Memories of a Movement – Building a Backward Reactor

Memories of a Movement

By Mark Evanoff



“I wasn’t exactly popular around the office
then, because most people thought I was just
kind of nitpicking and that I was just stirring
up trouble when they were having troubles
outside. If the mistake had been detected,
say, one year later, it would have been
impossible to work on and rectify.”

-John Horn,
PG&E engineer

During the summer of 1981, before the NRC issued a low power test license for Diablo Canyon, the Abalone Alliance staged a number of demonstrations outside PG&E’s corporate headquarters in San Francisco to let workers know why they planned to blockade the Diablo Canyon nuclear power plant. John Horn, a 25—year old engineer who began working for the utility in May 1980, talked to the demonstrators and accepted their literature. “It’s good to listen to both sides,” Horn said, recalling those days. After the blockade began, he and his fellow workers followed the news of the demonstration. “I think everyone should be interested in the blockade. It’s our responsibility as human begins. It’s you’re duty to be aware of other people’s concerns.”1

Several of Horn’s classmates from Stanford University participated in the demonstration. Horn does not claim to be anti—nuclear, but is committed to good engineering. He served as the liaison between structural engineers and computers and helped evaluate the plant’s ability to withstand an earthquake. The Friday after the blockade began, Horn stared at a rough sketch of the circular floor inside the containment dome. The sketch was divided into five sections and Horn could not figure out what the sections meant. No one else in the office knew the answer either. “Out of curiosity I pulled some detailed cutaway engineering drawings out of the file—drawings that showed the actual placing of coolers and the two diagrams didn’t match. It didn’t make sense.”2 Designers intended the five sections to be placed under the cooling fans, but that didn’t occur when PG&E built the plant. Horn tried to resolve the discrepancy with his fellow engineers.

The following Monday, (the day the NRC issued a low-power test license) engineers tried to bring the problem to the attention of their department head, Michael Tresler, but he was out of the office. Further evaluations didn’t continue until Tresler returned to the office on Thursday. By Friday, the department realized PG&E had a major problem on its hands. At a meeting with John Blume and Associates, seismic design consultants for the plant, Horn figured the potential seismic forces could be stronger that the plant was built to withstand. The actual figures on the plant’s ability to survive an earthquake did not match those supplied to the NRC by PG&E. Diablo could not withstand an earthquake on the Hosgri fault. Company engineers continued to study the problem over the weekend while the Abalone Alliance wound down the blockade. PG&E notified the NRC on Sunday and suspended plans to load fuel the following morning, coinciding with the last day of the Abalone Alliance blockade.

“I wasn’t exactly popular around the office then,” Horn recalled, “because most people thought I was just kind of nitpicking, and that I was just stirring up trouble when we were having troubles outside.”3

“If the mistake had been detected, say, one year later,” Horn speculated, “it A would have been impossible to work on and rectify.”4

News of the mistake put Diablo in the headlines and embarrassed both the NRC and PG&E, who just days earlier, confidently proclaimed the plant safe. None of their inspectors had managed to detect the error that John Horn found merely by eyeballing drawings.

NRC Commissioner Peter Bradford responded, It’s a first rate screw-up. Here you have the most controversial area of discussion in what is the most controversial plant in the country. To commit an error of that sort is almost analogous to a student copying down the wrong homework assignment; No matter how brilliant the work from then on, he’s not going to get the right answers.”5

The mistake occurred in 1977 when PG&E supplied John Blume Associates engineering information meant for Unit Two, but labeled Unit One. Blume engineers used that information to calculate where seismic stress would occur during an earthquake and identified the piping systems needing support to survive an earthquake. Blume designed a safety system assuming the two reactor annuluses (the area surrounding the reactor vessel) were identical, when in fact they were mirror images of one another. Hence the key safety supports had been installed backward.

The mistake affected five safety systems. Not only were key support systems placed in the wrong location, the equipment they supported (five 45,000 pound fans) were underweighted. If the support systems failed, more than 100 tons of safety apparatus could cascade to the ground, disrupting the emergency core-cooling system. Trays carrying cables controlling safety equipment did not meet the proper seismic design and could fail.

John Sumner, a structural engineer for Diablo maintained this was not a serious problem. ‘You’re going to end up with half the plant being built too strong,” and disagreed that the piping systems might break during an earthquake. “None of them are under supported to the point they have been reported. . . It’s being blown out of proportion.”6

Barton Shakelford, who served as chief civil engineer during construction and became the company’s president, maintained the plant was safe. “We don’t see that there’s anything here to suggest that there could be any safety consequences from any event on the Hosgri fault, even if we did nothing to change the existing hangers.”7

Nuclear power experts questioned why neither PG&E nor the NRC discovered the mistake earlier. Robert Pollard, who left the NRC to work with the Union of Concerned, Scientists, argued, “They should have found those problems during the course of the required reviews and they didn’t. Now they want us to believe they will do a good job finding out whether they missed any others.”8

Richard Hubbard, a nuclear engineer advising Governor Edmund G. Brown, Jr., pointed out that the newest problems said as much about the weakness in the inspection process as in the design flaws. “It proves what we have been saying all along, that b the NRC spends a lot of time looking at procedures and systems but very little time looking at hardware. It is more a paper-work review than anything else.” 9

NRC inspectors look at only about one percent of the actual engineering work. “Our reliance on the licensee to do these things right is fundamental,” NRC inspector Edward Jordan explained. “They employ thousands of workers and a couple of hundred design engineers and we spend, say, one man—year inspecting the plant. “ 10

“If the nuclear industry does not do its part,” Commissioner Palladino added, “no amount of regulatory reform will save it from the consequences of its own failure to achieve the quality of construction plant operators must have for its own well—being and for the safety of the public it serves.11

“There is no question the NRC licensing process takes a great deal on faith,” Commissioner Peter Bradford offered, placing the matter in perspective. “There is little checking of actual hardware. This is all well and good as long as the few systems reviewed turn out all right. But when you find an error, it does raise questions about how well the other systems work.”12

Bobby Falkenberry, chief of reactor construction review for the Western Regional Office did not criticize the NRC inspection program and placed the blame on the utility. If you had proper management control and good checks . . . you would not have had the type of problem we’re seeing.”13

“If we had found it during the normal course of design review, it wouldn’t bother me at all,” PG&E engineer John Hoch reflected. “That is what the quality assurance program is there for. But we didn’t and that bothers me.”14

“Our philosophy is that the fundamental responsibility for the safety of the plant belongs to the licensee,” Commissioner Victor Gilinsky concluded. “If you don’t have confidence in the operator, you should never license him. He should never get a construction permit. It’s a judgment thing, and at some point you have to say you’re satisfied if you’re not satisfied: That’s the system and I don’t see how it can work any other way.”15

PG&E missed several opportunities to find the mistake. In 1979, the NRC issued a series of bulletins requesting utilities to check for seismic design errors. After checking the seismic design against the blueprints and the computer model that produced them, PG&E detected several mistakes and corrected them at a cost of $18 million. But engineers failed to detect the fundamental error.

“Had PG&E done a thorough analysis they would have found the error,” Dale Bridenbough, of MHB Technical Associates said. “The bottom line is that there were indications over time that there were problems with the seismic analysis projections, and PG&E should have gone one step further. I can see how they might have missed it. But in retrospect, you can say ‘Damn, they should have found it.’”16

On November 19th, 1981, the NRC Commissioners met and suspended PG&E’s low-power test license. PG&E would not be allowed to load fuel until the plant had been proved safe by an independent design audit.


After Horn discovered the error, PG6cE hired Robert Cloud and Associates to conduct further investigations into the plant’s design. Cloud and Associates worked with PG&E on other projects and received forty-five percent of its income from PG&E. NRC officials warned PG&E that Cloud might not be acceptable to the Commission as an independent auditor.

On November 3rd, 1981, a representative of PG&E met with the NRC staff to discuss Cloud’s revivification program. NRC staff director Harold Denton asked PG&E if Cloud planned to send the same reports prepared by his firm to both the NRC and PG&E. PG&E senior vice-president George Maneatis responded, “You just got it. And, I have to say Mr. Denton, that some of those things have just been disclosed to me, so you get it almost the same time I did.”17

Bruce Norton, PG&E’s attorney for the case stated, “It’s not a question of us reviewing it. We don’t have it either. . . I frankly resent the implication that Dr. Cloud is not an independent reviewer.”18

Six PG&E employees present in the room when Norton and Maneatis made their statements had already seen and edited the Cloud reports before sending them to the NRC. None chose to correct the erroneous information or to inform the men making the statements that they misunderstood the situation. California Congressional Representative Leon Panetta discovered in December that three drafts of the Cloud reports had been delivered to PG&E before the NRC. One former Cloud employee told the NRC that he was asked to “reword the thing to make it sound better for PG&E.”19

PG&E vice-president Maneatis, maintained in testimony to the NRC that he did not learn until December 10th that the reports prepared by Cloud had first been shared with PG&E. Attorney Norton said he hadn’t learned of the editing until December 14th. Cloud contended that he thought everyone at the November 3rd meeting was I referring to the final draft and considered the drafts submitted to PG&E, “working papers.”

Four PG6cE employees who edited the reports insisted they did not mislead the commission. Two, however, admitted wrong doing. James V. Rocca, chief of PG&E’s mechanical and nuclear engineering division, and John B. Hoch, manager of nuclear projects, agreed that the testimony given at the November 3rd meeting was wrong, but chose not to correct the testimony. . .

“I guess I realized that there was an inaccuracy in his statement,” Rocca said. “First of all, I was not in that up-at—the-table in that area. I was in the back of the audience during the hearing. So it just wasn’t logistically reasonable at that time to jump up and down or anything.”20

PG&E engineers changed the tone of C1oud’s reports. The original version read, “There is no need to requalify the auxiliary salt water pumps if the building is truly rigid since the seismic design spectra were used to qualify these pumps. “The edited version read, “because the building is truly rigid. . .” 21

Another document originally read, “because of the recent development to the discovery of an air in the annulus spectra, no conclusion can be drawn on the structural adequacy of the annulus.” Engineers changed the statement to, “a conclusion, slightly qualified can be drawn.” 22

To defend the company’s integrity, PG&E Chairman of the Board Fred Mielke, sent a letter to the editor of every northern California newspaper stating, “Opponents of the Diablo Canyon nuclear power plant have brought their campaign to a new low in attacking the integrity of PG&E engineers and the independent auditor it has retained to review the plant’s design features.”23

Mielke explained the submission of drafts for editing as “standard audit procedure recommended by the ‘Standards of Aud1ts’ of the Comptroller General of the United States Nuclear Regulatory Commission’s Office of Inspector Auditor, to help eliminate factual errors in audit reports.”24

NRC investigators disagreed with Mielke, and found the utility guilty of softening its reports. “Some of the comments made by PG&E personnel and submitted to R.L. Cloud were of an editorial nature and were intended to make particular statements of the draft report less critical of PG6cE,” the NRC investigation noted. 25

The NRC Commissioners voted 3 to 2 that PG&E made material false statements when it denied C1oud’s study had been submitted to utility officials before sending it to the NRC.

Commissioner Joseph F. Aherne dissented in the vote arguing it “established an unacceptable low threshold for material false statements.” However Aherne agreed that the company’s conduct “was not the best” and thought the six employees knowing about the editing should have clarified the matter at the hearing. 26

Commissioner Thomas M. Roberts said it appeared to him that a false statement was made at the meeting by PG&E representatives, but dissented on the violation because he was not certain, “that this statement was a material false statement within the sense of the Atomic Energy Act.”27

“It is troubling that a company which asks permission to operate nuclear power plants should be so insensitive to its obligation to inform federal regulators and the public,” Commissioner Victor Gilinsky wrote. “The issue is not the circulation of reports, but the false portrayal of PG&E’s relationship with Dr. Cloud’s firm. . . I would have gone beyond the terms of the Commission’s order and imposed civil penalty to underline the seriousness with which the Commission views PG&E’s action.”28


PG&E’s persistent refusal to supply information to the NRC aggravated the Commission’s attitude toward the utility. Robert Engleton, Western Regional Director for the NRC testified that PG&E knew it was using the wrong seismic information during construction in 1978, but felt the building engineering was conservative and therefore did not inform the Commission. 29

“That fact,” Commissioner Gilinsky added, “calls into question the integrity of the company and the question of whether it’s fit to run a nuclear plant.”30

Director of Inspection and Enforcement Richard DeYoung testified before the

Commissioners, that PG&E’s problems with Diablo stem from “its failure to give proper direction and allowing lawyers without proper technical background to oversee technical decisions. I have known this utility for a long time and there is something basically wrong with the leadership, the direction they give the staff. It has been a problem for some time.”31

NRC staff member Robert Engelton added, “the utility’s attitude seems to be one of regulation being some sort of nuisance that they put up with and it results in a kind of arrogance that we all feel. It is rather general feeling that they are not always free and forthcoming with information.”32

Prompted by questions raised by the intervenors, the NRC staff investigated PG&E’s “independent” design audit of Diablo and found Cloud’s study program deficient in a number of areas. If a design error was discovered, Cloud’s program had no procedure to correct the problem or notify the NRC. The staff further found the level of detail inadequate and “confusion and lack of defined goals” among Cloud employees. “There are serious questions requiring prompt NRC management and staff evaluations and directions.” Without that “Cloud and PG&E will continue on their present program, with its various potential problems.”33

Robert Cloud denied the inadequacies of the audit. “There is no quarrel going on here about the adequacy of the revivification. These areas are properly addressed in the scope of the work. Due to the press of time, we just hadn’t committed to paper all of the details that were needed.”34

After holding a public hearing, the NRC told PG&E on March 4, 1982, it could no longer use Robert Cloud and Associates to conduct the design audit at Diablo Canyon because the firm was too small and had financial ties to ‘PG&E. As an alternative, the NRC approved Teledyne Engineering Services — a company owning 400 shares of T PG&E stock, and the retainer of $1.2 million in contracts at Diablo Canyon. Teledyne retained Robert Cloud and Associates to help with the audit. Intervenors challenged the adequacy of the revised audit program because it did not include on-site inspection to insure that the plant was built according to design.

Even the engineers working on the audit remained dissatisfied with its scope. One engineer complained, “The PG&E management only corrected mistakes that are found accidently or are forced down their throats. If the error is a generic one, they will not review everything, they will only correct that one mistake. I am pro nuclear, but invalid analysis and incompetence must not be ignored. This plant, in my opinion, is bad from the analysis to the supports.” 35

Despite problems in the analysis, Teledyne and Cloud discovered more than 400 additional design mistakes. Frustrated with its own sloppy design and construction work, PG&E hired Bechtel Corporation to correct the mistakes. Bechtel, builder of half the nuclear power plants in the United States, hired 5000 workers to correct the mistakes at Diablo. The corporation issued “We Can Do It” buttons to illustrate the urgency of the project and people worked around the clock. The workers didn’t concentrate on their assignment, and the NRC discovered workers drunk and under the influence of marijuana on the job. Several workers suffered injuries on the job attributed to drug and alcohol abuse.

PG&E hired R.F. Reedy Inc. to investigate why the design mistakes occurred in the first place. Reedy Inc. found PG&E’s quality assurance program for design work “inadequate in areas of policy, procedure and implementation.” Six out of seven consulting firms working for PG&E had no quality assurance program at all, which violated NRC procedures for Quality Control and Quality Assurance. The 89 page report described more than a dozen areas in which PG&E failed to implement its own in-house quality assurance program, or to require contractors to assure the quality of their work. Because of the general weakness with construction documents, Reedy’s investigation raised questions as to “whether appropriate design information was being exchanged and utilized by design groups and consultants.”36

The NRC requires utilities building nuclear power plants to maintain accurate records of all information relating to design changes — reasons for the changes, and what information was sent to consultants. If mistakes are discovered in analytical methods, the records can be consulted, and everyone given wrong information can be informed of the accurate information. With good record keeping, engineers can correct all mistakes that might occur. PG&E, however, kept no such records.

Richard Hubbard explained, “Quality Assurance and Quality Control. Recognize human imperfections and thus impose a control system designed to detect those inevitable errors and to . . . insure that the facility is . . . designed and constructed to the highest possible standards.”37

PG&E’s Russel P. Wishow assured the Atomic Safety and Licensing Board in 1977 that PG&E had a quality assurance program. “When you are dealing with people who are imperfect, you must add that the management controls and management assurance mechanisms that double-checks to see whether or not the individuals are indeed performing what they agreed upon and in accordance with the established program procedures and understood them.”38

However, URS/Blume Associates, the principle seismic structural consultant was not contractually obligated to a quality assurance program until July 12, 1978, eight years after the NRC required such a program. Most of the construction work took place prior to adoption of a quality assurance/quality control program. PG&E did not even explain the law to Blume until 1977. David Lang, working for Blume Associates wrote to PG&E in August 1978 stating his firm planned to adopt quality assurance guidelines for all future work done at Diablo, but planned to make no effort to re-examine all previous work.39

PG&E audited Blume’s work after 1977 and found 12 instances where URS/Blume did not implement contractual and quality assurance requirements.40 Blume personnel did not visit the Diablo site to see if the completed plant actually followed the design plans. PG&E didn’t review Blume’s calculations nor did Blume engineers check one another’s work.41

Problems existed within PG&E. Informal communications with consultants resulted in misunderstandings and inaccuracies in building strengths. PG6cE engineers failed to notify all contractors about design changes.42 The sloppy record keeping make it impossible to determine who had not been informed about design changes, and where unsafe structures existed.

PG&E’s own audits revealed a habitual pattern of failure to implement proper quality assurance design controls. “Design review reports,” a 1972 audit concluded, “have not been written by responsible engineers. It is therefore impossible to verify l whether the design was checked for applicable scientific requirements. There appears R to be confusion and a lack of understanding within the engineering department as to what a design review constitutes and how comprehensive it should be.”43

Five years later, in 1977, another PG&E audit revealed that the problem design review procedures identified in 1972 still had not been corrected. R.P. Wishow, working for the Quality Assurance Department wrote to J.D. Worthington, “Although the comprehensive. design reviews are nearly completed, some apparent design deficiencies which were identified during the design reviews, have-not been resolved. Also several design review reports lack required approvals and the appropriateness of the proposed resolutions to a number of apparent deficiencies appear to be open to question.” Wishow stipulated some of the proposed changes were not reported in the Final Safety Analysis submitted to the NRC.44

More problems appeared in a 1979 audit. Not all safety equipment and pipe systems had been properly tested on their ability to withstand an earthquake along the Hosgri. And the auditors still didn’t understand how extensively the quality assurance program had been applied.45

Even the consultants hired for seismic related safety tests destroyed their quality assurance records when it moved to a new building. Auditors concluded, “the seismic safety related testing activities performed by Whyl for Diablo Canyon cannot be accepted as having been performed under a quality assurance program.”46

Richard Hubbard concluded when requesting the Atomic Safety and Licensing Board to reopen hearings on quality assurance on design, “the significance of the quality assurance deficiencies disclosed to date at Diablo Canyon should not be characterized as a failure of dotting the ‘i’s and crossing the ‘t’s, but rather the significance was the disclosure of the nearly complete void of required quality assurance/quality control management controls during design activities by PG&E and its major subcontractors over almost a ten year period.”47

The poor quality—assurance program worried intervenors because it showed PG&E did not pay close attention to detail when building the plant. The plant was not built as PG&E claimed when it received permission to operate the facility. Hubard remained the NRC that the ASLB approved the plants seismic design on September 27th, 1979, under the assumption NRC staff review of the plant design was the most extensive ever undertaken.48

Hubbard continued, “Such reliance is misplaced since massive breakdowns in QA/QC have been disclosed. Second, the QA/QC breakdown at Diablo Canyon means there is no basis for confidence that safety related structures, systems, and components have been designed with and constructed in accordance with regulatory requirements and PG&E committeemen’s to its Construction Permit and Operating License applications.

“At Diablo Canyon, the need for a QA program . . . is even more important than at other generating facilities. The reason is that PG&E, the staff, and even the Advisory Committee for Reactor Safeguards have relied upon the alleged lack of errors in design and construction to compensate for less conservativism in Diablo Canyon than for other plants,” Hubbard concluded.

NRC acceptance of “superior QA/QC” allowed PG&E to relax normal criteria in assessing earthquake magnitude. The new analysis reduced the potential shaking of the reactor building caused by an earthquake along the Hosgri fault from a peak of 1.5 g. to an effective .75 g. This analytical method became known as the “Tao effect.”

Hubbard pointed out that, “as a result of the analytical relaxations introduced during the Hosgri reanalysis, the horizontal acceleration values for the Hosgri reanalysis were in a number of cases lower than the corresponding acceleration values in the original Double Design Earthquake (DDE) analysis. This is astonishing since the DDE accelerations were based on a magnitude 6.75 earthquake 12 miles away, while the postulated Hosgri event is magnitude 7.5 earthquake 3 miles from the plant. Clearly the analytical method used in the Hosgri reanalysis results in seismic spectra less conservative than those used in the original licensing.”49

Congressman Edward Markey asked the NRC to investigate PG&E and report on why PG&E had so many problems building Diablo Canyon. The NRC found, PG&E “had developed a false sense of security with respect to its engineering capability.” Diablo “was fitted into an environment that had not been adequately modified to handle nuclear work.” Company officials had “an ever—present tendency to short—cut procedures. “The report also said, “The NRC tended to loose sight of what it was trying to achieve and failed to provide adequate guidance on what a quality assurance program should be.”

However the NRC submitted the report to PG&E for editing, and company executives removed the damaging passages. Markey obtained a copy of the original report and released it to the media. Disregarding the design errors and PG&E’s building style, not all the NRC Commissioners accepted the plant’s safety. Even if PG&E built the plant without making mistakes, only two Commissioners, John F. Ahearne and Thomas M. Roberts, remained confident that the plant could withstand shaking from the Hosgri earthquake fault.

Commissioners Victor Gilinsky and Peter Bradford issued a` ten page decision denouncing the Licensing Boards decision approving Diablo Canyon’s earthquake design. Bradford and Gilinsky described the Tau effect as “almost mystical” and said the Commissioners should review the theory, “we cannot escape the impression that the Commission is declining review, not because the decision is sound, but because it is unsound and the prospect of reviewing it is so unsettling.”50

“Without Commission review,” they concluded, “not only will questions remain about the correctness of the Diablo Canyon seismic design, but the Board’s decision will stand as an unfortunate precedent which will undermine application of the Commission’s regulations on seismic design.”51

But because Commissioner Nunzio Palladino abstained from the March 19th, 1982 vote, (thinking it not appropriate to consider the matter until the completion of the plant’s design revivification review) the commissioners never garnered the majority votes needed to review the theory that made Diablo Canyon earthquake safe. On his own initiative Commissioner Victor Gilinsky asked the Advisory Committee on Reactor Safeguards to reexamine the tau effect in October 1983. Dr. Richard Savio working with the ACRS, said Nathan Newmark, the theory’s formulator, “was working on the edge of technology, or certainly on the edge of what other people are able to understand and agree on.” Savio said the ACRS would need more time and resources to examine the tau effects application at Diablo Canyon. He wouldn’t recommend using the theory when planning new nuclear power plants.

Despite doubts from the experts, the NRC allowed PG&E to load fuel at Diablo Canyon. Doubts not only existed about the theory that made Diablo “earthquake safe,” but the Atomic Safety and Licensing Appeals Board hadn’t finished hearings on the plant’s design quality assurance. Errors in design and quality assurance caused the blue print reversal and the Mothers for Peace wanted the NRC to find out why the mistake happened in the first place and the extent of the problem.

Joel Reynolds, attorney for the Mothers for Peace, said after the vote, “It’s always been our fear that the outcome of the licensing procedure was predetermined.”

Eight hours before the NRC allowed fuel loading, 20,000 gallons of water spilled onto the floor of an auxiliary building. Plant workers couldn’t shut off the flow immediately because the handle on a back-up valve was blocked by a support brace.

The Mothers said the water spill illustrated the design and construction problems with the plant. The NRC said the spill wasn’t serious and refused to conduct any additional investigations to see if braces blocked other valves. Fuel loading began November 18th, 1983. The Abalone Alliance scheduled a new series of demonstrations to begin on Friday, January 13th, 1984.

Footnotes for Chapter 9

1. John Horn, personal interview, July 6, 1982.

2. David Pearlman, “He Found Diablo’s Flaws,” San Francisco Chronicle, November 6, 1981.

3. ibid.

4. Susan Calhoun, “A Blueprint for Catastrophe,” Westward, December 10, 1981.

5. Judith Cummings, “inquiry on Diablo Canyon Reactor Design Expanded to Five Safety Systems,” New York Times, October 1, 1981.

6. Richard Saltus and Peter H. King, “A Scramble for Answers at Nuke. Site,” San Francisco Chronicle, October 4, 1981.

7. David Pearlman, “PG&E Braces for Its Diablo Quiz,” San Francisco Chronicle, October 9, 1981.

8. San Jose Mercury, October 29, 1981.

9. ibid.

10. ibid.

11. ibid.

12. ibid.

13. ibid.

14. ibid.

15. ibid.

16. ibid.

17. Carl M. Cannon and Tom Harris, “PG&E ‘mislead’ on the NRC Diablo Report,” San Jose Mercury, January 28, 1982.

18. ibid.

19. ibid.

20. ibid.

21. R.L. Cloud Associates, Inc., A Preliminary Report on the Design Interface Review of the Seismic Revivification Program, Project 105-4, October 1981, Copy 5, page 21.

22. R.L. Cloud Associates, Inc., A Preliminary Report o the Design Interface Review Of the Seismic Revivification Program, Project 105-4, October 1981, copy 3 page 16.

23. Fred Mielke, letter to the editor, Oakland Tribune, January 8, 1982.

24. ibid. .

25. John Fogarty, “PG&E Saw Diablo Reports First, NRC Staff Reveals,” San Francisco Chronicle, March 19, 1982.

26. “NRC Scolds PG&E on Diablo,” San Francisco Chronicle, February 11, 1982.

27. ibid.

28. Additional Views of Commissioner Victor Gilinsky, Regarding Pacific Gas and Electric’s Material False Statement, February 28, 1982.

29. John Fogarty, “NRC Questions PG&E’s ‘Integrity’ on Diablo Canyon,” San Francisco Chronicle, March 19, 1982.

30. ibid.

31. ibid.

32. ibid.

33. Tom Harris, Diablo Study Appears Inadequate, NRC Experts Say,” San Jose Mercury, February 17, 1982.

34. ibid.

35. Anonymous, Memorandum from Darrekk Eisenhut, Allegations Concerning Diablo Canyon Nuclear Power Plant, Docket 50-275, June 29, 1982.

36. R.F. Reedy, Inc., Quality Assurance Review gpg Audit Report, Phase L pp Safety Related Activities Performed by Pacific Gas g Electric Company Prior to June 1978, March 8, 1982.

37. Affidavit of Richard E Hubbard Concerning Breakdowns in the Diablo Canyon Quality Assurance Program, In the Matter of PGGLE, Diablo Canyon Nuclear Power Plant, Units 1 and 2, Docket No. 50-273, Operating License 50-232, United States Nuclear Regulatory Commission, May 24, 1982, p. 36.

38. Diablo Canyon Atomic Safety and Licensing Board, Tr. 3603.

39. Hubbard affidavit, pp. 62-66.

40. W.A. Raymond, letter to Barton W. Shakelford, June 29, 1979, Audit of URS/Blume and Associates, Engineers Audit No. 91605, Hubbard Affidavit, Appendix J.

41. ibid., pp. 67-68,

42. ibid., pp 69-70.

43. PG&E Quality Assurance Audit, June 19, 1972, Hubbard Affidavit, Appendix M-3.

44. R.P Wishchow, letter to J.D. Worthington, May 16, 1977, Comprehensive Design

Review Conformance to Procedure PRE—6, Audit No. 77016, Diablo Canyon Project, Hubbard Affidavit, Appendix N and pp.70-71.

45. W.A. Raymond, letter to J.D. Worthington, February 28, 1979. Design Verification Diablo Canyon, Audit No. 91320, Hubbard Affidavit, Appendix 0-1.

46. Hubbard Affidavit, p. 83.

47. ibid., p. 91.

48. Atomic Safety and Licensing Board, September 27, 1979, Partial Decision, p. 91, cited in Hubbard Affidavit, p. 41.

49. ibid., 39.

50. John Fogarty, NRC Approves Diablo Quake Safety Design,” San Francisco Chronicle, March 20, 1982.

51. ibid.

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