ML16340C287

Ack Receipt of Re Recently Detected Seismic Design Errors at Facility.Design Verification Program Must Be Reviewed Satisfactorily Prior to Fuel Loading

ML16340C287
Person / Time
Site:	Diablo Canyon
Issue date:	02/01/1982
From:	Palladino N NRC COMMISSION (OCM)
To:	Dingell J HOUSE OF REP., ENERGY & COMMERCE
Shared Package
ML16340C288	List: ML16340C287 ML20040E369 ML20132A590
References
ISSUANCES-OL, NUDOCS 8202040233
Download: ML16340C287 (20)

Text

DESIGNATED ORIGINI Certl+'fed By UNITED STATFS NUCLEAR RcGULATORY COMMISSION WASHING i QN, D. C 20~c~

p CHAIRMAN February 1,

1982 The Honoiable John D. Dingell, Chairman Co

...i o on Energy and Cori'ce United States House, of Representatives Washington, D.C.

20515

Dear Mr. Chairman:

Me share the con'ce'ms expressed ln your November 13, 1981 le.ter regarding the implication oi the recent selsiillc design errors dei c ed at the Diablo Canyon nuclear power plant.

The imolication of.these errors has been and will be though fully considered by the Corimission.

The timing of the detoction of these errors, so soon after authorization for lcw-.power oper'ation, was inde d unfortuna e and it is quite understandable that the Congress'nd the public's perception of our lic nsing process has been adversely aifected..

Had this information been known to us on or prior to September 22; 1981,,I am sure'that the acility license would not have be n issued until the questions raised by these disclosures had been resolved.

Because of these design errors, on Hov'=-mbel

.19, 1981 we suspended Paci-,iic Gas and Electric Company'

(.PCRE)

Iicense pending satisfactory completion of tho following:

I ne'o:i sa i etv<<

Sel 5Iii a C

-saTeTv-duct of a

-re ta ed r 1a ed s

n inde"endent d

s',cn r=:iew prooram cf Il ctivi".ies oerformed priicr to June 1, l978 unc=r a

service con racts used in tne C sion of t.uc ures, sys-ms and cc-;:,ponents.

2.

co

~ ~ ~ I cal ri ol"5 re c, that fu11v ass fo nd anC -heir impact on 5>es n

b ic c" u oi facili.y design.

aI I

-.hie t"=='E' c

proc ram 4.

A sch du are r "u cnclusions of the 'ef eci.ive iess of the design veriiica-icn in assuring ihe acecuacy of facility Qeslcn.

le -.or ccmplgting any modifications to the faciliity tha.

ired as a result 0

h design veriiication pxogram.

in acci ticn, a p rove I ',

the Cc;.-iiss ion. order=d I v-Ca - i.o p. ovide.~r>>RC revie>>'nd.

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~ iJr wcu1 I pore-.e cuali ii i 'ca-ions of

. he I opose 70 caI ry out

independent design verification program, including information that demonstrates the independence of these copipanies.

2.

A detailed program plan for conducting the design verification program.

/

In recognition o

':he need to assure the credibility 'of the design

'verification program, NRC will decide on the acceptability of the

'ompanie's'roposed by PGaE to conduct this program after providing the Governor of California and Joint Intervenors in the pending operating licensing proceeding 15 days for comment.

Also, the NRC will decide on the acceptability of the plan proposed by PG5E to conduct the program, after providing the Governor of California and the Joint. Intervenors in the pending operating license proceeding 15 days for comment.

Prior to authorization to proce d with fuel loading, the NRC must be satisfi d with the results of the seismic design verification program and with any plant modification resulting from that program that may be

. necessary prior to fuel loading.

The NRC may impose additional requirements prior to fuel loading necessary to protect health and

- safety based upon.-its..review of..the program or any.of..the information provided by PGKE.

This may'nclude some or all of the reauirements specified in the letter to PG&

dated November 19,:1981.

Responses to each of the four questions in your le.ter are enclosed.

A decision to permit PGaE to proceed with fuel loading will not be made until all th'e actions contained in the Commiission's November 19, 1981 Order are fully satisfied.

Sine rely, Nunzio J. Pallaaino cc:

Re".

Ca. los i'ioorhead

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Co,

• iission Order, dated ll/19/81 R "-.'litton, RRC -'o

?GR= dated 11/!9/8'i de.4~

3. Res-"nses to questions LL/eo o.Ji.<'

t T

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p GNATED ORIGINAL Certiflel BF Question 2:

Please provide t'e criteria to be used in assuring that tiie proposed audit will be "independen Resoonse:

The competence of the individuals or s is the. most important. factor in the selection of an auditor.

so, Ol 1A 1vi ua d

d 1 s rlay not have had any irect s at olvement with the activiiie pl evious 1AYO reviewino.

Diablo Canyon that they will be re

'd t "he following factors. wi be considered in evaluating the question of independence:

'1)

Whether the individuals or companies involved had been previously hired by PG&E to do similar seismic design work.

2)

Whether any individual involved had been

~

previously employed by PG&E (and the nature of the employment).

J 3) e Mh ther the individual owns or con~rois k.

SigAli1can).

'f c-n amounts of PG&E stoc Mhether m mbers of the

present, household of individuals involved are employed'y PG&E..

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Mhether any relatives are empl loved b

PG&E in a

manaoement ca'pacity.

d'"

he above considera.ion the

'n ad i ion o

following procedural ouidelines

'to assure independence:

d'"-ble.record will be provided of all co-m nts on draft or vina p

hanges made as a result of such s

Tol such collP=~

s) 2Ad t.he reasons chanoes; or onlv 2 7inal J polt

{w ttlou'llor licenseo commen i 2)

NRC will assurl 2nd exercise ih~ respon sibility for serving the repor.

on.all parties.

b~~ l.

Q(( v~

DESIGNATED ORIGINAL Certi+9eci By MEETING HITE PACIFIC GAS AND EIECTRIC, COMPANY TO-DISCUSS SEZSPZC DESIGN REVZZN~ DIABLO CANYON UNIT 1

. Haxc11 25'9.82 PAGZZ: 1 thru 177 Be ~hesQa, Maryland 4LZCP~MX, REPÃG'L'iYi 4QQ 7'= "- z eve 5 + 8

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6 ilxPAQLXA:

One item tnat came up was an e:~ressio>

oz clear indication of what the staff requirements are

="or "he zbn~3act-o-='.iaaf'~re'sL s~L~e~enrs

. ~I think the stafz wou'd be receptive to each of the program plans cescribing the procedures

~

l and process that you oroposed to use relet've to these conflict 4<<

'IO of interest statements and the criteria which you ~ould use to have an individual fill them out, the kind of =ecords that you would propose to maintain and implement that requ'rement and if the-procedures are explicit'nough and acceptable to the stazf.

Ve understand that -you have a process and that you have criteria by which you are going to implement that process.

.12

..;COOPER:

That one gives me a lot of dif=iculty.

13 Individual companies choose to handle that by different techniqu~

That has to be demonstrated to date in this prograa, and I think 15 16 17 it's possible we might get.these techniques

together, but it's ar administrative type oz commiss'ion requirement, and until I have more guidance in -- than I have seen put forward at this. time-an~

18 19 20

'22 noticing that there are d'erences in the way we handle the thing, our response to what we understand to be the requests, I would have great difziculty responding to that at least in the kind of time frames we are t'alking about for the plan suomittal.'

would rather -- perhaps we could eventually include 24 it as one of the things that.X have called project procedures program procedures, but I certa'nly wouldn't want to commit to 25 I this for next 'week, and I might have trouble even after that.

ALDERSON REPORTING COMPANY. INC.

163 f

2 3

I I just -- maybe some who have been involved in this issue longer than I have a thought on it.

Bob?

ll1 AI IC II)

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6 7

CLOUD:

Yeah.

Having enjoyed the benefits of participating in this program for some period of time, my firsts question is would you want such procedures to be addressed to all individuals that might be involved?

HR. HTRAGLIA:

I think what we are saying is that we tA

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'ould leave it to yuu'-"Aeo ptoooaIf th~critezie-:. b~whmh-..you-.wou~+

us-e;

-wha>

'=Md='vi'dual shou-wou'~Fd"-.- ~den~z

..Q~D,cs.~ha

.Criterra-~~

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)fW~4J anon.

-e=fthat "you'-'wiQ..--'elop ~ceduxes-,ter--imoUmenCRKi.:s Aw~'~Itff',.A."'w

. fef'&wwf F:ird 0'f~w-'orogxaml and. thaI poll:wheal 'CBcs1I&181~ soTGe zijld~of'2u 3.G~

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24 have the -- you know -- the son-n-law oz any of the PG&Z people on my stazf.

I am just saying as a matter of practice that t's going too za that each pro.essional not o ~ stock n PCS"., for example.

It's sort of -- to quote an eminent membe" oz the NPC s tazf, i" wou d be contrary to the Americar way.

>E.

COOPED>.: '- Let'e cite an exar.".pie.

I showed a

Figure 1 and 2 todav.

I had scrifobled those out anc I went to YR.

CLOUD:

I wouldn't have any objection to that except that I would propose that such orocedu"."es should be conzined to the management offices involved with the program.

Just as a matter of practice.

Don't misunderstand me.

I don' 25 P,on rvrav a..d I said, Vr y, you got somebody -- Ron, can you get

F'

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somebody that can letter t..ese up fo=

t:e: n a iurry and get thg in this report?

He said yeah, and one o-ou= co-op students and about ten minutes after tney we=e given to me, the QA engineer in the program came 'n and sa."d I m "oing to c te you t

lA for not having those guys cleared through pe"sonnel depa".twent before he did it, and I said, Gee whiz, don' I even have two d,

to get that guy to rill out the thing?

I got in this bind and nad Ron do it ive minutes ago.

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10 12 13

-14 He said, Okay.

I'l give you two cays..I said, Fini He will have gone back to school in two days.

= (Laughtei) 1%,., COOPER......-This's how -ridicule.ous it is'eally getting as we are trying to do this thing through what we are cotcnitted to today, and guidance -- Pa'ai%-ce

=""Yiidance-.i~~need'5 NR.

HOCH:

Can I ask you a question?

I don't know 16 if I reviewed all these things.

H'ave you found any of your ae

.empl'oyees who have a conflict yet?

18 19 HR.

COOPER:,

No.

NR.

CLOUD:

No.

20 21 something-at-iw-ll""Se'1j;-

KR.

COOPER:

Excuse me.

The ans.-er would have been 23:

ves only -we-knew better than, to ask him to fillout the form 24, because he worked on Diablo Canyon.

Now PR.

DENISON:

The answer is yes in one instance.

ALDERSON REPORTING COMPANY, IN(.

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father o.~s sixty-three shar'es of stock.

BPOL&l:

I don't think anyone is satisfied with the 3

ult mate esolution of -- the governor, the joint intervenors

~ we all would h-ve iked it differently, but T. think the staff better oe cautious in not getting into a position and backing 6

I down jus t because somebody suggests that it might not be I conven'ent.

The bottom line was that there were pretty 10 thoroughly understood guidelines.

Nobody liked exactly what they were because thev came out of different stufz, but I think it would be proven and we would insist from a literal reading of what the commission-did;--t e...hay.~

12, 13 conf~et,=of=.i~t:eres iso-dezMed~b~the,-cogm=:s s ion sent to the worHpev. Ey-the ChararsIaw: -":~on't recall the subseqoent 15 16 1

17 I

ectens=ve conversation that went on, and'his ended in two days of inconvenience.

That is something that we have to live with or we w ll end uo quibbling over something that we should have long ben nd us.

18 19

.20,'OLLtWR:

T. think those guidelines were "airly clear E don' think they caused the problem.

l: think the pro'ole-... being posed was one share of PG&:" or a hundred sha"es is 21 a confl't of inte"est or thing's oz that-na"u e.

. Es that right?

22 23:

i hooe that the e is no quest on in anybody's mind that oeople who a"e part of this progra~

shop,~d-not..ge.-."e~r.:ey-'ag

--c"~ tha" I

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25

,I they-~e=e.-a~var~g--.tq-Q, zo.re;,andztha~hasDega

@~de.c ear a

T. hooe that is not the proclem.

along.

0 1"

FM.

FR I:<<ND:

Doesn'0 seem ~ have anything to do wit>

I stock ownersnip wnatsoever.

KR. VOUMR:'o. but ~mt ~as another matter tnat g~s brouant up in a numer of ctner meeMgs to which you ~men't a party i

5 b

7 MR. FRI "M3:

But the wnole a'alogue has been about II some different rules.

I:think~tMt.. is-~robaalf.wKy=.iWs=.-.:=

owning stock and inancial interests, and you just enunciated important".tna~"'"-'ouo give,.us some cuicance.

i~gybe both-.of thes W*

app y.

Maybe only one.

10 MR. MIRAGLIA:

Bo,theof.them<do..apply-'as~tms cur en tip""m.itten'. v=--n e:.will-.,do<;tha t.

-12

-- -- MR. CLOUD:

I.would.say.- that, the issue of persons 13

(

15 lb 17 18 reviewing work that they nave par ic'pated in 's a non-issue.

one ever aoes that.

What I'm suggesting ana perh-ps we are, going overboard when we require that every person involved in the project not own stock, not have a re3:ative in PGBZ, et cetera.

I mean half the people in the Bay area worked for PG&E at one time or have relatives that worked or them or whatever.

19.

20 21 22 23; I

MR. HOCE:

As an alternative to I'm a little.unclea If we didn't take advantage of what you stated or the program people didn '

take advantage of what you stated w'h respect to putting a procedure together and stating wnat the procedure

was, in the'ear term at least, is* it acceptable o just continue wiQ the policy of having everyone ao wnat they'e been doing2 Pilat 25 t is, s.ign the statement and so I

forth?

ALDERSON REPORTING COtv1PANY. 1NC.

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a 167 1IV NT.RAGLIA:

Yes.

HOC<:

Because in the short. term that may be the mos-expedient way to handle it-I HI%-".GLIA:

Yes-b COOPER:

Iz we can agree on tnat, I vill try to put together a program procedure as defined in our program plan I;

It '

tne

.i lplementa,t'n oz: the criter 'a I am concerned

about, and I vill trv to put together such, but I. won.'t,.implement it prior to send'ng it in for your comments because it is in resoonse to a direct, proceaural issue that you folks have raised::

~

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Ordinarily I would plan to implement

a. procedure.and.send it to 12 I

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1 13 14 15 I

lb 17 you for in=.ormation.

NR.

CLOUD: I think we could right now with cd-lete and zull assurance know that no engineers will be involved in revievhng work that they have aone.

i<iR. COOPER:

That is true.

'lR.

CLOUD:

So -- and I would suggest that sooner or 1 ~

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.'3 later people will have to accept the zact tnat most of the 1

oeople doing this are honest men.

~~LE.

~1IBAGLIA:

The"e was some comments ra'sea by.tne pa ties, and I think we sa'd vith. respect to undocketed. reports tha-we a=e s-'ll -- there is still a question tha" the staff had on February 3rd ana that PG&E is attemoting to deal with.

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25 Again, I g"ess some ceg ee as the approor'a e plan is to adaress tha" matter to well.

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