IA-84-515, Discusses Design Verification Program & Potential for Programmatic Deficiencies,Discussed During 821020 Commission Meeting.Expanded Program Will Determine If QA Deficiencies Identified in Design Activities Also Exist for Const

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Discusses Design Verification Program & Potential for Programmatic Deficiencies,Discussed During 821020 Commission Meeting.Expanded Program Will Determine If QA Deficiencies Identified in Design Activities Also Exist for Const
ML20197F847
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/09/1982
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20197D852 List:
References
FOIA-84-515, FOIA-84-516 NUDOCS 8211220429
Download: ML20197F847 (8)
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56ocument Control 50-275 PRC System LB#3 File LRubenstein HDenton WJohnston NOV 9 RVollmer LChandler, OELD 1982 RMattson FMiraglia DEisenhut GKnighton JKnight HSchierling hEh0RA'40er; FOR: Robert H. Engelken, Renional Adainistrator JLee Region V FROM: Harold R. Denton, Director Office of ttuclear Reactor Regulation SUPJECT: DIA9LO CANYON DESIGN VERIFICATION PROGRAt1 During the Comission raeeting on October 20, 1982 regarding the Diablo Canynn design verification progran the potential for prograixaatic deficiencies in the PG!.E design process was discussed, anonq other issues. The dialogue seemed to indicate that NRR and Region V have different view points on this issue (see page 92 through 98 of the transcript). I do not believe that we differ in our views, however some clarification should be helpful.

Your nemorandun to re of Septenber 15, 1982 addresses the potential need for expanding the scope of the prograra because of the above issue. I believe that the expanded progran for Phase I and Phase II, as proposed by the staff in SECY 82-414 and as sumarized in Figure 3 of the paper, is responsive to your concerns and will assure that any broad prograrvaatic ctJP iciencies in the design progran of PG3E and its contractors will be identified. In particular, 4 the expansion of the prograta will deterraine if the QA deficiencies thus far identified in design activities also exist for construction activities.

If you have any comments on this matter please advise NRR promptly.

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Harold R. Denton, Director lOfficeofNuclearReactorRegu i

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&c. b b u 3.o g M 2- h 1 that if what you recommend is done that Pha se II will be

- 2 done adequitely?

3 MR. DENTON: I guess I don 't know where you 4 are going wi th this.

5 C3M5I55I3NER AHEARNE: I am trying to focus en 6 this vord " approval."

7 ER. DENTON: I mean by that NRC Commission a

8 approval and I just Wanted to fla; that we have not 9 approved the Phasa II program and we avalting your

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10 approval of a progras.

11 COM5I55IONIO AHEARNE. But you it:

12 reconsending that the Phase II program which you have ec- -13 described be approved.

14 33. DENTON: Yes, sir.

f 15 "C5YISSIONER 2.HEAENE: Jean there at the 16 bottos you have " implicit questicas vi-- ; e s'p e c t to ,

17 ov e rall Q A ." What does that mean? .

18 EE. EISENHUT: 'Let se t 7 to explain that.

f 19 Ihere has not been any specific ites tha vculd point to 20 con struction , but there have been questions concerning 21 the overall CA 112 3a07 The number of problems that i

22 have been f ound fros Phase I and the number of problems 23 f rom Phase II hiva cut across sany,.ssay aspects. ,It is 24 indicative c'f a general breakdown in OA and that is all 25 I meant here by th e "is plicit." The obvious question I

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2 plant and the utility saw it the saae vay, you know, and 3 voluntecrai this program.

4 32. DE5 DON: Bob had taken a real interest in 5 this aspect and saybe he would like to talk about it.

6 is a result of discussions, the cocpany expanded the 7 program.

53. EN CELK EN : With respect to the QA for 8

9 construction?

10 [- MR. DIN TON : Yes.

11 33. EN G2 LK E.4 : We relt t ha t in ll4!it Of thC 12 Reedy Report and in light of our findings vhea ve co-- 13 initially did some inspection vork out in the region re 14 following the discovery of the error in tha use of'the 15 diag ram, ve fcund that there vere discrepancies in the _

16 O A progran._ What gave us concern I think was an < .

17 apparent lack of top sanagenent involve =ent in the 18 1:plesentation of Q A at least in certain areas.

19 . .This did cast some sort of a shadow over the 20 general area of C A, quality ass'urance, and this had been 21 as issue raised by the intervenors. It had been raised 22 ,b? the intervenors in hearing or prior to the hearing 23 and it was denied as a contention, as I recall it, but l

24 it was a lingaring concarn with them. l l

25 I thought that I didn't want to be in a l l

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  1. ~ 1 position, since ve had been inspecting that plant 2 through its construction , o f def endin; the QA for 3 construction. I though t it was appropriate for part o_f 4 the reverification prograa to cover quality assurance 5 f or construction even though our inspection progras had 6 indicated that the construction OA p rog ram was an 7 adequate program and was at least average and perhaps e

8 better than average than th e progras that we had seen 9 for construction at other facilities. But we did feel 10 that it vould be a further reassuranc_a that there vers 11 no serious construction errors built into the plant.

12 CO MM ISSIO N ER AHEARNE: So that your oc_ 13 re ossendation though, which as I recall was sometime 14 around May, was not based upon kncan but unwritten 15 conclusions that Region 7 inspectors had reached?

16 52. ENGELKEN : That is corre::. It was just 17 further assurance which we felt was apprcpriate. The 18 reco :endation, incidentally, was made to M r. Denten by 19 e in a sesorandca dated March the 29th. That letter 20 subsequently be:ana public and was picked up by other 21 parties and given some esphasis.

22 205%ISSIONER AHEARNE: On Septecher 15th o f 23 this year Ycu wrote a letter to Harold and you made a 24 romment in it. Iou say that "We offer the following 25 consents and quest. ions." No. 3, and this is from l

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95 y 1 Enclosure 6, but in No. 3, you asked the question 2 "Should the scope of the Phase II progras plan be 3 re-examined?"

4 You go :n to say that th e Reedy findings, S "Iheir combination with the licens ee audit findincs 6 suggests th e possibility of broad programmatic 7 deficiencias in the licensee's design progran and__

  • 8 certain of their contractors. Based on this, it may be 9 appropriate to re-exa:ine the scope of the initial to. verification sa:ple defined in Phase II."f

.11 Could you expand on that a little hit and 12 th en , Harold, could you cossent on, you had just

  • 13 previously said you felt that what you have proposed is

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p 14 correct and whether it seets 2ob 's concerns.

15 Bob, rould you expand on that?

16 1R. ENCELKIN: I thin k that we are principallf 17 talking in terns of the numbers of contractors that 18 vould be sampled with respect to C A audits and we simply 19 s a d e the sughestion that perhaps this should be 20 considered in evaluating'the Phase II progran plan. I 21 think that we made the su;;e stien to NRR and Mr. Denton 22 f :t their consideration and I think perhaps for the 23 con sideration of the ID7? if %:. Denton agreed that it 24 was something that they should ronsidar.

25 0053ISSIONE3 AMEARNE: So you are saying that l

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95 1 rou vere primarily icoling at expanding to check more 2 contractors?

3 MR. ENGELKEN: I think tha t was my 4 understandin;.

5 C0EMISSIONE3 AHEAENE: ,Sut your coosent also 6 h as "the possibiliev mf hen'd crocrammatic deficiencies 7 in the design progras."

a 8 MR. ENGELKEN: Well, tha t wa s another 9 consideration. Ies, the var the audits were conducted,

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10 if there was no for:al QA p rogras, then the Reedy 11 organization did no further review of the Q A program ,

12 but reviewed the practices that vere actually, applied.

ee- 13 I think the succestion here is that without further 14 revievias the formal QA program, then all of the known 15 deficiencias nar not be detected.

  • 16 I also think that we had sonevhat of a Legal 17 problem vich the wording in th e le,tter which suqqested 18 that all contractors would be reviewed and the proposal 19 by Reedy was to just reviev certain enes. I don't think 20 that we hai any real technical prob'lec there. It was 21 scre a proble,m cf whether it set the verding of the 22 letter.

23 53. DENTON: 'Je sent Bob's letter and 24 identified the concern to Teledyne and it is one of 25 these details ve propose to straighten out in their r

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97 1 prograa. Their progra: can expand and we haven't quite t' 2 srcal;htened that one out.

I 3 COMMISSIONER AHEARNE: Just a minute ago I 4 asked you with respect to approval on whether or not the

, 5 Phase II program that was here is what you vere 6 proposing we approve, and I thought you said yes._ Nov .

7 Bob has said that he didn't think the P hase II program

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8 was adequate in two regards. So nov I am not sure 9 vhether it is up to Taledyne to decide whethat or not

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10 ER. DENTON: No, it is not up to Teledyne. I

.11 just wanted their opinion. It is an issu' that remains 12 to be fully developed. 7e don't have a difference. Bob

  • C" 13 concurred in what we were recommending. All these 14 prograss tend to be a little bit open-ended and this is e

15 One ve vill have to straigh ten out a bit.

16 00M3ISSIONER AHEA3NE. Let ne go bark to '3cb -

17 then. I read this letter of yours saying that you felt 18 that you veren't ready to concur in Phase II.

19 X H". EN CELK EN : I didn't consider it in those 20 terms. We vere asked for commen'ts on the proposed 21 plan. These were some of our consente and it was for 22 ronsideration by 53E ind if they a; reed with us, and I 23 as not sure whether they agree with us or not at this 24 point.

25 Ihen I think it was something for them to

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But I don't it was written in the 2 spirit of nonconcurrence with the proposal.

3 COMMISSION ER GILINSKY : Just trying to be 4 helpful.

5 3R. ENGELK EN : Right.

6 ER. DENION: On page 8 of our slides we have r

7 pointed out that the program ve are recommending tha t

, 8 you approva includes certain things and it includes

,9 additional sampling vepification if required. 'Je are to taking a sna:: shot today and Bob and I will no do u'u .

11 solve this one before va get back to you. It is just 12 ene that ve have not been able to get enough infor:ation t' - 13 o n . But taa fa:t that the pr ;ran in:ludes O A ;and it s

14 in:1udes additional s.apling, as 3cb succested, if we 15 decide it is required. 'J e just haven't had a chance to 16 straighten cut all the datails. .

17 COMMISSIONER GILINSKY: Ca n I a sk you, wh'en 18 this is all dona are you going to turn out =. s.afety 19 evaluation?

20 33. DINTON: Yes, sir.

21 COE,!SSIO NIR GILINSKY : And that is what you 22 are going to submit to us, as SER which would for: the 23 basis of a decisi:nV 24 33. DESION U Ye8-25 COMMISSIONER GILINSKYs Or we hope in four CEASON AEPCAUNG COMPANY,INC. ,

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