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I 'AAME: _MII343060 PAGE 25 550 DCMM DOMOCK ([ 551 Mr. PATTER 50M. ~Mr. Yin? 552 Mr. YIM. Thank you. 553 Mr. Patterson and Mr. Panetta, thank you for your { 554 invitation to testif, 555 My nana is Isa Yin. I an a senior,Mechnical Enginear in 4 556 XRC's Region III. Division of Reactor $afety. 557 Relative to the Diablo Canyon Xuclear Powerplant 558 investigation effort, my assignment was to follow uP on some 559 of the allssations made by Mr. Charles Stokes. The sPeeific 560 investigation areas were restricted to site small bore 561 piping suspension system design control. 562 However, due to hardware deficiencies observed during 563 plant walkdown, the licensea design cont ~rol naasures for 564 1arge bore Piping system were also included as Part of the 565 overview inspection and evaluation. My inspection effort 566 was carried out Pe riodically-f rom November. 2 9, 1983 to May 567 2, 1984. ~ 568 My testimony before the XRC Commission hearing conducted 569 cn August 2, 1984 for the issuance of Diablo Canyon. Unit One 570 full power operating license focused on four pain issues. 571' Tirst,_ the staff's handling of inspection findings had not 572-been forceful and thorough. Defective Programs such is the 573 ensite quick change of Piping restraint design by a few 574 appointed site individuals and the onsite Project f \\. e
PE4') MAME: HII243060 "^** 575 Engineering Group design activities, which had been in ( 576 violation of nany regulatory requirements for substantial 577 Periods of time, were allowei to continue until June 1984, 578 When PGCE decided to abolish.thkse practices. ?* 579 .:"**.Maving neglected the implementation of a 2A Program for 580 years, the adequacy and effectiveness of the latest prograa ,581 upcz ade-renaissa ques tionable. t e he -: - .?. ?. 582 second, the Peer p.eview Team' did not
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583 of the seven license conditions that were instigated by me, N andrequiredgolutionprior 584 to the Conkitsion 's issuance of f 585 a full power license. 586 The tean reports contained nostly undocumented reviews ani 587 casual observations. There were cases where the inspection 588 sample selected was extremely small, whera prob' lens 589 originally identified continued to exist, where reviev 590 criteria were compromised without technical justification. 591 and where team failed to address the specific program 592 deficiency issues. 593 Third, the nanagenont and acceptance of the Independent 8 Design Verification Program {f IDVPJ were regrettable, The 594 A / 595 OPEG's technical review adequacy and overall 2A program 596 neasures were passed by IDVP and accepted by the staff. 597 The same areas were inspected later and had resulted 100 598 percent reevaluation of small bore pipe support computer ~ 599 calculations and the abolishment of OPEG design 1 I i
I j RAME: MII243D60 PAGE 27 t 600 responsibilities, ] . (~ 601 The dellowup review of my 29-page Concern Items on IDYP 602 Ivaluation of large Bore and Small Bore Piping and pipe 603 Support. Design' performed by the Special Review Team, 604 organized,on the-spot,.did.not fully addr'ss my concern of e 605 the apparent insufficient progran scope and review depth: to 606 resolve the: seisnic-design problems that had led to the 1 607 connission's suspension of a low power license in Xovember. 608 1981.
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{1'i;, even though my 9A program insP,ection, allegation 610 investigation, and technical review findings had resulted in 611 excess of two man-years followup effort conducted by the 612 peer Review Team from March 30 to. July 11, 1984, my desire i 613 to participate in the resolution of the license conditions 614 with the team was granted but nade lupossible due to 615: concurrent worF. activities. 616 I subsequently nade requests {ne to carry out follovup 617 observations on Diablo Canyon prodect organization and programchangesj(,two 618 to review specific dat( base from 619 which the peer Review Tean drew its favorable conclusion on t licenseconditionsp{hree to continue the interrupted 620 the 621 review of IDVP technical naasures wt loud officap and F / 622 our to be given opportunity to review Reedy records which 623 had concluded that there was no design 9A breakdown at CPEG. 624 All ny requests were denied. p. 8 \\
7_. v I e HAME: HII243060 PAGE 28 625 During the August 2, 1984 Commission hearing, ({ I stated 626 that I believe additional investigation and insp ection 627 effort is warranted to properly close out identified areas 628 of concerns. -I beideva this-could be accomplished in three i 629 to dive weeks...This foilowup inspection would provide the 630 Commission a clearer picture of the extent of the problam'. or 63 1 the lack of problem. ' '. $ o r n t er' i C 3..- 632 I still believe in the above statenant today. 633 Iet ne sust add a personal note. If the NEC P.egion III ( 634 nanagement body,- whon I report to for the past 10 years, 635 would assune the responsibility of evaluating OLNA issues 636 identified by me, Am,assassing the PGCE's correct action 637 taken in the Pasty and that maybe required in the future. I 638 am sure that the Diablo Canyon project will be licensed in i 639 compliance with XF.C s regulation without further delay and i 640 uncertainty. 641 ThanX you again for the opportunity to testify. I shall 642 truthf ully answer any questions you any wick to ask 643 IIhe statement of Mr. Yin follows t ] 644 j } 645
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\\, i MAME: MII243060 PAGE 32 721 effort to add ess his concerns aFout the adequacy of the ( 722 seismic d sign work and the erliication efforts, 723 Mr. PATTER 50X. Mr. Yin, did you receive a fair review, c: 724 ' did they connent to your satisfaction? 725 Mr. YIX. I did not receive a f air review by the staff, 726 My inspection report consists of 160 pages of write-up, and 727 I would say 9 Percent of theh consisg i problems or 728 violation itens. 729 g t is full of specifics, dealing with specific Sih s;;.0anfthe 730 violations at the Architect Engineer's Office. 4% 731
- d-the response from the staff is of a general. type.
They 732 did not specliically address every single issue and every W W 733 single Aten have identified. 734 nr. PATTER 50X. How about the peer ' review proup? 735 nr. YIX. T i '- - -. 'i- , -
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Tha peer review 736 proup only addressed certain itens,. sed.
- hey pulled out the 737 significant itens and put.sA i he limited license 7 J738 c o n di ti ons,
gg, Np1N $W bg,~ Thefa were six or seven Atens,c l 739 2-lhins au v un But _ 740 in addition to the six or seven itens A _ _,;1',;;;,;- e 7,,;, ) 741 l '- -== ww u r - w=w 17 " L iWali-n:. :: Miti;;.:,"we l 742 still have many, many other issues involving the SA progran, 743 involving other issues, like the IDVps. We $1;; y,- have RL 744 never really had enough tine to finish w? work. 745 __' ' "i ' - - -b,. xi l! Lishi C.~;; - g. A i l f 1 A
XAnri MII243060 PAGE 33 l s I 746 Mr. TATTERSDX. Mr. Yin, let me just bacM up a minute. l l !( 747 You are a nachnical engineer, is that correct? 748 Mr. YIX. Yes. l 749 Mr. PATTERSDX. - Your. Position with the XRC is what, and 750 how long have y'oubeeninthatposition?} 751 Mr. YIX. I have been with XRC Region III for the last 10 a hat'ter of fict'. next' Monday'will be ay 752 years. As Gym's VCMS ATk a 10th 753 didges I am Presently a senior mechnical engineerf.med I was f (0 f rom calggffpffy Polya Mechnical Engineering 754 a graduate 6%* 755 Departisent 1965. 756 nr. PAT 7ERsoX. And you raised some seven questions 757 generally in regard to piping supports and that sort of 758 thing. And these are the 160 violations in that blue book? 759 Mr. [IX. There are 1/s 0 pages of re'por t write-up. I have, 760 in one paragraph, sunnarized all the inspection violations 761 and findings against all the regulation requirements. I { 762 believe the report is a nade Ub public document,2.~ k I 763 available to Mr. Fanetta. 764 Mr. PAT 7IRSOX. And the response to your 160 pages was a ~ 71E _seneral response that We thinx we have already reviewed 766 it. ~ 767 Mr. YIX. That is right. More or less a verbal response, t o fW'. h*E4-O j 768 When I requested then A ti.a specifics de.the data 769 base--there was no response from the staff. 770 Mr. PATTIR50X. You indicated, if not today, previously to, f e
~ i I { .g MAMI: MII243060 PAGE 34 771 ne that you thought three to five weeks, you could re view-- ( 772 would it be all of the violations that you found? 773 Mr. YIX. Yes. 774 Mr. PATTERSOX. Computations you made, you could review 1 775 in al natter.odethree.torfive weeks and.then nake a 776 determination? .e. Mr. :.YIX.7 : That is c o rrec t. - Pr - 4 3 " > i.* ** 777 778 Mr. PATTIRson. And have you asked for that, have you bee 779 granted the opportunity? 780 Mr. YIN. I discussed the issue with ny management in vwy 781 Region III, Chicago, and 6es nanagenent had got in touch R. d 782 with the XKR nan a g e m e n t/,-&hd te have discussed this back and i 783 forth a number of tines. "I* 784 And subsequently A ve made a fornal" request during the 785 connissi n necting to allow ne to pursue it hree to five 786 weeks more, so that I can present a note fackual picture on 787 what has happened. 788 Mr. PATTERSOM. Mov, in your to years in Region III, you reviewed a number 'of nuclear powerplants, is that 789 have ___790 _ correct? 791 Mr. YIM. I have perforned nore than 300 inspections. S including inspection in Taiwan and Korea, helping then outy oe 792 h 793 setting up their construction programs. g 794' Mr. PATTERSOM. And hava each of those resulted in the 795 nuclear plant going forward or the problens being resolved? 3 e
r-MAME: NII243060 FAGE 35 796 Mr. YIX. As far as \\ edue Einner, my last inspections ( 797 resulted in the connission's decision to stop work, and 798 subsequently the Plant went under. M Eut I did recommend 799 license for' LaSalle, dee manye cther Powerplants. j 800
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m u.- r/ 80 1 Mr. P A TTER50X. Commis sioner Asselstina, one of your 802 reconnendationsthere is-that' the conhission in f act grant 803 the opportunity: to Mr'.' Tin to nake. his review. Will you be 804 naking that reconnendation to the Connission, or have you'? 805 Mr. ASSELSTIXZ. I made that recommendation at the time o 806 the full power operating license decision. I intend to 807 renew that suggestion to my colleagues, and try and 808 encourage then to now go back and take a look at this. 809 I think with the Court of Appeals' ' decision, there'is 810 seine additional time nou. And I think that time ought to 811 be used productively. One way 2. think we can do that is to 812 set up a group with Mr. Yin's very activa involvement, to go 813 back and look at his concerns and try to lay then to rest,s.- 814 and resolve those concerns. ___ 815 I think it is particularly useful, \\ given the inPortance of { 816 seismic design for this Particular Plant, c, given the extent 817 of the problems we have had in the seismic design area, to 818 really go the extra. mile and try. to nake sura there is a 819 consensus resolution on these kinds of concerns so that 820 everyone can have confidence that in fact the plant has been l
s - MAMEs XII243060 s PAGE 39 896, area of low to noderate seismicity and this As the proper ({ 897 level--which is roughly twice that of any other plant in any 898 other part of the United States. 899 ., *: eMyreelleagues, InthinX,t tooX that. statenant out of contax 300 and basically: ran:.with11t,. and said, wallu thisr aean \\ s that 90 1 California is no different than any other part of th e 802 country.
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.n.'. .; ; s e-e t-me. tr.- j r. s..., 903 I think that was the basis f or their judgnant. I would 904 have to say for myself that I don't think that was an 905 adequate basis. I think they were taking that one statenant 906 out of context. 907 I don't believe there is a rational factual basis for not 908 considering the issue.in this particular casa. 2ut again, 909 it is a decision that they made zather t'han the
- staff, 910 Mr. PANETTA.
Does the staff want to m say anything about 911 that? Probably not. 912 Let ne ask Mr. Yin. You had indicated a nunbar of areas 913 in your various conditions. Let ne ask you to talk about 914 one which is Condition 6, ^ relating to quick fix design. 915 Could you kind of briefly sunnarize your concern about the \\ 916 quick fixes and what the staff found in zesponse to your 917 concerns? l S1B Mr. YIX. Yes, sir. } 919 o Morna11y, the designo]"largeborePipingandtheneeded 920 = selsnic restraints and i supports is perforned in san O i
\\ ', - i ~ XAME: MI1243060 s PAGE ko 921 Trancisco. It is either Performed by Bechtel, by Cygne, by (( 922 Inpell or by Westinghouse. 923 So there are four coupanies involved. /' 4mHb :he design of II 92 4 the smallfeborer supports Performed at the site by cPEG; I WQf M Xow;4- ( 925 shen those. drawings to forward to. the'* site,'.s ometimes it khi N .s> 926 very difficult to install because the people located in the b 927 san Trancisco ar'em was not aware doiseG the l actual situation f 928 at the site twt"- 7.;;
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l r-929 4~ 930 Mr. PAXETTA. Is it basically designed,in San Francisco, 931 then, by these conpanies that are working theret 932 Mr. YIX. That is correct. 4 933 Mr. PAKETTA. .And they send it to the Plant site,.then 934 those putting the equipnent in nake the ' decision as to how 935 it actually fits at the site. 936 Mr. YIX. That is right., Normally, if you run into 937 difficulb'at a sai+, you wilf request changes C But'in this g 938 site here, whether or not they ewa cutting W4 corners or trying 939 to sava costs, they emm#C. enaking gg)L s&. changes right at the spot on 940 the site,
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all the design requirements 941 originally installed for those hangars and suPPortsbIMsiall d a 942 Mr. P A NETTA. F. o ' many changes were involved? 943 Mr, YIX. The total changes amounts to 16,000 About 70 - 944 percent of everything they installed. So it is quite 945 substantial. 1 m I
I t 1 -NAME: MII243060 PAGE 41 946 Mr. PAMETTA. So I understand what takes ylace--my (( 947 understanding is that on site, then, as they put the 948 equiPnent in Place, and they have to make a change from the 949 original design, if theyinake thatvehange as they are going 950 along,.thatcis. called a quick dix change..- t-Mr. TIM. That is right. .".e 9.51 952 '.0 iMr. PANETTA.- Mornally to do. a guibK fix change, do you 953 have to yet permission to do it, do you clear it with 954 sonabody? What is the process for doing that? Dr1L4 955 Mr. YIM. The process is unclear--because the procedure og A 956 never c: li; deline ated too cle arly on what specific (44RLed 4 egg bmpased am 957 restrictions the site people __,_;.-.,; r_ _ 15 ]f is & emMen >E e +r ie r 5" for rd 958 --didl. L : 1 the site people--in the other nuclear 959 Powerplants di ..-~~,;--, I;; 4?- "d'"^ _ r ^ ^ ;10- to do s ome 960 ninor changes within certain Procedure requirements. 961 But in this case here, whether it is najor, minor or in-962 between, it can all be changed by the on-site staff. 963 Mr. PAXETTk. So all of the. decisions were made by the on-964 site staff? ) 965 Mr. TIX. That is correct. 966 Mr. PAXETTA. All right. l 967 When you are trying to then check back on some 16,000
- 968, quick.fix changes, how do you inspect those changes to l
1 969 assure that they have been denit with? course of construction, because tha$ k 970 Mr. YIX. During the ge ; A I i f 4-3 i i
U...i E 3,,,,,,, HAMrs MII243060 PAGE 42 N g 971 wee quick fixes at the site r-thr/ by-pass the normal RA S #5 mdailf te ( 972 Program requirenant, essentially h no way N ___ += is..,fAf.w .n. 973 keep the inspection systenA th:/ are all temporary. 974 a 4WW" he)SA program audit cannot be in' Place, because'you 975 are nottreally doing:your' work in a norna'l sensa. So I 976 would thinX.this is the beginning of many systen f ailures, I 977 nean the R A 'tysten Mailures. e.< s 2.v cs-. oyde*si4 s 978 A RA'progIam is / kind / link one to another. If one, 979 part dails, nany other parts will be affected/ also. p 980 Mr. PANETTA. Have you, in your experience, known of or 981 seen any plant that involved 16,000 quick fixes? 983 Mr. YIM. No, sir. 983 Mr. FAMETTA. You indicated in your report this is I 984 indicative of a SA treakdown. ~ 985 Mr. Y1M. It is a SA breakdown. 986 Mr. PANETTA. It is a quality assurance breakdown that 987 would normally protect against that kind of thing happening, 988 is that correct? 989 Mr. YIX. That is correct. 990 Mr. FAXITTA. Could the staff respond to that? l 991 Mr. V OLI.iER. I think, Mr. Fanetta, as I indicated, as ou; f i 992 report indicated, we agreed this quick dix program did ) l 993 exceed l significantly its procedural boundaries under things l 994. that were performed by that act'rity. 995 As Mr. Yin indicated, it is not at all unconnen for a
'i \\. HAME HII243060 FAGE 51 s. 1196 which a Court of Appeals has stepped in and prevented ({ 119'7 operation, full power operation of a plant. I think this is 3 1198 the first instance, at least that I am aware of. 1199 I think it. is:.an; unprecedented. step. n-1200 .tMrs-PANETTA:.. What: is that XRC. explanation as. to why Pctt 1201 did not comply with SA requirements in 1981 through 1984--let i 1202 me ask that of theestaff. **. 1203 Mr. VOLLMER. Mr. penetta, I* am unabler to answer that. 1204 perhaps you would care to ask that of pGEE. 1205 Mr. PANITTA. I ask it of the MRC because, obviously, you 1 1206 are the ones that have that oversight responsibility. I l 1207 believe what happened here is that everybody points their 1208 fingar at someone else, and the publie winds up wondering, 1209 who is really carrying the ball. ~ 1210 Mr. Yin, if I could ask a final tuestion. I asked th'is 1211 question of you'in ny o.tfice. I think the public is 1212 entitled to hear your ans war.' t 1213 Based on your experience, and what you know about the 1214 plant at the present time, in responding to the concerns you 1215 have raised, if you had the power to license that plant, 1216 would you licensa it at the present tine? 1217 Mr. YIX. I certainly cannot speak for the commission, 1218 because ny knowledge, my expertise area is very limited. 1219 so, let ne just speak on my behalf on the subject matter 1220 that I know. If I have to assign a confidence level, say, [
(u XAME: MII243060 PAGE 52 J 4 1221 high confidence, confidence, sona confidence, and no ) de d -{ 1222 confidence, I would assign it p sone confidence level. 1 1 1223 So, I an not conpletely certain. { 1224 Mr.:PAXETTA:s Based'en d'some confidence, Would you 1225 licen'se thht plantti. { . tra t. s: , t. ;.5.... r ;. - il 1226 Mr. YIX. I certainly would not. j i 1227 -;.Mr..PAXITTA - Thank you, Mr. Chairman. 2 1228 Mr. PAITIRS0X. Just a couple of' quick questions. 1229 In 1977, the audit,of Pu11 nan Power, conducted by Xuclear 1230 Services corporation, found significant deficiencies in tha 1231 Pullman quality assurance progran. The Xuclear Services i 1232 Corporation audit report was turned over to the XRC in 1983. 1233 The HRC sinff states that there Was no significant qualit i 1234 assurance breakdown. In a July 19 lette~r to the Commission, j 1235 Quadrex stands by its Previous findings. That appears very 1236 prominently to be a direct conflict of opinion between,the 1237 Sundrex Corporation and the XRC position. 1238 Nith that as a break drop, I would like to ask you whethesi 1239 you read the July 19 letter to the Connission frca Quadrex 1240 as an eMPression of support for the MSC's 1977 findings? 1241 Mr. ASSILSTIXE. That is the way I read it, Mr. Patterson 1242 Although I have to say that I supported ferner Connissionar 1243 Gilinsky's request to ask the.Duadrex pebple to come in and ~ 1244 neet with the commission, so we could discuss in detail what 1245 they had done when they did the audit, what conclusions they (L m}}