ML20041E876
| ML20041E876 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/01/1982 |
| From: | Dircks W, Dirks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20041E875 | List: |
| References | |
| REF-10CFR9.7, TASK-PICM, TASK-SE SECY-82-089, SECY-82-89, SECY-82-89-1, NUDOCS 8203150207 | |
| Download: ML20041E876 (50) | |
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SECY-82-89 March 1,1982
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s, POLICY ISSUE I
(Commission Meeting) l l
For:
The Commissioners l
From:
William J. Dircks Executive Director for Operations
Subject:
DIABLO CANYON PROPOSED SEi3MIC DESIGN VERIFICATION PROGRAM
Purpose:
To provide the Commission with the staff's con-clusions and recommendations resulting from review of:
(1) the scope and technical adequacy of Phase I of the Diablo Canyon Seismic Design Verification Program proposed by Pacific Gas and Electric (PG&E); (2) the technical competence and corporate qualifica-tions of the contractors proposed by PG&E to implement this program; and (3) the financial, organization, and professional independence of the proposed i
contractors.
Discussion:
On November 19, 1981, the Commission ordered the l
suspension of PG&E's Diablo Canyon license to load fuel and conduct tests of up to five percent of rated power pending satisfactory completion of a number of j
specified actions (CLI-81-30).
Among these actions was verification of the adequacy of implementation of all seismic service-related work performed prior to June 1978 used in the design process fpr safety-related structures systems and components.
CL I-81 -30 also required the licensee to submit to the NRC a detailed program for the conduct of the proposed seismic design verification program and information concerning the technical competence and independence of the proposed participants in the proposed seismic verification program.
CONTACT:
H. Denton, NRR Ext. 27691 8203150207 820304 PDR 10CFR PT9.7 PDR
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The staff has prepared a report, provided as Enclosure 1, which addresses the scope of its review and its findings with respect to program adequacy and contractor competence and independence.
The documents retied upon are listed in the report.
The staff met on several occasions with the licensee and representatives of the Governor of California and Joint Intervenors.
In addition, the staff has conducted a number of inspections of the licensee's activities and has had a number of technical observers witnessing the conduct of the ongoing design verification work at the offices of PG&E and its proposed contractors.
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Conclusions:==
Based on our review of the proposed Diablo Canyon seismic design verification program, we have reached the following conclusions:
1.
With respect to the technical adequacy and scope of the proposed seismic design verification, we believe that the Phase I program is acceptable and, if properly implemented, would meet the criteria specified in CLI-81-30.
Secondly, we believe that the proposed seismic design verification program considers appropriate elemeats of the seismic design and quality assurance programs for Diablo Canyon in sufficient depth to allow determination of whether there is reasonable assurance that the overall seismic l
design is in conformance with the application to permit fuel loading and operation of the plant up to five percent of full power.
E 2.
With respect to the competence of those contractors proposed by PG&E to carry out the design verifica-tion program, we believe that the necessary experience and technical skills are being provided.
However, the size of the Robert L. Cloud Associates, Inc., (Cloud) and R. F. Reedy, Inc., (Reedy) professional organizations is relatively small (19 and 6 respectively, some of which are part-time), and lacks a robust technical infrastructure.
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. 3.
With respect to the independence of the contractors involved, we believe that the in-dependence of Reedy and Teledyne Engineering Services (Teledyne) appear acceptable in view of those independence criteria provided in the Commission's February 1,1982, responses to Congressmen Dingell and Ottinger.
Although Cloud appears to satisfy most of the Commission criteria for independence, namely, competence, previous involvement in specific work being reverified, and stock, family or employee ties to PG&E, we do not consider that this contractor is sufficiently independent from PG&E from a financial standpoint based on the level or work (48%) done in 1981 prior to the initiation of this program and the current level of work (70%) currently being undertaken for PG&E.
Such a level of business is considered to be prejudicial to the independence of the design verification program, even though we do not currently see evidence of such prejudice.
To summarize our conclusions, we believe that the scope and technical adequacy of the Phase I seismic design verification program and the competence of the individuals involved are acceptable.
The financial dependence of the Cloud organization on PG&E poses an apparent ccnflict.
Recommendations:
We recommend that a contractor with little prior financial involvement with PG&E and a large, experienced staff in nv:. ear plant design and quality assurance, such as Teledyne, be given responsibility for the performance of the Phase I program.
This contractor should have all other contractors for this program under its control.
Since we do not consider the apparent lack of financial independence of the Cloud organization to have invalidated his findings to date, these technical results could be adopted by the new contractor to the extent they are evaluated and found responsive to the Commission's Order.
This contractor's role should include the following items, to be defined in the program plan and implementing procedures:
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' 1.
Evaluate the scope, depth, and quality of the previous work performed in connection with the t
Commission Order.
2.
Perform additional verifications, as detennined necessary by 1, above.
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Examine the corrective action plans for effective-ness (considering such aspects as sample size for further verifications, depth of further reviews, and technical adequacy of proposed hardware changes).
4.
Verify corrective action implementation.
5.
Upon implementation of the above and completion of the Phase I review, provide a statement to PG&E and the NRC indicating:
a.
verification status; b.
findings and corrective actions status; and c.
conclusions regarding the quality and thorough-ness of the verification effort and the implications of the findings and resultant corrective actions with respect to conformance of the as-built design to the application.
6.
In performing the abc/e activities, this contractor should report independently to PG&E and the NRC, in a manner which assures that independence is not compromised.
Reports, prcposed findings, findings, etc. should be transmitted simultaneously to the licensee and the NRC, and auditable records maintained on all document reviews and changes.
To effectively implement such a role, Teledyne, if selected, would need to considerably augment its current assignment of technical resources, especially in the civil-structural areas of nuclear power plant design.
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l William' J. Di rcks Executive Director for Operations
Enclosure:
DISTRIBUTION:
l Report on Proposed Seismic Design Commissioners Verification Program Commission Staff Offices EDO ELD ACRS ASLBP ASLAP
ENCLOSURE 1 J
E e
Report on Proposed Seismic Design Verification Program I
4 I.
Background and Introduction I
II.
Independence III.
Qualifications IV.
Verification Program Plan Scope V.
References t
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I.
Background and Introduction On November 19, 1981 the Commission issued an Order to the Pacific Gas l
and Electric Company (PG&E) (CLI 81-30) which suspended the PGSE license for the Diablo Canyon Nuclear Power Plant (DCNPP) Unit 1 to load fuel and to conduct low power tests (Reference 1).
The considerations leading to the Order were initiated by the detection, in late September 1981, by PG&E of an error in the seismic design of equipment and piping in the containment annulus of DCNPP Unit 1.
Subsequently, based upon the results of an inspection performed by NCR Region V Office j
and based upon additional information supplied by PG&E, the NRC staff identified serious weaknesses in the PG&E quality assurance pro-i gram, in particular with regard to seismic service-related contracts.
These findings were of sufficient concern to the Commission re-garding the proper seismic design of DCNPP Unit 1 that the Order was issued suspending fuel loading and low power testing. The Commission Order also required PG&E, as a condition for removing the suspension of the license, to conduct an independent design review of all seismic service-related contracts that were in effect prior to June 1978.-1/ In an attachment to the Order, the Commission set forth the requirements for this seismic design verification program, also referred to as Phase I of the program.
Speci fical ly,
the following is required.
-1/ The quality assurance program and its implementation after June 1978 had been found to be improved.
However, in a letter to PG&E from the Director of the Office of Nuclear Reactor Regulation (NRR),
dated November 19, 1981, PG&E was directed to conduct an independent review of the seismic service-related contracts in effect after Juna 1978 and of all other service contracts before and after June 1978 (Reference 2).
This review and the approval of the results by the staff was made a condition for the consideration of the issuance of a full power license.
This part of the design verification program is also referred to as Phase II.
(1)
Information on all seismic service-related contracts prior to June 1978 including (a) information and results of an independent design verification program, (b) a technical I
report that fully assesses the basic cause and significance
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of all design errors, (c) PG&E's conclusions on the effective-i ness of the design verification program, and (d) a schedule for i
completing any modification to DCNPP Unit 1.
(2) Qualifications of companies proposed to conduct the independent design verification reviews.
(3) A program plan for the design verification programs which should include the elements discussed in paragraph (1) above.
i (4) Biweekly status reports on all ongoing reanalysis efforts and independent design verification programs.
i In addition, the Order states in paragraph (5) that prior to authorizing fuel loading the NRC shall be satisfied with the results of the seismic design verification program and with the necessary plant modifications.
The NRC may also impose additional requirements prior to fuel loading based upon the staff review of the program.
Furthennore, the Commission Order stipulates that the Governor of California and the Joint Intervenors, both of which are parties to the pending operating license proceeding, shall have sufficient opportunity to comment specifically on the company qualifications (paragraph 2 of the Order) and on the program plan (paragraphs 1 and 3 of the Order).
PG&E responded to the Commission Order in a letter to the staff dated December 4,1981 (Reference 3). - The submittal provided detailed information
on (a) the technical qualifications of the companies proposed to conduct the independent seismic verification program for PG&E (paragraph 2 of the Order), (b) the scope of the program (paragraph (1).a of the Order) and (c) the program plan (paragraph (3) of the Order).
In addition, PG&E implemented with this letter a procedure for submitting to the NRC staff biweekly reports to inform the staff of the status of any activities associated with the seismic verification program (paragraph (4) of the Order).
During the course of its review of the PG&E submittal, the staff detennined that additional information was needed for its evaluation.
The staff met on February 3,1982 with PG&E and the proposed organizations to perform the independent review to discuss specific staff questions, including some concerns that had been raised by the staff in a letter to PG&E dated January 28, 1982 (Reference 4).
To expedite the review process the staff has used the verbatim transcript (Reference 21) of this meeting as supplemental information to the December 4,1981 submittal. The findings presented in this report reflect the supplemental information and commit-ments made by PG&E and its proposed contractors.
Additional information was subsequently provided by the organizations proposed by PG&E to conduct the independent seismic verification program as explained below.
R. L.
Cloud Associates, Inc. (Cloud) in letters dated February 10 and 11,1982 provided information on the financial independence and professional qualifications of individuals including those associated with R. F. Reedy, Inc. (Reedy) (References 5 and 6).
Teledyne Engineering Services (Teledyne) in a letter dated February 5,1982 provided information on its program activities (Reference 7), and in a letter dated February 10,1982 to l
F. Maneatis, Senior Vice President, PG&E, provided information on Teledyne's financial interests in PG&E (Reference 8).
However, PG&E will be required
to update the December 4,1982 submittal at a later time to reflect the additional information provided and agreements reached at the meeting and to include the recommendations of the staff discussed in this report.
As stated above, the Commission Order explicitly required that oppor-tunity be provided for the Governor of California and for the Joint Intervenors to conment on the program.
Accordingly, all relevant infor-mation was provided to both parties for their comment.
The Governor of California either personally or through counsel provided written comments and expressed his opinions a number of times throughout the review period (References 9 through 14).
The Joint Intervenors likewise provided comments and opinions (References 15 through 18).
Both parties were also afforded the opportunity to participate and make statements as observers at the meeting on February 3,1982.
Senior NRC management met with both parties on February 17, 1982 specifically to solicit their comments.
A verbatim transcript was taken (Reference 19) and the Governor of California subsequently provided comments (Reference 22).
The staff has considered all comments in its evaluation as discussed in this report.
The Commission Order required in paragraphs 1, 2 and 3 that the verifi-cation program be an independent review.
He' ?ver, the Order did not explicitly provide guidance for the determination of such independence.
The criteria were subsequently developed and are contained in a letter from Chairman Palladino to Congressman Dingell and Ottinger dated February 1,1982 (Reference 20).
These criteria were applied by the staff regarding the determination of independence.
The following is a brief description of the elements of the organization for the Phase I seismic design verification program (i.e., seismic
i service-related contracts prior to June 1978) as proposed by PG&E in their December 4,1981 submittal (Reference 3).
The program will be administered by the PG&E Senior Vice President for Facilities Development.
Cloud will develop and implement the independent review, reporting to the above PG&E Senior Vice President. Cloud has engaged Reedy to develop a program for and perform the review of the quality assurance activities of all organizations with seismic service-related contracts for DCNPP Unit 1.
Teledyne has been designated by PG&E to independently review and evaluate the program and the activities per-formed by Cloud and to report its findings directly to PG&E. According to remarks made by William Cooper at the February 3,1982 meeting, Teledyne will determine the adequacy of the implementation of the verification program by reviewing Cloud's performance and conclusions, and by the results of the Cloud program with consideration of supplementary efforts conducted by Teledyne.
Teledyne will perform supplementary efforts to respond to concerns which Teledyne may generate with respect to the adequacy of the program or the way it is being conducted, or to provide another sample of independent checks on the methods used by Cloud.
The scope of the staff evaluation reported here encompasses the following:
(1 ) As assessment of the independence of companies and individuals proposed to perform the independent seismic design verification
- program, (2)
An assessment of the technical qualification of companies and individuals proposed to perform the independent sesmic design verification program, and 1
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(3) An assessment of the technical adequacy of the scope and plan of
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t the proposed seismic design verification program.
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I Each of the above subjects is discussed in separate sections below.
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II.
Independence Criteria for Independence The Commission's Order (Reference 1) specified that PG&E provide infor-mation which would demonstrate the independence of the companies PG&E proposed to carry out the design verification program.
The criteria to test the independence of the proposed companies were listed in Chairman Palladino's response to Congrassmen Dingell and Ottinger dated February 1,1982 (Reference 20).
The most important consid-eration is the technical competence of the companies or individuals involved.
Further, these parties were not to have had any direct previous involvement with the activities at Diablo Canyon that they were to review.
In addition, five factors would be considered in evaluating their indepen-dence as follows:
1.
Whether the individuals or companies involved had been pre-viously hired by PG&E to do similar seismic design work; 2.
Whether any individual involved had been previously employed by PG&E (and the nature of the employment);
3.
Whether the individual owns or controls significant amounts of PG&E stock; 4
Whether members of the present household of individuals involved are employed by PG&E; and 5.
Whether any relatives are employed by PG&E in a management capacity.
- The Campanies Proposed by PG&E Three companies were proposed by PGSE in the December 4,1981, submittal (Reference 3) to conduct the design verification study:
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Robert L. Cloud Associates, Inc. (Cloud) t 2.
R. F. Reedy, Inc. (Reedy) 3.
Teledyne Engineering Services (Teledyne), a division of Teledyne Industries, Inc.
Cloud has been designated to have overall responsibility for the veri-fication study and reports to PG&E, as described in Section I above.
Reedy is responsible for the quality assurance aspects of the study and is a subcontractor to Cloud.
Teledyne, headed by William Cooper, is to review the work of Cloud and its subcontractors and reports to PG&E.
In a sense, Teledyne is to provide verification of the scope of work reviewed by Cloud and Reedy.
1 Cloud was formed in 1979 to provide engineering and seismic qualifica-tion services to privately-owned utilities.
Although other jobs pre-ceded work done for PG&E, "The PG&E work grew as fast or faster than the company," (Reference 6).
In the first ten months of 1981, 48% of Cloud's reviews were derived from work.with PG&E.
Since the verification program has started, it appears that most of Cloud's resources are devoted to the verification program.
For example, during the ten day work period of February I to February 12, 1982, Cloud's 14-man staff has expended 1500 man hours on this job, an average of over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per man / day.
. Cloud has approximately $400,000 in annual revenues (Reference 21, pp. 217-218; Reference 6).
Reedy was formed in 1981 and provides consulting services dealing with quality assurance, design, fabrication, construction, and licensing.
As a subcontractor to Cloud, Reedy is responsible for the QA aspects of the verification program and reports the results of this QA assessment directly to Cloud.
Teledyne Engineering Services is a division of Teledyne Industries, a multi-billion dollar firm, and employs about 200 persons. The majority of Teledyne's business is related to nuclear power.
Clients include the NRC, the Department of Energy, NSSS suppliers, and approxi-mately 30 electric power utilities (Reference 3).
In 1981 Teledyne derived 64% of its revenues from work with investor-owned utilities (Reference 8).
The role of Teledyne in the seismic design verifications program is to review the effectiveness of Cloud's implementation of the program.
William Cooper of Teledyne reports directly to George Maneatis, Senior Vice President of PG8E.
Previous Work on Diablo Canyon According to the December 4,1981 letter from PG&E to'Mr. Harold Denton, (Reference 3) "While both R. L. Cloud Associates, Inc. and Teledyne Engi-neering Services have been retained previously by PG&E to perform a limited
number of specific engineering services related to Diablo Canyon, these firms will not be permitted to review or audit their own work.
If the design verification effort of either of these consultants involves their own work, arrangements will be made to have this work reviewed by another party."
Cloud has performed three projects for PG&E associated with Diablo Ca nyon.
The three projects include a review of pipe whip restraints, a seismic systems interaction program, and a research program on seismic capability of non-seismic designed components. The seismic systems interaction program is continuing with billings of approxi-mately $200,000 per year (Reference 21, pp. 212-217).
In addition, Robert Cloud was responsible, as manager of the mechanics and materials technology organization at Westinghouse, fcr the dynamic analysis of the NSSS installed at DCNPP Unit 1.
Teledyne has had two projects related to Diablo Canyon: "a project involving two days' consulting by D. F. Landers, senior vice presi-dent, and a major $1.2 million project in response to NRC I&E Bulletin 79-02 concerning pipe support systems" (Reference 21,
- n. 226).
Previous Dnployment by PG&E No individual from Cloud or Reedy has been previously employed di rectly by PG&E.
. Ownership of PG&E Stock No member of Cloud owns any PG&E stock (Reference 5).
One member of Reedy owns 500 shares cf PG&E stock valued at approximately $10,000.
Teledyne Industries owns 400 shares of PGSE stock valued at approximately
$3,000 (Reference 8).
Employment by PG&E of Present Household of Individuals No members of the present households of Cloud, Reedy, or proposed Teledyne employees are employed by PG&E (Reference 21, p. 221; Reference 23).
Employment by PG&E of Relatives of Individual Contractors in a Management Capacity No relatives of Cloud, Reedy, or William Cooper of Teledyne are employed in a management capacity at PG&E (Reference 21, pp. 221-222).
No relatives of Teledyne employees currently considered for assignment to the program are employed by PG&E (Reference 23).
Position of Intervenors Regarding Indepcndence On February 17, 1982, the staff' met with representatives of Governor Brown of California and Joint Intervenors to discuss issues such as the independence of contractors involved in the independent seismic ve'rifica-tion program.
PG&E and Cloud also participated as observers (Reference 19).
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. Essentially, the position of Joint Intervenors and Governor Brown is that the appearance of independence cannot be achieved as long as PG&E unilaterly chooses the contractors. They argue that all consultants are chosen in order to advocate the position of their client.
Regardless of the safeguards which PG&E may take to assure
" independence" they do not beileve it can be achieved.
They view the role of Teledyne in reviewing Cloud as " vague."
In addition, the r
Governor and the Joint Intervenors object to the participation of Robert Cloud on the basis of his previous involvement, while at Westinghouse, in l
the Diablo Canyon license proceedings, including ACRS meetings.
The remedy which the Governor and the Joint Intervenors seek is a process whereby PG&E, representatives of the Governor and the Joint Intervenors, and the NRC jointly agree on an acceptable list of contractors, the selection of which would be the responsibility of the NRC. They feel that Diablo Canyon is a unique situation which requires greater Federal and State cooperation and that a process such as this would assure public public acceptance (Reference 19, pp. 8-10, 44-55, 54, 71-74).
PG&E's Position on Independence It is the PC'E view that the company has complied with the Commision Order.
PG&E suggests that if the Commission wants to monitor the performance of Cloud, they can appoint an inspector to Cloud's office and monitor the work (Reference 19, pp. 85-86).
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. Staff's Position on Independence The staff believes that the independence criteria suggested by the Commission is met by Reedy and Teledyne and that these organizations had relatively little financial involvement with PG&E prior to this verification program. The impact of this current work on Teledyne is likewise not significant. The staff review also shows Robert Cloud's personal financial holdings and family employment ties with PG&E are not likely to be a concern.
Technical competence, which the Commission considers of foremost importan.ce on the selection of a contractor for this program is discussed in Section III of this report. Two important issues remain however. One is previous involvement of Robert Cloud (personally) and Robert Cloud Associates in closely allied work and the other, although not explicit in the Commission's criteria, is the past and current level of revenue provided to Cloud by PG&E. Of the former, it was stated that Cloud would not be involved in work for which they had previous cognizance.
The staff believes that this could be achieved but it could be awkward in some areas since Cloud has overall programmatic responsibility. Of the latter, we do not feel that Cloud is sufficiently independent, from a financial standpoint, from PG&E based on the h'istoric level of support given to Cloud by PG&E.
Such a level of business is, in the staff's viewpoint, prejudicial to the independence of the verification program even though the staff does not currently see evidence of such prejudice.
III.
Qualifications Requirements of the Commission Order The Commission Order CLI-81-30 (Reference 1) required that PG&E provide the NRC with a description and discussion of the corporate qualifications of the company or companies that PG&E would propose to carry out the independent design verification program.
Commission Guidance Guidance on evaluating the qualifications of the PG&E consultants was contained in the February 1,1982, letters from Chairman Palladino to Congressmen Dingell and Ottinger (Reference 20).
These letters state that:
"The most important factor in NRC's evaluation of the individuals or companies proposed by Pacific Gas and Electric to complete the required design verification program is their competence.
This competence must be based on knowledge and experience in the matters under review."
PG&E Program Plan and Staff Findings The qualifications of Cloud, Reedy and Teledyne were submitted by PG&E on December 4,1981 in the seismic design verification program plan (Reference 3).
Additional information on the qualifications of these companies was presented at the February 3,1982, meeting (Reference 21) and in a follow-up letter from Cloud dated February 10, 1982, (Reference 5).
The staff reviewed the qualific,ations of the proposed PG8E consultants described in the seismic design verification program plan of December 4, 1981, and identified two areas where additional information would be needed to reach a conclusion on the technical qualifications.
The staff needed additional information on:
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. the qualifications of individuals in addition to Roger Reedy who would be performing the QA review, and
. the expertise of individuals in civil-structural design and seismic analysis of structures.
These items were discussed in the February 3,1982, meeting.
In response to the first item, Mr. Reedy stated that including himself there are six individuals at the equivalent of approximate four full-time professionals assigned to the effort.
Each individual has had several years of industrial QA experience, and all but one has been a QA manager.
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Regarding the second item, Dr. Cloud stated that he had ratained the services of four structural engineers to verify the civil-structural aspects of the design of the plant.
All four have a Ph.D. dyree in civil or structural engineering.
One member of the group has extensive experience in seismic analysis, another has extensive experience in structural concrete design and a third individual has extensive experience in soil dynamics and l
foundation design.
The fourth member of the group, while somewhat less experienced, has structural steel and structural dynamics analysis I
experience to complement his training.
In addition to these individuals, Cloud has assigned two civil engineers to review the building analysis and soil dynamics aspects.
One has a Master's degree with ten years experience and the other is a recent graduate with a Bachelor's degree.
In the areas of piping, pipe supports and small bore analysis, Cloud has assigned the equivalent of approximately seven full-time professionals.
The majority of the people assigned to this area have Master's degrees
,. I and have an average of approximately ten years experience.
In the areas of component analysis there are four people assigned by Cloud. They are devoting the equivalent of approximately three full-time engineers to this area.
Two of the engineers assigned have Master's degrees and two have Bachelor's degrees.
The average number of years of experience of these individuals is approximately five.
Mr. Reedy and Dr. Cloud each have over twenty five years of experience in their respective fields.
They are both noted in the industry for significant technical and management accomplishments and are both well qualified to manage the efforts they are undertaking.
Teledyne has not provided a breakdown of the individuals that will be assigned to the different areas of reviews, as was provided by Cloud and Reedy.
From the resumes provided in the December 4,1981, submittal (Reference 3), Teledyne has a number of well qualified engineers to assign to the piping and components portion of the verification program which they are conducting.
Teledyne has assigned William Cooper to the task of managing the verification program.
Mr. Cooper has been employed in the nuclear field for thirty years.
He is a recognized expert in the stress analysis of nuclear components and has held management positions throughout his career.
He is well qualified to manage Teledyne effort.
However, Teledyne has not demonstrated that they possess experience in the analysis of major nuclear power plant structures or in soil dynamics.
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Comments by Governor Brown Governor Brown's comments on PG&E's proposed design verification program attached to the February 25, 1981, letter from Herbert Brown to the Commissioners (Reference 22) states that:
"... the size and technical qualification of the proposed review team, as described in Robert L. Cloud's February 10 letter to Frank Miraglia of the staff, appear to be too limited to adequately s
address the widespread number and types of design and construction breakdowns already uncovered."
As noted in the Commission Paper, we believe that the necessary experience and technical skills are being prnvided.
In his February 10, 1982, letter (Reference 5) Cloud has proposed a review team with sufficient breadth and i
depth of technical experience to address the scope of the requirements contained in the Commission Order.
This has, however, necessitated a con-l siderable increase in the number and types of technical skills in the Cloud organization and an increase in the size of the Reedy organization.
Staff Conclusions The staff has reviewed the technical qualification of the Cloud and Reedy organizations and has determined that these companies are qualified to undertake the Diablo Canyon seismic design verification program.
This determination is based upon the increase in numbers and types of skills in these companies that was necessary to respond to the Commission Order.
R. L. Cloud and R. F. Reedy individually have sufficient technical and management experience to lead their respective teams of reviewers.
Cl oud and Reedy have retained individuals who are knowledgeable and experienced in the appropriate areas for this effort.
r The Teledyne organization has well qualified individuals to undertake a seismic verification effort in the piping and components area.
- However, as noted above, Teledyne has not demonstrated technical capability in the civil-structural engineering area.
In order for PG&E to demonstrate that Teledyne is fully qualified to review the program and the activities per-formed by Cloud, we recomend that Teledyne retain additional expertise with knowledge and experience in the design and analysis of major nuclear power plant structures and in soil dynamics.
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IV.
Verification Program Plan and Scope Requirements of the Commission Order As a result of the indentification of serious weaknesses in the quality assurance program implemented by PG&E for certain aspects of the design of Diablo Canyon, the Comission's Order (Reference 1) required PG&E to demonstrate through independent contractors, that all safety-related design activities performed prior to June 1,1978 under all seismic-related service contracts utilized in the design process for safety-related structures, systems, and components were properly performed.
Such a demonstration should include the following items.
(1 )
A review of all quality assurance procedures and controls used by each pre-June 1978 seismic-related service contractor and by PG&E with regard to that contract.
In conducting the review, a comparison should be made of these procedures and controls with the criteria of Appendix B to 10 CFR 50 and the relevant guidelines contained in ANSI N45.2.ll, Section 6.3.1.
Any deficiencies or weaknesses in the quality assurance procedures and controls of the contractors and PG&E should be identified.
(2)
An identification of the organizational interfaces that existed during the performance of seismic safety-re:ated design acti-vities where design information was transmitted between PG&E l
internal design-groups and each contractor.
(3)
A review of the implementation of the quality assurance pro-cedures and controls, including the transmittal of informa-
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1 tion, by each design group contractor.
Deficiencies or weaknesses in implementation should be identified.
(4)
A suitable number and type of sample calculations related to the design of safety-related structures, systems and components particularly in the areas of any identified contractor or PGSE quality assurance weaknesses or deficiencies and criteria for expanding the sample size when problems in verification are encountered.
(5)
A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of design errors found, and their impact on facility design.
(6)
Conclusions by PG&E regarding the effectiveness of the design verification program in assuring the adequacy of the Diablo Canyon design.
(7)
A schedule for completing any modifications to the facility that are required as a result of this program including the bases for modifications proposed as not to be completed prior to fuel load.
PG&E Program Plan PG&E submitted a program plan (Reference 3) that is intended to respond to the requirements of the Commission Order.
The program plan includes the following features.
(1 )
An identification of each of the organizations involved in the seismic design chain.
. (2)
An identification and review of the controlling quality assur-ance documents for each of the organizations including the PG&E Safety Analysis Report for Diablo Canyon, the Quality Assurance Manuals and Procedures applicable for the design activities, and the applicable procurement and design speci-fications.
(3)
A review of the controlling quality assurance documents for compliance with the requirements of Appendix B to 10 CFR 50 as amplified by regulatory guides and endorsed ANSI standards.
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The documents will be reviewed against the following Appendix B criteria at a minimum:
I, II, III,.IV, V, VI, VII, XI, XII, XVI, XVII, and XVIII (Reference 21, slide RR-3).
(4)
A review of the implementation of the quality assurance controls by each of the involved contractors and groups, both within each organization and across organizational interfaces.
The review will address all of the items of work that were performed by each organization and the objective evidence that quality assur-ance controls were applied.
Where it is found that the proper quality assurance controls were not present, a determination will be made as to whether the design activities were neverthe-less properly controlled (Reference 21, p.178).
D !
(5)
Independent analyses of a sample of structures and equipment to verify all steps and interfaces in the seismic design chain.
The process will involve the following steps:
(a) select a sample based on importance to safety, diversity of sample, and sufficiency of size to give a clear understanding of basic engineering work; (b) perform an independent analysis for each sample item, (c) check results of independent analysis against design analysis, (d) issue errors and open item reports, and (e) perform additional verification if errors are found in design or weaknesses are discovered in the quality assurance area.
Comments by Governor and Joint Intervenors Representatives of Governor Brown of California and the Joint Intervenors have provided their comments on the proposed program plan for the design verification effort as noted in References 5 and 6.
The specific comments can be summarized as follows:
(1 ) A number of errors have been identified during the course of the verification effort already underway.
The proposed pro-gram has not devoted much effort to addressing the root causes of these errors.
The program should be modified to accomplish this purpose (Reference 19, p. 24).
(2)
The proposed program does not address all of the criteria of Appendix B to 10 CFR 50 that have been shown to be violated sometime during the design and construction work.
At a mini-l
=
. mum, the proposed program should address Criteria I, II, III, IV, V, VI, VII, X, XI, XV, XVI, XVII, and XVIII (Reference 19, pp. 25-28 and Reference 13).
(3)
The proposed program addresses design veriff cation only and every area investigated has revealed some errors.
Errors may also exist in the constructed features of the plant and there-for the program should be expanded to include a review of the adequacy of the quality assurance program during construc-tion (Reference 19, p. 28 and Reference 13).
(4)
To provide improved assurance of the proper design and con-struction of the plant, two or three systems of the plant should be reviewed in depth by addressing all activities from design to final testing (Reference 19, pp. 56-57).
(5)
The sampling plan for independent analysis should be based on statistical methods. A program similar to that employed at the Marble Hill project should be considered.
(6)
In the February 17, 1982 meeting (Reference 19) the intervenors questioned how the IEEE-323 and IEEE-344 Standards and NUREG-0588 are going to be applied in the verification program.
i
. Staff Findings and Resolution of Comments Based on the staff's review of the program plan proposed by PG&E and I
review of the comments provided by representatives of Governor and the Joint Intervenors, it is concluded that:
(1 )
The proposed program plan as modified by the February 3,1982 meeting and the additional requirements noted in this attachment, should provide an identification and evaluation of any significant seismic design problems and their root causes.
(2)
As noted in Reference 21, PG&E has expanded the listing of Appendix B criteria that will be reviewed to address all aspects of the seismic design effort.
The staff finds this acceptable.
(3)
The Commission Order focused the review effort for Phase I to seismic design activities that involved service-related contractors.
^
The staff presently.. sees no need to expand this phase of the review program to include construction activities, the Appendix B criteria related to construction, or an in-depth review of two or three systems as suggested by the intervenors.
Implementation of the proposed program may lead to an expanded scope depending upon the problems found, but for the present such an expansion is not warranted.
Errors were found only in the seismic design area and
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extensive inspections performed by the NRC Regional Office during i
the course of design and construction provide adequate assurance of acceptability.
(4)
The program plan provides for suitable numbers and types of independent analysis for structures, systems and components important to safety.
(5)
Because of the high seismic hazard and the seismicity of the region, the adequacy of seismic resistance of safety related 4
equipment received a detailed review by the staff.
PG&E made a comitment in the FSAR to adhere to the seismic qualification methods endorsed in the Regulatory Guide 1.100 and IEEE-344-1975 Standard.
The seismic verification program will provide assurance regarding the adequacy of the seismic qualification of equipment.
The IEEE-323 Standard provides guidance for the overall environ-mental qualification of electrical equipment.
The Diablo Canyon environmental qualification review is covered by the require-ments of NUREG-0588 imposed by the Commission t1emorandum and Order (CLI-80-21) of May 23,1980. Requiremefits-afNUREG-0588 are consistent with those of the IEEE Standard 323. Howeve r, the seismic design verification was not intended to cover environmental qualification of equ,ipment.
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, The staff believes that statistical techniques are largely inappropriate for a design verification program.
In our opinica the use of expert engineering experience in choosing the design samples to be verified, in understanding the significance of differences in the results of the sample and original analyses, and finally in determining whether addi-tional samples are required provides significantly greater assurance that all critical aspects of design have been considered.
The staff does support the use of statistical techniques in establishing sample size for programs such as those employed to assess proper pro-duction of items like weldments, or the placement of rebar.
In this connection the sampling effort undertaken on the Marble Hill plant as mentioned by the Governcr's representatives was instituted to evaluate and verify specific fabrication, erection and documentation end pro-ducts for which the use of statistical techniques to establish sample size with established confidence limits is ideally suited.
The program for structures, systems and components are discussed in more detail below.
Structures With regard to the structural sample chosen to be independently analyzed, a single structure, the auxiliary building, has been chosen.
The use of this builaing is judged sufficient to develop a clear understanding of the quality of the basic structural engineering that was accorded the facility.
The number of structures considered as the " population" is
. only four and the auxiliary building is of rather more complex geometry than the containment structure, hence more difficult to model for seismic loading.
In addition, reanalysis of selected substructures of the con-tainment are already being accomplished by both the applicant and the staff.
These reanalyses will provide addition verification of the quality of the current structural design.
With regard to structural acceptance criteria, Dr. Cloud proposes to use deviations of fifteen (15) percent between the design and verification model properties and floor spectra as the criteria for issuance of an Error and Open Item (E01) report.
Deviations of up to fifteen percent are considered normal and have been implicitly accounted for by the design factors approved for usage in design criteria for the plant's. We therefore find this acceptance criteria adequate.
The staff intends to review all structural E01 reports.
If further assessment of such reports shows that significant structural modifications are required, the staff would consider this a basis for expanding the structural verification.
Systems and Components The program plan for the design verification of safety related mechanical systems and components at Diablo Canyon has as its core the independent verification of ten piping problems. Based on the staff review, we have concluded that careful engineering judgement went into the selection of these ten problems so that they provide a representative sampling of piping' from various elevations of the containment, auxiliary and turbine buildings,
o and in addition represent a spectrum of systems used in reaching plant shutdown.
For small bore piping and conduit and cable tray supports in which the same criteria is representative of large lengths of piping or conduit and cable trays, sample sizes were selected based on a review of the methodologies used in establishing the support spacing criteria.
i The program plan of December 4,1981 as augmented by the transcript of the February 3,1982 meeting incorporates the following procedures for I
piping:
1)
The ten selected piping problems are modelled using the actual as-built piping system verified from measurements taken from the piping j
during site visits.
Only design drawings which have been independently site verified will be used in this process.
2)
Each problem is analyzed using a computer code benchmarked as currently required by the staff.
i 3)
Pipe stress, valve acceleration, pipe support loads, and any system component nozzle loads which are products of the verification analysis are compared with those of the original design.
This comparison is done for all the components and supports analyzed as part of the system not merely for the number of supports or valves shown in Table I of the February 3,1982 transcript.
In the case of supports (using an average number of 20 supports per problem), this would be approxi-mately 200 supports rather than the 20 of the table, and, for valves, approximately 24 instead of the 2 shown in Table I.
i i 4)
The program as propused uses a 15% difference value as significant.
In analyzing differences between the results of the piping veri-fication analysis and the design analysis, the staff feels that it will not be satifactory to merely compare and note differences.
Differences might result from modelling assumptions and techniques,
?
or the analytical assumptions, design methodologies and computer l
codes, used in the original and verification analyses.
The staff will review the differences and their causes in reaching its decision on the need to perform verification analyses of additional piping problems or to redo portions of the verification.
Therefore, the staff will additionally require that the results of all of the verification analyses be presented not as simple pass / fail, but with an engineering evaluation that will permit the staff to reach a decision as described above.
With that additional provision, we j
believe that the proposed criteria for reaching a decision whether to perform additional verification are adequate.
As previously discussed, the piping verification analyses are the core of the verification effort of safety related mechanical systems and components and effectively includes within its scope, valves and piping supports. The valves, pumps and heat exchanger which are part of the verified piping systems
(
will have their nozzle loads verified.
In addition, four pumps, two valves, and the same heat exchanger including supports will be reanalyzed to verify l
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0 6 the or.ginal design analysis.
It is not clear from the proposed program plan that the supports of the pumps included in the piping problems will be analyzed.
The staff will require that these pump supports also be analyzed.
In analyzing small bore piping and conduit and cable tray supports, the program will use 200 feet and 20 supports respectively.
The analyses developed by design organizations for these systems result in the i
specification of support spacing criteria, but must also provide for other influences such as concentrated masses represented by valves and their operators, system layout, and any other dynamic loadings which may be p resent.
The staff will require demonstration that these influences have been considered in the review. The staff will also require the analyses representative of each of the original design organizations performing work fer PG&E (including PG&E itself) in this area be verified.
Subject to these two additional provisions we believe the proposed program for small bore piping and conduit and cable tray supports is adequate.
In summary, the verification program as modified by the February 3,1982 meeting the additional requirements contained in this report, the verification program consists of a complete review of the quality assurance procedure and controls for all safety related activities under seismic contracts, independent analysis of selected samples of structures, systems and components, comparing the results of independent analysis against design, issuing error reports, and checking against generic quality lapses. The The staff has concluded that this program should provide reasonable i
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assurance that should there be any major deficiency involving significant reduction in available margin of safety, it will be detected following a proper implementation of the plan under the scrutiny of Teledyne Engineering l
i Services, NRC staff and the intervenors.
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References 1.
Commission Order Suspending License, CLI-81-30, dated November 19, 1981 in the matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Unit 1).
2.
Letter from H. Denton, Director NRR, to M. H. Furbush, General Counsel PG&E, dated November 19, 1981.
3.
Letter from M. H. Furbush, General Counsel PG&E, to H. Denton, Director NRR, dated, December 4, 1981.
4.
Letter from D. Eisenhut, Director, Division of Licensing, to M. H. Furbush, General Counsel PG&E, dated January 28, 1982.
5.
Letter from R. L. Cloud to F. Miraglia, NRC, dated February 10, 1982.
6.
Letter from R. L. Cloud to H. Denton, Director NRR, dated February 11, 1982.
7.
Letter from W. Cooper, Teledyne Project Manager, to G. Maneatis, Senior Vice President PG&E, and to H. Denton, Director NRR, dated February 5, 1982.
8.
Letter from W. Cooper, Teledyne Project Manager, to G. Maneatis, Senior Vice President PG&E, dated February 10, 1982 (copy of letter was provided to NRC on February 24,1982).
9.
Letter from E. Brown, Governor of California, to N. Palladino, Chairman NRC, dated October 30, 1981.
10.
Letter from B. Georgiou, Legal Affairs Secretary to Governor of California, to N. Palladino, Chairman NRC, dated November 7, 1981.
11.
Letter from H. Brown, Attorney for Governor of California, to N. Palladino, Chairman NRC, dated November 16, 1981.
12.
Letter from E. Brown, Governor of California, to N. Palladino, Chairman NRC, dated December 17, 1981.
13.
Letter from H. Brown, Attorney for Governor of California, to Chairman Palladino and Commissioners of NRC, dated January 15, 1982.
- 14. Mailgram from E. Brown, Governor of California, to N. Palladino, Chairman NRC, dated January 19, 1982.
15.
D. Fleischaker, Counsel to Joint Intervenors, to H. Denton, Director NRR, dated December 17, 1981.
16.
D. Fleischaker, Counsel to Joint Intervenors, to N. Palladino, Chairman NRC, and Commissioners, dated December 22, 1981.
17.
D. Fleischaker, Counsel to Joint Intervenors, to N. Palladino, Chairman NRC, and Commissioners, dated December 27, 1981.
O 18.
D. Fleischaker, Counsel to Joint Intervenors, to N. Palladino, Chairman NRC, and Commissioners, dated February 5, 1982.
- 19. Transcript of NRC Meeting in San Francisco, Ca. on February 17, 1982 with representatives of E. Brown, Governor of California, and of Joint Intervenors.
I
- 20. Letters from N. Palladino, Chairman NRC, tc, J. Dingell and R. Ottinger, Members U. S. House of Representitives, dated February 1, 1982.
- 21. Transcript of NRC Meeting in Bethesda, Md. on February 3, 1982 with PG&E, Cloud, Reedy and Teledyne.
22.
H. Brown, Attorney for Governor of California, to N. Palladino, Chairman NRC, and Comissioners, dated February 25, 1982.
23.
Letter from W. Cooper, Teledyne Project Manager, to G. Maneatis, Senior Vice President, PG&E, dated February 18, 1982 (copy of letter was provided to NRC on February 26,1982).
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SUMMARY
OF ERRORS i
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I Errors Identified to Date I
Based on our review of all submittals submitted to date by the Pacific Gas &. Electric Company and Robert L. Cloud Associates, Inc., and meetings
?
held on October 9,1981, October 14, 1981, November 3, 1981, January 25, 1982, and February 3,1982.
Enclosed is a. list of the errors found to l
date. In some instances the errors are grouped under one' heading.
For example, item 5 on the list includes the following five errors:
(1) parallel lines which were qualified in design from a single analysis now require two analyses to properly model both configurations;
)
l (2) in two cases a small bore piping snubber required by analysis was not designed;
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(3) two supports containing gaps insufficient for thermal movement; (4) one support was not rigid in the restrained direction; and i
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F (5) one support on a non-safety related pipe had not been qualified to the Hosgri loads as required to prevent interaciton with a safety related pipe.
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i At the February 3, 1982 meeting, we requested that the Pacific Gas &
i Electric Company develop a system that would identify and track all i
i errors and open items (E01s) that have been identified. We expect the i
i next Pacific Gas & Electric._ Company's semi-monthly report to contain a I
l computer printout of all E01s found to date.
In summary, in excess of
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one hundred discrepancies have been found to date.
i n.--
No.
Description of Error Source 1.
Diagram Error - Fan Coolers PG8E ltr. 9/30/81 2.
Misapplication of Vertical Response Spectra Within-Containment Annulus Area. Affected areas included piping, and electrical and cable tray supports.
PG8E ltr. 9/30/81 3.
Use of superceded spectra for design of cable trays and electrical conduit supports.
A total of 15 modifications such as increase size of snubbers, replace angle iron support, and base-plate modifications were identified at this meeting.
10/9/81 Mtg.
4.
Use of incorrect weights in analysis within contain-ment annulus 11/3/81 Mtg.
5.
Piping design errors not associated with diagram error (improper model of configuration, insufficient gap for thermal movement) 11/3/81 Mtg.
6.
Use of filtere'd response spectra in design of regenerative heat exchanger supports 11/3/81 Mtg.
- 7..
Misapplication of response spectra for electrical raceways 11/3/81 Mtg.
8.
Use of incorrect and unconservative seismic input to HVAC fans Nos. S-67, 68, and 69.
In addition, the forced draf t shutter damper qualification showed l
l incorrect seismic definition because gravity was
[
not added to the vertical acceleration.
Cloud ltr. 11/11/81 to PG&E 9.
Differences between the as-built and design conduit support configuration Cloud ltr. 11/11/81 to PG&E 10.
QJestion con:erning proper auxiliary / fuel building floor weights PG&E ltr. 11/18/81 11.
Use of superceded response spectra - control room floor P5&E itr.11/18/81 12.
Misapplication of respones spectra to electrical I
conduits located in main buildings.
PG&'E l tr. 11/18/81 13.
Use of filtered response spectra for accumulator supports PG&E ltr. 11/25/81 14.
QJestion Concerning use of Correct methodology for qualifying electrical raceway supports PG&E ltr.1/8/82 15.
QJestion,Concerning proper installation positioning of three. valves PG&E ltr.1/8/82 9
No.
Description of Error Source 16.
Differences between containment spray isometric
^
drawings and field layout PG8E ltr. 1/8/82 17.
Three raceway supports were found to be at var'i'ance with installation instructions PG8E ltr. 1/8/82 18.
Support is shown as a rigid vertical support, field
, G8E l tr.1/8/82 P
information indicates dead load support only 19.
Mo'dification to fan cooler attachment weld PG&E ltr.1/25/82 20.
Modifications to two tubing supports PG8E itr.1/25/82 21.
Modifications' to small and large bore piping supports PG&E ltr.1/25/82 22.
Conduit support was attached to opposite side of wall-4 installation acceptabld since structural i esponse is identical on both sides of wall. Program being developed to determine if similar situations exist.
PG8E ltr.1/25/82 23.
Use of 1977 instead of 1979 response spectra in North-South direction of Auxiliary Building PG&E ltr.1/25/82 24.
Only partial vertical restraint in combination with correct horizontal restraint used in piping support PG&E ltr.1/25/82 25.
Improper modeling of six valves in annulus area PG&E ltr.1/25/82 26.
Error in digitization of east-west translational hosgri spectra for 140' elevation in the auxiliary building PG&E ltr.1/25/82 27.
Method used to calculate raceway weights may result in underestimation of weights of some conduits.
PG8E ltr.1/25/8
- 28. Modification of all unit 1 single rod supports required to provide restraints in both vertical directions PG&E lt'r.1/25/82 i
29.
Differences between length of pipe run shown on isometric drawings and as-built length.
Three of these kinds of discrepancies were noted in 1/25/82 letter.
PG&E ltr.1/25/82 30.
Differences between location and/or omission of certain items such as tees, flanges, supports as shown on isometric drawings and the as-built configuration.
Five of these kinds of discrepan-cies were noted in the 1/25/82 letter and ten more in-Cloud letter dated 2/11/82 PG&E ltr.1/25/82
No.
Description of Error Source 31.
Main Annunciator cabinet analysis incorrectly assumed that cabinet was rigid in longitudinal direction.
Associated anchor bolts exceed allowable pullout -
load PG&E ltr. 1/25/82 32.
Concern raised about proper application of the soil
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spring considerations with regard to certain of the N-S floor response spectra for the Auxiliary Building
- "NRC Mtg. Sum. dtd. 2/3/82 33.
Use of inappropriate spectra for intake structure roof NRC Mtg. Sum. dtd. 2/3/82 34.
Concern over overstressing of containment polar crane NRC Mtg. Summ, dtd. 2/3/82 35.
Plates shown on DC0-G-M-876 as 1/2 inch thick.
Field inspection showed them to be 3/8 inch thick Cloud 1tr. 2/11/82 36.
Support shown on isometric drawing to be active in the x, y directions.
Field inspection showed the support to be active in the x, y, z directions.
Cloud ltr. 2/11/82 37.
Two lines shown as insulated on isometric drawing.
Field inspection showed them to be uninsulated Cloud ltr. 2/11/82 38.
Support was shown to be active in the vertical direction on isometric drawing.
Field ins ~pec-tion showed two skewed snubbers 20 and 25 degrees respectively from vertical.
. Cloud ltr. 2/11/82 3E.
Spectra have not been provided or scaling criteria defined for support locations above elevaton 140' for the containment interior Cloud ltr. 2/11/82 40.
Spectra have not been lprovided or scaling criteria defined for support locations above elevation 140' for the turbine building Clead ltr. 2/11/82 41.
Test response spec;ra used to qualify the group IV electrical equipment did not envelope the required rMagri response spectra.
Cloud ltr. 2/11/82 42.
Spectra. have not been provided or scaling criteria defined for the piperack attached to the containment exterior Cloud ltr. 2/11/82-43.
Diesel generator oil priming tank qualification analysis used 4% daihping.
Regulatory Guide 1.61 specifies 3% damping.
Also, less than half 'the actual weight of sight-glass level indicator was used in PG&E analysis.
Cloud ltr. 2/11/82
No.
Description of Error Source 44.
The anchor allowables on PG&E drawing 054162 Rev. 3 do not agree with those on DCM-M9, Appendix C, Rev. 7 Cloud ltr. 2/11/82 45.
One support is shown on isometric drawing to be '
active in the EW direction.
Field inspection showed it to be active in both EW and NS directions. Similar directional type discrepancies noted on certain other supports including incorrect location of supports
' Cloud ltr. 2/11/82
- 46..One support is shown on isometric drawing to be active in both the vertical and EW direc-tion.
Field inspection showed a 1/4 inch gap in both directions of restraint.
Cloud ltr. 2/11/82 47.
Fourteen additional piping analyses have been found to contain inaccurately modeled valves PG&E ltr. 2/12/82 48.
One talve list in the Hosgri report was
,not updated as required PG&E ltr. 2/12/82 49.
Certain small bore piping spans exceed standard spacing criteria PGaE ltr. 2/12/82 50.
Two piping thermal analyses used incorrect'.
+
modeling of supports.
PG&E ltr. 2/12/82 51.
Piping with supports attached to contain-ment internal structure above elevation 140' were dynamically analyzed using elevation 140' spectra.
PG&E ltr. 2/12/82 7
52.
Piping, electrical raceways, and supports attached to the containment exterior pipeway were dynamically analyzed using the containment exterior spectra.
FG&E ltr. 2/12/82 53.
Review of piping in the annulus identified i
one case of pipe stress exceeding allowable limits due to a pipe support design with fewer pipe lugs than required by the design criteria PG&E ltr. 2/12/82 i
54.
Review of piping analyses for the revised i
reoriented containment annulus spectra i
identified seven analyses which used i
spectra sets not enveloped by all apprcpriate spectra-
~
PG&E ltr. 2/12/82
(
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l No.
Description of Error Source 55.
Question has been raised concerning dynamic properties used in the seismic qualification of the plant exhaust vent.
PG&E ltr. 2/12/82 56.
In the formulation of the vertical dynamic model of the containment interior structure, some masses were represented incorrectly.
PG&E ltr. 2/12/82 57.
Some of the intake structure maximum absolute accelerations contained in Table 4-53 of the Hospri Report differ from those in the May 1979 Blume Report PG&E ltr. 2/12/82 58.
Question has been raised concerning the use of the correct response spectra for qualification of PORVs and associated block valves.
PG8E phone call to Region Y on 2/24/82 O
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STAFF CONCLUSIONS AND RECOMMENDATIONS ON 1
t PG8E VERIFICATION PROGRAM f
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ELEMENTS OF PROPOSED PG8E PROGRAM PLAN PROPOSED MANAGEMENT ORGANIZATION 1
SUMMARY
OF DISCREPANCIES
SUMMARY
OF VIEWS OF GOVERNOR BROWN OF CALIFORNIA AND JOINT INTERVENORS STAFF CONCLUSIONS STAFF RECOMMENDATIONS I
l I
i
ELEMENTS OF PROPOSED PG8E PROGRAM PLAN EFFECTIVENESS OF DESIGN QA PER SELECTED PARr 50 APPENDIX B CRITERIA
- REVIEW OF QA PROCEDURE AND CONTROL DOCUMENTS
- DETERMINE CONFORMANCE WITH APPROPRIATE APPENDIX B CRITERIA
- REVIEW IMPLEMENTATION OF QA CONTROLS WITHIN DESIGN GROUPS AND ACROSS INTERFACES VERIFICATION OF SEISMIC DESIGN
- SELECTION OF STRUCTURE AND EQUIPMENT SAMPLE
- INDEPENDENT ANALYSES OF SAMPLE ITEMS
- COMPARISON OF INDEPENDENT ANALYSIS WITH DESIGN ANALYSIS
- ERROR AND OPEN ITEM REPORT
- ADDITIONAL VERIFICATIONS WHERE GENERIC IMPLICATIONS FOUND
_1_
R. Vollmer X27207 l
l
PROPOSED MANAGE'iENT ORGANIZATION PACIFIC GAS AND ELECTRIC COMPANY SENIOR VICE PRESIDENT FOR FACILITIES DEVELOPMENT TELEDYNE ENGINEERING SERVICES INDEPENDENT REVIEW l
l ROBERT l. CLOUD ASSOCIATES,'INC.
PROGRAM MANAGEMENT
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R.F. REEDY, INC.
RLCA OTHERS l
l QA ACTIVITIES DESIGN CHAIN &
AS REQ'JIRED INDEPENDENT.
CALCULATIONS l
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! o R. Vollmer X27207
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SUMMARY
OF DISCREPANCIES l
0 IDENTIFIED BY CLOUD 97 6 ERRORS l
t
- 91 OPEN l
O IDENTIFIED BY PG&E 1 14 r
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- 12 ERRORS l
2 OPEN f
0 TOTAL 111 l
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R. VOLLMER
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SUMMARY
OF VIEWS OF GOVERNOR BROWN OF CALIFORNIA AND JOINT INTERVENORS I
l t
- PG&E SELECTED AUDITORS DO NOT ENSURE i
CREDIBILITY AND PUBLIC CONFIDENCE
- ALL PARTIES TO PROCEEDING SHOULD AGREE ON l
LIST OF AUDITORS P
- NRC SHOULD SELECT AUDITOR FROM LIST
- PHASE I AND PHASE II ACTIVITIES SHOULD BE COMBINED INTO SINGLE EFFORT
- PROGRAM SHOULD INCLUDE CONSTRUCTION ACTIVITIES'
- SAMPLING PLAN SHOULD BE EXPANDED I
- ADDITIONAL QA CRITERIA SHOULD BE INCLUDED IN i
REVIEW PROCESS I R. Vollmer X27207
STAFF CONCLUSIONS 0
ADEQUATE SCOPE AND IECHNICAL APPROACH
- INCLUS!ON OF NSS VENDORS
- CONSIDERATION OF STATISTICS IN SAMPLING PLAN
- INCLUSION OF SAMPLE OF STRUCTURAL ELEMENTS 0
PROPOSED CONTRACTORS HAVE TECHNICAL SKILLS AND EXPERIENCE BUT NOT ROBUST
- CLOUD ORGANIZATION TRIPLED
- PART-TIME PROFESSIONALS 0
INDEPENDENCE OF REEDY AND TELEDYNE ACCEPTABLE O
CLOUD'S LEVEL OF BUSINESS WITH PG&E IS CONSIDERED PREJUDICIAL
- CLOUD REVENUE 48% PRIOR TO VERIFICATION PROGRAM
- REVENUE N0w 60-70%
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l R. Vollmer X27207
STAFF RECOMMENDATONS
-- COMPLETION OF PHASE I BY INDEPENDENT CONTRACTOR WITH EXTENSIVE RESOURCES, SUCH AS IELEDYNE
-- ADOPTION OF RESULTS TO DATE PENDING EVALUATION OF RESPONSIVENESS TO COMMISSION ORDER
-- EXPANSION OF PROGRAM PLAN DEFINITION TO HIGHLIGHT:
EVALUATION OF PREVIOUS WORK ADDITIONAL VERIFICATION BASED ON ABOVE EVALUATION EXAMINATION OF CORRECTIVE ACTION PLANS VERIFICATION OF CORRECTIVE ACTIONS REPORTING OF FINDINGS AND CONCLUSIONS REGARDING ADEQUACY OF VERIFICATION EFFORT, IMPLICATIONS OF CORRECTIVE ACTIONS, AND CONFORMANCE OF AS-BUILT DESIGN TO APPLICATION INDEPENDENT REPORTING AND AUDITABLE RECORDS
- R. Vollmer X27207
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