ML16341B828

Discusses NRR 820526-28 Seismic Reverification Program Insp. Major Areas Inspected:Blume Independent Internal Review of Past Blume Structural Analyses,Util Document Control Manual & Impacts of New Project Organization

ML16341B828
Person / Time
Site:	Diablo Canyon
Issue date:	07/21/1982
From:	Herring K Office of Nuclear Reactor Regulation
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML16340C726	List: ML16341B828
References
NUDOCS 8208030018
Download: ML16341B828 (14)

Text

Docket No.:

50-275 JUL 2 1 1982 f

tlEthORANDUII FOR:

Frank J. Hiraglia, Chief Licensing Branch No. 3, Division of Licensing, NRR FR%:

SUBJECT:

Kenneth S. Herring Systematic Evaluation Program Branch Division of Licensing, NRR DIABLO CANYON SEISMIC REVERIFICATION PROGRAII INSPECTIONS-IIAY 26-28, 1982 OFFICEI SURNAMEIN As part of Region V's ongoing inspection activities regarding the Diablo Canyon seismic design verification program, I conducted an unannounced inspec-tion of the ongoing PG8E efforts on Hay 26 through 28, 1982.

The purposes of this inspection were to:

o1) review available results of the PG8E initiated Blume Independent Internal Reivew (BIR) of past Blume structural analyses related to Diablo Canyon;

2) review the PGSE Document Control tIanual (DCI1) developed to control response spectra and to assure the use of appro-priate up to date response spectra for ongoing design and evaluation of structures.,

systems and components; and 3) verify that the newly formed Diablo Canyon project organization was functioning in a manner to alleviate

'eaknesses in the previous organization relative to seismic analysis and design in the civil/structural areas.

Observations and conclusions are discussed below.

Blume Independent Internal Review (BIR)

The BIR was conducted by Blume at the direction of PGSE.

The purpose of the BIR was to have a group of internal Blume personnel who had not worked on Diablo Canyon in the past conduct a review of all Hosgri structural analyses previously performed by Glume to determine their adequacy to predict the behavior of the as-built Diablo Canyon safety-related structures.

In this effort, Blume engineers reviewed the previous Hosgri structural analyses performed by Blume and generated comments regarding their adequacy.

These comments were reviewed by a Blume supervisor and passed to the BIR Advisory Committee, chaired by Dr. Blume, for review.

When all parties in this process'ere satisfied, the comments and evaluations were forwarded to PGSE.

Enclosure 1 is the procedure by which these comments are handled by PGSE to provide for their resolution.

PGBE is responsible for final resolution of items requiring further evaluation, unless such items are a subject of the Independent Design Verification Program

( IDVP) managed by Teledyne.

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~ s F. J. Ilfraglfa At the time of the inspection, the above program had not been completed.

The BIR report was still under preparation, and additional evaluations with regard to the BIR were still being conducted.

PG8E indicated that a total of 150 comments had resulted from the BIR.

PG&E was able to provide 147 of the comment packages fn various stages of resolution for my review.

The three additional BIR comments were still under prepara-tion.

Given the preliminary and incomplete nature of these comments, and associated resolutions, I conducted a cursory inspection of the 147 comments to gain an insight into the nature and depth of the BIR and associated PG&E program for comment resolution.

The comments ranged in content from relatively minor discrepancies to those which required substantial additional effort to determine their significance.

Based upon my review and discussions with PG&E, it appeared that these comments were about equally distributed in three major significance categories,

namely,

1) those insignificant by inspection,

2) those found to be insignificant or expected to be found insignfffcant after additional analysis and/or evaluation, and 3) those which were significant and required additional analysis and evaluations to determine their impacts.

From my cursory inspection of the 147 BIR comments, it appears that Blume generally performed a thorough review of its previous Diablo Canyon Hosgri structural analyses.

PG&E has implemented an organized program for BIR comment resolution which provides a necessary formal process for PG&E to supply Blume additional information and comments to allow for accuracy in the BIR determinations.

The adequacy of this entire effort can only be ascertained after review of the final BIR report,,

and PG&E's and/or Teledyne's final evaluation of the individual 'findings.

PG&E indicated that they do not plan to submit the BIR final report to the NRC.

Details will be submftted for only those items which become part of the Verfffcation Program via entry into the PG&E tracking system.

Therefore, if not submitted, an NRC review; of this report and associated PG&E comment dispositions should be conducted at the PG&E offices.

Only two potential concerns were noted fn my review of the 147 contents>and, any associated resolutions, and these were discussed-with PG&E.

The firIst

'..'oncern was that information associated with BIR corrments AB 018 and TBt.',006 fndfcated that figures in Blume reports were inaccurately labelled.

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BIR comments were dismissed essentially because the inaccuracies did,riot'ater-ially affect any analyses.

I cautioned that future ramifications of-such

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inaccuracies must be carefully considered.

The second concern uas:that

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resolutions associated with BIR comments CE 022 and IS 007 dfd not document<

the resolution of all the reviewers comments.

I indicated that they should~

ensure that resolution of all revieuer comments are clearly documented in, all final packages.

OFFICE/

SURNAME/

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Res onse S ectra Document Control flanual (DCM)

I reviewed PG&E DCH Ho. 17, Revision 0, dated 04/19/82.

This contained all the Hosgri response spectra to be used for design and evaluation of safety-related structures, systems and components.

As a controlled document, re-visions to spectra are cfrculated to the appropriate PG&E supervisory personnel responsible for the analysis of the various structures, systems and components, arid requires their signature to indicate that they have noted the revisions.,

In addition to containing the spectra, this DCH summarizes the way fn which they are to be used.

If spectra are not available at the point of attachment of a particular structure, system or component being designed or evaluated, the DCM requires that the Civil Engineering group specffy the spectra, consid-ering fntermedfate member or structure flexibility, as appropriate.

This DCN should avoid future problems with keeping track of the up to date response spectra and alleviate previous problems in this area.

However, I indicated that neither this DC)i nor the associated Engineering flanual Procedure No. 3.2 clearly indicated a requirement that the appropriate supervisory personnel insure that the impact of spectra changes is assessed for existing safety-related structures, systems and components.

PG&E indicated that functionally this was performed by the appropriate supervisors fn the fashion they felt was required.

Given 1) the large number of response

spectra,

2) the large number of items which would be potentf'ally impacted by changes in spectra, and 3) the potential for changes fn these spectra as a result of the current reverification effort, I indicated that it would be prudent to have a clear requirement fn the procedures to assess the effects of spectra changes; In addition, I indicated that it may be prudent to have a formal procedure for each supervisor to follow.

PG&E indicated that they felt that the former concern would most appropriately be addressed by a revision to'Engineering Manual Procedure No. 3.2.

Also, they indicated that they would carefully consider the need For implementation of my latter commment fn light of,.ali eady established procedures and practices.

Impacts of the New Diablo Canyon Project Organization As indicated fn the previous discussions, the newly formed project organization of PG&E and Bechtel personnel has taken positive steps to correct defic'fencfes fn previous practices, especially fn the area of controlling dfsciplfnj ijter-faces.

In addition, PG&E indicated that the desfgn and drafting personnel',,'I~hfch are responsbile for much of the civil/structural related design and evaluqgon are now reporting directly to the Assistant Project Engineer (APE) for Sef(fhfc Analysis and his associated supervisors.

This was done to eliminate a poteiptfal for communication errors resulting from these personnel being fn a separatet,

internal organization, as was the case previously.

PG&E also indicated thy'rocedures were still being established and revised as appropriate to prov(cfe for design control.

OFFICES SURNAMEQ DATE P

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0 F. 0. Hiraglia Informal discussions regarding the above severe conducted among the individuals listed in Enclosure 2-After discussions with Region Y, a formal exit inter-view was conducted among the individuals listed in Enclosure 3.

Original Signed Byt

Enclosures:

As stated cc w/enclosures:

See next page Kenneth S. Herring Systematic Evaluation Program Branch Division of Licensing Distribution:

Document Control 50-275 PRC System LB¹3 File FHi rag 1 i a

, HSchierling KHerring JLee JKnight PTKuo HPolk RBosnak MHartzman HSchierling RMorri 1 1 TBishop JFair BJones LChandler WHaass OFFICEI SURNAME/

DATE0 DL: LB¹

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thr. lhalcolm H. Furbush

' cc:

Resident Inspector/Diablo Canyon NPS c/o U. S. Nuclear Regulatory Commission P. 0. Box 369 Avila Beach, California 93424 lls. Raye Flemin9 1920 I'attic Road Shell beach, California 93440 Joel

Reynolds, Esq.

John R. Phillips, Esq.

Center for Law in the Public Interest 10951 Vest Pico Boulevard Thira Floor Los Angeles, California 90064 Paul C. Valentine, Esq.

321 Lytton avenue

'Palo Alto, California 94302 Nr. byron S. Georgiov Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814 Herbert H. Brown, Esq.

'ill, Christopher 6 Phillips, P.C.

1900 h Street, N.l".

'~'ashington, D.C.

20U36 i>r. Dick Blankenburg, Editor 5 Co-Publisher South County Publishing Corapany P. 0. box 460 arroyo Grande, Cal i forni a 9342U t1r. Jam s 0. Schuyler Vice President

- Nuclear Generation Department Pacific has 5 Electric Company P.O.

box 7442 San Francisco, California 94120 bruce Norton, Esq.

Suite 202 3216 North 3rd Street Phoenix, Arizona 85012

Hr. Halcolm H. Furbush Vice President - General Counsel Pacific Gas I Electric Ctxnpany P;0.

Box 7442

,San Francisco, California 94120 I

C DIABLO CAWYON CC:

Philip A. Crane, Jr.,

Esq.

Pacific Gas fi Dectric Company P.O.

Box 7442 San Francisco, California 94120 Janice E. Kerr, Esq.

California Public Utilities Commission 350 N=Allister Street San Francisco, California 94 102 l)r. Frederick Eissler',

President Scenic Shoreline Preservation Conference, inc.

4623 t~iore tlesa Drive Santa Barbara, California 93105 Hs. Elizabeth Apfelberg 1415 Co za dero San Luis Obi spo, California 93401 ttr. Gordon A. Silver t ls. Sandra A. Silver 1760 Alisal Street San Luis Obispo, California 93401 Harry N. h'illis, Esq.

Seymour S Willis 601 California Street, Suite 2100 San Franci sco, Cali fornia 94108 Nr. Richard Hubbard HHS Tech~ical Associates Suite K

1723 Hamilton Avenue San Jose, California 95125 llr. John tlarrs, hanaging Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P. 0.

Box 112 San Luis Obispo, California 93406

Mr. Malcolm H. Furbush Mr. W. C. Gangloff Westinghouse Electric Corporation P. 0. Box 355 Pittsburgh, Pennsylvania 15230 David F. Fleischaker, Esq.

P. 0. Box 1178 Oklahoma City, Oklahoma 73101 Arthur C. Gehr, Esq.

Snell 5 Wilmer 3100 Valley Center

Phoenix, Arizona 85073 Mr. Owen H. Davis, Director Federal Agency Relations Pacific Gas and Electric Company 1050 17th Street, N.W.

Suite 1180 Washington, D.c.

20036

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