ML17096A328
| ML17096A328 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/15/1983 |
| From: | Buckley B Office of Nuclear Reactor Regulation |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16340D257 | List: |
| References | |
| NUDOCS 8302250060 | |
| Download: ML17096A328 (16) | |
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1 UNITED STATES NUCLEAR REGULATORY COVIMISSIO WASHINGTON, O. C. 20555 FEB 1 5 1983 Docket Nos;:
50-275 and 50-323 MEMORANDUM FOR:
Darrell G. Eisenhut, Director Division of Licensing THRU:
Thomas M. Novak, Assistant Director for Licensing Division of Licens ng 7
I George M. Knighton, Chief Licensing Branch Ho.
3 Division of Licensing FROM:
SUBJECT:
B. Buckley, Project Manager Licensing Branch Ho.
3 Division of Licensing Hans Schierling, Project Manager Licensing Branch No.
3 Division of Licensing DIABLO CANYON UNITS 1
AND 2 Enclosed's the NRR input for the Diablo Canyon Units 1 and 2 Cycle 3
SALP evaluation.
The input from the appropriate HRR and IE Divisions has been factored in the overall ratings.
I l>ctt4 4 Itt'gL Bart Buckley, Project Manager Licensing Branch No.
3 Division of Licensing
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ns Schierling, P
ject Manager Licensing Branch Ho.
3 Division of Licensing
Enclosure:
As stated cc:
D. Kirsch, Region V
D. Sternberg, Region V
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UNITE0 STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 fACILITY NAME:
DIABLO CANYON, Units 1 and 2
LICENSEE:
Pacific Gas and Electric Company NRR PROJECT MANAGER:
Bart C. Buckley/Hans Schierling INTRODUCTION This report presents the results of an evaluation of the licensee, Pacific Gas 8 Electric Company, in the functional area of licensing activities.
It is intended to provide NRR's input to the SALP review process as described in NRC Manual Chapter 0516.
The review covers the period July 1, 1981 to December 31, 1982.
More than 90 percent of al 1 1 icensing acti vities was assoc i a ted with Unit 1.
The basic approach used for this evaluation was to first select a
number of licensing issues which involved a significant amount of staff manpower.
Comments were then solicited from the staff.
In most cases the staff applied the evaluation criteria for the per-formance attributes based on their experience with the licensee or his products.
Finally, this information was assembled in a matrix which allowed an overall evaluation of the licensee's performance.
This evaluation is based on staff input from five branches in three NRR divisions and from one branch from the Division of Emergency Preparedness, OIE.
Summary of Results NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category based on a composite of a number of attributes.
The single final rating should be tempered with judgement with respect to the significance of individual elements.
Based on this approach, the performance of the Pacific Gas 8 Electric Company in the functional area Licensing Activities is rated category 2.
Criteria Evaluation criteria, as given in NRC Manual Chapter Appendix 0516 Table 1, were used for this evaluation.
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Performance Anal sis The licensee's performance evaluation is based on a consideration of seven attributes as given in the NRC Manual Chapter.
For most of the licensing actions considered in this evaluation, only three or four of the attributes were of significance.
- Thus, the composite rating is heavily based on the following attributes:
- Management involvement
- Approach to resolution of technical issues Responsiveness
- Staffing Mith the exception of Enforcement History, for which there was no basis within NRR for evaluation, the r'emaining attributes of Reportable events Training were judged to apply only to a few licensing activities.'he evaluation was based on our review of the following licensing activities:
- Equipment gualification
- Breakwater Structure
- Control of Heavy Loads Operator Licensing
,- Independent Design Verifcation Program
( IDVP)
Emergency
Response
Capability A.
Management Involvement in Assuring (}uality The overall rating for this criterion is category 2.
An example of management involvement was their early commitment, on its own initiative, to postpone fuel loading upon discovery of the seismic discrepancies at the plant in September 1981.
Initial management involvement in the area of the design verification effort was limited, however subsequent management attention has significantly increased.
Other areas where management involvement was evident is its participation in equipment qualification and the breakwater repair where large allocation. of resources were approved to undertake extensive breakwater model studies.
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B.
Approach to Resolution of Technical Issues from a Safety Standpoint The overall rating for this criterion is category 1.
There is consistent evidence of planning and assignment of priorities;
'ecision making is at a level that ensures management review.
C.
Responsiveness For individual licensing actions examined for this assessment, category ratings varied from 1 to 3.
The licensee pqpI.formance in only one of the actions examined was 'judged to fall into category 3 and that was in regard to control of heavy loads (NUREG-0612).
In other areas the licensee's responsiveness is judged to be timely with resolutions propos'ed usually acceptable with little or no modification required.
The overall rating is category 2.
D.
Enforcement History There is no basis for an HRR evaluation of this criterion.
E.
Reportable Events 1
The overall rating for this Category is 2.
The Pacific Gas 8 Electric Company promptly notified the NRC on September 28,'1981, prior to fuel ever being loaded into the core, of the seismic discrepancies found at the plant which resulted in license suspension and the initiation of the IDVP.
L'ERs will be evaluated by the Diablo Canyon resident inspectors in accordance with Mr. T. Bishop's memorandum dated January 21, 1983.
r F.
Staffing Cat'egory 1 is assigned based on a limited basis for evaluation only.
The number of qualified plant operators exceed the number of operators required for full power operations of Diablo Canyon 'Unit 1.
G.
Training The overall rating for this criterion is category 1.
The licensee has a defined training program for the station staff.
Mith respect
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to the operator licensing program, four RO and twenty three SRO examinations were given during the evaluation period with an overall passing rate of 81.5'X.
The Training Program at Diablo Canyon is considered to provide a good understanding of work and adherence to procedures.
Conclusion Based on the evaluation of the Pacific Gas 8 Electirc Company's performance for a number of significant activities in the functional area of licensing with respect to the seven criteria, an overall performance rating of category 2 is determined.
Specifically, management attention and involvement with the resolution of matters of nuclear safety is evident by senior management participation in the IDVP.
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C Enclosure i
I Appendix to NPR Input for SALP Evaluation
{fiemorandum to D.
G. Eisenhut from B. Buckley and H. Schierling, dated 2/15/83)
IV Performance Anal s i s - Des i n Verificatioh'ffort
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The design.-verification-effort for Diablo Canyon Unit 1 is an activity that was caused bythe detection of the so called "mirror image problem" in September
'1981 and which resulted in the Commission Order and NRR letter of November 1981.
The effort consists of.an Independent Design Verification Program
{IDVP) and the PG&E Internal Technical Program (ITP).
The majority
{approximately three quarters) of all NRR 'licensing activities {both technical, review and project management) during the evaluation per~od were associated with the design veriMea~rf acT.'iO.indies for Erfho'lb t.any~nii."-1;" n >eparaLe performance evaluation is prepared for the appropriate attributes of this-activity.
The elements listed in NRC Manual Chapter 0916 were found to be insufficient and not appropriate because of the uniqueness,and scope of the design verification effort.
Instead this evaluation is based on specific examples of activities.
The design verification effort by the licensee has sho~n continuous improvement in quality of work performed, understanding of issues and management commitment'-.
In the beginning, the licensee had some difficultyin developing'a clear definition of the program and its scoph.
Since about Nay 1982, both the IDYP and ITP have demonstrated excellent performance.
An evaluation af the licensee's peri'unAance with respect to the appropriat,e at,t.tibet.e> listed io th= Honual Chap.er is provided below.
Based on these evaluations the overall performance for the design verification proqram is Category 2.
Hanagement Involvement and Control in Assuring guality
'PG&E management has been actively involved in the deve'lopment and evaluation of the design verification program.
The immediate notification of the NRC of the initial "mirror image" problem in September 1981 and the licensee's comnitment, prior to issuance of the: NRC Order, not fa commence fuel loading shows prompt management attention
.o a,safety issue.
For a brief period thereafter same management actions reflected imcamp'lete information from its staff (e.g.
unawareness of necessary scope and of importance and implication of independence issue).
- However, because of its involvement
= the licensee's.-.
xecutive management recognized'he need to strengthen its own staff'ith outside upper management and technical expertise.
This resu'tted in the emp'loyment of the Bechtel organization and the formation of the. Diabla Canyon Project.
This step demonstrated PG&E management involveinent and interest for a quality pragram.
Throughout the evaluation
.period, PG&E management has demonstrated an eagel".ness and willingness to coirmunicate with the NRC management regarding any'ssue.
Examples are 'the initiation of the PG&E "look back" evaluation of its gA program and implementation and its commitment to perfarm an audit of gA activities during the construction phase.
Based on NRR interaction with the licensee, we rate the PG&E management involvement and commitment to quality in
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the design verification effort as Category 1.
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-.2-Approach to Resolution of Technical Issued FrOm a Safety Standpoint E
The licensee's staff ot iginaly underestimated or did not envision the required scope of the design verification effort.
After full implementation ot the IDVP, as required by the Comnission Order, technical issues were more clearly identified.
The subsequent formation of the Diablo Canyon Project in conjuction with the employment of Bechtel resulted in a PG&E effort and commitment
., to resolve all technical safety issues to the satisfaction of the NRC as well as its own satisfaction.
The expansion of the original program from a sample basis to a complete reanalysis of the seismic aspects of all safety related structures,'ystems, and
~ components and the commitment of extensive manpower resources to the
'esolution of the safety issues demonstrate -the necessary and proper approach to the resolution of the issues.
Anothe~ example of appropriate
. action is the recalculation of pressure and temperature environments for safety related components.-
In summary, the design verification program
'ow in place (both IDVP and ITP) is an excellent program for the resolution of technical
- issues, has the full support of PG&E managements and meets our requirements.
However continued NRR involvement in the
. execution of the program is required, such as attendance
- a. pG&f/Teledyne meetings.
Considering the entire evaluation period.
He rate the "Approach to Resolution of Technical Issues
'Fr om a Safety Standpoint" as Category 2.
Responsiveness to NRC Initiatives The Commission Order and the NRR letter of November 19, 1981 are the NRC actions that initiated the entire design verification effort.
The licen'see's response to the requirements was prompt and positive irr:the development and implementation of program plans for. Phase I and Phase II.
The -licensee responded at all times: to modifications to the program and additional NRC initiatives, for example,.
the audit of gA activities related to construction and the exp'ansion of the initial sample.
The licensee has also been, responsive i'n the resolution. of issues identified by the IDYP.
The licensee has stated at various meetings and in submittals to the, staff its commitment.
to respond to all 'NRC requirements's part; of the staff evaluation Brookhaven National Laboratory performed a detailed seismic analysis of the annulus steel structure inside containment.
This resulted in requests for additional information from PQ&E.
The responsiveness to such requests were not as prompt as desired.
The licensee's performance in thisattribute of "Responsiveness to NRC Initiatives" is rated Category 2 for the design verification program.
Enforcement History no input
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D.
Repot ting and Analysis of Reportable Eyengs..
The "mirror image problem" was reported promptly to thd HRC after its detection.
Initally this problem was thought to be an isolated case and immediate action was taken to determine the circumstances and bases for the prob'.cm.
After issuance of the NRC Order and letter, a program plan was developed that includes specific procedures for identifying and resolving additional deficiencies and concerns by the IDVP and the ITP.
The events are reported periodically and effectively to the HRC through semi-montly reports.
We rate the performance for "Reporting and Analysis of Reportable. Events" as Category 2, however a definite improvement during the last. six months of the reporting period is evident.
E.
Staffing (Including Yanagi'.ment)
At the outset of the'esign verification program the licensee intended to use R.
C. Cloud Associates for the performance of the NRC directed Independe..t Design Verification Program (IDVP) and the PGSE staff for the Internal Technical Program.
After recognition of the required scope of the program the licensee took positive actions to devote all the necessary resources to this effort.
Teledyne was selected as the IDVP program manager with R. F.
Reedy Inc., Stone 5 Webster Engineering Services and R. L. Cloud Associates as subcontr actors.
Addftional
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technical consultants were also employed.
In March of 1982 Bechtel was employed in a program management and technical support fuction.
'ince early 1982 the licensee has always dedicated the necessary resources, both management and technical staff, to the design verification effort.
Me rate, this attribute as Category l.
'F.
Training Not appl icable.
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