with peonle. I think it is really 3 interesting h'ow he handled that because he sent that telegram 3 knowing full well that I was in the San Luis Obispo area, he 4 sent that telegram to my office in Washington I didn't even 8 see.acopyofitdntilyesterday. 4 so it seems as though rather than living up to the 7 policy that they take credit for in SSER 21 and now in SSER 22 8 of trying to get back with the original allegers, in fact, 9 . it seems that the staff is trying to avoid the witnesses and 10 I think avoid some of these issues. 11 I would urge the Commission before doing anyt'hing in 12 - this case to at a minimum from the submission that we gave to 13 region V on Friday and that I understand was served on you 14 all yesterday morning, read the affidavit of Harold Hudson 15 because he was the internal auditer for a period of two and 16 a half years for Pullman Power Products. He knows more than 17 any other individuai alive, I am sure, the nature of the NSC 18 audit of Pullman and what it means and the fact that those 19 violations of Appendix B have continued unabated or in some 20 cases even getting worse up to the present day. 21 The staff made no effort whatsoever to get a hold 22 of him and his affidavit is very interesting in that regard 23 because he explains the initiative that he took to discuss the 24 quality assurance breakdown at Pullman and the fact that the 25 l staff at that point was apparently preparing report 83-37 that
( 267 didn't mention to him at all that this was underway. They 8 didn't ask him any questions about that nor did they get back 8 to him on any of the issues that he brought up that .were very similar to this. , I think it is amazing that six weeks after the staff a me t with Harold Hudson that they issued this report, 83-37, 7 which pretends that none of this happened. 8 I wanted to clarify that point particularly because 9 it seems that the staff is trying to avoid the witnesses and to avoid the issues. I think you can see that throughout the
- staff's response. I don't have time and I won't try to take 12 your time to go into any great detail, but one single example 13 of that is in our letter which we dated the 23rd, one of the 14 specific points that refers to a material false statement by 15 ~' -- <
, PG&E has to do with qualifications of quality control 16 personnel. 17 . - Now because of the haste with which this was put 18 together, this letter refers to these as nondestructive l 19 examination personnel. In fact, as you can see by going back j i 20 l to the actual materials and in particular, the a,ffidavit of 21 Stephen Lockert, the question is not the NDE personnel but 1 22 -- i it is the quality control inspectors. PG&E said in its ' 23 letter, DCL-84-082, that Pullman Power Products can qualified l 24 all of its QC inspectors, that they were all certified to 25 ANSI N45.2.6. 7l Mig rebuts that in considerable detail.
aos
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., (
I The staff which said that they had read all of these 8 materials reviewed the letter and : focused on the fact that 3 it erroneously said NDE personnel and said thgy. don't have to 4 meet ANSI N45.2.6. So as far as we are concerned this issue 5 is closed. . Well, the- issme is not closed because regardless .
' of the fact that there was e typo;or a "thinko" perhaps in I writina this up, the issue still temains.
8 I think the Commission 'should be very careful that
' its staff is not misleading the C'mmission o and I think that to the staff is misleading you folks and I hope that you don't 11 buy it.
12 I thank you again for letting me make a brief II presentation to you. 14 CHAIRMAN PALLADINO: The Commission may want to 15 follow-up after lunch. Thank you very much. We are going 16 to break now until 1:45 and then reconvene. . 17 (Whereupon, the Commission meeting recessed at the
's 12:35 o' clock p.m., to reconvene at 1:45 o' clock p.m.,
I 19 same day.) 20 31 --- 22 24 25 (
es 100 469 01 arl. l ) !
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,t AFTERNOON SESSION
. 1 3 (2:30 p.m.) '
i 3 CHAIRMAN PALLADINO: Good afternoon, ladies 4 and gentleman. . 5 I want to apologize for the delay, but I did 8 ' want all the Commissioners here. 7 t COMMISSIONER BERNTHAL: Let me just say that I 4 regret that you didn't proceed without me.
, I had an earlier 8
commitment, and unfortunately had we been able to mesh 10 our earlier commitments better, we probably could have il made more efficient use of our time. 12 CHAIRMAN PALLADINO: Let me propose an agenda 13 for this afternoon that goes as follows: 14 That we first give the Staff three minutes to 15 respond to the remarks made by GAP; then allow five 16 minutes to Mothers for' Peace, who had requested time and 17 the Commission voted to give that time. Then I would 18 propose that each Commissioner spend about five minutes, 19 hopefully not more than ten, giving guidance to OGC on 20 the kind of order that they ought to prepare, and at the 21 end of that period I would suggest then we recess until 22 Friday morning, and in the interim have OGC prepare the 23 draft order -- walk the halls if necessary to c'larify points - - 24 1 and see if we can't then vote on whatever order comes up 25 on Friday. . l t
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( ) 136 I g UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 DISCUSSION /POSSIBLE VOTE ON DIABLO CANYON CRITICALITY ' AND LOW POWER OPERATION .. 4 (Continued) - J g Public Meeting g Nuclear Regulatory Commission 1717 H Street, Northwest 7 Room 1130 Washington, D. C. 3 . .. Tuesday, March 27, 1984 9
, 10 The Commission met in open session, pursuant to 11 adjournment, at 9:00 a. m., Nunzio J. Palladino, Chairman of 12 the Commission, presiding.
12 cob 21ISSIONERS PRESENT: 14 ' NUNZIO P'A.LADINO, Chairm'an of th'e Commis'sion ,
. VICTOR GILINSKY, Member of the Commission
- 15 JAMES ASSELSTINE, Member of the Commission THOMAS ROBERTS, Member of the Commission 16 FREDERICK BERNTHAL, Member of the Commission 17 STAFF & PRESENTERS SEATED AT COM!!ISSION TABLE:
l 18 H. PLAINE W. MAGEE 19 , W. DIRCKS .l D. EISENHUT 20 E. CASE ] J. KNIGHT 21 R. JACKSON H. THOMPSON 22 I. YIN 1 J. CLEWETT . 23 - AUDIENCE SPEAKERS: 24 i J. MARTIN 26 ATTACHMENT 5
AR RET g ) 269 41 arl . 1 AFTERNOON SESSION 2 (2:30 p.m.) 3 CHAIRMAN PALLADINO: Good afternoon, ladies 4 and gentlemen. , 5 I want to apologize for the delay, but I did 6 want all the Commissioners here. 7 COMMISSIONER BERNTHAL: Let me just say that I 8 regret that you didn't proceed without me. I had an earlier 9 commitment, and unfortunately had we been able to mesh 10 our earlier commitments better, we probably could have 11 made more efficient use of our time. 12 CHAIRMAN PALLADINO: Let me propose an agenda 13 for this afternoon that goes as follows: 14 That we first give the Staff three minutes to 15 respond to the remarks made by GAP; then allow five 16 minutes to Mothers for Peace, who had requested time and 17 the Commission voted to give that time. Then I would - 18 propose that each Commissioner spend about five minutes, 19 hopefully not more than ten, giving guidance to OGC on 20 the kind of order that they ought to prepare, and at the 21 end of that period I would suggest then we recess until 22 Friday morning, and in the interim have OGC prepare the 23 draft order -- walk the halls if necessary to. clarify points
'4 4
and see if we can't then vote on whatever order comes up ~ 25 on Friday.
( ) 270 Er2 1 Now if this is agreeable, that is the way I 8 would propose to proceed. 3 All right, hearing no objection, let me turn , 4 to Jack Martin, I believe, who is going to comment on the 5 GAP remarks. 6 MR. MARTIN: I don't believe I will take my 7 full three minutes. I only had two or three comments, 8 and I'd like to try to avoid a bickering contest here, but
' I made a couple of notes of things that were said that to just aren't true.
11 For example, the statement was made that no 12 effort whatsoever was made to contact the allegers or to 13 close the loop with people to go over how we dealt with I' their concerns. This is not true. We spent hours and 15 hours and hours with Mr. Stokes, for example, doing just 16 that. 17 I think I pointed out to the Commission 18 Monday -- yesterday and the previous Monday -- that we did 18 not do that in all cases. We'd like to, but we couldn't
" do it in all cases. But we did do it in some. So the assertion that no effort was made whatsoever is just false.
COMMISSIONER GILINSKY: Well, let's see. I I think what the man from GAP was saying was not that no l 25 effort had been made to talk to these people, but I think
271
.. . cr3 ( ;
. g he was saying that no contact had been made subsequent 3 to your resolution of the issues --
.MR. MARTIN: That's what I'm saying, that that's 3
4 not true in all cases. So it's just not a true s'tatement. i 8 Another assertion was made that no effort was made to get ahold of Mr. Hudson. Well, that's not true. 4 7 on the slide I passed out to you yesterday, we had talked a to him for at least nine hours involving several people at g several different times. 10 So I think he had plenty of opportunity to bring 11 up his concerns which are'now in a fourth affidavit. , 12 So to paint the picture that we made no effort 13 to talk to the man or plumb him for his concerns is just 14 not true. 15 And the other business about the factually Is incorrect statement about the nondestructive examination 17 personnel, I'm not sure how we are supposed to deal with is "thinkos" or " typos" or whatever in letters. We dealt with 19 what was written, not with what they may have intended, 20 and really that's all I have to say. 21 We did send the telegram to their' address. Many ! of us have trouble getting our mail. I think the reason --I 22 23 wasn't able to check with my lawyer -- but I think the 24 reason we did that is because we didn't know Where he was. 26 So that's really all I have to say. I'd like to
) 272 Or4 (
, 1 take a closer look at the transcript, but that's a reaction, 3 if you will.
3 CHAIRMAN PALLADINO: Are there any Commission 4 questions? . 5 All right. Well, then, I propose that we have 6 the representative for Mothers for Peace join us at the 7 table. 8 The Commission has allowed up to five minutes. g could you get closer to the mike? You have 10 to speak right into it. 11 Could you identify yourself, please, for the 12 record. 13 MS. SILVER: I am Sandy Silver. I am with 14 the Mothers for Peace. The Mothers for Peace have been _ 15 intervenors in these proceedings for over 10-1/2 years. 16 ordinarily I would courteously thank you 17 for allowing me to speak. However, that wouldn't be honest.' 18 We have asked you in the past to come to San Luis obispo l 19 to talk to the people and to listen to the people, and l 30 you have refused us on every single account. 21 You are going to be making a decision that 22 affects the lives of our children, the future of our l 23 children, and you sit here isolated, 3000 miles' away from i 24 us. - l l 2 I spent all night on a plane last night, along l l
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+ . . AFFIDAVIT My name is Steven Iockert. I am making this statement freely, without any threats or inducements, to John Clewett, who , is an attorney working with the Government Accountability Project. I am making this statement because I have knowledge of false and misleading statements made by the Pacific Gas and Elec-tric Company (PG&E) to the Nuclear Regulatory Commission in re-cent investigations concerning construction Quality Assurance. l The acceptance of the false and misleading statements by the NRC staff in its investigation has shed light on what type ~of investe-gation the staff has conducted. I am becoming increasing con-cerned .with the character and competance of PG&E from my review of their answers to the NRC staff. More importantly, it appears 1 that the staff has not reviewed the utilities answers to the ques-tions with the care and attention the matter deserves. . l ' The subjects I intend to discuss that show false and mis-leading statements by PG&E are: ! I. Qualification of Pullman Quality Control Inspectors. . II. Welding of ASTM A-325 High Strength Bolts. I ask that the utility be held to full accountability for its state-ments to the NRC staff and that the staff show cause for accept-ance of those statements. ATTACHMENT 6
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R e sponse to PG&E Letter No. DCL-84-082 M
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Subject:
IPG&E's aasortion tha.t Pullman Power Noducts has Quality Control inspectors certified to ANSI N45.2 6 require-
~
ments . . At the NRC's request PG&E has prepared a statement that ad-dresses the qualification of Pullman Inspectors. PG&E has alleged that the Pullman unspectors are certified to ANSI N45.2.6 requirements. This statement is totally false. The following facts are given to ! show why PG&E's statement (DCL-84-082) is false, i 1.) Pullman nover required the prerequisites of schooling and on l the job training per ANSI N45.2.6, paragraph 3.1.2 of its inspector candidates for InvalII capabilities. Currently there are inspectors who ' hired in as SNP-TC-1A Nondestructive Examination personnel .and who have been subsequently upgraded to I4 vel II visual, dimennonal, and welding inspectors. Many of these people do not have a four year degree and two years of experience or a high school degree - with four years experience, as required by ANSI N45.2.6. 2.) N either Pullman ror PG&E told the Pullman inspector that he . l l was certified to and responsible for ANSI N45.2.6 Level II capabili-tie s. Pullman's certification card for the inspector does not refer-ence ANSI N45.2.6, the required basis for certification. 3.) Pullman's training program did not address the technical ob-jectives of the project. While Pullman's training program did cover l l l
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. 3 some of the Pullman procedures (ESD s ) the training program did zwt cover: 10 CFR 50, Appendix B, Quality Assurance Criteria 10 CFR 21 Reporting of Defects and Noncompliance ANSI N45.2 Quality Assurance Program Requirements ASME Boiler and Pressure Vessel Code- Sec. III,VIII, and IX ASME Pressure Piping Codes B31.1 and B31.7 AWS DI.1 Structural Welding Code AISC Steel Construction Manual Training in the above mentioned documents is necessary because Pullman procedures, like any in-house procedure, can not cover -
every possible application that the inspector will encounter in the performance of his duties. Knowledge of what staru..: above the Pullman procedure, aids the inspector in finding the applicable re-quirements for quick resolution of problems and provides feedback to the company on how well the procedures are being applied to work performed in the field. j 4.) Pullman did not adequately explain in the training program the Quality Assurance elements, the capabilities and limitations of those elements, to be employed on the job. For instance, it was only after I had talked to the NRC that I learned the Pullman Discrepency Report (DR) was word for word the same thing at a l Non-Conformance Report JNCR.) Pullman QC inspectors dfd n'ot l
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_is . , l write DRs but were instructed to communicate quality problems l through a Deficient Condition Notice (D'CN ) The DCN was sub-ject to engineering approval before the DCN could be inser'ted in-to" the QA system and in that way the inspector's ability to perform independent of production in reporting of problems was subverted 1 5.) Fullman QC Inspectors were specifically instructed to only consult Pullman procedures (ESDs) for evaluation of a component or activity's adherence to quality objectives and code compliance. l Further, Pullman inspe'ctors were specifically instructed by Pullman management to accept all conditions falling outside the scope of 2 Pullrr.an procedures. The ANSI Level II inspector is required as a minimum to evaluated inspection and test results which would in-cludie referencing the appropriate codes and standards when nec-essary. l
Conclusion:
The Quality Assurance requirements at a nuclear power plant can be viewed as a pyranid with the most important requirements ' at the top. The next lower tier would hold more requirements as 1/ See incident surrounding DCN 1/1640-021 related on pages 9-12 i of Steven Lockert's report to USNRC dated Jan. 2,1984, included as part of attachment 3 of the 2.206 petition filed on Feb. 2,1984 . by the Government Accountability Project. 2/ See page 5 of Steven imekert's report to USNRC, Jan 2,1984 e e
- ~ . .
5-the nature of the wcrrk becomes diversifked and more specific. The lowest tier would be the actual instruction to each person for each act requiring quality control in the construction of the plant. Each CFR ANSI N45.2 ASME, AWS, ASTM, AISC CENCEE AND CONTRACTORS PROCED th - i . .. e tier supports and hopefully includes all applicable requirements from the tier above it. Pullman inspectors were not certified to A2:SI. N45.2.6 requirements and neither were they allowed to con-duct themselves as inspectors capable of recognizing problems l w.ithin the quality assurance pyramid because Pullman inspectors viere blocked from obtaining information beyond company procedures l and boxed in the lowest tier of the quality assurance pyramid. i ! For PG&E to make the statement that Pullman QC inspectors were certified, to ANSI N45.2.6 requirements without telling the inspec-tors or allowing the inspectors to conduct themselves as such, appears to be only for the purpose of misleading the NRC into granting a licence before a complete evaluation of construction' Quality Assurance problems has been completed, f e
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i sp) L $ l U. S. NUCLEAR REGULATORY COMMISSION REGION V Report Nos. 50-275 83-37 and 50-32 /83-25 Dockat Nos. 50-275 and 50-323 License No. DPR-76 and Construction Permit No. CPPR-69 Licensee: Pacific Gas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Facility Name: Diablo Canyon' Units 1 and 2 Inspection at: Diablo Canyon Site, San Luis Obispo County, California Inspection conducted: November 14-18 and November 28 - December 9, 1983 Inspectors: M. 4 A4 d S/ST/SY Date Signed Gg i. ernandex, act @ nspector
. k $w CM R ss, Reactor Inspector 2lt9bY Dde S'igned
- AU D. E Kitnti, Chief, Reactor Safety Branch AYSY Dite' Signed Approved by: _
1M4 /84 H. L.' Canter, Chief Date Signed Reactor Projects Section No. 3 Inspection During the Period of November 14-18 and November 28 - December 9, 1983 (NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25). Areas Inspected: A special, unannounced inspection by regional-based insjutetors to nerform an in-depth review of selected findings contained in an audit of the Pullman Power Products Quality Assurance Program conducted by Nuclear Services Corporation (NSC), during August - September 1977. Concurrently, the licensee and contractor responses were evaluated to establish whether the outstanding issues identified by NSC were resolved or corrected. The inspection involved 402 inspection-hours by three NRC inspectors. Results: Of the areas examined one item of noncompliance was identified (failure to assure that welding inspectors are qualified and certified in accordance with procedural requirements, paragraph No. 17). t
^
G N O! PDR 5 ATTACHMENT 7
d j g Finding: C The inspector reviewed the historical file for ESD-223, " Installation and . Inspection of Pipe Supports" and, specifically, the extensive revisions
.that occurred on November 11, 1975 and May 25, 1976. The inspector found that the procedure revisions contained adequate Quality Assurance / Quality Control instructions for the control and identification of Class I pipe supports. Additionally, the inspector found that other existing procedures, contained in the Pullman Quality Program, provided additional or amplifying instructions for the identification and control of Class I pipe supports.
No items of noncompliance or deviations were identified.
- 17. Criterion IX, NSC Audit Findina No. 3:
'~
"The qualification and certification program for NDE and inspection personnel has been inadequate. The records of the following personnel were examined: D. R. Geske, T. L. Koch, J. E. Cavelti, G. P. Keeler, K. E. Beck, L. Glass, W. R. Johnson, E. Stanton, C. B. Athay, R. G.
Sears, D. S. Tutko, J. N. Shiromizu, V. J. Casey, J. A. Brasher, L. F. Myrick, S. R. Stan1.ey, H. Guest, D. E. Bentley, R. D. Kincade, K. D. Cuy, J. R. Bowlby, E. R. Jennings, A. L. Newton, C. C. Lenzi, J. J. Sisk, L. K. Thomas, A. A. Conques, and R. L. Marks. In virtually all cases, the individuals begr.n performing their duties without fulfilling the specified requirements. The most prevalent discrepancies are: not completing the required training, not having proof of previous experience, insufficient time as Level I, unsigned tests, and insufficient background and experience." NEC Finding: The inspector examined the procedures for qualification and certification of non-destructive examination and inspection personnel that existed in Pu11mac's program before September 1977. These are Engineering Standard-Diablo (ESD) No. 235, " Nondestructive Examination Personnel Qualification and Certification Procedure," dated September 25, 1973, and ESD No. 237, "Qa lity Assurance Inspector Training Program," dated February 26, 1974. The requirements for qualification of Pullman inspectors must have been revised or amplified on or af ter September 25, 1973. This is based on the Pullman response, to the above NSC audit finding, which states in part, that "All current inspectors have been qualified by test as outlined in ESD-237. Requirements for qualification and certification of field inspectors were added in ESD-237 on September 25, 1973 to reflect the requirements of ANSI N45.2.6, just published. Persons hired before this time were not necessarily tested at time of hire. Subsequent to 1973, the records indicate that all inspection personnel received required training and examination." A review of the ESD-237 historical file indicated that a prior revision had occurred on May 1,~1969, however, no procedure revision could be found which was spec.ifically dated September 25, 1973. l i i ._ _ _ - - _ . _
( - sjk 'dh i 1 I ESD-237, dated February 26, 1974, states in paragraph 2.3 that, "All ) personnel engaged as Field QA Inspectors involved in the inspection of 1 velements, interpretation of Engineering Specifications and Welding Procedures, and documentation work, shall be required to complete an indoctrination period as described in Section 4 of this specification." Paragraph 4.1 states that, "The indoctrination period for the Field Q.A. Inspectors described in Section 2.3 shall contain as a minimum, but not necessarily limited to, the following courses: Visual Inspection Welding Procedures ,j' Welding Inspection Welding Processes Basic Q.A. , Other courses offered as optional are: Welding Steam Power Plant Fundamentals Basic Power Plant Instrue. Welding & Piping Eng. Technology ~ Introducing Nuclear Power (I.C.S.) The Visual Inspection and Welding Inspection tests shall be administered and controlled by the N.D.E. Training Officer. All N.D.T. training, qualifications and certifications will be covered by ESD-235." The terms NDE and NDT are synonymous and refer to nondestructive examination. Paragraph 4.2 states that tests used for the indoctrination courses for Field Q. A. Inspectors shall be:
- 1. For Basic Q.A. Test-ESD's.
- 2. Far Weld Procedure Test-Approved Welding Procedures.
- 3. Fce the Weld Process Test, Welder Qualification Card and Pipefitter's Manual.
- 4. For s'elding Inspection Qualifications, General Welding Information.
- 5. Visua: Inspection Qualifications-General Dynamics NDT Introduction.
Examination of ESD-235 indicated that although this procedure is a nondestructivs personnel qualification and certification procedure, the ' procedure also d scribes levels of qualification for visual _ inspection personnel, the ty,e of examination, the number of questions, and the acceptable grade for the examination. Additionally, a welding test requirement is contal:md in paragraph 11.2.14 which states that, "A combination of General. Specific, and Practical examinations will be given using the Diablo Ca. yon Welding Seminar Test Paper, containing 66 questions." Therefore, it is apparent that Field QA Inspectors were required to be indoctrinated through a program of coerses related to their job function, including visual and welding inspection tests administered and controlled by the NDE Training Officer. Discussions with contractor personnel indicated that, in the pre-1977 time frame, the training officer controlled all personnel certifications, with no distinction,being made between NDE and welding inspection personnel. The inspector examined the personnel files of 20_of the 28 individuals named in the NSC audit, comparing the date when each individual started e
(s @ II Y )
,eployment with Pullman Power Products versus the date each individual started accepting work. This exsiination confirmed the NSC audit finding that in virtually all cases, weldinz Quality Assurance Inspectors began perzorming their duties without fulfilling the specitica requirements and' witnous completing the required training. Two examples are as follows:
- V. J. Casey began employment with Pullman Power Products on November 19, 1973 and began accepting weldments in November, 1973.
'He was not certified as a welding inspector until February 27, 1974. 1
- E. R. Jennings began employment with Pullman Power Products on (
January 16, 1974 and began accepting weldments on January 22, 1974. I he was not certified as a welding inspector until April 21, 1974. l Additiona31y, two other inspectors were found to have questionable backgrounds which, in the inspector's opinion, would not warrant their immediate certification as welding inspectors. K. D. Guy had essentially no background in quality control / quality assurance, yet within two months Wiwas a fully certified inspector accepting weldsents. A. L. Newton had some background in the aircraft industry, but a lapse of several years had occurred between the time he had terminated his employment in the aircraf t industry and the time he began employment with Pullman. Yet within two months Newton was accepting weldments. Bo_th of these individaals had taken several, but not all, of the required welding examination tests specified in ESD-237. Therefore, both of these inaividuait also began performing their duties without fulfilling the specified requirements and without completing the required training. The failure to assure that Quality Assurance Inspectors were qualified and certified in accordance with the contractor quality orocedures is considered an apparent item of noncompliance (50-275/323/83-37/01). It should be noted that for all personnel files examined, with the exception of Messrs. Guy and Newton, all individuals appeared to be experienced, with adequate backgrounds either in welding or in the area of quality control inspection. . The inspectors review of personnel files further concluded that Pullman NDE personnel were properly certified and had not accepted or performed work prior to being certified in accordance with Pullran procedures or
- codes.
The inspector concurs with the NSC audit finding that welding inspection personnel performed inspections prior to being certified. The inspector does not concur with the NSC finding that NDE personnel performed nondestructive examinations prior to being certified.
- 18. Criterion IX, NSC Audit Finding No. 10b:
"The Ninety-Day Welders' Log was not maintained f rom August, 1972 to December, 1972. There is no Weekly Qualified-Welders List for that time period to substantiate that the welders were actually qualified."
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I t ,o l 49 mAY l M o PACIFIC GAS AND ELE C TRIC C O MPANY bOWb l 77 BEALE STREET . SAN FRANCISCO. CALIFORNIA 94106 . (415) 78142p 8
. TWX 910-372 6587 ,
. o. senunes.
February 29, 1984 PGandE Letter No.: DCL-84-082 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 - Diablo Canyon Unit 1 SSER 21 - Item 23, Qualification of Pullman Inspectors
Dear Mr. Martin:
Enclosed is PGandE's response to Item 23 identified in SSER 21 pertaining to the , qualification of Pullman Power Products quality control velding inspectors. Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope. Sincerely,f 1
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J. O. huyler Enclosure cc T. W. Bishop D. G. Eisenhut H. E. Schierling
, Service List e
o ATTACHMENT 8
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.k PGandE Letter No: DCL-84-082 ENCLOSURE DOCUMENTATION OP PULLMAN POWER PRODUCTS
, 'e VELD INSPECTOR QUALIFICATION s
' Request for Information The NRC reviewed the findings resulting from a 1977 audit of Pullman Power Prcducts (Pullman) performed by Nuclear Services Corporation (NSC). This review 1983. was conducted during the period from November 13th through November 1 The NBC identified a number of welding inspectors who, prior to documentation inspections. of their qualification, had appa'rently performed acceptance only performed fit-up and visual weld inspections.These inspectors did j The NRC has requested that PGandt, review the Pullman welding inspector
! gualification program and report the results of this review to the NRC. ' Response ' Pullman began construction at Diablo Canyon in mid-1971. from start of work through late 1973, weld inspector qualification andDuring the period documentation of qualification was not formalized. An individual's qualifications were reviewed and accepted prior to assignment to inspection duties. and technical requirements.The inspectors were indoctrinated and trained in accorda not consistently retained. However, documentation of these activities was It ahculd be noted that prior to September ,1973, there was no requirement or guidance available within the industry, directing the documentation of Tialification earporate and or certification of inspection personnel. In late 1473. with _ besan forma 11sina tkt oroceng of weld inspector gualification.anaf te resulted in the_iesuance and annroval of Procedure ESD-237 in FebruaryThis effort 1474. Reviews 1974. performed to date indicate the Procedure was fully' implemented by June 3 _establishina Procedure
.This coanlies with ANSI N45.2.6 with the excention of inanector levels. Beginning in early 1973, Pullman has been surveyed by the ASME a number of times and has been granted certificates of authorisation qaality controlindicating activities.compliance with ASME code requirements including i -
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1 ME Procedure ESD-237 was modified to include identification of inspector level as which a result required fullof a PGandE compliance QAANSI with audit#45.2.6. and a contract soecification chanae r A review of the NSC audit results indicates that, during the period from 8 Septenber 197.3 through May 1974, certain inspectors did perform inspections prior to docvaentation of qualification. However, this condition'was corrected in June 1974 by full implementation of Procedure ESD-237. The IRC identified two inspectors who may have performed inspections prior to being adequately trained and qualified. These inspectors have been identified as Mr. Newton and Mr. Guy. PGandE's review of their records is discussed below. Mr. Guy was hired on November 8,1973, which was at a period when the program for training and documentation of qualification was being developed. Documentation exists which shows Mr. Guy's qualification to perform weld inspections after January 18, 1974. A sample of Mr. Guy's work performed Prior to January 18, 1974 will be reinspected. This reinspection will be completed end ths results will be reported to the NRC prior to March 30, 1984. A high level of confidence in the quality of the work to be reinspected is established by the fact that
- 1. All code Class A, B, and C welds were inspected using NDE methods by qualified individuals in addition to the visual inspections performed by Mr. Guy.
- 2. In some cases, the welding inspection was witnessed by the Authorized Nuclear Inspector.
- 3. All Design Class 1 piping has been hydro-tested and, in some cases, reinspected for the base line data as a part of the Inservice Inspection Program.
Documentation exists which shows that Mr. Newton did not perform acceptance - inspections prior to documentation of his qualifications. Therefors, no reinspection is required. In addition, PGandE plans to review quality records prior to June 1974 to confirm that no other acceptance inspections were made prior to docu=entation of inspector qualification. Should any deviations be found, the basis for qualification will be established and documented, or reinspection will be performed. For the period following June 1974, a sample of inspection records and documentation of inspector qualification will be reviewed to confirm that no inspections were performed by inspectors prior to documentation of their qualification. These record reviews, and any resultant inspections, will be completed and the results reported to the NRC prior to power ascension. l 0382d/ l \ ._ _ __ __.
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I U.S. NUCLEAR REGULATCRY c0MMIS$10N Office of Inspector and Auditor 5
- o. ,, ... September 10, 1985 '
- Report of Interview i John B. Martin, Regional Administrator, Region V, was interviewed concerning allegations by the Government Accountability Project (GAP), that on March 26, i 1984 and March 27, 1984, he made false or misleading statements to the Commission and that on March 26, 1984, he was present when a member of his ,
staff made a false or misleading statement to the Comission, and that these ; statements could have influenced the Comissioners in their decision as to l whether to permit low power testing at the Diablo Canyon Nuclear Power Plant. ; At the outset of the interview, Martin was informed that the alleged false or misleading statements could later be determined to be a violation of Federal Law by the Department of Justice and may also constitute employee misconduct. Consequently, Martin was informed that.he had a right to remain silent if his answers could tend to incriminate him and that any answer or information he gave could be used against him in any subsequent administrative or criminal proceeding should it occur. Martin was also advised that if he chose not to talk to this investigator, as was his right, no adverse action could be taken against him for the mere refusal to answer questions. Martin was informed, however, that his silence could be considered in an administrative proceeding f for its evidentiary value that was warranted by the facts surrounding this case. Having been advised of his rights, Martin elected to discuss the , allegations under investigation. The first allegation discussed was that on March 26, 1984, Martin made a false or misleading statement to the Comission regarding the use of ANSI N45.2.6 as the a)plicable standard for Non Destructive Examination (NDE) personnel, and that iart1n's statement that " ANSI-N45.2.6 is not the applicable standard" for NDE persormel was false. In response to this allegation, Martin asserted that the applicable qualification standard for NDE personnel is SNT-TC-1A while ANSI-N45.2.6 is the applicable standard for quality control (QC) inspectors. The second item in the March 23, 1984, GAP letter to the Comission, to which. Martin was referring when he made the coment, alleged that "NDE" personnel , I ! were not qualified under ANSI N45.2.6 as claimed by PG&E: Consequently, ' i Martin's response was factually correct when he addressed that allegation and stated to the Comission that NDE personnel have to meet only the standards of SNT-TC-1A. The point he was trying to make when he made the observation was that GAP's allegation was factually wrong. Martin's reply to a rebuttal by John Clewett, an attorney for GAP, before the Comission on the morning of March 27, 1984, was then discussed. In his rebuttal to Martin's March 26, 1984, coments, Clewett essentially admitted that GAP's several references to NDE personnel in their March 23, 1984, letter were erroneous and the point that GAP was making in the letter was false i statements by PG&E to the NRC having to do with qualification of " quality l
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2
.o a control" personnel. Clewett claimed that the materials provided as attach-ments to the March 23, 1984, letter showed that the issue was qualification of QC inspectors in accordance with ANSI M45.2.6 and not qualification of NDE ,
personnel. During testimony before the Comission on the afternoon of i ' March 27, 1984 Martin responded to the Clewett rebuttal by stating that Region V " dealt with what was written, not with what may have been intended." Martin explained his reply to Clewett's rebuttal by stating that he was given no notice by the Comission when the morning session of the March 27, 1984 Comission meeting recessed for lunch that he would be required to respond to Clewett's remarks when the meeting reconvened. Martin had only a vague recollection of what Clewett had said, and he had not taken detailed notes. In fact, Martin was still uncertain about the point GAP was trying to make. When Martin was called upon to respond to Clewett's remarks, he had no inten-tion of trying to portray that Region V had completed a thorough exa'nination of the March 23, 1984 GAP letter. Additionally, Martin did not want to react to Clewett's morning coments and further evaluate GAP's March 23, 1984, l submittal on the spur of the moment. As stated in the transcript, he wanted to take a closer look at what Clewett and GAP had to say before comenting further on the allegations. By way of additional explanation Martin stated Region V received the GAP letter on Friday evening, March 23, 1984. During the weekend between March 23 and 26, 1984, Region V read the GAP letter to get a " sense" if GAP was raising any substantially different issues from the ones Region V had already investigated. This purpose was accomplished by reviewing the issues outlined' in the cover letter and reading through the attachments. Region V did not study the attachments to the letter and did not evaluate the merits of i individual allegations other than to detemine if they were similar to previous GAP allegations and submittals or were new allegations of such impact to warrant resolution prior to low power operation. Martin noted this is clearly discussed in the meeting transcripts. The second allegation discussed was that on the afternoon of March 27, 1984, l Martin made a false or misleading statement to Comissioner Gilinsky regarding close-out interviews with allegers. According to GAP, Martin implied there . had been several follow-up interviews with an alleger, when in actuality, there had been only initia) interviews. Furthemore, Martin falsely stated to Comissioner Gilinsky that follow-up interviews had been conducted with allegers subsequent to Region V's resolution of the issues. In response to this allegation, Martin stated that his coments on the afternoon of March 27, 1984, were in response to statements made by Clewett to the Comission during the morning of March 27, 1984. It was Martin's understanding that Clewett had two concerns: 1)RegionVwasnotconductingclose-outinterviewswith allegers, and 2) Region V made no effort whatsoever to interview Harold Hudson. Martin pointed out that page 270 of the transcript of the March 27, 1984 Commission meeting documents his reply to Clewett's assertion that Region V was not conducting close-out interviews of. allegers. Martin stated that when he refuted this assertion he had in mind the close-out Martin interview that Region V conducted of noted this was clear in the meeting transcript. Martin used this as an example to the Comission that Region V had conducted close-out interviews in some, but not in all, cases. Martin stated he had the same thoughtin mind when he responded to Comissioner Gilinsky's question concerning whether l 9
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3 I Region V was conducting close-out interviews by stating that Clewett's . assertion was not true in all cases. Martin stated that his testimony on page 271 of the March 27, 1984, transcript was in rebuttal to what he considered to be the second issue raised by Clewett, i.e., Region V had made no effort to interview Hudson. Martin noted the transcript was clear that he considered this "another assertion." Martin responded to this "other assertion" by stating that Region V had interviewed Hudson on several occasions to gather his concerns. Martin stated he did not intend for this connent to imply nor did he consider it to imply that Region V had conducted close-out interviews with Hudson. Martin commented that, like the previously discussed allegation, he was not prepared on the afternoon of March 27, 1984, to formally reply to Clewett's earlier comments. Martin's consnents to the Comission were meant to convey the thought that GAP had made a sweeping allegation concerning the lack of close-out interviews that was not true in all cases. The third allegation discussed was that Martin was present on March 26, 1984, when a Region V official made a false statement to the Commission when he stated he had not been provided supporting material by GAP for an allegation concerning hydrostatic test records. In response to his allegation, Martin commented that to the best of his knowledge, the statement made by . Thomas Bishop, the Region V official, was accurate. Martin noted that Bishop himself qualified his statement to the Commission with the phrase "to my knowledge." Martin was personally aware that GAP had raised the issue of hydrostatic test records in its 10 CFR 2.206 Petition dated February 2,1984. However, Region V had not had sufficient time before the March 26, 1984, Connission meeting to review the issue in detail. Additionally, Martin was aware that GAP's February 2, 1984, 2.206 Petition was missing an attachment; however, he was not aware that the missing exhibit had been received by Region V prior to the March 26, 1984 Commission meeting. Martin commented he had no reason to believe Bishop intended to mislead the Commission by his comment. Martin also noted that, in his opinion, Bishop's connent was not meant as a criticism of GAP. It was just a factual statement that to the best of his knowledge, Region V had not yet received all the information from GAP. l Additionally, the allegation about h: drostatic test records was not being ignored by Region V. As stated in the transcript, this was an area Region V had already paid close attention to and felt Region V understood. This issue was eventually addressed in detail, found not to be a problem, and was dis-cussed and closed out with the alleger. 9 O e
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1 UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION 3 DISCUSSION /POSSIBLE VOTE OM DIABLO CANYON CRITICALITY AND LOW PoliER OPERATION . 4 (Continued) J 8 Public Meeting g Nuclear Regulatory Commission 1717 H Street, Northwest y Room 1130 Washington, D. C. t; - Tuesday, March 27, 1984 9 to The Commission met in open session, pursuant to 11 adj ourn. gent , at 9:00 a. m., Nunzio J. Palladino, Chairman of U2 the Commission, presiding. 13 COM!!ISSIONERS PRESENT: 14 NUNZIO P'LLADINO, A Chairm'an of the Commission VICTOR GILINSKY, Member of the Commission 15 JAMES ASSELSTINE, Member of the Commission THOMAS ROSERTS, Member of the Ccmmission 16 FREDERICK BERNTHAL, Member of the Commissien 17 STAFF & PRESENTERS SEATED AT COM!!ISSION TABLE: 18 H. PLAINE W. MAGEE 19 W. DIRCKS D. EISENHUT , 20 E. CAS E J. KNIGHT 21 R. JACKSON H. THOMPSON 22 I. YIN J. CLEPETT , 23 AUDIENCE SPEAKERS: 24 J. MARTIN 25 ATTACHMENT 10
AR R&T ) 269
' 01 a'I l 1, 1 AFTERNOON SESSION ,
2 (2:30 p.m.) _ 3 CHAIRMAN PALLADINO: Good afternoon, ladies 4 and gentlemen. 5 I want to apologize for the. delay, but I did 6 want all the Commissioners here. 7 COMMISSIONER BERNTHAL: Let me just say that I a regret that you didn't proceed without me. I had an earlier 9 commitment, and unfortunately had we been able to mesh 10 our earlier commitments better, we probably could have 11 made more efficient use of our time. . 12 CHAIRMAN PALLADINO: Let me propose an agenda 13 for this afternoon that goes as follows: 14 That we first give the Staff three minutes to 15 respond to the remarks made by GAP; then allow five 16 minutes to Mothers for Peace, who had requested time and 17 the Commission voted to give that time. Then I would 18 propose that each Comraissioner spend about five minutes, 19 hopefully not more than ten, giving guidance to OGC on 20 the kind of order that they ought to prepare, and at the 21 end of that period I would suggest then we recess until 22 Friday morning, and in the interim have OGC prepare the 23 draft order -- walk the halls if necessary to clarify points - -
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l 24 and see if we can't then vote on whatever order comes up l 25 on Friday. l
, - I 270 ar2 1 Now if this is agreeable, that is the way I 2 would propose to proceed.
3 All right, hearing no objection, let me turn 4 to Jack Martin, I believe, who is going to co'mment on the 5 GAP remarks. 8 MR. MARTIN: I don't believe I will take my 7 full three minutes. I only had two or three comments, 8 and I'd like to try to avoid a bickering contest here, but 8 I made a couple of notes of things that were said that 10 just aren't true. 11 For example, the statement was made that n6 12 effort whatsoever was made to contact the allegers or to 13 close the loop with people to go over how we dealt with 14 their concerns. This is not true. We spent hours and 15 hours and hours with Mr. Stokes, for example, doing just l 16 that. 17 I think I pointed out to the Commission 18 Monday -- yesterday and the previous Monday -- that we did I8 We'd like to, but we couldn't not do that in all cases. 20 do it in all cases. But we did do it in some. So the l assertion that no effort was made whatsoever is just false. COMMISSIONER GILINSKY: Well, let' see. I 24 think what the man from GAP was saying was not that no 25 effort had been made to talk to these people, but I think
~ Or3 271 { ') 1 he was saying that no contact had been made subsequent 2 to your resolution of the issues -- 3 MR. MARTIN: That's what I'm saying, that that's 4 not true in all cases. So it's just not a true statement. 5 Another assertion was made that no effort was a made to get ahold of Mr. Hudson. Well, that's not true. 7 On the slide I passed out to you yesterday, we had talked a to him for at least nine hours involving several people at g several different times. p3 So I think he had plenty of opportunity to bring 11 up his concerns which are'now in a fourth affidavit. 12 So to paint the picture that we made no effort 13 to talk to the man or plumb him for his concerns is just 14 not true. 15 And the other business about the factually 16 incorrect statement about the nondestructive examination 17 Personnel, I'm not sure how we are supposed to deal with 18 "thinkos" or " typos" or whatever in letters. We dealt with 19 what was written, not with what they may have intended, 20 and really that's all I have to say. 21 We did send the telegram to their~ address. Many 22 of us have trouble getting our mail. I think the reason --I 23 wasn't able to check with my lawyer -- but I think the 24 reason we did that is because we didn't know where he was. M So that's really all I have to say. I'd like to
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, 1 UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION 3 DISCUSSION /POSSIBLE VOTE OM DIAB',0 CANYON CRITICALITY AND LOW POWER OPERATION . 4 (Continued) J g Public Meeting s Nuclear Regulatory Commission 1717 H Street, Northwest 7 Room 1130 Washington, D. C. 8 - Tuesday, March 27, 1984 9 10 The Commission met in open session, pursuant to 11 adj ourn. gent, at 9:00 a. m., Nunzio J. Palladino, Chairman of u the Commission, presiding. 13 COM!!ISSIONERS PRESENT: 14 NUNZIO P'LLADINO, A Chairman of the Commis'sion VICTOR GILINSKY, Member of the Commission 15 JAMES ASSELSTINE, Member of the Commission THOMAS ROBERTS, Member of the Commission . 16 FREDERICK BERNTHAL, Member of the Commission 17 STAFF & PRESENTERS SEATED AT COM!!ISSION TABLE: 18 H. PLAINE W. MAGEE 19 , W. DIRCKS D. EISENHUT
'20 E. CASE J. KNIGHT 21 R. JACKSON H. THOMPSON 22 I. YIN J. CLD.TTT -
23
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AUDIENCE SPEAKERS: 24 J. MARTIN 25 ATTACHMENT 11
^
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I can address the order and see whether it is in shape enough 3 where we might possibly affirm it today. That would be'my 8 suggestion. - 4 COMMISSIONER BERNTHAL: I think that is a pretty 8 fast track in view of the fact that one or two Commissioners 8 yesterday expressed the desire to have some time to, I guess, 7 prepare statements or collect thoughts between the end of our 8 deliberations and the time that we vote. CHAIRMAN PALLADINO: We have had the additional time. I am guided by what you would like to do. I don't know II that it is necessarily a fast track. We have~had the draft 12 orders and I have son.o comments and I am sure everyone else 13 has some comments. COMMISSIONER BERNTHAL: I am trying to be realistic. 15
- Maybe we can do it this afternoon.
16 CHAIRMAN PALLADINO: Well, let's try it. If we get to a point where a significant revision is needed on the 18 order, if at least we have voted in principle, then we can 19 proceed to revise the order. 20 ' COMMISSIONER BERNTHAL: Are we not going to take 21 any time then in between end of deliberations and vote? 22 CHAIRMAN PALLADINO: I don't know when the delibera-tions end. I don',t even know when they start. 24 COMMISSIONER BERNTHAL: Whenever they end. 25 CHAIRMAN PALLADINO: I was going to come back and ,
263 I ask if we are prepared to vote on general principle. Then I. after that, we can either put in a period of time and then l 8 come back and see where we stand on the order and that period 4 of time might also be useful for cross-talk Commissioner-to-0 Commissioner on aspects of the order. 8 COMMISSIONER BERNTHAL: It wasn't clear to me 7 either that we had resolved -- we have heard the staff and' 8 Mr. Yin, but we hadn't resolved exactly how we are going to 8 deal with that concern, have we? 10 COMMISSIONER ASSELSTINE: That is a big question, II I think, in my mind. CHAIRMAN PALLADINO: It is my understanding that 18 the staff including Mr. Yin are going to continue to address I4 the analyses that need to be made, further analyses, and out 15 of that may or may not come hardware' changes and the proposal 16 to the staff is that low power operation not be held up, 17 that they could be done after low power operation. Isa said that he would prefer the other way around. I think that is I' an approach to the resolution that I understand. COMMISSIONER BERNTHAL: That is the proposal of the 21 staff, yes. CHAIRMAN PALLADINO: Why don't we at least get GAP up here and give them three minutes and then we_will see 24 where we are. . MR. CLEWETT: Hello. My name is John Clewett. I am
. . 264 I
1 an attorney working with the Government Accountability Project. 3 Thank you for letting me address you for a couple'of minutes. 3 In listening to the presentation of -the staff 4 - yesterday there were a large number of times when I restrained 8 myself from jumping up and saying, "No, that is not right." 8 - But there was one point in particular that I think is important 7 l to clarify to the Commission. 8 _That is on the , question of whether the staff has 9 made an effort *to get back in touch with the original 10 allegers to see whether the staff's resolution is adequate. 11 They have not made any effort whatsoever. 12 Just to clarify the efforts, the unsuccessful efforts 13 that GAP made to talk the Region V staff into meeting with the 14 original allegers again, I know that Tom Devine of GAP,and 15 Tom Bishop of Revion V also had some negotiations, but in 16 particular for my part, I called Louis Sho11enberger, ~ 17 the regional counsel for Region V, on March 8th to ask when 18 they were going to be meeting with the criginal allegers again 19 because I could tell on the 19th when the staff was going to 20 he recommending action to you all was coming up soon, and I 21 knew that they had made no effort to date to contact GAP 22 or to directly contact any of the original allegers, so I 23 - called Mr. Sho11enberger and asked him what plans Region V had 24 for meeting with these people. 25 He said, "Well, I don't know. I am not really sure
265
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I - that I know one way or another, but I will get back to you I soon." So four days later on the 12th when he had not called 3 me back, I called him again and reminded of the fact that the 4 staff takes credit for this policy of meeting with the 5 original allegers. At that point he again said that he didn't know what the plans were but that he would back to me in the near 8 future. So two days later on the 14th, I called him again because I had not heard from him. 10 At point he said, "Well, if you can bring two of II the people up tomorrow af ternoon to Malnut Creek," which is 12 " a four and a half hour drive from San Luis Obispo, ... we 13 will meet with them." I told him that both of these people 14 ~ worked, that that was a practical impossibility. He said, 15 "Well, you just ought to be flexible." I said, "Well, why 16 can't you come down to the San Luis Obispo area to talk with 17 these people again like you did when you talked with them at 18 first?" He categorically refused to do that. Region V would 19 not do that. 20 So I checked with these people just to make 21 sure that they were going to work tomorrow and didn't feel 22 like calling in sick at the last minute or somethine and they 23 said that it was not possible for them to meet., So I called 24 Mr. Shollenberger again to tell him that. . 25 Apparently he sent me a telegram saying that they
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Shut he G f ilu.ud 28 0 , l were eager to meet with people. I think it is really 3 interesting h'ow he handled that because he sent that telegram 3 knowing full well that I was in the San Luis Obispo area, he sent that telegram to my office in Washington I didn't even 8 see a copy of it until yesterday. 6 So it seems as though rather than living up to the 7 policy that they take credit for in SSER 21 and now in SSER 22 8 ; of trying to get back with the original allegers, in fact, 9 . it seems that the staff is trying to avoid the witnesses and 10 I think avoid some of these issues. 11 . I would urge the Commission before doing anything in 12 this case to at a minimum from the submission that we gave to 13 region V on Friday and that I understand was served on you 14 all yesterday morning, read the affidavit of Harold Hudson 16 because he was the internal auditer for a period of two and 16 a half years for Pullman Power Products. He knows more than 17 any other individual alive, I am sure, the nature of the NSC 18 audit of Pullman and what it means and the fact that those 19 violations of Appendix B have continued unabated or in some 20 cases even getting worse up to the present day. 21 The staff made no effort whatsoever to get a hold 22 of him and his affidavit is very interesting in that regard 23 because he explains the initiative that he took to discuss the 24 ; quality assurance breakdown at Pullman and the fact that the 25 staff at that point was apparently preparing report 83-37 that
,267 4 3 I . didn't mention to him at all that this was underway. They I
didn't ask him any questions about that nor did they get back a to him on any of the issues that he brought up that were very
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,similar to this.
5 I think it is amazing that six weeks after the staff s me t with Harold Hudson that they issued this report, 83-37, 7 which pretends that none of this happened. 8 I wanted to clarify that point particularly because 9 it seems that the staff is trying to avoid the witnesses and to avoid the issues. I think you can see that throughout the 11 staff's response. I don' t have time and I won' t try to take 12 your time to go into any great detail, but one single example 13 of that is in our letter which we dated the 23rd, one of the it seccific points that refers to a material false statement by 15 PG&E has to do with qualifications of quality control 16 personnel. 17 Now because of the haste with which this was put 18 together, this letter refers to these as nondestructive 19 examination personnel. In fact, as you can see by going back , 20 to the actual materials and in particular, the a,ffidavit of 21 Stephen Lockert, the question is not the NDE personnel but 22 _ it is the quality control inspectors. PG&E said in its n - letter, DCL-84-082, that Pullman Power Products _can qualified 24 all of its QC inspectors, that they were all certified to 25 ANSI N45.2.6. fhisrebutsthat in considerable detail.
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1 The staff which said that they had read all of these 2 materials reviewed the letter and focused on the fact that 3 it erroneously said NDE personnel and said they don't have to 1 4 meet ANSI N45.2.6. So as far as we are concerned this issue 5 is closed.. Well, the issue is not closed because regardless, 8 of the fact that there was a typo or a "thinko" perhaps in 7 writing this up, the issue still remains. 8 I think the Commission should be very careful that its staff is not misleading the Commission and I think that I0 the staff is misleading you folks and I hope that you don't 11 buy it. - 12 I thank you again for letting me make a brief 13 presentation to you. 14 CHAIRMAN PALLADINO: The Commission may want to 15 follow-up after lunch. Thank you very much. We are going 16 to break now until 1:45 and then reconvene. (Whereupon, the Commission meeting recessed at 18 12:35 o' clock p.m., to raconvene at 1:45 o' clock p.m., the 19 same day.)
'20 21 22 23 24 25
e fs. ', '- T429-0" } 2C 4 To: Hon. Victor Gilinsky, Commissioner . United States Nuclear Regulatory Commission 1717 H Street Washington, D.C. 20555 From: Harold Hudson - Former Pullman Power Products Quality Assurance Inspector, Quality Control Inspector, Qualitg7 Assurance Program Internal Auditor and Lead Auditor. Date: 11-14-83 ~
Subject:
Deviations Codes From Pullman dP=Mf Power Products' Weld Procedure Ga lectric's Contract Specificati
#8711 #B833XR Qu ty osurance and Welding Require mentsi At The Diablo Can, on helear Plant Project, Units
#1 andNf2. #
* ' N _. , _
This report identifies major breakdowns in the PG&E Contract l i Specifications #8711 and #8833XR Quality Assurance Programs for the welding of Pipe Supports and Pipe Rupture Restraints by Pullma: Power Products at the Diablo Canyon Nuclear Plant Project, Units il and #2. There have been deviations from the PG&2 approved Weld Pror'ec.- ure Specifications. Velding has been performed using *.1 eld Proced-ure Specifications that were not qualified for, and did not provide welding specifications for , the base metals, structural stael shapes, and joint configurations used. These deviations have spc ni the whole construction program for Pipe Supports and Pipe Ruptu e Restraints and includes the current Design Modification constructic program for Pipe Supports. The Weld Procedure Codes referenced in i this report have been approved by PG&E but it is alleged that therc l 1s no documented authorization from PG&E allowing Pull:an to deviat from the approved Veld Procedure Specifications. Weld Procedure Specifications have been prepared and Qsed by Pullman, and approved by PG&E that were not properly qualified per the A.'.f.S. Code as required by C.S. #S833XR.
'Jelding has been perfor=ed which did not comply with the Weld Procedure Codes and processes specified on Process Sheets and approved by the proper authorities. Pullman QA/QC Hanagecent has attempted to justify / cover up this breach of Quality Assurance by implying that Production had the authority to disregard the Procer Sheet instructions. '
There have been deviations from PG&E's C.S. #8711 and #8833XR l ' welding require =ents for which there are no PG&E Contract Specifi-cation Change notices and/or proper Management au,thorization. Quality Assurance / Quality Control discrepanctes are as follows
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J. g ATTACHMENT 12
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to o pradetsnninsd and preapproved procedure !
- and process as specified on Process Sheets (the controlline document for field weldine)7, '
C. ISR#4713 waere states under all qualified Condition for SMAW 1 andof2 stainless welding that welders 8/ st; eel. It is alleged that at least one welder's qual-: iScation status cannot be assured for the time , peeriod involved (October and November 1972). l Azn attachment to DR#4713 list a Welder, stencil N, hart # 26,as making 10 of the field walds involved 12s DR#4713. These welds were made on 10-25-72, 1G-26 and 31-72 and 11-1-72 The attachment indicates tinat Welder N's qualification date for Code 15/16 (SMAW) was 12-17-71.
;gbe 1977 Nuclear Services Corporation Internal Audit of Pullman Power Prodnets states in Criterion IL10 t):.at "the Ninetv Day Welder's Los was not maintained 4
from August 1972 to December 1972" and that "there is no Weekly QumMfied Welders List for that time period to substantiate that welders were actually qualified". ' Pc11 mans offical respons'e to PG&E concernina the NSC q ,Wludit. datedi~s it "there 4-11-78. a void states in the 90 under day criterion weld los IX.lO'o from y August .1972 to December.1972. By reviewing we.La-
\' ing records has been rec,onstructed.a qualification status for this period All welders were- found to be within the 90 day requalification period.
Records are available for review". . A Pullman unsigned, undated, rought draft response states under Criterion II.10b that a "90 Day Welders' j I,og will be maintained from August 1972 to December 1972 We are investigating this particular area and attempting to make an update of the log by checking weld rod requisitions during the missing period. A log will be reconstructed from this information".. A Pullman Interoffice Correspondence, dated 10-13-77, to E.F. Gerwin from W. Mitchell/J.P. Runyan, concern-ing N.S.C. Audit Comments states under Section II.4.E that "further investigation in process - Log can be ; up period". dated by checking rod requisitions during void Welder #N, per DR#4713, was originally qualified for Code 15/16 on 12-17-71. Welder #N made the DR#4713 welds in October and November of 1972-which was dur-ing the time period when the "Ninety Day Welders' Leg" was not maintained and there was no " Weekly
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3U l i b Qualificd Woldcro Lictm. Tha cbccnco of th2 "Rinety i Day Welders' Img" means that Walder #N cannot be assured to be qualified for the SMAW process by l virtue of documented evidence of use of the SMAW process within a 90 day period. Pullman's procedure required a welder to requalify for a welding process in the event he hadn't worked with a process during a 90 day period. There are no original records to determined that Welder #N was qualified or had re- 3 qualified for the SMAW process (Code 15/16) during ) the August to December 1972 period. ! Pullman has stated that by reviewing welding records (rod requisitions) a qualification status for this period had been reconstructed. But DR#4713 identified that welding records (both process sheets .and rod i requisitions) are not accurate because of " incorrect reference Sheet andto Weld Rod Procedure S7ecification in Process . Requisition". N11 man's reconstructed l qualification status is based on documents that cannot be assured of having correct information. l' et I Therefore the DR#4713 statement that welders were all qualified for SMAW welding of stainless steel is questionable. Any qualification records for , Welder #N for the October - November 1972 period
' would be based on the reconstructed qualification status which inturn is based on welding records now known not to be correct. Welder #N cannot be assured as stated onto bave been qualified for SMAW DR#4713. 2 (
D. Contract Specification #8711 Section 4 Contractors Quality Assurance Requirements), paragra(ph 2.2 i states Quality Assurance comprises all those planned and systematic activities necessary to establish confidence that material (component or system) will perform satisfactory in service. Paragraph 2.3'
,h1 states Quality Control comprises those quality i assurance actions which provide a means to control dl the quality of the material to predetermined require-ments. The Containment #1 Spray Ring Pipe Attach-ment welding as identified in DR#4713 and this report do not fall under Quality Assurance " planned and systematic activities" establishing confidence that material will perform satisfactory or under Quality Control actions providing a "means to control the quality of the material to predetermined requirements.'
C.S. #8711 Section 4.3.23 states Contractor shall assure that special processes such as yelding are br controlled in accordance with applicable codes,
standards, specifications, etc., and that special processes are accomplished by qualified personnel.
t m
n The Containment #1 Spray Ring Pipe Attachment weld-ing was not controlled in giccordance with the approved Process Sheet Wald Procedure Specification and at
*1 east one welder's qualification status is in questy ion. 1 C.S. #8711 Section 4.3.24 states Contractor shall assure that material and work furnished under this Specification conform to the applicable specifications, drawings, codes, and other requirements necessary to provide the quality desired. Containment #1 Spray Ring Pipe Attachment welding does not conform to the approved Process Sheet Weld Procedure Specificatics. (U C.S. #8711 Section 4.3.28 states Contractor proced=res shall assure that all conditions adverse to quality, such as deficiencies, tieviations, nonconformances, etc., are promptly identified, reported and corrected.
[ 3
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e DR#4713, as written, misrepresents / cover,s up the more significant breakdown in the QA/QC Program of not ( welding to predetermined and preapproved procedures
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( and processes. DRf4713 states that the Process
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Sheets' predetermined (specified) and preapproved welding procedure was wrong and that Production's unauthorized and unapproved welding procedure was cor-rect. . This is Bull Shit generated by Pullman to keep 1972 welding (all areas) from become suspect. DRp.L713 has not identified all conditions adverse to quality.p C.S. #8711 Section 4.3.29 states Contractor shall prepare, use,.and maintain a records procedure l adequate to document and assure quality of material and work. Records collected shall include workmanship reports and procedures. The Containment #1 Spray Ring Pipe Attachment Process Sheets and Weld Rod : Requisitions (workmanship reports and procedures), l prepared, used, and maintained by M.W. Kellogg (Pu .1 map) do not assure the quality of material and work. Q The 1972 welding of Pipe Attachments to the Contair-ment #1 Dome Spray Ring Piping System does not comply with C.S. #8711 Section 4 Quality Assurance requirements welding, and cannot be assured of being qualityk, E. The 1977 Nuclear Services Corporation Internal Audit ho iman Power Products concludes under cr1Terla [IA T,na D there is_no confidence that weldinst done _ niorTo early 1974_was _rerformed in .accordance with _ weldine suecification Jeouirements"_ h Juelear
) Services Corporation Audit S"-wr found that "Pricr k to early 1974. there in littla_eyidence_available to -
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s s verify the adequacy _of _the work -Derformed. -The avail-
/ able evidence indicates -that--only-e- rudimentaryp=1ity
~ Ebntiel trograu existed and that control over the
_ production organization was niinimalv, l l l
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_Thma dinnrnpannies identified in DRd4713 and *Mm
' _ remport verify the Nuclear Services corneraH en een-cid.usions. There was no control over the Ps oduction or:rganization during the installation of P11e Attach- ,
meants to the containment #1 Spray Ring Pipi;2g System ansd there is no assurance that welding was Jerformed inn accordance with weldi.ng specification re luirements. Whnat is of paramount importance is the possibilty of' other welding (Piping, Pipe Attachments, Pipe
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Su:pports and Pipe Rupture Restraints) having the samme or similar discrepancies as identified in DR# 47213a' nd this report or other conditions adverse to qumality. The Nuclear Regulatory Commission should cczncern itself with reviewing all pre 1974 welding tea assure that conditions adverse to quality do l nc:rt axist. - ttae Nuclear Regulatroy Commission should address ' wbether Pullman Power Products and PG&E/Bechtel have mi.srepresented the discrepancies identified in DE.#4713 in an attempt to cover up a significant b: eakdown in the implementation of C.S. #8711 Quality Asssurance requirements during the 1972 constru.ction pe riod. This repen has identified areas where Qualit welding require:.ents have not been implemented and/y or deviated 1ssurance from and/or there are unresolved questions. The purpose of this report is to identify to the Nuclear Regulatory Commission these areas of questicnable Quality Assurance / Quality Control. The NRC should review these findings and allegations to determine their validity a:nd/or the seriousness of the discrepancies and/or; the adequacy of corrective action and investigate the unresolved questions raised. There have been and there continues to be serious breaches in the PG&E and Pullman Power Products Quality Assurance Program at the Diablo Canyon Nuclear Plant. A thnrough review of this Quality Assurance Program should be performed to provide the citizens of San Luis Obispo County and the State of California l the assurance that construction is of the highest quality. ko^ok U N Baro.Ld Hudson
. 805-528-5970 Phone
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'.' " AFFIDAVIT go 44,1T. Dme 3
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r pqr name is NPmld Arisan. I am submitting this affidavit f
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and voluntarily J without any thmats inducements, or coercion, to Mr.Ypmas D who hh identified himself to me as the Legal Director of the Govern ab11Tiy Project of the Institute for Policy Studies. I am subraitting this state-ment to evidence sy concern over a comprehensive quality assurance (QA) brea for the work of Pullman Power Products at the Diablo Csnpn Nuclear Power . There is no possible justification for allowing this nuclear power plant to critical until the iluclear Regulatory Coenissien (NRC) confirms the full sc QA breakdown; identifies the causes; and monitors completion of a corrective action program, including a full reinspection of safety-related work at the p In many instances, the reinspe: tion may be the first legitimate quality control coverage the hardware has had. I base this. conclusion on my four and a half years experience at Diablo Canyon in Pullman's quality assurance / quality control (QC) program, inclu two and a half years, through 1982, during which I was the Internal Auditor. The ba:ic lesson I learned is that the conclusions of a Nuclear Service Corporation audit o'f Pullman an more true today than when first published in 1977--the program does not raeet the requirements of 10C.F.R. 50, Appendix B; and it does . not have an operative corrective action system. The latter has been demonstrated by the further deterioration in cornettve action from 1g7g-1g83. While before. the system was merely failing to identify and solve problems, now it is actively covering them up.
~ This has been especially true with respect to weljing, non-destructive: examination procedures (NDE), and hydrostatic tests--allhf which I 1 earned. E_.
- were consistently uncontrolled, and that some of the procednes-for the first two items were not qualified by a testing process which proves the procedure ai:tually work as claimed.
. ATTACHMENT 13
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The system also broke down for vendor quality assurance, where Pacific Gas and l Electric (PG&E) management ordered Pullman inspectors to stop reporting cracked welds found in structural steel restraints supplied by vendors such as Boston Bergen and American Bridge. As an auditor trying to work within the Pullman site and corporate QA system
! learned the cause of the QA breakdown and why it has not been corrected.
Pullman QA Management does not want to know about QA/QC violations. Management's corrective action has been to harass, threaten, and intimidate QA/QC personnel who ider.tify problens, and to dismiss those who persist. Although I exhaustively reported deficiencies, the aujor effect of my disclosures was to prompt orders from the QA manager to only look where I was told, and his angry threats to "get rid of me"During one such exchange,he exclaimed Pullman's bottan line: we're not committed to building this plant to 10 C.F.R. 50, Appendix B. In that case I do not see any legal basis for the NRC to allow this plant to operate. I am not opposed to nuclear power. Rather, I believe in the technology enough to insist that it receive the proper respect. I began working in the ' nuclear power industry in 1974 at the Trojan Plant and have worked at the Humboldt Bay Plant.'!ith the exception of two months in 1979, I worked at Diablo Canyon for Pullman from September,1978 until Friday the 13th,1984, when I wa's' f laid off. The layoff occurred the day after I finished a two-month series of disclosures to the NRC. For my first three to four months on site, I was a documents reviewer. For nineteen months I worked as a weld inspector in the pipe rupture restraint program. t In August, 1983, I was promoted to QA Internal Auditor. O O
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My responsibility was to evaluate and monitor the entire QA/QC program for l compliance with our legal obligations. This is how I learned that Pullman does not consider 10 C.F.R. 50 a legal obligation for work at Diablo Canyon. In January,1983, I was removed as internal auditor, but remained in the QA program to help close out Discrepancy Reports (DR) and Deficient Condition ' Notices (DC.1), as well as to complete my pending audits. QA Manager, Harold Karner, restricted me to carrying out his specific assignments. The harass-ment was so intense that in mid-May. I resigned. Through my union, the next day I return to Diablo Canyon as a pipefitter. There simply had been too many headaches attempting to work within the corporate system. On my own time, at ' home, I finished organizing and sumarizing my evidence of QA violations. , In November, I completed an initial report. On November 28, I sent it to NRC i temissioner, Victor Gilinsky. On December 6,1D*3, his office wrote that I would be contacted by the Office of Investigations (01). Although 0! never called, on January 6, 9, and 12. I was interviewed extensively by a series of - NRC inspectors from Region V. On January 13, I was laid off. This statement will summarize the information and list the allegaticos in three written reports already disclosed to the NRC. My affidavit also is to submit a written record for allegations which I have only described to the NRC in interviews and identify allegations not yet described to the NRC. I. QUALITY ASSURANCE'DREAKDOWN FOR WELDING With a few exceptions, from the onset of construction, the welding program for structural steel essentially has been uncontrolled--in violation of legal requirements, as well as contract and design specifications- The techni:ues t: circumvent quality assurance included unqualified weicers; _ , , _ , . _ . . _ . . .-----v.--- ----.---.s. - - - - - - - - " - - - ' - - ' " - - ' ' ~ ~ ~ ~ - - " ^ ~ ~
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- 31 repeated occasions, I identified sah/ of the issues in this affidavit to a variety of officials within the PG&E supervisory and management staff.
1though some officials iistened and expressed agreement and/or sympathy, none of the violations were corrected. I believe that PG8E and Pullman have been gambling that the NRC will not enforce the QA laws, even if' - they are caught. For the sake of the public's health and safety. I hope that the NRC calls their bluff. I have read the above 31 page affidavit, and it is true. accurate and complete to the best of my knowledge and belief.
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Harold Hudson SUBSCRIBED AND SWORN this ! ' day of January,1984, in
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( ) NUREG-0675 Supplement No. 22 l l Safety Evaluation Report related to the operation of Diablo Canyon Nuclear Power Plant, Units 1 and 2 Docket Nos. 50-275 and 50-323 Pacific Gas and Electric Company U.S. Nuclear Regulatory
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Commission Office of Nuclear Reactor Regulation
. March 1984 s5 -
s.....e W M; k-Sp 7 g, ATTACMBT 14
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. . . . I Site Inspections Many of the allegations required onsite inspections to verify con-struction practices, records, procedures and personnel qualification.
These were handled by teams of staff personnel with appropriate con-sultants. In some cases additional, independent measurements and evaluations were performed where appropriate. Technical Reviews Consideration of allegations in technical areas previously reviewed by the staff included detailed evaluations using licensing documents, regulations, standards, additional information provided by the licensee, and independent analyses as necessary. In some cases additional audits were performed at the site or in'the offices of the licensee and its contractors as necessary. Interviews: Interviews with site personnel (crafts, quality assurance personnel, engineers and management) were carried out as required to resolve the issues. , Public Meetings: I Where significant technical meetings were held, verbatim transcripts
. were generally taken to maintain an appropriate record.
Feedback from Allegers: When practical, the staff attempted to discuss with the alleger the j approach and findings of the staff's evaluation related to their allegation. The purpose was to assure that the staff properly
, understood the concern and to demonstrate how the staff dealt with the concerns. .
Allegation Management Instruction: Region V's instruction on allegation management was used as guidance for this process. The draft instruction (entitled Management of Allegations") was provided as Attachment 4 to SSER No. 21. The staff examined in detail almost all of the first 180 allegations.1 The purpose in doing this was to gain an overall perspective of not only the technical aspects of the problems raised but also to use the specific allegation as a vehicle for assessing whether the licensee and its major contractors acted responsibly over the years. Considerable insight was developed on the licensee's and contractor's management control and quality control activities. . l 1 The allegations were not add ossed in the same sequence as presented in Attachment ". ' Diablo Canyon SSER 22 E-3 i , ,
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, Task: Allegation or Concern No. 68 ATS No. None BN No.
Characterization:
, Nuclear Services Corporation (NSC) conducted an audit of Pullman Power Products, the prime piping contractor at Diablo Canyon, in 1977. The audit findings implied a breakdown in the programmatic aspects of Pullman's QA '
, program.
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Implied Significance to Plant Design, Construction or Operation The implication of the audit findings is that the Pullman QA program was not effectively implemented prior to 1977. Action Required No further action required on this allegation refer to SSER 21 and NRC inspection report 50-275/83-37 dated February 29, 1984. I A.4-68.1
. . .I Task: AllegationorConcernNos.h03,104,105,106,107,108,109,110, Ill, 112, 113, 114, 115, 116, 117, 118, 119, 214, 215, 216, and 217 s
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ATS No: RV-83-A-0074 BN No: 84-009 (1/16/84) Characterization Multiple allegations associated with a failure of the licensee and Pullman Power Products to meet required codes and standards for welding pipe supports and pipe whip restraints. Implied Significance to Design, Construction or Operat,lo_n The failure to meet stated codes and standards in the fabrication of pipe supports and pipe whip restraints may result in components which would not perform their intended safety function. Assessment of Safety Significance Th.e allegations or concerns discussed in this section were received in the form of a 35 page letter from the alleger to a NRC Commissioner. Attached to the letter were numerous documents provided to support the allegers concerns. The staff's general approach to address these concerns was to interview the alleger, exanine the contractors and licensee's written requirements, examine pertinent procedures, documentation, and to conduct interviews with personnel, as appropriate. A.4-103.1
r The alleger's written submittal and interview included multiple cross referencing of issues. The staff did not examine every example of each type of issue individually, but instead focused on the substantive technical and l quality concerns by grouped topics. Many of the issues were topics which had t been formally documented and addressed by the licensees and contractor's control programs. The staff directed special attention to where the licensee ' ar.d contractors addressed these items in a responsible manner. The staff has placed the issues into 21 topics. These are discussed individually below, i
- 1. Allegations 103, 104 and 105:
Pullman Welding Procedure Specification (WPS) 7/8 was inappropriat'ely applied in that deviations from WPS 7/8 existed in the following areas: (a) structural shapes, (b) weld joint geometry, (c) materials Staff Position (a) The alleger is correct that WPS 7/8 was used to weld structural shapes in addition to piping and plate as specified in the WPS., y However, the structural shape of the member is not required to be . )' included in the WPS. All structural shapes, such as W, ,H beams and angle iron, shall have the connecting sections prepared to conform to the weld joint configuration of the, qualified WPS The structural shapes are identified on the design drawings. A.4-103.2
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The alleger is correct in stating that the WPS documents do not (b) WP5 7/8 is adequately illustrate all joint types which are welded. qualified in accordance with ASME Section IX requirements which indicates in QW 402.1 that a change in joint type is a non-essential variable. Lack of description of all types of joints utilized is contrary to Section IX rules and requires a revision to the WPS. However, this is an administrative change only and does not require requalification of the WPS. In response to the allegation regarding unapproved welded materials, (c) the staff reviewed each type of material identified by the alleger. Certain of these materials such as A500 and A307 were not listed the published code but were approved for use by a separate code case. The staff is satisfied that all the materials of concern in this allegation were properly approved for ASME or AWS usage.
- 2. Allegations 106, 107 and 108; The alleger stated that Welding Technique Specification No. AWS 1-1 was' .
not applied to AWS welding in that, (a) AWS 1-1 was not referenced on every Pipe Rupture Restraint Welding Process Sheet, (b) AWS 1-1 was l d (c) AWS 1-1
,ritten w and approved by an unqualified individua , an specified an unlisted AWS code material.
l Staff Position
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f A.4-103.3
R (a) The alleger is correct that in some cases QC failed to clearly identify on the weld process sheets when welding was to be conducted to the WPS plus the Welding Technique Sheets. However, the use of Welding Technique Sheets to amplify and clarify WPS documents is an accepted standard industry practice. At Diablo Canyon the significant clarification made by the Welding Technique Sheet is the introduction of tighter controls on preheat. Whether this information was directly tied to the WPS through the technique sheet is of little consequence since the same information is clearly stated in other relevant documents (EDS 223 and EDS 243). As the preheat is covered in all cases, the inclusion of the exact document, whether it is the WPS or Welding Technique Sheet identification, is considered to have no engineering or quality related significance. l (b) The alleger expressed concern that a Welding Technique Sheet was prepared by an unqualified individual. In so doing Pullman utilized ! a QA/QC person to perform a function out of his area of expertise [ and permitted this individual to audit his own work. The staff found that there are no codes and standards requirements that state that a WPS or Welding Technique Sheet must be prepared by a specific individual. The only requirement is that the document adequately address the codes and standards variable rules i.e., essential and non essential variables. The WPS documents and Weld'ag Technique Sheets met the rules (with the exception of the QW 402.1 non-essential variable as previously discussed) and were roperly approved by the licensee. QA/QC personnel normally monitor A.4-103.4
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implementation of programs and procedures, the fact that they may have assisted in writing the implementing procedures does not support the conclusion th.at QA/QC is auditing its own work. (c) The~ alleger is correct that ASTM A515 steel is not listed in AWS DI.1 as an approved welding material. The staff found that A515 is not listed in AWS 01.1 Structural Welding Code because A515 is normally considered as a pressure vessel material. However, A515 was properly qualified and is acceptable material for welding structures in compliance with AWS D1.1 rules.
- 3. Allegations 109 and 110:
The alleger states that structural steel pipe supports were not designed, fabricated and erected to the American Welding Society (AWS) code. He further states that the PG&E Contract Specification 8711 requires pipe supports to comply with the applicable standards of the ASTM, ANSI, ASME, MSS, AWS, and PFI. Additionally, he states there was no change to the PG&E contract specification to allow pipe support to be worked to a standard other the AWS. Staff Position The staff found that the pipe support work was properly do'e to the ASME code which is permitted by the AWS code. Supporting details of the staff's findings are as follows: , 1 A.4-103.5
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- The American Welding Society D1.1 permits the ENGINEER to " accept evidence of previous qualification." It is normal practice to f interpret this as permitting ASME Section IX welding qualification in lieu of D1.1 qualification by testing. In addition, the 8711 Specification Section 3 (para 4.11 and 4.12) require performance and 1
procedure qualification in accordance with Section IX. Based on staff reviews, the welding qualification methods utilized by Pullman meet ASME Section IX requirements.
- The materials for pipe support welding were: A36, A500, SA515, _
SA516, and bolting materials A307, and A108 (grades 1010-1020). The staff found that each of these materials is suitable and allowable for ASME pipe support welding. The staff reviewed Pullman procedure qualification documentation for engineering justification for welding in accordance with current ASME Section IX and AWS D1.1 rules (through utilization of the ENGINEER'S prerogatives in paragraph 5.2). This review included the procedure qualifications for "as welded" fabrications and the following types of I welding: ASME P1 to P1 material using shielded metal arc welding (SMAW); AWS Group I to Group I, using SMAW; AWS Group II to Group I and II, using SMAW; Welding of SA500, A441, A588, using SMAW; welding ASME P1 to AWS Group I using gas tungsten are welding (GTAW), ASME P8 to P8 using SMAW; ASME P8 to P8 using GTAW; tack welding, using SMAW or GTAW. Various thickness ranges were included. m f A.4-103.6
l All WPS documents were properly qualified for AWS welding, all structural steel fabrication met AWS requirements. Therefore, no contract specification change was required or needed.
- 4. Allegation 111 and 112:
Contract Specification No. 8833XR was not officially changed / revised to reflect that procedure qualification in accordance with ASME Section IX may be used in lieu of AWS 01.0-1969. Staff Position: The staff found that no contract specification change was required because the AWS Code allows qualification of "other processes" and
" evidence of previous qualification" of joint procedure qualification.
In this case, Pullman Power Products provided evidence of qualification to ASME Section IX, which is allowed by the AWS Code. Therefore, no contract specification change or revision was needed since no deviation from the contract specification had taken place.
- 5. Allegation 113:
Contract Specification No. 8833XR requires welders to be qualified to the AWS Code, instead Pullman utilized welders qualified to ASME Section IX to perform the scope of work required by the contract. W A.4-103.7
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- i. ) i Staff Position .
The staff found that ASME Section IX qualified welders are qualified to AWS rales if the AWS thickness criteria is properly addressed. The staff found that the AWS thickness criteria was properly addressed and therefore, the Pullman welders were qualified in accordance with Contract Specification No. 8833XR requirements. i The licensee's and contractors practice of using ASME/AWS qualified welders is reasonable and acceptable in this case.
- 6. Allegation 114: .
Pullman utilized welding procedures which have not been tested for notch toughness in the weld Heat Affected Zone (HAZ) for weldments made under Contract Specification 8833XR (pipe restraints). Contract Specification 8833XR requires in Section 3.6 such qualification. The Pullman practices in this area represent a deviation from the contract specification. Staff Position }
. The alleger is correct in that Contract Specification 3833XR does require HAZ notch toughness verification. However, this requirement was clarified with a contract revision which indicated that notch toughness is required (only) if specified on the drawing.
A.4-103.8
N ~ Licensee correspondence and staff reviews indicate that HAZ notch toughness is not required, and therefore, the design of the rupture restraints does not require welding qualification documents demonstrating HAZ notch toughness. The licensee position that notch toughness verification is nst required is documented in a licensee to NRC memo dated Janauary 18, 1984. Notch toughness in the weld HAZ is not a code or NRC requirement for rupture restraints. Therefore, the al19ger is correct that the Pullman practices in this area appear to represent a deviation from the contract specification, however, the staff found that because of the licensee correspondence referenced l above no deviation from Contract Specification 8833X had occurred.
- 7. Allegation 115:
No Contract Specification Change Notice was issued authorizing the deletion of full penetration welds less than 9/16 inch effective throat from the ultrasonic exami ation program for the repair of pipe rupture restraints. l Staff Position The staff's examination of licensee documents and discussions with engineering and quality assurance individuals revealed that the licensee'sEngineeringDepartmentdidnotformallyreviseofprocessa design change allowing a deviation from Contract Specification 8833XR, paragraph 7.21. This item is not considered a safety problem because all A.4-103.9
{ s t the technical requirements and procedures for ultrasonic examination were reviewed and approved by the licensee. However, it does represent an unauthorized change'which is not in strict compliance with Engineering Department Procedure No. 3.6 " Design Changes." This failure to formally change the contract specification appears to be an oversight on the part of the licensee, since all appropriate reviews were conducted, and approvals obtained. Therefore, the alleger is correct that no contract specification change was initiated, however, based on the above no safety significance is attributed to this administrative oversight.
- 8. Allegations 116 and 117:
Pullman weld procedure code No. 88/89 was used to weld plate when the procedure was qualified for pipe welding under ASME Section IX. The Pullman weld procedure was never qualified in accordance with the AWS Code as required by Contract Specification No. 8833XR. Staff Position The staff found that no contract specification change was required because the AWS code allows qualification of "other processes" and
" evidence of previous qualification" of joint procedure qualification.
In this case, Pullman Power Products provided evidence of qualification ofWPS88/89toASMESectionIX,whichispermittedbytheAh5 Code. The AWS Code states that qualification or. pipe shall also qualify for plate. A.4-103.10
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. t Therefore, no contract specification change or revision was needed because no deviation from contract specification had taken place.
- 9. Allegations 118 and 119:
Pullman Power Products uses a Welding Technique Sheet (AWS 3-1) to allow Gas Tungsten Arc Welding (GTAW) and a material (A515 steel). Neither of which are not allowed by the AWS Code. Staff position This allegation is addressed as two parts as follows:
- a. Gas Tungsten Arc Welding is not allowed by the AWS Code (Allegation 118)
The alleger is correct that the gas tungsten arc welding (GTAW) process is not specifically covered in the body of AWS D1.1. . However, AWS D1.1 (paragraphs 1.3.4 and 5.2) permits qualification of "other processes" and " evidence of previous qualificiation" of joint procedure qualification. Pullman Power Products has demonstrated proper ASME qualification of this process and is, therefore, considered satisfactory for welding supports and restraints. A.4-103.11
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. l The GTAW welding process was qualified in accordance with AWS DI.1 provisions; therefore, there is no safety or quality management significance attributed to this allegation. !
- b. Grade ASIS Steel is a Material not Listed as Approved in the .
I AWS Code (Allegation 119) The alleger is correct that ASTM A515 steel is not listed in AWS D1.1 as an approved welding material. A515 steel is not listed in AWS 01.1 because the steel is normally considered as a pressure vessel material. However, A515 was properly qualified and is acceptable for welding structures in compliance with AWS DI.1 rules. I
- 10. Allegations 214, 215, 216, and 217: l The use of Code 92/93 to weld pipe rupture restraints when the process sheets specified Code 7/8 and Pullman's justification for this change is a major breach in the welding Quality Assurance Program.
Introduction The alleger refers to a September 15, 1978 memorandum to file from the Assistant QA/QC Manager. This memorandum states, in part, "Both weld codes 7/8 and 92/93 are qualified to allow welding of unlimite; thickness on structural members under AWS requirements. Technical aspects of both procedures are the same." A.4-103.12 __ m
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Assessment of Safety Significance The staff examined the referenced memorandum and supporting documentation. Based on this review, it is clear that the alleger has four issues in question. The following is a characterization of these four issues along with the staff's conclusions:
- a. Allegation 214:
The alleger's concern was that Welding Procedure Code 7/8 and 92/93 were not identical. He lists a number of welding parameters which - are different between the two weld procedures. The staff found that the alleger is correct the procedures are not identical, though from a technical standpoint they are both acceptable for the work required (the rupture restraint work). This allegation appears to be an apparent misunderstanding on the alleger's part on the interchangeab'iity of the welding procedures.
- b. Allegation 215:
. This concern is whether or not Code 92/93 is qualified to allow welding on unlimited thickness structural members under AWS requirements. Based on staff examination of AWS D.1-1 and Pullman's use of Code 92/93, the staff concludes that Code 92/93 has been properly qualified. .
A.4-103.13 s.
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- c. Allegation 216:
This issue is that Code 92/93 is not a suitable substitute for Code 7/8. As mentioned in item 1 above, even though, the two documents are not technically identical, they are both technically adequate for the work that was performed. Therefore, there is no safety significance associated with this issue.
- d. Allegation 217:
Based on the alleger's concerns that the above three issues were safety significant, the alleger concluded that Pullman's QA/QC management attempted "to cover up a serious breach in the Quality Assurance program for welding Pipe Rupture Restraints...." However, because of the existence of the Assistant QA Manager's memorandum and the alleger's misinterpretations discussed above, the staff cannot see any objective basis for the conclusion that a " cover up" was attempted or existed. To the contrary the Pullman memorandum, makes it a formal document available for all to see and review. Staff Position The allegation is not substantiated. It may have been generated, in part, because of a misinterpretation of the September 15, 1978, Interoffice Memorandum. . A.4-103.14
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Action Required None, 11 Further Allegations l l A further staff examination of the alleger's submittal disclosed the following information: This allegation relates to the installation of the Unit I containment spray ring piping in 1972. A review of the records associated with this activity resulted in the identification of discrepancies between the weld process sheets and weld rod requisit. ton documents. These discrepancies were documented on Pullman Discrepancy Report (DR) No. 4713, dated April 14, 1983. The alleger contends that the Discrepancy Report misrepresents the discrepancies in order to cover up more significant Quality Assurance / Quality Control problems. More specifically the alleger states that:
- a. DR No. 4713 did not identify the fact that the Production Department disregarded the process sheet and the specified weld procedure and lE substituted their own unauthorized and unapproved weld procedure l (Code 15/16).
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( b. The DR does not address the failure to detect the discrepancies at ~ I the time they occurred. g e j A.4-103.15 1
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I c, The DR states that all welders were qualified, when, in the alleger's opinion one welder's (Welder "N") qualification status cannot be assured for the time period involved (since the Ninety Day Welder's Activity Log was not maintained from August 1972 to December 1972). Staff Position t To address these issues the staff reviewed the DR, the contractor's j response to the DR, examined evidence of weld procedure approval and
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interchangability, examination of welder activity logs, process sheets
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rod requisition documents, and other records. The allegers concerns are l addressed below: I
- a. Use of unapproved and unauthorized weld procedure Code (Code 15/16).
A staff examination of the weld procedure in question (Code 15/16) disclosed that it had been properly qualified and approved. . Therefore, the alleger's statement that unapproved procedures were used is incorrect. The statement is correct that the record discrepancies make it somewhat unclear as to which specific procedures were used. The staff, therefore, requested the licensee to perform a technical review of weld procedure interchangability. The conclusion of the review was that, for the weldments in question, any of the welding procedures listed could have been used to achieve acceptable welds. The staff concludes that there is no A.4-103.16
m k ) technical significance to the record discrepancies in this case. The general implications of record errors follows in item b.
- b. Failure to detect the discrepancies at the time they occu.rred indicates a significant breakdown.
The alleger contends that since the personnel involved in the work at the time (crafts, QC/QA, supervisors) failed to detect the discrepancies and that this is indicative of a significant breakdown. The staff examined the situation to determine whether the record discrepancies were widespread (significant) or somewhat isolated. To assess the magnitude of the record discrepancy problem,-300 weld process sheets were reviewed. 100 for the Containment Spray System, 100 for Chemical and Volume Control System and 100 for Component Cooling Water system. These process sheets are for welds (piping to piping, attachments to piping, and pipe supports) completed between April 1972 and October 1975. There are 531 weld rod requisitions associated with these process sheets. The staff examined results of these reviews. The results showed that 20 weld rod requisitions records (15 Containment Spray, 5 Component Cooling Water) have a WPS listed on them that is not in agreement with the process sheet. This equates to 3.7 percent. Based on the results of the review it does not appear that record discrepancies were a widespread problem. O
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A.4-103.17
.- I . l
- c. Welder "N" qualification status.
The alleger contends that the Ninety Day Welder's Log was not maintained current during August 1972 to December 1972 and therefore, Welder "N"s qualifications are in question. The staff notes that neither the AWS or ASME Codes require maintenance of a welder's activity log. The codes simply require that welder activity be maintained. The method of providing evidence of welding activity is not stated, and no explicit method is required to meet codes and standards rules. Based on NRC inspection there is evidence (e.g., filler metal issue slips, welding process sheets, etc) that welder N met the above codes and standards requirements. In his written submittal the alleger further alleges that process sheet and rod requisition records cannot be relied upon to reconstruct evidence of welder activity. His basis is a discrepancy report identifying inconsistencies between process sheet and rod i requisition records related to 1972 work involving the containment spray ring. An examination of the records, however, does not - disclose widespread inaccuracies in the records (as discussed previously). Based on the above it appears that Pullman's and the licensee's approach to resolving the question of welder "N"'s
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activity is an acceptable approach. Based on the results of the foregoing, the stan Luncludes that the individual discrepancies are not technically significant, that the
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discrepancies were not widespread, and that procedures and welders A.4-103.18
r
. . . i. }
were appropriately qualified. It does not appear that Discrepancy Report No. 4713 misrepresents the scope of the problem. It appears that licensee and contractor management handled the problem in a acceptable manner. Overall Staff Position The staff's review of the above allegations disclosed that there were minor, isolated weaknesses in implementation of the contractor's and licensee's program. Ho<ever, these discrepancies were not widespread and were primarily administrative in nature. The welding processes, welding procedures, welded materials, welders and nondestructive examinations were found to be in accordance with the required codes and standards. In general, it appears that the licensee and his contractor managed their activities in a reasonable manner. Action Required None. W A.4-103.19
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_ , , . paw 22 II iJF:.*.'T n o g /}w,a :7 e 12 W-06 '1_ u m, u, m .- + .m My name is Harold Hudson. I am submitting tnis affidavit freely and voluntarily, without any threats, inducements or coercion to Hr. Tnomas Devine, who has identified himself to me as the legal director f of the Govern:. ant Accountasility Project. This statement supplements my
%A (CMLAt./ 1984 affidavit, because I an deeply concerned about two major problems at Diablo Canyon that the liuclear Regulatory Comission
(.lRC) staff overlooked in its recent recocunendation to pennit low-power operations: 1) Large' portions of the plant were not built or inspected to 10 CFR 50, Appendix B, the HRC's legal quality assurance (QA) regulations. 2) The ;1RC based its recommendation for low power operations on false statements in Pullman's file or in February 1983 Pacific Gas and Electric (PG5E) letters to the NRC. This abuse was especially prevalent for Pullman's responses to the 1977 Nuclear Services Corporation (145C) audit findings of a severe quality assurance break-down. I know, because as Pullman's . internal auditor for 2.5 years until late 1982, I became intimately familiar with the quality-related documentation. s I am deeply' disappointed that the NRC did not discuss with me the contents of report 83-37, the staff evaluation of the 1977 HSC audit.
, The eventual report represents an attempt to rewrite history. I do not
_kn.ow if the' ;IRC was duped or is part of a coverup. ButIcouldAave easily set them straight. l I tried to take the initiative. by submittina three repor~ts to the Me# 3 22 f3 - l _ .lRC between November 1983 .d 2.. ;., L43 and January 1984. Further, i _during January 1984 I met with the NRC on three occasions to disclose i l j, W E2. ?34'A " ""'"' l
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- t. 411 :,. 4:.s r.nte ([.*) viola:te. . Tr,e s t yteia:ier, u ,: .:.:
issue: in tne I350 audit. but were not identical to 1.P.e st tvet; tr ac e .*e: by tne staff for Report 83-37. I did not even kno. tne staf f ws working on Report 83-37. I did, no ever, inform the staf f tnat as Pallran's internal auditor I had tnoroughly researched the iSC audit. J I also told the staff that iiSC was right. I also told tne staff that ' I nad tried to implement corrective action. I also told the staff that management refused to permit necessary corrective action. Finally, : explained to the staff hgw management harassed and retaliated against g me so much that in in 1983 I resigned y job and returned to Diablo Canyon as a pipefitter. In case there is any question about what I told the ilRC, I have tapes of the meetings. Under the circumstances 1 cannot conceive of any good faith explana-Mion that the llRC failed to discuss the NSC (or Pulliran) audit with me or tell me that they were working on the issue. There is no excuse for _ , the gross inaccuracies in the liRC's findings. It is as if my knowledge were threatening, or might get in the way of something they had already decided. _1 also want to emphasize that the ilRC staff never had any followup meetinos with me to clarify the issues I raised, or to test whether PG&E's defenses were bluffs. That is odd, since I disclosed over 80 Sl%1E He{ pages of my can etMe spaced reports and affidavits to sumarize over s n op 11 o 4 a thousand pages of documentation. I only learned of PG&E's answers, g , because GAP xeroxed them and gave me copies. The .*1RC staff complimented highly the analysis in my reports, b'ut they never got back to me. I
, ( 3 }
,'.' g4 SiD ' IM c 's c i t ie.: A allegatior.s t tne F.~. cat of the 170 ir. a Ja :ua , 31 legal petition. Any statement that the hRC staff.followed up with r4 personally after I first raised my charges would be totally false. I have no idea what tne NRC staff did to resolve my allegations, other inan to nave PG&E respond to some in letters.
s.~ .+ - After I received PG&E's letters from GAP I studied my files and 4 saw that some of the responses represented false statements. After GAP provided me with a copy of Report 83-37. I saw that it relied on false statements and missed the most significant issues. If the NRC had chosen to speak with me, I would have discussed in detail the issues and evidence introduced for the record below. If the NRC ever convinces me tnat it will look seriously at the general issues below, then I will write up specific allegations with detailed analysis.
- 1) I am particularly concerned that until at least 1982 Pullman's ,
I program for pipe supports and pipe rupture restraints did not comply with /' g 10 CFR 50, Appendix B. I cannot understand why the NRC would not have A covered this issue in Rehort 83.37, since that is what' the NRC is all , j
' about. Presumably there should be some effect if the 3RC's recommenda -lji tio'ns are not part of the picture. In a previous affidavit I recalled y how on several occasions Mr. Karner told me that we didn't have to
~
comply with 10 CFR 50, Appendix B. Mr. Karner was thoroughly familiar with company policy. The official I excuse was that Pullman's program complied with Section Three of the Anerican Society of i'echanical Engineers (AS;1E) 1971 code req'uirements, which are consistent with 10 CFR 50, Appendix B. (SeeJune 13, 1978
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- a.;;i t, r ~lched as Ex' it i t 1, i.; p 2. ) Tu problem is tnat 19e A3 2 c. ode
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did not cover pipe supports and r.:?ture restraints. T.At left us on our own. Unile PG&E paid general lip service to Appendix B, it d!!d not , enforce that policy on us through contract requirements. A'1 October 13, 1977 Pullman memo on the .iSC audit (Exhibit 2 at p. 2) explained, "We PGtE have not been required by M L.en to update to Appendix B." An unsigned, undated draft report on the idSC audit (Exhibit 3) explained further:
. . V .. ,. ~ m . - - _..- . , .. "lio attempt, however, was made to totally
~
revise the program to incorporate specifics of 10 CFR 50, Appendix B." (Id , at p. 4.) On page 9 of the draft, the author implies flRC approval for failing "to update the program to match Appendix B...." (Id at p 9.)
- 2) After conceding the problem of not meeting 10 CFR 50, Appendix B, Pullman chose to perpetuate it. A fiovember 3,1978 program description (Exhibit 4) did not make any references to 10 CFR 50 in the charts and
= ',- PifE Soffod.T5 ft ub g ttachments a forg pipe rupture restraints. The ESD's, or installation . '
1f ' procedures, are the only guide for the QA program. (Id . Chart #3 and Attachment 3-1.) ( 3) Actua the problem was worse. In effect there was no formal f - - -
,., g.\S$ Pn S U F968.TS 6 ND QA program forgpipe rupt;re restraints. The problem first was identified in a ilovember 1973 audit (Exhibit 5) which conceded that the QA ltanual
\\@ skipped iniC SuffoSJTS AND ,
g pipe restraints. Instead there was only ESD-223, the installation "p , procedurewhichtheauditorcalled"inesse'nce,an'alternabQAprogram' b
}\% REODEM7 A1ECHANIW. E Nci& rte PIRECT*8 01-approved by thegc;n:to tica =mpr, instead of thegQA r_:pr as ,
required. Qd ._)., l i
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- 4) Altrup Pullr.an identified r.any ceficiencies of IS3 2:3 ir.
1973, tne co .pany did not learn its lesson. Tne NSC audit repeated sir.ilar findings in 1977. % 2 "S Th%C #r.,_ Mr N t
-f
- 5) A January 10, 1977 memo from Pullman QA manager J. Ranyan explained another major point: The pre-December 1973 pipe supports we
{M ' installed " prior to implementing the inspection program" (Exhibit 6)
- 6) A November 13, 1978 memorandum from Pullman's Senior QA Engineer R. J. Manning (Exhibit 7) conceded that "in the past" Pallman "did not conduct audits or practices to ASME or 10 CFR 50, but I feel .,
it very essential to do so now." As demonstrated by my own personal experience, the author's advice was ignored. From my own reviews, I know that the early audits which existed were well-intentioned, but crude, uncontrolled and infomal. They were too sloppy to constitute c - a minimal program. For example, a 1973 audit referenced conclusions ,
~
g_ about pipe rupture restraints to the contrac.t for pipe supports, which didn't apply to the work in question. (Exhibits, Supra.)
- 7) Until at least November 1978, some parts of the QA pbogram had never been audited. As revealed by Mr. Manning, "The Diablo Canyon program has been audited extensively only in hardware areas. The entire program has not been evaluated." (Exhibit 7)
-{.
- 8) In Report 83-37 the NRC accepted uncritcally PG&E andfullman's S
position that Nondestructive Examination (NDE) personnel have met,the f,LfP American National Standards Institute (ANS rements_ sinpe g \ cn m N@ A Eff"
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( ) 2 22eh 6 1973 or 1974. Tnat is false. :t:nage ent has recog .ized a pro.le-sirice 1973, but as of July 1982, they had not upgraded tne progra- to l
, l comply with A:iSI id45.2.6. In the meantime, various r.anage reco r, ended cormitm2nts to nonor A.iSI, but it simply did not nappen. -F,'r e a Decemoer 1974 example of the recom endations, see enclosed Exhibit 8.
Tne Pullman QA manager's July 1982 refusal to honor A:lSI ti45.2.6, is enclosed as Exnibit 9. Don't forget again, even ASME compliance Toes mot @W M would not cover the entire QA program, si .c e+-A pipe supports 3
~ . and rupture restraints. 'N 9) The reason Pullman didn't meet the A'iSI requirements is that it ..as not willing to pay for the experienced personnel required underI toe professional code. As Pullman's QA nanager explained in a i*ay 13, 1975 remo (Exhibit 10), "[I]t is virtually impossible to comply totally to :(45.2.6 because of experience require ,ents. We connot hire personnel E -
that meet the experience rqquirements for the salary scale.we offer."
- 10) _In its Report 83-37 the ilRC agreed with Pullman and 'PG&E that.
l the personnel files demonstrate adequate records for welder and I4DE l certification. As a result, the staff decided that .iSC was ..rong. l l That is false. A September 15 1977 memo (signed September 22), from goA Di(Edo*L of su^um, y AssutAw c Pullman's p p:r:.t.c vice e.ceinnt to the site QA uanager, (Exhibit 11),
"Ge: uric dDE and Inspection Records", including - " lack of evidence i
sno..ing the necessary records" to support the certificatioy; lack . of any certifications; certifications dated "as much as a year" after
~
tne inspectors began work; and " lack of evidence supporting previous l ..ork e.varience and Level I and Level II qualifications at a previous e"plojer", anang many other deficiencies. The corporate conclusions of
- ( , LWA a 8
39 3 generic deficiencies were based on a review cf 95 files. Tne :,2C 10:4 td at the sa.ne files and found nothing wrong. Wnat happened?; t.
- 11) I decided to thoroughly researcn one of tne 95 heTicien files.
I chose Pullman's iiDE supervisor Don Geske, who certainly sneald nave had adequate qualification records. Reviewing Mr. Geske's file revealed the magnitude of the inaccuracy. His records say he passed tne tnree iiagnetic Particle exams with flying colors -- a score of 93%. But records on the three specific exams record the following results for the supervisor: "
, ,[and] ." There are no grades recorded for his performance on individual tests. The records are attached as Exhibit 12.
- 12) On September 25, 1980 an internal Pullman audit (Exhibit 13) admitted that two HDE technicians were certified for advanced (Level II") responsibilities, despite " letters in their personnel files l.~ stating tney are not qualified to perform Level 11 functions...."
Pullman's " solution" was for Mr. Geske to backdate letters to July 24 - 1980 (Exhibit 14) that said the opposite -- that the two men were qualified. I do not believe that rer.riting history is any way to solve quality problems.
- 13) Qd I also challenge the accuracy of QAgager Harold Karner's UDE qualifications records. In 1979 when' he was originalli, certified AT bt%to f
itr. Karner's certification did not cover :4DE. (Exhibit 15) But on g v'I 7 7I July 27,1981, when Mr. Karner was racertified after the re' quired two ' ' r' years, he was certified as Level II for s'agnetic Particle Testing ( 'P) Wh-Radiograpny (RT); and Liquid Penetrant Testing (LPT), as well as M
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417.bi L i tis.., ud. i.evel I for Ultrasonic Testing (UT))s Frca my o.:n experience as tne internal auditor with tir. Karner during that general time frame, I know he could not possibly have obtained the 600 hours of required practical experience even for 14T -- let alone the other two dtsciplines.
- 14) In 1976 Pullman reported that fir. Geske allayed concerns about 1200 suspect weld attachments by reinspecting 314 with magnetic IM f6pR particle tests in +ee days. (The attachments had been in question due CSSKE CAMKb M:W M wEtts *EMi to noncompliance with preheat requirements.) EMA TM:te
_ 95 WeseceW MDTat Rtmasume,wB35 ovE4.TRE IVGVf"two Myf . N04 gW They all passed. Unfortunately, the mar.imum possibl: number of magnetic particle exams that an inspector can perform in a day is around 50. The 1976 inspection findings are enclosed as Exhibit 17. - g eat Tote RESW'5'T8 go4
- 15) The signatures on gweld process sheets -- which insure the vork was not done in an a_d_ hoc manner -- were phoney. A blank sheet was
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signed and then xeroxed. This is evident fenm a review of multiple r % h II p. weld process sheets signatures are too perfectly identi,cf. c . I also confirmed this practice with. engineers from the early y rs q , i __ Af Exampics are enclosed as Exhibit 18, [ - { r 6 ,x
- 16) In Report 83-37 the :1RC nade the following ' finding o.n page 18:
l "The inspector examined the 90 day welder's log and found that no void i existed between 8/72 and 12/72." This was the basis for fiRC findings. f I don't know who is responsible, but that statement is false. J,a 11$ SEsf8W56 70 7AE WC- A vDIT , April 1978 intrrnel Pullman n:r=.da (Exhibit 19, at 'p. 25.f f[, , concluded the opposite: "There is a void in the 90 day weld 1 g rom August,1972 to December,1972." Any excuse based on a purported 7 reconstruction of the log cannot wash. The ::RC should know, because [ my :Jovecer 1983 report to Comissioner Gilinsky should have been
o ;
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reviewed by tne .JRC staff months before Report 83-37 was issued at tne
- r.V r d Ltw r W 1em u *F wef dtC M LT end of February 1984. C%.WT. La M 1 challenged the reconstructi (tdt-4 as not being reliable, due to inconsistencies and omissions that .
rendered impossible any confidence in the results.
^
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- 17) During the early years of construction QA/QC personnel
) l intenningled responsibilities with production personnel. Because of this phenomenon, the quality of early audits was sacrificed beyond repair.
For example, part of the reason for the informal, unprofessional
=.
nature of 1971 and 1972 audits (Exhibits 20,21) is that they were per-formed by individuals identifie'd in the signature log (Exhibit 22) as the snop and field engineers. It appears that the shop engineer even . audited tne shop. Due to their unreliable nature these audits could ' not reasonably substitute for required audits, such as for the welding M Prog Mo rRER EX ArnfLC of I kTCA 8hl P'iLO RE9a,WIWG
.q L tn g gge,g g , g .7, g s g.g g A t go gy. mp i n W hg gg wgf FIE0 ENGINEEC (IP N I6tT 12. M - NO N-E -
- 18) The practice of intermingling QA/ production duties continued into 1976, as a QC weld inspector named Art Mullis inspected the same -
drawings he had prepared as a field engineer, (assi i ning field weld / p numbers and weld symbols). (Exhibit 23) h th. ?' !
, 19) Contrary to Pullman's assertions, in response to the NSC 7
audit, the quality of QA/QC suffered due to these conflicts-of-intere t. To illustrate, Mr. iiullis accepted his own practice of having one ,b AQE r 140lP process sheet for five weld joints. Q:p3}is was Q also the' s roxed(,- N' '
/ signature for numberous blank weld process sheets (Exhibit 18, supra.)
7g' Q -
- 20) i'.anagement's refusal to back me against harassment from production made it more difficult to do my job properly. To illustrate,
( ) on A.rgust 13, 1982 I attempted to report harassment -- such as, rifling
- my desk and taking an audit notebook. Mr. Karner refused to let the memo be sent, and threw it out. I kept a copy, which is enclosed as Exhibit 24.
- t
- 21) The PG&E response to my report on minimum valve wall thick-nesses is so incomplete and internally contradictory that it could be the basis for numberous allegations. I will list a few of the high-lights here. PG1E asserted that procedure qualifications tests were not necessary because the inspectors calibrated their tools. But that is a totally uncontrolled response, and one which the inspector should take anyaay. Additionally, my January 1984 affidavit to the NRC and -
my January 1984 report on minimum valve wall thicknesses also demonstrated the unreliability of calibration data for the equipment. In many instances, there was no calibration data. Obviously, this was no sub-stitute for procedures whose reliability is proven by tests -- the E - nomal QA foundation -- especially for valves with key safety functions. a _._ I wonder if the NRC has considered this issue in connection with PG&E's r request to waive previous licesning comitments in the FSAR.
- 22) PG&E's response on the inability of valve thickness test equipment to catch specific eccentricities were accounted for through a CRT screen. Unfortunately, the test procedure doesn't use a CRT screen. Instead, it uses pulse ecao digital readout equipment.
-I
- 23) PG&E's responses to welding allegations suffers from a gross omission. It fails to demonstrate that the procedures used to
r ( ; l verify tne quality of the welds were the same as those specified by l Code 7f8 to install the welds in the first place. From the sketchy information provided by PG&E, I know there are significant differences. t
- 24) PG&E's February 17, 1984 letter to the tiRC takes cre'it d for having prepared the final approved drawings (original and revisions),
without exception. That is false. A September 18, 1973 fut.LmW 55 f_ audit dc4 6L, revealed, "PG&E is not approving the design of any 2" and under Hangers." , (Exhibit 25) I have read 'the above 11 page affidavit, and it is true, accurate and complete to the best of my knowledge and belief. - Mo W
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SYl,Gyl 1 I UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION 2
E DISCUSSION /POSSIBLE VOTE ON DIABLO CANYON CRITICALITY AND LOW POWER OPERATION 4 8 Public Meeting Nuclear Regulatory Commission
, 1717 H Street, N.W.
Room 1130
, Washington, D.C.
, Monday, March 26, 1984 ,
10 The Commission met, pursuant to notice, at 2:05 p.m. COMMISSIONERS PRESENT: SUNCIO PALLADINO, Chairman of the Commission 14 VICTOR GILINSKY, Member JAMES ASSELSTINE, Member - THOMAS ROBERTS, Member
, FREDERICK BERNTHAL, Member g STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
18 S. CHILK W. DIRCKS H. DENTON 30 J. KNIGHT 21 .
- 3. JACKSON J. MARTIN g T. BISHOP
!.~. DEVINE .
y I. YIN , 24 AUDIENC SPEAKERS: 25 L. CHANDLER ATTACHMENT 16
. )
6 11b5
, *1 in SECY 84-101 and SECY 84-104. And then, when we 2 get to it, repeating additional recommendations.
3 That's how we would like to proceed, if that is 4 satisfactory to you. 5 CHAIRMAN PALLADINO: Any objections? 8 (No response.) 7 Bill, why don't we proceed? 8 MR. MARTIN: On the allegations, I would like to 9 use, as a point of departure, just a very brief review of to what we talked about last Monday and then discuss the 11 allegations that we did not cover last Monday and discuss . 12 some new ones that we received last Friday. 13 To review briefly, as of last .v.onday, we had 14 cons'idered the first 219 allegations, which included all that 15 we had received except for two petitions. One was received 16 on February 2nd and the other one, a supolement to it, on 17
!! arch 1st. .
18 The conclusion we drew on the first 219 was 19 based on a very thorough review of the #irst 170 or so, with 20 particular er."hasis on two noints. 21 First is the technical problem. And secondly, is it reflective of any manacement 22 or quality problems. _After we did the first 170 or so, and 23 thought we had a oretty good handle on the manaq ment 24 situation, as well as a pretty good feel on the first 170 or 25 180 specific items, t we got somewhat more discretionary on the
i ) t 7
, 11b6 - l 1
remaining 130 or so. S And we discussed that last week. 8 So as we ended, we thought we had dealt properly with the first 219 items. 4 But we had not gone through the next 300 or so items, 6 that were contained in the two petitions received on February 2nd and March 1st. 6 We are prepared to speak to those today. 7 We spent the last week 8 or ten days going through those and comparina them to the , 8 screening criteria that we talked abnat last week, and th ey are included in SSER-22. 10 11 In addition, we received another batch of allecatio ns at close of business on Friday. I am not 12 sure how many are in there. 13 We haven't -- they were not numbered very well and it - you know, 14 they didn't have all of the enclosures _ delivered to us. 15 B.ut we have read the entire package and there is some numoer, on the order of 150 or 200 o 16 r something like that. 17 . 18 We have read the entire package and we think we 18 can give you an informed opinion of now they stack against the screening criteria. i I would like Tom to do that now, 21 and then I have a couple of comments , 22 to make on the submittal that we received last Friday, that I 23 think the Commission should have the Staff perspective on, 24 on the submittal. - MR. BISHOP: 26 _This document came to Reaion V offices , shortly before closing time on Friday. ?! We did snent Friday !
l
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)
8 '1 11b7
~1 evening and Saturday and an unfortunate Sunday reviewing the 8
new document, the contents of which I can get to in a 8 . minute. 4 That was one of the two additional packets we 8 looked at since we have last met. The other two packages 8 were the 2.206 submittal, dated rebruary 2nd and the sunclemen t 7 to that submittal, dated March lat. 8 Let me take those first. Cnd tl 8 10 11 12 13 14 15 16 17 18 19 2o l 21 22 24 l 25 l 1
i I 14 .b6 *1 Problem. 3 So the bottom line is, of the 318 we have looked b 3 at, about 3/4ths of them, and the remaining 1/4th we have 4 reviewed for significance in reference to a criticality 5 decision. And it is the Staff'.s recommendation that there e is nothing there which warrants an immediate holdup to the 7 process. 8 CHAIRMAN PALLADINO: Can I ask, does this 318 e include the 219 that -- 10 MR. BISHOP: No. Many of them are the same. 11 CHAIRMAN PALLADINO: So these are over and above 12 the 219 that you looked at in depth? 13 MR. BISHOP: That's correct. Many of the documenta 14 provided in the petition are the same documents that we 15 received earlier through other processes. So that's why, 16 there's such a large number, which are the same enclosed. 17 MR. MARTIN: Mr. Chairman, there is some overlap. 18 Some of these 318 are identical to the 219. In fact, about 19 half of them or so, Items number 1 and 2, for example. 20 CHAIRMAN PALLADINO: Yes. Aside from the overlap, 21 I was trying to get a feel for whether or not 219 was in 22 the 318.
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23 MR. MARTIN: No, they are not. 24 MR. BISHOP: In addition to this, I mentioned 25 a new set of material, which the Staff received, Region V
'. ( )
15
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2pb7 1 Staff received Friday night at closing time. I believe it 3 was docketed here in Washington Monday morning. You have the a cover letter associated with that. It's about three inches 4 worth of supporting material. . 8 We have only had two-and-a-half days to look into e that. But we have spent that time going through reading 7 that document and reading all the supporting material. And a we do note, again, some similarity with previous issues 9 here and there. Others -- other issues are identifying what to they contend are inaccuracies in submittals made to the Staff 11 by the utility. 12 The forwarding letter is very direct and specific, 13 calling these falsifications and such. When you go back to 14 the supporting document, the affidavits, it appears that the 15 individual provides examples and then concludes, based on his 16 differing opinion of the situation that the submittal made 17 by the utility is false or inaccurate or misleading. 18 We did not have the time to do an exhaustive 19 analysis of that. But one thing we do note is that we made 30 much less reliance on the utility's sube.ittals than the 21 document tends to imply. Now most of the utility's submittals 22 came very late in the game. Whereas our efforts to exanine 23 andinvestigatetheseallegationsstartedmanfmonthsago, 24 and continued for many months. 2 Would you like to add anything specific in
- L_ __ __ __ _
i
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16 byb8 1 reference to the letter?' 3 MR. MARTIN: No, I don't think so. Other than 3 our assessment in reading through it. Since it was so 4 diffuse, we didn't number the items. But in' reading through 5 it, I think we came up with about the same proportion; o roughly 3/4ths of the items in there we have seem before, 7 dealt with one way or another. And there was about 1/4th a c f it or so that were new items. But not the sorts of things e that look like they needed to be dealt with right now. 10 That's our impression. And I think that's about 11 as much as we can tell you on the statistics of the th'ing. 12 That's what we've done since we talked last week. And -- 13 is to go through and categorize and screen these things. 14 And we have concluded that none of the new ones appear to 15 be the sort of thing that needs to be done prior to a ~ 16 decision. . 17 We either have enough background on it or it 18 isn't relevant. Or even if true, would not pose a significant 1d 2. 19 problem. 20 21 i I 23 l i i 24 i ! 25
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CONFIDENTIAL MEETINGS WITH ALLEGERS ALLEGER DATE RRS TYPE INTERVIEVER 1 1/6/84 abt 3 Followp (Initial) RV
" Followp 1/9/84 "
3 RF 1/12/84 4 Followp .. RV -
#4/84(Onsite)" 2 Closecut/Follt.wp RV
*4/84(Shell Beach) " 1 Closecut/Followp RV 4/7/84 OI/RV OI/RV 4/11/84 01 01/RV i
" Closecut 5/2/85 2 RV 5/2/84 OI 01/RV l 1/5/84 2 Initial RV
" Followp RV 1/12/84 "
2 t 1/13/84 3 Followp RV 7/31/84 01 8/1/84 01 10/31/84 01
" Closecut RV 1/10/85 2
" RV 1/5/84 2 Initial 4/11/84 Tour Followp RV 4/6/84 Followp OI/RV 4/9/84 Followp OI/RV 5/1/84 OI i 1/8/85 " 2 Closecut RV
" RV Team /0I abt 12/6/83 6 Initial ,
l 12/83(at site) Closecut on U-Eracket (Reynolds) - l
*" 2/84 " 2 Followp RV Conf.Ra.
3/84 " 3 Follon y RV (Bishop's office)
*4/84(Shell Beach) " 2 Closecut (Bishop) 4/3/84 01 4/26/84 OI
! 4/27/84 01 4/30/84 OI l 10/11/84 01 10/19/84 _ OL l 3 ATTACHMENT 17 [ - - _ _ . .
i t
)
ALLECER DATE BRS TYPE INTERVIEWER
*abt 1/10/84 2 Initial RV
*" 1/11 or . .
12/84 2 Followup RV 4/10/84 ; c1 4/11/84..(Tour) ' Tour - 4/6/84 Initial 01/RV 4/7/84 Fo11ovup cI/RV
*abt 4/84 (Shell Beach) Closeout RV 4/10/84 Follovup OI/RV 7/31/84 OI 10/18/84 or 1/8/85 Closecut RV
#9/84 (Hendonca) Initial RV 10/84 01 1/10/85 Fo11ovup RV 10/15/84 02 10/16/84 oI 10/18/84 oi 1/9/85 Follovup RV 10/15/84 01
*abt 1/10/85 Follovup RV
*12/83 to 1/84 (Several) Initial & Followup RV (Crews)
*12/83 (Several telecons with H. Meyers & Bishop) ,
*Crowley & Shackleton Initial Initial NRR 4/9/84 Initial 01/RV 4/11/84 Followup OI/RV 4/30/84 01 l
' 4/9/84 Initial 01/RV 4/11/84 Follovup 01/RV 4/30/84 , 01 4/11/84 (Tour) Tour RV 10/10/84 ,_ 01 4/11/84 f OT 5/3/84 i OI
, 1------. _
y
s e e 4
,_ 4 84 4/12/s4 og S/2/84 , .
og 4/20/s4 , c1 4/30/s4 oi 10/11/s4 01 10/12/84 o! 10/30/84 of 10/20/s4 c1 10/31/s4 c1 10/31/84 c1 20/30/s4 OI 20/19/84 ol
*No tape recordings or documentation of this meeting exists.
The meeting specifies were based upon the memory of the individual involved. l 1 . i f I 6
U.S. NUCLEAR CEGULATORY COMMisS404 Office Gf inspector and Auditor
.. ir Sootember 23. 1985 i Report of Interview Samuel D. Reynolds, Lead Reactor Engineer, Region I, NRC, was telephonically interviewed concerning the. circumstances surrounding his close-out interview of alleger at Diablo Canyon nuclear power plant l ! Reynolds recalled that ir.. participated in a tour of the Diablo Canyon plank to identify to the NRC inspectors the areas he had I cer.cerns with. Among other issues,. pointed out some U-brackets that were used to support tubing. ReynoTus noted that the U-brackets were very small and fragile and it was possible to change their configuration by ::and.
In fact, it was difficult to install the U-brackets without bending them. Reynolds explained this to and told him that although he was . technically correct in his Toncern, there was no significance to the issue. agreed and the issue was dropped.
- Reynolds comented that, with the possible exception of the above incident, he conducted no close-out interviews with allegers at Diablo Canyon. Reynolds stated he was sufficiently confident in his resolution of allegations to
- discuss the issues with the allegers and answer quest' ions. However, at that time, Region V was not conducting close-out interviews.
4 i 1
.,,,,,, ,,,,, ,,, S e p t enbe r 23, 1985 ,, Bethesda, MD ,,,,, 85-16
,, Ce t. Mulley,Jr.. Investigator OIA o.,, ,,,,,,,, S e p t emb e r 23, 1985 m::en'::i :=: =n,==; ,:.=:. ;; ::.=:n'=,; "c ~ c'"~c '
M u' i ATTACHMENT 18 ! I
6 ( ) SYl,Cyl 1 1 UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION S
3 DISCUSSION /POSSIBLE VOTE ON DIABLO CANYON CRITICALITY AND LOW POWER OPERATION 4 - 8 Public Meeting 4 Nuclear Regulatory Commission 7 1717 H Street, N.W. Room 1130
, Washington, D.C.
, Monday, March 26, 1984 10 The Commission met, pursuant to notice, at
- 2:05 p.m.
COM:iISSIONERS PRESENT: 14 NUN'IO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Member JAMES ASSELSTINE, Member
- THOMAS ROBERTS, Member
, FREDERICK BERNTHAL, Member 1
g STAFF AND PRESENTERS SEATED AT COMt1ISSION TABLE: g H. PLAINE S. CHILK W. DIRCKS H. DENTON , 30 D. EISENHUT J. KNIGHT 21
.. JAC ON J. MARTIN 22 T. BISHOP J.~. DEVINE .
g I. YIN , 24 AUDIENCC SPEAKERS: 3 L. CHANDLER ATTACHMENT 19
)
6 1
*1 in SECY 84-101 and SECY 84-104. And then, when we 3 get to it, repeating additional recommendations.
3 That's how we would like to proceed, if that is 1 4 satisfactory to you. 8 CHAIRMAN PALLADINO: Any objections? 8 (No response.) 7 Bill, why don't we proceed? 8 MR. MARTIN: On the alleoations, I would like to 9 use, as a point of departure, just a very brief review of to what we talked about last Monday and then discuss the 11 . allegations that we did not cover last Monday and discuss 12 some new ones that we received last Friday. 13 To review briefly, as of last Monday, we had 14 considered the first 219 allegations, which included all that 15 we had received except for two petitions. One was received 16 on February 2nd and the other one, a supolement to it, o n, 17
!! arch 1st.
18 The conclusion we drew on the first 219 was 19 based on a very thorough review of the #irst 170 or so, with 20 particular emahasis on two noints. ! 21 First is the technical problem. And secondly, is it reflective of any manacement 22 or quality problems. \ After we did the first 170 or so, and ( 23 ~ thought we had a oretty good handle on the management 24 situation, as well as a pretty good feel on the first 170 or 25 ' l 180 specific items, we got somewhat more discretionary on the l S4 h
- - - , --m-- , s , - . - - - - - - _ , _ , - _ _ , , - _ _ _ , - . - - - - - -, _ _ , - . - - - - - . - - - - - - ,
( ) 7 51b6 - 1 remaining 130 or so. S And we discussed that last week. 8 So as we ended, we thought we had dealt properly with the first 219 items. But we had not gone through 4 the next 300 or so items, that were contained in the two 8 petitions received on February 2nd and March 1st. We are 8 prepared to speak to those today. We spent the last week 7 or ten days going through those and comparino them to the 8 8 screening criteria that we talked about last week, and they are included in SSER-22. 10 11 In addition, we received another batch of allecation s at close of business on Friday. 12 I am not sure how many are in there. We haven't -- 13 they were not numbered very well and it - you know, they didn't have all of the enclosures 14 delivered to us. But we have read the entire package ano 15 there is some numcer, on the order of 150 or 200 or somethi ne is like that. 17 . We have read the entire package and we think we i 18 can give you an informed opinion of now they stack against 19 the screening criteria. 30 1 I would like Tom to do that now, and then I have 21 , a couple of comments 22 to make on the submittal that we received i ! last Friday, that I 23 think the Commission should have the I Staff perspective on, on the submittal. . l 24 MR. BISHOP: 3 This document came to Recion V offices shortly before closing time on Friday. We did snent Friday
1 I 8 g 11b7
*1 evening and Saturday and an unfortunate Sunday reviewing the 8
new document, the contents of which I can get to in a , 3 minute. 4 That was one of the two additional packets we 8 looked at since we have last met. The other two packages 8 were the 2.206 submittal, dated February 2nd and the sunclemen t 7 to that submittal, dated March lat. 8 Let me take those first, cnd tl 8 to 11 . 12 13 14 la 16 i . 17 18 19 I 21 i [ 24 25 r, .-. . - - - .
---.,,----------.p..-- - , _ . - - - . . . - - - - - , - . . - . . . , , - - , . , , ,
---,-----,-.--...=r- -
--_ - , , , , ,n. - - - - - ,-
. )
9
- 2pbl 1 Those two packages contained, by our count, a a total of 318 allegations.
The Staff, both on the west coast 8 and on the east coast, took those documents, went through 4 them item by item and evaluating whether or not it was 8 identical to, or very similar to allegations that we had 6 already dealt with. Whether it was, perhaps a slightly 7 different twist to an issue that we had already dealt a with, or whether in fact, it was totally new. 9 The breakdown of those 318 is provided on a 10 slide which was handed out. Item i being those which we 11 have previously addressed in a closed , be 98. Of the 318, 12 those which we previously addressed but are still open, 13 involve 56 of the new items. And those which we have -- 14 number 3, which we say involve a new wrinkle on an old issue. 15 Just to give you an example of what we're talhing , 18 about. We had an issue before us on the use of a welder 17 technique sheet in lieu of a welding procedure. Well, the 18 new wrinkle in this case was that an individual claims that 19 an inspector brought up this issue as being wrong to his 20 management. And the manage- did not deal with that issue. 21 Now we had already looked at the technical 22 aspects of that particular situation and concluded that 23 the use of the technique sheet was a proper thing to do. So 24 it had no technical significance in terms of being a problem. 25 But we have this new twist on it. That an
........-~......
g 10 2pb2 1 individual brought it up to his management and didn't get 3 back with him and explain the situation. 8 Another example might be the misuse of a particula r 4 welding procedure, 7-8. We had looked into the application 6 of that welding procedure for the other instances. Its use s was identified and found that it was an appropriate procedure 7 to use, and addressed that in our SSER. 8 The new twist is that that same procedure was e used on other types of welding. And so, it needs to be 10 addressed, once we get the specifics, which were not - 11 provided in this document. . Where else it was used and 12 whether that was significant, too. 13 But we see that the procedure itself is a proper 14 procedure to use for structural welding. And the fact that 15 it's used in other structural welding would most likely not 16 be determinative of the problem. Those are the types of 17 things that we have identified as new wrinkles on old 18 issues. 19 l If you sum up those top three, you end up with 30 a bou t , a little over 75 percent, or a little over 3/4ths 21 of the issues contained in the 2.206 docunent have been 22 addressed by the Staff. That leaves the remaining Itens 23 4 and 5 on your handout, which we have entitled, Totally 24 _New Icsues, Insufficient Information Given. 25 The totally new issues the Staff has reviewed to
t
}
g 11 pb3 , 1 determine whether or not those issues, using the criteria a that we provided in SSER-22, should hold up a decision on 3 reactor criticality. Each of those was reviewed by the 4 Staff as appropriate in NRR or by the region, if it related 5 to a construction issue. And none of those items, in our e opinion meet our criteria of being an issue which should hold 7 up the decision on criticality. O _Giving you an example of some of those, one dealt s with a backing bar held by tack welds, which it is alleged to the fusion of the tack welds was so weak that the sli.ght t 11 tap of a hammer could knock it off completely. We don't 12 have a problem with the backing bar being able to be tacked 13 off in a wel' ding process, because it can perform its function 14 just being held in place while you put in the first bead 15 of weld. It's not a component which provides strength in is the welds when the work is done. 17 CHAIRMAN PALLADINO: But the tack weld then is 18 followed up by a -- 19 MR. BISHOP: It is replaced by a more permanent so weld. Another issue dealt wich the purchase of clamos, 21 where they purchased a one-size-fits-all clamp for securing 22 instrument tubing or conduit members. - 23 The statement is made that the clamps were 24 cockeyed and appeared loose by a visual determination. We 25 have two sources of information. Both our examination of
! )
12 4 . 2pb4 I installations through our routine inspectirn program. Plus s those supplemented by our contra,etor Lawrence Livermore 3 Laboratory, which tell us that if there are clamps that are 4 not proper out there, it certainly isn't a widespread 8 problem. And the use of a one-size-fits-all beam type clamp, e again, doesn't meet our criteria of being one which we 7 feel should hold up a decision. 8 COMMISSIONER BERNTHAL: Can we avoid the feedback 9 here? I was just going to comment that saying that if there to are clamps out there that do not meet standards or specificat: .or 11 then it's not a widespread problem, is not totally comforting 12 What does that mean? 13 MR. BISHOP: Let me explain that. I was referring 14 to the fact of whether, because of the use of the is i one-size-fits-all clamp -- which we have not yet assessdd. 16 We haven't gone out to determine whr:ther that is in fact 17 an accurate statement. The concern is that if they used 18 an improper clamp, that it may be loose, and not perform 19 their function. 20 We have performed inspections which tell us that 21 the clamps that we have observed and the clamping process 22 l that has been done, we did not see widespread problems in* 23 that area. - 24 Other concerns, a number of them deal with the 25 installation of tubing. Various concerns about the procedures
I 13 2pb5 1 used. 1 This happens to have been the subject of a previous S NRC review not too long ago, where we looked at the tubing 8 installation practices employed by the contractor and found 4 them to be consistent with codes and requirements.
~
And 8 so we have some background in it to indicate to us that 8 we don't feel this is an area that we have no knowledge of 7 and could turn into a significant problem or anything. 8 Other problems relate to hydrostatic test records, 9 missing data. When we go back into these supporting material , 10 which is provided in the petition, we find a statement that ' 11 the supporting material is not attached and will be provided 12 1;ater . That note is dated February 2nd, '84 and we have 13 not yet been provided that additional supporting material, 14 to my knowledge. 15 Nevertheless, we do have a background in the
- 16 hydrostatic test area, where we have gone in from our .
17 inspection program again, both under earlier allegations 18 last summer, as well as standard NRC Staff reviews of the 18 hydrostatic testing process, which give us some background 20 in that area. 21 Anyway, those are examples of the totally new 22 issues. We also have some 11 issues which the Staff identified , 23 that had insufficient information and were vagau, that we 24 just couldn't make an assessment on because there was not 25 enough meat there to determine whether or not it was a
I \ t'V8l/A l'fZ- . g -)- fN' UNITFD STATFS OF AMERICA N.lCLFAR REGilLATORY CGtMISSION BFF0#E THE C009tISSION
) ,.
In the Matter of ) PACIFIC GAS AND ELECTRIC CO. Docket No. 50-275 OL (Diablo Canyon Nuclear Power Plant, finit 1) PETITION PURSUANT TO 10 CFR 2.206 THOMAS M. DEVINE, ESQ. Legal Director JOHN CLEWFTT, ESQ. GOVERNMENT ACCOUNTA9ILITY PRO.1ECT INSTITUTE F00 POLICY STIIDIES 1901 Q STRErT, N.W. WASHINGTON, n.C. 20009 (202) 667 7904 C0llNSFL FOR MOTHEDS FOR PFACE DATED: FEBRUARY 2,1988 ATTACHMENT 20
e . (' UNITED STATES OF AMERICA ) , BEFORE THE NUCLEAR REGULATORY COMISSION In the Matter of )1 i PACIFIC GAS AND ELECTRIC COMPANY h Docket No. 50-2750L 3 (Diablo Canyon Nuclear Power Plant, )
. Unit 1) )
)
Pursuant to 10 CFR 2.206, on behalf of the San Luis Obispo Mothers for , Peace (Mothers) the Goverruent Accountability Project of the Institute for Policy Studies (GAP) petitions the Nuclear Regulatory Comission (IRC or Comission) to defer any decision on whether to grant a low-power operating license to the Diablo Canyon Nuclear Power Plant (Diablo Canyon or DCPP) until completion of -- (1) a comprehensive, third party reinspection program of all safety-relat'ed construction in the plant, with full authority by the independent organization to identify and impose corrective action en any nonconforming condition that deviate from 10 CFR 50 Appendix 8, the Final Safety Analysis Report (FSAR) or plant specifications, through implementation of corrective action. (2) an independent audit of design quality assurance, including the reliab-of conclusions from remedial design verification programs imposed since 1981 suc.6 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 (a) a management audit by an independent organization, and (b) publication of a report by the NRC Office of Investigations (01) following a full investigation to determine the causes of construction and design QA violations at Diablo Canyon, including issues such as harrassment and retaliation, subordination of quality assurance to cost and scheduling concerns, destruction of records and false statements, 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 organizations from nominations submitted by either PG1E or any interested member of the public, and creation of a public oversight comittee consisting of equal representation by state and local representatives and the intervenors with the authority to obtain all requested information and,to conduct legislative-style public oversight hearings. - G
24
) '
This violatad ESD 263, they explained. My audit was voided. Both individuals neglected to mention the violation of ESD that I had raised - the QA violations were not getting fixed (g., at 9-10). , 64 In January 1983, I was further punished for Mr. Xarner's improprieties. I was removed as internal auditor because only 5 instead of the required 18, 8 audits had been closed out, part of..the problem was due t a circumstances - beyond my control. Mr. Karner or supervisors were sitting on some of my audits beyond the required deadline. Mr. Karner also es loading me down with ancillary assigranents.and unschedule counted.
- 65. On January 28, 1983, during the meeting in which Mr. Karner.
threatened to get rid of me for looking at quality -related issues without
.being assigned (Suora,' Nos. 27-28), I informed Mr. Karner that he had violated.10 C.F.R. 50, Appendix 8.
.He responded twice that we are not committed to 10 C.F.R. 50, Appendix 8; and that it was "O.K." for him to violate the Code of Federal Regulations and related contract speciff -
cations.
= -
III. l EREAKDOWN IN OUAl.ITY ASSURANCE FOR HYDROSTATIC TESTS Hydrostatic testing at Diablo Canyon from 1975 to 1978 does not j have the necessary QA documentation to prove the reliability of the tests . In hydrostatic tests, water is run through the plant at higher pressures than normal to see if the piping is reliable. In February.1981, I conducted Internal Audit 86, in-which I learned that nearly all hydrostatic piping tests for a, year during 1980 and 1981 were conducted without required QC documentation. -In Apri1 19 ~ NRC inspection identified that documentation problems identified
. 25- .
1
)
in Internal Audit 86 were not ' properly.. corrected. I became convinced that.. serious problems may exist with the hydrostatic tests. In March 1983 I completed Int'ernal Audit 106, which examined the records for 79 original hydrostatic tests and 118 ratests conducted from 1975 onward. I learned that the test documentation did not have evidence of required QC oversight, QA rr mrds, consistent procedures, or controlled , test conditions. In short, there has been a generic breakdown in the QA requirements for hydrostatic tests. They must be redone. Internal Audit 106 is enclosed as Exhibit 4. My specific allegations follow.
- 66. The procedures for hydrostatic tests conducted before
.Ja ntary 27, 1975 are fundamentally inadequate, due to their failure to include documentation requirements, and due to lost pages, the inability .
to even entirely reconstruct the procedure requirement. t
- 67. Almost all hydrostatic tests and. retests fran 1975 onward lack required QA documentation. The most significant omission involves QC coverage documented on a piping system closecut - F98 Department Release. This activity is necessary to assure that departments performing the test comply with procedure checklists. Unfortunately, departments only complied sporadically with the requirement to complete and maintain the form whichchmanstrates compliance with the test pro-Cedure. In other cases, there is not necessary backup documentation to verify the conclusions in the release. (Exhibit 4. AAR #1).
. 63. From December 1977 - April 1978, in 28 cases Pullman test requirement forms did not have information necessary under 4he
( ) ,
. procedure E5D 229. ' Fundamental data, such as the type of fluid, pressure and temperature, simply is missing (M., AAR #2).
i
- 69. , In 28 cases, Pullman's NT procedure data form does not match PG&E requirements. This form is the guide used to conduct the test, so the distinctions translated into different test conditions that disqualify the results from Pullman's hydrostatic test. To illustrate, in one test Pullman's procedure only had a pressure of 2485 PSIG, when PG&E's acceptable micimum was 2312 PSIG.
- 70. The absence of backup documentation continued after 1978. -
From March 1978 to April 1980, there were 14 hydrostatic retests without a signed QC field pipe release, dispite the conclusion by Quality Engineering in the test records that QC had verified the results (M. AAR f3).
- 71. The problems with hydrostatic tests offer another example of management harassment of QA personnel. During the May 1982 NRC inspection, I spoke extensively with. NRC representatives. After the interview Mr. Karner expressed anger at' the length of the meeting. At a later ,
meeting, during this general time frame, he threaten to get rid of me. IV. BREAKDOWN IN VENDOR 00ALITY ASSURANCE. Although I was not as actively involved with vendor QA as with special process and hydrostatic test procedures, I observed the synptoms of a generic QA breakdown after becoming familiar with two examples of QA violations involving vendors. One case involved a vendor that calibrates micrometers, a precision measuring device for Pullman
~
tools and the impact of weld repairs, among other functions. Al tho ugh
- the vendor had a clean bill of health and was on the Approved Vendors
l {, . } 1 2-2-44 - l EXHIBIT 4 IS NOT ATTACHED, AND WILL SE PROVIDED LATD.,
.2 2-t
. JOHN CLEWETT e
.' I O
s O M D ..-,J. . _ - _ -, . . , _ ~ ,,-- -
GOVERNMENT 'COUN%DIUTY PROJECT Inntute for Polici dies 1901 Que Street. N.W., Washington. D.C. 20009 (202)234 9382 March 2, 1984 Mr. Thomas Bishop Division Director . U.S. N.R.C. Region Five ' 1450 Maria Lane, Ste 210 Walnut Creek California 94596 Re: PACIFIC GAS IND ELECTRIC (Diablo Cany'on ' Nuclear Power Plant, Unit 1), Dkt. No. 50-275
Dear Mr. Bishop:
Enclosed with this letter is a copy of a petition filed with'the Commission pursuant to 10 C.F.R. 2.206 on March 1, 1984, together with Attachments 1 through 17 thereto. Also enclosed for your use, bound separately in this package, are three documents that were not include'd in the petition filed on Febru-ary 2, 1984: Exhibit 4 to Attachment 2, and two Discrepancy Reports inadvertently omitted from Attachment 7. Best wishes in your continuing investigation. Sincere your,s, rf f
& A -
Jo n Clewett l
Enclosures:
A/S RECD b5 ,;
;, - c.t:,: . -G-- ATTACHMENT 21
~
i ) , Preblem States 2nt Allegation f(s): . 2,'2 8 - ATS
- No.(s):
7".
~~
Bh(s): This document lists (or directly references) each allegation or concern brought to the attention cf NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview). Problem Statements (use extra sheets as necessary) Allenation# Verbatum Statement or Reference 2R@ $df 70/HT INTERVEYdRS'/>107/oM JF 2/22/8Y A LLFG/> 7~/DN #f 9 (faff .2 7 ) I Commentary 7h'E ALLEGAT/d^l AA/O THE /977ACHMENT /?RE All #f W
'O OUEU/CA /9V/I// A845 M YH/S 774 6 Date This Statement was Completed ///J//9' Tepfdical RevieweJ Signature I
y l ATTACHMENT 22A
M # 2l2 5 1 pq( ggewc% -zs-
)
.p> 77 inoma # 2kM in Internal Audit *86 were not properly. -corrected. I became convinced that.. serious problems may exist with the hydrostatic tests. In March 1983 I completed Internal Audit 106, which examined the records for 79 original hydrostatic tests and 118 retests conducted from 1975 onward. I learned that the test documentation did not have evidence of required QC oversight, QA records, consistent procedures, or controlled test conditions. In.short, there has been a generic breakdown in the QA requirements for hydrostatic '
__ i.ests. They must be redone. . Internal Audit 106 is enclosed as Exhibit 4 My specific allegations follow. '
- 66. The procedures for hydrostatic tests conducted fort SI))$ Janua~ry 27, 1975 are fundamentally inadequate, due to their failure to include documentation requirements, and due to lost pages, the inability to even entirely reconstruct the procedure requirement.
( -
- 67. Almost all hydros *atic tests and, retests from 1975 onward inck required QA documentation. The most significant omission involves QC coverage documented on a piping system closecut - F98 Department Release. This activity is necessary to assure that departments .
;.:arforming the test comply with procedure checklists. Unfo rtunately, ; departments only complied sporadically with the requirement to complete and maintain the form whichdr:cnstrates compliance with the test pro-cedure. In other cas'es, there is not necessary backup documentation to verify the conclusions in the release. (Exhibit 4. AAR #1).
- 68. From December 1977 - April 1978, in 28 cases Pullman test recuirement forms did not have information nepessary under the y- -- - - - - - _ .
~
'. .' I )
+ ..
Probles Statestat Allegationf(s):.2'28 - ATS No.(s): - 3 BN(s): Tinisdocumentlists(ordirectlyreferences)eachallegationorconcern brought to the attention of NBC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. ( ' If the probles statement is not clear as to who, what, where, when, or whyThe re==rding the issue, the commentary section will amplify the statement. commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview). Problem Statements (use extra sheets as necessary) A11eastion# Verbatum Statement or Reference
'2. ~25 Sff Je/AT lHTEA'VEMcA'5'Mo7'/oM #F 2/22/8Y a ur&n rim #19 Osse .2,)
l . I l l l Conssentary 7//E~ ALLEGAT/dN AA/O THE ATTACHMEMT ARE AU W IN
- OocuMEN7 4 7 tog gyg7L4ggg 47~ 7pjpg 7ygg Date This Statement was Completed '
/J/89 Tep[dicalReviewerSignature ATTACHMENT 22A
mgg: j w v
-~
fgGE g ' . $77YNA ) p, f I .'p w ra> N s f 2 4 '/9 9
, - in Internal Audit 86 were not properly. -corrected. I became convinced that.. serious problems may exist with the hydrostatic tests. In March 1983 I completed Internal Audit 106, which examined the records for 79 original l hydrostatic tests and 118 retests conducted from 1975 onward. I learned
\ that the test documentation did not have evidence of required QC oversight, QA records, consistent procedures, or controlled test conditions. In,short, there has been a generic breakdown in the QA requirements for hydrostatic
- --t ests . They must be redone. . Internal Audit 106 is enclosed as Exhibit 4
~
My specific allegations follow.
~
- 66. The procedures for hydrostatic tests conducted before N)M Ja nua'ry 27, 1975 are fundamentally inadequate, due to their failure to include documentation requirements, and due to lost pages, the inability to even entirely reconstruct the procedure requirement.
t- L
- 67. Almost all hydrostatic tests and. retests from 1975 I
onward lack required QA documentation. The ecst significant omission involves QC coverage documented on a piping system closecut - F98 Department Release. This activity is necessary to assure that departments performing the test comply with procedure checklists. Unfo rtunately,
; departments only complied sporadically with the requirement to complete and maintain the form whichdenonstrates compliance with the test pro-cedure. In other cas'es, there is not necessary backup documentation to verify the conclusions in the release. (Exhibit 4. AAR #1).
. 68. From December 1977 - April 1978, in 28 cases Pullman j test reautrement forms did not have information nepessary under the e
( -) 1 l Preblem Statement ' Allegation f(s): . 229 4
.e Ap No.(s): -
R$i(s): This doetssent lists (cr directly references) each allegation or concern brought to the attention of NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview). Problem Statements (use extra sheets as necessary) Allegation # Verbatum Statement or Reference 129 6ff IO/W /NTERVfNONS $7/oM #f W h
)9LLESAT/eN D 5 @ ME 27)
Commentary 7WS/90564'7/JNNA 75fA774CN/*!MT AFff Add of 7HE
'bOCu /hFfAJ TAT /oAl /9VA/l A 8df 8 Y 75/.S 7//W.
Date This Statement was Completed J [ ical Reviewer Signature Tep/ ATTACHMENT 228 i
. '229 ,
25 PAGE.25 of. 74cHN wr g ) '
'7D J Z Dro776N OF2-/22/f9c in Internal Audit 86 were not properly -corrected. I became convinced that.. serious problems may exist with the hydrostatic tests. In March 1983 I completed Internal Audit 106, which examined the records for 79 original . j hydrostatic tests and 118 ratests conducted from 1975 onward. I learned that the test documentation did not have evidence of required'QC oversight, QA records, consistent procedures, or controlled , test conditions. In short. -
there has been a generic breakdown in the QA requirements for hydrostatic j tests. They must be Tedone. Internal Audit 106 is enclosed as Exhibit 4 My specific allegations follow. *
, 66. The procedures for hydrostatic tests conducted before
.Ja nuary 27,'1975 are fundamentally inadequate, due to their failure to include documentation requirements, and due to lost pages, the inability to even entirely reconstruct the procedure requirement.
\..
67 Almost all hydrostatic tests and retests from 1975 cnward lack required QA documentation. The most significant omission . A involves QC coverace documented on a piping system closecut - F98 LT Department Release. This activity is necessary to assure that departments performing the test comply with procedure checklists. Unfortunately, departments only complied sporadically with the requirement to complete and maintain the fom whichdrienstrates compliance with the test pro-
.c edure. In other cases, there is not necessary backup documentation to verify the conclusions in the release. (Exhibit 4. AAR #1).
. 68. From December 1977 - April 1978, in 28 cases Pullman test requirement forms did not have information nettssary under th'e
._.c , - - , - . . -- , - . - . , - - - . - - - , , - - - - - - , - - - - - . - - - - - - - . . - . . - , , , - . - - , - - - - . , - -- - ,.- . ~ ,_ - - -
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2/% 301 N T INTER VEN0AS,Mo'rtoNer Y The internal auditor informed Mr. Karner that he had violated 10 CFR 50, Appendix B. Karner responded twice that Pullman was not comitte'd to 10 CFR 50, Appendix B, l and that it was "O.K." for him to violate the Code of Federal Regulations and related contract specifications. (Id.)
'C . Hydrostatic Tests In hydrostatic tests, water is run through the plant to higher pressures than normal to see if the pipi'n g is reliable. Hydrostatic testing at Diablo Canyon l from 1975 to 1978 does** not have the,necessary QA documentation to prove the reliability of the tests. In Mart:h 1983 Mr. Hudson denenstrated this problem
' through Internal Audit #106, which examined the records for 79 original hydrostatic tests and 118 retests conducted from 1975 onward. 'The test documentation did not have evidence of required QC oversight, QA records, consistent procedures,'or controlled test conditions. On balance, there was a generic breakdown in the QA requirements for hydrostatic tests, which must be redone.
The procedures for hydrostatic tests conducted before January 27, 1975 are fundamentally inadequate due to their failure to include documentation require-ments, lost pages, and the inability to even entirely reconstruct
. the orecedure requirements. (Id., at p. 25.) ,
MCl-'P Almost all hydrostatic tests and retests from 1975 onward are missing required QA documentation, such as evidence of _ QC, on the piping system closecut l -- F98 Department Release. QC is supposed to assure that departments performing i the test comply with procedure checklists. Unfortunately, departments only spor-l adically completed and maintained the forn which demonstrates compliance. In other cases, there is not backup documentation to support the conclusions in the l F98 Release. (Id.) .
. From Cecember 1977 - April 1978, in 28 cases Pullman test requirement forms did not contain basic information such as the type of fluid, pressure and 1
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1 -
i I
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Prrblem Statement Allegationf(s):.JJC :. A,TS No.(s): R$1(s): is document lists (or directly references) each allegation or concern brought to the attention of NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview). Problem Statements (use extra sheets as necessary) A11eastion# Verbatum Statement or Reference
,1, 3 O $f*C JotHT /p7"cgVEppgS'/>107/bH do c ~2/22//if
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Commentary TWE 444Ed~fTVsy ANs THE A774 CHM &h)g45
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{~. Date This Statement was Completed I2 f - f Reviewer Signature Techn
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. To* 3,9 Rnv ten' of .z / n /s j' in Internal Audit 86 were not properly -corrected. I became :onvinced
.-^
that.. serious problems may exist with the hydrostatic tests. In March 1983 I completed Internal Audit 10E, which examined the records for 79 original . hydrostatic tests and 118 retests conducted from 1975 onward. I learned that the test documentation did not have evidence of required QC oversight. QA records, consistent procedures, or controlled . test conditions. In short. l the:e has been a generic breakdown in the CA requirements for hydrostatic tests. They must- trredone. Internal Audit 106 is enclosed as Exhibit 4 My specific allegations follow.
- l
- 66. The procedures for hydrostatic tests conducted before '
.Ja nuary 27, 1975 are fundamentally inadequate, due to their failure to include documentation requirements, and due to lost pages, the inability to even entirely reconstruct the procedure requirement.
t .. . 67 Almost all hydrostatic tests and, retests from 1975 onward lack required QA documentation. The most significant omission involves QC coverage documented on a piping system closecut - F98 Department Release. This activity is necessary to assure that departments performing the test comply with procedure checklists. Unfortunately, departments only complied sporadically with the requirement to complete and maintain the form whichdrnonstrates compliance with the test pro-
, cedure. In other cases, there is not necessary backup documentation to verify the conclusions in the release. (Exhibit 4, AAR #1),
g - 68. From December 1977 - April 1978. in 23 cases Pullman 2D test recuirement forms did not have information necessary under the M
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. _ . . . _ . . ~ --
. - - _ . . _ - - - - _ . _ ._.-L_-- . - - _ - _ - _ _ _ _ _ - _
, -26
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f procedure ESD 229. Fundamental data, such as the type of fluid, pressure
-w and temperature, simply is missing (M., AAR #2).
69., In 28 cases Pullman's HT procedure data form does not match PG&E requirements. This form is the guide used to conduct the test, so the distinctions translated into different test conditions that
-disqualify the results from Pullman's hydrostatic test. To illustrate, in one test Pullman's procedure only had a pressure of 2485 PSIG, when - -
PG&E's acceptable minimum was 2812 PSIG. -
- 70. The absence of backup documentation continued after 1978.
From March 1978 to April 1980, there were 14 hydrostatic retests without a signed QC field pipe release, disaite the conclusion by Quality Engineering in the test records that QC had verified the results (M. AAR #3),.
- 71. The problems with hydrostatic tests offer another example of management harassment of QA personnel. During the May 1982 NRC inspection, I spoke extensively with. NRC representatives. After the interview Mr. Karner expressed anger at'the length of the meeting. At a later meeting, during this general time frame, he threaten to get rid of me.
IV. BREAKDOWN IN VENDOR OUALITY ASSURANCE. Although I was not as actively involved with vendor QA as with special process and hydrostatic test procedures, I observed the symptoms of a generic QA breakdown after becoming familiar with two examples of QA violations involving vendors. One case involved a vendor that calibrates micrometers, a precision measuring device for Pullman
~
tools and the impact of weld repairs, among other functions. Al tho ugh the vendor had a clean bill of health and was on the Approved Vendors e e ,
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Jol T IHTER VEHoPSmoTloN 0F 2/22/a y The internal auditor informed Mr. Karner that he had violated 10 CFR 50, Appendix 8. Karner responded twice that Pullman was not comitted to'10 CFR 50, Appendix B, and that it was "O.K." for him to violate the Code of Federal Regulations and , related contract specifications. (Id.)
'C . Hydrostatic Tests In hydrostatic tests, water is run through the plar.t to higher pressures ~~
than normal to see if the pipi'ng is reliable. Hydrostatic testing at Diablo Canyon from 1975 to 1978 does not have the,necessary QA documentation to prove the reliability of the tests. In March 1983 Mr. Mudson derrenstrated this problem
' through Internal Audit #106, which examined the records for 79 original hydrostatic tests and 118 retests conducted from 1975 onward. 'The test documentation did not have evidence of required QC oversight, QA records, consistent precedures, or controlled test conditions. On balance, there was a generic breakdown in the QA requirements for hydrostatic tests, which must be redone.
The procedures for hydrostatic tests conducted before January 27, 1975 are fundamentally inadequate due to their failure to include documentation require-ments, lost pages, and the inability to even entirely reconstruct
- the procedure requirements. (Id., at p. 25.) .
Almost all hydrostatic tests and retests from 1975 onward are missing required QA documentation, such as evidence of QC, on the piping system closecut
-- F98 Department Release. QC is supposed to assure that departments performing the test comply with procedure checklists. Unfortunately, departments only spor-adically completed and maintained the form which demonstrates compliance. In i .
other cases, there is not backup documentation to support the conclusions in the F98 Release. (Id.) - c _
.. 4 From December 1977 - April 1978, in 28 cases Pullean test recuire-ent__
forms did not contain basic information such as the type of fluid, pressure and { $2/s* L ._ _
.I.(@@ ) ;rowr \$reeyenone. tHonon or +/8y .
# no temperature for the hydrostatic tests. (Id.,at pp. 25-26.)
In 28 cases. Pu11 sun's hydrostatic test procedure data form is inconsistent with PG&E requirements. Since this form guides the test, the distinctions meant relaxed test conditions that disqualify Pullman's results. For example, in one test Pullman's procedure only had a pressure of 2485 PSIG, when PG&E'a acceptable minisim was 2812 PSIG. (Id. , a t- P. " 2fr:)
- 98. Post-1978 hydrostatic-retests did not consistently have a signed QC field pipe release, despite other rc:ords claiming that QC had verified the results. (Id. ) - :"
- 99. The problems with hydrostatic tests offer another exampie of manacement harassment of QA personnel for comunicating with the NRC. In May 1982 after Mr. Hudson spoke extensively with NRC representatives, Mr. Karner expressed anger at the length of the interview. Soon afterwards, Mr. Karner threatened to get rid of Hudson, the auditor. (Id.)
D. Vendor Ouality Assurance The workmanship of vendors who sell sensitive parts and components can be more significant for public safety than the construction performed on-site. As a result, each licensee's audit, surveillance and inspection prcgram must extend to the vendors' own facilities. When shoddy work slips through anyhow, it still must be fixed if uncovered on-site. The program for QA oversight of Diablo Canyon vendors broke down on both counts. At least one fir.n. Microsurface Engineerir.g. was a longtime member in good standing on the Approved Vendors List, although in 1981 the internal auditor discovered the ccmpany only had a token QA program. Second, PG&E repeatedly refused Pullman inspectors permission to write reports on significant quantities of cracked welds that slipped through from two vendors,
~
Boston Bergen and American Bridge. One QC inspector stated that some of these welds are "truly abominable" and "so ragged that they will tear your clothing if
8.
- 1 .-
3 h* ave read the above eight page statement. I have based the information
~
contained therein either on personal knowledge or by reviewing the relevant information with the particular witness involved. This stateme nt is true, correct and complete to the best of my knowledge and belief. I declare under penalty of pe -ju:,j that the foregoi:ig is true and correct, and that the.sne was executed this 17th day of Ap i',1984at San Inis Obispo, California. ,
. RIOiARD D. PARKS, L.l-4 clarant
! STATE OF CM TTDRNIA )
) ss.
CDUNTI OF SAN LUIS 031SPO ). Ch April 17, 1984, before me, the undersigned, a k ta:,/ Public in for said State, personally appeared RIORRD D. PAK<S, personally kro.m to me and proved to me on the basis of satisfactory evidence to be the pe son Wse noe is subscribed to the within instet, and that he executed the s2TE . WHESS my hand and official seal. ,.
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- * :.:.n m os>Jo em kq.,.f l said Co.:nty and State l
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i , k[{ - ) ROU3I ERAFT - Not reviewed by Project knagenent or Licensing department and therefore to be considered preWNrv. I M No. 1 Platform As-builts, Unit 1 It is alleged that As-built drawings for certain mmbers in Platforn 477G, Elevation 163', 10 3/4", Steam Generator 14 are not shown correctly on As-built drawings. Field observations verifies that this support is installed as shown on the associated As-built drawing. (Ref. dag. 6181 C1 13 380, Rev. 5, Detail 3 80A) . %erefore the allegation is false. I':EM No. 2 Accmulator Injection Line, thi't 1 It is alleged that the Accmulator Injection Line, (R;andE Designation 1-S6-254-10) adjacent to field weld 157, has two areas of undercut or unacceptable grinding, and an maoceptable grinding gouge. Wis weld has been inspected by two welding engineers who are also AWS Certified Welding Inspectors. Bere are no taidercuts. We alleger apper-ently thought that a slight difference in thickness between the weld and pi;e was undercut. We d2fference was caused by grinding the weld very close to flush with the pipe in preparation for inservice inspection. Inspection has verified there was no excessive grinding. Wis is known because the areas of concern are discolored by welding heat tint, whereas the groand areas are bright metal. Se grinding nark in the pipe fitting just below the field weld was present in the fitting prior to field welding as evidenced by thermal discoloration of the area. S e depth of the area in question has been determined by neasurerent to be 1/32" deep. Ihgineering review has determined that the pipe is schedule 140 which has a rminal wall thickness of 1.000" with a ranufacturing tolerance of minus 12.5 percent or a minim e thickness of - 0.875*. Design requirenents for this line based on pressure and taperature is 0.74 8". As stated above the depth of the ground area is 1/32" deep. Based on a worst case basis of 0.875" minus 0.031", the ground area is 0.056" above minimm design wall requirenents. We mark does not represent a sharp discontinuity and is therefore acceptable as is. I M No. 3 Platform Welding, thit 1 It is alleged that a certain weld on Platform 965F, Elevation 125' near Reactor Coolant Pump 1-1 does not satisfy applicable requirements for a fillet weld che to the obtuse angle of renber intersection. A review of the H.P. Foley Ccnpany As-built Drawing 6181-Cl-13-37 Rev. 3, and 6181-Cl-13-38 Rev. 3, clearly shows that the weld in question is detailed and constructed as a groove weld, not as a fillet weld. -Visual observation confirms the accuracy of the As-built drawings. %e weld was . nade with a backing bar and meets the requireents for a groove weld. %ere-
- fore, the allegation is without merit and the weld is acceptable as is.
3 ATTACHMENT 28
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L * ; ' ,'; N No. 4 Excessive Welding and Distortion on Pipe Support 97-3R, Unit 2 It is alleged that the attachment of a pipe support to stainless , steel piping has excessive weld metal which has caused unacceptable distortion. Also, there are resi &al stresses which have not been accounted for in the design. Contrary to the allegation, the welding and distortion on the pipe is acceptable. 'this has been evaluated by a welding engineer, who is an AWS Certified Welding Inspector, and a piping engineer baaed on criteria issued by Project D>gineering on January 9,1984. Se isst.e of resikal stresses is addressed in Itm 6. N No. 5 Rupture Restraint Welding, thit 2 It is alleged that s e e of the pressurizer surge line rupture restraints shop welds fabricated by Bostrom-Bergen are grossly unacceptable. his does not represent a new issue since the rupture restraint welds of concern are similar to many other Bostrm-Bergen welds which have previously been evaluated in reviews of Bostratr Bergen welds and in previous reviews of rupture restraint adequacy. Se welds of concern are coaretically unattractive; hcwever, the welds are acceptable. S e welds have been reviewed by welding engineers who are AWS Certified Welding Inspectors and by civil structural engineers and have been found acceptable. For example, during this review the two apparent worst welds in the welded connections of concern were. evaluated. Although these have a significant length of undercut, approximately 95% of these undercut weld lengths are within original AWS DI.1 acceptance limits. Se remaining undercut is outside the undercut limit of the original AWS DI.1 code edition but is consistent with mrrent AWS DI.1 criteria in effect since 1980. Further, the effect of the weld discontinuites in the two worst welds in a single weld connection were evaluated and found to satisfy loading requirments. . N No. 6 Weld size, distortion and Residual Stress on Pipe support 50-26V, Unit 2 It is alleged that a pipe support has lugs with undersized welds, excessive distortion and residual stress in the pipe, and the eccentric loads on the lugs were not accounted for.
%ese lugs were originally installed by the piping spool fabricator using 7/16" partial penetration welds with fillet cap of unspecified size.
Pu11ran Power Prockets Discrepancy Reprt-8109 was issued on 02-15-84 to document the unspecified fillet weld size. On 03-09-84 Design Change Notice DC2-EP-8188 was issued and specified 1/2" fillet welds for- the lugs.
%e additional welding required has been conpletea and accepted by Pullman l Power Prockets Q.C. inspection. In addition, a AWS Certified Welding Inspector has determined that these welds meet the design requirment of l 1/2" fillet welds.
1 2 L-______. . - . _. . - _ - _ _ . _ _ _ _ _ _ _ _ . - . _ - - _ _ _ . . . - - . - _ _ _ . - _ . ___ . - - _. _
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, . Eccentric loading of shear lugs is required to be accounted for in thg local stress analysis of the pipe by proce&re. S e alleger aw arently believes that the loads are analytically applied at the surface of the pipe. %is is not the case. Rather the point of loading is taken at a point 2/3 of the height of the lug away fran the pipe wall. %is properly accomts for the eccentric loading of the lugs. In addition, as required by our desip criteria, only two af the four lugs would have been i considered to carry the piping load. Se distortion present in the pipe at support 50-26V, and support 97-3R . to a much lesser extent (Ref. Item 4), is typical of this type of welding ' on stainless steel pipe. Residual stresses are local and aeoondary, and therefore of a self-limiting nature. Se ASME code recognizes this and therefore does not require specific consideration of it. An ASME publica-tion (Criteria for Design) discusses this further. - rrEM No. 7 Effective Weld B roat, Unit 2 * .
, It is alleged that the penetration groove welds were not being used as ,
required and that only fillet welds were utilized. Also, it is alleged that the effective throat for a 3/16" fillet weld adjacent to a 3/16" partial penetration weld would be insufficient. We design calculations take no credit for penetration welds of pipe - attac} nents to code class II and III piping unless the extent of penetration is provided by a specific weld inspection reported in writing to the engineer. Bis limitation on calculations is directed by procedure. Se installation contractor's procedures require full penetration welds for all attactr:ents to code class I piping. Specific ins);ections have been perfonred to verify ccrnpliance with this requirement. B erefore all pipe attacterent welds are known to be acceptable. Se second part of this allegation is. incorrect. S e AWS DI.1 code conservatively requires that 1/8" be deducted for non-fusion frorn certain pre-qualified partial penetration weld joint geanetries. Actually the . non-fused area is less than wtat DI.1 postulates ~ and the effective weld is 7 greater. BrArever, accepting the DI.1 postulation, the allegation is 1 incorrect as shown in the attached sketch drawn to scale, and enlarged for ., clarity. He fillet weld effective throat is maintained when the non-fused region is deducted frorn an adjacent 3/16" partial pentration weld. D ! I i 4
} -
g _, ) I,W~%, a NUCLEAR REGULATORY COMMISSION c f* neoson v 1490 MARIA LANE, SUITE 210 WaLNLH CREEK. CALIFORNIA teles JUN 121984 Docket Nos. 0-275 and 50-323 - l Pacific Gas and Electric Company - 77 Beale Street, Room 1435 San Francisco, California 94106 . Attention: Mr. J. O. Schuyler, Vice President Nuclear Power Generation Gentlemen:
Subject:
NRC Inspection of Diablo Canyon Units Nos. I and 2 This refers to the special inspection conducted by Mr. G. H. Bernandez of this office on May 14-23, 1984, of activities authorized by NRC License No. DPR-76 and Construction Permit No. CPPR-69. Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. No items of noncompliance with NRC requirements were identified within the scope of this inspection. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, ' by telephone, within ten days of the date of this letter and submit written l application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requiressents of 2.790(b)(1). o O ATTACHMENT 29 _ _. -_. r' _- _
y { l l JUN 1. i984 d PaciYicGasandElectric Should you have any questions concerning this inspection, we will be glad to discuss them with you. , Sincerely. .
/si T. W. Bishop, Director Division of Reactor Safety and Projects
Enclosure:
Inspection Report Nos. 50-275/84-20 50-323/8413f cc w/ enclosure: P. A. Crane, PG&E W. A. Rayond, PG&E S. M. Skidmore, PG&E R. C. Thornberry, PG&E cc w/o enc 1: Sandra Silver bec: RSB/ Document Control Desk (RIDS) --- Distributed by RV: JBM State of California Resident Inspector l l l Her ez:dh P.J son D.Ki ch 7.B1 op l 6/ff /84 6//' /84 6/// /84 6////84
. a ,
- l.
- I s
U.. S. NUCLEAR REGULATORY C0!911SS10N REGION V _ Report Nos. 50-275/84-20 and 50-323/84 ef . Docket Nos. 50-275 arnd 50-323 License No. DPR-76 ' Construction Permit No. CPPR-69 Licensee: Pacific Ces and Electric Company 77 Beale Street, Room 1435 San Franr isco, California 94106 Tacility Name: Diablo Canyon Units 1 and 2
- Inspection at: DiaLlo Canyon Site, San Luis Obispo County, California Inspection conducted: May 14-23, 1984 Inspectors: .
LL4 k
. He.mandez, Proj@ Inspector 6 /[8[
Date Signed Approved By: , j d// M. KirsWd Chief Bat ( Signed Reactor Projects Branch Summary: Inspection During the Period of May 14-23, 1984 l Areas Inspected: A special, unannounced inspection by a regional-based ) inspector to assess alleged deficiencies identified by three allegers. Three anonymous allegers had identified seven alleged hardware deficiencies during a NRC conducted plant tour on April ll,1984 The inspection involved 59 inspection-hours by one NRC inspector. Results: No items of noncompliance or deviations were identified. W
o
,( ,e i.
DETAILS
- 1. Individuals Contacted -
- a. Pacific Cas and Electric Company (PG&E) .
J. B. Boch, Project Manager . M. R. Tressler, Assistant Project Engineer R. R. Lieber, Field Construction Manager D. A. Rockwell, Project Field Engineer M. E. Lepphe, Mechanical Engineer J. Arnold, Resident Mechanical Engineer
- b. Bechtel Power Corporation (Bechtel)
P. F. Mason, Spe-ial Project Engineer
- c. Pullaan Power Products Corporation (PPP)
', E. W. Karner, Quality Assurance / Quality Control Manager -
- d. Others Anonymous Allegers A, B and C R. Parks, Volunteer Investigator for the Government Accountability Project (GAP)
- 2. Background As a result of NRC: Region V participation in interviews with anonymous allegers during April 1984, in San Luis Obispo, California, three allegers offered to identify specific hardware deficiencies in the plant.
A plant tour was arranged to allow these allegers the opportunity to point out deficiencies which they believed existed at the Diablo Canyon site. The seven items identified during the plant tour of April 11, 1984, and the NRC fiedings are addressed in paragraph 3. Additionally, . the inspector reviewed the licensee's response to these iti.ms as documented in their letters to the NRC dated May 2, 1984 (PG&E letter No. DCL-84-170) and June 1, 1984 (PG&E letter No. DCL-84-200).
- 3. [eLails I
- a. NRC Tag No.1/ Allegation No. 344:
The concern was erpressed that the catwalk support channel and associated fishplates in Unit 1, Platform No. 77G, Elevation 163', located adjacent to Steam Generator No.1-4 is in the wrong place and is not in accordance with the design drawings.
~
NRC Finding: The inspector examined the catwalk support and the associated fishplates and found the support is installed in accordance with the
a - I { .) design drcwings (Drewing No. 6181-C1-13380, Revision 5, Detail 380A, dated 11/5/83). No violations or deviations were identified. .
- b. NRC Tan No.2/A11egation No. 345: . .
The concern was erpressed that the area adjacent to weld No.157 on l the Unit 1 Safety Injection Accumulator line (PGEE Designation l No. 1-56-254-20) to the cold les line contained a grinding gouge and
. two areas of undercut on the weld.
1
~
NRC Tinding: I The staff examined licensee documentation generated both prior to ; the plant tour and subsequent to the tour. This documentation i included: the results of design minimum wall thickness calculations, the results of depth measurements performed on the alleged grinding gouge, inspector certifications and surface visual examination records. These records appeared to be in order and acceptable. Subsequent to the tour, the subject veld was inspected by two licensee Welding Engineers, who are Certified Welding Inspectors, and who measured the depth of the grinding mark. The results of the licensee's evaluations are contained in letter No. DCL-84-170, dat'ed May 2, 1984. Subtraction of the measured grinding mark depth from i the worst case wall thickness results in a remaining wall thickness in excess of minimum wall requirements. The rationale for the licensee's calculations and conclusions was examined by the staff. Based upon these examinations, the staff concludes that the alleged discrepancy does not represent a violation of the code or licensee procedures. Additionally, the licensee's Certified Weld Inspectors found that the alleged undercut was an area wherein the weld crown and the base material had not been fully blended when the weld was prepared for Preservice Inspection. Thus, the alleged undercut was not really . undercut at all and does not violate any code or regulatory requirements. The inspectors observations during the tour are consistent with the licensee's findings. No violations or deviations were identified.
- c. NRC Tag No.3/A11egation No.346:
The concern was erpressed that a support in Unit No.1, Platform
- No. 65F, elevation 125', near Reactor Coolant Pump No.1-1 was welded to a wide flange . beam with an obtuse angle that is in excess of that
'.. . allowed for fillet welds and the welding procedur(..
h NRC Findina: . 6 . The inspector examined the applicable drawings (Drawing Nos. 6181-CI-1337, Detail 2, Revision 3 and 6181-C1-1338, Detail 2, I
(.
, ,i -
Revision 3, both dated 6/23/83) and determined that' the weld in question is a groove weld with a backing bar, as found during the
~
April 13, 1984, plant tour and as it exists today. Therefore, fillet weld angle restrictions are not applicable because the weld in question is a groove weld. Additionally, the weld was found to
, , conform to the N. P.-Toley welding procedure and the applicable -
code. No violations or deviations were identified.
~
- d. NRC Tag No.4/A11eantion No. 347:
The concern was erpressed that the stainless steel line on pipe ' support No. 97-3R (Unit No.2) has 'such excessive overwelding that 4
. shrinkage or deformation has occurred at the weld areas. This overwelding was alleged to cause damage to the pipe due to a failure of the stress calculations to consider the residusi effects o' f overwelding. ,
NRC Finding: cr The inspector found that the licensee had already considered this issue on a generic basis and had provided acceptance criteria to their. engineering staff. The licensee's acceptance criteria are, based on NUREG/CR-0371 entitled, " Stress Indices for Girth-Welded
-, , Joints, including Radial Weld Shrinkage, Mismatch and Tapered Wall Transitions," by E. C. Radabaugh, S. E. Moore, dated September 1978.
These criteria are provided to their engineering staff for resolving identified cases of pipe concavity which appear excessive. The licensee evaluated this particular support and found it met 5 their acceptance criteria. On May 22, 1984, the inspector observed and verified licensee measurements and determined that the pipe (on
. pipe support No. 97-3R) met the aforementioned acceptance criteria.
, The staff concludes that the licensee does consider the effect of overwelding, does perform calculations to assure that the pipe can :
perform as intended, and that the existing pipe concavity (deformation) does not violate code requirements. No violations or deviations were identified.
- e. NRC Tag No. 5/ Allegation No. 348 -
The concern was erpressed that the Bostrom-Bergen fabricated rupture restraint beneath the Unit 2 Pressurizer contains velds that are
.' / . excessively rough and of such a profile that the welds would not conform to AWS DI.1.
1 . l NRC Findinz: The staff found tt licensee had previously consideted these types of welds on i meric basis and provided for a revised acceptance criteria, as allowed by the AWS DI.1 Structural Welding I s
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) . Code (paragraph 3.7.4). The licensee determined that these welds would perform the design function.
The estent of the licensee's esaminations of Bostrom-Bergen shop , welds, are detailed in letters DCL-84-134, DCL-84-119, and ' DCL-84-200, dated March 23,1984, March 27,1984, .and June 3,1984,
.: . ., respectively. The inspector examined the results of the licensee's t
'*2k.*,
. considerations and concluded that the Ifcensee's analysis of thes'e '
types of welds appears to be reasonable and responsible. The inspector reviewed the calculations performed on these typical supports and found them acceptable. No violations or deviations were identified.
- f. NRC Tan No. 6/A11emation No. 349 The concern was erpressed that overwelding on pipe support lugs (Unit No. 2 pipe support No. 50-26V) has caused excessive shrinkage (deformation) to the pipe. This excessive shrinkage, the accompanying residual stresses, and the eccentric loads were alleged
+
not to be considered in the stress calculations. l NRC Findina: The inspector found that the licensee had already considered this issue on a generic basis. Refer to the NRC finding of paragraph 3.d, above. For pipe support No. 50-26V, the licensee determined that their acceptance criteria, as based upon NUREG/CR-0371, had not been exceeded. On May 22, 1984, the staff verified the licensee's measurements, reviewed the stress analysis calculations, and determined that the pipe (on pipe support No. 50-26V) met the licensee acceptance criteria. The staff concludes that the licensee does consider the effect of [ overwelding, does perform calculations to assure that the pipe can ( perform as intended by the designer, and that the existing pipe f concavity (deformation) does not violate code requirements. } No violations or deviations were identified.
- g. NRC Tag No. 7/A11egation No.350:
J'. . The concern was expressed that the eight lug attachment welds for two Unit No. 2 pipe supports Nos. 413-131R and 24-1)R, were required
.. ;- to be full penetration welds on three sides by the design drawings.
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, B:owever, the actual welds were not full penetration welds but finstead are fillet welds, contrary to design requirements.
NIRC Findina: . T!ne inspector concurs with the alleger that the eight Ings are - s actached by fillet welds instead of the design specified full prenetration welds (from three sides). Bowever, during the tour w~ith tse allegers on April ll,1984, the allegers were asked to make note tiat a " hold tag" was in place on both of the referenced pipe asupports describing the exact situation noted above. The existence oif the hold tag indicates that the licensee's quality program was f':unctioning and had detected this discrepancy. Neo violations or deviations were identified.
- 4. Concluision The in:spector concludes that none of the seven items identified by the 1
allege:rs, described above, constituted a violation of a code or regulatory requirements. l l l l l l
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e 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 4 STATUS OF PENDING INVESTIGATION ON 5 l' e - DIABLO CANYON ( - 6 Public Meeting 8 8 Nuclear Regulatory Commission 1717 H Street, N.W., Room 1130
, 10 Washington, D.C.
11 Monday, March 19, 1984 , 12 The Commission met, pursuant to notice, at 10:20 a.m. g4 COMMISSIONERS PRESENT: 15 NUNZIO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Member 16 AMES ASSELSTINE, Member FREDERICK BERNTHAL, Member 17 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: 18 H.E. PLAINE j gg S. CHILK J. DIRCKS
- 20 H. DENTON G. KNIGHT 21 D. EISENHUT J. MARTIN 22 T. BISHOP 23 AUDIENCE SPEAKERS: ,
24 L. CHANDLER ~ D. KIRSCH 25 ATTACf9fENT 30 l
19 A N 1 13 4
*1 to a Board notification on at least some of these items, at 2
least on the Pullman audit? You said earlier that people got 3 the impression that we just turn things over to the company. 4 It does appear at least in that case that the 5 conclusions were made on the basis of what was received from 6 the company or what was in hand at that time in the NRC files . 7 MR. MARTIN: You mean the NSC audit? Is that 8 what you're referring to? I COMMISSIONER GILINSKY: Right. 10 MR. MARTIN: Yes. I was very careful txtre-read II the transcript of previous meetings on that, and I think what 12 we said to the Board and what I told the Commission is that 13 the original contention that was made on that issue -- all I' the staff did was look at the original audit and the answer I that PG&E and Pullman made back in 1978, and we stated that 10 it looked like both Pullman and PG&E responded properly to I all of the audit findings. 18 There were two or three of them that didn't quite 19 look right to us, and we did some independent inspection. 20 That was the filing that we made to the Board and, I think, 21 advertised it that way. 22 Subsequent to that -- and this is listed as one 23 of these allegations, number 68, -- the alleger, being me, 24 ~ decided to look at that in much more depth. The background 25 on that is that decision was made prior to getting many of
j 14
~ , 1 the.se allegations. I was worrying a little bit, being new 2
in the region, how do I certify that a plant has been built 3- right? What personal basis do I have for deciding that? 4 The Pullman audit -- 5 COMMISSIONER GILINSKY: I don't see that in 6 Number 21. Is that, you say, Number 68? 7 MR. BISHOP: It's in the public document. 8 MR. MARTIN: That's just the sensitive part. 8 So I decided -- and it is covered in 21. So I decided to 10 look at it in more depth, so we went and did an independent 11 inspection on, oh, 50 percent or so of the more significant 12 issues that got raised in the 1977 NSC audit. And in part, 13 that is the basis for the conclusion I just gave you. 14 That is included as a single a.llegation of, you 15 know, 20 or 30 parts that we looked into in some detail. 16 CHAIRMAN PALLADINO: And what did you conclude? MR. MARTIN: We concluded that there were no' major significant problems proceeding from that NSC audit. We did l 19 find one open item concerning qualification of inspectors that is still open that we have some additional work to do, ' 21 ' but in balance, the detailed inspection confirmed the more 22 superficial inspection or review that Pullman and PG&E did l 23 in fact respond properly to those audit findings. COMMISSIONER GILINSKY: Is that the allegation 25 - that listed inspection report --
) 15 l
'l !
MR. MARTIN: Yes. It's also the subject of a 2 Commission paper we sent down a week or two ago. 3. COMMISSIONER GILINSKY: Right. I have to say 4 that it's not surprising that people get or raise questions 5 about the way things work because I must say, I have them 6 myself when in the first place, we -- let's say the staff, 7 but they're the NRC,after all -- notify the board that 8 everything is okay on the basis of, as you said, a super-9 ficial review, and we thin go back and on the second round
', 10 refer to an inspection report which does not, at that time, 11 exist.
12 MR. MARTIN: May I correct you. It did exist. 13 COMMISSIONER GILINSKY: Well, it existed -- there 14 was something down on paper. I guess I wouldn't call it an 15 inspection report. 16 MR. MARTIN: I beg to differ with you. I would, 17 - and it looks almost the same as the final that was issued. 18 COMMISSIONER GILINKSY: Well, it looked to me 19 like a set of notes. In fact, nothing that approached an 20 inspection report. 21 But in any case, it was not something that was 22 signed off at the time. 23 MR. MARTIN: This is true. - 24 COMMISSIONER GILINSKY: And this doesn't mean 25 that the results are wrong, but it does undermine the results
6 .
, l! I 16 I when things are done in this, you might say, ragged fashion.
2 I think we need to do things differently. 3' I think it would have CHAIRMAN PALLADINO: 4
. helped had that been referred to us -- the draft report.
i . 5 MR. MARTIN: I agree with you. That was wrong, 6 and I think we pointed that out in the Commission paper. 7 CHAIRMAN PALLADINO: But does that change the 8 results or your conclusions in any way?
. MR. MARTIN: No.
COMMISSIONER ASSELSTINE: Jack, let me ask you a 11 question or two about the NSC audit. I gathered that NSC 12 had very little confidence in the early welding work by 13 Pullman; that is, prior to November 1973. In fact, did 14 Pullman do any auditing of weld work itself prior to 15 November 1973? The early welding work. My impression was 16 that they hadn't. . 17 MR. MARTIN: I guess if we're going to reconstruct 18 that issue, why don't we -- 19 COMMISSIONER ASSELSTINE: Maybe it's covered in 20 the supplements, but I guess what I was concerned about was 21 my impression was that NSC had very little confidence in the 22 Pullman welding work that was done in those early years; 23 that is, prior to November 1973, and what I'm. wondering is 24 what you did in the inspections to reach the conclusion that 25 you reached on that.
I 17 1 MR. MARTIN: Let's look at that. I think maybe 3 ydmt we should do is look at the final inspection report that l 3 we sent down. And I wonder, would it be okay to perhaps j
~
4
.go on with the briefing and come back to that in a minute, e 5 as soon as we find that paragraph?
8 COMMISSIONER ASSELSTINE: Sure, that's fine. 7 MR. MARTIN: Because our conclusion was that that 8 was just not a reasonable finding to make, and we have the 8 details in the inspection report and I can go over it with 10 you in a minute or two. II COMMISSIONER ASSELSTINE: Okay. Let me ask just 12 ~ one other question following up on Commissioner Gilinsky's 13 concern. And that was second, when you prepared the draf t I inspection report, the one that was done at the site during 15 the time of the November-December 1983 inspection, was there 16 ever any question about preparing a final inspection report on that issue? 18 What I'm wondering is when you have a board 19 notification on a particular subject and then you do a 20 follow-up inspection, it would seem to me that there never 21 would be any question but you would always want to have an 22 inspection report if it covered the same topic or same i 23 area of interest that was covered by a previous board 24 notification. I'm wondering if there was any question at the 25 time from the time that that inspection was done and the e -- , . - - -- - - - - - - - . . . . , . . . .n. . . , . , -
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I we focused principally on allegations because of the large 2 number. 3-So we are trying to take some steps to coordinate 4 and integrate those items altogether.
'i ,. . -
5 MR. DENTON: One point I did want to mention, too, 8 before we get too far off the topic. Talking about board 7 notifications, Jim and I did receive a call from GAP Friday 8 informing them that -- or alleging that some of the material 8 on which he has based some of his reviews and evaluations 10 including board notifications contained a material false II statement. This is material that was supplied by PG&E. 12 COMMISSIONER ASSELSTINE: I take it that's the 13 thrust of the letter that we got today, based upon a fairly I4 clear reading of it --
~
MR. DENTON: And I believe Friday Larry Chandler 16 informed the board -- and, Larry, you may want to mention 17 anything more about that. 18 MR. CHANDLER: We did provide informal notifica-19 tion to the board and we intended to formalize that if 20 it's necessary, talk to OI who was not available Friday. 21 But we intend to do that today and get it to the board and 22 parties. , 23 MR. MARTIN: I think I can answer y5'ur question 24 now about the early 1974 report. _It's Item 30 in our final 25 inspection report of the Pullman audit. And the issue was 1
,__,I_..___._____.__ _ __ _ ,_
I ! t 24
*1
_the NSC finding listed about seven areas where problems 2 existed in welding and then drew the conclusion that 3' therefore, there is no confidence that weldin'g done prior 4
;to early 1974 was performed in accordance with welding 6 *: '
specification requirements. It's a very alarming finding., 6 COMMISSIONER ASSELSTINE: Yes. 7 MR. MARTIN: , We did a detailed inspection on each e of these seven items and what we have come to find out was 9 the NSC audit finding was tot based on anything they did; it 10 was based on a review of Pullman internal audits where 11 Pullman had done some 183 internal audits,during that time 12 period. And if one reads those 183 internal audits, they 14 found a number of problems in the shielding and purging, 15 use of temple sticks, amperages, that sort of thing. We go 16 through and look at each one of those and conclude that . 17 ! yes, there were some problems; none of them seemed to be 18 terribly significant, but the bottom line being that all of 19 these problems were discovered by Pullman in their internal 20 audit, and we do not draw the same conclusion that because 21 a guy is finding a problem in his internal audit system 22 that you should draw the conclusion that you have no 23 confidence in the welding. ~ 24 CHAIRMAN PALLADINO: Did they -- 25
- COMMISSIONER GILINSKY: You have to resolve it
'.I 25 1 it further than that, you have to know that these problems 8 were resolved.
- 3. MR. MARTIN: That's what we discuss in here; is 4 the detailed resolution of each one. And in evpry case it
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t 5 appears to have been resolved.
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8 So I find that the finding itself was based on 7 simply a catalogue of what the company found in their 8 internal audit program, and which each item by itself isn't 8 . , terribly significant,and there are problems. 10 CHAIRMAN PALLADINO: But they were resolved. 11 MR. MARTIN: Yes. And more significant is that 12 the company was finding its own problems, which is a much 13 more significant cast on this than appeared at first blush. 14 CHAIRMAN PALLADINO: But was the company also 15 resolving the problems? 16 MR. MARTIN: Yes, sir. 17 COMMI'SSIONER GILINSKY: And how did we ascertain I8 that the problems had been resolved? 19 MR. MARTIN: Well, we looked at, I believe, each 20 of the audits. Let me ask Dennis Kirsch who did the 21 inspection. Dennis, are you here? Didn't each of these internal audit reports have the resolution as part of the 23 audit report? 24 MR. KIRSCH: The vast majority of the internal --
" they were not internal audit reports- they were welder audits,
- t. 26 an unscheduled program of auditing welders performing S
welding in the field. They were performed above and beyond the Code requirement. , 4 Throughout the process, the sheet was - .the 6-audit checklist, if you want to call it that -- was upgraded 6 periodically as more was learned. Each finding that was 7 adverse in nature had some indication on the sheet as to 8 what the auditor had done in response to that finding. And
, by that review, I was able to conclude that they had 10 adequately responded or effected corrective action to each 11 of those adverse findings.
12 CHAIRMAN PALLADINO: You said this was not an 13 internal audit? I didn't understand what you meant. 14 MR. KIRSCH: No, sir. An internal audit is a 15 different kind of structured audit program that Pullman 16 uses. This was what they called the welder audit. ,. 17 CHAIRMAN PALLADINO: Was it done by Pullman? 18 MR. KIRSCH: Yes, sir, it was done by Pullman. 19 CHAIRMAN PALLADINO: I just wan ted to understand 20 what you meant. Okay. 21 COMMISSIONER GILINSKY: Was this information not 22 available to this other company that reviewed the findings? 23
- MR. KIRSCH: I would assume that it -was available 24 to NSC. It was certainly available to me and it's still 25 available. I can't speculate on that.
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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report Nos. 50-275 83-37 and 50-32.1 Docket Nos. 50-275 and 50-323 ! License No. DPR-76 and Construction, Permit No. CPPR-69 , Licensee: Pacific Gas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Facility Name: Diablo Canyon Units 1 and 2 Inspection at: Dia*>lo Canyon Site, San Luis Obispo County, California Inspection conducted: November 14-18 and November 28 - December 9, 1983
< Jespectors: d.
- 4 hM S/c99/8'/
, Gp. ernandez, act @ nspector Date Signed
. W A9 9' fM R ss, Reactor Inspector D#te signed
. AM)
D. T. KiWiib', Chief, Reactor Safety Branch 2hrM Dite' Signed Approved by: . 1M9M9 H. L. Canter, Chief Date Signed Reactor Projects Section No. 3 Inspection During the Period of November 14-18 and November 28 - December 9, 1983 (NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25). Areas Inspected: A special, unannounced inspection by regional-based inspectors to perform an in-depth review of selected findings contained in an audit of the Pullman Power Products Quality Assurance Program conducted by Nuclear Services Corporation (NSC), during August - September 1977. Concurrently, the licensee and contractor responses were evaluated to establish whether the outstanding issues identified by NSC were resolved or corrected. The inspection involved 402 inspection-hours by three liRC inspectors. Results: Of the areas examined one item of noncompliance was identified
'(failure to assure that veldinF inspectors are qualified and certified in accordance with procedural requirements, paragraph No. 17).
/d.<0 q
8403060149 940229 PDR ADOCK 05000275 G PM , ATTACHMENT 31
- -- - - - , _ _ _-----~_ _ - , .-,.__ -._- -. -
27 - ( ) ESD-218 (Postweld Heat and Preheat Treatment Procedure) was revis.ed and improved December 30, 1977 to prescribe preheat requirements sad indicate preheat applicability, in addition to the information prescribed on the Welding Precedure Specifications. ESD-264 (Process Planning and Control-Field Process Sheet) was reviewed
. by the inspector. The Field Process Sheets were revised in early 1978 to indicate preheat requirements. Prior to early 1978, compliance with the preheat requirement was dependent on the welder's knowledge of and compliance with the welding procedure specffication and was indicated on the process sheet by the craftsman and QC signature in the welding block, which specified the welding procedure to be used. The philosophy used was that when each signed a block, the signature meant that all applicable procedure requirements had been accomplished.
The inspector concludes that, while no separate and specific procedure for preheating of weld joints existed prior to December 30, 1977, preheating requirements were adequately prescribed by the welding procedure specifications and documented by signature on the welding block of the process sheet, which specified the applicable welding procedure. No items of noncompliance or deviations were identified.
- 30. Criterion IX, NSC Audit Finding 10o:
"The initial results of the welding auditing (from November 5, 1973 to February, 1974) indicate that the following problems existed:
(1) The welders did not understand shielding and purging. (2) Tempil sticks were not used. f (3) Amperages were not within procedure limits (mainly root welds and l tack welds). 1 l (4) Weld procedures were not available, and many welders did not know where to obtain them. (5) The oxygen analyzer was not available or not operative. Also, the time vs. flow rate alternate technique was not used. (6) Oven rod temperature control was not monitored by the welders. (7) Many welders did not understand their duties and responsibilities. Based on a review of the Pullman Power Products welding audit reports and c the frequency of the above-noted problem areas, there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification requirements." NRC Finding: , The inspector's approach was to examine the records of welder audits conducted during the above time period and assess the validity of the NSC I
( as
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( .J finding and Pullman response. The welder audit program is an example of extra effort, not required by the Code, to provide assurance of a quality welding program implementation and effect prompt corrective action for identified discrepancies. The inspector critically examined the records of welder audits performed between November 1, 1973 and April 1, 1974. A total of 183 welder audit records were examined. Each of the above NSC audit statements are addressed below. -
. a The NSC audit statement was that "The welders did not understand shielding and purging." The inspector observed that 23 of the reviewed audits identified problems regarding compliance with the 20 psi and 20 Ffe requirements for gas pressure and flow. Weld quality problems could occur if the gas flow rates are excessively high or low. The vast majority of safety-related stainless steel welds were radiographically examined and the film was reviewed and accepted by a qualified interpreter for code compliance. The audit findings did not indicate that welders did not understand shielding and purging, rather the
'-. findings point out the difficulties which can be experienced when more than one purge / shield line is connected to a single gas source and regulator. In all cases, corrective action was taken to return the pressure and flow rate to the required values.
' The NSC audit identified that tempil sticks were not used. The purpo'se of Tempil sticks is to verify proper preheat and assure that the interpass temperature was low enough to begin welding the next weld pass.
Of the 133 audits examined, fourteen of the audits identified that the weldera did not have tempil sticks in their possession. In each case Several of action was taken to provide the welder with Tempil sticks. the welders apparently told the auditors that prior to resuming welding s they wait until they can touch the weld; thus providingThis assurance is an that interpass temperature requirements are not exceeded. acceptable practice. The NSC u dit identified that asperages were not within procedure limits. Of the 183 audits reviewed, four instances were identified wherein In
- amperages were not within welding procedure specification limits.
each case the welder corrected his amperage setting. A lower than acceptable amperage would result in lack of adequate root penetration or lack of acceptable heat affected zone fusion, which would be seen in a radiograph and may be detectable by surface examination methods, such as the liquid penetrant or magnetic particle techniques. High amperage would result in excessive spatter, a condition which qualified welders would not veld under because welding is quite difficult under high amperage conditions. Further, amperage is not an essential variable specified by the ASME Code, Section IX and is only a supplementary essential variable for material with notch toughness requirements. The NSC audit identified that weld procedures were not available and many welders did not know wher'e'tB obtain them. Welders are reguired to have a copy of the welding procedure at the job location. Of the 183 audits examined, five audits identified cases where the welder did not have a welding procedure. Three of the five cases identified that the welder t
, , - , ,y_ - , . ___----- - _ _ . _ _ _ _ _ , _ _ . , ,,m .- . , , - . . -, - . . . - - - _ _ . ~ . , -
e . 29 g ) ( p In each case the corrective action did not know where to obtain them. was to have the welder obtain a copy of the welding procedure alongThe with an explanation of the location from where they could be obtained. l inspector concludes that the vast majority of welders used welding procedures and knew where to obtain them and that this NSC finding has only minor technical significance.
) The NSC audit indicates that the oxygen analyzer was not available or '
l, operational. Althcugh this was not a required checkpoint, only one l i finding of the 183 audits reviewed indicated a problem with the oxygen analyser. This problem was corrected. Thus, the inspector considers that the welder audit records do not support the NSC conclusion. The NSC audit indicates that oven rod temperature control was not monitored by the welders. Of the 183 welder audit records reviewed, fourteen of these audits identified instances where the welders rod oven temperatures were lower than the 225'F required by Pullman procedure, and did not meet the 225'T requirement. Most instances observed by the auditors identified deviations up to 35'F, however, two audits observed temperatures as low as 150*F. In all cases the welder was required to , 4
. The audits return the defective oven to the rod room and obtain another.
further indicate that a large number of the apparently discrepant findings were due to the thermometer being out of calibration and reading low, thus indicating that the actual temperature of the oven was high'er The primary reason that rod than that indicated on the thermometers. ovens are maintained hot is to preclude moisture entry into the welding electrode coating and, thus, minimize the potential for inducing underbead cracking. Recent industry findings indicate that when the temperature of the weld rod is maintained significantly in excess of the I atmospheric temperature, thus above the dew point, the entry of moisture into the coating is effectively precluded. The NSC finding that rod oven temperature was not monitored by the welders is not supported by the inspector's review of the audits, although isolated instances of ovensthis In addition, being below temperature were identified by the audits. should not be a technical problem because rod is removed from a hermatically sealed shipping container and immediately put into an oven " with temperatures of sufficient value to preclude moisture intrusion. The NSC audit indicated that many welders did not understand their duties and responsibilities. The NRC considers that the reason these welder audits were done was to identify such instances and provide corrective action. Of the 183 audits reviewed, five welder audits indicated that the welder in question did not understand their duties and responsibilities. In each case the welder was reinstructed by the Quality Assurance inspector auditing the welding activities, including notification and reinstruction of the welder's foreman, as applicable. It is important to recognize that none of these were NSC findings, but were instead findings of the Pullman welder audit program, which was designed to detect program weaknesses and provide prompt corrective action during the early phases of site welding activity. ~ 1 In summary, the inspector notes that isolated instances of problem areas were identified and corrected by the Pullman welding inspectors.
30 ..).
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)
- Nowever, the inspector does not consider the aggregate of probles areas to be so pervasive such that support can be given the MSC conclusion that
' "There is so confidence that welding done prior to early 1974 was
.' performed is accordance with welding specification requirements."
No itees of noncompliance or deviations were identihed. i
! 31. Criterion X NSC Audit Findina Nos. 5 and 6:
t Finding 5: "For all inspection processes, there is"so mechanias to
)
provide the inspector the particular characteristic to be inspected; the to , particular acceptance criteria; the particular methods and eq The exceptions to this statement the particular inspection being made. are radiography, where the reader sheet allows the recording of results, (such and those procedures that specify the use of particular equipment as some of the ultrasonic procedures)." The N'
"The inspection pro' cess is generally not auditable.
8 6 t exhibiting an acceptance signature only does not permit Practice if the individual characteristics were examined, i - r e were used for acceptance, and the correct specific th c r ec measuring devices were used. l . N_RC Finding: To resolve this issue the inspector examined the Pullman program procedures in this area, the validity of the NSC findings and Pulleen responses and examined field process sheets to verify compliance with the prescribed Pullman program and 10 CFR 50, Appendix B, Criterion X. The inspector examined ESD-264 (Process the field Planning process and sheets Control - Field do identify, Process Sheet) and observed that and are required to identify, the procedures necessary to perform a The inspector's signature as meant to verify that particular inspection. l the required inspections were performed in accordance with the referenced procedure. . Examination of some of the procedures referenced on the process sheet indicates that each contains numerous inspection requirements and These inspection requirements and crateria are so acceptance criteria. inclusion of each on the field process sheet would numerous that _The inspector considers that t excessively complicate the process sheet.and acceptance crateria on the l inclusion of each inspection requirement j process sheet would decrease the effectiveness, and work process ) continuity, afforded by the field process sheet. I 100 completed field process sheets indicates that l Examination of about ' the required procedures were consistently identified ;ndon the processto be examinations sheet, thus identifying the group of inspections performed by field inspectors. r at ele is _ The NSC finding that the inspection process is lener true if one defines auditability as the ability to verify,~a,fter - -- the I
SY1,'cyl ( ) 1 I i UNITED STATES OF AMERICA S NUCLEAR REGULATORY COMMISSION 3 4 STATUS OF PENDING INVESTIGATION
~
ON DIABLO CANYON - 8 Public Meeting 8 8 Nuclear Regulatory Commission 1717 H Street, N.W., Room 1130 Washington, D.C. ' 11 M nday, March 19, 1984 12 The Commission met, pursuant to notice, at g 10:20 a.m. g4 COMMISSIONERS PRESENT: 15 NUNZIO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Member 16 JAME ASSELSTINE, Member FREDERICK BERNTHAL, Member 17 - STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: i 18 H.E. PLAINE gg S. CHILK ' J. DIRCKS 20 H. DENTON G. KNIGHT 21 D. EISENHUT J. MARTIN 22 T. BISHOP ; t 23 AUDIENCE SPEAKERS: i 24 L. CHANDLER - D. KIRSCH l i 25 ATTACHMENT 32 i
k I 8 1 which says Results, is what you'll find in that document I l 2 when you get it later today. And then we'll have the formal
- 3. meeting on the SSER a week from today. That was'my r-4 understanding.
5 COMMISSIONER GILINSKY: So this is a guide to 6 reading the document? 7 MR. MARTIN: Yes, it is. It's sor t of a preview 8 guide to help you through all 300 and some-odd pages of it.
- 8 CHAIRMAN PALLADINO: I suggmit that we proceed 10
, along the lines that you outlined.
11 MR. MARTIN: All right. As of March 9th, which l'i was the catoff date for this document, we had received 13 219 allegations, and as of today we've addressed 219 14 allegations. During this time period -- let me correct 15 that. As of March 9th we had addressed 219 allegations 16 that we had received from various sources. 17 On February 2nd, we received a 2.206 petition' 18 which was then supplemented on March 1st, which presents 18 many new allegations, additional allegations. We have not 8 dealt with those yet in any detail. 21 So if we take the total universe of allegations, 22 y,.ve dealt with the first 219 or so that we received, and 23 they have been addressed and we're prepared to-discuss them 24 ~ i in detail. 25 A month or so ago we received another installment L
( ) 7
'. 1 in the form of a petition which was supplemented on March 1st.
3 Those two submittals we have not dealt with in great depth. i 3. I can speak somewhat about them, but we have not dealt with 4 r them in depth. As of now, those are the total number of 6 allegations. 6 COMMISSIONER GILINSKY: We have some letters 7 dated today -- or at least one. Have you seen those? 8 MR. MARTIN: No. d COtiMISSIONER GILINSKY: I wondered if there were 10 some new questions raised in them. 11 MR. MARTIN: I haven't reviewed that letter.~. 12 What I can tell you is that in the 2.206 petitions -- I 13 don't want to be too absolute on this, but I've read them and 14 the staff has read through them, and our impression is that 15 most if not all of the technical issues are essentially the 16 same as what we dealt with in the first 219 items. 17 As far as management issues, most of them look 18 the same to me, although there are some different wrinkles 19 on some of them. That's sort'of a non-definite impression, 20 that I didn't see much in the petitions that looked very i 21 different from what we already looked at in a thorough manner 22 in the first 219. I 23 j I'd like to go through the method -- it's on the second page -- that we used, and the reason I want to do this is that there are some who are claiming that all we've i
8
)
done on these allegations is turn them over to PG&E for 2 resolution and then we've sort of spot-checked their 3 resolutions. This is not correct, and I'd like to go through 4 what we did do.
~
S Part of it stemmed from my position of not having 6 a whole lot of background on this plant, and I really had 7 no personal basis to judge one way or the other the allega-8 tions we were getting. So what we've done is examined the
. 9 first 170 or so in considerable detail and just accepted d
to them, looked into them with an inspection team. We interviewe d 11 where we could get a hold of them, the allegers, face tg face 12 if possibles those who were anonymous or didn't want to 13 reveal themselves to us we talked to them over the phone 14 where we could. 15 So the first 170 or so we decided to go into 16 in some depth. We had a diverse inspection team of many 17 - people in the region, a large number of people outside the 18 region who came from IE, NRR, other regions. I think to date 19 we've spent on the order of 7 or 8 thousand man hours, lookinc 20 into this first couple of hundred allegations. 21 Early on, I instructed the team to focus for 22 allegation on two questions. First of all, is it a technical
=
problem for the plant, does it present a safeti problem. 24 - And secondly, does the allegation reveal any significant ' 25 defects or w'eaknesses in the way the plant was managed or [ l
-- . - _ _ _ - - , - . _._ __..-,.._-,r, , , . _ - , , . , _ _ - . _ . _ . . . _ . . . - - - - , - - - - - _ _ . . _ _ _ . - . - _ . - - _ . . _ _ . _ _ , _ _
( I 9 I its quality systems. What I was concerned about is that E many allegations may turn out to be okay technically but 3 they sort of got that way by luck rather than by a deliberativ e 4
. system. So we looked at those questions. ! 5 +
And in our write-ups of each question I think , 6 you'll see it's apparent that both of those issues were 7 addressed. After the first 170 or so t.1at we looked at in 9
, detail and we started forming or evolved sort of a composite 10 picture of the safety and the management questions, we 11 '
started using more discretion on how much depth we looked 12 into things. And the last 30 or 40 allegations or so that 13 looked very similar to ones that we had looked at in depth 14 or did not seem to present any new kinds of issues, those 15 we didn't look into in as great a depth. Many of those we 16 either have or plan on referring to PG&E, and we will look 17 at their responses and do independent inspection as necessary. 18 So we're gradually moving in that direction in 19 areas that we feel we know something about. But that was 20 not the case for the first 170 or 180 items. 21 COMMISSIONER ASSELSTINE: Let me ask you a 22 question about that. I recall that in previous meetings you 23 had said that you had resolved a certain block _of allegations 24 at that time, but the ones that still remained to be 25 resolved were the tougher issues, the more difficult ones.
) 10
, (
1 I MR. MARTIN: Yes.
- COMMISSIONER ASSELSTINE: What's the significance 3 of that in terms of this greater detailed review for the 1 .
4 4 first 170 versus some flexible review on the last 49 or 50
- v. e - ..
3 O MR. MARTIN: We did not take the easier road on 7 I think you'll see when you get the SSER the tough ones. a they're the ones that are either identical or duplicates or essentially raise exactly the same issue that we had already I' looked at in great detail. I COMMISSIONER ASSELSTINE: So for the tougher ones 12 you feel like you did whatever was necessary to answer both I3 of the questions that you had identified? 14 MR. MARTIN: Yes, that's right. Now, if we look 15 at the next sheet of paper that's listed as " Scope of to Allegations," the reason I put this on here is to get some 17 appreciation for in what depth did we look at activities 18 involving PG&E and their major contractors that are still 19 onsite. . 30 This chart is not terribly precise numerically 21 but it is approximately right. Each of the allegations -- 22 some of them just have one issue; some have several, so we've , i 23 lookedintoontheorderof90ormoreallegat[onswith 24 j PG&E, 60 or so with Foley and 50 or so with Pullman, many of i 26 which have multiple parts involving, among other things, the P I l
( 11
' 'I major issues that we have listed with bullets by them, l
a The reason why we put this in here is to give you a' some appreciation of the breadth of the review and why we 4 feel that we are in a fairly good position to draw judgments 5 8
- 6. on the way these outfits conducted their business over the i 4
last several years. 7 It has been my experience over the years that you a don't have to look at too many items to get an appreciation 9 of how a place is run, particularly if there are a lot of o 10 problems. It tends to show up almost everywhere. 11 This is why we feel we have a pretty good basis 12 for saying -- understanding the technical issues at least 13 in a couple hundred allegations and understanding the 14 management picture, irrespective of the number of allegations. 15 Our results so far are listed on the last page and I'll just 16 go through these in general. 17 , We have yet to find any issues of major technical 18 significance. We have found two or three items that did 19 require -- or the utility has elected to make minor changes 20 in the installed condition of the plant. We did not argue 21 about that. There are at least two out of those three items 22 that probably would be arguable as to whether they needed 23 to do it or not, but they did. So that's why de say 24 ~ there's been no significant rework. 26 We think we do have an accurate understanding of
12
)
I I the way the place was managed and the way the quality a systems have performed over the years. And I think sort of 3 a composite picture of what we found is that there have indeed been lapses occasionally in their management and i
- 5 i quality systems in the constructi'on area. However, on the 4
, whole, these seem to have worked reasonably well, and when 7 there have been lapses they seem to have corrected themselves e in terms of internal audits and that sort of thing. And 9 I think that's our bottom line conclusion. 4 to CHAIRMAN PALLADINO: What do you mean, they seem 11 to have corrected themselves? - 12 MR. MARTIN: For example, there may have been a 13 problem in drawing control, but a few weeks or months later 14 i one finds that there was an internal audit done that raised 15 it as an issue and it eventually got resolved using the 16 internal processes that -- so that there were problems that 17 tended to get found by the quality and management systems 18 ~~~ that are set up to do that sort of thing. 19 So I think the bottom line is that we have 20 reasonable confidence that the Licensee and their contractors 21 acted responsibly over the years, and that at least in the
- - - * - ' - - - - = - --
22 first 219 allegations we haven't found anything that constitute s significant comment on the quality of the as-constructed plant. 24 - COfiMISSIONER GILINSKY: What is the relation of 28 this, that you have described, to the earlier review that led
y {,
! 13 t *1 to a Board notification on at least some of these items, at a ,
least on the Pullman audit? You said earlier that people got 8 the impression that we just turn things over to the company.
-4 [.
It does appear at least in that case that the . 6 . conclusions wEr;e made on the basis of what was re j 4 the company or what was in hand at that time in the NRC files . 7 MR. MARTIN: You mean the NSC audit? In that ; 8 what you're referring to? ' 8 ! COMMISSIONER GILINSKY: Right. .
', 10 MR. MARTIN: t Yes. I was very careful b3.re-read 3 11 the transcript of previous meetings on that, and I thin'k what ,
12 i we said to the B'oard and what I told the Commission is that I3 the original contention that was made on that issue -- all I' the staff did was look at the original audit and the answer l 15 that PG&E and Pullman made back in 1978, and we stated that [ 18 it looked like both Pullman and PG&E responded properly to II ' all of the audit findings. t 18 ! There were two or three of them that didn't quite 1 I' look right to us, and we did some independent inspection. . That was the filing that we made to the Board and, I think, advertised it that way. ; 22 Subsequent to that -- and this is listed as one ' of these allegations, number 68, -- the alleger, being me, 24 decided to look at that in much more depth. The background 25 on that is that decision was made prior to getting many of
-- 14
' ~
1 these allegations. I was worrying a little bit, being new 3 in the region, how do I certify that a plant has been built 8 right? What personal basis do I have for deciding that?
~
4 The Pullman audit -- 8
,. . := -
1 COMISSIONER GILINSKY: I don't see that in e Number 21. Is that, you say, Number 68? 7 MR. BISHOP: It's in the public document. 8 MR. MARTIN: That's just the sensitive part. 8 ! So I decided -- and it is covered in 21. So I decided to
. 10 look at it in more depth, so we went and did an independent 11 inspection on, oh, 50 percent or so of the more significant 18 issues that got raised in the 1977 NSC audit. And in part, is that is the basis for the conclusion I just gave you.
4 14 I That is included as a single allegation of, you ' 16 l know, 20 or 30 parts that we looked into in some detail. 16 CHAIRMAN PALLADINO: And what did you conclude? MR. MARTIN: We concluded that there were no major significant problems proceeding from that NSC audit. We did I' ! find one open item concerning qualification of inspectors , that is still open that we have some additional work to do, ' e 21 but in balance, the detailed inspection confirmed the more [ 22 superficial inspection or review that Pullman and PGtE did l 23 in fact respond properly to those audit findings. ' 24 COMMISSIONER GILINSKY: Is that the allegation 26 that listed inspection report -- l i
. _ , _ . . . . _ . _ , . . _ - . . . . _ . . . . _ , _ . _ . . _ ~ . _ _ . . _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ . . _ . . _ _ _ _ _ _ . , . . _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . . _ _ .
. s o
, Problem Statement
~
Allegation f(s): . 2 ~5 / - - 5 ATS 5 No.(s): ~ R$i(s): is document lists (or directly references) each allegation or concern brought to the attention of NRC. personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview). Problem Statements (use extra sheets as necessary) A11eastion# Verbatum Statement or Reference l gg ToIMT /NTERVEMORS'/bortoAJ jf 2/2ajff nu eenrisN "97 (psce .2g3 Commentary
. TJff AlLK647//M /9MD H7~ F A77Ac//kWG) ypgg nit of THB DatuMNTAT/W
*f s VA/Ln8L5 #7~ 7~#ff 77MA Date This Statement was Completed /////
'ffchnicalReviewerSignature .
L____----u___,____ ____. _ _ _ _ _ _ . _ _ . . _ . _ _ _ _ _ _ _ _ _
yblN', ,NTERVEKOkS' fYIoTloN oF2/1.:n,) ' tempersture for the hydrostatic tests. (!d.,at pp.25-26.)
# A*3 / 9 _
In 28 cases, Pullsun's hydrostatic test procedure data form ;s inconsistent with PG1E requirements. Since this form guides the test, the distinctions meant relaxed test conditions that disqualify Pullman's results. For example, in one test Pullman's procedure only had a pressure of 2485 PSIG, when PG&E's acceptable ministan us 2812 PSIG. (Id., at p. '26. ) - - J
- 98. Post-1978 hydrostatic retest:Md not consistently have a signed QC field pipe release, despite other records claiming that QC had verified the results. (Id.) -
- 99. The problems with hydrostatic tests offer another example of management harassment of QA personnel for comunicating with the NRC. In May 1982 after Mr. Hudson spoke extensively with NRC representatives, Mr. Karner expressed anger at the length of the interview. Soon afterwards, Mr. Karner threatened to get rid of Hudson, the auditor. (Id.)
D. Vendor Quality Assurance The workmanship of vendors who sell sensitive parts and components can be
. acre significant for public safety than the construction performed on-site. As a result, each licensee's audit, surveillance and inspectica prograin sidst extend to the vendors' own facilities. When shoddy work slips through anyhow, it still must be fixed if uncovered on-site. The program for QA oversight of Diablo Canyon
~
vendors broke down on both counts. At least one firm, Microsurface Engineering, was a longtime member in good standing on the Approved Vendors List, although in 1981 the internal auditor discovered the ccmpany only had a taken QA program. Second, PG&E repeatedly refused Pullman inspectors permission to write reports on significant quantities of cracked welds that slipped through ~from two vendors,
~
Boston Bergen and American Bridge. One QC inspector stated that some of these
~
welds are "truly abominable" and "so ragged that they will tear your clothing if hp __ _ . _ _ . _ [
;g.,
p p 24 g l Mcf M p7 2.
- of C HH Il W ' )M0 .
'75 pprwuof Uz2Aff procedure ESD 229. Fundamental data, such as the type of fluid pressure
'% and temperature, simply is missing (Jd., AAR #2).
- 69. , In 28 cases. Pullman's NT procedure data form does not match PG&E requirements. This fo'ra is the guide used to conduct the d test so the distinctions translated into different test conditions that -
disqualify the results from Pullman's hydrostatic test. To illustrate. in one test Pullman's procedure only had a pressure of 2485 PSIG. when -- PG&E's acceptable minimum tes 2812 PSIG. - L.--. -
- 70. The absence of backup documentation continued after 1978.
From March 1978 to April 1980. there were 14 hydrostatic retests without a signed QC field pipe release, dispite the conclusion by Quality Engineering in the test records that QC had verified the results (Id, AAR #3),. 71 . The problems with hydrostatic tests offer another example of management harassment of QA personnel. During the May 1982 NRC inspection, I spoke extensively with. NRC representatives. After the interview Mr. Karner expressed anger at'the length of the meeting. At a later. meeting, during this general time frame, he threaten to get rid of me. l IV. BREAKDOWN IN VENDOR OUALITY ASSURANCE. Although I was not as actively involved with vendor QA as with special process and hydrostatic test precedures. I observed the symptoms of a generic QA breakdown a fter becoming familiar with two examples of QA violations involving vendors. One case involved a vendor
~
that calibrates micrometers, a precision measuring device for Pollman tools and the impact of weld repairs, aeong other functions. Al tho ugh the vendor had a clean bill of health and was on the Approved Vendors Y/pbr
i ~) . Preblem Stctement Allegation f(s):. 2 '$ 1 - ATS No.(s): i k 2 BN(s): This document lists (or directly references) each allegation or concern brought to the attention of NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the coassentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for eyample, a line concern was received in an interview). ProblemStatements(useextrasheetsasnecessag A11eastion# Verbatum Statement or Reference 2 ~$ 2 SEE JoINf INTERVEMoMS'/WortsA l W 2/22/8f AUEGAT/CAI
- 9 8 (jo/)S E 2 8 )
Commentary TKAJ4FGAT/#N AAM? THE A77AC/V/*!fM A4E #4 W 7/E j>ucuAtr/JTAT/dAl AVA/l A$f #77f/J 774t5. Date This Statement was Completed ' AIf' TecpalRevieweySignature
@@D ATTACHMENT 22E
w cs y b-( .-
) .
.- ~ gowwrenwoW proTuon of 2/22/ot i
temperature for the hydrostatic tests. (Id.,at pp.25-26.) h In 28 cases, Pullsun's hydrostatic test procedure data fors, is inconsistent with PG&E requirements. Since this form guides the test, the distinctions meant relaxed test conditions that disqualify Pullman's results. For example, in one test Pullman's procedure only had a pressure of 2485 PSIG, when PG&E's acceptable ministan was 2812 PSIG. (Id., at p. 46. ) - 98. gy 4 Post-1978 hydrostatic retests did not consistently have a signed QC field pipe release _, despite other records claiming that QC had verified the results. (Id.) - :
- 99. The problems with hydrostatic tests offer another example of management harassment of QA personnel for cormunicating with the NRC. In May 1982 after Mr. Hudson spo' - - *--*4aal u win NRC reoresentatives, Mr. Karner expressed anger at the length t rid of Hudson, the h&
D. Vende The workr a more signific; As a result, eac tend to the vendors' i 1 must be fixed if u n
, vendors broke down on both counts. At l east one r i na, n.s. . .. .__ _ _, 'ing, was a longtime member in good standing on the Approved Vendors List, although in 1981 the internal auditor discovered the company only had a token QA program.
Second, PG&E repeatedly refused Pullman inspectors permission to write reports on significant quantities of cracked welds that slipped through fima two vendors. Boston Bergen and American Bridge. One QC inspector stated that some of these welds are "truly abominable" and "so ragged that they will tear your clothing if 28 - ggg
83rs;.#2 $2 % pnes 2g gp'. Ic1Arn'T #1- .
) -
rp 72 nu770H *PW**Ilf i . procedure ESD 229. Fundamental data, such as the type of fluid, pressure and temperature, simply is missing (1,d., AAR #2). s -
- 69. , In 28 cases, Pullman's NT procedure data form does not match PG&E requirements. This form is the guide used to conduct the test, so the distinctions translated into different test conditions that disqualify the results from Pullman's hydrostatic test. To illustrate, in one test Pullman's procedur,e only had a pressure of 2485 PSIG, when--
PG&E's acceptable minimum was 2812 PSIG. - 9 . I 70. The absence of backup documentation continued after 1978. From March 1978 to April 1980, there were _1_4 hydrostatic retests without a signed OC field pipe release, disotte the conclusion by Quality Engineering in the test records that QC had verified the results (I,d. AAR #3),.
- 71. The problems with hydrostatic tests offer another example of management harassment of QA personnel. During the May 1982 NRC inspection. I spoke extensively witJt NRC representatives. After the interview Mr. Karner expressed anger at' the length of the meeting. At a 1.ater meeting, during this general time frame, he threaten to get rid of me.
IV. BREAKDOWN IN VENDOR 00Al.ITY ASSURANCE. Although I was not as actively involved with vender QA as with special process and hydrostatic test procedures I observed the symptoms of a generic QA breakdown after becoming familiar with two examples of QA violations involving vendors. One case involved a vendor that Calibrates micrometers, a precision measuring device for Pullman tools and the impact of weld repairs, acong other functions. Although .. the vendor had a clean bill of health and was on the Approved Vendors
------_____-,-=----------,-,n-._ . _ _ _ _ --- - -- --
. .S. NUCLE AR CEGULATCGY COMMISSI3.
Office cf Inspector and At ditor o.w .e . ,ie ... Jul y 16, 1984 Report of Interview Thomas Bishop, Dire 3 tor, Division of Reactor Safety and Projects Region V. I upon interview cor@terning various allegations of false statements raised by " l the Government Accountability Pr:dect (GAP) and' an allegation that he made a l false and/or misleading statement to the Comissioners that could have I influenced their decision as to whether to pemit low power testing at the Diablo Canyon nuclear facility, provided the following information: As to the specific allegation that Bishop, on March 26,1984, made a 41se and formisleadingstatementbystatingthattheNRChadnotyetbeenprovided additional supporting material for an allegation concerning hydrostatic test . records. Bishop first pointed out that he qualified his comment to the o Comissioners at the time with the phrase "to my knowledge" (Exhibit 1). In
. any event, at the time of his statement, he was not personally aware that the questioned materials had, in fact, been received by Region V. No possible i-purpose could have been served by hiding the fact that they had been received. .
His only purpose in even mentioning the matter was to make it clear to the . , Comission that Region V had not examined all of the GAP documents, so far as
- Bishop knew. .
i. After the issue was raised by GAP in their 2.206 petition dated April 12, effort was made to reconstruct what had happened to the documents within
%gion V. It was establi.shed that they were received by Region V on March 5, 1984 (Exhibit 2). Bishop was on travel that day. Apparently, the 17 enclosures plus the questioned " Exhibit 4 to Attachment 2" and other documents .
Isid around the office for a few days. Someone, it is not clear who, then reproduced the first 17 enclosures, " Attachments 1 thru 17." The original
" Exhibit 4 to Attachment 2" was not received by Bishop. The document was finally retrieved from the original package which had ended up in Lewis Shollenberger's office (Regional Legal Counsel). i P::garding the specific concern about hydrostatic testing, based on sumaries !
provided elsewhere in the GAP 2.206 petition of March 1,1984, and other allegations previously received, the issue was already within a " body of knowledge Region V already knew something about." The allegation, therefore, was not being ignored. l l
. . . . . . . . . . . July 10, 1984 ,, Walnut Creek, CA ,,,,, 84-26 w
Ronald M. Smith. Senior Criminal Investigator. OIA O,,, a.c i.i.e July 11, 1984 TMi$ DOCUMENT #5 PROPt m7 w Op Nmc 48 LOANic TO ANOTHE m AGE NCY 47 AND iTS CONTENTS Amt NOT
- OUTSsDt THE mt CE eveNG AGE NCY wiTMouf PE RMISSION OF THE Of s sCE Op eNSPECTom ANO AUDITOR.
ATTACHMENT 23 eio s7i l , _
( . ) DIAPLP CANYON GAP ?.706 PETIT 10P OF FEBRUARY ? AND FARCH ), 1980 AND GAP LFTTER OF MARCH 10, 1990
- 1. PPEVIOUSLY ADDRESSED AND CLOSED 08
- 2. PPEVIOUSLY ADDRESSED: NOT CLOSED 56
- 3. NEW WRINKLE ON DLD ISFI'E 87 TOTel.LY FEW ISSilE AF D.
IPSUFFIC?ENT INFDPrAT!0?' 6! vel; V,4i'r 11 5. TOTAL 318 NO ITEM REQUIRES RESOLUTION PRIOR TO CRITICAliTV / I.0W POWER l O PARCP ?F, loch ATTACFEENT 24
s
. )
1 I UNITED STA7 ES OF AMERICA 2 NUCLEAR REGOLATORY COMMISSION 3 4 DISCUSSION /POSSISLE VOTE ON DIABLO CANYON 5 CRITICALITY AND LOW POWER OPERATION 6 7 PUBLIC MEETING 8 9 Nuclear Regulatory Commission Room 1130 10 1717 H Street, N. W. Nashington, D. C. 11 Friday, April 13, 1984 ' 12 13 The Commission convened, pursuant to notice,
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14 at 2:15 p.m. 15 COMMISSIONERS PRESENT: 16 NUNZIO PALLADINO, Chairman of the Commission 17 VICTOR GILINSKY, Commissioner THOMAS ROBBRTS, Commissioner 18 JAMES ASSELSTINE, Commissioner " FREDERICK BERNTHAL, Commissioner 19 20 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: 1 l 21 S. CHILK H. PLAINE I 22 T. DEVINE N. COLVER 23 C. STOKES H. DENTON 24 D. EISENHUT J. FARTIN 25 . TAYLCE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C. 20006 (202) 293 3950 ATTACHMENT 25
)
43 I company at stake that Mr. Naymark is talking about nobody 2 paying him for coming in and talking about it. I would 3 suggest the Commission issue a rather stronger invitation 4 and, if necessary, consider a subpoena. I think Mr. Naymark 5 ought to come here and discuss this report. 6 CHAIRMAN PALLADINO: I wonder also, and maybe I this is something I want to asked PGEE, the extent of their 8 interest in resolving this question. Perhaps when we get 9 PG&E up here we ought to explore the extent of their
. 10 interest in seeing this matter resolved because they had -
11 hireo tne organization in the first place and their 12 interest in resolving the question may lead to an , 13 arranagement that would be satisfactory to everybody. 14 Do you want to do that now? I would suggest we 15 wait until we get them up here. 16 COMMISSIONER ASSELSTINE: That would be fine. 17 CHAIRMAN PALLADINO: All right. 18 COMMISSIONER ASSELSTINE: Jack as to leave i,n a 19 few minutes and mayoe we ought to cover the other things we 20 want to cover with him. 21 CHAIRMAN PALLADINO: Yes. I would be interested, 22 Jack, before you leave in any comments you have on the 23 comments made by Mothers For Peace and GAP and also any 24 comments you might have on their April 12th submittal. 25 COMMISSIONER ASSELSTINE: In connection with TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, DL 20006 (202) 293 3950
44 I tnat, maybe Jack could also give us an update on what he 2 has done over the past couple of weeks in terms of the 3 allegations, further discussions or meetings with people 4 who had provided information and what, if anything else, he 5 can report on those. 6 MR. MARTIN: What I have done since the last j
~
meeting is to try to get caught up some. At that time we 1 8 had gone through the first 219 allegations and we just had 9 not in any disciplined way gone through them. We had read 10 through them and had drawn preliminary conclusions that 11 they either were not new or were not significant or, if 12 they were new, that they didn't exceed the criteria that,'e w 13 had in the SSER. 14 Since then I have had the staff go through and 15 draw up in a more systematic way each of the allegatidns 16 that we have received in the February 2nd, March 1st and 17 March 23rd letter and to draw up a chart showing where they 18 fit in and which ones we will look at and which ones we ! 19 will refer to PGEE and again confirm that they don't exceed 20 our criteria. That is not a whole lot new to report, but it 21 does involve an awful lot of work to do that. 22 Secondly, we were somewhat concerned as of the 23 last meeting since GAP was on record as refusing to talk to 2 us any more. So we went back and had discussions with them 25 as wny don't we rekindle these interviews and discussions TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHINGTON. D.C. 20006 (202) 293 3950 1 l
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I )
- - 45 I and that worked out satisfactorily. There wasn't too much 2 argument.
3 So since the last, oh, I think we started a week 4 or so ago, we have had several discussions down at the 5 site that, as far as I know, are still going on. They were 6 going on yesterday, including a plant tour where some of 7 tne allegers offered to point out problems that they could 8 do best by actually going in the plant. So we arranged 9 that. So there have been lots of discussions and a plant 10 tour. 11 I have not reviewed the transcripts of the last 12 week or so's information and all I have are telephone , 13 reports, but I gather that for the most part the 14 discussions have centered around further elaboration of 15 things that are in affidavits, in some cases new items. 16 _Although tne GAP letter says they pointed out I believe 17 eight deficiencies, we noted down the deficiencies, this 18 was Wednesday, and yesterday the staf f looked at each one 19 of these and has concluded, at least preliminarily, that M none of them violate any requirements. 21 So at this point we have no new specific safety l 22 issues that look lixe they are of immediate concern for 2'l purposes of this decision. 24 Things have gone slowly in these meetings 3 because I think both sides are being very caref ul to make TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON. D.C. 20006 (202) 293 3950
{ ] 46 I their points for the record. So the record is replete with 2 very exhaustive exchanges, and we will continue. 3 I guess as far as what the people had to say ; 4 this morning, Mr. Devine is a pretty fast talker, so I f 3 didn't get all that down. So I guess I would really rather 6 not give snap Judgments on these things. I did~not hear 7 anything tnat we had not already dealt with one way or 8 another. I don't mean resolved, but dealt with and have 9 seen and included and considered. In many cases they are 10
.i items that we conclude we don't have to deal with now. We -i 11 discussed all this at the last couple of meetings. !'
12 CHAIRMAN PALLADINO: Of the items that you'say , j 13 are not resolved, are there any of them that need to be 14 resolved before low power? - 15 MR. MARTIN: No. That is what I am saying, no. I 16 guess I notice a couple of statements in here that are just 17 wrong, but I would rather not get into a bickering contest. 18 I got this this morning and haven't really digested it. . 19 COMMISSIONER ASSELSTINE: That is the GAP letter,
- 20 the one that came in yesterday?
21 MR. MARTIN: Yes. 22 COMMISSIONER ASSELSTINE: Is it the staff's 21 position then that as far as all of the allegations, even 25 up through and including that letter is concerned, that it 25 may not have documented an analysis in all cases, but you TAYLOE ASSOCIATES 1625 i STREET. N.W. - $UITE 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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l e e W ATTACHMENT 26 l
C. w:r wD* T~~r * , EfH$* $ r g My name is Richard D. Parks. I am submitting this affadavit to document the discrepant conditions identifie'd, and corresponding violations of time l opplicable codes as a result of the plant tour conducted on April 33,1964 with D. Kirsch and G. Hernandez of Region V, United States Nuclear
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Regulatory Commission (NRC) at the Diablo Canyon Nuclear Power Plant. . . I and three witnesses accompanied the NRC to provide " bands *on"
- examples I
i of non-compliance with regulations, specifications and codes that form the
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basic cornerstone of a comprehensive Quality As surance/Ouality Control program. tification Ea ch example identified to the NRCHras s ubs equently "ta gged" for id and a " report sheet" was filled out by the NRC. The " problem description" is a cuote from the report sheet. The examples identified that violated , npplicable codes are discus sed as follows: t' ITEM al . Tag *2: Elevation 116 Unit 1 Reactor Building. Line Designation NO.52-254-13, in the area of Pres surizer and Reactor Coolant Pump 1-2. P r oblem De s c riotion: Weld attaching Safety Injection A cumulator line to nozzle of the cold leg line (NO.52-254-10). On the side , facing .. Reactor Coolant Pump (RCP) is a grinding gouge in the pipe at D2e l pipe-weld interface approximately 3/8 inches long,1/8 inch at ATTACHMENT 27
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' widest point and 1/16 inch deep (dimensions as visually determined by NR'C Inspector - no measurements taken). Additionally,'there appears to be a slight amount of undercut at two locations. The undercut is approximately 5/8 inches on the weld side facing the RCP and approxi-mately 1 inch at 12D' from the side away from the RCP. . .
Code Violation: American Society of Mechanical Engir.eers (ASME) Section ID, " Rules for Construction of Nuclear Power Plant Components - 1977 edition,-Division I General Requirements. Subsection NB, " Class 1 Components", para NB-4424 " Surfaces of Welds". ,
"As-welded surfaces are permitted, and for piping the appropriate stress indices given in Table NB-3683.2-1 shall be applied. However, the s urface of welds shall be sufficiently free from coarse ripples, grooves, overlaps, and abrupt ridges and valleys to meet (a) through (f) below: .
(a)... l
<b)...
(c)Undereuts shall not exceed 1/32 inch (D.Smm) and shall not e ncrea':h on the required section thickness. (d)... - W
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(e)... '
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(f)1f the surface of the weld requires grinding to meet the above criteria, care shall be taken to avoid reducing the weld or base
, rnetal below the required thickness."
-The discrepant condition identified-by the witness vioictes the code receirements with respect to being " free from coarse rippies, grooves, overlaps, and abrupt ridges and valleys to meet (c) and (f)."
3 TEM [2. Tar #4: Unit 2 Reactor Building, Elevation 135, Support 97-3R in vicini:y of RCP 2-3. Problem Des cription: " Excessive overweld has caused excessive shrinkage of SS line. This was supposed to be a full penetration weld with fillet cap and is as specified. The overwelding can damage the pipe because calculations don't account for residual stresses caused by such overwelding." Code Violation: United States of America Standard (USAS) B31.7-3969 _
" Code for Pressure Piping - Nuclear Power Piping" (note: this standard now is known as ANSI-B 31.7), forewa rd " FABRIC ATION REQUIREMENTS AND THEIR CORRELAT3ON WITH DES 3GN", page XVI paragraph 5.
"Even hanger attachment details are covered. For Class 1 piping, complete penetration welds are required. The designer must consider all stresses in the attachment as well as their 'effect on the pressure
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The welds in question do not conform to the stated intent of the *
" Nuclear Power Piping" code with respect to the residual stresses Induced by the overwelding. It is the concern of this particular anon-ymous witness that these ' residual stresses should have been but were not a factor in the design calculations. - -
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2 TEM 43 Ta c f 5: \ Unit 2 Reactor Building, large restraint wall attachment (around surge line), beneath Unit 2 Pressurizer . Problem Des cription: "Shopwelding is supposed to conform to AWS I l Dl .1 sta ndards. The inner welds are excessively rough and of s_uch a profile that they would not conform to AWS Dl.3 The welds are ragged." Code Violation: American Welding Society (AWS) Structural Welding , Code - Steel, paragraph 8.15 "Ouality of Welds", subparagrap . .
"Vis ual Ins pe ction". "All welds sh a ll be visually inspected. A weld shall be acceptable by visual inspection if it shows that 8.15.3.1 -The weld has no eraeks 8.15.3.2 Thorough fusion exists between adjacent layers of weld metal and between weld metal and base metal M
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, 8.35.-3.3 All craters are fitted to the full cross.section of the weld .
- 8.15.1.4 Weld profiles are in accordance with (para.) 3.6
[ weld profilij " The weld in ques tion does not conform to the requirements specified in paragrapli 3.'6 [ weld profile @ or the evident thorough.fesion requirements as stated in B. 3 5.1.2 ITEM #4 Tac #6: Unit 2 Auxiliary Building, area GW, elevation 115, line No. 2,52-265-8 (Containment Spray Discharge Pipe - 4 lug attachments between 5 and T line.) Item De s cription: " Lug attachments 7.re called out to be 1/2 inch fillet welds on three sides. Actual size is 7/16 inch fillet or les s." Problem
Description:
" Actual size is alleged to be less than or equal to 7/16 inch which is 1/16 inch less than required. The excessive weldinE used in the design of the lugs attachment welds, when welded to Schedule 10 stainless thin wall pipe, has caused excessive shrinkage.
The excessive shrinkage causes residual stresses in the pipe which has not been accounted for in the design or stress analysis. The position of the clamp is such that there is a torsional force applied to p m ee me we e e * # * " * *
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o [ o (~ i 6. the lugs, because the clamp car.not contact the wall of the pipe due to the shrinkage. This torsional force is not accouoted for in the - design and comprmmises the pipe integrity." Code Violation: R efer to " Code Violation" discussion in " ITEM #2, Ta g #4". - The welds in ques Ion do not conform to the stated intent of the
" Nuclear Power PCping" code u-ith respect to the residual stresses ind.uced by the welding or the torsional force applied to the lugs due l
to exces sive shrink.a ge. It is the concern of this particular anon >mous witness that these s tresses ,should have been but were not a factor in the design calculations. ~ l ITEM #5, Tar #7: Unit 2, Auxiliary Building, Area 2H, support 413-131R around CCW line. Pr oblem De s cription: "Eight lug attachment welds are required to 6e full penetration welds on three sides. Actual weld is not a full pene-tration weld, but is, instead a fillet weld, contrary to the design." _ Code Violation: American Welding Society (AWS) - A2.4 - 79
" Symbols for Welding and Non-Destructive Testing," paragraph 9.0
" Groove Welds," s ubparagraph 9.2.2 " Complete Joint Penetration Required." "When no depth of groove preparation or effective ~
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- throat is shown c= the weldiog symbol for single-groove and symmetrical double-groove welds, complete joint penetration is required."
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\ Symbol pr ovided on " Detail"
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for weld (s) in question. I . PG and E bas stated in their letter, DCL-84-040, "The. . weld . ( symbols used at Diablo Canyon are consistent with the standards specified j 930, 146.20, , in AWS. .." and in an Interoffice Memorandum (file no. CA2) dated 0:tober 25,1983 that "all pipe support as-builts issued 15, 1983 should have 11 by Ge neral Construction after October weld symbols in conTMm c e with AWS A2. 4. "
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The welds in question were incorrectly performed because of lack of i proper interpretation of the weld symbol utilized on the design drawing. It is the concern of this particular anonymous witnes s that this discrepancy provided an example of code compliance violation due to These particular welds a lack of intimate knowledge with AWS A2.4. had been inspected and accepted by Pullman Quality Control and PG and E
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Ouality Control prior to the discrepancy being identified by a Pre-Inspection Engineer. . 4 S
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