ML17083A973

Outlines Addl Info Required Under Oath for NRC Review & Consideration Prior to Issuance of OL Above 5% Power.Areas Include Nonseismic Svc Contracts,Internal Design Activities & Program Plan for Design Verification Program

ML17083A973
Person / Time
Site:	Diablo Canyon
Issue date:	11/19/1981
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Furbush M PACIFIC GAS & ELECTRIC CO.
References
NUDOCS 8112230598
Download: ML17083A973 (30)

Text

November 19, 1981 Docket No. 50-275 Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas

& Electric Company P. 0.

Box 7442 San Francisco, Cali fornia 94120

SUBJECT:

DIABLO CANYON UNIT 1 - INDEPENDENT DESIGN VERIFICATION PROGRAMS The Commission's Memorandum and Order (CLI-81-30) dated November 19, 1981 suspends your license to load fuel and operate Diablo Canyon Unit 1 at power levels up to M of full power, and specifies the programs that must be satisfactorily completed before license suspension will be lifted.

Also, based upon recent HRC inspections conducted at PG&E and the Blume Offices in San Francisco, the NRC staff has identified a number of serious guality Assurance

((}A) program weaknesses related both to the errors in the Unit 1 seismic design and to the-implementation by PG&E of applicable cri.teria of Appendix B of 10 CFR Part'0.

He have preliminarily concluded that:

a.

the PG&E gA Program did not appear to effectively exercise control over the review and approval of design information passed to and received from Blume.

b.

the PG&E gA Program did not appear to adequately control the i di stribution of design information from Blume within affected internal PG&E design groups, and c.

The PG&E gA Program did not appear to define and implement adequate quality assurance procedures and controls over other service-related, contracts particularly in the pre-June 1978 time period.

Accordingly, you are required to provide the following additional informa-tion, under oath or affirmation, for 'NRC review and consideration prior to issuance of any operating license authorizing operation of Diablo Canyon Unit 1 above 5% power:

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For All Hon-Seismic Service - Related Contracts Prior to June 1978 (a)

The results of an independent design verification program of all safety-related activities performed prior to June 1,

1978 under all non-seismic service contracts utilized in the design process for safety-related structures, systems and components.

Information concerning this program should address quality assurance procedures, controls and practices concerning the development,

accuracy, transmittal, and use of all safety-related information both within PGSE and within each contractor's organization, as well as the transmittal of information between PGSE and each contractor.

It should also include performance of a suitable number of sample calculations related to each contract to verify the adequacy and accuracy of the design process for affected safety-related structures, systems and components.

The information to be provided concerning this design verification program should be based on and include the results of conducting the program elements set forth in Enclosure A.

(b)

(c)

(d)

A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of design errors found, their impact on facility design.

PGSE's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility design.

A schedule for completing any modifications to the facility that are required as a result of this program.

For modifications that you propose not completing prior to operations above 5% power, the bases for proceeding should be provided.

2.

For PGSE Internal Design Activities (a) cerning this desi n verification ro ram h

f The results of an independent design verification program of PG&E internal design activities performed on Diablo Canyon Unit 1 related to the development of the design of a suitable sample of safety-related structures, systems or components.

The extent of the information provided related to this program should be that which is necessary to determine whether the overall PGSE quality assurance procedures and controls de<<

scribed in its gA I1anual and associated procedures since

1970, have been fully and effectively implemented.

This information should also include a suitable number of sample calculations to verify the adequacy and accuracy of the PGSE internal design activities for the sample of safety-related structures,

systems, or components.

The information to be provided con-l p

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(b)

(c)

(d)

A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of design errors found, and their impact on facility design.

PGSE's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility desi gn.

A schedule for completing any modifications to the facility that are required as a result of this program.

For modifications that you propose not completing prior to operations above 5% power, the bases for proceeding should be provided.

3.

For All Service-Related Contracts Post-January 1,

1978 (a)

(b)

(c)

(d)

The results of an independent design verification program of a suitable sample of the activities performed on Diablo Canyon Unit 1 by each service-related contractor that were completed subsequent to January 1,

1978 related to the development of the design of safety-related structures, systems and components.

The extent of the information provided related to this program should be that which is necessary to determine whether the overall contractor and PGSE quality assurance procedures and controls that were in effect during this time period were fully and effectively implemented.

This information should also include a suitable number of sample calculations to verify the adequacy and accuracy of the sample contractor and PGSE design activities for safety-related structures, systems and components.

The information to be provided concerning this design verification program should be based on and include the results of conducting the program elements set forth in Enclosure C.

A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of design errors found, and their impact on facility design.

PGSE's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility design.

A schedule for completing any modifications to the facility that are required as a result of this program.

For modifications that you propose not completing prior to operations above 5% power, the bases for proceeding should be provided.

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In addition to the above, we require that you provide the following in-formation for NRC review and approval as soon as practicable.

4.

(}ualifications of Com anies Pro osed to Conduct Inde endent Reviews A description and discussion of the corporate qualifications of the company or companies that PG&E would propose to carry out the various independent design verification programs discussed in 1 through 3 above, including information that demonstrates the independence of these companies.

NRC will make its decision on these proposed companies after providing the Governor of California and Joint Intervenor s in the pending operating license proceeding 15 days for comment.

As soon as practicable following NRC approval of the company or companies to conduct the various independent design verification programs, you should also provide the following information for NRC review and approval.

5.

Program Plan For the Design Verification Programs A detailed program plan for conducting the various design verification programs discussed in 1 through 3 above.

The information provided should include the bases for the criteria proposed to be used for selection of a suitable number and type of sample calculations to be performed under these pro-grams and the bases for the criteria proposed to be used for expanding the sample size based upon the results of the initial samples.

In addition, the criteria for selecting the sample safety related structures, systems and components and sample contractor activities in the design verification pro-grams under 2 and 3 above should be provided.

tlRC will make its decision on the acceptability of the program plan after providing the Goveenor of California and Joint Intervenors in the pending operating license proceeding 15 days for comment.

To keep the NRC currently informed regarding your progress on the items discussed in 1 through 3 above, you are required to provide semi-monthly status reports on the ongoing reanalysis efforts and design verification programs being conducted by and for PG&E.

These status reports should be submitted on the second and fourth Friday of each month to the Regional Administrator, Region V and the Director, Office of Nuclear Reactor Regulation.

Should these reports or any other information that becomes available to the NRC indicate that the NRC requirements described in this letter should be expanded or supplemented, PG&E will be promptly informed.

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In the interest of efficient evaluation of your submittals, vie request that you submit as soon as practicable a response to the request for additional information that Was enclosed in the Staff's meeting Summary dated October 19,

1981, on the October 14-16 meetings v(ith PG8E.

Sincerely, 0FItmpg-tlarold R. Danie, Director Office of Nuclear Reactor Regulation

Enclosures:

As stated cc:

See Next Page OFFICEI SURNAME/

NRR/DL FMiraalia;p NRR/DL RTedesco NRR/DL/D DEisenhut NRR/DD ECase NRR/D HDenton oAvE P 7 1.(.

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Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas 5 Electric Company P.O.

Box 7442 San Francisco, California 94120 DIABLO CANYON CC:

Philip A. Crane, Jr.,

Esq.

Pacific Gas 8 Electric Company P.O.

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

California Public Utilities Commission 350 McAllister Street San Francisco, California 94102 Mr.. Frederick Eissler, President Sc'enic Shoreline Preservation Conference, Inc.

4623 Nore Mesa Drive Santa Barbara, California 93105 Ms. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, California 93401 Mr. Gordon A. Silver Ns.

Sandra A. Silver 1760 Alisal Street San Luis Obispo, California 93401 Harry N. Willis, Esq.

Seymour

& Willis 601 California Street, Suite 2100 San Francisco, California 94108 Nr. Richard Hubbard NHB Technical Associates Suite K

1723 Hamilton Avenue San Jose, California 95125 Mr. John Marrs, Managing Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P. 0.

Box 112 San Luis Obispo, California 93406

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Mr. Malcolm H. Furbush cc:

Resident Inspector/Diablo Canyon NPS c/o U. S. Nuclear Regulatory Commission P. 0.

Box 369 Avila Beach, California 93424 Ms. Raye Fleming 1920 Mattie Road Shell Beach, California 93440 Joel

Reynolds, Esq.

John R. Phillips', Esq.

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

321 Lytton Avenue Palo Alto, California 94302 Mr. Byron S. Georgiov Legal Affairs Secretary Governor' Office State Capitol Sacramento, California 95814 Herbert H. Brown, Esq.

Hill, Christopher 5 Phillips, P.C.

1900 M Street, N.W.

Washington, D.C.

20036 Mr. Richard E. Blankenburg, Co-Publisher Mr. Wayne A. Soroyan, News. Reporter South County Publishing Company P. 0.

Box 460 Arroyo Grande, California 93420 Mr. James

0. Schuyler Vice President Nuclear Generation Department Pacific Gas 8 Electric Company P.O.

Box 7442 San Francisco, California 94120 Bruce Norton, Esq.

Suite 202 3216 North 3rd Street

Phoenix, Arizona 85012

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Mr. Malcolm H. Furbush Mr. W. C. Gangloff Westinghouse El ectric Corporation P. 0.

Box 355 Pittsburgh, Pennsylvania 15230 David F. Fleischaker, Esq.

Sui'te 709 1735 Eye Street, N.

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Washington, D. C.

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EHCLOSURE A

Elements Which Should be Included in the Design Verification Program o

on-essm>c ervsce e

a e

ontracts r>or to

une, 1978.

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A review of all quality assurance procedures and controls used by each pre-June 1978 ron-seismic service contractor and by PG&E with regard to that contract; a canparison of these procedures and controls with the related criteria of Appendix B to 10 CFR 50; and an identification of any deficiencies or. weaknesses in the quality assurance procedures and in controls of the contractor and PG&E.

2.

Development of a network for the design chain for all safety-related structures,

systems, and components involved.

This should include all'nterfaces where design information was transmitted between PG&E internal design groups and each contr actor.

3.

A review of the implementation of quality assurance procedures and controls used by and for:

o PG&E internal design groups, o

each contractor internal des'ign group(s),.

E o

transmittal of information between PG&E and each contractor, o

transmittal of contractor developed information w'ithin PG&E; and an identification of any deficiencies or weaknesses

.in the implementation of quality assurance procedures and controls by each contractor and by PG&E.

4.

Development of criteria for the conduct of this design verification program should consider the relevant guidelines contained in ANSI N45. 211,'ection 6.3.1.

~ Encl'osure A (cont'd) 0 t

5.

Development of criteria for selection of a suitable number and type of sample calculations related to the design of safety related structures, systems and components involved.

The purpose of these sample calculations should be to verify the design process, particularly in the areas of any'identified contractor or PGAE quality assurance weaknesses or deficiencies as determined from the procedure and implementation reviews discussed in steps 1 through 3 above.

Criteria for expanding the sample.

size when problems in verification are encountered Should also be developed.

1

ENCLOSURE 8

Elements Whi,ch Should be Included in the Design Verification Pro ram ot nterna Des> gn Act> v> t> es l.

A review of all quality assurance procedures and controls used by internal PGSE design groups by selecting for detailed examination certain safety related structures, systems or components as representative samples of the overall facility design.

A comparison of the PG8E procedures and controls used-for the sample structures, systems or components with the related criteria of Appendix B to 10 CFR 50; and an identification of any, deficiencies or weaknesses in these PGKE quality. assurance procedures and controls.

2.

Development of a network for the design chains for the sample structures, systems or components involved.

This should include all interfaces where design information was transmitted between internal PGKE design groups.

3.

A review of the implementation of quality assurance procedures and controls used in the design of the sample structure, systems or. components by internal PGEE design

groups, and an identification of deficiencies or weaknesses in the implementation of quality assurance procedures and controls by internal PGSE design groups.

4.

Development of criteria for the conduct of this design verification program should consider the relevant guidelines contained in ANSI H45.211, Section 6.3.1.

c

Enclosure 8 (cont'd) 5.

Development of criteria for selection of a suitable number and type of sample calculations related to the design'f the sample structures, systems or components involved.

The purpose of these sample calculations.

should be to verify the design

process, particularly in the areas of any identified PGEE quality assurance weaknesses or deficiencies as determined from the procedure and implementation reviews discussed in steps 1 through 3 above.

Criteria for e~panding.the sample size when problems in verification are encountered should also be developed.

ENCLOSURE C

Elements Which Should be Included in the Design Verification rogram 0

ervlce-e a

e ontracts ter anuary 1.

A review of quality assurance procedures and controls used by each post

'anuary 1, 1978 contractor and by PG&E with regard to that contractor by selecting for detailed examination certain activities of the contractor as representative samples of the entire activities carried out; a

comparison of the procedures and controls used by the contractor and PG&E for the sample activities with the related criteria of Appendix B

to 10 CFR Part 50; and an identification of any deficiencies or,weaknesses in the quality assurance controls of the contractor and PG&E 2.

Development of a network for the design chain for the structures, systems or components involved with the samole activities.

This should include all interfaces where design information was transmitted between PG&E internal design groups and each contractor.

3.

A review of the implementation of quality assurance procedures and controls used in the conduct of the sample activities by and for:

o PG&E internal design groups, o

each contractor internal design group( s),

o transmittal of information between PG&E and each contractor, o

transmittal of contractor developed information within PG&E; and an identification of any deficiencies or weaknesses in the implementation of quality assurance procedures and controls by each contractor and by PG&E.

0

Enclosure C (cont'd) 0 4.

Development of criteria for the conduct of this design verification program should consider the relevant guidelines contained in AHSI H45.211, Section 6.3.1.

5.

Development of"criteria for selection of a suitable number and type of sample calculations related to the sample activities involved.

The purpose of these sample calculations should be to verify the design

process, particularly in the areas of any identified contractor or PGEE quality assura'nce weaknesses or deficiencies as determined from the procedure and implementation reviews discussed in steps l through 3 above.

Criteria for expanding the sample size when problems in verification are encountered should also be developed.

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DISTRIBUTION:

Docket File 50-2 LPDR PDR N IC TERA LB83 Fi1 es

Attorney, OELD DEisenhut RPurple RTedesco FMi rag 1 i a JLee (4)

Lana Cobb IE (5)

HPA

'Bailey, OA (w 4

RDiggs, ADM (

SHanauer JKramer RMattson RVollmer TNovak GLainas JKnight WJohnston DMuller PCheck TSpeis LRubenstein WKreger HErnst ASchwencer JHiller EAdensam IDinitz AToal ston

SDuncan, NHSS BGrimes JWetmore ARosenthal, ASLA BPaul Cotter, AS ACRS (16)

ADH (15 copies)

HDenton ECase BBuckley 75 encls.

per docket)

B LEP (W. Jones)

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OFFICE t1 SURNAME) 0ATE f>

NRC FORM 318 UO/80) NRCM 0240 OfFICIALRECORD COPY

• USGFO: 1980-329-824

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