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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20212B1681999-09-13013 September 1999 Forwards Insp Repts 50-275/99-12 & 50-323/99-12 on 990711- 08-21.Four Violations Being Treated as Noncited Violations ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210H6181999-07-27027 July 1999 Forwards Insp Repts 50-275/99-07 & 50-323/99-07 on 990503- 0714.Apparent Violations Being Considered for Escalated Enforcement Action ML18107A7011999-06-25025 June 1999 Requests Rev of NRC Records to Reflect Change of PG&E Address ML20205J3381999-04-0808 April 1999 Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision Expired. Commission Declined Any Review & Became Final Agency Action on 990406.With Certificate of Svc.Served on 990409 DCL-99-038, Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f)1999-03-31031 March 1999 Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f) DCL-99-033, Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl1999-03-12012 March 1999 Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl DCL-99-010, Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld1999-01-26026 January 1999 Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld ML20202A9831999-01-18018 January 1999 Informs That Modesto Irrigation District No Longer Seeking Addl Interconnection with Pacific Gas & Electric Co at Pittsburg,Ca & Matters First Addressed in 980429 Comments in Opposition to Restructuring of Util Have Now Become Moot IR 05000275/19980121999-01-13013 January 1999 Informs That Insp Repts 50-275/98-12 & 50-323/98-12 Have Been Canceled DCL-98-163, Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld1998-11-24024 November 1998 Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld ML20195G5161998-11-16016 November 1998 Forwards Insp Repts 50-275/98-16 & 50-323/98-16 on 980913- 1024.No Violations Noted ML20155F7951998-11-0303 November 1998 Second Partial Response to FOIA Request for Documents. Records Subj to Request Encl & Identified in App C DCL-98-123, Submits Listed Address Changes for NRC Service Lists for Listed Individuals1998-09-0909 September 1998 Submits Listed Address Changes for NRC Service Lists for Listed Individuals DCL-98-108, Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year..1998-08-0707 August 1998 Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year.. ML20236T2931998-07-24024 July 1998 Forwards Order Prohibiting Involvement in NRC Licensed Activities for 5 Yrs.Order Being Issued Due to Falsification of Info on Application to Obtain Unescorted Access to PG&E Plant ML20236T3431998-07-22022 July 1998 Forwards Insp Repts 50-275/98-11 & 50-323/98-11 on 980526-28.Apparent Violations Identified & Being Considered for Escalated Enforcement Action ML20236J2251998-07-0101 July 1998 Ltr Contract,Task Order 232 Entitled, Review of Callaway, Comanche,Diablo Canyon & Wolf Creek Applications for Conversion to Improved TS Based on Standard TS, Under Contract NRC-03-95-026 ML20236G0691998-06-19019 June 1998 Forwards Endorsement 123 to Neila Policy NF-228,Endorsement 145 to Neila Policy NF-113,Endorsement 124 to Neila Policy NF-228 & Endorsement 89 to Maelu Policy MF-103 IR 05000275/19980051998-04-17017 April 1998 Forwards Insp Repts 50-275/98-05 & 50-323/98-05 on 980202-06 & 23-27 & 0302-18.No Violations Noted.Insp Focused on Resolution of Previous NRC Insp Findings & Included Review of Issues Identified During Architect/Engineering Insp Rept ML20203G0371998-02-25025 February 1998 Forwards Revised Copy of NRC Form 398, Personal Qualification Statement - Licensee, (10/97) Encl 1,which Has Been Revised to Reflect Current Operator Licensing Policy DCL-98-014, Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld1998-02-10010 February 1998 Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld ML20199H6691998-02-0202 February 1998 Ack Receipt of ,Transmitting Rev 18,change 11, to Plant Physical Security Plan,Submitted Under Provisions of 10CFR50.54(p).Role of Video Capture Audible Alarm Sys Needs to Be Addressed in Security Plan,Per 980123 Telcon DCL-97-187, Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld1997-11-19019 November 1997 Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld IR 05000275/19970181997-10-31031 October 1997 Forwards Insp Repts 50-275/97-18 & 50-323/97-18 on 971006- 10.Insp Verified That Liquid & Gaseous Radioactive Waste Effluent Mgt Program Was Properly Implemented.No Violations Noted DCL-97-156, Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld1997-09-16016 September 1997 Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld ML20210H4671997-08-0202 August 1997 Requests That NRC Suspend Investigation & Review of Issues Raised by Modesto Irrigation District & Transmission Agency of Northern CA Re Contention That PG&E Had Violated Nuclear License Conditions Known as Stanislaus Commitments ML20137N1591997-03-31031 March 1997 Informs That Licensee Facility Scheduled to Administer NRC GFE on 970409.Sonalsts,Inc Authorized Under Contract to Support NRC Administration of GFE Activities ML16343A4801997-02-25025 February 1997 Forwards non-proprietary WCAP-14796 & Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methodology. Proprietary Rept Withheld,Per 10CFR2.90 ML20134H6271997-02-10010 February 1997 Fifth Partial Response to FOIA Request for Documents.Records in App I Encl & Available in Pdr.App J Records Withheld in Part (Ref FOIA Exemption 5) & App K Records Completely Withheld (Ref FOIA Exemption 5) ML20134K3421997-02-0606 February 1997 Conveys Results & Conclusions of Operational Safeguards Response Evaluation Conducted by NRR at Plant,Units 1 & 2, on 960909-12.W/o Encl ML16342D5291997-01-31031 January 1997 Transmits WCAPs Supporting NRCs Review of License Amend Request 96-10,rev of TSs to Support Extended Fuel Cycles to 24 months.WCAP-11082,rev 5,WCAP-11594,rev 2 & WCAP-14646,rev 1 Withheld ML16342D5331997-01-24024 January 1997 Requests Proprietary Version of WCAP-14646,rev 1, Instrumentation Calibration & Drift Evaluation for Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1997 Be Withheld from Public Disclosure Per 10CFR2.790 ML16342D5311997-01-24024 January 1997 Requests That WCAP-11594,rev 2, W Improved Thermal Design Procedure Instrument Uncertainty Methodology,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation Be Withheld from Public Disclosure,Per 10CFR2.790 ML16342D5321997-01-24024 January 1997 Requests WCAP-11082,rev 5, Westinghouse Setpoint Methodology for Protection Sys,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1996 Be Withheld from Public Disclosure Per 10CFR2.790 ML20136C3521997-01-11011 January 1997 Discusses Japan Oil Spill & Np Intake & Possibilities of Such Event Occurring at SONGS or Dcnpp ML20133F8961997-01-0909 January 1997 Responds to NRC Ltr of 961206 Received on 961210 Which Requested Further Info Re Utils Violations of Conditions of Its Nuclear Licenses Designated to Promote & Protect Competition in Bulk Power Market in Northern & Central CA ML20133F8721997-01-0909 January 1997 Acks & Responds to NRC Ltr of 961206 Received by Undersigned on 961210 Requesting Further Info to Document Tancs Assertion,Per Filing on 960429 That Util Has Violated Terms & Conditions of Nuclear Power Project Licenses ML16342D5521996-12-18018 December 1996 Requests That Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methology, Be Withheld (Ref 10CFR2.790(b)(4)) ML20129J4001996-10-18018 October 1996 Forwards Order Approving Corporate Restructuring by Establishment of Holding Company & Safety Evaluation NSD-NRC-96-4846, Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl1996-10-16016 October 1996 Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl ML20129G6121996-09-24024 September 1996 Second Partial Response to FOIA Request for Documents. Forwards Documents Listed in App C,E,F & G.Documents Available in Pdr.App E,F & G Documents Partially Withheld Ref FOIA Exemptions 4 & 6.App D Record Listed as Copyright DCL-96-170, Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld1996-08-14014 August 1996 Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld DCL-96-141, Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld1996-07-31031 July 1996 Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld ML20116B8411996-07-22022 July 1996 Forwards Revisions to SR 95-03,SR 95-04 & SR 95-05 Re EDG 1-2 Valid Failures ML20117E6171996-05-24024 May 1996 Forwards Public Version of Rev 11 to EPIP EP R-7, Off-Site Transportation Accidents DCL-96-102, Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld1996-05-0606 May 1996 Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld DCL-96-096, Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 151996-04-16016 April 1996 Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 15 DCL-96-054, Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld1996-02-28028 February 1996 Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld 1999-09-13
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18107A7011999-06-25025 June 1999 Requests Rev of NRC Records to Reflect Change of PG&E Address DCL-99-038, Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f)1999-03-31031 March 1999 Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f) DCL-99-033, Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl1999-03-12012 March 1999 Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl DCL-99-010, Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld1999-01-26026 January 1999 Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld ML20202A9831999-01-18018 January 1999 Informs That Modesto Irrigation District No Longer Seeking Addl Interconnection with Pacific Gas & Electric Co at Pittsburg,Ca & Matters First Addressed in 980429 Comments in Opposition to Restructuring of Util Have Now Become Moot DCL-98-163, Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld1998-11-24024 November 1998 Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld DCL-98-123, Submits Listed Address Changes for NRC Service Lists for Listed Individuals1998-09-0909 September 1998 Submits Listed Address Changes for NRC Service Lists for Listed Individuals DCL-98-108, Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year..1998-08-0707 August 1998 Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year.. ML20236G0691998-06-19019 June 1998 Forwards Endorsement 123 to Neila Policy NF-228,Endorsement 145 to Neila Policy NF-113,Endorsement 124 to Neila Policy NF-228 & Endorsement 89 to Maelu Policy MF-103 DCL-98-014, Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld1998-02-10010 February 1998 Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld DCL-97-187, Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld1997-11-19019 November 1997 Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld DCL-97-156, Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld1997-09-16016 September 1997 Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld ML20210H4671997-08-0202 August 1997 Requests That NRC Suspend Investigation & Review of Issues Raised by Modesto Irrigation District & Transmission Agency of Northern CA Re Contention That PG&E Had Violated Nuclear License Conditions Known as Stanislaus Commitments ML16343A4801997-02-25025 February 1997 Forwards non-proprietary WCAP-14796 & Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methodology. Proprietary Rept Withheld,Per 10CFR2.90 ML16342D5291997-01-31031 January 1997 Transmits WCAPs Supporting NRCs Review of License Amend Request 96-10,rev of TSs to Support Extended Fuel Cycles to 24 months.WCAP-11082,rev 5,WCAP-11594,rev 2 & WCAP-14646,rev 1 Withheld ML16342D5321997-01-24024 January 1997 Requests WCAP-11082,rev 5, Westinghouse Setpoint Methodology for Protection Sys,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1996 Be Withheld from Public Disclosure Per 10CFR2.790 ML16342D5331997-01-24024 January 1997 Requests Proprietary Version of WCAP-14646,rev 1, Instrumentation Calibration & Drift Evaluation for Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1997 Be Withheld from Public Disclosure Per 10CFR2.790 ML16342D5311997-01-24024 January 1997 Requests That WCAP-11594,rev 2, W Improved Thermal Design Procedure Instrument Uncertainty Methodology,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation Be Withheld from Public Disclosure,Per 10CFR2.790 ML20136C3521997-01-11011 January 1997 Discusses Japan Oil Spill & Np Intake & Possibilities of Such Event Occurring at SONGS or Dcnpp ML20133F8961997-01-0909 January 1997 Responds to NRC Ltr of 961206 Received on 961210 Which Requested Further Info Re Utils Violations of Conditions of Its Nuclear Licenses Designated to Promote & Protect Competition in Bulk Power Market in Northern & Central CA ML20133F8721997-01-0909 January 1997 Acks & Responds to NRC Ltr of 961206 Received by Undersigned on 961210 Requesting Further Info to Document Tancs Assertion,Per Filing on 960429 That Util Has Violated Terms & Conditions of Nuclear Power Project Licenses ML16342D5521996-12-18018 December 1996 Requests That Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methology, Be Withheld (Ref 10CFR2.790(b)(4)) NSD-NRC-96-4846, Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl1996-10-16016 October 1996 Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl DCL-96-170, Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld1996-08-14014 August 1996 Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld DCL-96-141, Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld1996-07-31031 July 1996 Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld ML20116B8411996-07-22022 July 1996 Forwards Revisions to SR 95-03,SR 95-04 & SR 95-05 Re EDG 1-2 Valid Failures ML20117E6171996-05-24024 May 1996 Forwards Public Version of Rev 11 to EPIP EP R-7, Off-Site Transportation Accidents DCL-96-102, Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld1996-05-0606 May 1996 Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld DCL-96-096, Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 151996-04-16016 April 1996 Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 15 DCL-96-054, Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld1996-02-28028 February 1996 Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld ML20100L4631996-02-23023 February 1996 Forwards Response to NRC Enforcement Action 95-279 Re Violations Noted in Insp Repts 50-275/95-17 & 50-323/95-17 on 951021-1208.Corrective Actions:Directive Was Issued to Plan 2R7 W/Six Day Work Schedule DCL-96-036, Forwards Public Version of Rev 18 to EPIP EP EF-1, Activation & Operation of Technical Support Ctr1996-02-20020 February 1996 Forwards Public Version of Rev 18 to EPIP EP EF-1, Activation & Operation of Technical Support Ctr ML20097E9341996-01-25025 January 1996 Forwards Public Version of EPIP Update for Diablo Canyon Power Plant,Units 1 & 2 DCL-95-272, Supports Comments Submitted by NEI Re Licensee Qualification for Performing Safety Analyses,With Listed Exception.Nrc Should Allow Traning Requirement to Be Met by on-job Training1995-12-11011 December 1995 Supports Comments Submitted by NEI Re Licensee Qualification for Performing Safety Analyses,With Listed Exception.Nrc Should Allow Traning Requirement to Be Met by on-job Training DCL-95-264, Forwards Change 6 to Rev 18 to Physical Security Plan.Encl Withheld (Ref 10CFR73.55(d)(5))1995-12-0606 December 1995 Forwards Change 6 to Rev 18 to Physical Security Plan.Encl Withheld (Ref 10CFR73.55(d)(5)) ML20094M6001995-11-21021 November 1995 Forwards Final Rept of Investigation & Analysis of Event 29257 Re Substandard Fastner Processed & Sold by Cardinal Industrial Products,Lp,So That Customers Can Evaluate Situation in Light of 10CFR21.21(a)(1)(ii) & (b)(1) DCL-95-204, Forwards Proposed Changes to Physical Security Plan.Encl Withheld1995-09-19019 September 1995 Forwards Proposed Changes to Physical Security Plan.Encl Withheld DCL-95-199, Requests Exemption to 10CFR73.55 & Provides Draft Changes to Plant Physical Security Plan1995-09-14014 September 1995 Requests Exemption to 10CFR73.55 & Provides Draft Changes to Plant Physical Security Plan ML20087A0471995-07-28028 July 1995 Forwards Security Safeguards Info in Form of Change to Proposed Draft Plant Security Program.Encl Withheld DCL-95-153, Forwards Public Files Version of Revised Corporate Emergency Response Plan Implementing Procedures,Including Rev 14 to 1.1,Rev 8 to 1.2,Rev 11 to 2.1,Rev 5 to 3.1,Rev 12 to 3.2,Rev 6 to 3.5,Rev 14 to 4.3.W/950807 Release Memo1995-07-27027 July 1995 Forwards Public Files Version of Revised Corporate Emergency Response Plan Implementing Procedures,Including Rev 14 to 1.1,Rev 8 to 1.2,Rev 11 to 2.1,Rev 5 to 3.1,Rev 12 to 3.2,Rev 6 to 3.5,Rev 14 to 4.3.W/950807 Release Memo DCL-95-134, Forwards Rev 4 of Diablo Canyon Security Force Training & Qualification Plan.Encl Withheld Per 10CFR2.790(d)1995-07-0505 July 1995 Forwards Rev 4 of Diablo Canyon Security Force Training & Qualification Plan.Encl Withheld Per 10CFR2.790(d) ML20086H5461995-06-29029 June 1995 Forwards Final Exercise Rept for 931020,full Participation Plume Exposure & Ingestion Pathway Exercise of Offsite Radiological Emergency Response plans,site-specific to Plant.No Deficiencies Noted DCL-95-046, Submits Summary Description of Proposed Vehicle Control Measures Per 10CFR73.55.Encl Withheld1995-02-28028 February 1995 Submits Summary Description of Proposed Vehicle Control Measures Per 10CFR73.55.Encl Withheld DCL-95-039, Forwards Public Version of Revised Epips,Including EPIP Table of Contents,Rev 18 to EP G-2,rev 3 to EP OR-3,rev 17 to EP EF-1 & Rev 3 to EP EF-9.W/950306 Release Memo1995-02-23023 February 1995 Forwards Public Version of Revised Epips,Including EPIP Table of Contents,Rev 18 to EP G-2,rev 3 to EP OR-3,rev 17 to EP EF-1 & Rev 3 to EP EF-9.W/950306 Release Memo ML18101A5671995-02-17017 February 1995 Informs of Improper Presentation of Jet Expansion Model in Bechtel Technical rept,BN-TOP-2,Rev 2 Design for Pipe Break Effects Issued May 1974.NRC May Need to Consider Evaluating Consequences of Potential Misapplication of Expansion Model ML18101A5681995-02-17017 February 1995 Requests NRC to Clarify Whether Plant Should Declare ESF Portion of Ssps Inoperable & Enter TS 3.0.3 LCO Under Circumstances as Ref in in 95-10.Subj in Re Postulated Slb W/Potential to Render One Train of Ssps Inoperable ML18101A5741995-02-17017 February 1995 Requests Clarification of Whether Plant Should Declare ESF Portion of Ssps Inoperable & Enter TS 3.0.3 Limiting Conditions for Operation Under Circumstances Described in Info Notice 95-10 DCL-95-033, Forwards Public Version of Rev 3,Change 14 to Corporate Emergency Response Plan (Cerp) & Cerp Implementing Procedures1995-02-13013 February 1995 Forwards Public Version of Rev 3,Change 14 to Corporate Emergency Response Plan (Cerp) & Cerp Implementing Procedures DCL-95-013, Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-11,rev 7A to EP RB-15:F,rev 4A to EP RB-15:G,rev 15A to EP EF-2 & Rev 14D to EP G-4.W/950208 Release Memo1995-01-24024 January 1995 Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-11,rev 7A to EP RB-15:F,rev 4A to EP RB-15:G,rev 15A to EP EF-2 & Rev 14D to EP G-4.W/950208 Release Memo DCL-94-258, Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-8,Rev 4B to EP RB-10,Rev 5 to EP RB-12,on-spot Change to Rev 9 to EP RB-15:C,Rev 16A to EP EF-1 & Rev 3B to EP EF-3B1994-11-21021 November 1994 Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-8,Rev 4B to EP RB-10,Rev 5 to EP RB-12,on-spot Change to Rev 9 to EP RB-15:C,Rev 16A to EP EF-1 & Rev 3B to EP EF-3B 1999-06-25
[Table view] Category:PUBLIC ENTITY/CITIZEN/ORGANIZATION/MEDIA TO NRC
MONTHYEARML20236U6921987-11-20020 November 1987 Telex from San Luis Obispo California Mothers for Peace Re Facilities ML20236C1201987-10-20020 October 1987 Forwards Request for Stay Filed by Sierra Club in Proceeding Re NRC Issuance of Amends 8 & 6 to Licenses DPR-80 & DPR-82,respectively.Requests Commission Act on Request by 871026 ML20235K7941987-10-0202 October 1987 Informs of Change of Address for Receiving All Matls Related to Facility.New Address Listed.Served on 871002 ML20235F2561987-09-24024 September 1987 Forwards Request for Stay & Notice of Appeal of Licensing Board 870911 Initial Decision,Authorizing License Amends & 870902 Order of Board Denying Sierra Club Motion to Admit Contention & Request for Preparation of Eis.W/O Encl ML20238B7731987-08-0707 August 1987 FOIA Request for Records Explaining Status of Listed LERs Omitted from List,Previously Received from Nrc,Of LERs Filed by Commercial Nuclear Power Plant Licensees for Operating Year 1986 ML20237G9911987-07-28028 July 1987 Comments Supporting Onsite Storage & Reracking Until Federal Repository for Storage of All Spent Fuel Built.Support of Util & Facility Operations Discussed ML20236K7881987-07-0202 July 1987 Appeals Denial of FOIA Request for Interview Tapes Re SER of Operation of Plant ML20235G8501987-06-15015 June 1987 Appeals Denial of FOIA Request for Documents Re Plant Listed in App E.W/O App ML20215B1431987-02-25025 February 1987 FOIA Request for Listed Documents Re Mgt of Facility QA & QC Personnel ML20213A3971986-11-30030 November 1986 Summarizes ACRS Subcommittee on Extreme External Phenomena 861120 Meeting Re Facility long-term Seismic Program.Studies Necessary & Conducted in Excellent Manner ML20214P8771986-09-16016 September 1986 Submits Addl Corrections to 860822 Preliminary Conference Transcript.Requests That Response Remain Open Until 860919 in Order That Items Be Accurately Researched & Corrected. W/Certificate of Svc ML20212L1781986-08-18018 August 1986 Forwards Rept on Efforts to Resolve Sierra Club Contention (I)(A) ML20207H7661986-06-25025 June 1986 Supports San Luis Obispo Mothers for Peace & Sierra Club Request for Stay of Issuance of Amends 8 & 6 to Licenses DPR-80 & DPR-82,respectively.Problems Associated W/No Significant Hazards Determination Noted ML20214T6541986-05-28028 May 1986 Appeals Denial of FOIA Request for Ofc of Inspector & Auditor Rept & Related Documents Re Allegations That NRC Responded Improperly to Allegations of Whistleblowers at Plant.Response Requested within 20 Working Days ML20214T7651986-03-0404 March 1986 FOIA Request for Documents Re Ofc of Inspector & Auditor Investigation & Audit of Charges That NRC Improperly Responded to Allegations of Whistleblowers at Plant ML20210G9101986-01-27027 January 1986 Undated FOIA Request for Transcript of Closed Commission 811119 Meeting to Discuss Suspension of Diablo Canyon Unit 1 Low Power OL ML20141N3161986-01-14014 January 1986 FOIA Request for R Jackson to R Vollmer Re Diablo Canyon Hearing Reopening & San Onofre Review Status ML20138Q8561985-11-20020 November 1985 FOIA Request for Documents Re Ofc of Inspector & Auditor Investigation Into Charges That NRC Responded Improperly to Allegations by Whistleblowers at Facility ML20133G9571985-08-20020 August 1985 FOIA Request for Documents Re Ofc of Inspector & Auditor Charges That NRC Responded Improperly to Allegations of Possible QA & Safety Violations by Whistleblowers at Plant ML20198M9631985-06-17017 June 1985 Forwards Allegations of Safety Violations of Nuclear Regulatory Law or Westinghouse QA Requirements.Investigation Requested.Related Info Encl ML20133H5871985-05-0808 May 1985 FOIA Request for Documents Re Plant,Including All Contacts Between DOE Task Force on Commercial Nuclear Power,White House Cabinet Council Working Group & NRC Concerning OL ML20128Q6531985-05-0808 May 1985 FOIA Request for Three Categories of Documents Re Facilities ML20128P8031985-04-0808 April 1985 FOIA Request for Access to or Records Re Potential Environ Impact Associated W/Fuel Loading &/Or Low Power Testing at Diablo Canyon & AEOD Sept 1980 Rept on Browns Ferry Interim Equipment to Detect Water in Discharge ML20126J0361985-03-26026 March 1985 Ack Receipt of 850325 Telegram Re Followup Interview of Clients for Pending Allegations.Finalization of Interview Schedules Requested.Second Witness Name Should Be Deleted If Telegram Publicly Available ML20127F1741985-02-0101 February 1985 FOIA Request for All Records & Info Re Vendor Insp Branch 840229 Rept 99900840/83-01 at Cardinal Industrial Products Corp That Mention Diablo Canyon ML20107K7771984-11-28028 November 1984 Appeals Denial of FOIA Request for All Transcripts from Commission June,Jul & Aug 1984 Meetings Re Issuance of Full Power License for Facility ML20215L7951984-11-15015 November 1984 Forwards Amended Mcdermott & O'Neill Petition Re Plant,Per 10CFR2.206.Exhibits 7-18,consisting of Affidavits from 12 Witnesses,Being Filed W/Nrc to Avoid Compromising Ongoing Ofc of Investigations Investigation.W/O Encl ML20133Q2971984-11-0505 November 1984 Appeals Denial of FOIA Request for Transcripts of Commission Meetings Held During June,Jul & Aug 1984 Re Effects of Earthquakes at facility,SECY-84-70 & SECY-84-291 & Commission Final Order CLI-84-12 ML20107C4631984-11-0101 November 1984 Forwards Mc Thompson,Tm Devine & Lockert Affidavits Representing Portion of Results from 841009-30 Investigative Trip.Commission Has Adopted Adversary Position W/Respect to Public Since 840817 Stay ML20107H7671984-10-19019 October 1984 FOIA Request for Documents Re Commission Meetings Held During June,Jul & Aug 1984 on Complicating Effects of Earthquakes on Emergency Preparedness ML20107H0161984-10-15015 October 1984 FOIA Request for Documents Re Facility,Including Transcripts of Meetings Concerning Issuance of Unit 1 Full Power OL ML20107F9121984-10-0909 October 1984 FOIA Request for Transcripts of Closed Commission Meetings Held During June,Jul & Aug 1984 Re Complicating Effects of earthquakes,SECY-84-70,SECY-84-291 & Drafts of Final Order CLI-84-12 & Related Documents ML20107J4551984-10-0404 October 1984 FOIA Request for Documents on Jul 1984 SER Re Operation of Facilities ML20107J8011984-09-13013 September 1984 FOIA Request for Documents Re 840612 Congressional Briefing on Facility ML20129A3601984-09-13013 September 1984 FOIA Request for Documents Generated in Connection W/Sser 22 (NUREG-0675) Re Operation of Facilities Which Provided Further Findings on Whistleblower Charges ML20117B7041984-09-13013 September 1984 FOIA Request for Documents Re Sser 26 (NUREG-0675) Concerning Operation of Diablo Canyon Plant ML20107K5221984-09-13013 September 1984 FOIA Request for Documents Re Ofc of Inspector & Auditor Rept by R Smith on Allegations of Staff Misconduct at Facility ML20213F0181984-09-0404 September 1984 Alleges That NRC Handling of Allegations Has Shifted Burden of Proof to Allegers & Posed Threat to Anonymity.Nrc Posturing Also Alleged.Recommendations for Improved Handling & Relationship Between NRC & Whistleblowers Given ML20096H4441984-09-0101 September 1984 Suggests That Yin Be Assigned as Technical Liaison to Work W/R Meeks on Investigation.Team Could Help Regain Respect & Perform Definitive Exhaustive Investigation No One Could Challenge ML20117M9621984-08-0101 August 1984 FOIA Request for Probabilistic Seismic Safety Assessment of Diablo Canyon Nuclear Power Plant & Amend 52 to FSAR ML20093N8071984-07-31031 July 1984 Forwards Suppl Supporting T O'Neill 840727 Petition Under 10CFR2.206 on Behalf of J Mcdermott & T O'Neill.Also Expands Original Request for Retraining ML20093K0901984-07-29029 July 1984 Forwards Attachment 1 to T O'Neill 840727 Petition,Omitted from Original Submittal Due to Administrative Error. Affidavits in Support of Petition Will Be Executed on 840730 ML20093K1821984-07-27027 July 1984 Submits Petition to Defer Any Further Licensing Decisions Until Effects Neutralized from Onsite Harassment & Retaliation That Have Intensified Since 840413 Low Power Testing Decision ML20090H7461984-07-25025 July 1984 Withdraws Allegations Against NRC Staff as Summarized in Rept of Interview W/Ofc of Inspector & Auditor Atty R Smith. Methodology for Investiation Obviously Designed to Predetermine Results ML20093G5751984-07-23023 July 1984 Clarifies & Suppls 840716 Petition by Requesting Public Participation in 840726 Plant Tour,Nrc Public Rept on Postponement of Util Compliance & Naemark Comments on NSC Audit ML20093E5021984-07-16016 July 1984 Petitions Commission to Take Six Listed Minimum Steps Legally Necessary to Assure Public Safety Before Issuance of Ol.Petition Submitted,Per 10CFR2.206 ML20090A8451984-07-11011 July 1984 Forwards Affidavit of T Devine Notifying of Resignation of I Yin from Review Team Overseeing Plant Readiness for Commercial Operation,As Suppl to 840503 Petition Under 10CFR2.206 ML20092N1441984-06-29029 June 1984 Extends Time Limit for Relief within 840503 Petition Filed Per 10CFR2.206 Until Date When Commission Schedules Licensing Vote on Commercial Operations.Deadline Extended Due to Large Vol of New Evidence ML20092G7121984-06-21021 June 1984 Forwards Summary of 17 Addl Witness Statements Gathered in Support of 840503 10CFR2.206 Petition to Defer Further Licensing Decisions Until Completion of Listed Tasks ML20140C6471984-06-15015 June 1984 Extends Deadline for Commission Response to Mothers for Peace 840503 Petition Per 10CFR2.206 Until 840629 1987-09-24
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- - - _ . _ __ _ _ _ _ . _ _ _ _ _ _ . _ _ . _ _ . . . _ - . . . .
- GOVERNMENT ACCOUNTABluTY PROJECT institute for Policy Studies COLKETED 1901 Que Street N.W,. Washington. D.C. 20009 US E (202)234-9382
'84# N 1g2,fjg l9 g Nunzio J. Palladino, Chairman Bf MAkJP, I r -
Victor Gilinsky, Comissioner r ' er 3Egy l Thomas Roberts, Comissioner " , , . .- A.M. QM t i James Asselstine, Comissioner C"'
Frederick Bernthal, Comissioner l United States Nuclear Regulatory Comission 1717 H Street, Northwest Washington, D.C. 20555 i
Re: Diablo Canyon Nuclear Power Plant, Units 1 and 2 Docket Numbers 50-275 and 50-323
Dear Comissioners:
On behalf of the San Luis Obispo, California, Mothers for Peace,
+
the Government Accountability Project (GAP) submits this disclosure of misleading or false statements by the Nuclear Regulatory Comission staff with respect to the Diablo Canyon nuclear power plant. The statements involve material issues for the Diablo Canyon low-power license decision.
The record before the Commission was disterted by the NRC staff with j respect to evidence received from "whistleblowers" -- including both i what the witnesses told the staff, and how ;he staff responded. Examples of this misconduct occurred during steff briefings of the Comission on March 19, 26 and 27, 1984, and in Sup;temental Safety Evaluation Report
- - 22. NUREG-0675 (March 1984) ("SSER-22').
If the Comission had voted on a low-power operating license on March 26, its decision would have been' based upon a highly inaccurate and incomplete record. -The staff's misconduct suggests that its briefing will be equally deficient at the April 13, 1984 Comission meeting and possible vote. The staff's bias may also neutralize any Comission-imposed corrective action programs during low-power testing at Diablo Canyon. In i light of the staff's admitted uncertainty about the condition of the plant, r these pcssiblities must be eliminated prior to any licensing decision.
For these reasons, pursuant to 10 CFR 2.206, the Mothers for Peace petition the Comission to institute the following relief prior to any low-power licensing decision:
- 1) - provision for the joint intervenors to brief the Commission on April 13, along with the staff; 8etween April 3 and 13, 1984, interviews have been scheduled between the staff and nine whistleblowers represented by GAP.* The interviews will result in thausands of. pages of transcripts from a court reporter. These
- Two other whistleblowers who previously agreed to speak with the staff changed their minds, due in one case to loss of confidence in the staff's F ability to maintain witness confidentiality, and in the other to a loss of confiderce in the staff's integrity.
L g
b bo !5 PDR _ j]
f t
- Nuclear Regulatory Commission April 12, 1984 Page 2 1
! interviews already have disclosed highly significant new evidence both of potential safety hazards, and of misleading and false statements by the Pacific Gas and Electric Company (PG&E), that even continued to occur during PG&E's April 2,1984 bri.efing of the NRC staff. Examples of the issues L, discussed during the last week are enclosed as Attachments 1 and 2.
i Due to the staff's previous deception, the Mothers for Peace have no confidence that the staff will summarize the additional evidence in good 4
faith. These witnesses all waited for more than a month to have an oppor-tunity to tell their stories to the NRC. Despite growing mistrust, the witnesses agreed to meet with the staff due to their unanimous belief that Diablo Canyon is not ready to go critical. To make a difference in the decision, however, their message must be heard by the Commissioners. Under the circumstances, only the joint intervenors can be trusted to speak for the whistleblowers.
! 2 ), assumption of responsibility by the Commission to engage in further fact finding on an expedited basis and to oversee ongoing corrective action; The Commission must assure an objective evaluation of the evidence, free from conflicts of interest. The allegations below suggest that Region V and certain other officials have misrepresented the record. If the charges are correct, the responsible officials have disqualified themselves from ongoing responsibilities at Diablo Canyon. In addition, the staff's judgment is compromised by a serious conflict of interest. Region V is in large part responsible for the condition of Diablo Canyon. In order to support the whistleblowers now, Region V would have to repudiate its own regulatory per-formance dating from the mid-1970's through February 1984. For example, during the past week Region V inspectors Dennis Kirsch and Gonzalo Hernandez.
listened to whistleblowers disclose evidence of generic Pullman Power quality assurance (QA) deficiencies that also revealed basic errors in IE Report '
83-37, which Messrs. Kirsch and Hernandez co-authored.** The conflict of interest may explain why the NRC inspectors appeared to pay more attention to a penknife and a paperclip, respectively, than to Mr. Harold Hudson, Pullman's former auditor, during his interview. It may_ explain why the great majority of interview questions on specific violations and locations of defi-ciencies have come from GAP rathtr than from the NRC inspectors who need the specifics. In short, there must be definitive resolution of the issues raised by whistleblowers at Diablo Canyon. The current staff has an inherent credi-bility gap.
- 3) Board Notification of transcripts of whistleblower interviews; The whistleblowers have spent hours detail'ing specific QA violations, deficient hardware and material false. statements that illustrate a generic program breakdown. On April 6,1984 the Office of Investigations Region V director, Owen Shackleton, announced that the transcripts would not be released
- ' Region V rejected the intervenors' request that due to complaints from whistleblowers, Messrs. Kirsch and Hernandez be replaced with " fresh faces."
Nuclear Regulatory Commission
! April 12, 1984 Page 3 i
publicly until completion of 01's work, which could take months. But the i extensive evidence presented to the NRC staff could well be decisive for l the intervenor's motions for design and construction quality assurance l hearings.
For these reasons, the Commission should direct the staff to honor its
, previous policy of disclosing interview transcripts to the Atomic Safety and ,
Licensing Appeal Board as Board Notifications. That policy was followed for Mr. Stokes' January 25 interview transcript. 01 deleted portions of the transcript that could compromise pending or planned investigations. Region V and GAP reviewed the transcript to delete information that could identify confidential witnesses. If necessary, the transcripts could even be provided ;
to the Appeal Board in camera.
- 4) Investigation by Office of Inspector and Auditor, f
~
The Office of Inspector and Auditor (0IA) should conduct an investigation to determine a) whether there have been misleading or material false statements by the NRC staff to the Commission during the March 19, 26 or 27 briefings, or in Supplemental Safety Evaluation Reports SSER-21 (December 1983) or SSER-22 (March 1984), and b) the causes of the QA breiikdown within the NRC staff
- responsible for Diablo Canyon.
, o A sampling of.the basis for the Felief requested above is discussed below.
MISLEADING OR FALSE STATEMENTS'BY'THE' NRC STAFF TO THE COMMISSION.
The point of the allegations below is that the record is inaccurate.
In some cases the statements are false; in others they are merely misleading.
The Mothers for Peace do not seek to question the staff's . motives. But regard-less of intentions, the granting of a license cannot be based upon misleading l* and false statements of material fact, whether from the licensee or. the staff.
The allegations discussed below are illustrative, not comprehensive.
A. METHGD0 LOGY.
- 1. Notice
' At the Monday, March.19 Commission briefing, the Director of' the Office of Nuclear _ Reactor Regulation, Mr. Harold Denton, stated that it was on Friday, ;
March 16 that GAP notified Mr. Knight of material false statements in PG&E submittals. That statement is highly misleading because it conceals the fact that as early as March _5, through Mr. Devine, GAP began attempting to schedule whistleblower interviews through the office of Mr. Bishop of Region V, to disclose v
, PG&E's material false statements to the NRC. GAP did so because Mr. Bishop was i administering the Commission's Diablo Canyon whistleblower " allegation manage-ment program." Mr. Dennis Kirsch took that call. On March 8, Mr. Clewett spoke with Region V counsel Lewis Sholle'nberger about scheduling interviews with these
- i. .
i Nuclear Regulatory Commission April 12, 1984 Page 4 I
witnesses. (See Attachment 3 to March 23, 1984 letter from Thomas Devine and l John Clewett to U.S. Nuclear Regulatory Commission (" March 23 disclosure")).
! On March 9 Mr. Devine left a message for Mr. Yin and Dr. Hartzman of NRR in j an attempt to schedule interviews on design issues. On Monday, March 12 Mr.
j Devine spoke with Mr. Yin and separately with Mr. Hartzman to describe the
- relevant issues. Also on Monday, March 12, Mr. Clewett spoke again to Mr.
Shollenberger in the attempt to schedule interviews with the witnesses. On Tuesday, March 13, both GAP attorneys and four whistleblowers met with Office of Investigations (01) Director Ben Hayes and three OI investigators to summar-ize evidence of material false statements connected with design and construction j . quality assurance. On March 14 Mr. Clewett again called Mr. Shollenberger about Region V meeting with the witnesses. Also on March 14 Mr. Devine explained i to Mr. Knight that certain of PG&E's responses were " inaccurate," represented
" false statements," and were " bluffs" and " mush." On Thursday, March 15 and Friday, March 16. Mr. Devine spoke with Messrs. Bishop and Shollenberger to emphasize the urgency of the evidence and the necessity of avoiding a licensing i decision based upon false statements. On Thursday, March IS, Mr. Bishop called f Mr. Clewett to ask if Mr. Clewett had any personal knowledge of material false j statements, to which he replied that it was not he, but the whistleblowers with whom Region V was effectively refusing to meet, who had the specific facts to prove that certain of PG&E's assertions were material false statements. On
~
Friday,' March 1671984, Mr. Devine called Mr. Knight again. This final attempt was the only communication, out of some twelve, at least five of which speci- ,
fically referred to material false statements by PG&E, which Mr. Denton disclosed ,
to the Commission. None of the communications led to any result.
- 2. Identity of the whistleblowers.
l On March 19 Region V Administrator Jack Martin explained to the Commission i that .the "new allegations are, by and large, the same people who had the old l allegations." (March 19 transcript, p. 64). In fact, of 17 witnesses who dis- ,
l- closed allegations through GAP petitions,11 had not spoken to the NRC as of .
'- March 19, 1984. (A twelfth witness agreed to speak to the NRC staff about a gag order instituted by the Bechtel Corporation in January 1984 but did not
- provide a statement).
- 3. Nature of the issues.
i
' On March 19 and 25 Messrs. Martin and Bishop explained that new allegations i essentfally represented mere " wrinkles" on the same issues that had already been examined in depth through~ SSER-21 and SSER-22. (March 19 transcript, at 7, 9-10, -
and 61;'and March 16 transcript at 59). In one sense that statement is accurate.
- All the charges involved alleged quality 1 assurance (QA) violations, retaliation against workers who report serious safety or quality problems, design flaws or' ;
breakdowns in management integrity and competence. Beyond this generalized common ground, however, the staff's report was inaccurate for numerous, highly
- - significant, specific issues. To illustrate - the following allegations in the i March 1, 1984 petition were not discussed in SSER-22,.which.was not released 7
s
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Nuclear Regulatory Commission April 12, 1984 Page 5 until after the March 19, 1984 Commission meeting:
- inaccurate Operation Valve Identification Diagrams (0VID) for use by the reactor operators, which include such sericus discrepancies as valves on the wrong side of other components. (March 1 petition,
- p. 42). This problem is particularly significant, since there is no dissent within the Commission that reactor operators should "know the plant cold." (March 27 transcript at 213, statement of Chairman Palladino).
- a generic breakdown in design control through the quick fix program, in which major design changes were approved on-the-spot to accommodate construction plans, without normal engineering review and supporting analysis. (March I petition, pp. 19-21).
- pressure by the Bechtel Corporation that employees who resigned should sign a statement that they were not aware of any design, pro-fessional code, or quality assurance violations -- despite common knowledge to the contrary. This left honest employees in an illegal
" Catch-22" at a critical period: either they could lie to the Govern-ment or risk industry blacklisting. (March I petition, p. 41).
- knowingly false statements in licensee responses to previous employee allegations, illustrated by PG8E's February 7 assertion to the NRC that the lack of consistent weld symbols to guide personnel had no safety significance. (March I petition, p. 28). Instead of investiga-ting this new " wrinkle," the staff accepted at face value the licensee's alleged false statement as a basis to " resolve" the original weld symbols issue.
- December 28, 1983 procedural changes that denied inspectors the ability -
to reject welding on pipe supports, even when a weld that was required by the design did not even exist. (March I petition, p, 6).
The March 23 disclosure also contained more than mere " wrinkles." For example, one affidavit ' revealed a continuing " mirror image" problem /ith electrical installations by the Foley Corporation. In January 1983, super-visors called an employees meeting to try to resolve the issue. Unfortunately, the meeting broke up when the supervisors could not agree among themselves what was forward and what was backward. (March 23 disclosure, Attachment 12, p. 4).
4 Follow-up interviews.
The staff has made a mockery of its written policy and verbal commitments that allegations would not be closed out without follow-up interviews to insure accurate resolution of the issues. The staff also misled the Commission on this issue. To illustrate, on March 27 Mr. Martin said that it was "just not a true statement" that Region V had failed to schedule follow-up interviews. He referred to Region V's communications with Mr. Hudson, Pullman's former internal auditor:-
A Nuclear Regulatory Commission
' April 12, 1984
+. y , . .
"we had talked with him for at least nine hours involving several people at several different times." (March 27 transcript, p. 271).
Mr. Martin neglected to inform the Commission that these were all initial interviews, not follow-up meetings to check the accuracy of PG&E's '
answers or the staff's resolution. As Mr. Hudson stated in a March 22, 1984 affidavit:
I also want to emphasize that the NRC staff never had any followup meetings with me to clarify the issues I raised, or ,
to test whether PG&E's defenses were bluffs. That is odd, since I disclosed over 80 pages of my own single-spaced reports and affidavits to summarize over a thousand pages of documentation.
I only learned of some of PG&E's answers, because GAP xeroxed them and gave me copies. The NRC staff complimented highly the i analysis in my reports, but they never got back to me. I disclosed approx [imately] 80 allegations to the NRC, out of the 170 in a January 31 tsic. Reference is to February 2 petition]
legal petition. Any statement that the NRC staff followed up with me personally after I first raised my charges would be to-tally false. I have no idea what the NRC staff did to resolve my allegations, other than to have PG&E respond to somein letters.
(March 23 disclosure Attachment 2, pp. 2-3).
In some cases the inaccuracies may well be due to ignorance, rather than to bad faith.. Unfortunately, the record is equally -inaccurate on important' matters -- whether due to sloppiness or deception.- For example, the reliabi-
- lity of hydrostatic test results is highly significant to determine Diablo Canyon is ready for low-power testing. On March 26, Mr. Bishop reported that Region V had not yet' received documentation on that issue, to his knowledge.
(March 26 transcript, p.13). In fact, the documentation to which Mr. Bishop ~
referred was sent via Express Mail to Mr. Bishop himself, on March 2,1984.
- A copy of the cover letter to GAP's submission of documents on this issue is enclosed as attachment 3 (the specific materials referred to by Mr. Bishop are identified in attachment 3 as " Exhibit 4 to Attachment 2" (to the February 2 petition]). To date Region V has not discussed this evidence with the alleger, Mr. Hudson.
Even if Mr. Bishop's statement were accurate, it would not constitute an excuse to ignore the issue. Region V took no initiative whatsoever to obtain the relevant. records either from the alleger or from counsel.
B. EVIDENCE OF QUALITY ASSURANCE VIOLATIONS'
[ 1.. Disclosure of Yin inspection findings Prior.to Mr. Yin's March 26 Commission statement, the staff did not
(- provide' the Commission' with an adequate record for an imminent licensing decision. The staff's briefings contrasted sharply.with, and failed to disclose from. Mr. Yin's-draft inspection report on issues material- to the decision.
- . = .
^
Nuclear Regulatory Commission April 12, 1984
- Page 7 April 3, 1984 memorandum from Darrell Eisenhut to the Commission, Board -
Notification No.84-071. As a result, the Mothers for Peace
~
believe that the staff engaged'in material false statements by omission.
On March 19 NRR representative James Knight characterized the resolution of allegations on design control and verification: .
And we found that the design quality assurance implementation was not as good as it should have been. I can only cast that as a somewhat - '
disappointing finding.
(March 19 transcript, p. 37.) By contrast, on March 26, Mr. Yin presented an accurate summary of the staff's inspection findings:
Based on the many assessed violations against the 10 CFR 50 Appendix B criteria resulting from followup on these allegations and the independent overview inspections, it was concluded that there had been apparent QA program breakdowns in the areas of small bore and large bore piping design control. ,
[T]he lack of licensee large bore and small bore piping system design control that had resulted in an alarmingly large number of calculation errors and
- deficiencies that had slipped through various review and ekecking stages, is indicative of the failure of the Corrective Action Program conducted by the Diablo Canyon Proje'ct group in the past two years.
At the time of the (December 15, 1983 NRC licensee]
meeting, none of the issues was considered to be a problem by the Diablo Canyon Project. However, during follow-up inspections, all the above items have resulted in staff assessment of violation items. The event reflected Diablo Canyon Project's lack of concern for -
establishment and implementation of a sound design control QA program.
In particular, Mr. Knight's presentation did not reveal serious ,
problems with design verification for large-bore piping, which Mr. Yin described as follows on March 27:
Furthermore,.if you review the IDVP on the large bore support and piping analysis, they are full of deficien-cies and pages and pages of deficienciet. How can we assure that the rest of it would not have the same problem. . . -[?]
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or p . .. y
Nuclear Regulatory Commission April 12,1984 i .Page'8
+
(March 27 transcript, p. 251.) Mr. Yin assessed the nature of unresolved questions about large-bore piping on the design as "a different ballgame,"
(id., p. 254), as compared to the small-bore issues which previously had dominated the staff's presentation.
Similarly, on March 19 Mr. Knight did not inform the Commission of the serious questions from wiespread, uncontrolled design changes in the
" Quick Fix" program. At a har;h 28 public meeting, Mr. Yin characterized the effect of the Quick Fix on design control for larger bore pipe supports
- as follows:
h'7s '
It is a breakdown to re because right now you have thousands of thousands of those TCs, so-called,
~_ and the stuff that I review is not really tolerance clarification. The stuff that I have reviewed
- really is a complete change of the support, design s and it was kind of accepted right at the spot without any given review and consideration and it was just based on the fact if it doesn't meet the requirement we will turn it down. It is kind of taking a chances approach rather than following the procedures approach that we consider the system breakdown.
I Right now you have got more than 30 books of those i little things.
l (March 28,1984 Memorandum from Darrell Eisenhut to the Commission, Board Notification No.84-068, pp. 63-4.-) As Mr. Yin emphasized to PG&E on March 28: "But don't forget the quick fixes, which is the biggest problem."
(Id., p. 77.)
! Mr. Knight should have disclosed it. Nor. does SSER 22 address the '
~ issue. The omission is inexcusable. In the aftermath of Quick Fix, there I is no assurance how much of the approved, verified design 'still exists at i Diablo Canyon.
l l On March 19, Mr. Knight did not disclose an undocumented Westinghouse j ' management policy that Mr. Yin discovered during his review of 1982-83 i
Independent Design Verification Program (IDVP) audits. As he explained on March 28, "[T]he original audit checklist findings / records had been systematically destroyed in accordance with Westinghouse management policies
. . This is very, very different from the normal practice." (Id. , p. - 108).
The Mothers submit that systematic destruction of records for QA-oversight-
.of the.1IDVP is a significant finding which the staff was obligated to disclose
'and, explain prior to any recommendation for a license.
i It appears that Mr. Knight had adequate notice of the findings. On
- March 27 Mr. Yin explained, So it is a short iteration of asking that information W ..
s, that caused the element of surprise. As a matter of T
3 fact, I have been providing the inspection inputs,
- ./w ' , . - - . , - . . .- . . - . - - - - - . - . , . -.
4 Nuclear Ragulatory Commission April 12,1984 Page 9 January, February and March. So every time I have inspection problem findings, I always communicate in a timely manner with Mr. Jim Knight and it was kind of surprising, there was no discussion at all.
(March 27 transcript, pp. 249-50.)
In short, the. Mothers believe that Mr. Knight should have informed the Commission of these and other, equally serious violations at the March 19 briefing. The belated disclosure materially affected the decisionmaking
. process. Mr. Knight was not alone, however. His presentation on March 19 reflects the incomplete disclosure in SSER 22 of Mr. Yin's analysis. The Mothers believe that Mr. Knight's inaccurate briefing represented an organizational breakdown. They further believe that accountability must be established. It is unacceptable that full disclosures such as Mr. Yin's represent the exception, rather than the rule.
- 2. Corrective Action for 0A Violations. _
On March 19, 1984, Mr. Martin informed the Commission that "when there have been lapses they seem to have corrected themselves. . . [T]here were problems that tended to get found by the quality and management systems that are set up to do that sort of thing." (March 19 transcript, p.12.) Indeed, on March 19 when Commissioner Gilinsky reminded the staff that problems must be resolved as well as identified, Mr. Martin replied, with repect to Pullman welding: "
And in every case it appears to be resolved." (March 19 transcript, p. 25.)
The staff was on notice that this essential conclusion was inaccurate both with respect to design (supra, p.-7) and construction assurance. Mr.
Hudson's March 22, 1984 affidavit summarized his January 1984 disclosure to the staff on that same issue: "I also told the staff that I had tried to
, implement corrective action. I also told the staff that management refused to permit necessary corrective action." (March 23 disclosure, Attachment 2, p. 2.) The' issues discussed belcr illustrate the evidence behind Mr. -
Hudson's charges. The staff has received or reviewed all referenced documents.
At a minimum, both sides of the story should have been presented for the staff-to honor its obligations to fully and objectively brief the Commission.
- 3. Compliance with 10 CFR 50, Appendix B.
The staff's faile4 y discuss this issue in IE Report 83-37 is a material false statement by Mssi n. Region V ignored Criterion II, Finding No. 1_in the 1977 Nuclear & r (cri Corporation (NSC) audit reviewed by Report 83-37:
"While a written .7#d Usurance Program exists, the program does not meet the requirements'ef 10 CFR 50, Appendix B. . ." (February 2 petition, Attach -
ment 1, p.10.) This issue could not be ignored,'since it is the cornerstone
-of NRC licensing requirements for quality assurance. -
The omission also masks inaccuracies in a September 21, 1983 PG&E licensing, brief. The licensee stated that Pullman'r. QA program commitment for. piping,
- pipe supports and pipe rupture restraints Ryorporated the ASME Section III '
- 1971 Edition requirements. The. licensee concluded, "These commi.tments are
.,.s y- T -4vy ?- T~-- r# t* + --T'-- er t - w 2+N-T e-- - --t' <-T -
9
- j. Nuclear Regulatory Commission April._12, 1984
- Page 10 consistent with the requirements of 10 CFR 50, Appendix B and became part of the program manual." (PG&E's Answer to Joint Intervenors' Supplement to Motion to Reopen the Record on the Issue of Construction Quality Assurance, Docket Nos. 50-275 and 30-323 (September 21, 1983), p. 7.)
! Prior to the February 17 release of Report 83-37, the staff received notice that this statement was inaccurate. Mr. Hudson's February 1,1983 affidavit disclosed that as late as January 28, 1983 Pullman's QA manager denied any commitment to 10 CFR 50, Appendix B. (February 2 petition, Attachment p. 24.)
Prior to the March 26 briefing, Region V received further notice. In his
! March 22 affidavit Mr. Hudson explained that ASME Section III (1971 Edition)
]- did not cover pipe supports and rupture restraints. He referenced the Pullman NSC audit file to demonstrate that as of 1977 Pullman had not even attempted to comply with 10 CFR 50, Appendix B. (March 23 disclosure, Attachment 2, and exhibits referenced therein.)
4
- 4. Qualifications of Nondestructive Examination Personnel.
- Criterion IX, NSC Audit No. 3 stated
- "The qualification and certification program for NDE and inspection personnel has been inadequate." (February 2 petition Attachment 1, p. 21.) On March 26 Messrs. Martin and Bishop asserted that NSC mistakenly assumed a Pullman comitment to American National Standards Institute (ANSI) on 45.2.6, when a lesser standard was applicable. Mr. Martin added that "the very same alleger [Mr. Hudson) includes in the package later, a letter from him saying they were adequately qualified to that one. So this issue that we feel is adequately resolved at this point." (March 26 trans-cript, p. 21.)
In fact, the " letter" did not purport to represent Mr. Hudson's views.
The " letter" was the minutes of a meeting for which Mr. Hudson acted as L secretary. (March 23 disclosure, Attachment 2, Exhibit 9, p. 1.) Further, the staff's 1984 version of program requirements is not the same as the AEC's
~
l- -position a decade ago, the period covered by_'NSC. Again, Mr. Hudson already had disclosed in a December 12,1974 Pullman (Kellogg) corporate memorandum that
~
L l
Pullman had already committed itself in the corporate QA.inanual to" ANSI N45.2.6 because the AEC "had begun to require qualification of inspection'and testing
__ personnel'in addition to non-destructive personnel all in accordance w.ith ANSI N45.2.6 . . ." Failure in the field to "accomodate this requirement . . ."
led 't6 "the_ AEC breathing down 'our necks in one or two places."' The Pullman official recommended that Pullman's program on the issue be implemented-
"immediately." (Id.. Exhibit 8.) As Mr. Hudson' further documented,. it wasn't. - (Id. , ExhYits 9-16. )
- 5. Qualifications of Velding Inspectors.
Although the staff confirmed the NSC finding on this issue, it failed to inform the Commission ^ that thec problem continued at -least until July 30,1982 This is contrary to Mr. Martin's assertion that in every case the problems L appear to have been resolved. 'In Report 83-37 (at 15), the staff found:that procedures were revised in 1973 or 1974 "to reflect the requirements of ANSI.
L N45.2.6, just published." By contrast, in.1982 the QA~ manager still refused to recognize the requirement::"'PG&E has not stated in writing that Pullman x- .- . . -- . . - -. -. . .-
Nuclear Regulatory Commission April 12,1984 Page 11 j must comply with ANSI N45.2.6. (Ref: 8711) We are not in violation of PG&E i spec on our procedures EDS 235 and 237." (March 23 disclosure, Attachment 2, Exhibit 9.) Mr. Martin clearly had read the documents; it is the same " letter" Mr. Martin used to inaccurately assert that Mr. Hudson was contradicting himself on NDE qualifications. (Supra,p. .)
Conclusion The staff's bias is clear from its recommendation to go critical, in spite of the assessed condition of the plant. This recommendation is indefensible under the Atomic Energy Act. The staff's claim is that the condition of the plant is uncertain; that dangerous effects on the hardware have not yet been verified. That is a rose-tinted way of saying the quality is indetermin-ate. Until now, a nuclear power plant has not been considered innocent until proven guilty. Under 10 CFR 50.57 tiie licensee must be able to document the facility's safe structure. At Zimmer, a quality indeterminate status meant that construction had to be suspended. At Diablo Canyon, the staff is recommending that the same assessment meets the requirements for criticality. The Commission should carefully consider before approving a landmark determination of QA licensing requirements under the Atomic Energy 4
Act.
It is even premature to reliably conclude that the quality of hardware is uncertain. Last night Region V agreed to let three whistleblowers point out specific examples of poor welding in Units I and II. In eight cases out of nine, the witnesses confirmed that eight out of nine alleged welding deficiencies remain uncorrected. Although the staff refused to take
, pictures o_f the welding deficiencies, Region V did record the observations.
The Commission should study the findings before making any licensing decision.
The Mothers requested presentation to the Commission on Friday, April 13 would review the technical significance if the welding deficiencies are representative rather than exceptions. Under these circumstances, the l Commission must resolve the " uncertainty" about Diablo Canyon's hardware, rather than surrendering to-it.
Respectfully submitted, i j ms) i Thomas Devine
! Counsel for Mothers for Peace L Government Accountability Project of the Institute for Policy Studies
-1901 Que St. NW Washington, D.C. 20009 l
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