ML20080T502: Difference between revisions
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GAP, in February 1983, wrote to the Office of Investigations ("OI") | GAP, in February 1983, wrote to the Office of Investigations ("OI") | ||
to outline its concerns about how the investigations were being handled by OI and Region V. See February 28, 1983 letter, without attachments, attached and incorporated herein as Exhibit 1.- We have yet to receive , | to outline its concerns about how the investigations were being handled by OI and Region V. See {{letter dated|date=February 28, 1983|text=February 28, 1983 letter}}, without attachments, attached and incorporated herein as Exhibit 1.- We have yet to receive , | ||
l' b ' | l' b ' | ||
an answer to that letter _.__ In fact from news accounts, we nave learned | an answer to that letter _.__ In fact from news accounts, we nave learned | ||
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integrity of the invsstigation and/or report. | integrity of the invsstigation and/or report. | ||
In addition,.given the NRC and in particular Mr. Shackleton's questionable _ response to FOIA requests for information on the Earl Ik: Kent investigation, GAP is understandably nervous that come'of the requested information may disappear prior to its identification and release. , | In addition,.given the NRC and in particular Mr. Shackleton's questionable _ response to FOIA requests for information on the Earl Ik: Kent investigation, GAP is understandably nervous that come'of the requested information may disappear prior to its identification and release. , | ||
From the public -record currently available I believe the NRC's investigations-into Mr. Gunderson and Mr. Royce's allegations are ' flawed in many of the ways outlined in GAP's June 20, 1983 letter | From the public -record currently available I believe the NRC's investigations-into Mr. Gunderson and Mr. Royce's allegations are ' flawed in many of the ways outlined in GAP's {{letter dated|date=June 20, 1983|text=June 20, 1983 letter}} | ||
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to the Commission on the Kent investigation. However, I withhold any generic criticisms pending my hoped-for receipt of the background ' | to the Commission on the Kent investigation. However, I withhold any generic criticisms pending my hoped-for receipt of the background ' | ||
Latest revision as of 16:57, 26 September 2022
| ML20080T502 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde, 05000538  |
| Issue date: | 07/14/1983 |
| From: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20079G392 | List: |
| References | |
| FOIA-83-450 NUDOCS 8310240215 | |
| Download: ML20080T502 (19) | |
Text
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Rehm GOVERNMENT ACCOUNTABILITY PROJECT stelle Institute for Policy Studies -- dfGrRGRV CEE9 1901 C e 5:ree: N.W.. Wcshinoton. D.C. 20000 Denton GC C93 JE $nningham0 P:t 12: 47 July 14, 1983
. Honorable'Cha'irman Nunzio Palladino g g.g. . 7 Honorable Victor Gilinsky Honorable John Ahearne Honorable James Asselstine .
Honorable Thomas Roberts United States Nuclear Regulatory Commission Washington, D.C. 20555
Dear Commissioners:
On behalf of Mr. Robert Gunderson and Mr. Wallace Royce, whom we represent as counsel, we request that the Commission review the NRC staff's serious mishandling of its investigation into these two workers' allegations about deficiencies in electrical work and the startup testing program at the Palo Verde Nuclear Generating Station, Units 1,2, and 3. We specifically request the following:
- 1) A new investigation of~ Mr. Gunderson and Mr. Royce's allegations by' a group of inspectors and investigators independent of the former Region V and Office of Investigations personnel who conducted the original investigations / inspections; ,
- 2) An investigation into the original investigation of Mr.
Gunderson and Mr. Royce's allegations, which failed to meet minimal investigative standards or the NRC's own regulations, to be conducted ' by another government agency Inspector General's Office;
- 3) A request from the Commission for an investigation by the
- Government Accounting Of fice ("GAO") into Region V and the Office of Investigations general inve.stigative practices and procedures to j k g determina
- ether they rneet minimal investigative standards and thef - V
_NRC's own guidelines and regulations on investigations. Y I. BACKGROUND J The Government Accountability Project (" GAP") is a project of theY Institute for Policy Studies, Washington, D. C. GAP's purpose is to broaden the public's understanding of the vital role of the public t) employee, corporate employee and private citizen in preventing waste, corruption, and health and safety threats. GAP offers legal counsel and other support to whistlbblowers, canages a legal clinic for law students, and promotes meaningful reform of the government workplace through disclosure of government actions which are repressive, wasteful, illegal or a threat to the American public's health and safety. ci,() - 5.74, 5 L i g5W , _ 8310240215 830908 PDR FDIA QARDE83-450 PDR - [h . GI for appropriate action ~
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a;. ' i GAP. regularly monitors government activities, offers expertise to Exe.cutive Branch offices and agencies and state and local govern-
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'mentalJbodies, and responds to requests by Congress and state legis-
~
1ctures for analysis of legislation to make government more accountable to thd public. With regard t'o the NRC, GAP conducts an ongoing monitoring of the . agency's efforts to protect the public health and safety. GAP believes a thorough and comprehensive examination of nuclear workers' allegations A
'ofsafetyandqualityassuranceproblemsatnuclearplantscancontributep[*g ,
cignificantly-to the NRC's effectiveness in its miscion. 4 E . In.the winter of.1982 GAP was requested by the Palo Verde' Inter- '
/gvention Fund, a grassroots group based in Phoenix, Arizona, concerned-lM ~
about numerous complaints about safety _ problems at the three plants, (3\[ i
- jj to conduct _an investigation int'o several workers' allegations. Previously L.y these allegations had been forwarded to the NRC staff which, in the -
case of Mr. Gunderson,. had still failed to complete any report - nine
- _ months after the allegations were made. In Mr. Royce's case, the NRC i
staffcorroboratedhisallegationsbut(discounte]r3eAnterventivutheirsafetysignificanceg. Intoth b instances, by February, 1983, tWe Pole Vo Funa
#pgac' uncovered sufficient information to indicate that the NRC staff, I (f)BothRegionVandtheOfficeofInvestigations,hadconductedgrossly inadequate investigations of the two workers' allegations. Moreover, y
-it appeared that the purpose and intent of the NRC investigations and )f
, ins p gMconduct pections a serious, was togood-faith discreditinvestigation Mr. Gunderson of their and Mr. Royce-)(rathe complaints.
' Y ~ GAP, in February 1983, wrote to the Office of Investigations ("OI") to outline its concerns about how the investigations were being handled by OI and Region V. See February 28, 1983 letter, without attachments, attached and incorporated herein as Exhibit 1.- We have yet to receive , l' b ' an answer to that letter _.__ In fact from news accounts, we nave learned
' tnat Roger Fortuna, OI's Deputy. Director, to whom this letter was personally delivered, failed _to review it or forward it to the appro- .
.priate office for review for three months. See Arizona Star and New ^
Times articles, attached and incorporated herein as Exhibits 2 and 3. Mr. Fortuna has offered no explanation for overlooking GAP's letter for ' this period of time. , Mr. Gunderson is a journeyman electrician with 19 years of experience, ' .- three years' experience at nuclear plants. He was formerly an elec-
]; trician employed by Bechtel Corporation, the architect / engineer and q_ . constructor of Palo-Verde. He left his job after two years when he a became convinced that poor construction of-the three plants was seriously gy compromising their safety. Prior to leaving, he brought the construction
%4 and quality assurance problems he discovered to his supervisors' attention I
's .
- and to the attention of the Arizona Public Service Company ("APS)"
.which owns the plants. He_also attempted without success to
$ contact the NRC, whose presenc_e_At;_JJ1,olerfe h no.t_ obvious'.
- PTifally he broirght-h-iE" allegations to the intervenor af ter
- reading about the ongoing licensing hearings.
~
Ms. Honrihan, the intervenor, informed the Licensing Board of Mr. Gunderson's allegations and his concern that his identity - be protected. Since he had recently received a threat to his life, he wished his identity to remain confidential. The Licensing Board impre~ssed on the NRC staff the need to protect Mr. Gunder-son's identity which the NRC staff promised to do, in accordance with NRC regulations. -
.i Unfortunately, GAP has been forced to conclude that the NRC (6[/ghNstafffailedtokeepthispromiseandtheconfidentialityof
-- c Mr. Gunderson and his allegations was breached. For a period of about six months after describing his allegations to the D NRC staff, Mri Gunderson was unable to find work; finally he 2)f.b'>/ \ found employment at a fossil fuel plant in Craig., Colorado.
In licensing hearings before the Atomic Safety and Licensing Board in June, 1982, an APS attorney informed the Board that he understood the investigation into allegations about deficient ON'> electrical work at the plant was proceeding well. The intervenor, who brought these allegations to the Board and NRC staff's attention, had been told by the lead investigator, Owen Shackle-ton of OI, that she could not be informed of the status of the investigation because it was against NRC practice._ The NRC staff promised that the report on Mr. Gunderson's allegations would be issued in August, 1982. The report has yet to be issued. In a September-October 1982 newsletter, APS claimed that the NRC investigation had already "resulted in a clean bill of health." i See The New Generation, at 3, attached and incorporated herein as Exhibit 4. When I telephoned Mr. Shackleton to ask how APS could make such a statement in its newsletter, Mr. Shackleton
\0 said he would not speak to me and hung up the telephone. In October, 1982, the NRC brought Mr. Gunderson back to the Palo Verde site for an exit interview. At that site visit, an NRC inspector told him that all his allegations were being handled adequately by APS and Bechtel because the problems had been f detected or corrected prior to the NRC inspection or because the specifications for the work had been changed so that construction was no longer in nonconformance with the specifications.
Mr. Gunderson, concerned that the NRC might warn APS and Bechtel of his allegations prior to its inspection, did not detail all his concerns in his original affidavits. He did, however, raise three or four additional problems on the spot to the NRC inspector conducting the exit interview. In touring N the plant, Mr. Gunderson found that these newly raised deficiencies which had not been listed in his confidential affidavit had not been corrected or had not yet been discovered by Bechtel construction or quality control.
l(* 2 _4 , We spoke in February 1983~to_Wallace:Royce, formerly an electr'ical start-up engineer performing tests on electrical systems ' cnd sub' systems at Palo Verde. Mr. Royce was terminated by Bechtel in November 1982, after he. complained to his supervisor that a quota cystem' requiring e,ach start-up employee to complete a test per night
.was compromising the quality of workmanship at the plant. .Mr. Royce .
contacted Mr. Shackleton, prior to his termination to tell him of his fear of. retribution for-his attempt to raise safety problems. Mr. V Shackleton . told Mr.t Foyce that the NRC could .do nothing to protect 1
---workers such as himself. John Roedel, APS Corporate QA Manager, told Mr. Royce that he would not lose his job for raising safety concerns to his supervisor. Unfortunately, Mr. Shackleton was correct and APS was not, since Mr. Royce was fired the next day.- l Subsequent to his termination, Mr. Royce gave the NRC a formal statement of the problems with startup testing he believed compromised the safety of the plants. These included the following:
- 1) The so-called " bean count" or -quota system which required occh employee to complete testing on one system per shift rushed start-up tests and in some cases encouraged workers to write up test rssults for tests they had not conducted.
- 2) 'Bechtel was duplicating a great deal of work in the start-up prog.am; and
- 3) start-up engineer's were not properly trained. -
The NRC inspection corroborated .all'of Mr. Boyce's charges but found they had no safety sig'nificance. Needless to say, the NRC . did not bother to investigate whether or not Mr. Royce had been terminated i !- in violation of the legal guarantees provided nuclear workers who bring forward safety problems. , The NRC staff might have been well-advised to take Mr. Royce's i concerns more seriously. In a June 9, 1983 inspection report, the ! NRC documents problems with startup testing, and an as-yet unexplained L rupture-in a four-inch PCV water line serving ~a standby cooler for ; l the Unit I control room. See Report Nos. 50-528/83-19 and 50-529/83-11 l sttached and incorporated herein as Exhibit 5. i' t jA, The NRC, FEMA, APS and workers present during-the latter accident all seem to have differing interpretations of what happened when the
~
l' .wnter line broke and discharged enough water to soak the power supply equipmen- to the plant's computer, disabling the computer for several ; days.. See New Times article, Exhibit 3. 'If the startup tests were i 3
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conducted properly it is-possible;these problems would have been
' prevented. -
-p : II. FREEDOM OF INFORMATION ACT SUIT TO OBTAIN MATERIALS RELATED TO THE NRC INVESTIGATION.
~
- f On' July 127 1983,* GAP filed suit under the Freedom of'Information .
/{ ,
= Act ("FOIA" or "Act") to obtain all documents relating to the investigation of Mr. Gunderson's allegations. Three months earlier we made_a request for these same materials. On April 28, 1983,
-GAP was2 informed that two inspection reports had been. issued
; responsive to our request. At no prior time had eith,er Region V, OI, . or Mr. Fortuna informed us that the NRC had issued reports documenting partially its investigation of Mr. Gunderson's allegations.
GAP has, ,however, been effectively denied :the bulk of documents related to the-investigation and report on Mr. Gunderson's allegations
-by the NRC's failure to identify or disclose the materials used in compiling the ' reports (s) .
~
In late June, 1983, we were told that an identification of any of the materials might compromise the investigation. ~The investigation thus far seems to have been kept confidential only from GAP, the individuals making the allegations, and the Palo Verde Intervention Fund. Therefore, it is hard to understand how responding to an FOIA ' request could compromise the
~
integrity of the invsstigation and/or report. In addition,.given the NRC and in particular Mr. Shackleton's questionable _ response to FOIA requests for information on the Earl Ik: Kent investigation, GAP is understandably nervous that come'of the requested information may disappear prior to its identification and release. , From the public -record currently available I believe the NRC's investigations-into Mr. Gunderson and Mr. Royce's allegations are ' flawed in many of the ways outlined in GAP's June 20, 1983 letter
~
to the Commission on the Kent investigation. However, I withhold any generic criticisms pending my hoped-for receipt of the background ' documents to the Gunderson inspection / investigation. III. 'NRC REPORTS ON MR. GUNDERSON'S ALLEGATIONS FAIL TO ADDRESS SAFETY CONCERNS Region V and presumably OI have documented a portion of their
' inspection and investigative findings on Mr. Gunderson's allegations in five inspection reports. Report Nos. 50-528/83-05; 50-529/83-03; 50-530/83-02 (March 31, 1983); 50-528/83-10; 50-529/83-07; 50-530/83-05 (April 22, 1983); 50-529/83-09; 50-529/83-06; 50-530/83-04 (April 25, 1983) 50-528/83-17 (March 24, 1983); 50-528/83-19; 50-529/83-11 (June 9, 1983).
- . ~. - - .. -.
5
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r ~.'. *' 4 In the April 22, 1983 Report the-NRC staff substantiated ' Mr. Gunde'rson's allegationsL that his supervisors and those for other electric.ians deliberately instructedLthem to falsify termination cards, that-is, sign cards stating that they had made terminations on cables when they had not done so, and did not know.who had made the terminations. For many'of Mr. Gunderson's other allegations, the facts were_ [ " 238231antiated in whole or in part but the NRC staff cli'd n6E~Eerceive A - the safety significanua Of sne nonconformances. For others, ~ the staff 4&* found the problems u.sw.ibec in Mr. Gunderson's affidavits but believed /N"'uf*- that other measures taken by APS, Bechtel or the QA program would ensurdDI'"E% that the nonconforming conditions did not result in safety problems. N g However, the fact that APS and Bechtel did not detect many of these
. problems until after Mr. Gunderson gave the NRC affidavits outlining his l6 concerns, leads GAP to believe the-QA program at Palo Verde is not catching
, ell these problems on its own.
; For example, a-number of concerns described in Mr. Gunderson's ,
g4 affidavits were documented by APS as potentially reportable under i. 710 CFR 5150.550=)~enly after Mrv Cundarson spoke to the NRC. See, e.g., Ehe rollowing items,also documented on APS Deficiency Evaluation Reports (DER's); Report Nos. 82 Improperly Crimped Electrical Terminations Lugs,~ Unit 3 4160-Volt Switchgear; 82 Improperly Crimped Electrical [V d Tarmination Lugs, Unit 2 Main Control Panels; i Electrical Termination Lugs - Termination Lugs 44-ImproperlyCrimpedj{f Unit 3 480-Volt Load- ' canters. , G The NRC staff for many allegations did no more than a' paperwork IGview. ~In some cases li supplemented the paperwork review with /7 i questioning solely of those individuals alleged to have acted improper y or to have directed other workers to act improperly. In other instances the staff misinterpreted or distorted Mr. Gunderson's allegations. f ~ The following examples are illustrative of the flaws found throughout the Reports issued up to this point.1 l
- A. Improper Splicing of Quality Class, Safety Related Cables.
sMr. Gunderson states that a foreman directed that splices be made on Class IE cables in violation of Bechtel specifications. The,NRC staff i j found no such spliced or g o cable)at the particular locations stated thA Q fD WH rv 1 GAP hp . ( with experts' assistance will make a more detailed review of the Reports if the Commission decides not to order a new investigation i into the allegations and an independent review of the Region V and OI's j original investigation. ! t
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by/Mr. G.underson. However, the foreman mentioned by Mr. Gunderson noted an incident in which Class lE cable located in the Unit 1 s ControllBuilding at the same elevation mentioned by Mr. Gunderson '
/had been' repaired.with " shrink tubing" in violation ~of Bechtel
- iSpecification 13-EM-30. The first nonconformance report ("NCR")
written on the damaged cable was improperly dispositioned to allow this repair. QC accepted this disposition on September 9, 1981. ' According to records examined by the NRC a second NCR was written on the very same day and eventually dispositioned by requiring replacement of the damaged cable with a new cable. The NRC staff acknowledged that the disposition of the first NCR was incorrect. Its report does_not \ lq rldguaLe-ly e7. plaid hvw a secord-NCR was written on the very same day I the[fAr_st MCR WaY~iMpf6' p~5rly dispositioned and acEp~Elebd~by QC. ds Mtrch 31, 19 837epv& L 5 La La::, than a revi'ew of the' log-for -electr-ical 1 nonconformances for the period September. 1981 throuch April, 1983 showe --
"no recorded instances of cable splices or jacket repairs in any Unit safety-related cables." It appears, therefore, that the second NCR, !
dated September 9, 1981, may not have been logged. Moreover, the NRC staf f did no more than a paperwork review of l this control room cable according to the report It does not p that the NRC did a physical inspection., dw, a M e p e - t e k The report states further that Mr. Gunderson's allegation was not substantiated even though the very problem he dese_ribed was found. 2C Moreover, the documentation which demonstrates that Bec tel ,iscovered End remedied the problem is unusual at best. *jb P f . The NRC staff itself does not appear totally confident that this f q) problem April 22 is as insignificant reports. In a May as24, might 1983appear reportfrom its March the staff notes 31that andAPS - has agreed to assemble a history of all NCR's concerning splicing of cables during cable-pulling for Unit 1. Therefore, the NRC has lef t Mr. Gunderson's allegation as an open item pending review and evaluation,4 A of all cable-splicing NCR's for Unit 1. N . #^ ~- ' x, ~ i B. Improper Insulation on High Voltage Terminations. Mr. Gunderson stated that 2200 Scotchfill was used in the high-pressure safety injection ("HPSI") pumps, the low pressure safety-injection pumps ("LPSI") and the emergency pumps to the cooling tower and the spray pumps, instead of 130-C as required by Bechtel specifications. Mr. Gunderson's concern was that Scotchfill 2200 was rated at only 600 volts and used on motors rated from 4160 to 13,800 volts. The NRC staff found that all connections for the HPSI, LPSI and essential cooling water pump motors were reinsulated at some time during the period from November, 1981 through 1932. At that time L-
,," }*
@) h f h Scotchfill 2200 was replaced with 130-C or its equival
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the report does not indicate whether this r.e-i'nsulation was conducted prior to or after Mr. Gunderson forwarded his allegations to e NRC.
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Moreover, , the NRC' report assumes that Mr. Gunderson'y/all s gationsg cre of concern only for outdoor motors expected to be exposed to high , tcmperatures. Mr.-Gunderson did not indicate that this was his concern'.N , Instead, he states clearly that his concern is the low voltage rating /F of the Scotchfigl 22AOL and the failure of the insulation to meet Bechtel 44 rpecifications. , It is clear that insulation for at least some of the terminal connectors for the. power cables to the pumps listed by Mr. Gunderson was not replaced in ac~cordance with Bechtel specifications at the time CA Mr. Gunderson made his allegations in May, 1982. , C. Use of One-Bolt Lug in Plhce of Specified Two-Bolt Lugs. Mr. Gunderson stated t' hat Bechtel directed the installation of a'one-bolt lug with a lower amp rating in the place of specified and required two-bolt lugs. He also alleged that Bechtel attempted to make the connector to the motors look as though two-bolt lugs were used when clearly one-bolt lugs were used. The NRC staff substantiated Mr. Gunderson's allegations but found they had no safety significance because the connectors were of adequate current carrying capacity. The staff also found that the two-hole feeder cable connector bolts used, which made it appear a two-bolt lug had baen installed, were used merely as spacers. ' The staff further suggests, somewhat cryptically, that the manu '. fccturer's rating of the connectors as 45 to 65 amps was different'tha the ampacity required by the design documents f r the p { The staff does not explain the iffere ce between the manufactur '
- rating and Bechtel's design rating. In. addition, bolts are not used r4 rely as " spacers" as this report states. Finally, the NRC made no -
attempt ta investigate an allegation by Mr. Gunderson that a nonconfo . ncan ' report was prepared about delibercte attempts to make the connectors look as though two-bolt lugs were used instead of one-bolt lugs and t . f,j W construction had ordered destruction of this NCR. The staff fails to document adequately those broad conclusions it does reach: (1) The feeder cables running to the safety-related pumps are larger than required; ntY (2) The rating of the cable and connectors is more tha cdequate for.the motors they serve; and 2 Bachtel Specification Change Notice 2826 was issued on September 10, 1981, to change the cable termination procedure to replace 130-C or its equivalent Ls installation filler where Scotchfill 2200 had been previously used.
(3) " Review of the design and records of the feeder cable and motor connectors for the above identified pumps demonstrated thn connectors to be of~ adequate current carryi'ng capacity." April 22,, 1983 Report, at 7. 4 D. Improper Training and Qualification of QC Inspectors Inspecting Electrical ~ Work. , Mr.-Gunderson stated that it was his experience that QC' inspectors oxamining electrical, work were not qualified to perform their job. He gave as an example a6 incident in which two named QC.irspectors asked ? him to splice a quality cable in a manhole in front ~ of the Unit l_ spray pond._ Mr. Gunderson believes Bechtel specifications do not allow splicing l~ of quality' cables.
~
The NRC staff in its first report states that a paperwork review of APS'. training program shows the program meets ANSI standards. The , staff goes on to state that QC could not instruct Mr. Gunderson to g( eplice a cable since all cable splices must be . requested by field . .cngineering by means'of a field change request. The NRC staff apparent did not interview the two QC inspectors named by Mr. Gunderson in his affidavit. Nor did the staff explain how field engineering could have made's33hs.,a request of Mr. Gunderson if Bechtel specificptions explicitly , ~ prohibit , splices of quality cables. _ g7 The May 24, 1983 report states that the NRC conducted its own i cxamination of ten electrical QC inspectors and determined they were
- qualified. However, given the past performance of the NRC.in fore-warning APS and Bechtel of its concerns, GAP believes the particular questions asked of the inspectors .and the manner in which the questions were presented to the inspectors must be better documented to ensure the adequacy. of the NRC's testing procedures. -
I (h)'-ThedaughterofE.E.VanBrunt, APS's Vice President in charge' of Palo Verde, is employed in the Bechtel QA Program. Mr. Gunderson alleged that the daughter of Mr. Van Brunt, the APS Vice President, Nuclear Projects Manager, worked in the Bechtel QA Program, in violation of Appendix B to 10 CFR Part 50. The NRC staff found-that Ms. Van Brunt did work in the Bechtel QA program, although in a different position than suggested by Mr. Gunderson. Nonetheless, Mr. Gunderson's point -- that the Bechtel QA program should be-totally independent from construction as required by Appendix B -- is not examined. Clearly Ms. Van Brunt's familial ties could compromise the independence of the QA program, regardless of he position or the fact that she has supervisors. 1, e
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F. Deliberate Falsification of Records. Mr. Gunderson stated that he and other electricians were directed by'their supervisors to falsify records and to prepare termination cards for terminations on safety-related and non-safety-related systems-whan they did not do the work. Mr.-Gunderson further stated that he and other workers sometimes documented that they were pressured to falsify records by writing on the hottom of the termination cards "U.P. " to indicate they signed the cards "under protest." He also stated that ha saw quality control inspectors sign termination cards for work they hcd not physically inspected even though physical inspection is required. The' NRC. did find one card signed by Mr. Gunderson which indicated that he had signed the' card.under protest. On another 12 cards the NRC inspectors
-signed, found that electricians' names were printed instead of being as required. Upon questioning, Bechtel supervisors admitted that they had lost termination cards and had made up new ones merely by writing in the electricians' names and crimp tool numbers. Of 13 electricians interviewed, eight stated that they had been requested to and did sign termination ce-ds-for terminations they did not do. Some of1the cards were to document Class IE terminations. In addition, the electricians signing cards for these terminations merely recorded the
- crimp tool number for the crimp tool they had in their possession at
-the time. Without stating.its method of estimation, the NRC calculated from 50 to 100 cards of Class IE terminations were falsified.
The staff apparently did no investigation to determine the root ' cause for the falsified records or the supervisor or management per-r connel responsible for directing the falsification. Moreover, the NRC appears to find the deliberate falsification of termination cards for i non-Class lE terminations acceptable. .
- The staff indicates little interest in the' identification of the Bcchtel or APS personnel who directed the falsification of the cards.
l Since the entire NRC regulatory system is based on the requirement that licensees and their contractors provide the NRC with full and I l complete information, it is astounding that Region V and OI should l care so little about the falsification. The question must also be ~ asked whether such falsification is widespread'and is occurring in other I creas of construction and the quality assurance program. l According to the April 22, 1983 Report, the NRC is anticipating i taking enforcement action against APS for the falsification of records. Certainly any such enforcement action should be decided upon prior to l ' allowing the Initial Decision of the Atomic Safety and Licensing Board for Unit 1 to become effective. Moreover, any such enforcement action, GAP believes, must be based on an adequate and thorough investigation { of all the circumstances surrounding the falsification. This type of investigation has clearly not been done. GAP doubts an adequate VJ L 1 e > fLV'1 - l
.. y .
N sll- , f investigation can be done by the Region V and OI investigators assigned to this case.
~
Apparently the Office of General Counsel, in April 1983, did consider this issue. At this point the public and the individuals
' bringing the allegations to the NRC's attention should be informed of what-decision-the Commission has made. Certainly it can do little '
to enhance the agency's credibility if the Commission allows serious ellegations'such as Mr. Gunderson's to remain unanswered for over a yaar and then allous the Initial Decision of the Licensing Board to b:come effective prior to enforcement action based .on the allegations. Whatever the decision of the Commission in this regard, it must be made public to assure the public and the workers risking their livelihood to bring their co,ncerns to the NRC that the safety problems at Unit 1 have been. resolved. , IV. NRC ' REPORTS FAIL TO ADDRESS THE SAFETY CONCERNS RAISED
- DY WALLACE ROYCE.
In November, 1982, after his termination, Mr. Wallace Royce, l a startup engineer, brought -to the NRC's attention problems in the ; startup program. In an inspection report issued in late December '
~1982,- the NRC substantiated all his allegations. Yet the report failed to examine, to even the slightest degree, the possible safety consequences of the " bean count" system, duplication of work by Bechtel, and writing up of test results by startup personnel who did not actually conduct
. tha tests. - Mr. Royce stated clearly that he believed the duplication of work by Bechtel demonstrated that APS management was not adequately controlling its contractor and that he believed both Bechtel and APS management
- ware not handling the startup testing properly. The NRC report simply' states that APS feels the situation is now under control since Bechtel's duplication of testing.has been reduced from eight to one percent.
. . The NRC did little investigation as to whether or not repeated testing and duplication weakened-particular systems or subsystems. The NRC also did little more than a paperwork review of the , testing.and qualifications of startup personnel. The review it did conduct d
~fot2r-"Etn.gmanstrated tup electrical' that test documentation for the training of av bes t
, whtrse--traini'Tg WaY exanilife~d in great deptIdTe~% . Royce. _ It appears
'dfrectors was l'ost. Tlie- crrly-individual jD
- i. that the purpose of examining Mr. Royce's training, which did not differ from that of any other startup personnel, was to ctrscred Mr.
Royce.
&-{ 4+s.~v i --^ " ,
To determine whether or not " pencil-whipping"m/
\
occurred -- workers writing in test results for tests they did not conduct -- 3h'e NRC did nothing more than ask for a confession from vario fart-up
/u W i y p NgAA ,;(.J h'~9 h) u w
~*~""~
- -_ . _ . . . _ _ , _ _ _ _ _ . _ . _ . _ . , _ . _ . . . - . _ . - . , . . _ . . - , _ . . . . _ . _ _ _ . _ . _ _ . . ~ . _ . . . . _ , _ _ _ _ _ . . _ . . _ .
,.},..h:'.
psrsonnelithat.they had in fact done'this. In'the case of the one
-individual .Mr. Royce identified, the NRC found - that the named individual was subsequently terminated. The system's designer Teledyne was brought-in"to redo these tests on the system which th-. NRC staff daccribed as "very complex." The NRC did not. examine why the individua
.wan pressured to conduct a test for which he was not qualified. .
As is the c'ase with Mr. Gunderson's' allegations, Mr. Royce's allegations _ point to, larger safety concerns beyond the particular allegations. The NRC staff failed to understand or deliberately 3g , _ ignored the larger potential-safety problems caused by rushing startup tOcting;-deliberate; duplication of work; and inadequate training of ctartup personnel.' J V. CONCLUSION. In conclusion, GAP believes that no less than a new and independent ~ investigation into Mr.-Gunderson and Mr. Royce's allegations is' required to restore public confidence in the NRC's investigative program nt Palo Verde.- Moreover, the Commission should order immediately an inquiry, either by GAO or another agency's Inspector General, into tha repeated, inadequate investigations by Region V and the Office of Investigations. Given the performance of this region in its investi-gations into Mr. Kent's allegations, into Mr. Gunderson's allegations, j and into Mr. Royce's allegations, and given the historic problems i cutlined in the Narbut Report, the Commission should act quickly to rostore the legitimacy of its regulatory program in Region V. ( Sincerely yours, . QQ Du ' - --- Lynne Berne.bei Staff Counsel
, Government Accountability Project i
'6f the Institute for Policy Studies 1
i
TUCSON, MONDAY,'fUNE 13,1983. IEhe dt12en intervenor in the plant's
.r "
EXHIBIT 2 Scenang bearings b'. (
- kg y Some e f GundIrson's charges cen.
'aer en Bechtel worters allegedly jg
.asing the wrong parts on various
"^ j pba, such as the one bolt lugs.
,- "nese lugs cannot totente a 400-
$5 d 'a t's m jsah
] M 5nE 5 afy
*asep surge, and may melt in the
, . ' event of an accident," he said in a t
M M W ti/ ~
' , , , ' 'w,orker Gunderscs also complains of carelessness: "Bechte' con-
~ '
H ,* struction workers .*1ad core ddlled a O . [ j g Jole through a concrete wall,and 5 struck a pipe. They then forgot the
'. pipe. This could be a serious prob.
Cy Ceverfy Medlyn - h since*&e pipe en struck was a
--The Artrone DeHy Stat .
quality-control or Q-class pipe,
* .which, according to NRC regula-Seiond si a series ,
,tions, cannot be ddlied into." .
The Palo Verde Nuclear Generat.- . ad He ano alleged that Bechtel su-Ing Station has been hailed as a tech- l
- t pervisors required him and other nological, scientific wonder, com- electricians to falsify records indi.
posed of 625,000 cubic yards of concrete, more than 75.000 tons of @h'"*" M
*, M :
cating that they had finished work on electrical systems that they ac-rei reingsteel,andmillionsof tiny tually hadn't done. E*
- l ,
~
~-
". Andhe said quality-controlinspec.
Six thousand workers are erecting [' - tors sometimes becameless diligent
. , the mammoth energy mill, installing i ! . when examining their friends' work:
stretrical circuits, switches.
"!! they knew you oryour work,you brackets, pipes and cables at the Eadier this month, a division of could bnng them a large stack of 3 state of-the art plant, destined to be- the NRC began investigating the in-
, cards and they would sign them all
; come the nation's largest. tegrity of the regional office's inves. without reviewing the work itself." -
'. So,is everything going right? .tigatim, to see if the staff leaked Royce has criticized his former
"" 8tnployer for providing what he Or did someone pet one-bolt lugs
! .. Insteadof two-bottlugsontheemer. R'e presentatives of the Bechtel viewed as inadequate training. He s. !, gency pumps at the cooling tower- Power Corp., which is building the also took exception to a quota sys. I n the pumps that flood the reactor - Pl ant, and the Arizona Public Ser- tem he called the " bean count," core dunng an accident? vice Co., the project manager, say which required one " bean," or test, the safety of Palo Verde has not been - 40 be coropleted each day, even Did quality-control inspectors compromised, though some tests took as long as y Jim Mackin,a Bechte! spokesman sev days to complete properly, j da t a ed? in Norwalk, Calif., has said his com- - As the target completion date was pany investigated the allegations "I believed then, and continue to
, continually postponed, was a quota and made some corrections. Some be!! eve now, that workmanship can p systern established to pressure engi.
problems are bound to occur dunng be compromised and that workers neers to rush through tests? (r a project of this magnitude, he said. who feel themselves under such in-l4 And did government regulators And when theydo,theyare promptly tense pressure wil: make mistakes
" double cross" the whistle-blowers resolved, he said. and may not do as thorough a job as by leaking their allegations to the
- eey would otherwise do," Royce grant Smith, a spokesman for company building the plant just be. APS, declined to comment on the .
said in a swom statement. fore an inspection was conducted?
.a!!eEations because they are under Shortlyafterhecomplainedof the These are some of the nagging ' investigation. j bean count, Royce was fired. He safety questions about Palo Verde and the people who oversee it.
The two former employees are i says it was an act of retaliation. Robert D. Gunderson, who worked Bechtel says it happened because of The Nuclear Regulatory Commis. as an electrician at Palo Vere.e froen Es work performance.The firing u!. Won's Region V office began investi. April 1933 to March ICS2, and Waj. timately was upheld by a U.S. De-gating the charges by former work. lace R. Royce, an electrical s: art.' partment of 1. abor administrative ers more than a year ago. The up engmeer who was employed at law pdge. . Inquiry was expanded in February, Palo Verde from August to No- i The two mens' charges are under when additional a!!egations came to vember, when he was fired. I investigation by Nuclear Regulatory light. The office has yet to report its Commission officials in Region V. The two men ar'e being'repre. findings on any of the workers' sented by a Washirgton-based group And in turn, Region V has become c!:ims. called the Government Accountabu- the target of an investigation by its _ lty Project and by the Palo Verde , higher ups. ' T-Intervention Group, which supports
- - -=
J .[ '
~ m ., . ,
?
ARIZONA DAILY STAR -
*: MONDAY, JUNE 13, 1983 PAGE TWO 4
That inquiry was prompted by Gunderson's claim that regional offi-cials had leaked information on the alleged safety violations to APS and Bechtel so the deficiencies could be t
~ forwarded to the appropriate divi.
fixed before NRC investigators ar. The group also-W that the sion of the NRC that week. For. rived to inspect them. NRC's Othee of Investigations in tuna's office only handles com. Washingen had been ssked to re.
"When I gave my sworn state. view IM rWonal omdals' investi- paints akut nie violadons of ments to the NRC in June, I as - licensees,he said.
concerned that Bechtet would be in.
- gative Precedures. The request was The NRC division responsiWe for made in a'Feb. 3 letter from the brmed of my a!!egations and that Govemment Accountabuity Project internalinvatigauons is the Omce the problems I described would b'e to Roger Fortuna in the Office of of Inspector and Auditor, Ingram corrected before the NRCinvestiga. Invatigadons. said.Theletter was forwarded there tors had a chance to tavestigate June I, and aninvestigation wasint.
them," Gunderson said in a later "Alemgh me Gmmment Ao tiated, he said. affidavit. countability Project generally When asked why the letter hadn't "With this fear in mind, I inten. agrees with correction of idenufied been acted upon for three months, tionally did not tell the NRC about construction problems as early as lagmm said, "It was just one of r three or four consttuction defiden* possible, it is unconscionable that those things." cies untillmet with the NRC inspec. workers who take great risks to s on site in October 1982," he identify deficiencies . . . are double. Bernabei said her greatest can. c crossed by government officials in cern is resolving the serious allega. His fears were confinned. At the an effon to vindicate their own in- tions made by the former workers. f October visit, the NRC inspector adequate investigations and inspec. " e want to rnake sum mat m ' sold him the problems had been cor. Sons," wrote project officials. Port comes outene of these days.It's rected or the specifications for the been over a year," she said. work had been changed, Gunderson Fortuna has yet to respond to the Jim Hanchett, a spokesman for l said. request for an investigadon, said Lynne Bernabel, staff counsel for the Region V office, said the report "When I raised problems that I the project. Owen Shackleton, the is expected to be released within a i had not included in my prior affida. Region V investigator accused of month. vits, the engineer found that these leaking the information, works for And he saidheis confident thathis i problems had neither been cor. Fortuna, Bernabei said. colleagues at the regional office will recten nor discovered at a prior ca the Inumal W ,
"" " When contacted for comment, vestigation is completed. "The To call attention to 'he unresolved Fortuna referred all media inquiries ge am not (me," he said.
safety allegations, the Palo Verde to Frank Ingram,as lpRC spokes. .",We,re Prepared to respond to Intervention Fund released the snan. ; C' s - . thern. , } ' sworn statements of Gunderson and In a June 2 interview,Ingram anid Tomorrowt How much does it
- Royce at a February press confer. east?
.that the Feb.28 letter had just been ence. -
1 4 p
- , ..-.. _,- . _ -.._~ _ _ . . , _ . _ _ , - - , _ _ . . - _ _ . . . , _ _ . , - ~ . . - _ _ , . , _ , _ , - _ .
Llb,B5 -
Neuf 6 i me_& ' MUdPMENTFAILUNE i B. r. yo
= amma gg !
A E\E AT m@mkwan spokeswornanhi>TnaFnxungsaidJun
.h.-4W .. . 20-morethanamonthafterthe. *
>n"
&re. 3 .$ v';., *..,*cdd'n' . .AdaylaterM . Msaidt
. r,..
. e-.g--' a;..m s.%:w: - 5*c e " Q.ireak <
' *haF MtW@: " " c. - . .<
.a.:m .
.g occaredbecause IWNUn p ,qqa,m,g:/y beenthereaImgtime,so m' . fangue -it wss ed
- Dama"geh'ad beer warrioriid r diemistshpped,fellandspbedsome oustittle'moretoadd.NR .c ;Verycafyonthemomin erRayFishacknowledgesthatsome'I ofMay11a'.. And
..esumatedat$6.000lsheadded ; He.N samplesof aradioacutesubst.tnceon ., ;floodmgoccurredbutdoesntknow;' + beausethePVCp:pecarried.coo himself. He was still in an ambulance en .gwhere tdcrurred;whatcauseditor'e'ven'?, k ld dh anaarcxmditionermacomputerroom,s h h dbeen .
it route to Mary.-Je Samaritan Hed al-T".s C if theflo6dingwasresponsibleforthe'.4."'.ac now e ge t att ere a~ ' .se co whenroutme monitoringreveale - inatestin rde,sothedourrtimedid NANfailure.*Thereasonitwasn't :c.
'second,farrnore serious problern: // ' wo king may nothase had anything to do aHec ann mg *. g a .
radioacuvefuelwasleakingintoth'e - - withtheDooding?hetoldNewlimes- . Fronmgoffcredoneadditiona' detail: water that cods the reactorcxne. The f , raismg the unanswered uestion dhow , the flooding didn't occar unti! 830 a.m.. heart of the Palo Verde nudcar plaat wa
~. 1 FEMA,workingwithNikCinformation,
.. rruntuesc)?crFEMAdaimec d;sintegraung. to such amore definitive condusion. ortwengsystemhadbeenrestored."T Thus began an eight. hour scenario'at ' ~came . Fish's uncertainty is explained by the th%m, first a.fuhcum[dNAN wasnota Arizona'a 'ere nukethat edted fact that NRC didn't have any observers Wtheleak, she ' - before . ,
intothe of a radioactiveplame, residentsuptotwelve e . inthereactorcontrotroom.eithecFish's . addingsheis notm e*justihatdid~ the evaluatorswereaDinthePaloVerde. cause n. . . , m ,p .\ 3 ,
. milesamayandanunrelated,+m A , simulatocinwhichtheexercisewss .
uncontrdled fire among oil storage tar.ks. being mndticted beause the appropriate gweek's endtherestiDwerenianf malexplanationsfmmAPSfora Allditwaspartof atestof fhe i:.if- - msuumentreadingsmuldbe sto@atseemstahav*asmany . still/mcomoletereactor's ..y programmedintothe simulator's vanaams as there, mere participents.Ti disasterp15n,and atitspeakht t gi i gthcNRCabetterchance mgcertaintsthatnota wwd abo-hundredsofcounty,stateandfedemployeeswereconducung,partopating toevaluate*thereac ionsdthe- gfailure.mnputerdown-timeor compu er, v n
. operators." . . . " . . mntrotrmnfbecngwasuueredtothe inandevaluatingthetest. . . ..
GastonFiorel5,oneof theNRCs ; press at any time dunng the dn11itself - Theproctorsforthisfinalexamwre residentinspeciars at Palo Verde.added a drill desqned m part to*dernonstrate dulyimpressed.giungvirtually . tothe mystery by ' telling New Ecs that the adequacy cf communication linkage a unammnusraverenewstojustabout the floochegwasn Lin the ccntroi room but tobothtne publicandnewsmedia every agencyinvulved..What noneof inanotherpanof thebuilding. Acconiing din themmenooned atthe time,homever-i to Fiorelli,the problem ocnured w hen a {dmgs.gtoFEMA's evah.ation and whathasbeennotedon)bnpassing pumpwasstartedandcreateda* water * . . G 6. W-e c. . since - wasa trataccidentt t occurred1.arnmer-asuddensurgein uter wetmcosa=LwisaboutPaloVer at the drifts outset. At the very least the tressure-inatemporary PVCpipe, first surfaced in a big wav about a year result usa short<ircuitinthe hepiperupturee'snderthestress, into ago,wtien tuo electrcans told the NRC Notification AlertNeturk,an sp31ing antmknon amountof uter o, r unproper materials being used qu;& emergencywaming systemthatalerts acrrndor;someof the utenhesaid, inspecnonsthatwerebeirifakedand ' crrnty and state officials that a potential dra:redintoaroomfuDofelec:rical systemsbeingunpmedthatledtc disasterisinthe making. equmentandcausedminordamage wortNRC'srespmsewasto . y* Atitsworst howevetthe acrident "hayiwlateditpre la anmvestigationoutofitsRe.gion raisesseriousquestionsaboutthe '
' Fure'hadof APS.ad that*the Voffice:mvestganoonsultsum -
training of contral room operators, th'e tystemhssbeen ealsosaid prornisedfortastsummee 5P credibthtyof ArizonaPublicServiceand . tnathehadn'tbeen givena douar Todatetheinvesegatxmlmsd!!nct theovers:ghtcapabihtiesof..theNuclear ' ' estimatedthedamageandthathehadn't . beencompletedandsomeneooleare - RegulatoryCommission. seentheruptadpipe.Andal he . - gtowonderwhy.hispast-The first clue to what occurred isinwasonedtheobserversintne a '~ ' toc theGovemrneAccountaM i document ticed " Evaluation Findings" Fe . morellisaidbewasn'tawarethatthe ~ r. . Pnycr,aWashingtombasedgroupthat prepared bythe FederalEmergenef+m . NAN wasnar>funcncr.af '
. inveshgatesworkercomplaintsabout Management Agency.% - ' Thatleavesonlytwootherversionsof tconstrucnonaroun:
essmaa!!y worked we", throughout the whathappenedatthedriD,cueadvanced , nudearponer theNRCsOfficeof systemf notes the recently issued report, '.byworkersattheplant,theotherby ."f AP9 r thecuatry.E == tuview theRegion
*notwithstandine a few rrurar problems. . itself. ~ e 4 0, u , . - -. toworker aitidundPaloTer
. Theproblem?"TheNANciruntwas -
inoperative from 5 a.m. to 8:10 was a.m.This caused by ~ Acrzrdingtetbewerkers,theflood a contrai roarn operator 8"P""" ion.SttDrghappened. - anutrud ,
. was due to flooding in Control Room #1 st who avalveinasteamptpetoo - . a cold M=ratheNRCooudstiHbeturni:
shodder tem pd 'he aDegations if
- PaloVerde whichshortedout ,-- .
-causingthe samela'nad . Starreporter ^ :
mennenedby Fxrelli.onlyina notkrAmenaDa@lierthismonth'? '
- cxnmunicationscable." . Bemiy Ear Althoughthatsounds grim, FEMA systempressumedto2.000 per Matyn.
perturbedbecause er on aaximrtseries * ' wasnot squareindn.Defortzofthe aboWPaloVerd eaDedtheNRCtoask
*altema means cnmrnurucation were wasso theentn ' surged. J. , twhsithaddoneinresprumetotheGAI l .used*and*therewasnodelay".in s ~
with toriploose l e stearapipe;; Os)une2shewastnidthatthe 25letterfrornGAPhadjust - notifying the apprceriate PVC' auther'tuestrhididx!. Qq d i)-thevanorisalerts.The*alter
" u~t ittums
' 'Th ngwewereconcemed .t.:., tem ehRC
' about it 1. divumm wican N RCthat askadwhyithadtakentheNRC 7 weet Wikin aboutwas a interferencethat ,becausethey'retakmg eattitu that.it .c resuhedina ' FEMAteamleader : - [the PVCprpelisonly temporary " .hburarme a 1 ; . numthsshe toperfcrro a KenNaumantoi NewTimestwoweeks ago. FEMA.heexplained,was
- , .cfferedonesiteprpefittec*butthepomtV isthatthey've got unproperoperator g jf Ge justNitCoow oneof those
*y;~ %
saysitam responsible only for evaluating how web trauung.How many morennstakescan 4 gn the dnil was anducted off-site; on. site ~
' . we exped therntomake?" . N . , M.%citsRegionV duelastmannerasdfice todetermine w e ta! cation wasthepurvienof the NR 'Anotherplantworkerwentfurtherand .!n Thatreportwas .
and FEMAtearnedof thefl chargedthat Nin. % . syurem, g . be withina wint becauseofinformationitrecerv thetest imeof theNRC-therewereno FEMA jh [
.. [ wouldn
~wfw,mw* */'J[.,w there n s.
a,L weekstoseafaD APSexplanationof the 2, . iinodenthavenenedremarkablysketchy.m* v -- ._ g ,. h.;. EXHIBIT 3 Idetails.Defiritiesponsetocc quen:; iproducedthekdaruanonthatdamage p ~ 4-(j.g s[.ad7 M 7 .f C... L. L E5 y ,drymgautof
=cminm. ire tcentaaedmiy
- erppment"andthatna .i .3.y.. ..e%.f y,y q.,
..G. n,4.rn.j .. md.... - m.. ..
dollarvaluenaabernassignedtatbe,.vva . -
.n o ' ..
r.,y.n l * .... .. . . r . y. . '
. ;..%p: m'a v .
- ' ; :a 3 ,:. :W.. . .s;.
. ~ ,(. y ,,..=
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, ,:.c.u . e l
e* f Ml' EXHIBIT 4 y ' TW
.t. WW ; T. .n.;. S m + 3:E 91 JA .-
Palo Verde Quarterly News y,i,7, ggg;
/ / .
[? Allen, Kirby already
~
6- ,A ., seasoned veterans
.e(
.. [ Managing a nuclear power station y ',, j' requires a staff with many varied backgrounds and experiences...
n q
," /-
( y p' s- engmeers, operators, radiation tech-
!,. . .. ra V N
. ,__ /Mf4mmeq'*M nicians, technical advisors, main-
,yE
. ,___-- .-- F " tenance personnel, and others.
MU [ hg h. gp.[,<y /;.::- e n.- N 'MM./- erg-Two of Palo Verde's managers for Operations, John Allen andJohn WW rse, . 2. j ., f-:9 N Kirby, bring to the project almost TE p *Q M +3. W E Vmd 9s . j l half a century of power plant oper-
- (t,b y4 A. MK5fif W " k. ! ations and nuclear engineering 3'
igejk d^ , ' V j , experience. Q g..- 4 jyn y a-..f. l
- M . p
/ - %.m*. *
-- sd $$Yolet ,"* "*N'io$*s" the Arizon2 Nuclear Power Project e
- L
"; " *? d in 1973. He moved to APS in 1978 and, most recently, served as 4
.m
. M4m -
8 nuclear engineering manager in Twelve steel panels are Installed stop the third containment building at Pelo Verde. Nuclear Project Management. The steel!!ning wf!! be covered with concrete, capping the building that will house a nucle ar resetor for Unit 3, which le 45.7 percent complete se of Aug. 31. (Unit i ls 96.5 responsibic for electrical engi-percent complete: Unit 2, so.s percent). r:eering, instrumentation and con-i trois engineering, health physics, Good news about Palo Verde radiari- P - i - avi - - protection, licensing and nuclear The newspapers are filled with highest rating possible from that records management. . stories about nuclear power plants agency, which gave special Allen is currently the technical ! being delayed, mothballed, and notice to the areas of quality support manager for Palo Verde even cancelled. The appearance of assurance and sa'ety. Operations. He is responsible for such stories has raised some under-
- The plant has had a positive engir eering. radiation protection standable concern about Palo review by the advisory commit- and chemistry, shift technical Verde's future promise. tee on reactor safeguards, a key advisor / independent safety engi-Tom Woods, APS' executive group of academicians who neering group, licensing, and the vice president and chief operating advise the NRC on nuclear plant water reclamation facility.
officer offered some good news safety. (Continuedpg. 2/ about Palo Verde at a recent APS
- Arizona Governor Bruce Babbitt, 5g employee meeting. who was a member of the ,G g g "We have a lot of reasons to be Kemeny Commission which -
7 very proud of the project," Woods examined the accident at Three d j+ said. "Palo Verde is one of the best Mile Island, has described Palo . nuclear power projects being built Verde as the "best-run nuclear AT.-%* s in this country, and that's not just my opinion but an opinion that's facility in the country. 2 really first-class construction and f
- f. p 8J held throughout the industry design job." M 3 {i 1 and the Nuclear Regulatory Com-mission itself," he added.
- James Hanchett, public affairs Ql 9 l
I Woods reeled off fact after fact officer for NRC Region Five, after a recent construction perform-4
-a 5 ,
j
- (,
9 about the state's first nuclear ance review of Palo Verde $ , power project. Among them: referred to Palo Verde as "better, @y, n 4 l
- A recent NRC appraisal described if not the best" nuclear station % .
(hc Palo Verde's overall construction under co truction. , record as "above average, f (Continued pg. 2/ ,, ,, , , , ,,, o p, ,, ,, ,, ,, , ,, j ,3, gi,,,,, __ L_ _ _ __ g, _ _ _ _ _______._._.._____.up._ _ _ _ _ _mana_ ger for start .____.
- I, native that could have been built Good news < continues; in this time frame. Dist's not just our opinion. but the opinion of inde. Palo Verde .in
- T. W. bishop, chairman and chief pendent consult nts."
of Project Section 1, the Reactor "We're pleased with Palo Verde's CUSIOrnerS, Construction Projects Branch of progress. We're going to continue the NRC, confirms the high marching right down the road beSt in . terBSt I l regard f,or this project in his to licensing and operation with recent report: "The licensee's the assurance that Palo Verde is The construction of Palo Verde is ! (APS)performancein the are;ts of going to be a plant we can all be in the best interest of APS cus- l quality assurance, safety-related proud of." tomers,2ccording to 2n independent ' structures. corrective actions and assessment of the company's ; reporting. 2nd training displayed construction program filed recently , unusual competence." Allen, Kirby< continua, with the Arizona Corporation ' In addition to his experience with Th rt, which reviewed tal s as en r ise e SRP and APS, Allen was employed APS* total construction program the plant's long construction. at the Rancho Seco Nuclear Generat- but centered on Palo Verde, was period, participants have good ing Stati n near Sacramento, ordered by the commission in reason to be pleased with the pro- California and previously served February of 1981, when the com-ject's record of cost control. with the U.S. Atomic Energy pany's emergency rate increase was While Palo Verde has tmt been Commission. He holds a bachelor of approved. The ACC contracted immune to the increased costs science degree in mathematics from with Decision focus, Inc., of Palo experienced throughout the con- b" ** '80" Alto, California, to conduct the study.
'8* 2nd 2 struction industry, its current master f science degree in engi-The report concludes that APS projected cost is still signifi- current construction program,
"'" 8 CI'*') frcm the Uni-cantly lower than many other versity f Wash.mgton. with its current share of the Palo nuclear power plants constructed J hn Kirby joined APS nine Verde plant (29.1 percent)2nd with in a comparable time frame. years ago as a nuclear operations coal plant instalianon in the late o in 1981, after 1,3-16 manhours consultant, coming from the Sac- 1980s or early 1990s, as needed, ,
ofinspection, the NRC found ramento Municipal Utility Dis- offers APS customers a significantly only five items of non<om- trict where he served as training lower cost than alternative plans. pliance in Palo Verde con- coordinator. "We recommend that the company struction. That's 269 manhours Kirby was promoted to assistant tm a2gement and its regulators ofinspection per item of non- plant manager for Palo Verde in proceed with the completion of compliance versus a national 1976 and in 1980 became West Palo Verde units maintaining APS* sverage of only 72 hours. And Phoenix Power Plant superin- current ownership share," the sfier 571 manhours, no items of tendent. He is presently the manager study states. - l for start up2t Palo Verde, The study, which includes detailed non compliance were found by the NRC in Palo Verde operations. Kirby has attended the University sensitivity analyses of Palo Verde f Nebraska, Glendale Community costs, operation dates and capacity
- The Palo Verde licensing process College, Scottsdale Community factor as well as load growth rate is on schedule and, despite the College and is recently attending and cost of future coal units. confirms
< interrenor's claims that the Arizona State University to finish 2 APS own findings that the com-plant is not assured of adequate bachelor of science degree m pany,s present construction program i cooling water. contracts with the industrial supervision. is on target with the future needs
! supplying cities are sound and * ***"
- E *
- 8 ******
! water'is already being delivered l under those contracts to the site. Woods said construction of nuclear power plants has become l 2 sensitive and complex business.
' Our critics are tenacious, but i ;
f 77&a.
.. Palo Verde chemist David Fuller de-l t
the fact remains that the overall cost i'. c4 monstrates the " abdominal thrust" he used to save the life of Bob Johnson, l to produce power at Palo Verde {q . .,
,..M.g supervising chemist on unit 2, recent-will be lower than any other alter- r
#p.-?M g , it I i *..,
l Qt '$ e ly. When Johnson began choking on a piece of ground beef during lunch l s ., g
' *' h, at the plant site, Fuller applied the lif a e
saving technique he had learned
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.,. Ing. With the very first attempt, the l
- 4 g, ,s # food lodged in Johnson's throat broke
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f loose and he was etde to breathe A, 3
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t 0 'y 4 Of PVNGS expected - Additionally. strong testimony was given during the hearings Es\ j f 1(9 s by November showing adequate efriuent water j,, a W.,g ;,-a M
. supplies even under the most 2 -
A decision by the Nuclear Regula- adverse weather conditions. Exist-
"t , tory Commission (NRC) on the ing contracts with supplying cities
, licensing of Palo Verde Nuclear are sound. And effluent is, in fact,
_ Generating Station ut is expected already being delivered to the site later this year following the recent under those contracts. 6- h, -$g - completion of the Atomic Safety and Licensing Board (ASLB) hearings in The ASLB hearings were com-pleted in June and APS filed it's pro-1( . Phoenix. . posed initial decision on Julv 26.
"- D During those hearings,interrenor
~
The interrenor's proposed initial [ g [--- Patricia Lee Hourihan argued that Palo Verde will not have a sufficient decision, filed with the ASLB on August 13, reiterates the contention M ,
- n. meg effluent cooling water supply. that Palo Verde does not have an Indian water rights and alleged assured cooling water supply. A cYnd vieYled e Pa o e de N aulty workmanship were addit- decision on licensing for Palo Verde Ocneratini station enroute to Agentic sonal issues raised during the hear. Nuclear Generating Station units
- city for the Miss Americe Pageant Debra ings by Hourihan and her attorney, is expected from the NRC by plaled in tr e top ten in the finale of the Lynne Bernabel. November.
bruty pageant held sept.11. However, as Indian water rights and other legal issues surrounding the contracted cooling water supply No increase expected Bynum named manager were raised, testimony on these issues was disallowed by the ASLB. In Palo Verde,s cf Nuclear Operations According to Board Chairman Joe Bynum has joined APS as Robert Lazo, the board did not want COnStruCi on l COSTS manager of nuclear operations at legal experts testifying on the Construction costs for the Palo Palo Verde. He will report to law Int rather expert testimony on Verde Nuc! car Generating Station are Electric Operations Vice President technical areas at issue in the pro- expected to remain at the current Carl Andognini. ceding. Hourihan and her counsel projected 54.3 billion for com-Bynum comes to APS from have filed a motion seeking a review pletion of all three units,in spite the Tennessee Valley Authority of the board decision to disallow of delays in the in-service dates for j (TVA) where he was assistant plant restimony, and hope to present their Units 1 and 2, according to Tom superintendent for the three-unit, testimony to an appeals board. Woods, executive vice president and 3,456-megawatt Browns Ferry Allegations ofimproper work- chief operating officer. nuclear plant, largest of its type in manship, inferior materials and "We now anticipate that Uni: commercial operation. Bynum falsified construction records at I willload fuelin August of 1983 and also served as principal plant con. Palo Verde also were aired by Unit 2 the following August," tact with the Nuclear Regulatory Hourihan during the hearings. said Woods. Both units are expected Commission. According to the intervenor. an to generate electricity in the same During his 10 years with the TVA, electrical worker claimed some years that fuelis loaded. Woods said Bynum worked as assistant plant electrical system work, including scheduling for Unit 3 has not superintendent and special test sorne involving s'afety syttems, was changed. It is expected to be on coordinator for the Sequoya Nuclear improperly done and improper line in 1986. Plant, as start up and plant support materials used. However, these In the meantime, start up activities section supervisor in the utility's claims were never serified because for Unit I continue at an accel-e civision of nucitar power. and start- the intervenor's witness never crated pace. Pressure testing of the up engineer for Units I and 2 at physically appeared at the hearings. primary and secondary cooling Browns Ferry. He spent a year at A!though no specific a!!egations - systems for the Unit I reactor have Westinghouse in a program of were brought out, the board been completed. famihanzation on pressurized water ordered a quality control review of Woods said that start up pro-reactors, is a graduate electrical the general areas of construction cedures call for a series of tests engineer and holds a master's mentioned by Hourihan. That to be conducted on each system degree in nuclear engineering. review resulted in a cican bill of and sub system in the plant prior to health. j fuel loading. "These tests insure Got a question about Palo Throughout the hearings, the that each piece of equipment is Verde? If so, call 271-3385 primary issue continued to be functioning properly before we cr 386-6167. We've got adequate effluent supply and safe put the power plant in operation,_ l shutdown of the pl ant. Neverthe- he said. anewnre . . , , .
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Palo Verde's use of effluent deemed productive, beneficial Palo Verde's.three units, as do systems. These tests have pros ed . Palo Verde but also economical. , effluent to be a practical source of The water reclamation facility is i other power plants, need enormous cooling water. Practical experience designed to get "more mileage" out amounts of water to feed their of the water purchased from the in the usage of effluent for cooling cooling systems. But unlike most ; electric ge'nerating facilities, Palo has been gained in several coal fired cities' wastewater treatment Verde will use treated sewage . power plants which have success- sources. Thus, not only is pro- { cffluent as its cooling agent. fully used effluent in their con- ductive use made of what !s i The u>e of effluent has,in recent denser systems. normally considered waste, but . months, become a controversial Pre-operational testing of Urdt I the water is re-used up to 15 times issue in Arizona. Opponents of Palo systems and the water reclamation in the cooling system before it 1 Verde have publicly questioned facility is currently underway. . is discharged into a 250-acre the quantity and quality of effluent Since March, the water reclamation , evaporation pond. that would be used in the cooling facili:y has treated over 186 million The use of effluert will also bene-towers and condensers of the gallons of effluent. The treated fit those communities that will effluent is being stored in an 80 acre supply Palo Verde. Phoenix, Glen-plant, as well as the economic impact its use might have on communities. reservoir and is undergoing exten- dale. Mesa Tempe, Scottsdale. sive testing. Tests have shown the Youngtown and To!!esan will all Palo Verde contracts with the City of Phoenix and other nearby effluent coming out of the treatment supply the plant with needed facility meets or exceeds plant cooling water and will receive in , communities will more than meet return over 52 million annually. the plant's calculated annual operational quality. effluent requirement of 64,050 acre- Effluent is not only practical for feet for three units.The 91st Avenue .m ~ "'
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and 23rd Avenue water treatment *I ~...- ~
.,_ r plant is in fact obligated to supp!v as much as 140,000 acre-feet
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per year. . ' inJune of 1981, APS entered into
- a contract with the City of To!!eson ' - ^ ~ ^
e for the purchase of effluent to 'I N...%, - M . .iaga.- further guarantee an adequate water supply. The contract provides for a A.y . gq " ' Y ,. minimum of 525 acre-feet of addi-tional effluent during each month q.gf
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of the year. ' Effluent has never before been
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used as the cooling agent in a bN i , nuclear power plant. Because of - - - - , ff 4 . y;,y , this, extensive laboratory tests have The $210 mlltion PVNGS water treatment facility, one of the largest water treatment been performed to determine the plants in the U.S is now in operation proceselne effluent.The pient, which represents Artsone's tereest water conurvation program, witi employ a start of 150 when fuity impact of effluent on such coaling operational. i l New" Generation - eaesoar FIRST-CLASS Mall , Palo Verde Nuclear Generati ng Station 1- U.S. AGE P.O. Box 49 . PERMIT No.90
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Pato Verde, Arizona 85343 %,7c# (602) 932 3230 l l l
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EXHIBIT 5 UNITED STATES -
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. x JUN 9 1983 g
' Docket Nos.
0-528 50-529
. s Arizona Public Service Company P. O. Box 21666 f Phoenix, Arizona 85036 -
Attention: Mr. G. C. Andognini Vice President, Electric Operations Gentlemen:
Subject:
NRC Inspection - Palo Verde Unit 1 '
' This refers t o the inspection conducted by _ Messrs. G. Fiorelli and G. Johnston cf this office on May 2 - May 31,1983, of activities authorized by NRC Construction Perr.it No. CPPR-141 and 142 and to the discussion of their findings with you and members of your staff at the conclusion of the
; inspection. .
Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selected examinations of procedures and representative records, interviews with personnel, and observations by the inspectors. While no items of noncompliance with NRC requirements were identified within - the scope or this inspection, we wish to identify a matter which warrants additzcual management attention. Our follow-up of the control room cooler pipe rupture indicates that more emphasis needs to be placed on clearly defining and communicating the responsibilities for the execution of corrective actions to problems, particularly when several organizational units are involved. Please_ advise Mr. Fiore111 of'your conclusion and intended actions. 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 application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
Arizcina Public Service Company 2 JilN9 1983 Should you have any questions concerning this inspection, we will be glad to discuss them with you. ,
~
Sincerely, s (\_
, } \l( , '
D. M. Sternberg, Chief
, Reactor Projects Branch No. 1
Enclosure:
Inspection Report Nos. 50-528/83-19
, 50-529/83-11 cc w/enel:
E. E. Van Brunt Jr., Vice President Nuclear Projects Management G O e
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U. ',. NUCLEAR REGULATORY COMMISSION REGION V Reporc No.'50-528/83-19 50-529/83-11
' Docket No. 50-528 and 529 License No. CFPR-141 & 142 Safeguards Group Licensee: Arizona Public Service Comoany '
P. O. Box 21666 Phoenix, Arizona 85036 - Facility Name: Palo Verde Nuclear Generating Station Units 1 & 2 Inspection at: Palo Verde Site, Wintersburg, Arizona Inspection conducted: May 2 - May 31, 1983 Inspectors: M . [ ~3 - h3_ G. Fiorelli, Sepr Residjn[/Insp/ctor Date Signed Y b}$2Ut4-G. Johnston, Re ident I peftor / k d4- 23 Date Signed Approved by: T. Young, Jr., h . [-h ief, Regt r Projects Section 2 Date Sigred Summary: Insoection on May 2 - May 31, 1983 (50-528/8:,-19 & 50-529/83-11) Areas Inspected: Routine, resident inspection of startup testing procedures, Plant cleanjiness, control room cooler line rupture, startup testing, l allegation related to the lifting of leads and follow-up to the Circular 81-01. The inspection involved 199 hours onsite by the rasident inspectors. Results: No items of noncompliance or deviation were identified. l l t l C. w l
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DETAILS
- 1. Persons Contacted *
- a. Arizona Public Service Company (APS) y 'G.'C.-Andognini, Vice President, Nuclear Operations T.-Cotton, Engineering Manager ,
i G. Arnaz, Startup Quality Control Engineer J. Self, Shift Technical Advisor Snpervisor - D. Joy, Startup Quality Control Engineer
*J. R. Bynum, Nuclear Operations Manager
*G. Roedel, Corporate Quality Assurance Manager I
*J. Ki'rby, Startup Manager .
*G.
Pankonin, Startup Quality Assurance / Quality Control Manager
*R. Burdick, Shift Test. Coordinator
*W. Kraig, Quality Control Supervisor *
- b. Bechtel Corporation D. Emerson, Construction Craft Superintendent L. Fotter, administrative / Technical Support Manager T. Kelly, Electrical Engineer Group Support Supervisor J. Robinson, Electrical Startup Engineer R. Moody, Training Supervisor
- Attendees at Exit Interview on May 24, 1983.
I
- 2. Follow-up of IE Circular 81-01 (Closed)
IE Circular 81-01 discusses concerns over relamping of Honeywell Series 2 indicating pushbutton switches. The applicant has determined that there - are no Honeywell switches of the type described in the circular. However, the plant does incorporate switches similar to the Honeywell product made by Master Specialties. , The training program at present does incorporate a lecture for operators on relamping of these switches. However, the lecture does not include information available from the manufacturer that describes recommended procedure for relamping of the switches. The use of this particular procedure obviates the problem described in the circular where a bulb could fall back into the switch unit and short the contacts. The inspector discussed this circular with the manager of training and his staff and they agreed to review their lesson plns and include any topics from the manufacturer's procedure that are not included in this lesson plan. \
?
The applicant is still in the process of reviewing for action a number of bulletins and circulars. Because of this the inspector has emphasized that conrideration be given to items in these issuances that would be of interest to operator training. No items of noncompliance or deviations were identified.
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-3. Preoperational Test Procedure Review
. : The following preoperation test procedures bere reviewed for technical content, regulatory conformance and consistency with administrative
. contr.ols ~ governing procedure development, review and approval: ,
,- a. Precore, Reactor Internals Vibration Measurements b .- -Precore Hot Functional Testing Controlling Document '
- c. PlantprotectionSystem
- d. Balance of Plant Thermal Expansion Test
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Minor comme'nts were brought'to the attention of APS _ test personnel for ' appropriate inclusion in revisions to the procedures. No items of noncompliance or deviations were identiffed.
- 4. Startup Testing-i The heatup for hot functional testing commenced on May 17, 1983, with one reactor coolant pump running to provide heating for the first temperature plateau of 150 F. Preliminary measurements of the reactor coolant system piping were conducted to provide the baseline positions at ambient-temperature. Reactor coolant and steam generator chemistry were verified to be within specifications.
Testing of the safety injection system was not completed prior to the hot _ functinal test as planned. The portion of the high pressure safety injection,'l'ow pressure safety injection and shutdown cooling associated , with flow to the vessel could not be completed with the reactor head in place.. The problem is the flow out of the vessel could not be controlled.
- for a sufficiently long period of time to do. flow balancing. APS startup i
personnel stated that the testing will be conducted after the hot functional test when the head will be removed. The inspector reviewed the portions of the tests that were conducted and determined that testing had progressed to'the point to assure that a shutdown cooling pump would function in support of the hot functional test. i A review of the hot functional test controlling document confirmed that appropriate signoff of test requirements were being made. Information such as system lineups, procedure changes, and valve settings were documented as required. Observation of control room activities were menitored and noted to be controlled. The inspector challenged the existence of an annunciator light associated with the 1A reactor coolant pump which was in operation. The test coordinator and operations supervisor were cautioned to respect annunicator lights and alarms and to take proper corrective actions to clear abnormal annunicator/ alarm !. indications which were not justified by tests or existent operating . conditions. No items of noncompliance or. deviations were identified. l l l .
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3 S. Building Tours TheinspectorstouredthefacilitiesofUnitIanbUnit2onseveral
.: occasions during the reporting period. APS startup QA personnel and the e field superintendent for Bechtel Power Corporation for each unit
( accompanied the-inspectors on the tours. The housekeeping in Unit 1
' remains satisfactory, however,.the inspecto s continued to emphasize that t
furthcr. improvement would be necessary prior to reactor operations. Some isola.ed areas such as the inside of. electrical cabinets were found to , l cents- n varying amounts of debris. These areas were to_be cleaned foll.aing the _ tour. A check of two leads noted to be unterminated were checked and. it was confirmed that they were spares. No equipment abuses or unauthorized work was observed. It was noted.that some jurisdictional tags affixed to equipment indicated that the eq6ipment was still under the jurisdiction of Bechtel when it had already been turned over to APS. A review of status of plant tagging was to be made by the startup organization. The housekeeping at Unit 2 remained much as it has been, however, more effort has been expended to keeping the reactor cavity in better condition. The covering on the deck is in better shape, and the reactor
. vessel debris is out. covered with a plastic test structure that effectively keeps There remains significant work activity in the cavity which still contributes some debris on the deck.
No items of noncompliance or deviations were identified.
- 6. Rupture Control Room Cooler Line On May 11, 1983, a 'four-inch PCV water line servicing a standby cooler for the Unit I control room ruptured discharging water to an area outside
'the~ control ^ room. The rupture occurred when a cooler pump had been started for unknown reasons. While wetting was confined to the 140 foot floor area outside the southeast section of the control room, water did '
flow to the lower 100 foot level soaking the power supply equipment . associated with the' plant computer. Several components ret 2 ired replacement and the plant computer was again operable in several days. The potential for damage was much greater than was experienced. In following up of the corrective efforts of APS, the inspector noted that the actions had been limited to the tagging by Bechtel of the cooler pump discharge valves. The inspector had expected to see the power switch to the pumps locked out, tagged and evidence that instructions following the repair of the line would include a hydro test with precautions to operations which took into account that the pipe rupture was probably caused by a water hammer when the pump had been started. Following discussions with startup management representatives, the inspector was provided assurances that proper corrective and preventative actions would be taken. , i. ' Aside from the unknown reason for the operation of the pump (the system still' belongs to Bechtel) which had been run many tinies before and which would not have been of consequence if the pipe had not ruptured, the l
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- 4 inspector noted that several organizational . units were involved in some
.. vay with the problem and its resolution with none assuming the full
;a'uthority and responsibility for initiating complete and proper
- , corrective action.
While this incident did not represent an immediate
' safety problem, this matter was brought to the attention of APS L_ ' management since it represented one of several problems where the absence < .of coordination or definition of responsibility for an activity was a contributing factor. .
No items of, noncompliance or deviations were identified.
- 7. Allegationhollow-up -
The inspector followed up on a concern reported to the NRC by a former Bechtel employee who worked at the Palo Verde Plant. The concern was reported as follows:
"Startup personnel do not follow construction cable termination procedures. Startup personnel remove wirer without termination cards and leave them hanging in cabinets. In one instance, I had to do a termination three times in one day, and it appeared that someone in startup had changed two of the wires in the cabinet after each time I hooked it up. This was verified by an engineer whose name I do not recall.
wanted to. This The startup personnel simply changed the wires any way they - is one instance of a common occurrence." A subsequent discussion with the individual was conducted in an attempt to narrow the location of the console involved and to get an estimate of the time of the event. The inspector's follow-up efforts provided the following information. ~ Testing activities are not controlled by construction procedures. Equipment and systems are tested by a startup organization which is separate.from construction using startup testing and administrative - control procedures. These procedures allow the lifting of leads for the
- purpose of checking circuits and testing equipment. The lifting and restoration of leads are controlled by procedures utilizing check sheets, drawings or other documents such as the Bechtel EE 580 report which provides termination identification and location. If leads remain lifted
( and test personnel are not in attendance such as during the interruption L or termination of a test, the leads must be tagged and the condition recorded in a test modification log. This log which controls equipment changes and their restoration such as lifted leads is used to assure proper restoration and verification. The inspector discussed the identified concern with the referenced engineer. The engineer did recall an assignment of his at abcut the same l time and location, however it did not involve the repetitiveness of the l lifting or the cuitching of the leads. In the experience he discussed l with the inspector, the engineer believed the leads had been lifted by construction personnel to permit a plant modification since the system was still under the jurisdiction of Bechtel construction. Restoration was properly made, i l ! The incident occurred during the initial phase of prerequisite testing. Any leads which would have been left unterminated would have been i I .
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detected.during the preoperational testing phase which is conducted-to confirm that system operability requireme,nts are met.
, ,. No items' of noncompliance or deviations were identified.
- 8. Exit Meeting
* -An exit meeting was held on May 24, 1983. The findings of the inspection were discussed. Highlighted was a discussion on the need for management to improve the definition of. responsibilities and authorities, -
particularly when activities involve several organizational units. i O e e e O e s ,_.~y+, - , , ~ , ---.-,.7 ---- . . . - - - - y, -w,w,- .--,y---.7-._-,.,__e.c.. =~, , ,, . r_, ,-- *}}