ML20033A389
| ML20033A389 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/09/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML16340C103 | List: |
| References | |
| REF-10CFR9.7 SECY-81-636, NUDOCS 8111250306 | |
| Download: ML20033A389 (80) | |
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l NUCLEAR REGUI.ATORY COMMISSION COMMISSION MEETING
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PUBLIC MEETING BRIEFING ON RECENT SEISMIC DESIGN ERRORS AT DIABLO CANYON UNIT 1
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November 9, 1981 PAagg:
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1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
(
4 BRIEFING ON RECENT SEISMIC DESIGN ERRORS 5
AT DIABLO CANYON UNIT 1 8
7 PUBLIC MEETING 8
9 Nuclear Hegulatory Commission Room 1130 10 1717 H Street, N. W.
Washington, D. C.
11 Monday, November 9, 1981 12 The Commission met, pursuant to notice, at 13 j
,e ~
10:f40 a.m.
i 14 BEFORE:
15 NUNZIO P ALLADINO, Chairman of the Commission 16 VICTOR OILINSKY, Commissioner PETER BR ADFORD,' Commissioner i
17 JOHN AHEARNE, Commissioner THOMAS ROBERTS,.. Commissioner 18 STAFF PRESENT:
l 19 l
S. CHILK l
20 L. BICKWIT R. ENGELKEN 21 R. DeYOUNG H. DENTON 22 W.
DIBCKS F. REMICK l
23 F. MIRAGLIA l
E. CASE l
24 D.
EISENHUT B. FALKENBEERY 25 J. K!iIGHT l
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2 CHAIRMAN PALLADINO:
The meeting will please come 3 to order.
4 The Commission meeting this morning is to receive s
5 a briefing from the staff on seismic desian errors at Diablo
- q 6 Canyon, Unit No.
1.
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7 In late September the Pacific Gas and Electric 8 Company notified the C,ommission of its discovery of design
.1 7;
e errors involving the seismic design of Unit 1.
It also s.
m l h 10 announced that fuel loadino, which was authorized under the 11 recently issued low-power license, would be indefinitely l
12 def erned.
13 Since that time the NRC staff has held several
'14 public meetings with the applicant, PGCE, and has conducted 15 a number of technical inspection and audit a c tivi tie s.
The l
- 16. applicant has also been active in its reanalysis and l
's 17 reverification of seismic matters at Unit No.
1.
58 Today the NRC staff is prepared to brief the s
' ;g Commission on the errors that have been detected to date and 2g give the staff's understanding of the causes of these l
21 errors.
The 3RC staff also intends to cover in some detail 22 its proposed reverification program for Diablo Canyon and to 23 outline for the Commissilon the additional actions it 24 intends to take.
25 I should note for the benefit of the people here ALDERSoN L 'oRTING CotAPANY. INC.
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L 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
3 1 that the Commission intends today to hear only from its 2 staff.
We will not be asking the other parties to the 3 Diablo Canyon licensing proceedings to present their views 4 at this time.
I would now ask the staff to proceed with its 5 briefing.
6 COMMISSIONER GILINSKY:
Before we do that, I 7 vonder if the Ganaral Counsel could explain to us the 8 relationship of what is going on here today to the licensing f
9 'groceedings?
10 MR. BICKWIT:
The issues that are being discussed I
11 today, as I understand them, are not issues which are in 12 contest in the proceedinc.
There was an issue in contest 13 that had a close relationship to what is being discussed l
14 todaT, but that issue was not appealed and therefore is not 15 a live issue in the matter.
16 As a result, I think the Commission and the staff 17 should feel free to discuss these issues in whatever depth l
l 18 they choosa and need not worry about ex parte constraints.
COMMISSIONER GILINSKY:
What about discussions 19 20 with other persons?
ER. BICKWIT:
Discussions with other persons would 21 22 also be permissible under the ex parte rule.
COMMISSICNER GILINSKY:
Thank you.
23 COMMISSIONER A12ARNE:
So there are essentially no 24 25 constraints ?
l ALDERSoN REPORTING COMPANY. INC.
400 VIA*ilNIA AVE., S.W., WASHINGTON. D.C. 20024 (::02) 554 2345
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- 58. BICK3ITs That is right.
2 CHAIRMAN PALLADINO:
However, we have not 3 indicated in our published agenda that we were receiving 4 comments from others.
5 MR. BICKWIT:
That is right.
I simply meant to 6 indicate that there wouldn't be a legal bar to doing so.
7 CHAIRMAN PALLADINO:
But it would take a 8 Commission decision, I beli, eve, for us to depart from what 9 our plans were?
10 MR. BICKWIT4 Tha t is righ t.
11 CHAIRMAN PALLADINO:
Any other comments?
12 (No responsa.)
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13 CHAIRMAN PALLADINO:
Then I will turn the meeting 14 over to Mr. Dircks to lead us through the discussion.
l 15 MR. DIRCKS:
Mr. Chairman, we transmitted on l
16 November 5th a proposed summary of the actions that we would l
17 like the Commission to consider.
We have today the l
18 intention of going through the background of the situation l
19 up to date.
We have people here from Inspection and 20 Enforcement, Mr. DeYoung and Mr. Engelken, who is the 21 Director of Region V.
They will proceed to go through the 22 background and a summary of the situation and then Mr.
23 Den ton will provide the Commission with a summary of the 24 steps that the staff is recommending to the Commission to I
l 5 take in th e proposed 50.5aE letter that we have before you.
I ALDERSoN REPORTING COMPANY. INC.
400 VIRGINfA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5 1
Er. DeYoung, would you start?
2 MR. DeYOUNGs Yes, I will.
3 I have a brief rundown of how we came upon the 4 problem and how we divided the work.
Then we will turn it 5 over to Harold who will lead us through his part and we will 6 be prepared to talk about potential enforcement that we are 7 considering in a closed session.
8 MB. DIBCKS:
I mi,qht add that we have another part 9 to the briefing that we would like to discuss with the 10 Commission and that is an enforcement action.
11 CHAIRMAN PAL 1ADINO:
If the Commission wishes to 12 hear the enforcement action, I think then we will have to 13 close the meeting.
14 Why don't we proceed without that until we develop 15 enough background to decide how to deal with that.
16 HR. DeIOUNG:
That was our plan.
l 17 I think the problem began to arise on the 21st of 18 September when a PGEE engineer began questioning the diagram 19 tha t has become so f amous.
About that same date the Commission was briefed on the licensing of Diablo Canyon, 20 21 the low power licensing action.
The next day on the 22 September the 22nd NRR issued the low-rower license.
23 On September the 25th the lowest level, the second t
24 level PGEE management was advised of the potential error 25 tha t had been f ound by the engineer.
l l
ALDERSoN REPoFITING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
6 1
CHAIRMAN PALLADIN0s What date was that, the 25th?
2 MR. DeYOUNG:
September the 25th.
3 On September the 27th at about 4:30 in the 4 af ternoon we were informed, our resident inspector was 5 inf ormed of the potential mistake that had been made.
That 6 was on a Sunday, a Sunday af ternoon.
He informed the 7 regional people that same day.
8 The next day, Mon, day, the 28th of September, the 9 licensee of ficially notified the NRC of the apparent 10 mistake.
11 The next day we met, our people met.
We have a 12 rather formal arrangement when a potentini problem of this 13 type comes up.
Who is responsible?
We don't want to do 14 redundant work.
So we have a group within NRE and IEE that 15 g et together to try to define the problem to make a 16 distribution of the wo rk and so on..
It is a rather formal 17 gr:up.
Darrel'Eisenhut for NRR, for example, will sign the 18 agreement of distribution of work on any problem of this 19 type with Ed Jordan of IEE.
I 20 They met, they talked it over all day and ther 21 agreed and signed on September 29th an agreement of how we 22 would proceed with this problem.
They divided the work up 23 and they proceeded to follo w that.
CHAIRMAN PALLADIN0s This was an internal 24 25 agreemen t?
ALDERSON REPORTING COMPANY,INC,
@W@C'ID AML @.W WZHINGT@No D.@. 2i384 (2B $54-2345 y
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MR. DeYOUNG:
Internal agreement of how to address 2 the problem.
We had limited resources and we wanted to get 3 the best resources we have various aspects of the probles.
4 On each major problem of this type that goes across office 5 lines we try to aske sura ve don't waste the resources we 6 have.
We get the best resources possible to focus on the 7 problem.
8 They made the agr,eement on a Tuesday and they 9 began to work on that agreement.
Part of it was for a join.t 10 inspection, a special inspection that involved meetings with 11 the ICE people and the NRR people and they began to follow 12 that procedure.
13 COMMISSIONER BRADFORD:
About how large a group do 14 ve actually have working on Diablo Canyon matters at the 15 soment?
18 5H. ENGELKEN:
Out of Region V we had four people 17 engaged in the investigation work at the PGEE offices on a 18 f ull-time basis for a couple of weeks.
NRR had a group of I 19 think five or six people working concurrenty for a shorter 20 period of time, approximately a week I believe.
21 3R. DeYOUNG4 Is that sufficient?
22 I think we have gotten to the point we are now.
l 23 We have it in three phases.
We have the technical 24 requirements to satisf y the staff, the program that we need l
25 to follow to convince the staff that the plant is ready to ALDERSoN AEPoRTING COMPANY,INC,
-,..-- -..,. _.. _ _..___ _ __._... _, 00 vtRGINIA AVE., S.W, W ASHINGioN, D.C. 20024 (202) 554 2345 4
8 1 proceed with licensing and to load the fuel and so on.
That 2 is.one big aspect of it.
Harold Denton is going to make the 3 prasenta tion on that.
4 ICE, as I said before, has as one part of it 5 looked at the potential enforcement that we might take.
6That is a separate issue and we are prepared to talk about 7 that af ter Harold gets through with his presentation if the 8 Commission wishes.
i 9
Then there is the matter of the State of 10 California.
They have proposals in to the Commission for 11 their consideration.
We have not addressed that.
One of the reasons the Regional Administrator from 12 13 Region V is here is that he is closest to the meeting out 14 there and he is closest to what he thinks is the feeling in l
15 the State and he might give you some views as to what he 16 hears and he feels in that realm'.
So you might take that into consideration when you are making your decision on what 17 18 to do with the proposal from the Governor of California.
19 Eith that I was going to let Harold begin his j
l 20 presentation on the first part of what we h ave done.
21 COMMISSIONER AHEARNEs Dick, I think you lost me.
22 You were talking about three phases.
MR. DeYOUNGs Three items, the technical 23 l
24 requirements to get the plant to procaed to licensing, the l
25 enf orcement and the Governor's letter.
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ALDERSoN REPORTING COMPANY. INC.
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_ _.,. _, _ _.._., __400 VIR_GINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9 1
Harold.
2 (Slide presentation.)
3 ER. DENTON:
If we could have slide No. 2.
4 I will talk about what we have learned in the two 5 meetings that we have had with the company to date and what 6 ve learned f rom the results of the inspections and meetings 7 which have been held with the applicant.
8 We will talk about what the company had proposed 9 to do last week, what we are recommending in the 50.54F 10 letter as an extension of that program and mention what is 11 known today about the company's schedule.
12 COMMISSIONER GILINSKY:
Can I just ask you about a 13 detail.
Bill kept referring to 50.54E.
Was that intended 14 to be "F"?
15 MR. DENTON4 It 1:
"F" I believe.
16 MR. DeIOUNG:
"F".
17 MR. DENTON:
May I have slide 3, please.
18 At the conclusion of that meeting, which was our 19 first introduction to the scope of the problem, we had asked 20 the company for three items.
We asked them for a technical 21 report providing the results of their reanalysis of the 22 containment annulus area and a description of the proposed 23 modifica tions and the analytical bases for those changes.
l l
l 24 We also asked them for a reverification of the seismic l
25 design of all safety related systems and we asked that a l
l ALDEP. SON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
10 1 priority reverification involving the UBS/Blume matters be 2 done first.
That set the stage for the October 9th meeting.
3 Then following that time the company was going 4 down this path and making these types of studies.- We were 5 meeting with them, as shown on the slide.
6 I nov' vant to turn to slide No. 4 and talk about 7 the errors which have been detected to date.
I think these 8 errors are well summarized,in the most recent letter from 9 Governor Brown.
There is an attachment to that letter that 10 identifies the same ones.
11 COMMISSIONER AHEARNE:
Do you agree with that 12 summary ?
13 MR. DENTON:
Yes.
14 The first three were the ones about the mirror 15 image problem of the f rames in the annulus that we discussed t
16 with you before and the incorrect distribution within the 17 company of some of the spectra that were generated by 18 Blume.
We may have mentioned that there was a Blume l
19 analysis done in May and then corrected in June and the 20 company had used the May analysis originally and did not 21 follow up on the new desion model.
Then there were errors l
22 s ad e in the assumed weigh t and distribution of the 23 components in that area.
Then there were a number of other errors which 24 have been detected so far unrelated to these three but 25 l
l l
ALDERSON REPORTING COMPANY. INC.
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,._.. _ 00 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345 4
11 1 related to the same general topic of seismic design.
Then 2 rlso a number of errors have been detected during their 3 reverification program by their consultant who is doing the 4 seismic reverification program.
These have all been 5 described in the transcript that was provided to you and was 6 provided to all the parties.
7 COMMISSIONER AHEARNE:
Could you give a short 8 summary of what kinds of errors those others are?
You said 9 they were unrelated.
10 NR. DENTON:
Unrelated to the above_three errors.
6 11 COMMISSIONER AHEARNE:
What kinds?
12 MR. DENTON:
If I could go to back-up slide No.
13 4A.
This is a summary of five specific errors that have 14 been found to date.
By unrelated, they are not related to 15 the seismic one.
They continue to indicate to me a lack of 16 engineering controls during this period, but they are not 17 related to the annulus weights.
18 CHAIRMAN PALlADINO:
Do we have a copy of tha t 19 slide in our package?
I 20 HR. DENTON:
No.
I would be happy to provide it.
21 CHAIRMAN PALlADINO:
Thank you.
22 MR. DENTON:
Slide 4B, I believe it is, shows the 23 errors which have been found by the reverification program 24 to date.
This is as a result of a reverification anarsis 25 that we have asked for in the original meeting.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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12 1
So all in all they are finding a number of 2 instances of a lack of formality in their controls and 3 follow-up in the areas relating especially to seismic design.
4 If I could go to page 5.
I had mentioned that 5 earlier, the first bullet, which we had asked the company to 6 do d uring the first meeting which was a complete 7 reverificatin of, the seismic design.
PGCE proposed at the 8 most recent meeting to cont,inue that effort and do a review g by themselves of all service related contracts looking 10 ERinly for verification whether QA controls were in place 11 but not looking behind the paper necessarily unless they 12 found that thera were deficiencies in the controls.
13 COMMISSIONER GILINSKYa Well, let's see, is that 14 what the reverification program meant then?
15 MR. DENTON:
That is wha't the com pany's proposed 16 reverification program was last. week, to do the three tests 17 that we had asked f or originally and to expand it.
18 According to this bottom bullet they would do an internal 19 review of all pre *78 service contracts and if they found 20 deficiencies in that they would look further.
Now we didn't 21 adopt that proposal.
CHAIRMAN PALLADINO:
Did you reject it?
22 MB. DENTON:
Well, I recommend that you reject it, 23 24 YeS*
25 The next page then, item 6, is a summary of the ALDERSoN REPORTING COMPANY,INC,
_400 VIRGlNIA AVE _S.W., WASHINGTON, D.C. 20024 (202) 554 2345
13 1 staff conclusions based on everything that we have heard so 2 f ar and learned so f ar.
3 CORMISSIONER GILINSKYa Could you just go back a 4 minute.
What is it that you are not recommending as 5 presumably not sufficient?
6 NR. DENTON:
The last bullet, that they would 7 review themselves ---
8 COMMISSIONER GILI,NSKY:
And what do yo1 find 9 deficient in that?
10 MR. DENTON:
I think it needs to look beyond the 11 existence of paperwork.
I want to see the numbers on the 12 paper are accurate.
I think they were proposing more to 13 look for documentation of a QA -- (Simultaneous 14 Conversations - Inaudible ).
15 COMMISSIONER GILINSKY:
That checks had been made isand so on?
17 MR. DENTON:
That may have been m9 e but did not d
18 propose, if they found examples of do=umentation, they were 19 not going to go under the documentation to see if the 20 assumptions and numbers were correct.
COMMISSIONER GILINSKY:
But in the items under the 21 22 first bullet the comparv was planning to go behind whatever 23 Q A documentation there was or wasn 't and actually examine 24 the calcula tions?
MB. DENION:
Yes, that is right.
In that one we 25 ALCERSoN REPORTING COMPANY,INC.
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_ _400,VIAGINIA AVE., S.W, WASHINGTON D.C. 20024 (202) 554 2345. _ _ _ _
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14 1 had asked for a complete reverification of the analyses and 2 calculations that went into that particular activity.
3 COMMISSIONER BRADFORD:
Does the first one apply 4 only to post-78 activities, or would that be pre and post?
5' MR. DENTON:
Since we didn't adopt it, I don't 6 vant to dwell too much on this onet but that is the 7 reverification of the activities in the '77 time frame'when 8 they were using Dr. Blume's, service for analysis of seismic 9 details.
10 COMNISSIONER AHEARNEa I an having difficulty 11 tracking what is then different between one and two.
No, t 12 is working on the seismic design of safety related 13 structures and No. 2 is also the seismic design of safety 14 related structures.
15 MR. DENTON:
let me ask Dick or Bob if they recall 16 what the company specifically had in mind.
17 COMMISSIONER GILINSKY:
This slide represents the l
18 company 's proposal; is that righ t ?
19 MR. DENTON:
Yes.
j-20 Can anyone help us out?
21 COMMISSIONER AHEARNE:
I assume you are going to 22 discuss in more detail what you are recommending?
23 MR. DENION:
Yes.
I just wanted to give you a 24 preview of it.
They were not proposing to expand beyond 25 what had been agreed to at the October 9th meeting with the l
l ALDERSON REPORTING COMPANY,INC, L
400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554 2345
15 1 exception of the last bullet.
They were going to do some 2 more internal checking f or documentation.
3 CONNISSIONER GILINSKI:
I must say I an a little 4 :onfused, too, because on top you say " Complete 5 reverification of seismic design of safety related 6 structures, systems and components.
You know, 7 complete reverification is pretty extensive.
8 CONHISSIONER AHEA,RNE:
I am glad someone shared my 9 confusion.
10 CONNISSIONER GILINSKI:
Now you can hardly do more 11 than have a complete reverification.
12 ER. DENTON:
Well, let's stop here and see if we 13 can straight it out.
I don't remember what the company had 14 proposed for that specifically.
15 MB. EISENHUT:
It has been a few days back.
Let 16 se try to go back.
The first item was they referred to as a 17 Cloud reverification program.
They were using an 18 independent co n sul t. ant, Bob Cloud.
Tha t was the first 19 distinc tion COMMISSIONER GILINSKY:
Well, that is on a 20 21 saapling basis.
ER. EISENEUT:
The first program was looking at 22 John Blume interfaces and it was looking pre-1978 and it wa s 23 24 using an independent consultant.
Those were really the 25 three elemen ts.
ALDERSON REPORTING COMPANY. INC.
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COMMISSIONER AHEARNE:
Was it strictly focused 2 then on the work done by Blume or the PGCE/Blume interf ace?
3 HR. EISENHUT It was that service related 4 contract that they had with Blume and it was looking both 5 internal in PGCE and in Blume.
6 COHHISSICNER AREARNE:
It was focused on that one 7 service contract?
was.
That is the 8
HR. EISENHUT:
Ye,s, it 9 distinction.
10 HR. DENTON:
Then there are other soismic design 11 f acets that were not done by Blume and were done 12 internclly.
That is why they were proposing an audit with 13 their own resources for siequate documentation.
14 Slide No. 6 sumasrizes what I think we consider 15 the shortcomings in their Q A program in that time period.
I 16 have characterized there is a lack of rigor and formality in 17 their engineering controls and have attempted to identify at 18 least the three characteristics where we found weaknesses in 19 their system.
The person who had responsibility for the contract 20 21 with URS/Blume did not have a formal way of communicating 22 input da ta.
Apparently it took place by telephone by 23 various levels in management and he did not sign every memo 24 that went to Dr. Blume.
Neither did he follow-up formally 25 in the results that came back f rom Dr. Blume.
So it seems ALCERSoN REPORTING COMF ANY,INC, 400 VIRGINIA AVE., S.W,. WASHINGTON D.C. 20024 (202) 554 2345
D 17 1 to be that informal interface between the company and 2 URS/Blume in that time period that led to these difficulties.
3 CHAIRMAN PALLADINO:
Were the communications
(
4 clearly identified as related even to Diablo Canyon Unit 1 5 in every case?
In other words, you say they weren't signed, 6 but my impression was that some of them were not even 7 clearly identified as being appropriate for -- (Siraltaneous 8 Conversations - Inaudible).,
9 HR. DENTON:
That is right, and they were n 't all 10 written down.
It appeared to be a very informal use of a 11 consultant.
12 COMEISSIGNER GILINSKY Well, that key diagram, as 13 I recall, wasn't labeled at all.
14 MR. DENTON:
That is right.
They just had not 15 applied to their service contract with Dr. Blume the type of 16 QA controls which you would have expected to have been in 17 pla ce at th a t time.
There are a number of our criteria that 18 go to a QA program that were not followed in this time frame.
19 COMMISSIONER AHEARNE:
You say this time frame.
20 MR. DENTON:
I am talking about the '77 period l
i l
21 where most of our effort has focused.
Now they did change the nature of their contracts with service consultants after 22 23 this time f rame and I will come to that part later.
MR. DeYOUNG:
There might be a point as to why it 24 25 was so inf ormal.
The PGCE and Blume homes are so close ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9 18 1 together they can walk to each other and work together as 2 staff s.
It is not that they have to write letters to each 3 other but they are very close together.
They have had a 4 long relationship together and they know each other.
So 5 they have formed some habits perhaps that were not as formal 6as they might be otherwise.
7 CONHISSIONER GILINSKY:
Well, that was mentioned 8 at the meeting the other da,y and I wondered about it, 9 because the degree of informall'ty was greater than you would 10 expect between two departments in the same company.
11 NR. DeYOUNG:
We are not sure of that, and that is 12 why we are looking within PGCE.
13 COMMISSIONER AHEARNE:
I would agree with Vic.
I 14 think your point, Dick, is that you are not sure whether 15 even within the company that informality is there, but I 18 would certainly agree with Vic's point.
COMMISSIONER GILINSKY:
My impression was at least 17 18 in other areas that things were handled differently in 19 dif ferent subject areas within the company.
NR. DeYOUNG:
Within the com pany.
20 COMMISSIONER GILINSKY:
Although I would certainly
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21 22 like to hear about that.
ME. DeYOUNG:
That is what part of the 23 24 verification program is going to do.
COMMISSICNER GILINSKY:
But I must say that those 25 ALDERSoN REPORTING COMPANY. INC.
__. _ _ _ _ _ _400 VIRGINIA AVE., S.W., WASHINGTON 0.Cj. o024 (202} 554 2345
d 19 f
4 1 diagrams and the manner in which they were transferred 2 surprised me and it would have surprised me even if it had 3 happened between two adjoining offices -within the company.
4 CHAIREAN PAL 1ADINO:
I would be personally 5 surprised if I had kept my own notes that poorly because I
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6 am not sure that I could later verify what was intended by 7 these no tes.
I think they represent more than informality.
8 I think they actually repre,sent what I would call poor s practice.
10 MR. DeYOUNG I understand.
11 ER. DENTON:
It appears that when they bought 12 materials such as steel pipe that they had a formal QA 13 program in place.
The proposal on steel pipe had long, 14 detailed specifications attached to the contract.
Their 15 department would pour through the specifications and a QA 16 program formality existad in the procurement of materials 17 and in the procurement of instruction activities where you 18 would expect the kind of controls we are talking about to 1g exist.
20 It appears that when they went out for analytical 21 services during this period the contracts were extremely 22 brief.
They were one-page or two-page contacts and that 23 they sort of deferred perhaps to the prestige of their 24 consultants and they gave him very informally the 25 laformation he needed to do the review and they treated the i
I l
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20 I
1 result that came back in an informal f ashion.
2 MB. ENGElKENs I would like to just add to that.
3 Tha relationship with Blume began I believe back in the l
4 '66 '67 time frame before there were any formal NRC/AEC 5 quality assurance requirements.
It was a small contract.
6 It grew through the years into a much more substantial 7 contract.
Initially I believe it was very small and there 8 were essentially no quality assurance requirements of the eAEC at that time.
So it began on a very informal basis and to it was just continued on that basis apparently as it grew 11 through the years.
I 12 COMMISSIONER AHEABNE:
I am rather surprised at 13 the, and I am not sure you can call 'it informal or bad 14 practice, but it just wasn't certainly the type of practice 15 that I am familiar with coming out of military systems, to weapons analysis and so f orth, in which this kind of keeping 17 track of information which you use is critical and you have 18 to keep track of it very carefully.
19 Is it your sense that in general in the nuclear 1
20 power field or in the large-scale power productiod, facility 21 development, large coal plants and so forth, that this is 22 standard practice, this what I would have called looseness?
ER. ENGELKEN Well, I think there is far more 23 24 formality.
For instance, there was far more formality 25 within the company on their own internal matters.
It is ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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21 1 their interf ace relationship with these service contractors 2 where the-system broke down.
I think the problem with 3 vendors and the interf ace between the owner and the builder 4 and his vendors is a perennial problem that we have been 5 dealing with and find to be a continuous source of trouble.
8 COMMISSIONER AHEAR,NEa Your answer sounds like it 7 is broader than just the relationship in this company.
8 MR. ENGELKENs I,think generally it is.
9 MR. DENTON:
With regard to the service related to contracts, apparently they had a total of 12 such service 11 related contracts at the time and these lack of formal l
12 interfaces and controls seemed to exist on all 12 and about l
13 8 of the 12 were seismic related.
The other four were other 14 saf ety related issues.
l 15 COMMISSIONER GILINSKY :
Had you touched on the 18 second item?
I was particularly interested in whether this 17 was a widespread practice or one limited to, let's say, the 18 lack of adequate control of design information.
19 MR. DENTON:
Well, design and use I would say of 20 the design information.
COMMISSIONEB GILINSKY:
Are you limiting that 21 22 observation to the contracts that we are talking about?
l MR. DENION:
Yes, that is right.
It was drawn 23 from the errors reported to date.
24 COMMISSIONER GILINSKY:
Was there a different 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
~'
22 1 practice followed on designs generated internally when ther 2 had to be transferred from one department to another?
3 HR. DENTON:
Let me defer to Bob.
4 MR. ENGELKEN:
I am only aware of one problem that 5 ve found in that particular area and that was the f ailure to 6 transait the design indormation to the electrical group.
7 The information came from Blume and it was distributed to 8 the other groups within PGC,E that were supposed to get the 9 information but there was a failure to distribute it to the 10 electrical group.
I know of only one problem that was found 11 in that area.
12 MB. DENTON:
Now as.to how to remedy this 13 situation, let 's go to slide 7.
This slide 7, the program 14 that is outlined here is predicated on the assumption that i
1 15 the weaknesses in the program are f ocused 1. the service 16 contract area and that it is not a universtl breakdown 17 throughout the company.
18 COMMISSION ER GILINSKY:
Well, that is what I l
19 wanted to pin down earlier.
ER. DENTON:
Although it is designed to sample 20
,t 21 these other areas and it is open ended, but if in sampling those you do find similar weaknesses that can be broadened.
22 23 But it starts out with a big focus on service related l
24 contracts and a sampling of other areas.
Then based on the l
25 results of that sampling it could be expanded.
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CHAIRMAN PALLADINO:
Did you investigate to see 2 whether or not this was limited to the interf ace problem 3 between Blume and PGCE?
4 ER. DENTON:
It is ongoing.
5 EB. ENGELKEN:
We looked at other service 6 contracts as well, three or four others, and found similar 7 problems.there.
I think the situation with Blume was the 8 worst case that We found.
e CHAIRHAN PALLADIN04 Did you investigate to see 10 whether there were problems other than interf ace problems 11 with anybody?
In other words, did you check to see if there 12 were problems within PGCE with regard to its own work?
13 MR. DENTON:
The focus so far as been on the other 14 and it has only been 30 days.
Bob has been sampling this 15 other area f or ten years I guess.
I 16 MR. ENGELKEN:
Generally we had found the QA 17 within the PGCE organization quite good.
After this problew 18 came up we did find that one case where they failed to 19 disseminate the Blume design information to the electrical 20 g ro u p, but other than that the design reviews and the design 21 verifications within the company we found to be adequate.
22 Generally in inspecting the on-site construction effort at the Diablo site through the years it has been at least 23 24 average and probably better than average.
COMMISSIONER AHEARNE:
Have you had in the past in 25 ALDERSoN REPORTING COMPANY,INC, I
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20 1 rour inspection history of Disblo Canyon during 2 construction, have there been previous findings and 3 enforcement actions taken in this area of quality assurance?
4 MR. ENGE1 KEN :
Our program does not really include 5 very much inspection in that particular area.
That is a gap 6 that has existed in our program.
Initially back in 1970 7 when the Appendix B criteria came out and were imposed on 8 construction efforts we ins,pected at that time to make sure 9 that the company did have a system for design review.
We 10 established at that time that there was a design review 11 system and that it had been implemented.
That was what the 12 program required of us at that time and we have fulfilled 13 that requirement.
14 Through the years we have had some inspection 15 effort in that area, but rather limited compared with our 16 on-site construction inspection work.
So it has been one of 17 the weaker parts of our inspection program, the general 18 inspection of design review requirements.
1 19 COMEISSIONER AHEARNE:
Well, given that then, 20 Harold, did you say that you are going to do a sampling?
l l
21 MR. DENTON:
Yes.
l "0MM73SIONEB AHEARNE:
What will you use to 22 determine whether or not the sample has led you to go 23 24 farther, any problem or some number of problems?
MR. DENTON.
Let's go to slide 7 and I will try t) 25 l
ALDERSoN REPORTING COMPANY sNC.
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25 1 answer that.
2 C055ISSIONEB GILINSKY:
Well, let's see, I wonder 3 if that is the right order to take things in, John.
4 COMEISSIONER AHEARNE:
I thought he was on this 5 slide.
6
- 58. DENTON :
I an.
7 CHAIBMAN PALLADINO:
You are done on this slide?
8 COMMISSIONER AHEARNE:
No, he is on the slide.
9 This is the slide he is talking to.
10 CHAIRMAN PALLADINO:
Is this slide 7?
11 MR. DENTON:
Yes.
I was going to deal with what 12 we ought to do in the known areas first and then go to what 13 to do in the areas we are goino to sanple.
14 CHAIRMAN PALLADINO:
Let's proceed then.
I 15 COMMISSIONER GILINSKY:
Assuming you are going to 16 start in on this slida, could you say a word or two about 1
17 what the significance of a 50.54F letter is as opposed to 18 any other action we might take.
For one thing you have l
19 obviously decided not to withdraw the license or recommend l
20 that.
In any case, where does this fit in our inspection of 21 regulatopy tools?
22 MR. DENTON:
It is a vehicle we often use to 23 solicit information from a licensee to det. ermine whether or 24 not a licease should be suspended, revoked or modified.
COMMISSIONER AHEARNE:
It is to require 25 l
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26 1 information.
2 ER. DENTON:
It is to require information from the 3 applicant to make that - determination.
So it is not an 4 order.
It stops short of ordering it, but it. doen require 5 information to enable us to make a decision of rhether an 6 order would be appropriate.
7 COHHISSIONER GILINSKYa To what extent is the 8 licensee constrained, not t, hat I expect them to rush ahead 9 or anything, but what are the legal constraints on moving 10 forward and, for example, loading fuel?
11 NR. DENTON:
At the moment we have not issued any 12 orders modif Ting the existing license, but he has committed 13 not to proceed with fuel loading and that would be i
14 reiterated in our letter to him until he had our approval 15 and we had this information and had reviewed it.
l 16 COMMISSIONER GILINSKY:
This is what, a written i
17 CGdmitment?
18 MR. DENTON:
Perhaps I should ask our counsel.
19 MR. ENGELKEN:
The licensee in his initial i
1 20 notification to us had a statement that fuel would not be 21 loaded until.the NRC qives concurrence.
22 00EMISSIONER GILINSKY:
Does that impose a legal 23 obligation ?
24 3R. ENGELKEN:
In my view it does.
I am not a 25 lawyer.
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HR. BICXWIT:
No.
I wouldn't say it imposes a 2 legal obliga ticn, -no.
3 MR. DENTON:
There is no doubt in my mind that it 4 is an effective obligation.
5 COMMISSIONER GILINSKY:
No, I don 't expect them to 6 load fuel but I as just trying to understand how we are 7 going about doing our business.
8 MR. BICK7IT:
It,is not a legal obligation'in the 3 sense that to violate it would not bring forth the sanctions 10 that the Commission is capable of using against violators.
11 MR. MIRAGLIA:
I think we also have to keep in 12 uind that they have technical specifications as part of 13 their low-power license.
These techincal specifications 14 define operability and inoperability of systems.
Since some 15 of the key systems are in doubt with respect to the errors, 16 they cannot declare them operable cnd would be prohibited 17 under the existing tech.cpecs to operato unless they can 18 clearly show that these systems that are required by the 19 tech specs are indeed operable.
20 COMMISSIONER GILINSKYa Well, it does seem a l
l 21 round-around way of communicating.
22 CHAIRMAN PALLADINO:
Frank, would you identify 23 Yourself for the record.
MB. MIRAGLIA:
Yes.
I am so rry, sir.
Frank 24 25 Miraglia, NRC staff.
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COMMISSIONER BRADFORD:
Le t's see, they are also 2 required to give you 30 days = notice and to provide certain 3 information 30 days before loading f uel.
So as a practical 4 matter with this letter in their hand I take it they 5 couldn't go ahead and load fuel if they hadn't given you 6 that information.
7 ER. DENTON:
That would be the practical effect.
8 COMMISSIONER AHEABNE:
I don't think anybody 9 expects them to load f uel.
10 MR. ENGElK EN :
Their initial report to us dated 11 September 28th signed by Philip Crane of Pacific Gas and 12 Electric Company says:
" Fuel loading vill be delayed until
~
13 a resolution of those items necessary for f uel loading are 14 completed and concurrence is obtained from the NRC.
We vill 15 keep you inf ormed of progrecs during the re view."
16 NR. DENTON:
I think the action we take depends on 17 the situation.
Since they had not loaded f uel a nd they have 18 agreed not to losi fuel antil it is resolved to our 19 satisfaction I didn ' t see the need for anything more than 20 wha t we vece proposing.
21 CHAIRMAN PALLADINO:
But this letter in effect 22 though tells them that they have got to provide information 23 before they can load fuel.
MR. DENTON:
Yes.
24 l
25 wHAIRMAN PALLADINO:
I gather slso that the NRC l
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29 1 aust accept the information.
2 MR. DENTON:
Yes, and approve it.
If they went
~ 3 ahead and loaded fuel, then in spite our admonition we would i
4 issue an order.
5 COHNISSICNER GILINSKY:
Let's see, does it say we 6 have to approve what we have received?
7 NR. DENTON:
Yes.
8 COMMISSIONER AHEARNE:
Why don't we wait until he 9 describes the program.
10 MR, DENION:
What we need is a progras' to restore 11 confidence in the adegascy of their design.
Tha t would 12 somehow re-establish the proper engineering controls in the 13 areas that we found deficient.
So our program starts by 14 requiring an independent complete reverification of all the 15 saf ety related activities performed by URS/Blume.
16 COMMISSIONER AHEARNE:
You'used a key word in 17 there which I think has become very important in much of the i
18 correspondance.
You said independent.
tg HR. DENTON:
Yes.
20 COMMISSIONER AHEARNE:
Would you describe what you 21 sean by independent because I think there are a number of l
l 22 different opinions on that.
l 23 MR. DENTON:
That is right.
My view of f
24 independent would be that the company or the individuals l
25 doing the reverification in order to be ind e pendent must l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA /.VE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
O 30 I demonstrata integrity, competence and not have been involved 2 in the activities which they are reviewing.
e 3
Now the Governor's letter that you received this 4 morning would go further than that and also say it must be s
5 someone who has not been employed by the company and that 6 they would like a hand in selecting that person.
But the s
7 three that I mention are the criteria that I would look for.
COMMISSIONER AHEA,BNE:
I have just a comment. that 8
a ve have received a number of letters and they aren't all 10 f rom the Governor that raise the question of independence.
11 MB. DENTON:
I think independence neans at the 12 bottom without undue influence from the activity.
I tnink a-13 integrity and competence are what we are looking for.
Then 14 there are toucher issues of credibility and public reception 15 that we vill have to take into ac sunt.
16 CHAIRHAN PALLADINO:
It is my impression also in 17 your letter that you want to review the qualifications of 18 the independent reviewers.
l tg MR. DENTONs That is right.
The main errors that have been found have been in l
20 21 the seismir area.
So the first element in our proposal le a 22 complete reverification of all the safety related activities 23 proposed by Blume, analysis of the impact of all of errors 24 on the safety of the plant and that the modifications to 25 correct those errors be submitted and be approved by us and i
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s 31 1 that we have adequate time to review and concur in those 2 changes prior to any fuel loading.
That would be the first 3 element.
4 COHNISSIONER AHEARNE:
Could you go a little bit 5 further into what you maan by a safety reisted activity?
6 Are these all the calculations that were done and would this 7 he tracking the calculations from looking to see whether the 8 PGCE material was transmitted accurately to Blume and 9 3hether the Blume Company did the calculations using 10 techniques that you agree with and then whether that information was then transmitted back into the PGCE system 11 12 accurately and then used accurately?
13 MR. DENTON:
Yes, all of those.
That would be 14 spelled out in our letter to them.
It would be the 15 development, transmittal and use of results.
16 COMMISSIONER BRADFORD:
If I have understood 17 correctly, first of all, that isn't limited to the '77 '78 18 period.
Tha t would cover the life of the contracts dating 19 back to '667 20 MR. DENTON:
I don't know about
'66.
Remember the 21 plant was redesigned after the original design to 22 accommodate the Hosgri inf orma tion.
So it would focus on the redesign done in order to comply with tne new Hosgri 23 24 criteria.
COMMISSIONER AHEARNE:
This track s with No. 1 then 25 ALDERSoN REPORTING COMPANY. INC.
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32 1 on page 3 of the paper s is that correct?
2 MR. DENIONa Yes.
3 COHNISSIONER AREARNE:
So it is the Hosori Fault 4 reanalysis?
5 NR. DENTON:
Yes.
6 00HEISSIONER BRADFORD:
When does that mean that 7 it would tend to begin in time?
The Hosgri Fault was found 8 in, what, '72?
When was the actual redesign undertaken?
9 HR. ENGELKEN I believe
'76.
10 CONNISSIONER BRADFORD:
So the bulk of this'vork 11 is from '76 c' wards?
12 MR. DENTON:
Yes.
13 COMMISSIONER BRADFORD:
Does complete 14 reverification mean doing it all over again in f act?
15 MR. DENTON Well, not necessarily.
I don't think 16 there is any finding to date that the way it was used within 17 Blume's purview was incorrect.
It is really the development 18 of information that went to their consultant and then it is 19 used later.
00MNISSIONER GILINSKY:
Has anyone checked that?
l 20 21 ER. DENTON:
Let me ask Bob.
That is part of the 22 reverification program.
l CHAIRMAN PALLADINO:
You mean whe ther or not Blume 23 24 used the right procedures will be part of the reverificatirn 25 p ro gra m ?
l l
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MR. DENTON:
To date the errors which have been 2 found have not bean in that area.
3 HR. DeYOUNGs I would like to ask Bobby 4 Falkenberry to answer that question.
5 ER. FALKENBERRY:
Bob Falkenberry.
We looked at 6 the Blume site and it looked like their program was much 7 more formally handled,than the PGCE site.
8 CONNISSIONER BRADFORDs You mean within Blume?
9 3R. FALKENBERRY:
That is correct.
10 COMMISSIONER BRADFORD:
And not at the point at 11 which they received documents f rom PGCE obviously.
12 MR. FALKENBERRY:
That is correct.
Now they did 13 not have a full Appendix B program in effect at that time.
14 It was probably not until about the 1976-77 time frame was 15 tha t in ef f ect.
16 COMMISSIONER BRADFORDs let's see, Blume would 17 have had a full Appendix B program in effect after '767 18 MR. FALKENBERRY:
They were committed to having a 19 f ull Appendix B program in ef f ect about 1977.
That is when 20 PGCE communicated to them formally and committed them to a 21 full Appendix B program.
That was in
'77.
00M5ISSIONER BRADFORD So that they, too, should 22 23 have had a program in effect tha t would have prevented work 24 being done on the basis of a document such as the ---
3R. FAIKENBERRY:
Every indication that we had in 2g ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
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s 30 1 looking at the anterials over at Blume and in talking to 2 people was that it appeared they had a design calculation 3 review program in effect for all work done for PGCE.
4 However, they admit that any of the information that was 5 transmitted to them from PGCE was not included in this 6 design verification of theirs.
So things like the diagram 7 would not have been picked up in their design review program.
8 COMMISSIONER BRAD,FORDa Is that an adequate 9 program then?
10 MR. FALKENBERRIs I don't think we would consider 11 it an adequate program as of today, no.
12 MR. DENTONa let's talk about what else needs to 13 be done besides fixing the known errors.
This goes to the 14 second bullet then.
15 COMMISSIONER BRADFORDs Before you go on, Harold, 16 I 15 still not c13Rr on what re verifica tion actually Beans.
17 Is it that in fact they will have to do over the 18 calculations that Blume or are they just going to be 19 checking in effect tha interface?
20 MR. DENTON:
It is not redoing the Blume 21 calcula tions over.
It is to reverify the development, 22 accuracy, transmittal and use of information and not rerun 23 the computer runs.
COMMISSIONER BRADFORD:
Ihey really aren' t 24 25 reverif ying the activities themselves then?
ALDERSoN REPoRiiNG COMPANY,INC.
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35 1
MR. DENTONs That is right.
2 00HNISSIONER AHEARNEs Well, I assume that that 3 means so long as they find the information transferred at 4 the interf ace of PGCE/Blume is information unlike that 5 diagram.
If they find other cases where the information 6 transmitted is incorrect they do have to then redo the 7 calculations.
8 HR. DENTON:
Sure,.
What-they have done is they 9 have outlined, and it is attached to the last transcript, an 10 identification of the types of information that were 11 developed and the interfscas that did exist in their plan to 12 look and in fact it is in their lookino that they have 13 identified five errors so f ar in this area of transmittal of 14 inf ormation.
15 So I think it is a very logical approach to 16 reverify, but it does not mean recalculating all the numbers 17 all over again.
It means a hard engineering look at beyond 18 just the existence of paper to document it.
It is to look 19 to see if there is an adequate. technical-basis underlying
't 20 the values used.
21 CHAIRMAN PALLADIN0s Are you going to check to see 22 if the information tha t was transmitted was the information 23 that was used in the calculations?
dR. DENTON:
Yes.
When we you "ve," we tend to 24 25 have the applicant do ' hat and we check him.
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36 1
COREISSIONER BRADFORDs Does complete 2 reverification mean the sampling techniques or will they 3 really look at everything that flowed from PGCE to Blume 4 during the period of concern?
5 MR. DENTON:
For this particulaa one, which is
~
6 where we found the errors to date, it is my intent to really 7 be complete and look at all the information that was 8 transferred.
I think we found enough errors there to 9 require complete re-examination as opposed to a sampling 10 re-examination.
11 Now, as I mentioned earlier, of these service 12 related contracts in that period, eight of them related to 13 seismic design and four did not.
I am not able to tell that 14 there was any organizational or procedural controls in place 15 for these other four that would separate them out from the 16 otn er eight.
So I think these other service related l
17 contracts should be subject to the same kind of design 18 review and reverification program.
All this is pre
'78.
CONMISSIONER AHEARNE:
Now you have lost me.
As I 19 20 understand there were 12 contracts here.
Four are not 21 seismic and you just addressed those.
Slume is one of the 22 seismic.
MR. DENTON:
Correct.
23 005MISSIONER AHEARNE:
What about the other seven?
24 MR. DENTON:
They will all be done as part of the 25 l
I i
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t 37 1 reverification, in other words, all the seismic related 2 service contracts will be re-examined completely.
3 CHAIRMAN PALLADINO:
How about the other four that 4 are not seismic.
5 MR. DENTON:
They will do those, too.
That is the 6 first item under the second bullet.
7 COMMISSIONER AHEARNE:
But your first item in your 8 letter at least speaks to s,pecifically the Blume <ontract?
e MR. DENION :
I wouli go to the la tter --
10 (Simultaneous Conversations - Inaudible).
11 CONNISSIONER AHEARNE:
That is what I am talking 12 about.
I as reading the le tter.
13 NR. DENTON:
Well', maybe it is not clear.
14 Fraak, do you want to expand on what we meant 15 there?
16 CHAIRHAN PALLADINO:
What page are you on?
(
17 CONNISSIONER AHEARNE:
I was on page 3.
18 MR. MIRAGLIA:
I think the key in that bullet is 19 all other pre-June 1978 service related contracts.
So Blume 20 is the first one, and that was done on the priority basis, 21 and then prior to going ibove five percent all other 22 pre-June 1978 service related contracts.
The "other" means 23 other than Blume.
COMMISSIONER GILINSKY:
Let me understand.
You 24 25 would f ollow these calcula tions in to the plant design ALDERSo*4 REPORTING COMPANY,INC, l
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38 1 wherever they were used and see that they were correctly 2 applied?
3 MR. DENTONa That is correct.
~
4 COMMISSIONER GILINSKY:
So you are going beyond 5 then what PGEE proposed or Mr. Cloud pcoposed at the meeting 8 the other day which clearly involved sampling.
7 MR. DENTON:
I don't think we are going beyond 8 with regard ta the Blume is,susc.
We are going beyond in the 9 other areas.
10 CHAIRMAN PALLADINO:
You are not going beyond in 11 where?
12 MR. DENTON:
For the Blume related analysis.
13 CHAIEMAN PALLADINO:
You are not going beyond wha t 14 the applicant had recommended or Blume.
Is-that right?
I 15 don 't want to put words in your mouth.
I would just like to 18 understand what you are saying.
17 MR. DENTON On the Blume related activities it 18 was our intent that the complete reverification would flow gg all the way back into the company to be sure that the 20 company used those numbers correctly in their analysis of 21 their analysis of the full response spectra and equipment l
22 modifications.
That would be a complete reverification 23 activity of the numbers that went to Blume and the numbers 24 that came back from Blume.
COMMISSIONER GILINSKY:
And you are extending that 25 ALDERSoN REPORTING COMPANY,INC,
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39 1 to other saismic related service contracts?
2 MR. DENTON:
That is right, ifcI am unable to 3 distinguish whethat they had any better controls on any of 4 those service contracts than they did on Blume, although for 5 some reason Blume seems to be the most egregious example.
6 COMMISSIONER GILINSKY At the bullet there you 7 say prior to f uel load and operation up to five percent 8 power.
Do you Pean prior t,o fuel load or are some of them 9 prior to five percent power?
10 MR. DENION:
Well, in the first bullet prior to 11 f uel load, valess there were something that we were to agree 12 with to be done later.
To the extent that they find' errors 13 through the reverification that they make the modifications 14 and restore the plant to the condition that it is 15 represented to 's or justify why they didn't.
16 COMM.
'ONER GIIINSKY:
Because in your letter you 17 break it up into tm categories, one prior to fuel load and se.
power.
Are you now lumping them 18 one prior to fit.
19all in together?
20 MR. DENTON:
In the first bullet I would lump all i
21 before fuel load.
Then since we don't have examples of 22 errors in these other areas I would permit them to do that l
23 during the fuel load and low-power testing provided they 24 don ' t tu rn u p big issues.
COMMISSIONER AREARNE:
In his letter that l
25 ALDERSON REPORTING COMPANY,INC.
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=
1 particular thing is low-power spectra.
2 COMMISSIONER GILINSKYa There are three items 3 under that bullet.
Which of those would have to be done 4 bef ore a f uel load?
5
- 32. DENION:
Under the first bullet all three.
Do '
6the reverification, analyze the impacts of the errors and 7 make the modifications that are required in the plant design.
8 COMMISSIONER AHEA,RNEs I don't think that is what 9 your letter says.
10 HR. DENTON:
It was intended to.
11 COMNISSIONER AHEARNEs I think your letter says at 12 least 30 days prior to the date you plan to proceed with 13 fuel loading and operations up to five percent power provide 14 the following information.
The first is the results of an 15 independent complete design review and verification program.
I 16 MR. DENTON:
We can correct that.
It was prior to j
17 fuel loading.
18 CHAIRMAN PAllADINO:
Yes, I think it would clarify 19 it.
I had that saae problea.
20 COMMISSIONER BBADFORD:
Harold, do you have any 21 sense of the dollar volume of these contracts?
I am 22 wondering ho w big a job this actually turns out to be?
MR. DENION:
Just the first bullet or more?
23 COMMISSIONEB BRADFORD:
No, all of the service 24 25 con tracts.
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41 1
ER. DENTON:
I think we in the meeting we expanded 2 the scope of their review by a factor of two or three or so 9 because we moved beyond just the seismic.
4 Let me just explain the rest of this and then we 5 will answer the dollar costs.
6 The other parts that we need to get the 7 independent look into are these other service related 8 contracts, and that is unde,r the second bullet, and then we o need to auilt PGCE's own internal design process to see if 10 it had any of these same weaknesses.
Then we need to check 11 the validity of the post '78 service contracts.
In other 12 words, by that time the company did get GA into all its 13 contracts and you would not expect to find these errors.
14 So the program that we have laid on them that 15 expands what they have proposed would be to do all service 16 related contracts, sample PGCE's own design process and 17 sample the accuracy of information used post '78 and supply 18 us with all the modifications f or our approval that would 19 flow from that.
Also, provide us a program plan for doing 20 it which would indicate the basis for their statistical 21 sampling and how many errors they would have to find before 22 it would grow and a description of the qualifications of 23 peo ple doing their work.
24 Having gotten out the entire program, let me come 25 back and ask if anyone knows what the dolla r cost to the i
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
O2 1 company in any phase of this would be.
2 HR. DIRCKS:
The dollar volume of the total 3 contract.
4 00HHISSIONER BRADFORD:
It wasn't so much the 5 dollar cost to the company of this that I was interested 6 in.
I wanted some sense of how much work was done under 7 those 12 contracts.
a MR. DENTON Oh, under those 12.
Well, they did I 9 guess the. analytical part of their reanalysis to accommodate 10 the Hosgri earthquake which was f airly substantial f rom a 11 saf ety standpoint.
There were eight of them for the 12 upgrading of the plant from a seismic standpoint.
Then the 13 other four dealt with things like containment penetration 14 design.
All eight were important safety related contracts.
15 COMMISSIONER BRADFORDs But we don't have a feel 16 at this point 'for the total volume of work it is that is 17 going to have to be reviewed as part of the satisf action of 18 the requirements you are proposing?
19 MR. DENTON:
I guess I don 't know how to define 20 volume.
I know the activities they encompassed, but I don't 21 know th e volume.
Does someone what to volunteer?
22 (No response.)
23 COMMISSIONER GILINSKY I hate to belabor this 24 25 point, but could I ask you again, when you talk about i
ALDERSoN REPORTING COMPA!!Y,INC.
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63 1 service related contracts down below are you talking about 2 the non-seismic contracts or are those the remaining seismic 3 contracts?
4 MR. EISENHUT Non-Blume.
It is all the remaining.
5 COMMISSIONER GILINSKYa Seismic contracts?
8 MR. EISENHUT No.
7 COMMISSIONER GILINSKY:
You are not distinguishing 8 between seismic and non-sei,saic?
9 HR. EISENHUT:
To put it another way, the first 10 one is just Blume.
11 COMMISSIONER GILINSKY:
I see, all of that is just 12 Blume.
13 MR. EISENHUT:
And the bottom one is the other 14 11.
If you look actually at th e letter, th e second ites, 15 and it might help to add the word "all" if you look at the 16 top of page 4.
The item at the bottom is they have to do 17 PGEE,'s service related contractors, work that was done prior 18 to 1978.
We didn't say all non-seismic Blume and all 19 others, but it is just all service related contracts other 20 than Blume in the first one.
21 MR. DENTON:
I think Commissioner Gilinsk y is 22 correct.
It was my understanding that the present activity 23 going on ehcompasses all seismic related with Elume just 24 having priority and we wanted a reverification of all 25 seismic related which would encompass the eight contractors ALDERSoN REPORTING COMPANY. INC.
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s NN 1 to the extent they did anything on seismic.
Now if they did 2 activities in other areas I would defer that to the second 3 bullet.
g 4
COMMISSIONER GILINSKY:
So the first category is 5 then all seismic contracts.
6 MR. DENTON:
Let me modify it here at the table to 7 say all seismic related activities.
8 COMMISSIONER GILI,NSKY:
With Blus'e 's analysis 9 having priority in the reverification program.
10 ER. DENTON:
Yes, that is correct, with that one 11 having the priority.
12 COMMISSIONER AHEARNE:
Are you also modifying the 13 way that it is written on the slide?
The first is something i
14 that has to be done prior to operation up to five percent 15 power.
16 MR. DENTON:
Before fuel loading.
17 COMMISSIONER AHEARNE:
The second is prior to 18 exceeding five percent.
So at least on the slide there are tg two different ways of saying approximately the same thing.
20 Are you saying that the first really is just prior to fuel 21 load?
22 MR. EISENHUT:
No.
CHAIRMAN P A.'. AJINO :
It says so.
23 MR. EISENHUTs The different piece there is true, 24 25 the first item is prior to fuel load, but the other piece ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554-2345
)
05 1 thst is aesnt is that is all that would be required prior to 2 going up to five percent.
Hence, that is why both the items 3 are there.
Maybe it is not very clear.
4 COMMISSIONER AHEARNE:
But, Darrell, if the first 5 group is what is required prior to going up to five percents 6 in other words, you can go up to five percent?
7 MR. EISENHUTs You must complete that work before 8 you can load f uel and you m,ust also have completed it before 9 rou can go up -- (Simultaneous Conve rsations - Inaudible).
10 COMMISSIONER AHEARNE:
But you must have completed 11 it before yo u load fuel.
12 MR. DENION:
I think it is an undue complication.
13 COMMISSIONER GILINSKY:
Can we just drop all of 14 those.
15 MR. DENTON Yes.
It was intended before loading i
l 16 fuel they would have a reverification of all seismic related 17 activities with service con tractors.
Maybe we got too fancy 18 with the words here.
However, the second part was intended 19 to apply in those areas where to date we have not found 20 errors of the type that hsve been described that we would 21 permit this reverification program to be ongoing during the 22 low-power phase.
When you actually make th e decison to 1
23 permit fuel load we would have at that time the results of 24 these other audit prograns to see if they were turning up 25 similar problems or not.
l l
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COMMISSIONER GILINSKY:
The first batch.
2 MR. DENTON:
Yes.
I think the wording can be 3 improved and would do that in any correspondence.
4 COMMISSIONER AHEARNE:
Would you look at page 5 of 5 your letter.
This speaks to the information to be provided 6 as a result of the design review and this is the otner 11 7 service contracts I believe.
Is that correct?
8 MR. DENTON:
Yes.
9 COMMISSIONER AHEARNE:
One of the things to be 10 provided :
"The criteria for the selection of a sample of 11 saf ety-related structures, systems and components for 12 reverifying the design process."
13 I had thought that you were doing a complete 14 reverification of everything that vent through the service 15 related contracts.
What is the sample that you are now
.8 speaking of?
17 MR. DENTON:
The sample would apply to the PGEE 18 internal design activities and the post '78 service 19 contracts.
COMMISSIONER GILINSKY:
I wonder if there is a I
20 1
distinction drawn between reverifying the manner in which 21 22 things were handled and actually recalculating.
MR. CASE:
We tried to word it so that you would 23 24 look at the way things were handled and reverify a sample, 25 and even though correctly handled to reverify some in that ALDERSON REPORTING COMPANY. INC.
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47 1
group.
2 CONNISSIONER GILINSKYa Well, it is a 3 reverification program but you are not reverifying every 4 itan.
Is that what you are suggesting?
5 NR. CASES That is what Frank and I had in mind.
6 OOMMISSIONER GILINSKYs What then is a complete 7 reverification?
8 NR. CASEa The complete means everything in that 9 area, seismic or Blume or whatever.
10 CHAIENAN PALLADIN0s If we are having this much 11 trouble interpreting what the word means'-- (Simultaneous
- 2 Conversa tions - Inaudible).
13 CONNISSIONER AHEARNE:
Let me ask the question a 14 dif feren t way.
15 CHAIRMAN PALLADINO:
All right.
If we, at least 16 for myself, if I have this much difficult / under sta nding 17 what your letter means, how am I going to understand whether 18 the results that you get back meets with what the letter 19 requests.
20 COMMISSIONER GILINSKY:
The letter hasn't gone out 21 yet and presumably we are coing to clarify the letter.
22 MR. DENTON:
I have indicated that this in which 23 we wanted to move and we sent this down last week so it 24 would be available and I would expect to polish it up based 25 on the comments we got.
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COMNISSIONER AHEARNE:
Ed has just pointed out 2 that the raverification is the sampling, co rrect?
3 ER. CASE:
(Nodding affirmatively.)
4 COMMISSIONER AHEARNE That is wh y one speaks 5 about the criteria for the section of a sample for 6 reverif ying.
But the description at the beginning talks 7 about doing a complete verification.
8 NR. CASE:
I have to distinguish that one from the 9 sampling ones of the internal PGCE where you don't have to 10 look at all the procedures.
11 COMMISSIONER GILINSKY Sure.
We understand that 12 part.
13 COMMISSION ER HEABNE:
What you describe I think I 14 probably don't have any problem with.
I would argue that 15 the letter doesn't really come across the sac. vay.
16 NR. DENTON:
I think that is why it takes a long l
17 time to get letters out.
l 18
( Latchter. )
MR. DENION:
This one was generated I guess just a ig 20 day after the meeting with the company so we would have l
21 --(Simultaneous Conversations - Inaudible).
i COMMISSIONER GILINSKY:
I understand you are i
22 23 trying to give us a job here so we would have something to 24 do.
( Lauch t er. )
l 25 f
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09 1
COHNISSIONER AHEARNE:- So if I can understand, 2 what you are saying, it is that you are going to try to 3 check every ites of information that crosses the boundary 4 between the PGCE organization and the service contractors 5 and then the service contractors back into the PGEE 6 organization, and that you are going to do a sample of 7 metually tracking the complete calculation along that chain a as well as do a sample of the calculations internal to PGEE; 9 is that correct?
10 3R. DENTONs That sounds like what I had in mind.
11 let me ask the paoole who wrote the latter.
12 (Laughter.)
13 CHAIRMAN PAL 1ADIN04 I think it would be worth 14 spending a littie time in clarifying this point.
15 MB. DENTON:
All right.
16 Slide 8.
In order to be clear on some of these 17 poiats the same letter had asked that the company provide l
18 its program plan as it had for the earlier effort so that we 19 could agree tha t the scope of program is what we had in mind 20 and to describe the qualifications of the people they had 21 selected to do these tasks so that we co'11d make our own 22 judgmen t.
23 CHAIRMAN PALLADIN0s Is there a statement in the 24 letter that says that you would comment on or approve the 25 qualification of personnel of the contractor to perform an ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554-2345
s 50 1 independent design verification program?
2 NR. DENION:
At the top of page 9, item B in the 3 proposed letter, does ask for this information and it would 4 give us the opportunity to object if we didn't agree with it.
5 CHAIRMAN PALLADINO:
It doesn't explicitly state i
6 that, does it?
7 HR. DENTON:
No.
8 00HNISSIONER ANEARNE:
Do you have a problem with 9 saying that?
10 ER. DENTON:
No.
It certainly can be explicit.
I 11 think it is usually understood.
12 CONNISSIONER AHEARNE:
dell, given particularly 13 the great interest in having an independent review and 14 recognizing thet sany people don't use your definition of 15 independence, thst is they would accept the integrity, the 16 competance and not previo'usly involved,but they would go 17 one step farther, not employed by the company.
18 HR. DENTON:
Yes.
CHAIRMAN PALLADINO:
I think the implication that 19 NBC would rule on the competency and the adequacy of these 20 21 consultants, I think it would be well to put that explicitly.
MR. DENTON:
If you do want to go beyond the three 22 I have stated now is probably the time to decide so that the 23 24 program could get moving in that way.
COMMISSIGNER GILINSKY:
This means in effect that 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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51 1 rou would review Dr. Cloud's effort to see whether it met 2 these criteria?
3 ER. DENTON:
Well, it brings up some practical 4 problems.
The Cloud effort will be over by mid-November.
I 5 sean that effort has been going on since early October.
6 COMMISSIONER AHEARNE:
This is almost mid-November.
7 (Laughter.)
8 MR. DENTON:
Well, it should be.
We should have 9 his technical report.
10 COMMISSIONER GILINSKY:
His entire effort?
I 11 thought he laid out a f airly ambitious program.
12 MR. DENTON:
Well, let me restate that.
I think 13 we will have some initial review of the Blume interf ace by 14 about mid-November and his conclusions in that area.
So 15 that ef f ort has been kicked off and is going.
Now, the 1e expanded eff ort, particular with regard to other service 17 contracts, with regard to PGCE itself and post
'78, I don't 18 know that the company has selected a contractor to do that.
COMMISSIONEB GILINSKY:
I see.
19 20 3R. DENTON:
You could either redo all the Cloud 21 by someone or we could write the criteria to be followed for 22 the next part.
COMMISSIONEB AHEARNE:
Currently hcw do you expect 23 24 to have the NRR or NRR anc ICE review of this reanalysis or 25 reverification done ?
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NR. DENTONa Let's go to slide 9.
2 C053ISSIONER AREARNE:
It somewhat gets to how 3 auch reliance you are placing upon independence.
4 NR. DENTON:
Depending upon the scope of the 5 off ort that we decide is appropriate, it would be a. joint 6 NRR/Ir.E effort.
I think we both would anticipate four to 7 six man-months of effort of your staff and the use of a Brookhaven for maybe the total of a man-year in doing some 9 detailed analytical reverification.
10 COHNISSIONER GILINSKY:
Would we actually check 11 calculations?
12 MR. DENTON:
Brookhaven would for us.
The staffs 13 would be involved in the review of the methodology and 14 assumptions and Brookhaven would rerun certain s' elected 15 calculations.
16 CONHISSIONER BRADFORD:
I am sorry, Harold, but 17 how much of a staff effort were you talking about?
Did you l
18 say half a man-year?
19 NR. DENION:
I would say pochaps a man-year total 20 from the staff over the next few months in this effort.
So 21 maybe IEE might have four people essentially full time and l
22 we might have the same number f ull time plus our consultants.
CHAIRMAN PALLADINO:
Over how long a period?
i 23 l
MR. DENTON:
A several month period.
24 CHAIRMAN PALlADINO:
It sounds like a little more 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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53 1 than a staff-year.
2 COMMISSIONER GILINSKY:
I have to say I was a 3 little surprised in listening to the presentation the other 4 day that Dr. Cloud was retained through the engineering 5 department, as I' remember.
So I presume it was the same 6 department that was responsible for the problems in the 7 first place.
I would have expected it to have been handled 8 at some higher level in the, ccmpany.
9 ER. DENTON:
So would I.
That is why I asked his 10 who he reported to.
I had assumed that he would report 11 rather high up in the organization.
12 COMMISSIONER AHEARNE:
To whom is he reporting?
13 MH. DENTON:
I think he reports ---
14 CONNISSIONER GILINSKY:
I think it was an 15 engineering vice president.
To be fair to him, he made the 16 point of saying he doesn't report to any of them but he is 17 retained by them.
18 COMMISSIONER AHEARNE:
No, there is a 19 distinction.
Where the actual contractual money comes out 20 of is sep ar a te, but to whom is he reporting?
l 21 1R. DENTON:
It is like the vice president for 22 engineering.
Maybe it is the Vice Presiden t for 23 Engineering; is that right?
l 3R. ENGELKEN:
Senior Vice President I believe.
24 25 COMMISSIONEB GILINSKY4 2 ell, maybe my concerns l
l l
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SG 1 were misplaced, but I got the impression it was the same 2 area of responsibility 3
COMMISSIONER AHEARNE:
Well, I am not sure it is.
4 That still mar not be high enough.
I am not disagreeing 5 with you.
6 MR. DENION:
I think he should report very high 7 up.
Having gotten the answer we did at the mee ting, I have i
8 not pursued it further to see how many levels there are 9 above the person he is repe r: ting to.
10 Well, if we can go to the last slide.
I can't say 11 a lot about it.
12 MR. FAIKENBERRY If I can clarify that.
I 13 believe Cloud repo'ets to a senior vice president who is over' 14 the Vice President of the Engineering Department.
15 COMMISSIONER AHEARNE:
I see.
16 MR. DENION:
Now looking at the schedule, a lot of 17 the schedule has not been developed but the program plan, 18 for example, for the reverification effort I think has been 19 submitted to the staff in draf t and to the parties and the 20 boards and we are looking at the scope of the program plan.
21 I think the reverification of the Blume PGCE 22 interfaces is due to be completed, as I said, about the 23 middle of November and a report supplied there.
It is my 24 understanding that the technical report which would 25 reanalyre the errors found in the interfaces and provide a ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
s 55 1 basis for modifications is expected around the end of the 2 year.
3 CHAIRMAN PALLADINO:
What is this technical report 4 again?
5 HR. DENTON:
This would be for those errors found 6 in the containment annulus and the weights and the spectra.
7 The technical report would contain a reanalysis of that 8 annalus, the development of new spectra, proper weights and 9 new floor input and list the pipe supports and hangers and 10 changes that had to be made in the plant and the basis for 11 those changes.
So that would be an engineering document.
12 COMMISSIONER AHEARNE:
And it is on that that you 13 currently would expect to ask Frookhaven to rerun some aets 14 of calculations?
15 MR. DENTON:
Yes.
Now no schedule has ret been 16 developed for the expanded reverification effort that we 17 have described today and that is covered by the last three i
18 bullets and it is my understanding tnat no contracter is l
19 selected either for it.
i COMMISSIONER GILINSKY Does Brookhaven have a l
20 i
21 group of seismic engineering?
3R. DENTON:
'Je have used them in the five-plant l
22 23 shutdown.
That was original use of them and they have 24 developed an expertise in seismic analysis of piping 25 especially.
l ALDERSoN REPCRTING COMPANY. INC.
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s 56 1
CH AIRMAN PALLADINO:
Forrest.
2 MR. Rh'NICKt Harold, in the Cloud proposed 3 reverification program there is one aspect that I don't 4 think has been referred to yet and I would be curious if the 5 staff has taken a position.
6 He talks about an independent qualification, and I 7 add the word to that of calculations, as I read what he 8 means, in which he truly proposes that you not only check 9 calculations that others have done but that you start over 10 basically from the basic information and independently do 11 the calculations on the sampiinq plan.
I realize that that 12 is just a proposal, but what I was wondering is has the 13 staff taken any position on that aspect of the Cloud 14 proposed expanded verification program?
16 MR. DENTON:
The plan for the scope of that 16 reverification program has been submitted to the staff for 17 review and my staff and Dick's staff have looked at it and 18 ve are on the verge of responding to that.
Let me see if anyone can speak to the issue you 19 20 raised.
(No responsc.)
21 MR. DENTON:
Apparently it is still under 22 23 development and we have not yet commented back to the 24 company on that proposal of their consultant.
MR. BEMICK:
We would have some comments on that, 25 ALDERSoN REPORTING COMPANY. INC.
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57 1 on. this multiple sampling, from the standpoint of defining 2 what are the confidence levels desired and what are the
?
3 desired acceptable results.
What results.are you looking
.U
,4 f or, wha t percentage of f ailures or acceptances.
5 COMMISSIONER AHEARNE:
I would be very interested 6 in that. ' That is what I was trying to get at earlier.
7 Acceptance criteria basically.
'8 MB. REMICKs Yes, both on a confidence level and 9 the acceptance of what.
10 COMMISSIONER AHEARNE:
On a related point to that, 11 do you havs some comments you could make on the level of 12 accuracy that you are looking f or throughout this process?
13 My experience in the past had been that the whole area of 14 seismic engineering was one in which large factors of 15 uncertainty were normally found.
16 Another way of asking the question is if you find 17 a calculation is off or a recalculaton changes the number by 18 ten percent, in your mind is that significant or not?
19 MR. DENION:
'Je would like the plant to be 20 restored to the conventional margins that exist in our l
21 cri te ria.
Now if you ask a diff erent kind of question as to l
l 22 how important is the probability of f ailure of a piece of 23 equipment to stresses within ten percent, we think there is 24 a lot of margin in our normal requirements.
But our l
25 approach here is to re-establish the nargins that did exist.
l f
I ALDERSoN REPORTING COMPANY.INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554 2345 58 1
There is a big dispute, as you know, between 2 ourselves and industry about whether margins are excessive 3 or not and I would not propc=
in this case to modify that.
4 COMMISSIONER AHEARNE:
Having lived through that 5 five-plant shutdown and gone through all of those sets of a calculations, my conclusion is that unless there has been 7 some great breakthroughs in the last two years in the area
' ~
8 of seismic analysis that it is still one where differences 9 of 10 or 15 percent are well within the reliability of the 1'o e a l c u l a t i o n.
11 MB. DENTON:
Let me ask our engineering department 12 if they would like to comment on that.
This is Jim Knight 13 from our Division of Engineering.
14 ER. KNIGHTS Jim Knight from the staff.
I think 15 roa have' characterized it very well, Commissoner Ahearne.
16 Accually levels of 10 or 15 percent are nominal and to be 17 expected.
Typically in any other review, be it a licensing 18 case or a special problem, where we do an independent piping 1g analysis such as we intend to do here, you would very 20 c ar ely, even using the same codes and the same basic input, 21 get exactly the same number.
For engineering purposes as long as you meet 22 23 basically the cod' O.clteria, then both the technical and the 24 legal, if yo~ : 3.1, requirements are met.
M fi - DENiv&-
This concludes our planned 25 ALDERSOM REPORTING CokPANY,INC.
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w-59 1 presentation.
As you sention, there are a number of letters 2 and correspondence that you have received from other parties.
3 COMMISSIONER AHEARNE:
Let me ask one other minor 4 technical question.
In the things that are being' redone and 5 looking over some of the notes, et cetera, that have come 6 in, it led me to conclude that one of the issues was to redo 7 the horizontal floor spectra at least at the floor level.
the items that is being done?
8 Is that one 9
ER. DENTON:
There are so many spectra that it is 10 ha rd to ---
11 COMMISSIONER AHEARNE:
I know, but from the 12 response spectra I gathered it wasn't being redone.
Then 13 rou look at the building response spectra and there is one 14 particular error that seemed to have been f ound.
You have 15 got the wrong spectra being used, but then you have got the 16 weights that are different.
17 Now since you have got the weights redesigned then 18 the response spectra for that floor I would expect would 19 also have to be redone.
True or false?
23
- 58. DENTON:
I have got to get it in the right 21 franework.
Does anyone know tha t issue ?
Obviously they are 22 going to reanalyze the entire annulus area.
Now, you 23 remember when we were out there we did find a case of an 24 incorrect spectra being applied and that is being picked up.
25 3R. KNIGHT:
As you stated, the original problem ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
60 4
1 of course was the vertical spectra.
We haven't seen yet the 2 revised, if you will, or updated weights and weight 3 distributions.
4
'CONNISSIONER AHEARNE:
So you are not sure how 5 significant it might be ?
8 MR. KNIGHT:
Without reserystion, if in fact there 7 is a large-scale redistribution, that is an area that will 8 certainly have to be looked at and there will have to be a e very sound basis for not proceeding.
10 COHNISSIONER BRADFORDa Let me ask a se pa ra te 11 question that also arises out of the weights probles.- As I 12 understood it, thst probles has two different levels to it.
13 One is that the informal diagram used weights that no one 14 could verify and that I take it is something that would be 15 picked up in the kind of review that is being proposed.
16 The other though is that the plant as built in any 17 case had weightc that were different from those in the 18 diagram and therefore those that we used in the seismic 19 d88193-20 What is there about the reviews that are being 21 proposed now that catch that problem, tnat is the plant 22 actually being built differently from the assumptions and 23 calculations that we used to design it?
MR. FALKENBERRY:
Actually what PGEE is doing is 24 25 that they have given the new weights to Blume.
They will ALDERSoN REPORTING COMPANY,INC,
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61 1 take those new weights and then develop new response spectra.
2 COMMISSIONER BRADFORD:
And that corrects it as to 3 this particular problem, but is the overall reviev QA/QC 4 practices in itself going to pick up other instances in 5 which the plant itself was built differently from the 6 assumptions used in putting the design toge ther?
7 That is, apparently there should have been a loop 8 which f ed the different weights back over to Blume and then g Blume would have done a recalculation or someone else would 10 have done a recalculation that would have indicated any 11 other changes that flowed f rom the different weights.
But 12 tha t didnt' happen'at all.
There isn't going to be a piece 13 of paper that doesn't look right.
There is just going to be 14 a f ailure to feed information at all and I am not sure that 15 shows up in the kind of review tha t you a re proposing here.
MR. FALKENBERRY:
I think the problem is that no 16 17 one really knows how the weights were developed that were 18 put on those diagrams.
So they really don't know if ther 19 use the as-built drawings ---
COMMISSIONER BRADFORD:
But even if they had had 20 21 the righ t original weights -- oh, I see wha t you are 22 saying.
They may have used the as-built
--no, but ther 23 didn't use the as-built weights because they aren't the 24 as-built weights that are on the diagram.
3R. FALKENBERRY:
That is correct.
No one really 25 ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHWGToN O.C. 20024 402) 554-7J45
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62 1 knows.
They could have used the as-builts but not included l
2 some aspects of piping or components and what-have-you.
But 3 certainly when you take the new calculations with the 4 current as-builts and include all of the significant 5 equipment they do come out differently.
6 ER. DENTON:
I think since the plant is built you 7 test it.1ust with the as-builts.
In the design phase you 8 are right that they should eventually verified that it was 9 designed with the proper weights as it got built.
10 CONNISSIONER BR ADFORD:
The point is that you have 11 two different possibilities, one of which is that they tried 12 to use the as-built weights and somehow got it wrong.
In 13 that case I assume that will show up in tne review of the 14 QA/QC practices.
The other is that they didn't try to use 15 the as-built weights at all.
If that is what actually 16 happened, then it seems to me that is a different kind of 17 problem and one that isn't necessarily subsumed or found out 18 in a QA/QC review.
19 COMMISSIONER AHEARNE:
But that would depend l
20 somewhat on how significantly different the as-built weights l
21 were from the weights that they originally used because in a 22 lot of the seismic analyses the models that one ends up l
23 using are so much of an approximation and there are so many 24 simplifications built in to what the code is actually I
I 25 running that some of the differences between as as-built l
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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63 1 versus a design will just completely wash out.
2 MR. DeYOUNG That is true.
Rarely in the plant 3 design can you usa the as-built weights.
You just don't 4 know them that early in the design.
So they take what ther 5 know will be conservative values for the design itself and 6 then check them later on.
7 COMMISSIONER BRADFORD:
But these turn out not to 8 have been conservative.
9 NR. DeYOUNGs Pardon?
10 COMEISSIONER BRADFORD:
The weights used turn out 11 not to have been conservative.
12 HR. DeYOUNGs That is right, they were wrong 13 weights.
14 CHAIRMAN PALLADINO:
Are the' weights going to be
~ 15 checked against what was finally constructed?
16 MR. Def0UNG:
They are being checked.
17 MR. ENGELKEN:
I don't think they were necessarily 18 non-conservative.
I don't think we know that yet.
The 19 problem was they could not trace how the weights were 20 arrived at.
I don't think they are necessarily all 21 non-con serva tive.
It was a mix I believe.
HR. MIRAGLIA:
I think a review of the transcript 22 23 would indicate the applicant's position with respect to th e 24 design of the containment annulus. The structure itself 25 assumed a floor loading I believe of 250 pounds per square 1
ALDERSON REPORTING COMPANY. INC,
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64 1 foot with respect to the design of the structure in steel.
2 With respect to the weights used and the weight 3 distribution for the supports with in the annulus, they used 4 somet'aing less than that.
So as I enderstood what the 5 utility was saying last week, it is that the structure and 6 the design of the ctructure and the weight differentials 7 that they are finding are below what they assumed for 8 modeling the structure itse1f and that the distribution in 9 weight now just affects the design of the equipment and 10 piping supports within-the annulus space.
11 I don't know if that clarifies it.
At least that 121s the utility 's view as stated to us last Tuesday.
13 In addition, Dr. Cloud in the description of the 14 program that he was undertaking did indicate that one 15 element of his program would be field verification of I
16 critical piping systems and things of that nature to check i
the as-built design in the field versus what they looked at 17 18 analyticall7 CONHISSIONER BRADFORD:
I think that is the 19 20 importan t point.
CHAIRMAN PALLADINO:
I wonder if I might review 21 22 where we stand or where I think we stand.
We have before us a proposal by the staff for a 23 50.54F letter to the licensee to provide cortain information 24 before a decision is made on further action.
25 ALDERSoN REPORTING COMPANY. INC.
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-I gather from tha discussion that there are some 2 clarifications the staff would like to maka in the details -
3 of the letter, but I think it is incumbent upon the 4 Commission -to indicate whether or not this is the direction 5 it wishes to pursue.
6 There are also letters froa others, including I 7 think two letters from Governor Brown of California who 1
8 proposes a different approach in the independant audit.
I g think we ought to examine whether or not we want to go with 10 the staff approach or whether there is a' desire to broaden 11 the scope to include other proposals,-
12 COMMISSIONER GILINSKY:
Well, they are not 13 necessarily inconsistent.
14 CHAIRNAN PALLADINO:
No, they are not necessarily i
15 inconsistent, but I gather the proposal, for example, that 16 Governor Brown indicated, and he had proposed a committee to 17 oversee the selection of the independent auditor and also to 18 oversee the application of the results.
COMMISSIONER AHEARNE:
Well, he modified that 19 20 slightly in his latest letter.
He pointed out that he 21 wasn' t really questioning the role of the Coamission in 22 naking the final choice, but his point seemed to be that in 23 order to get public acceptance of these reviews, at lea.st the Gove rnor 's staf f 's view was that having a mutually 24 25 agreed upon reviewer was going to be better than having one i
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1 chosen by the compt 37 At least I thought tha t was what the 2 latest letter said.
3 CHAIRMAN PAL 1ADINO:
You may be right. let's see, 4 this is ---
5 COMMISSIONER AREARNE:
The one that came this 8 morning.
7 CHAIRMAN PALLADINO:
Well, I have several of then 8 here.
I think I have the right latter of November 7th.
On 9 page 3 he says: "On the matter that errors at Diablo Canyon 10 be performed by outside experts who are independent of PGCE, 11 they should be persons who have not worked for PGCE on the 12 Diablo Canyon project.
Moreover the outside experts should 13 not be selected unilaterally by PGE but they should be 14 acceptable to all parties in the Diablo Canyon proceeding.
15 The final selection of any independent auditor should be 18 approved by the Commission following the staff's 17 consu tation with all parties.
We have already submitted 18 the staff's suggested list of possible independent auditors."
I think the Commission is going to approve or 19 20 disapprove the selection.
However, it would be based not on 21 consultation with all the parties involved.
That is the way 22 I understood it.
That is one of the differences.
EE. DENTON:
Yes.
23 COMMISSIONER AHEARNE:
Well, I guess there is 24 25 another issue that I more clearly realized in listening to ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 C45
s 67 1 this presentation this morning.
Many of the errors so far 2 are found and how significant they are, we still don't know, 3 correct?
But they seem to be at this interface between PGCE 4 and Blume.
5 MR. DENTON4 Yes.
6 COMMISSIONER AHEARNE:
But that review is almost 7 over.
8 MR. DENTON:
That is right.
That has been the 9 f ocus since the start.
10 CONNISSIONER AHEARNE:
Yes, I understand that.
A 11 lot of the focus upon discussing who is going to be doing 12 the review and what is going to be in that review is not 13 relevant unless one were to (a) disagree with what Cloud has 14 been doing and, (b) disagree in having Cloud do it or decide 15 that somebody else is going to do it.
Correct?
16 MR. DENTON:
Yes.
Or there would be a seeking of 17 a third op.nion perhaps.
There are other differences, too.
18 CHAIRMAN PALLADINO:
And there are other tg consulting agreements to be developed, if I understood you 20 correctly.
21 HR. DENTON:
That is correct.
22 CHAIRMAN PALLADINO:
So one could consider Governor Brown 's approach in those if one chose to do that.
23 24 In other words, a timing problem would not exist.
25 MR. DENTON:
Our proposal wouldn't foreclose the t
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68 1 selection contractors from that list, it just doesn't force 2 it either.
3 Also the letter I think proposes that no fuel 4 loading begin until all of the types of activities we have 5 described have been completed.
That is in their second 6 bullet I believe.
7 CHAIRHAM PALLADINO:
Any other comments on this 8 matter?
9 COHMISSIONER GILINSKY:
Now we might come to that 10 view under your proposal, too, as I understard it, if things 11 turn out badly in the first stage.
12 ER. DENTON:
Yes, that is correct.
And I.vould 13 hope that we would have by the time we have to make a 14 decision about f ual loading some input from these other 15 audits that we would have begun.
16 COMMISSIONER GILINSKY:
In other words, the way 17 you have phased it it assumes that these audits were 18 satisfactory and one could then go on to the next stage.
19 MR. DENTON:
Yes.
COMMISSIONER AHEARNE4 The way you have got it 20 21 pha sed, and tell me if this is correct, you will not 22 actually be able to reach a conclusion as to the 23 significance of the recent erars that are found until 24 sometime in January or February?
I have based tha t on the 25 conclusion that you have said that the technical report ALCERSoN r.EPoRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
69 O'
1 isn't going to be done until the end of the year and then 2 you were going to have Brookhaven redo some calculations.
3 ER. DENTON:
Yes.
4 COMMISSIONER AHEARNEs Is it correct that as far 5 as what to se at least has been the fundamental question of
~
6 how important are these, you aren't really going to be able 7 to tell us that until January or February?
8 MR. DENTON:
We aay be able to do that sooner 9 because we have also asked them for periodic updates of the 10 techincal report.
So if in fact they are able to complete 11 their reanalysis earlier than the and of the year and get it 12 to us in an informal f ashion we could get our contractor 13 checking that earlier.
But I think they are talking about a 14 formal report would be nearer the end of the year.
So to 15 the extent that they are able to accelerate along some 16 schedule system by system or however it is approached we i
17 will follow that also.
l 18 COMMISSIONER AHEARNE:
Does the staff have i
19 modifications that they would have imposed on the Cloud 20 progras ?
I gather you have imposed a number of changes on l
21 PGCE's general program, but how about the Cloud program 22 itself?
NR. DENTON:
I thin.A we definitely will have and 23 24 that is why it is undergoing staff review right now.
Ther 25 have submitted a program plan for Cloud doing to the Blume i
ALDERSON REPORTING COMPANY,INC.
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70 1 interfaces I believe only and we do have comments on the 2 extensiveness of that plan.
3 COMMISSIGNER AHEABNE:
That would go beyond the 4 work to be covered by Cloud in his report due in the next 5 couple o'f days?
6 ER. DENTONa Yes.
7 COHHISSIONER GILINSKY:
Well, it seems to me that 8 since the staff proposal needs to be adjusted in details in 9any case thnt we ought to take the time to decide what we 10 mean by an independent review and one way or another take up 11 the Governor's proposal and decide what we think about it.
12 CHAIRHAN PA11ADIliO I think what the staff means 13 by an independent review has been outlined.
Now maybe you 14 vant something in the document.
The question is should the 15 reviewer be selected by a consortium of parties or rather by 16 the licensee with the approval of NRC7 17 It seems to me that we have to hold the licensee 18 responsible for what work is done, not only for the 19 competency of the people that are selected to make th e 20 : eview, but also its action based on that review.
So I 21 would not by any stretch of the imagination by delegating 22 something to a consortium vant to imply any removal of 23 responsibility f rom PGCE and I think that is germane and 24 tha t is why I don't lean toward the consortium but I do 25 strongly lean toward wanting NRC approval of whoever is ALDERSCN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
71 I selected.
2 Likewise, I think with regard to the application 3 of results that we should do nothing that implies abdication 4 by NBC of its own responsibilities to make sure that 5 whatever is done is done correctly.
6 COMMISSIONER GILINSKY Well, I think that is 7 clear.
8 CHAIBMAN PALLADINO:
There could be implications 9 that might --(Simultaneous Conversations - Inaudible).
10 COREISSIONE3 GILINSKY No, that is true.
I am 11 not saying we end up adopting it.
I am juct saying we need
- 12.,t o ta k e it u p.
13 CHAIRMAN PAllADINO:
I guess one of the things I 14 was interested in finding out, if you are willing te so 15 indicate, is whether or not the approach that the staff has 16 outlined with regard to this letter, with appropriate 17 clarification and other comments that individual 18 Commissionars might make, whether you think this is the 19 direction we should be going so that if this is not 20 direction we don't have the staff do modification of the 23 letter unnecessarily.
COMMISSIONER BRADFORD:
I have no difficulty with 22 23 having the letter redone and looking longer at that 24 approach.
I am though concerned about the independence 25 issue.
I am thinting about the procealing as though there ALDERSON REPORTING COMPANY. INC.
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1 were no separate hearings going on and I just assume this 2 was a power plant near completion and in a state with no 3 contested precesses at all.
Then take the same set of 4 events and assume that we had a letter from the Governor 5 saying that he wanted to be satisfied regarding the adequacy 8 of all the reviews given that the plant had already been 7 licensed and then a bunch of unexpected problems had turned 8 up.
9 T sust say that I think that is a request that I 10 think merits real consideration.
11 CHAIBMAN PALLADINO:
Which part, Pe te r?
12 COMMISSIONER BRADFORD:
The business of the 13 Governor of the af f ected.itate wanting to be assurad that 14 the steps from now on were satisfactory to him as the 15 State's Chief Executive.
That doesn't incline me 18 necessarily to -- (Simultaneous Conversations - Inaudible).
17 CHAIRMAN PALLADINO:
Oh, I want t) give him that 18 assurance.
ig COMMISSIONER BRADFORD:
See, that doesn't
(
20 necessarily incline me toward the consortium proposal i
i 21 because tt.a t gets tangled up in the hearing and the other l
22 parties, and I don't know that we want to go that route at l
23 all.
i 24 But I think that there is a lot to be said for, 1
25 and I am not quite sure how to do it, but for explorine ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASitlNGToN, D.C. 20024 (202) 554-2345
73 1 further the Governor's concerns in this area and making sure 2 that even if we go essentially the staff's route that the 3 concerns of the Governor of California are adequately aired 4 and reflected in the process of reviewing what comes out of 5 the PGEE ' reverification program and conceivably setting up 6 some separate structure, although I must say I don 't know 7 what it would be because I don't think it is the consortium.
8 CHAIREAM PALLADIN0a I think whole process that 9 the staff is trying to develop here is one that would help to assure confidence not only for Governor Brown but for all of 11 us and all of the people of California and the rest of the l
12 nation, for that mat:er, that the problems are being 13 pro perly addressed.
l 14 So I think from that standpoint we are taking an 15 approach that would reflect our interest in Governor Brown's 16 comment to that extent.
i 17 I think it comes down to whether or not we want to l
l 18 have consortium people decide who should make the l
19 independent audit.
20 CONEISSIONER BRADFORD:
Well, I wonder if it 21 really does?
If one states that the only two choices are 22 the consortium doing it or the NBC retaining control, then, 23 as you put it, I don't think we can relinquish our 24 responsibility or let PGCE relinquish some piece of its 25 responsibility to a third group.
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74 1
What I am not so clear on though is whether there 2 isa 't some middle course in which the Governor's specific 3 concerns about the direction in which the review is 4 proceeding are listened to and, to the extent possible, 5 accommodated as that review progresses becabse the 8 alternative, it seems to me, is for him to~be told, sorry, 7 we are doing it our way and you are a participant in the 8 hearing and will have to raise your concerns exclusively in 9 the context of the operating license hearing.
10 I don't think that as a course of action turns out 11 to be very satisf actory either to him or to us, at least 12 compared to acconnodating those concerns within the confines 13 of the review as we eventually approve it.
14 CHAIRMAN PALLADINO:
Well, if you have a specific 15 suggestions?
16 COMMISSIONER BR ADFORD:
Well, I don't at the 17 moment.
I am saying that we should probably do more than 18 the staff proposal currently contemplates even if it isn't 19 the precise consortium proposal that the Governor first i
20 proposed.
21 COMMISSIONER GILINSKY4 Well, the General Counsel 22 made clear at the beginning that this review is really apart 23 f ron the licensing proceeding.
In a wa y the Governor's 24 proposal ties it to that proceeding.
It reflects the 25 configuration of parties in that proceeding.
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On the other hand, we are dealing with the 2 Governor of the State and if he has concerns and has some 3 thoughts about how this ought to be handled, then I think we 4 ought to listen to him.
5 CORMISSIONER AHEARNE Could I ask a question?
I 6 am still I guess somewhat puzzled by where we go with 7 respect to the particular review of the Blume interface 8 because, if I understand it, if we follow, Peter or Victor, 9 the approach in any of its various forms, because I think to the recent submission by the Governor's staff modifies the 11 earlier submission by the Governor's staff, but nevertheless 12 the Governor's representative at the meeting looking in the-13 transcript of the.t meeting says, "I want the record to be 14 clear that the Governor of California said that an 15 independent audit wouldn't be one not done by a party 16 selected exclusively and unilaterally by PGCE."
Now Dr.
17 Cloud would not be what the Governor considers to be an 18 independent audit.
But it is that portion which is assumed 19 to be completed.
20 I think what we are then fared with is is the 21 issue independent of how one would construct this 22 capproacheuent with the Gove rno r ?
Nevertheless, if we say 23 yec, we do want to in soms way work out that concern, it 24 seems that one of the things that would have to be done is to agree the're would be an additional reaudit rework cf that 25 ALDERSOl4 REPORTING COMPANY,INC.
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in te rf ace.
2 COMMISSIONER BRADFORD:
Well, perhaps not.
It 3 seems to me one of the things that would have to be done at 4 that point is that wha tever accommodation were set up would 5 then have to look at the work done to date and decide 6 whether or not it was acceptable.
If it was, fine.
If it 7 wasn-t, than it might have to be expanded or it might have 8 to be dche again.
9 COEMISSIONER AHEARNE You are sa ying that perhaps (Simultaneous Conversations - Inaudible).
10 the 11 CONMISSIONER BRADFORD To the extent that the 12 work is already done, whether by Cloud or by someone else, 13 it seems to me the first step for any next reviewer, whether 14 it is just the NBC or the NBC plus an expert of the 15 Governor's choosing, is going to be to decide how much of it 16 is acceptable.
17 COMMISSIONER AHEARNE:
Well, certainly the NBC f
18 Step is going to be doing that.
l 19 CHAIRMAN PALLADINO:
Well, may I try the following 20 suggestion, if you all agree, that we ask the staff to 21 modif y its letter to clarif y some of the points that were 22 raised this morning and ask any Commissioner who has some l
23 suggestion on how to handle Governor Brown 's concerns to 24 submit them so that we can all revie w them.
Then we can 25 consider them as part of our consideration in a revised I
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202) 554-2345
O 77 1 letter.
2 COMMISSIONER AHEARNE:
I would like to point out 3 that it is not, as I tried to say several times, it is not a 4 Governor Brown concern.
We have many letters in from 5 5 embers of Congress.
We have one, for example, I notice 6 from Congressaan Mineta.
It does not in any way speak to 7 Governor Brown 's suggestion.
It is just speaking to the 8 question of an independent audit and the necessity to g restore public confidence.
So I believe the issue is really 10 broader.
11 CHAIRMAN PALLADINO:
Yes, and I do think it is a 12 real issue.
I think the question of re-establishing 13 credibility is an important part of our task here and we 14 also of course want to be satisfied ourselves that we are 15 getting a truly independent audit.
16 So I was sincere when I said any suggestions that 17 might be forthcoming would be most helpful because that is 18 the way we might be able to put it into the letter itself.
l Is this a reasonable approach for the time being?
tg 20 COMMISSIONER AHEARNE:
Yes.
21 COMMISSIONER ROBERIS:
(Nodding affirmatively.)
22 COMMISSIONER GILINSKY (Nodding affirmatively.)
23 COMMISSIONER BRADFORD:
(Nodding affirmatively.)
CHAIRMAN PALLADINO:
All right.
24 Well now I see we are approaching the adjo urn men t 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
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G 78 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
We did not take up the question of enforcement 2 actions that you said you were prepared to discuss.
I think 3 perhaps that ic going to take more than five minutes.
So'I 4 am going to suggest that we reschedule that for discussion 5 at another time.
We will work on when it is going to be 6done.
Ihat would be a closed session I believe because it 7 involves enf orcement action.
8 Well, if thera is nothing further to come before 9 us now, we will stand adjourned.
10 (Whereupon, at 12425 p.m.,
the public meeting 11 adjourned.)
12 13 14 15 16 17 l
18 i
l 19 2
21 22 23 24 25 ALDERSON REPORTING COMPANY. INC, 400 VIRGINlA AVE, S.W. WASHINGTON. D.C. 20024 (202) 554-2345
m NUCLEAR AEGUI.L*CRT CDMLESSICN Ihis is tc ca.Mif*/ that Cha attached ;rcceedings befers the 7
- /
CCMISSICN MEEIDG in the matter of:.
PUBLIC MEETING - BRIEFINC ON RECENT SEISMIC DESIGN ERRORS AT DIABLO CANYON UNIT 1 l
- Data cf Proceeding:
November 9, 1981 Occk25 llunker:
Flace of Prcceeding:
Washington, D. C.
4cre held as hereis appears, anc cha't. this "is the 'criginal :: ansc:-i;;%
thersc f fct-che file of the Cc:m::1ssion.,
Mary C.
Simons-Official Repertar (~7:ed)
M r
Officisi Repertar (Signat.:r e) e l
. _ _ _