ML20072N275
| ML20072N275 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/26/1983 |
| From: | Hubbard R CALIFORNIA, STATE OF |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8304010494 | |
| Download: ML20072N275 (41) | |
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OCCKETED U3HRC UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION .-, '
y
- BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Dockets Nos . 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Unit Nos. 1 and 2) )
)
)
SUPPLEMENTAL AFFIDAVIT OF RICHARD B. HUBBARD CONCERNING BREAKDOWNS IN THE DIABLO CANYON QUALITY ASSURANCE PROGRAM STATE OF CALIFORNIA )
) ss.
COUNTY OF SANTA CLARA )
I, RICHARD B. HUBBARD, being of legal age and duly-sworn, depose and say as follows:
I INTRODUCTION
- 1. My name is Richard B. Hubbard. My professional qualifications and experience have been submitted to this Board as part of my May 24, 1982 affidavit concerning breakdowns in the Diablo Canyon Quality Assurance Program.
- 2. The purpose of this supplemental affidavit is two-fold. First it is to se t forth the events which have occurred since my May 24, 1982 affidavit which further 1*
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- 4 demonstrate that the Pacific Gas and Electric Compant/ (PG&E) did not have a Quality Assurance / Quality Control (QA/QC) Program which:
(a) met the requirements of General Design Criterion-1 (GDC-1) of Appendix A to 10 C.F.R. Par t 50 and the specific quality assurance criteria set forth in Appendix B to 10 C.F.R. Part 50; and (b) which could assure that PG&E had met the license commitments set forth in its Final Safety Analysis Report (FSAR) for the Diablo Canyon Nuclear Power Plant Unit 1 (Diablo Canyon).
Second, it is to describe the modifications which have occurred in the Independent Design Verification Program (IDVP) since my May 24, 1982 affidavit and why those modifications, even if adequately undertaken and completed, cannot assure:
(a) that Diablo Canyon as actually constructed will be consistent with the FSAR prepared for it; and (b) that the safety related and other important to safety structures, systems, and components (SS&C's) contained within the plant meet the technical require-ments of the regulatory standards which have been set i
for them.
- 3. The facts and conclusions set forth in this declaration are based upon the information I have received and reviewed during the period between June 1982 and March 1983 in my continuing role as technical consultant to counsel for the 2.
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s t Governor of California in the ongoing Diablo Canyon licensing proceedings. I have reviewed the semi-monthly status reports provided by PG&E and Teledyne Engineering Services (TES) concerning the IDVP. Further, I have reviewed the interim technical reports issued by TES. I have prepared and submitted to the NRC detailed comments concerning inadequacies in the proposed scope and methodology of the Phase I and Phase II verification programs. I have discussed these technical comments at the meeting between Mr. Denton of the NRC Staff and the intervenors in the Diablo Canyon proceedings in San Francisco on February 17, 1982, and September 9, 1982. In addition, I attended and made a presentation on these matters to the NRC at a meeting in Washington, D.C., on November 10, 1982. Finally, since June of 1982 I have continued to attend and participate at a number of meetings between the various participants in the Diablo Canyon QA/QC investigations, including meetings with-personnel from PG&E, TES, NRC, Bechtel, Stone and Webster Engineering (S&W), Robert L. Cloud Associates (RLCA), Roger Ready Incorporated (Reedy), and Brookhaven National Laboratory (BNL).
( However, despite the fact that I have continued to see the above-mentioned reports and to attend various meetings discussing them, I have not had access to the underlying technical data being developed by PG&E/Bechtel or to the data provided to the IDVP participants.
4 In general, I believe the intervening events have provided further new evidence of a pattern of significant l
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i e breakdowns in the implementation at Diablo Canyon of QA/QC requirements which are consistent with the facts and conclusions discussed in my prior affidavit. The new evidence cited herein confirms the testimony I previously gave this Board that PG&E's quality assurance program for Diablo Canyon did not contain an adequate policy for QA/QC, that it did not contain in a timely fashion the procedures adequate to carry out the policy it did have, and that it did not have a system capable of ensuring that even these procedures would be properly implemented.
It also supports my testimony that the often times generic nature of the discrepancies between what actually was and what should have been with respect to both the construction of the plant and the documents supporting that construction have led and will continue to lead to the disclosure of errors in design and construction which if uncorrected could threaten the public's safety.
Finally, this new evidence substantiates my earlier affidavit that given the demonstrated lack of an adequate QA/QC program and the number and nature of the errors disclosed, there is an extreme likelihood that further major errors exist in the design and construction of the plant which can only be uncovered i
by a rigorous and thorough design and construction verification ;
program.
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II SERIOUS QUESTIONS ABOUT THE SEISMIC DESIGN ARE NOT YET RESOLVED
- 5. E widespread pattern of significant breakdowns in the required management control systems regarding the QA/QC process for design and site activities for both seismic and non-seismic safety features has been disclosed since the Diablo Canyon license was suspended. Despite an ostensibly complete reevaluation of the seismic design of the plant , serious questions about that design , product remain and may not be resolved even upon completion of the IDVP because: symptoms rather than QA/QC root causes have been addressed; results have differed between those presented by PG&E/Bechtel and Brookhaven National Laboratory; and Teledyne's role has changed due to the PG&E/Bechtel seismic reevaluation.
A. The Discovery of Seismic Design Errors Make Imperative an Expansion of the IDVP
- 6. By the date of my initial af fidavit 195 design and construction discrepancies between what was and what should have been had been disclosed. At that time, 24 of these discrepancies,
! in my opinion, had turned out to be errors with significant implications regarding PG&E's failure to establish and implement the required QA/QC measures.
- 7. As indicated in my prior affidavit, in response to the initial disclosure of 14 of these errors, the Nuclear Regulatory Commission (NRC) ordered the suspension of PG&E's low power license, and the creation of the IDVP.
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- 8. The IDVP at the time of my initial affidavit,
, covered a limited audit of the seismic safety-related service contractors who performed design work on Diablo Canyon prior to June 1, 1978 (Phase I), and a further limited review of non-seismic and seismic safety-related design activities performed after 1978 by PG&E and its service contractors (Phase II).
- 9. As this limited IDVP was going forward, I advised the NRC staff (February 17, 1982, and September 9, 1982) and the NRC itself (November 10, 1982) that there was no rational-distinction between Phase I and Phase II, that the scope of the seismic safety related design and non-seismic safety related design reviews was too narrow, that a thorough review of important to safety SS&C's should be included in the IDVP, that objective statistically valid sampling techniques were necessary to enable extrapolations from a sample to the entire plant population and that added to the design review should be an audit of the construction of the plant and PG&E's material suppliers.
- 10. While the IDVP was going forward, the NRC staff was also receiving information from the Brookhaven National Laboratory (BNL). BNL had conducted an independent review and l development of the vertical floor seismic response spectra for I
the Diablo Canyon containment annulus structures. The developed response spectra were then utilized by BNL for evaluations of two i'
selected piping systems. A report (BNL Report) summarizing the BNL findings was issued in July 1982. In a July 1, 1982, letter 6.
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fr. 4 to Dr. William Cooper of TES, Mr. Denton noted the following seven aspects of the design process utilized by PG&E and its principal seismic subcontractor, URS/Blume, which, as a result of the BNL Report, required further exploration and assessment as to their generic implications for the Diablo Canyon design process:
(a) The distributed masses of the steel members comprising the annulus structure apparently were not included ir, the mathematical model used in the original seismic analysis. ,
(b) The mathematical model used in the original analysis apparently considered the joints between the beams and columns to be rigid, whereas the Brookhaven interpretation of the drawing indicates these joints are more appropriately considered flexible (shear carrying only).
(c) Statement on page 11 of the URS/Blume May, 1979 report "Diablo Canyon Nuclear Plant Unit 1 l
Containment Structure, Dynamic Seismic Analysis for 7.5 M IIosgri Earthquake," May, 1979, concerning the structural connections may not be consistent with the mathematical model used in the original analysis.
(d) The response spectrum smoothing techniques employed in the original analysis appeared inconsistent with the FSAR commitments.
(e) Design dimensions were apparently used instead of the as-built dimensions in the two piping problems samples.
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e- t (f) The SD bends in the piping analysis were apparently modelled as long radius bends. This has the effect of softening the model and reducing the natural frequencies.
(g) The piping support forces computed by the BNL model are much larger than those computed by the PG&E model.
- 11. As a result of these described breakdowns in the PG&E/Blume design process, BNL recommended that "given the magnitude of the support force increases, a reevaluation of all (pipe) support designs would seem warranted."
- 12. As BNL's analysis was going on, PG&E was developing new response spectra for the errors which had been disclosed early in the IDVP. (PG&E's "New Hosgri - 5 Mass Spectra".)
However, BNL has also concluded that its results still differed from even these new PG&E figures. Indeed, in response to a question from Mr. David Fleischaker during the July 27, 1982 meeting among PG&E, TES, BNL and the NRC, the BNL personnel
( confirmed the following two BNL conclusions with regard to PG&E's "New Hosgri - 5 Mass Spectra."
(a) BNL support force values obtained using BNL l models and PG&E supplied spectra do not match. The i
differences are probably iue to the differences in modeling. (BNL Report, p. 11.)
(b) Support forces calculated using BNL piping models and BNL 3-D Model B envelope or independent 8.
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't t spectra substantially exceed PG&E calculated values.
The major cause for this is that Model B spectra greatly exceed the spectra used by PG&E. (BNL Report, p. 12.)
Similar findings by BNL of differences between the BNL and PG&E horizontal response spectra for the containment annulus structure were discussed at an NRC meeting in Bethesda ori February 15, 1983. BNL noted dif ferences in both the frequency and magnitude at which the peak horizontal accelerations would occur. Thus, even the PG&E seismic reanalysis in important aspects appeared to be less conservative than the BNL analysis and therefore 'may provide an inadequate level of safety. Moreover, the BNL results to date raise serious questions about the adequacy of the Diablo Canyon seismic design since discrepancies continue to be identified between BNL's seismic models of the parts of the plant it was asked to review and PG&E's newest seismic models for those portions of the plant. Further, not all of the dif ferences presented by BNL had been identified by the IDVP participants, which raise doubts about the thoroughness of the IDVP reviews.
- 13. Based on the nature of the seismic design errors which were being disclosed in the seismic design product by TES's limited design verification program, based on the discrepancies disclosed in the BNL seismic design review, and based on the l
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.. e implications of the findings resulting from the Reedy review of PG&E's OA/QC process implementation,1! it became clear that the IDVP would have to be expanded significantly.
- 14. In summary, these reviews disclosed that:
(a) The PG&E seismic design breakdowns and the deficiencies in the OA/QC process were not limited to the period prior to June 1, 1978. Rather, the breakdowns were evident in the UPS/Blume 1979 report and continue to some degree in the New Hosgri - 5 Mass Spectra. Further, the seismic design process breakdowns appeared generic, thus requiring a complete remodeling and reevaluation of seismic safety features.
(b) The Phase I/ Phase II dichotomy in the reverification program, as originally contemplated by the NRC, was no longer technically justified. Thus, the
- 1. In a report first issued in March, 1982, as part of the Phase I verification program, Reedy stated the following three conclusions concerning the PG&E quality assurance program:
(a) The PG&E Quality Assurance Program for design work was not adequate in areas of policy, procedures and implementation. The Quality Assurance organization had insufficient program responsibility.
l, (b) A general weakness existed in internal and external interface and document controls. This questions whether appropriate design information was being exchanged and utilized by design groups and consultants. One concern is if the latest Hosgri seismic data were input for design analysis.,
(c) The design verification program was not formalized and was inconsistently implemented and documented. This included major gaps in design overviews of the design -
approach to mechnical and other equipment.
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Phase I/ Phase II dichotomy should have been and was essentially abandoned.
(c) The conclusions of the Reedy QA/QC audit raised serious questions as to the adequacy of the PG&E QA/QC program and its implementation in other than design activities. Thus, the TES reverification program needed to encompass all PG&E QA/OC activities, including site construction activities. Subsequently, in a letter from Mr. Engelken of Region V to Mr. Denton of the NRC, the Region recommended that a limited construction OA/QC reverification program be initiated.
B. PG&E Responds to TES and NRC Findings and Initiates a Seismic Corrective Action Program
- 15. PG&E substantiated the existence of a widespread breakdown of the OA/OC process and product for seismic design disclosed by TES, Reedy and BNL in two internal programs initiated by PG&E. First, the Blume Internal Review (BIR) of the seismic design disclosed approximately 150 potential discrepancies in the design product of which approximately one-third could be significant non-compliances with the seismic design criteria provided in the FSAR. Second, PG&E's QA Lookback Review identified failures to comply with Appendix B OA/0C l
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criteria with regard to the development, distribution, use, and control of design information.
( 16. Further, in late spring of 1982 PG&E announced that Bechtel had contracted to replace PG&E as the 11.
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engineering / construction manager for the work remaining to complete and license the two Diablo Canyon units. Additionally, in August 1982 PG&E announced that a seismic review and redesign of Diablo Canyon safety features had been initiated. Finally, in September 1982 PG&E requested that TES initiate a limited construction QA/QC review.
- 17. While efforts were initiated to correct the identified discrepancies (the symptoms of the problem), PG&E did not initiate efforts to identify and address the root causes within the QA/QC process which allowed the discrepancies to occur and, more importantly, to remain undetected throughout the time prior to the issuance of an operating license. The failure of PG&E to identify and address the root causes of the QA/QC breakdowns precludes a finding that the depth and extent of the QA/QC breakdowns at Diablo Canyon has been enveloped with any degree of confidence. Thus, as further revieas of non-seismic safety design, equipment procurement, construction, and operating QA/QC are conducted, I continue to believe that more errors,
( including non-compliance with the operating license application, will be revealed.Section III of this affidavit sets forth significant information concerning the further reviews.
1 l C. Seismic Reanalysis Results in Significant l Plant Modifications and Changes to TES Review Role
- 18. Approximately 800 technical personnnel have been involved in the PG&E/Bechtel seismic reanalysis of the Diablo t
{ Canyon safety features. The plant modifications identified to l 12.
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date are extensive. For example, at the January 13, 1983, meeting PG&E disclosed the following numbers of modifications being made to critical seismic safety items.
(a) 2400 out of 4000 large-bore pipe supports.2/
(b) 750 out of 3500 small-bore pipe supports.2/
(c) 900 out of first 12,000 of a total of 23,000 electrical conduit and cable tray supports.S!
(d) 13 modifications to piping systems.
- 19. In addition, design of structural modifications are still being developed for a number of areas including the containment annulus structure and the fuel handling building.
The construction work force required to implement the design changes i.s massive. For Unit 1, a completed plant, 1300
. construction workers were on-site in January, and PG&E estimated that the work force for the Unit would eventually approach 1600.E/ In my opinion, a continuing need for a large number of construction personnel will be required once the necessary changes resulting from the Phase II design-review of non-seismic safety features, as well as the construction QA/OC review are finally identified. In the following section of this affidavit,
- 2. Transcript of Diablo Canyon Design Verification Status Meeting, January 13, 1983, p. 68.
- 3. Ibid. 2, p. 74.
- 4. Ibid. 2, p. 75.
- 5. Ibid. 2, p. 136.
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4 I will address the scope and, findings to date of tha Phase II program.
- 20. Finally, it is important to recognize that the TES role for Phase I has changed significantly. The original Commission Order contemplated a sample verification of the Diablo seismic design. However, because of the significance of the errors disclosed, and PG&E's decision to conduct a seismic review i
and redesign, TES and the NRC are now faced with reviewing in many cases a new seismic design, with new models and new model parameters, and a reconstructed plant. Thus, the verification j program, at least with regard to seismic features, has now expanded into a redesign, recons truc t , and reverification program. This is a significant change in the scope and magnitude of the original program contemplated by TES and the NRC.
Moreover, this change raises serious questions about the adequacy of the present seismic design since discrepancies still appear to exist between BNL's seismic models of the parts of the I
plant it was asked to review and PG&E's newest seismic models for those portions of the plant.
A complete and detailed assessment of PG&E's seismic redesign and TES's reverification program is impossible at this i time because the affiant and other technical advisors to the State of California have not been granted access to the Diablo Canyon seismic design data developed by PG&E, Bechtel, and Westinghouse. In addition, the af fiant has not had access to the plant site to review the adequacy of the QA/QC measures and their 1
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4 e O implementation during the ongoing modifications to SS&C's.
Indeed, such a final review of seismic design data and plant modifications is not possible at this time since the design and modifications are not yet complete for all SS&C's. Likewise, the TES reviews, and resulting reports, are not yet complete.
III LIMITED PHASE II VERIFICATION PROGRAM DISCLOSES CONTINUING PATTERN OF QA/QC BREAKDOWNS
- 21. The limited Phase II reverification program has revealed a continuing pattern of breakdowns in the Diablo Canyon QA/QC process and of errors in the product resulting from that process. Thus, if major surprises af ter license reinstatement are to be avoided, then the Phase II program will need to be substantially revised to address in a statistically valid methodology the adequacy of all design and construction activities at Diablo Canyon which are "important to safety," as required by GDC-1 of Appendix A to 10 CFR Part 50 and Appendix B to 10 C.F.R., Part 50.
A. Non-Seismic Safety Design Flawed
- 22. S&W, a subcontractor to TES, has reviewed portions of three safety-related systems (one system each with regard to fluids, air, and electrical) to verify the compliance of the l
non-seismic safety design with the regulations and the Diablo Canyon operating license application commitments. To date, approximately 70 deficiencies have been reported. While the number of deficiencies for Phase II is less than for Phase I 15.
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(195), I believe that the Phase II results to date are at the very least equally significant to the Phase I findings which led to PG&E's decision to initiate a complete seismic review and redesign.
- 23. Indeed, Dr. Cooper of TES at a meeting on October 19, 1982, acknowledged the equivalence in safety significance between the design errors discovered during Phase I and Phase II in his comment that (October 19 Tr. at p. 36):
. . . we would anticipate a total Phase II EOI someplace in the mid to high 50s. Now, that is a much smaller number than the 200 (for Phase I). . . . But also, I think you will find that a much higher percentage of these are significant than the large number on Phase I. . . . So I would expect a biqqer percentage of these would be as significant as those dozen or so we said were significant for Phase I. My present guess is that something like the same number perhaps even a little larger, perhaps even 15, of these would be of significance. . . . What we are saying is in the very broad look on Phase II we are coming up with about the same number of significant items as on Phase I. . . ."
Furthermore, Mr. Maneatis of PG&E, in an exchange with Mr. Eisenhut of the NRC, concluded that there was no distinction between the PG&E QA/QC process for seismic and non-seismic design in the pre-1978 period as follows (September 1, 1982, Meeting Tr.
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t at p. 24):
"MR. EISENHUT: Okay. So really, not to belabor the l point, I guess the other piece of the question is, is there I
any distinction pre-1978, is there any distinction that can l be drawn between seismic service related and non-seismic service related from the standpoint of what PG&E required in the way of a seismic -- I mean in the way of a programmatic QA needs and reequirements? Any distinction between seismic and non-seismic?
"MR. MANEATIS: In what time frame again?
"MR. EISENHUT: Pre-1978.
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. o "MR. MANEATIS: No, there was no distinction.
"ME. EISENHUT: No distinction.
"MR. MANEATIS: Like I said in my remarks, there is really no distinction in the programmatic requirements between non-seismic and seismic contract, there 's no reason to have a distinction."
In addition, Mr. Maneatis and Mr. Friend of Bechtel agreed with Mr. Eisenhut that the majority of the non-seismic i
safety design was accomplished during the time frame in which l
l Reedy's Phase I review had identified deficiencies in the FG&E I l
QAQC program and its implementation. The. time period for non-seismic safety design was established as follows (September 1, 1982, Meeting Tr. at pp. 24-25):
"MR. EISENHUT: That's right, now of the fractions of work performed , was there an equal amount of the non-seismic work that was performed prior to 1978? I mean, was the majority of the -- let me put it another way. The majority of the seismic service related contract work was performed prior to 1978. Does that also hold for the non-seismic service related contract work?
"MR. FRIEND: I think that's correct.
"MR. MANEATIS: Essentially the plant was completed by 1979 and so I think the answer to your question was yes."
- 24. Finally, unlike a Safe Shutdown Earthquake (SSE) which is thought to be a low probability event, the non-seismic safety designs are in large part provided to deal with events which will happen, and in some cases happen of ten , during the operating lif e of Diablo Canyon . Thus, there must be valid assurances that these features important to safety will operate properly during and following all design basis conditions.
Implementation of a disciplined QA/QC process is intended to result in this assurance. However, as the Reedy Report revealed, 17.
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there can be no assurance that the Diablo Canyon-design QA/QC l I
process has been effectively implemented. Rather, the evidence l indicates that PG&E and its design contractors in important instances failed to implement the required QA/QC measures.
- 25. The S&W reviews to date of the product (the design documents) resulting from the OA/QC process as part of the TES Phase II program confirmed that design discrepancies do in fact exist in the normal and accident modes of the Diablo Canyon non-seismic safety design. Moreover, even prior to the initiation of the Phase II review, discrepancies in the non-seismic safety design were disclosed by PG&E and TES including the items as follows: improper piping thermal analysis; misapplication of circuit breakers; and failure to satisfy single failure criterion for the control room power supply. In addition, during its Phase II review, S&W has established that generic concerns may exist with regard to the following:
(1) Redundancy of Equipment and Power Supplies in Shared (Units 1 and 2)
Safety-Related Systems The S&W review of the Mechanical / Nuclear design of the Control Room Ventilation and Pressurization System (CRVP) identified generic concerns for the emergency electrical power supplied to shared safety-related systems. The FSAR, Page 8.3-4, states that for a postulated LOCA in one unit and a shutdown in the other unit, each unit can withstand an assumed single failure f of a vital bus. Since it must be assumed that a loss of offsite 18.
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o a power occurs coincident with the postulated LOCA, three vital buses (one in the LOCA unit and two in the shutdown unit) will not have power available, as the swing diesel would be aligned with the LOCA unit. Portions of the Class I components of the CRVP System are shared between Units 1 and 2, and as such are provided with safety-related power from Units 1 and 2. Based on the assumed single failure in both units identified above, adequate electrical power redundancy is not supplied to the shared CRVP System to meet the single failure criterion.
Therefore, a single failure could result in failure of the control room to isolate, pressurize, and/or select pressurization air from the least contaminated intake, or to provide adequate air conditioning to remove heat generated from the vital electrical equipment located in the safeguards room.5/
(2) Selection of Design Pressure, Temperature, and Differential Pressure Across Control Valves The S&W review of the Mechanical / Nuclear design of the Auxiliary Feedwater (AFW) System disclosed that the intent of the ANSI B31.7 piping code was not complied with and a nonconserva-tive design pressure was selected. Also, the addition of a valve in a low pressure portion of the AFW System resulted in
- 6. ITR 34, Rev. O, Verification of Diablo Canyon Project Efforts by Stone & Webster Corporation, pp. 3-1 to 3-3. See also PG&E's Phase II Status Report dated March 11, 1983; Letter, Dr. Cooper to Mr. Maneatis, et al., dated January 18, 1983; TES's Semimonthly Status Report for February 1983; and Draft ITR, Phase II - Additional Sample and Additional Verification, December 23, 1982. Also, see EOI's 8012 and 8016.
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r noncompliance with the ANSI B31.1 code regarding protection of low pressure piping and components from higher pressure. Either of these conditions could result in overpressurizing piping and components. The selection of a nonconservative design pressure affects the stress analysis of piping because longitudinal stresses caused by internal pressure are combined with stresses from other loads. Control valve specifications were reviewed by S&W to determine the maximum dif ferential pressure specified for actuator sizing. Valves FCV 37, 38 and 95 were specified with a maximum differential pressure that is lower than the valves are expected to operate against. The selection of low design pressures can affect the code acceptability of a system and the stress analysis. The selection of low differential pressures across valves can affect their ability to operate against expected higher differential pressures.2/
(3) Environmental Consequences of Pipe Ruptures Outside of Containment The S&W review of the calculational methods used to evaluate the environmental parameters outside the containment has identified that safety-related equipment located outside containment will be exposed to higher temperature and pressure
- environments than reported in licensing documents. This conclusion is based on the inapplicability of the CONTEMPT computer program used by Nuclear Services Corporation (NSC) to
- 7. Ibid. 6, pp. 4-1 to 4-3. See EOI's 8009, 8010, and 8062.
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calculate environments outside containment and on the other analytical errors.0/
(4)- Jet Impingement Effects of Postulated Pipe Ruptures Inside Containment The Reedy review for Phase II~ documented the concern that PG&E had no formal program supporting commitments in FSAR Section 3.6, addressing the ef fects of High Energy Line Break (HELB) jet impingement on safety-related components inside the containment building.E/
- 26. While the Phase II review is ongoing, and thus . tot complete, TES and its subcontractors have also identified other generic aspects of the non-seismic safety design which may be deficient, including the following :
(a) Power / Control Separation The S&W review of the Fire Protection System provided for the AFW System, CRVP System and the safety-related portions of the 4160 V Electric System concerning the power control circuit separation, identified the concern that the cable separation analysis performed by PG&E does not completely address all circuits required for operation of safety-related components required to ef fect a cold safe shutdown and maintain control room habitability. The significance of this concern is that a single fire could jeopardize the safe shutdown function i
- 8. Ibid. 6, pp. 5-1 to 5-3. See E0I's 8001, 8002, 8003, 8004, 8033, and 8034.
- 9. Ibid. 6, pp. 6-1 to 6-3. See EOI 7002.
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of a system if circuitry for redundant portions of ' the system are not adequately separated.10/
(b) Moderate Energy Line Break (MELB)
Protection PG&E's September 14, 1978 and December 28, 1978, submittals - to the NRC committed to evaluating the Diablo Canycn design for the effects of MELB on all equipment required for cold safe' shutdown. The CRVP System is required to maintain control room habitability during cold safe shutdown, but_was not included in the PG&E evaluation. The exclusion of the CRVP System from the analysis could indicate that other systems or equipment which are required for cold safe shutdown may also have been excludea.11/
(c) Motor Start Capability The S&W review of the documentation for the safety-related motors in the AFW and CRVP Systems identified in ITR No. 26, Rev. O, did not indicate the capability for~ all motors to start and accelerate to full speed at 80 percent rated voltage.12/
(d) Voltage Profiles The review of voltage conditions on 4160 V and 480 V systems by S&W identif ied the concern that continuous low voltage could happen during periods of low voltage on the 500 kV and 230 kV systems which will result in overheating of safety-related j 10. Ibid. 6, see EOI's 8019, 8020, 8021 and 8032.
- 11. Ibid. 6, see EOI C050.
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p o motors. Also, transient low voltage conditions due to starting large motors may drop out 480 V safety-related motor starter-contacts, resulting in losa of electrical equipment controlled from these starters.13/
(e) Short Circuit Availability The review of available short circuits currents by S&W identified the concern that the available short circuit currents calculated on 4160 V safesty-related b'uses.F, G and H are greater than the interrupting capacity of the 4 kV circuit breakers. A short circuit can cause failure of a circuit breaker and damage to main buses and power supply cables. The resulting outage might involve one or all of the 4160 V safety-related buses.11/
(f) Cable Separation Within Enclosures S&W identified the concern that redundant Class IE cables / wires are installed within enclosures without the required separation to meet the separation criteria in the FSAR.15/
-(g) Independence of Power Distribution S&W also identified the concern that two colored vital trains are located within one transfer switch or control
- 12. Ibid. 6, see EOI 8061.
- 13. Ibid. 6, see EOI's 8023, 8024, 8025, 8026.
- 14. Ibid. 6, see EOI 8022.
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-. o circuit. Failure in a single switch or circuit 'could result in the loss of redundant equipment.15/
- 27. Since the Reedy Report indicates that the_ design QA/QC process is deficient, and the Phase II review to date I indicates that the sample of non-seismic safety design output reviewed, which was a result of the QA/OC process, is also deficient, I conclude that there can be no confidence that the non-seismic safety design has been adequately implemented for normal and accident modes of reactor operation in accordance with the requirements of the NRC regulations and the operating license application commitments in the Diablo Canyon FSAR. The Phase II sampling has served its intended purpose. Now, similar to the seismic redesign, it is imperative that the design of all safety features for all important safety systems be reviewed and - ,
reverified in a statiscally valid manner since judgment sampling is no longer warranted or appropriate.
B. Limitations of Construction OA/OC Review
- 28. In September 1982, PG&E proposed that S&W, under the direction of TES, conduct a limited construction OA/QC review of two site contractors - the civil and piping contractors. To date, 29 potential deficiences have been documented in the construction review. Of the 29, 23 have been classified as Class C errors, while 1 has been classified as a
24.
Class A error. However, the reports which have been issued fail to provide the requisite information which would enable an independent observer to evaluate what the identified deficiencies mean with regard to implemen'tation of the QA/QC process. While the limited construction review should ultimately provide some useful information, in my opinion, the construction QA/QC review was improperly limited or restricted in five major aspects:
numbers of contractors, QA/QC Program adequacy, QA/QC process implementation, overemphasis on paper, and vendor quality.
- 29. First, the number of contractors selected was inadequate to provide an overall assessment of the quality of the Diablo Canyon construction. Important site activities including those of the electrical contractor and the heating, ventilating, and air conditioning (HVAC) contractor were not' reviewed. These are significant omissions. Further, there is no basis for
- assuming a correlation between the quality of concrete and the quality of electrical terminations. Also, HVAC and electrical contractor efforts are both complex and occur late in the plant cycle when there is greater schedule pressure. In my opinion, the construction QA/QC review should address a statistically
~
valid random sample of the activities of all major site contractors in order to yield meaningful results that can be extrapolated to all construction.
- 30. Second, no review of the two selected contractors' QA/QC programs was conducted to compare the programs with the regulatory requirements of Appendix B to 10 CFR Part 50, G DC-1 25.
of Appendix A and the ANSI QA/QC standards cited in the Diablo Canyon'FSAR. Thus, the construction QA/QC review was not the i type of program review conducted by Reedy for design activities which began with a review of the QA/QC program as compared to the regulatory requirements and PG&E commitments. Rather, PG&E and Bechtel personnel indicated that TES and S&W simply accepted as satisfactory the contractor's QA/QC programs and then attempted to confirm that aspects of the program had been implemented.12/
In my opinion, the contractor's QA/QC program should be demonstrated to be in compliance with the regulations and license application. Any areas of non-compliance or of omission should be addressed as appropriate as part of the implementation audit to determine if adequate compensating measures have been instituted.
- 31. Third, in reviewing the deficiencies , S&W apparently i
focused on the " safety significance" of the findings rather than focusing on what the deficiency may generically mean with regard to the overall QA/QC program implementation.1S/ Such reliance on
- safety significance is misplaced in a QA/QC review, for it may only be fortuitous that the identified discrepancies resulted in no or a ainor safety problem. Thus, in my opinion,
- 17. Ibid. 2, pp. 102-104.
- 18. For example, see TES Semi-Monthly Report, February 11, 1983, File No. 9015, Rev. 2, File No. 9016, Rev. 2, File No. 9017, Rev. 2, File No. 9018, Rev. 2, File No. 9020, Rev. 2.
A
! 26.
4
all discrepancies should first be evaluated with respect to to the QA/QC process implemen tation .
- 32. Fourth, the construction QA/QC review placed its major emphasis on reviewing installation OA/QC records or conducting visual inspections as compared to repeating actual installation tests or physical inspections of hardware items.
In my opinion, the construction QA/QC verification program should verify, to the maximum extent possible with non-destructive examination, the proper installation of Diablo Canyon safety features in the as-built configuration. In addition, as discussed in detail in Section IV of this affidavit, a statistically valid sampling methodology should be utilized by TES.and S&W. There is no evidence that such statistically based random sampling techniques were utilized in i
the construction QA/QC review.
- 33. Finally, no attempt was made by S&W to verify the adequacy of the QA/QC process implementation at the vendors of safety items or to confirm the quality of the received safety items. For example, there are approximately 24,000 Midland-Ross Company cable tray and conduit supports installed at each Diablo Canyon Unit. The supports werc classified as safety-related, but were purchased as catalog (commercial grade) items. In December 1982, the NRC determined that the Midland-Ross QA/QC program and its implementation was deficient as follows:1E/
- 19. Le t te r , Crews to Eisenhut of the NRC, December 16, 1982.
27.
._w
"(1) there was no formal Quality Assurance (QA) program prior to 1979, (2) there were no records of the qualification of welding operators or welding procedures, (3) prior to 1980, spot welds were not sample tested and not controlled by procedures, (4) there was no traceability of material, (5) there were no quality records before 1980, and (6) generally, the current QA program did not meet the intent of 10 CFR 50, Appendix B criteria."
The actual quality of the installed equipment.is still indeterminate. However, the NRC findings indicate that PG&E failed to properly document and control the quality of vendor supplied equipment as required by Criteria 4 and 7 of Appendix B. Further, the failure appears similar to PG&E's failure to properly control its seismic service related contractors. In addition, the Midland-Ross finding indicates that PG&E may not have properly identified all safety-related items or have completely listed such items in Section 3.2 of the FSAR. The potential generic implications of the two preceding deficiencies, as well as questions regarding PG&E's QA/QC neasures for commercial grade items should be determined.
C. Verification Program Fails to Address SS&C's Important to Safety
- 34. The NRC in its order suspending the Diablo Canyon operating license found that20,/
- 20. CLI-81-30, p. 3.
28.
o- .
.f d
" . contrary to statements made in PG&E's operating license application, certain structures, systems, and components important to safety at the plant may not be properly designed to withstand the effects of earthquakes, and further indicates that violations.of NRC's regulations in 10 CFR Part 50, Appendix B have occurred. Had this information been known to the Commission on or prior to September 22, 1981, Facility License No. DPR-76 would not' have been issued until the questions raised had been resolved." ( Dmphasis added. )
Further in drafting the order, the Commission found that2 1/
. . . it is now uncertain as to the extent which structures, systems, and components important to safety of fuel loading and testing at up to 5% of rated power will in fact withstand the effects of earthquakes, ...
( Emphasis added )
and thus the Commission made the order ef fective immediately.
- 35. However, despite the " Order Suspending License,"
both TES cnd the NRC have limited the reverification program to
" safety-related" rather than "important to safety" items. There are important distinctions between the two lists of SS&C's, and the QA/QC requirements for such items.
- 36. The Commission has recently reiterated the important distinction between the terms "important to safety" and " safety-related." This distinction was explained in a November 20,
- 21. Ibid. 20.
29.
1981, memorandum from Harold Denton , Director of the Of fice of -
Nuclear Reactor Regulation , to all NRR personnel. "Important to safety" SS&C's, systems and components are defined as those which provide reasonable assurance that the facility can be operated without' undue risk to the health and safety of the public.
" Safety-related" is defined with reference to 10 CFR Part 100, Appendix A as ' describing those SS&C's which are necessary to assure: (1) the integrity of the reactor coolant pressure boundary; (2) the capability to shut down the reactor and maintain it in a safe-shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposures of Part 100. Tne Denton memorandum explains that safety-related is a subset of the class of important to safety items.
- 37. The Diablo Canyon FSAR used the term "important to safety" interchangeably with the term " safety-related" and in
- Section 3.2 of the FSAR defines "important to safety" using the Part 100 definition. Thus, there is a lack of evidence that.PG&E has implemented a systematic QA/QC program, including a detailed l equipment list, for all SS&C's "important to safety" as required l
l by GDC-1 of Appendix A and Criterion 2 of Appendix B to 10 CFR I Part 50. The - S&W Phase II findings also indicate that even the list of safety-related equipment may not be complete. Further, the Bechtel topical report filed in the Diablo Canyon docket also only addresses a QA/QC program for " safety-related" SS&C's.
f 30.
- 38. Two recent events underscore the potential safety importance of items important to safety but not safety-related being provided the proper classification, maintenance, and QA/QC treatment commensurate with their safety importance. The events were the failures to scram at the Salem plant, a Westinghouse PWR, on February 22 and February 25, 1983. The scram breakers as a single component were classified as safety-related. However, neither the under voltage nor the shunt trip coil which are subcomponents of the scram breaker and essential to its function were properly classified as safety equipment. As a result, they did not receive the required maintenance.
- 39. At a recent Commission briefing on the Salem events, Mr. Denton described the problem as a total breakdown. He found it difficult to see how the assistant plant manager had fail,ed to recognize these scram breaker subcomponents as safety significant or to consider them safety grade for procurement or maintenance purposes.22/ The Salem examples are directly relevant because they clearly show why Diablo Canyon must have a list of equipment and its classification consistent with its safety significance.
Moreover, the Salem failures demonstrate that the NRC Staff must be assured that Diablo Canyon has implemented a systematic, quality program that provides the necessary care for the 1
equipment according to its safety significance. For example , the Salem plant had a list (Master Equipment List) but the scram
- - - - =
- 22. Transcript of March 15, 1983, Commission Briefing on Salem Events, p. 22.
l 31.
l l
breaker's shunt relay (which is important to safety) was not included on the safety-related list. Thus, for years the relay was given no maintenance. When it failed the first time (February 22, 1983), it was given ordinary commercial treatment.23/ The result was that the breakers again failed on February 25, 1983.
- 40. The Salem event has a close parallel in Diablo Canyon's lack of recognition of items important-to-safety but not safety-related, and in the absence of a clearly defined systematic program of QA/QC for such items. In the interest of preventing failures such as occurred at Salem which may impact the safety of Diablo Canyon's operation, a retrospective review of the sfety classification and quality program should be promptly initiated.
- 41. Any of the preceding deficiencies in the PG&E and Bechtel OA/QC program relative to SS&C's important to safety are exacerbated by the NRC Staff's recent admission during my participation in the Shoreham operating license proceeding that:
"The Staff does not review the quality assurance program for items important to safety but not safety-related, nor does it inspect for compliance with cuch a program." Speis
- 23. Tr. Commission March 15, 1983, briefing on Salem event,
- p. 41.
32.
e 9
et al., ff. Tr. 6357, at 8-9; Tr. 7063, 7480 (Haass); Tr.
16961, 17288-91 (Higgins).21/
Thus, neither the past nor current NRC Staff reviews or Inspection and Enforcement audits can be relied upon to provide a demonstration of conformance with the requirements of GDC-1 in Appendix A to 10 CFR Part 50.
- 42. In view of the fact that the same QA/QC program which was found to be inadequate for the design of safety-related systems in the plant may not even have been systematically applied to SS&C's important to safety, it is my opinion that in the absence of thorough verification of these items, there can be no assurance that these SS&C's have been designed or constructed in accord with the technical requirements of the NRC's regulations and PG&E's license application commitment.
IV SAMPLING TECHNIQUES ARE BASED ON JUDGMENT RATHER THAN STATISTICAL METHODS
- 43. Sampling is being utilized in the ongoing Diablo Canyca reviews by PG&E/Bechtel, the NRC, and by TES and its subcontractors. These sampling progcams rely on subjective engineering judgments rather than objectivr; statistically valid sampling techniques. Thus, there is a question whether the conclusions of TES, or e.ventually the NRC, that are based on sampling data are justified, given the sampling methodology
- 24. NRC Staff Proposed Opinion, Findings of Fact, and Conclusions of Law, Shoreham, Docke t No . 50-322, Finding 7B:82,
- p. 85.
33.
L 3 .
which was used. This is true where the samples taken were obtained in a non-random fashion and do not lend themselves to extrapolation to the populations of items and documents under study. In such an instance, it is my opinion that the substantive findings of TES and the NRC are unjustified.
- 44. An integral element of TES's verification program is sampling of structures, systems, and components to determine that they are in fact designed or constructed in accordance with applicable requirements. However, TES's program does not adequately describe the statistical basis for the criteria to be used for the selection of a suitable number and type of samples to be reviewed under the program or for the selection of items for additional verification. In short, TES has proposed to use sampling extensively without providing adequate guidelines or criteria for evaluation of that sampling.- Thus, the TES program should be altered as follows:
(a) De fine the confidence level which the auditors desire to achieve for each sampling ef fort and provide the basis for selection of that confidence l'evel.
(b) Provide the statistical basis for the relative l size of sample utilized in each case. If the sample is stratified, the basis and justification for the stratification should be given.
(c) For each sample selected, demonstrate factually that the sample is representative of the total population of the item being sampled.
34.
s a (d) Define precisely the acceptance criteria for t
cach sampling effort, together with the factual basis for those criteria.
(e) Specify precisely in advance the criteria to be used for expanding a sample based on the results of the initial sample.
(f) In addition, TES should specify in detail the scope of work proposed for the statistician who will conduct the Phase I program review of statistics.
VI CONCLUSIONS
- 45. Based on the foregoing, I conclude that the significant new information set forth 1.erein and in my May 24, 1982, affidavit demonstrates that PG&E and its major subcontractors failed to develop and implement a QA/QC program during the design and construction of Diablo Canyon which complied with the NRC's regulatory requirements. The examples given here document PG&E's failure to provide a QA/QC program for design and site activities in a timely fashion in compliance wth the license application and the regulations for activities conducted prior and subsequent to the 1977 Board hearings. We now know that significant errors resulted from the flawed Diablo Canyon QA/QC process.
- 46. The result of the mistaken assurances concerning the comprehensiveners of the Diablo Canyon QA program from PG&E and the NRC Staff is that the Board issued a seriously flawed 35.
e o decision. The magnitude of significant design and cotistruction discrepancies disclosed to date, and the widespread serious breakdown in management of the OA/OC program by PG&E and its major subcontractors, vividly illustrate the substantial uncertainty in the actual quality level achieved in design, construction, and installation of all important to safety structures, systems, and components at Diablo Canyon. A complete, statistically valid, design verification and physical inspection of all Diablo Canyon structures, systems, components, and other important safety features, as outlined in the preceding, is now r20th necessary and prudent. The results and underlying data, resulting from such a design review and site inspection, should be subject to the scrutiny of the Board and all parties in the cngoing Diablo Canyon licensing proceeding.
I declare under penalty of perjury that the foregoing is true and corect in all respects and that if called as a witness I could and would competently testify thereto.
RICHARD B. HUBBARD Subscri and sworn to b h re me this age day of T/ M , 1983. gennnennn,n,,,,,,,,,,,,,,,,,,,,2Es"c""'t E orrics
/ 3 ~ i RAYMOND A. PROCTOR '
/ I Notaar evout
- CAUmm
/ j Cousny op 8A8t?A Ctana I l //A/ b, . g"""'""""""""Comm, Exp. Dec. 20, I985 h d' For 'Sa MCounty
~
N sFy Tublic In """'""'""ma n = ==E and tate 36.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
l PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
__)
CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing " Supplemental Af fidavit of Richard B. Hubbard" served on the following by U.S. Mail, first class, postage prepaid.
Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H S tree t, N.W.
Washington, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission l
i 1717 H S t ree t, N.W.
Washington, D.C. 20555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 l
1.
o Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H S treet, N.W.
Washington, D.C. 20555 Hon. John Ahearne, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tree t , N.W.
Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. Thomas S. Moore, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. W. Reed Johnson Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge John F. Wolf, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge Glenn O. Bright Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Judge Jerry R. Kline l Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Jmmission Washington, D.C. 20555 l
i l 2.
o a J
Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Leonard Bickwit, Esq.
Office of the General Counsel 4 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence Chandler, Esq.
Jack R. Goldberg, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E. Kerr, Esq.
Public Utilities Commission 5246 State Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Deach, CA 93449 Mr. Frederick Eissler i Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 l
3.
l
Gordon Silver Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401 Joel R. Reynolds, Esq.
John Phillips, Esq.
Center for Law in the Public Interest 10951 West Pico Boulevard, Third Floor Los Angeles, CA 90064 Bruce Nor ton, Esq.
Norton, Burke, Berry & Junck 2002 East Osborn P.O. Box 10560 Phoenix, AZ 85064 Philip A. Crane, Jr., Esq.
Richard F. Locke, Esq.
F. Ronald Laupheimer, Esq.
Pacific Gas and Electric Company 1050 - 17 th S treet, N.W.
Suite 1180 Washington, D.C. 20036 David S. Fleischaker, Esq.
P. O. Box 1178 Oklahoma City, OK 73101 Arthur C. Gehr, Esq.
Snell & Wilmer 3100 Valley Bank Center Phoenix, AZ 85073 Mr. Richard B. Hubbard l
MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95125 Mr. Carl Neiberger l Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 4.
J
e 46 Virginia and Gordon Bruno Pecho Ranch P.O. Box 6289 Los Osos, CA 93402 blancy Culver 192 Luneta San Luis Obispo, CA. 93401 DATED: March 29, 1983 JOHN K. VAN DE KAMP, Attorney General of the State of California A!1DREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General t /
By [ M MIC AEL J. STRUMWAESER Attorneys for Intervenor Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 l (213) 736-2102 i
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