ML17083A984
| ML17083A984 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/28/1982 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Furbush M PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16341B765 | List: |
| References | |
| NUDOCS 8202190042 | |
| Download: ML17083A984 (7) | |
Text
UNlTED STATES
'UCLEAR R EGULATORY COMMtSWON WASHIINGTON, D. C. 20555 Jgy, 28 IRP Mr. Malcolm H. Furbush Vice President General Counsel Pacific Gas 8 Electric Company P. 0.
Box 7442 San Francisco, California 94120 Dear Hr. Furbush As a result of our ongoing inspection of the activities currently being implemented by you and your contractors in accordance with your proposed Reverification Program Plan described in your submittal of December 4, 1981, we have determined that additional information is necessary for us to determine the acceptability of the program plan.
These additional concerns are described in the Enclosure and relate to your procedures for conducting your proposed Reverification Program.
The purpose of this letter is to apprise you of those concerns which.
we believe warrant your immediate attention.
We will arrange a
m eting with you in the near future to discuss these
- concerns, in addi tion to our questions and concerns, which were provided to you in the form of meeting ac nda items on January 8, 1982.
As you know the Commission Order requires the review and.approval by the HRC of the Reverification Program Plan and of your contractors participating in the program.
Accordingly, you should understand that all work undertaken prior to such approvals are being done at your own risk and may be required to be revised in accordance with the HRC approved Reverification Progam Plan and contractors.
In addition to these
- concerns, you should be prepared to discuss at this meeting,.
procedural guidelines regarding the transmittal of information between you and your contractors that you would propose to follow to help assure the independence of the reverification efforts.
We will inform you in the near future of the time, date and place of the meeting to discuss these and other questions and concerns about your proposed Re-verification Program Plan.
Sincerely,
Enclosure:
As stated arrel isenhu U rec or Division o
Licensing Office of Nuclear Reactor Regulation cc:
See next page.
aaarieoOOa sa0202 PDR ADOCK o50002 5
Mr. Malcolm H. Furbush 2
CC:
Resident Inspector/Diablo Canyon NPS c/o U. S. Nuclear Regulatory Comnission 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's Office State Capitol Sacramento, California 95814 Herbert H. Brown, Esq.
Hill, Christopher
& Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Mr. Richard E. Blankenburg, Co-Publisher Mr. Wayne A. Soroyan, Hews Reporter South County Publishing Company P. 0.
Box 460 Arroyo Grande, California 93420 Hr. James
- 0. Schuyler Vice President Nuclear Generation Department Pacific Gas
& Electric Ccmpany P.O.
Box 7442 San Francisco, California 94 120 Bruce Norton, Esq.
Suite 202 3216 North 3rd Street Phoenix, Arizona 85012
fir. "::lcul
> H. Furhush
>'r.
M. C. Gangloff
~es tin.house L 1 ec tric Corpora tion P. 0.
E.'ox 355 Pittsb:.rgh, Pennsylvania 15230 "avid F. Fleischaker, Esq.
P. 0.
Box 1178 Uj;laho-..a City, Gklahoaa 73101
ENCLOSURE Staff Concerns Re Procedures for Conducting the Reverification Program l.
Notwithstanding your letter of January 8,
1982 stating that you do not require a reply from the NRC regarding your November 18, 1981 submittal of the Preliminary Report, the report did identify items requiring further follow-up and resolution by PGKE.
All of these items do not appear to be included in your Reverification Program Plan.
Examples are
( 1) the Westing-house application of the correct seismic response spectra (Preliminary
. Report, page 20) and (2) the, adequacy of control room equipment qualification
(Preliminary Report, page 33).
Please identify all items'that were included in tne Preliminary Report as requi ring further action, explain the actions being taken including a schedule for resolution and describe how the items are included in the Reverification Program Plan.
2.
The scope. of your proposed Reveri,fication Program Plan does not fully address the requirements of the Commission Order of November 19, 1981.
For example (1) your design review does not appear to examine PG8E internal interfaces
( Item 1.(a)(3) of the Commission Order) that rely on URS/Blum input for structural element evaluation, and (2) the exclusion of Westinghouse and General Electric from further design review on the basis that you consider the contracts with these companies as not "seismic service-related"
( Item 1.(a) of Commission Order ) is not adequate.
Please identify how these and all other items in the Commission Order are being addressed in the proposed Reverification, Program.
1
- 3. It appears that your procedures and threshold for identifying and reporting errors and open items identified during the proposed Reverification Program need improvement.
For example, (I) the HRC was not promptly notified of the difference in the auxiliary building seismic responses (Hosgri vs URS/
Blume 1979 report) which was identified within PG&E in mid-November
- 1981, and (2) a similar problem exists with the intake structure seismic responses which was not reported to the HRC until inspectors discussed this with
'I your engineering staff.
P]ease inform the HRC promptly of any error identified by your'staff or your contractors during'he course of the Reverification Program in conjunction with the biweekly progress reports.
In no case should the notification of the NRC be delayed more than t'wo weeks past discovery, whether or not the significance of the error has been evaluated.
In addition to the two items discussed in the preceeding paragraph, it appears that URS/Blume performed a structural analysis of the polar crane subsequent to that conducted in the Hosgri reevaluation.
This matter was noted in the Preliminary Report by Dr. Cloud.
Based on a
preliminary review of this later Blume analysis, it appears that the Hosgri reevaluation of the polar crane may not be conservative.
These three items lead to a general concern regarding the thoroughness of the technical review conducted by PG5E of URS/Blume seismic inputs in the Hosgri'reevaluation; particularly with respect to the review of the final design reports submitted to PG5E by URS/Blume to determine whether the Hosgri reevaluations should be updated or modified.
4.
The level of reverification, the criteria for determining additional
- sampling, and the applicable acceptance criteria are not adequately identified, described and updated.
Specific examples are as follows:
(1)
The independent reverification of the auxiliary building structure is simply a check (hand calculations) of building masses and stiffnesses without necessarily any verification by accepted computer codes or an examination of the URS/Blume input and output data files.
(2 )
An error in the seismic model of a fan cooler discovered by R. L. Cloud was determined to be conservative (in this case) and therefore no additional sampling appears to be scheduled.
(3')
The internal R. L. Cloud document "Criteria and methodology. for Independent Calculations and Criteria for Independent Evaluation", dated January 4, 1982, has not been incorporated into the Reverific'ation Program.
Thus, your program as described in the Reverification Program Plan does not provide the bases for initial sampling, the acceptance/rejection criteria and the criteria for expansion of the initial sample.
S.
Your biweekly status
- reports, including the R. L. Cloud progress
- reports, have not always concisely identified all deviations and errors that were found in the documentation,
- design, or as-built. configuration of systems and structures.
The initiation of the "Error and Open Items (EOI)"
report by R. L. Cloud, included in your status report of January. 8, 1982,
is expected to improve the situation.
However, while the Cloud progress report identified differences in the floor response spectra between the Hosgri report and the URS/Blume 1979 report, this item was not included in the EOI report.
We therefore request that you develop a
tracking system that identifies all deviations and errors discovered by you or your contractors since the initial notification of seismic design errors in September 1981 and during the Reverification Program.
The system should indicate when the problem was identified, on what basis it was determined'to be a problem, and provide the status of resolution, including any modifications th'at will be or have been implemented.
The system should be updated regularly and be included in your biweekly status reports.