ML20080S388

Testimony of WE Cooper,Rl Cloud,Je Krechting & Rf Reedy on Behalf of Idvp Re Contentions 1,2 & 5-8.Describes Role of Idvp in Verification of Design Work of Plant & How Idvp Performed Work

ML20080S388
Person / Time
Site:	Diablo Canyon
Issue date:	10/14/1983
From:	Cloud R, Cooper W, Krechting J, Reedy R LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Shared Package
ML20080S365	List: ML20080S362 ML20080S388 ML20080S432 ML20080S452
References
ISSUANCES-OL, NUDOCS 8310180361
Download: ML20080S388 (59)

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8 UNITED STATES OF AMERICA NUCLEAR REGULA10RY COMISSION 6

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 8

9 In the Matter of:

PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 0.L 12 COMPANY 50-323 0.L.

13 (Diablo Csnyon Nuclear PowerPlant, Units 1and2)

/ 14 15 TESTIMONY ON BEHALF 0F THE INDEPENDENT l 17 DESIGN VERIFICATION PROGRAM 18 0F 19 Dr. William E. Cooper Dr. Robert L. Cloud 20 Mr. John E. Krechting Mr. Roger F. Reedy REGARDING CONTENTIONS 1, 2 and 5-8 23 24 25 26 27 28 l

8310180361 831014 PDR ADOCK 0500027 u

~1 a ._ .. .

1 2 In the Matter of:

8 PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 0.L COMPANY ) 50-323 0.L.

(Diablo Canyon Nuclea-PowerPlant, Units 1and2)l )

5

)

6 TESTIMONY REGARDING CONTENTIONS 1_.2 and 5-8 7

8 m N ESTIM 9 Q.1: Please state your name, current position, business 10 address and qualifications.

11 l A.1: (WEC) I am Dr. William E. Cooper, Consulting Engineer la for Teledyne Engineering Services (TES), located at 130 Second 13 Avenue, Waltham, Massachusetts, 02254. My educational background 14 and professional experience are sumarized in Attachment 1 to 15 this testimony.

16 (RLC) I am Dr. Robert L. Cloud, Principal in the firm of 17 Rcbert L. Cloud Associates (RLCA), located at 125 University 18 Avenue, Berkeley, California, 94710. My educational background 19 and professional experience are sumarized in Attachment 2 to l

20 this testimony.

21 (JEK) I am John E. Krechting, Project Engineer, with Stone 22 l & Webster Engineering Company (SWEC), 245 Sumer Street, Boston, 23 Massachusetts 02107. My educational background and professional 24 experience are sumarized in Attachment 3 to this testimony.

25 (RFR) I am Roger F. Reedy, Principal in the firm of R.F.

26 Reedy, Inc. (RFR), 105 Albright Way, Los Gatos, California, 27 95030.

28 (1)

1 My educational background and professional experience are 2 summarized in Attachment 4 to this testimony.

3 Q.2: Please describe your participation in the Independent 4 Design Verification Progr6m (IDVP).

5, A.2: (WdC) As Project Manager for TES Project 5511, I 6 managed the efforts of TES as Program Manager for the IDVP as 7 described in A.2 of the Testimor.j Regarding Contentions 1 and 2.

8 lJ (RLC) As the principal of RLCA, I managed 15e firm's ll 9 efforts in connection with the IDVP as described in A.2 of the 10 Testimony Regarding Contentions 1 and 2.

11 (JEK) As Project Engineer, I managed the technical effort 12 of SWEC in connection with the IDVP as described in A.2 of the 13- Testimony Regarding Contentions 1 and 2.

14 (RFR) As the principal of RFR, I managed the firm's efforts 15 in connection with the IDVP as described in A.2 of tne Testimony 16 Regarding Contentions 1 and 2.

17 Q.3: What is the purpose of your testimony?

18 i A.3: (ALL) This testimony describes the role of the IDVP in 19 the verification of design work of the DCNPP-1, and how the IDVP 20 performed its work. In addition, this testimony addresses ,

21 Contentions 1,2 and 5-8 as they relate to the IDVP's work.

22 23 24 25 26 27 28 (ii)

L

y

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.1 CollTEllTI0llS 1 AIS 2 2 "1. The scopo cf the IDVP review of both the seismic and non-seismic aspects uf the designs of safety-related systems, 8

structures and components (SS&C's) was too narrow in the follow-ing respects:

4 (a) The IDVP did not verify samples from each design activity (seismic and non-seismic).

5 (b) In the design activities the IDVP did review, it did not verify samples from each of the design groups in the 6 design chain performing the design activity.

(c) The IDVP did not have statistically valid samples 7 from which to draw conclusions.

(d) The IDVP failed to verify independently the anal-8 yses but merely checked data of inputs to models used by PG&E.

(e) The IDVP failed to verify the design of Unit 2.

"2. The scope of the ITP review of both the seismic and 10 non-seismic aspects of the designs of the safety-related systems, structures and couponents (SS&C's) was too narrow in the follow-11 ing respects:

(a) The ITP did not verify samples from each design 12 activity (seismic and non-seismic).

(b) In the design activities the ITP did review, it 33 did not verify samples from each of the _ design groups in the design chain performing the design activity.

14 (c) The ITP did not have statistically valid sampids from which to draw conclusions.

15 (d) The ITP has failed systematically to verify the adequacy of the design of Unit 2."

16 Q.1: Why was the Independent Design Verification Program

. 17 (IDVP) f or the Diablo Canyon Nuclear Power Plant, Unit 1 (DCNPP-5 18 1) established?

19 A.1: (WEC) On November 19, 1981, the Comission issued i

20 Order CLI-81-30 (Commission Order) suspending portionc of Operat-21 ing License No. DPR-76. At the same time, the NRC Staff issued a

22 , ' letter (Staff Letter) which required additional steps prior to 28 power ascension. The Comission Order and Staff Letter required 24 an independent verification of design efforts performed 25 internally by Pacific Gas and Electric Company (PGandE) or on be-f n 26 half of PGandE by service-related contractors on safety-relsted 27 structures, systems, and components (SSCs). The IDVP was 23 1/2-1

o, s.

1 established in response to the Commission Order and the Staff 2 Letter.

8 Q.2: Which organizations narticipated in the IDVP?

A.2: (All! The participants in the IDVP were as fellows:

4 5 o Teled'/ne Engineering Services (TES) served as Program 6 Manager. In that capacity TES assured that the IDVP 7 was conducted in accordance with approved program 8 plans, including review and approval of all IDVP 9 reports and conclusions.

10 o R.F. Reedy, Inc. (RFR) performed the Design -QA Audits 11 and Reviews and the design office verification of the 12 Diablo Canyon Project (DCP) Corrective Action Program 13 (CAP).

14 o Robert L. Cloud Associates, Inc. (RLCA) verified the 15 scismic, structural, and mechanical aspects of the .

16 design process. t 17 o Stone & Webster Engineering Corporatiet. (SWEC) verified 18 the safety system and safety analysis aspects of the 19 design process.

20 In addition to these major participants, TES retained a 21 number of organizations and individuals to assist the IDVP in 22 specialty areas. Of most importance in this regard was the l

23 participation of Professors Myle J. Holley, Jr., and John M.

24 Biggs, who were sufficiently involved in the review of the civil-25 structural area that they were able to co-approve, with TES, the l

26 resultingInterimTechnicalReports(ITRs).

27 Q.3: To whom did the IDVP Program Manager report?

i 28 l 1/2-2 L_ .) 1

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1 A.3: (WEC) As IDVP Program Manager, TES reported independ-2; ently to NRC (Denton) and PGandE (Maneatis).

8 Q.4: Please sumarize the requirements of the Comission 4, Order and the process which lead to Comission approval of the 1

IDVP Phase I Program Plan.

5l 6 A.4: (WEC, RLC) The Comission Order required performance ,

7; "of 'an independent design verification of all safety-related I

8 activities performed prior to June 1,1978, under all seismic-9 related service contracts utilized in the design process for 10 safety-related structures, systems, and components." In summary, 11 the IDVP was to include the following program elements: QA pro- i 12

~

cedures and controls relative to the related criteria of Appendix 13 B to 10 CFR 50; identification of interfaces between PGandE in-14 ternal design groups and each contractor; implementation of the 15 QA procedures and controls; and selection and performance of 16 sample calculations, with criteria for expanding the sample when 17 probl9ms in verification are encountered. ,

t 18 The program developed in response to the Comission Order l 19 was identified as Phase I and was initially submitted by PGandE's  !

I I 20 letter of December 4, 1981.' During the period December 1981 21 through March 1982 there were a series of meetings involving the 22 various parties to review the proposed program and revisions 28 thereto. These culminated in NRC SECY-82-89 which sumarized the j 24 Staff evaluation of the scope and technical adequacy of the Phase 25 { I program and concluded that the proposed program satisfied the r l

26 ! Comission Order requirements and, if properly implemented, would l l

27 i allow determination of whether there was reasonable assurance 28 that the overall seismic design was in conformance with the  ;

1/2-3 l l

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1 license application. After TES was named as Program Manager, it 2 submitted the Phase I Program Managemert Plan, which integrated 8 previous . submittals and included requirements for TES review and 4 acceptance of IDVP work done prior to March 25, 1982.- An NRC 5 letter to 'PGandE dated April- 27, 1982 approved the activities 6 covered by the' Plan as being responsive to the Commission Order, t 7 to SECY-82-89 as revised and voted upon by the Commission on 8 March 4, 1982, and to previous Staff concerns.

-9 Q.5: -Please summarize the requirements of the Staff Letter 10 and the process wh'ich lead to Commission approval of the IDVP 11 Phase II Program Plan.

12 A.5: (WEC, JEK) The Staff Letter is similar to the Commis-18 sion Order, except that it addresses three aspects: all non-14 seismic service-related contracts prior to June 1978; PGandE 15 internal design activities, without stated restriction as to 16 -date; and all service-related contracts post-January 1, 1978.

17 Based upon the total IDVP efforts to date, on June 18, 1982, 18 -TES developed and transmitted the IDVP Phase II Program Plan to 19 NRC and PGandE. There followed a series of meet *ngs similar to 20 those . held during the earlier period with respect to Phase I, 21 ; which resulted in the Staff position documented by SECY-82-414.

22 l On December 9, 1982, the Commission approved "the Phase II 28 Program Plan of June 18, 1982, including the proposed IDVP l l 24 f Contractors, as modified by the Staff in Enclosure 11 to SECY l l

25 414." This approval was contained in an NRC letter to PGandE

'!6 dated December 25, 1982.

-27 Q.6: Is the distinction between Phase I and Phase II mean-l 28 ingful et this time?  ;

1/2-4 I

,O 1 A.6: (ALL) No, in that there is a more useful distinction 2 'available, that between " seismic" and "non-seismic" considera-8 tions. In using the term " seismic", however, it must be under-4 stood that the review included effects resulting from non-seismic 5 loadings whMh, in accordance with license application criteria, 6 must be combined with the effects of seismic loadings.

7 Q.7: Please identify the IDVP program elements and which 8 organization was responsible for each element.

9 -A.7: (ALL) The program elements are described in Section 10 3.5 of the IDVP Final Report. A convenient breakdown of the 11 program elemei.ts, including subsequent portions of this testimony 12 where each-is addressed, is as follows:

18 Element Q/A No. IDVP Program Element 14 1 9-14 Design Chain

15 2 15 QA Audits and Reviews 16 3 16, 20 Initial and additional sample 17 verification 18 4 17-19 Verification of CAP I

19 5 21-24 Ic'entification and resolution  !

l 20 of concerns 21 RFR, RLCA and SWEC performed element (1). RFR perfor:ised ele-22 ment (2) and the QA audit and the " design office verification" 23 whichwaspartofelement(4).

24 RLCA and SWEC performed elements (3), (5), and (6) in their 25 area of responsibility and RLCA performed the design process ver-26 ification identified as part of element (4). The RLCA area of 27 responsibility included all seismic, structural and mechanical 1/2-5

.. . . .~ -. -

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.- 1 aspects as defined by the IDVP Program Plan and ITR-1, and the 2 verification of the CAP as defined in ITRs-8 and -35.

8 The SWEC area of responsibility included the system design

, 4 aspects of safety-related systems and the performance of safety-5 related analyses for the sample systems and analyses defined by 9 the IDVP Program Plan, and verification of the corrective action

~7 taken by the DCP with respect to the generic concerns identified 8 by the IDVP (ITR-34).

9 All of the .. major IDVP participants were involved in the 10 identification of " basic cause", in the evaluations contained in ,

11 Section 6 of the IDVP Final Report, and in developing the IDVP

.12 ~ conclusions contained in Section 2 of that report.

(

13 Q.8: Please describe the types of reports issued by the 14 ( IDVP.

15 A.8: . (WEC) A description of Program Reporting is included 16 in Section 3.6 of the IDVP Final Report, and can be summarized as 17 follows:

, 18 o The IDVP issued Semimonthly Reports to all parties. j i

19 o The Error or Open Item (E01) File System was used for j 20 l tracking of IDVP concerns. When either the verifica-21 tion of the initial sample or the QA Audits and Reviews 22 determined that an item did not meet verification 4

23 t i

criteria or unresolved issues existed, an Open Item 24 Report (0IR) was issued. An OIR indicated a concern 25 that had not been verified, fully understood, or j 26 assessed as to its significance.

27 - o Interim Technical Reports (ITRs) were used by the IDVP 28 to document programmatic aspects or to report detailed  ;

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I technical results. An ITR was prepared when a program 2 participant completed an aspect of its assigned effort.

8 Most ITRs were technical and provided the results of a 4 completed verification or were in support of an Error, Open Item, or Program Resolution Report. Other ITRs 5:

6 (n, ITRs-1, -8, -34, and -35) were programmatic and 7 used to define the IDVP decision as to the need - for 8 additional verificatfort, additional samples, or verifi-9l cation of DCP activities.

10 o The IDVF Final Report summarizes the IDVP efforts and 11 includes the IDVP conclusions and evaluation in 12 response to the Commission Order and the Staff Letter.

13 Q.9: What is a " design chain", and were design chains i

14 ' identified by the IDVP?

15 A.9: (ALL) As discussed in the IDVP Final Report, Section 16 4.1, the IDVP developed design chains that identified the organi-17 zations involved in the separate but linked process of providing 18 the design for a specific safety-related SSC selected for evalua-Each design chain was develcped from a listing of service-19 l tion.

20 l related PGandE contractors. The specific contractors who P.- an 21 ! influence on the final (as of November 30, 1981) safety-rehted 22 design were identified. Additionally, interfaces were identified between service-related contractors and PGandE.

23 l 24 Q.10: What assurance does the IDVP have that all service-25 related contractors contributing to the final (as of November 30, 26 1981) design were identified?

I 27 l A.10: (ALL) The SSCs subject to Hosgri qualification and  !

l 28 , the participating organizations were identified by RLCA prior to j 1/2-7 f a

F 1 the development of the Phase I Program Plar., so were considered 2 in developing the initial samples. Similarly, the systems for 3 which PGandE was responsible were known at the time the Phase II 4 Program Plan was developed and three SWEC sample systems were 5 chosen accordingly.

6 RFR performed a review of the contractors list early in 7 Phase II, which provided additicaal assurance as to the role of 8 the various organizations. The RFR effort confirmed the earlier 9 RLCA work with respect to Hosgri organizations. With respect to 10 the three SWEC sample systems considered in Phase II, the SWEC 11 design process verification confirmed the RFR developed con-12 tractor list. The remaining organizations to be identified were 13 those involved with PGandE subsequent to January 1, 1978 which 14 were not involved with Hosgri qualification or the SWEC sample.

15 The RFR identification of these organizations was confirmed by 16 I the subsequent QA Audit and Review of PGandE interfaces with con-17 tractors and by the review of the PGandE "lookback" QA review.

I 18 These combined activities provided assurance that the IDVP con- l l

19 sidered the proper service-related organizations in performance  !

20 of the QA Audits and Reviews and the design process verification.

21 Q.11: Which service-related contractors were included in l

l 22 ; t5e design chains identified by the IDVP? j I l 23 A.ll: (ALL) The nine firms were ANC0 Engineers, URS/J. .

24 Blume, Cygna Energy Services (formerly Earthquake Engineering i

25 Services), EDS Nuclear, Inc., Garretson-Elmendorf-Zinov, Harding-

! 26 Lawson Associates, Quadrex (formerly Nuclear Services Corp.),

27 l Radiation Research Associates, and Wyle Laboratories.

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r 1 Q.12: Please explain why other service-related contractors 2 were eliminated from the list of those considered by the IDVP?

8 A.12: (ALL) As stated in Section 4.1.4 of the IDVP Final 4 Report, PGandE had identified 61 safety-related urvice con-5 tractors which were active at any time for seismic and non-6 seismic activities. All of these and their scope of work are 7 identified in ITR-9. Of the 52 contractors not included in the 8' IDVP design chains, 43 were eliminated becaus'e they did not con-l 9 tribute significantly to the final design, that is, they were {

i 10 involved only in licensing or in design studies, they provided I 11 only minor design input, they performed only non-destructive 12 examination (NDE) services, or they provided only design inputs I

is which wero not used in final design.

14 The remaining nine firms were eliminated for the following 15 reasons. Two firms, RLCA and TES, were elicinated because they were participating in the IDVP. Westinghouse was eliminated 16 l I 17 because it is the NSSS supplier. Three firms, James Engineering  !

18 j Company, Kaiser Engineers and Mark G. Jones, were eliminated 1 1 19 ' because all of their work had been performed in the PGandE office 20 under the PGandE QA program. Two firms, Nutech, Inc. and Western r

21b Canada Hydraulic Laboratories, were eliminated because their work 22 ' was subject to separate audit by the NRC. Finally, General i 23 Electric Co. was eliminated because it provided only consulting j 24 services in the testing of switchgear. It is included in this 25 specific listing only because its name had been raised in pre- ,

26 vious dicussions. However, since its part icipation was limited 27 to consulting services, it could have been eliminated on the same {

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1. basis as other firms which did not contribute significantly to 2 the final design.

8 Q.13: Please explain why the elimination of thne con-4 tractors from the IDVP's verification did not detract- from the 5 IDVP's ability to reach its conclusions as to the design of 6 DCNPP-1.

7 A.13: (ALL) Obviously the elimination of the contractors -

8 which did not contribute significantly to the final design had no 9 impact on the IDVP's efforts.

10 Elimination of the contractors named in A.12 did not detract 11 from the IDVP's ability to reach its conclusions for differing 12 reasons dependent upon the specific firms involved. The exclu-18 sion of the IDVP participants (TES and RLCA) was a recognized 14 fact since the beginning of the program, and the Program Plans 15 were approved by the Comission with that exclusion. The exclu-16 sion of Westinghouse is discussed in the testimony regarding 17 Contention 6. The work of the three firms working under the 18 PGandE program was subject to verification as part of the PGandE 19 effort, and thus was included or excluded solely on the basis of l 20 whether it was part of an IDVP sample. Two firms, Nutech and 21 Western Canada Hydraulic Laboratories, were excluded because the 22 specific work performed with regard to DCNPP-1 had previously 23 been reviewed by the NRC, and it was unnecessary to duplicate 24 such effort.

25 Q.14: What was the effect of this design chain effort on 26 the verification performed by the IDVP?

i 27 A.14: (ALL) The nine service-related contractors included 28 in the design chains were all subjected to the IDVP QA Audits and 1/2-10 1

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1 Reviews, in accordance with the requirements of the Commission 2 Order and the Staff Letter. ' Knowledge of the participating 8 organizations was also useful in verification of the design 4 process. Of the nine identified organizations, the work of all 5 but two was included in the initial samples for one or both of 6 the design process verification phases. The two organizations, 7 whose work was not included in the initial samples, were Harding-8 Lawson Associates and Garretson-Elmendorf-Zinov (GEZ). Because 9 of negative results from the subsequent evaluation of the QA 10 Audit and Review, additional verification was performed of the 11 l soils work originally conductad by Harding-Lawson Associates.

12 Because GEZ was known not to be included in the initial sample l 13 for Phase II, particular attention was given to its efforts by 14 RFR, and E01 7001 was opened to assure that additional investiga-15( tion was conducted of an aspect of potential concern. Additional 16 verification resolved the potential concern satisfactorily, and

, 17 the E0I file was closed.

l 18 Q.15: What was the purpose of performing the QA Audits and l

l 19 Reviews?

l 20 A.15: (WEC, RFR) The QA Audits and Reviews were performed 21 to evaluate both the formal QA program imposed for the work and 22 , the implementation of that program. Although QA Audits and 23 Reviews provided certain information in .firect response to the 24 Commission Order and Staff Letter, another IDVP purpose was to 25 obtain background information which might have impacted the 26 extent of design process verification. Based on Phase I experi-27 ence, ar additional step was added for Phase II. If the reviewed 28 organization did not have a formal QA program, or if its formal i 1/2-11 1 I

l 1 QA program was not properly implemented, its actual design con-2 trol practices were evaluated and reported as a part of the QA 3 Audit and Review Report. Additional sampling was considered if ,

4 4 negative results were obtained from the QA Audit and Review of an 5 organization whose work was not included in the initial sample.

6 Similarly, additional verification was considered when the organ-7 ization's work was included in the initial sample, but that 8' sample did not include the negative aspect.

9 Q.16: How were the initial samples chosen for verification 10 of the design process?

11 A.16: (WEC, RLC, JEK) The selection of the initial samples 12 to be used for verification of the design process are indicated 13 in the Engineering Program Plan for each phase. All initial 14 sample activities were performed on work completed on or before 15 November 30, 1981. For both the seismic and non-seismic verifi-16 cations, the initial samples were chosen on the basis of 17 engineering judgement, considering the experience of the partici-18 ' pants in the design of Pressurized Water Reactors (PWRs) and the I

implications of seismic and other operating conditions on such l 19l 20 svstems. 1 21 Q.17: Was the IDVP's work on the initial samples and addi- l l

22 ' tional verifications / samples in the seismic review superseded by l

23 . subsequent events? ,

i 24 A.17: (WEC, RLC) Yes. In response to the seismic design 25 ll concerns identified by June, 1982, PGandE instituted the CAP, ji 26 l which was consistent with and responsive to both the IDVP and the  !

i I

27 ' Commission Order. As described in the PGandE Phase I Final

! i 28 j Report, Section 1.5.2, the CAP included the performance of a i  !

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d 1 broad-based review of safety-related SSCs enveloping and ccrrect-2 ing the previous ITP and IDVP results. The expanded ITP effort 3 provided more complete and consistent documentation of the design 4 work, with all new work performed to the latest approved QA 5 requirements and procedures. Finally, the expanded program was 6 intended to make it unnecessary to review older analyses or cal-7 culations which were being redone. The CAP results became the 8 seismic analyses of record.

9 In response to this action, the IDVP issued ITR-8, "Verifi-10 cation of the Corrective Action Program". This plan included an 11 examination of tha corrective action scope, criteria, and 12 methodology for consistency with the criteria of the license 13 application. It also required that the CAP be audited for proper 14 implementation of the NRC-approved QA requirements, with emphasis 15 on technical interface control and project indoctrinetion. The 16 purpose of these audits was to gain assurance that the very ex-17 tensive CAP was being conducted in a planned and controlled 18 manner.

I 19 l Q.18: What was the scope of the IDVP verificacion of the  ;

I i 20 ' CAP seismic review and how was it accomplished?

l 21 A.18 (WEC, RLC) The scope of the IDVP verification of the j

22 CAP seismic review required a verification of all the CAP 23 activities for each safety-related SSC within PGandE's original i

l 24 scope for design.

25 The IDVP verification program for CAP activities was defined 26 by ITR-8. Prior to preparation of that ITR, the DCP had provided

! 27 its detailed plans in open meetings during the sumer of 1982 and l

28 had described its methodology in sufficient detail for the IDVP 1/2-13

s, ,,

1 to-judge that the CAP was a reasonable substitute for the program 2l of additional verification described by Revision 0 to ITR-1.

8 Specifically, it permitted the IDVP to combine several E01 Files 4 that had either indicated errors in the previous PGandE work, or

'5 .that had raised issues about that work which had not baan 4 6 resolved, into a limited number of generic E0Is which were used 7 to track the IDVP verification of the CAP work. Hence, those

^

8 generic E0Is identified all of the IDVP concerns previously 9 identified and all of the DCP efforts related to the safety-10 related SSCs to which these concerns applied.

11 The general approach of the IDVP toward verification of CAP 12 , activities was intended to develop a sound understanding of all 18 of the engineering used in the design activities subject to the 14 IDVP. The IDVP wanted to understand the rationale, methods and j 15 computer codes used by considering: all the options available; 16 the level and degree of sophistication of models employed; and

[ In short, the IDVP sought to 17 the completeness of the work. .

18 I develop a complete undertanding of the design process and confi-19 dence that the process w?s being properly applied.

20 ', With respect to SSCs, ITR-8 defined the following to be sub-j 21 ject to verification I

22 o Buildings (containment, auxiliary, fuel handling,

}

28 turbine, intake) 24 o Piping (large and small bore, with the supports)

[

i o "echanical and electrical equipment (at least one of i 25l i

26 each type) j i 27 o HVAC equipment and ducts, electrical raceways, and in- f 28 strument tubing, all with supports.

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_ a _ _.. _ _ . _ __. _ _ . _ _ _ _ _ , __ _

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1 The detailed application of this definition is described by the 2 appropriate sections of the IDVP Final Report and in the ITRs a numbered -51 and higher.

4 Three different approaches were followed by the CAP in the 5i performance of its review: a complete reanalysi", a complete 6 review followed by reanalysis of deficient segments and a 7 sampling approach. The IDVP verification methodology varied with 8 the approach followed by the CAP, which is also defined in ITR-8.

9' Given the SSCs subject to verification and the CAP identifi-10 cation of the approach it intended to use for each, it was 11 ; possible for' the IDVP to establish categories of like items,

12. where the term "like" relates to the engineering process required is for qualification. For example, the qualification of piping and 14 supports . involves similar features and uniform methodologies, 15 whereas each of the buildings involves unique features and a 16 differing methodology.

17' For each category, the IDVP reviewed the methodology to be 18 applied, requested and received a complete index of the CAP work le i with respect to the subject SSCs, reviewed that index to assure '

20 that the CAP work was totally responsive to its scope, and then l 21 selected Design Review Packages (DRPs) for detailed review. The f i

22 ' selection of appropriate DRPs was crucial to achieving the 23 objectives of the verification efforts. It was necessary to 24 select DRPs that addressed concerns developed by the IDVP either 25 during earlier verifications or during review of the CAP 26 methodology. It was also important for the IDVP to select a 27 : total set of DRPs sufficient to provide for an evaluation of the I

I entire CAP process and to develop confidence in the implementa-  !

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1 tion of that process. In addition, the DRPs were chosen to re-2 view the CAP work both while in-progress and after completion of 3 a significant portion of the work. In total, approximately 200 4 DRPs were reviewed in detail by the IDVP. Both the available and 5 the selected packages are identified in an appendix in each of 6 the CAP-related ITRs.

7 Upon receipt, each DRP was subjected to detailed review by 8 the IDVP, applying, singularly or in combination, two of the 9 recognized methods for design verification--design review or 10 independent analysis. As questions arose, they were transmitted 11 in writing to the CAP and all responses which the IDVP relied 12 upon were also in writing.

13 After completion of the review of various DRPs, the IDVP 14 applied its improved knowledge of the CAP design process to i

15 develop a comprehensive understanding of that process and of the 16 reeu'.ts obtained through the process. Where, in the opinion of 17 the IDVP, additional reviews were required or where planned 18 reviews could be deleted, the IDVP verification process was i

19 revised. Finally, the IDVP reached its present state of 20 understanding and acceptance of the CAP work.

21 Q.19: Please describe in more detail how the verification 22 of the CAP was performed by considering a specific area of 23 seismic verification.

24 A.19: (RLC) The specific area chosen as an example is the 25 verification of stresses in the containment shell.

Verification of the containment building was reported in 26l 27f ITR-54. That verification included both the interior and 1

28 - exterior concrete structures as well as the polar crane. The l 1/2-16

7 L'

I containment shell and the base slab constitute the exterior 2 structure, which is a Design Class 1 structure. The seismic con-8 ditions considered are Hosgri (both Newmark and Blume), Design

-Earthquake (DE) ar.d the Double Design Earthquake (DDE), each in 4{

6 appropriate combination with thermal effects, pipe reactions, missile impact and internal pressures.

6l '

7 The scope of the DCP work is defined in the PGandE Phase I 8f Final Report, and included a complete review of the dynamic 9 analysis and member qualifications, with physical modifications 10 to be implemented if required. The first step in the IDVP veri- ,

11 fication was to ccmpare the DCP scope to the applicable criteria 12 of the license application to assure that all requirements were 18 being andressed.

14 The second step in the IDVP verification was to review the 15 methodology described in the PGandE Phase I Final Igort with 16 respect to assumptions, modeling techniques and structure-unique requirements. For example, the basic safety function of the con-17f 18 ! tainment shell is to retain pressure during a F:ulted Condition 19 with recognition of all the defined load combinations.  ;

I 20 Therefore, the methodology review included an evaluation of {

the three-dimensional models used for analysis of the containment 21l 22 shell with respect to assumptions, computation of mass and stiff-28 ness properties, boundary conditions and the finite element 24 modeling of the physical structure. The DCP analysis of the 25 overall dynamic response of the containment building was not i

26 reviewed in detail, because such review was performed with 27 ; respect to other stru;tures.

28 i 1/2-17 l

1 Having developed an understanding of the general approach to 2 be applied by the DCP in its review of the containment shell, and 8 considering the IDVP knowledge .of the similarities and

4. differences between . the contai~nment shell and the other 5 structures, the IDVP was in a position to select the DRPs for 6 detailed review._ The first step in this process was the receipt 7 from the DCP of a calculation index identifying all calculations 8 pertinent to the containment building, which is an appendix to 9 'ITR-54. The IDVP examined this index to assure that all 10 calculations required -to perform the work were included, and 11 found that it was complete. The IDVP reviewed this list for 12 the purpose of identifying those DRPs which were to be subjected 13 to detailed review. This selection was made with the objective 14 of reviewing those DRPs which dealt with any previously 15 identified IDVP concerns and those which, when considered 16 together with the dos requested on other subjects, would provide 17 a comprehensive understanding of the DCP procest.

18 With respect to verification of the containment shell, the 19l IDVP requested DRPs applicable to:

i 20 I o Evaluation of the general containment shell using 21 seismic loads from the URS/Blume axisymetric models >

22 (Hosgri) and the associated pressure and thermal loads.

23 o Modeling ind evaluation of the equipment hatch region.

2i o Modeling and evaluation of the base slab /shell junc-25 tion.

26 The first of these calculations permitted review of the general 27 - characteristics of the containment shell. The second and third " l 28l j 1/2-18 i --

I

s *.

1 permitted review of those portions of the containment shell which 2 are usually limiting in the structural capability.

8 Each DRP was then reviewed by RLCA in accordance with a 4 checklist which was designed to ensure that all significant 5 topics are addressed. The main checklist items and guidelines 6 are as follows:

7 o Proper transfer of data from construction (pour lift 8 and shop drawings) to design drawings. Verification of 9 field conditions versus drawings was done on a sample 10 basis.

11 o Limitations of formulas, mathematical models, etc. and 12 impact on results. Degree of conservatism or non-13 conservatism present, if any.

14 o Formulation of mathematical models with respect to 15 licensing commitments and required data. Use of proper I 16 seismic ground motion.

17 o Inclusion of proper degree of freedom, mass, stiffness, i

l 18 and boundary conditions.

19 o Accuracy of results obtained and assessment of any 20 method limitations.

21 o Applicability of the time history and response spectrum 22 analysis methods.

23 o Verification that proper formulas are used.

24 o Verification of the mathematical accuracy of selected 25 calculations.

26 o Verification that all required loads, displacements and 27 ' accelerations are obtained for member evaluation.

28 o Review of all required load combinations and resulting 1/2-19 d

'l stresses against allowables in accordance wit [h the 4 2 specified criteria.

3 o Sample verification of data transfer for both hand cal- .

4 culations and computer runs.

5 o Verification that all calculation files reviewed are 6 properly signed, dated, referenced and approved.

7 Review of each of the DRPs against the applicable portions i I

8 of this check list was intended to assure that the IDVP consider- {

l 9 ed the important aspects of each DRP. ITR-54 includes a summary 10 of the DCP and IDVP results for each DRP.

11 The effort expended by the IDVP for the review, briefly 1

12 - described above, was extensive. RLCA first reviewed each DRP to 13 identify issues where more information was required from the CAP.

14 Following receipt of the additional information, a final review 15 was made. RLCA documented both reviews, and the DCP and RLCA l

16 - packages were reviewed by TES in conjunction with Professors 17 Holley and/or Biggs. Formal Requests for Information (RFI) were 4

18 used by both RLCA and TES to obtain additional information from l the DCP whenever questions arose in the course of the review, and 19l public meetings were held to permit the DCP to explain its 20 l 21 I approach, to answer questions and to identify additional

.22 information which was available through the RFI procese. In the l

23 course of this total verification effort RLCA issued almost 1200 24 RFIs and approximately 40 open meetings were held.

25 It was this extensive effort which enabled the IDVP to reach i

26 l the affirmative conclusions concerning the design of the contain-27 ment shell that are stated in ITR-54 and Section 4.4.4 of the IDVP Final Report.

28 l 1/2-10 1

1 Q.20: Please explain the scope of the IDVP's non-seismic review and why the IDVP believes that this scope was sufficient.

2l 8 A.20: (WEC,JEK) The selection of the non-seismic sample 4 of safety-related systems and analyses to be verified by the IDVP 5 was based on engineering judgement. The objective was to select 6 samples of various types of engineering design work to ensure 7 that generic errors did not exist in the unreviewed design.

8 The first step in the sample selection procedure was to G identify the safety-related systems designed by PGandE and any 10 service-related contractors who performed work that significantly 11 affected the system's final design as oi' November 30, 1981. The <

12 IDVP also identified the various PGandE internal design groups 18 that were responsible for the PGandE designed safety-related 14 systems.

15 Based on this information, the IDVP selected samples of 16 systems such that all of the PGendE design groups responsible for 17 non-seismic system design were sampled. In addition, the 18 service-related contractor who performed the most significant  ;

19 design work in the non-seismic system design area was reviewed.

20 The only other seismic-related contractor which performed system-21 I

related design work was reviewed in detail as to its QA and i

22 , design control practices by the IDVP. See discussion of GEZ in 23 A.14. The IDVP selected safety-related analysis work such that ,

24 all other identified service-related contractors which performed 25 significant non-seismic analyses were sampled.

26 The sel'ected systems were the auxiliary feedwater (AFW) 27 system, the control room ventilation and pressurization (CRVP) 28 i

1/2-21

1 system and the safety-related portion of the 4160 V electric 2 distribution system.

8 The AFW system was selected because its design represents an 4 interrelationship of several design criteria and interfaces.

5 Specifically, it involves interface with NSSS vendor criteria, 6 with containment design criteria, interface of PGandE internal 7 design organizations, and the methodology of determining a water 8 system's mechanical, electrical, and control component design 9 criteria. In addition, AFW systems often appear in the dominant 10 accident sequences in various probabilistic risk assessment prc-11 grams.

12 The CRVP system was selected because it too represents an 18 '

interrelationship of several design criteria and interfaces.

14 Specifically, it involves interface with a service-related con-15 tractor, interface of PGandE internal design organizations, and 16 interface with the control room habitability criteria. It also i

17 represents a contrast of design methods since it is an air system

+ 18 rather than a water system.

I 19 The safety-related portion of the 4160 V electrical distri-L 20 bution system was selected because it is the basic power supply 21 for safety-related electrical equipment. It also represents an 22 interrelationship of several design criteria and involves the 23 interfaces among several PGandE internal design organizations.

I 24 The three sample systems were designed by different engi-25 neering groups within PGandE, thus providing for evaluation of a 26 broad spectrum of the PGandE engineering organization.

27 In addition, the IDVP selected two areas of safety-related 28 analyses for review: the integrated dose analyses; and the tem-1/2-22 I-

.- ~ - - - . _ _. __ - -

i i perature, pressure and humidity analyses as they affect environ--

2 mental qualification of equipment. These analyses were selected 8 since this work was done almost exclusively by three service-4 related contractors and utilized by PGandE. The service-related  ;

6

5 contractors were different and their work involved a flow of I i 6 design information through PGandE engineering groups.

7' For the three selected sample systems, a complete vertical 8 verification of the system design was performed. The applicable

{ 9 licensing criteria were identified, and a system design chain was 10 developed. The system's design was then reviewed to determine if 11 the licensing criteria were satisfied. The review included the 12- aspects of mechanical, electrical and instrumentation and control 13 ' design.

14 In addition, the IDVP performed the following verifications i 15 of the sample systems. The IDVP verified the fire protection

j. 16 provided for the sample systems, including the separation, fire j 17 barriers, suppression and detection systems provided in areas I 18 containing sample system components. The IDVP verified that the-  ;

f 19 AFW and CRVP systems were adequately protected from the effects 20 of a high energy line break (HELB), high energy line crack .

I 21 (HELC), and moderate energy line break (MELB). This was an I

l 22 extensive effort which required identification of all hiya energy i 28 and moderate energy lines in relationship to the AFW and CRVP l 24 I system componeni.s to ensure that these components were adequately 25 protected. The IDVP verified that the AFW and CRVP system com-26 ponents were adequately protected from the effects of internally 27 generated missiles. This again required identification of

! 28

! 1/2-23 ,

i

- _ - . - - .. -- - t

1 potential missile sources and AFW and CRVP system targets to 2 ensure that adequate protection was provided.

8 Although the verification described by the preceding para-4 graph and the safety-related analyses verification (radiation and i

5 pressure, temperature and humidity) previously described were 6 specific to the three sample systems, the design work and 7 methodology reviewed are generic to all safety-related systems in 8 DCNPP-1, and in this sense are horizontal reviews. Thus, these 9 reviews permitted the IDVP to examine a very broad aspect of 10 safety-related design that is applicable to all safety-related 11 systems.

12 In addition, when the IDVP identified concerns that were 18 potentially generic, another review was performed by the DCP for 14 that specific concern for all PGandE designed safety related 15 systems and was verified by the IDVP. These reviews and verifi-16 cations were performed in all areas of analyses of pressure, i 17 temperature and humidity due to HELB; selection of system design 18 pressure and temperature; selection of differential pressure 19 across power operated valves; redundancy of power supplies for 20 shared systems; separation and single failure criteria for ,

l 21 mutually redundant circuits; and jet impingement effects of HELB 22 inside containment.

23 In summary, the IDVP not only performed very detailed and 24 comprehensive reviews of three sample systems which included all 25 the PGandE internal design groups responsible for non-seismic 26 safety-related system design, but the IDVP verification also 27 included work by the service-related contractor who provided the 28 most significant input into the safety-related system design. In l 1/2-24

_ _ _ _ _ _ _ _ _ , _ _ . _ _-._______.o

I I addition, the IDVP performed many verification. of analysis and 2 design functions that are generic to the design or design method-3 ology of all safety-related systems. Moreover, the latter 4 reviews included work from the various PGandE design groups as 5 well as from all service-related contractors performing signifi-6 cant non-seismic design analysis.

7 Based on these extensive and detailed rcviews, the IDVP has 8 achieved a very broad-based and comprehensive understanding of 9 the non-seismic design of the DCNPP-1. It is this broad-based 10 and comprehensive understanding that provides the IDVP confidence 11 in its conclusions as to the adequacy of the non-seismic design 12 of DCNPP-1, as discussed in Sections 2 and 6 of the IDVP Final 13 Report.

14 Q.21: How did the IDVP resolve any specific concern that it 15 identified?

16 A.21: (ALL) Additional verifications were performed to 17 resolve specific concerns if deficiencies were found by the eval-18 uation of the QA Audits and Reviews with respect to the safety-19 related SSCs of the initial sample systems or if the verification 20 criteria were found to be violated.  !

21 Additional sampling was performed either when significant 22 deficiencies in the QA Program or its implementation were 23 identified for an organization that was not a part of the initial 24 sample systam design chain, or when the reasons for the discrep-25 ancies fcurd during design process verification were not clear 26 and additional information was required.

27 Based on the results of each additional verification or f 28 additional sample, the responsible IDVP participant submitted a 1/2-25

1 recommendation to the Program Manager. When the item was deter-2 mined not to have met licensing criteria, this recommendation may 4

8 have included recommendations for additional verification of a

-4 generic concern. When the IDVP determined that the item met 5 licensing criteria, the item was closed and the results reported.

, 6 Q.22: How were generic concerns identified and resolved?

7 A.22: (ALL) The identification of generic concerns was an 8> important part of the IDVP. A generic concern was a concern 9 ,

which could impact design acceptability beyond the inanediate SSCs 10 for which the concern was initially identified. The IDVP conclu-11 sion that a generic concern existed was identified in an ITR 12 (e a , ITRs-1, -34). When generic concerns were identified, the la steps that were taken included, as appropriate, the evaluation 14 of the _ effect of the gener_ic concern on other safety-related i

15 structures and components within the initial sample system, 16 and/or an evaluation of the effect of the generic concern on 17 safety-related structures and components in other systems.

18 Q.23: What did the IDVP do when it determined that cor-l 19 rective action was required?

l 20 A.23: (WEC, RLC, JEK) An item that was determined not to 21 have met licensing criteria was reported to DCP for corrective 22 action, and the IDVP performed verifications of DCP corrective 23 actions. As stated in the Program Management Plan, "After PGandE 24 takes corrective action on an error, or performs physical modifi- '

25 cations to alleviate an error or deviation originating in the 26_ independent program, the PGandE engineering results are subject 27 to design verification by the independent program to assure that 28 proper resolution has been achieved." When IDVP verification of  !

l 6

1/2-26 l

[

i .

1 a corrective action indicated that the corrected item met 2- licensing criteria, the item was considered closed. If verifica-8 tion indicated that the corrective action did not meet licensing 4 criteria, the item was again reported to DCP for continuation of  :

5 corrective action.

6 Q.24: The answer to Q.19 describes how the IDVP resolved 7 its concerns in a specific area of seismic verification. Please 8 describe similarly how the IDVP identified and resolved concerns 9 in a specific area of non-seismic verification.

10 A.24: (JEK) A similar example in the non-seismic area is 11 the IDVP verification process related to the pressure and 12 temperature analysis to determine the environmental conditions 13 for equipment qualification for DCNPP-1, which has been reported 14 .

in ITRs -14, -34, and -47.

15 The verification was performed in accordance with the IDVP I 16 scope of work defined in the Phase II Engineering Program Plan, 17 SWEC Project Procedure 5-2-2, " System Design Verification Pro-18 gram", and the NRC-approved Topical Report, SWQAP 1-74A, " Stone &

19 Webster Standard Nuclear Quality Assurance Program".

20 The sample verified was defined in the Engineering Program 21 Plan to include the temperature and pressure analyses for two 22 representative locations outside containment, one associated with 23 the AFW and the other associated with the CRVP. The scope of 24 work was further defined to include a calculation by IDVP using 25 identical input to the codes used by PGandE or service-related 26 contractors from one specific calculation. The independent ,

i 27 results calculated by IDVP using its codes were to be compared i 28 with the PGandE design analysis.

1/2-27

i 1 Document requests were sent to PGandE to obtain plant 2 specific licensing documents such as Safety Analysis and Evalu-8 ation Reports and plant design drawings. Applicable generic l t

4 licensing documents were also reviewed. The " Design Chain-5 Initial Sample" (ITR-29) indicated that Nuclear Service Corp.

6 (NSC) was the only service-related contractor responsible for the 7 subject analysis.

8 After preliminary review of the DCNPP-1 design documents, 9 two specific locations in the auxiliary and turbine buildings 10 were chosen for the initial sample work. The following 11 activities were then undertaken by the IDVP to verify the 12 analysis of those areas:

is o Two independent blowdown calculations were performed 14 for main steam line double-ended rupture in the select-

-15 ed areas.

ic i o Independent calculations were performed of pressure and 17 temperature transients in two areas. l 18 o A sensitivity study was performed to compare CONTEMPT, the computer program used by NSC, to THREED, the SWEC l 19 20 program used in the independent analysis.

21 The computer sensitivity study revealed that CONTEMPT 22 calculated lower temperatures and could not model adjacent com-23 partments properly. As a result E0I 8001 was issued to report 24 the inappropriate application of CONTEMPT. ,

25 However, IDVP continued the verification procedure to deter-26 mine if further concerns existed. The IDVP's independent 27 pressure and temperature calculations were performed using models 28 and input data developed from the basic plant design documents  ;

1/2-28 l l

i

t 1 and IDVP's blowdown calculations without reference to the exist-2 ing NSC calculations. These independent calculations resulted in 8 higher pressure and temperatures. The NSC analyses were then 4 reviewed and it was determined that the calculation of computer i

5 program input data was not appropriate. Several further E0Is 6 were issued as a result of this review, as reported in ITR-14.

7 In order to perform the above work, the IDVP performed six 8 calculations based on input from approximately 64 drawings, 9 reviewed five NSC calculations and two reports, and performed a 1 10 field verification of as-built geometries used for input calcula-11 tions.

12 In parallel with this analytical design effort, the IDVP O

{

13 f performed a QA audit and review of NSC as described in the 14 Engineering Program Plan. Two E0Is were issued concerning the QA 15 aspects of information used as inputs to the NSC calculations.

16 The IDVP received information concerning all the E0Is issued l l

17 ! for this area of verificatica from DCP during several meetings i 18 l and resolution / completion packages for each E01. The IDVP  !

i i 19 ' reviewed this information and determined that the analytical i 20 errors and the QA concerns addressed in seven E0Is were not j

. i 21 resolved. Therefore, the DCP committed to reanalyze all the j h

22 y pressure and temperature transients to resolve the E0Is. These 23 were combined in E01 8001, which was classified as a Class A/B 24 Error.

25 l Since the CONTEMPT computer program was used for areas out-i l 26 I side containment other than those included in the initial sample, 27 l the problem was considered to be generic and, as such, required ,

i 28 j additional verification. The additional verification was per- '

4 1/2-29 l

I.

1-formed on the DCP reanalysis on a sample basis as identified in 2 ITR-34. The approach taren for this additional sampie was 8

similar to the initial sample with the' exception that more areas 4 were reviewed. Document requests were issued to obtain the cal-5 - culations and results of the DCP reanalysis. Approximately 12 6

calculations were reviewed and the yasults reported in ITR-47.

7 The DCP utilized the Bechtel Computer program FLUD to per-8 form the reanalysis. The IDVP performe.d a sensivity study to 9 compare FLUD and THREED with satisfactory results. The DCP 10 results for the selected areas were compared with the IDVP i 11 independent calculations and were satisfactory. Further, the DCP 12

. calculations were reviewed to determine if the specific concerns 13 identified in the E0I files and related to the initial sample had 14 been addressed by PGandE. The results of this review were also 15 satisfactory.

16 Based on these satisfactory reviews of the reanalysis, no 17 further additional verification was required. The IDVP . Final 18 Report describes the i

initial sample verification in Sec-l 19 tion 4.7.6, the additional verification in Section 4.8.4, the j 20 IDVP findings in Section 5.2 and the causes of E018001 in Sec-21 tion 6.3.4.

22 Q.25: There have been approximately 300 E0Is. Does this l 23 mean that there were 300 errors in the DCNPP-1 design?

l l 24 A.25: (ALL) No. Tce opening of an E0I File meant that a 25 condition had been identified which required additional evalua-26 tion to determine its significance, so a file number had been 27 assigned to track this additional effort. If the additional 28 effort subsequently established that an applicable license appli- l 1/2-30

I cation criterion had been violated, the item would be classified 2 and reported as an IDVP Finding. Many of the E0Is were, of 8 . course, resolved without being established as errors. Further, 4 since the significance of an E0I cannot be determined simply by 5 looking at its eventual classification, it is very easy to over-6 estimate or to underestimate the significance of E01s by a simple 7 " counting" of the files.

8 There is also no general relationship between the eventual 9 classification of a file and the potential for that file to 10 indicate a generic concern. The IDVP carefully considered the 11 generic implication of every E0I, as well as the generic implica-12 tions of possibly related concerns reflected in several E01s, as 13 described in the IDVP Final Report, Sections 5.5 and 5.6.

14 Q.26: In the judgement of the IDVP, was the scope of the 15 IDVP sufficient to provide reasonable assurance that those 16 aspects of DCNPP-1 design which did not meet the criteria of the 17 license application have been identified?

18 A.26: (ALL) Yes. The initial sample and additional sample 19 effort resulted in detailed verification of aspects of the work, 20 a so-called vertical slice. When the IDVP identified conce.ns 21 with respect to specific aspects of these samples, the IDVP work i 22 was expanded in accordance with the program plans to review those 23 concerns as they may have affected other safety-related SSCs, a 24 so-called horizontal slice. Thus, the IDVP program utilized a 25 systematic approach for determining the extent of its review 26 necessary to identify technical concerns. With respect to 27 seismic design, the fact that the DCP undertook an essentially 28 total review of the DCNPP seismic design, subject to verification 1/2-31 l

I i by the IDVP, provides further assurance that technical concerns 2 were identified. Similar, but less extensive, DCP responses were 8 made with respect to non-seismic generic concerns.- For the 4 reasons described in the IDVP Final Report and the previous

-5 i

testimony, in the judgement of the IDVP the scope of the IDVP was

'6 sufficient to provide the assurance sought by the Commission 7 Order and Staff Letter, and such scope was, of course, approved 8 by the Commission. j 9 Q.27: Does this mean that the IDVP identified each and 10 every deficiency in compliance with the criteria of the license 11 application?

12 A.27: (ALL) No. The IDVP was not intended to do this, nor 18 could any reasonable independent verification program. The IDVP l

14 was sufficient, and the procedures utilized to identify concerns 15 effective, to provide reasonable assurance that those aspects of ,

16 the design work on DCNPP-1 performed by PGandE or service-related 17 contractors which did not meet the license application criteria 18 have now been identified. This conclusion should not be inter-19 preted, however, to mean that the IDVP identified each and every l 20 error or questionable aspect of the design product of PGandE and 21 ! its cor. tractors or of the design process they utilized. It does I

22 mean that, in the judgment of the IDVP, there is very little i 23 likelihood that any significant undetected errors exist in such 24 design work i

25 Q.28: Did the IDVP retain a statistician in the conduct of

26 its program?

27 i A.28: (WEC) No. Neither the Commission Order nor the Staff 28 Letter required the use of a statistician in the IDVP efforts.

1/2-32

_ _ _ _ _ _ _ . _ _ _ _ _. _ E

1 Appendix C of the Program Management Plans indicated that the 2I IDVP would arrange for an evaluation of the completed program by 8 an expert in the application of statistics to an engineered 4 system. However, the IDVP tater determined that such an evalu-5 ation was not required, particularly since in its review of the 6 Phase II Program Plan the NRC Staff stated that " Rigorous 7 statistical techniques are largely inappropriate for a design 8 verification program" (see Enclosure 11 to SECY-82-414), and on 9 December 9,1982, the Commission approved "the Phase II Program 10 Plan of June 18, 1982, including the proposed IDVP contractors as 11 modified by the Staff in Enclosure 11 to SECY-82-414." .Neverthe-L 12 less, because issues relating to the use of statistics continued la to be raised by some of, the interested parties ..the IDVP believed 14 that a review of its efforts 5y a statistician should be con-15 l ducted. As described in Section 3.5 of the IDVP Final Report, 16 the IDVP recomended that 'any, proper statistical evaluation 17 l should address the efforts of both the IDVP and the DCP and con-18 curred in the selection of a s'tatistician retained by PGandE.

19 Q.29: In the judgement of the IDVP, was the scope of its l 20 l program sufficient without the participation of a statistician?  !

i 21 A.29: (ALL) Yes. The IDVP never intended to use statistical sampling in its ver1fication program.

~

22 .The IDVP 23 believes that the scope of its review was sufficient without the 24 l participation of a statistician because its program complied with 25 the Program Plans for Phases I and II approved by the Comission 26 and the Staff and because it enabled the IDVP to obtain reason-27 able assurance that the design of DCNPP-1 complies with license ,

i 28 application criteria, as stated in Sections 2 and 6 of the IDVP 1/2-33 .

1 Final Report. The IDVP did not perform analyses to determine 2 whether its sampling was " statistically valid" to any particular 8 statistical confidence level.

4 The _IDVP technical program concept employed an audit and 5 review of design QA in parallel with an engineering program for 6 verification of the design process in a manner which did not -

7 depend upon the effectiveness of the QA program applied in the 8 original DCNPP-1 process. The IDVP verification samples were 9 carefully chosen in both the seismic and non-seismic areas, and 10 the verification was expanded whenever necessary to resolve con-11 cerns that were identified in our original review. All potential 12 concerns were recorded, tracked, and resolved in a systematic 13 manner using the E01 system, and reported in detail in ITRs. In 14 addition, the 10VP was organized to require levels of engineering 15 peer review by different organizations within the program to 16 ensure the validity of all IDVP technical conclusions. The 17 reasons for the IDVP's belief that these samples were properly 18 chosen and suitable for the IDVP's purposes are set forth in the 19 IDVP final Report and the ITRs, and are amply illustrated in A.19 20 and A.24.

21 Q.30: In the conduct of its program, has the IDVP "merely 22 checked data of inputs to models used by PGandE"?

23 A.30: (WEC, RLC, JEK) No. In its verification of seismic 24 design, the IDVP performed a complete independent analysis of the 25 initial sample and additional sample / verification in accordance 26 with the Phase I Program Plan. It, 'is verification of the CAP as 27 defined by ITR-8, and in its verification of the DCP activities 28 as defined in ITR-35, the IDVP used independent calculations on a 1/2-34 l

1 selected. basis as part of the design verification process. In 2 every aspect of the.IDVP's seismic work, the verification process 8it consisted of much more than merely checking data of inputs to

)

4 models used by PGandE.

5 In its verification of the non-seismic design, the IDVP per-

-6 formed independent calculations or analyses, and/or independent 4

7 review of PGandE calculations and analyses in accordance with the 8 Phase' II Program Plan. The majority of the Phase II non-seismic 9 verification consisted of - the performance by the IDVP of in-10 dependent calculations or analyses. The independent calculations 11 and analyses performed by the IDVP used independent models devel-12 oped by IDVP and/or 'different computer programs. In its addi-k 18 tional verification of DCP-performed activities as defined by 14 ITR-34, the IDVP used independent calculations, analyses, and/or 15 field verification for essentially all of the verification 16 effort.. In every aspect of the IDVP's non-seismic work, the ver-17 l ification process consisted .of much more than merely checking L 18 data of inputs to models used by PGandE. j 19 The full extent of the IDVP's verification efforts is {

20  ! spelled out in the IDVP Final Report and the ITRs, and is amply 21 illustrated-in A.19 and A.24.

22 Q.31: Did the IDVP verify the design of the Diablo Canyon j 23 Nuclear Power Plant, Unit 2?

24 A.31: '(WEC) No. The IDVP's review was performed in i 25 accordance with the Commission Order and the Staff Letter, which 26 -contemplated only an independent verification of Unit 1. In l

l 27 addition, the IDVP- completed its work in accordance with the 28 I

1/2-35

1 1 Program Plans, approved by the Comission, which included only 2 Unit 1.

8 Q.32: Was the scope of the ITP's analyses and modifications 4 of the seismic and non-seismic aspects of the design of safety- (

5 related SSCs at DCNPP-1 sufficient for the purposes of the IDVP?

6 A.32: (ALL) Yes. The scope of the ITP's analyseru and 7 modifications was sufficient to respond to all of the IDVP's con-8 cerns, to permit the IDVP to complete its verification in 9 accordance with the Program Plans, and to enable the IDVP to 10 reach the conclusions and evaluations stated in Section 2 and 6 11 of the IDVP Final Report. The design work performed by the ITP l

I 12 for verification by the IDVP is set forth in ITRs-8, -34, and -35 18 and is discussed further in Section 3.5 cf the IDVP Final Report.

14 The results of the IDVP's verification of design activities per-15 formed by the ITP is set out in ITRs-45 to -49 (SWEC), ITR-51 j

16 -(TES) and ITRs-54 to -61, -63, -65, -67 and -68 (RLCA).

17 Q.33: In summary, in the judgment of the IDVP, was the 18 scope of its efforts sufficient that it could properly reach the 19 conclusions and evaluations stated in Sectiors 2 and 6 of the 20 IDVP Final Report?

21 A.33: (ALL) Yes.

, 22 28 24 25 26 27 28 i 1/2-36 i l

l- l

CONTENTION 5 l 1[ '

-2 I "The verification program has not verified that Diablo Canyon Units 1 and 2 'as built' conform to the design drawings 8 and analyses."

4 'Q.1: As part of its verification of non-seismic design, did 5l-the IDVP perform field verifications of implementation of the '

l

63 design of the DCNPP-17 j t

7 , A.1: (WEC,JEK)Yes.

j 8 Q.2: Please explain how such field verifications were per- t 4

91 formed.  !

1 4

A.2: (JEK) As described in the Phase II Program Plan, the

< 10l-11 l IDVP performed independent field verifications to ensure that the

f.  ;

12 y safety-related SSCs in its sample are configured in the same

- p '

13 :i manner as described in the PGandE design documents used in the li 14he IDVP analysis or calculations. The IDVP also independently field I

15 l verified all modifications performed by the DCP to resolve E01s.  !

l 16 i However, the field verifications did not necessarily include all }

i i

17 l of the aspects normally associated with a complete "as-built"

l 1

18 review,- such as material selection and application, fabrication, l 19 examination and inspection (including the pre-service inspection j

' 6 l

20 requirements), system installation requirements, system cleaning, .

i 210 pre-operational testing or wiring checkout, unless these were j

? i' L~ 22 specifically requn ed to support the IDVP's conclusions. .

f 23 The specific IDVP field verifications of as-built conditions 24 n are described in detail in various ITRs. For example, ITR-18 y  :

i. 25 !; describes the field verification of the as-built location of AFW i p 26 d and CRVP system electrical cables / wires to ensure that FSAR ,

! 27Mo separation requirements were satisfied. This ITR also describes l

28 the field verification of the fire zone separation / barriers, f t

j. i i; 5-1

_L. _ _ _ . _ _ _ _ _ _ _ _ . . _ . _ _ . _ . _ _

1 I detection system, suppression system, and special hazards control l 2d for areas containing AFW and CRVP system components to ensure u

3 1 that they were installed in accordance with licensing comit- l 44 ments. Additional descriptions of the IDVP non-seismic field 5 verifications are contained in ITRs -14, -19 through -28, ' 48, -

i O I 61 and -49.

i' U

7l Q.3: As part of its verification of seismic design, did the 8 t IDVP perform field verifications of the implementation of the d

0" design of the DCNPP-l?  ;

10 A.3: (WEC,RLC)Yes.

t 11 Q.4: Please explain how such verifications were performed. l

'l2 A.4: (RLC) Field verifications were performed as part of the seismic design verifications of the initial samples, the ad- l 13 l '

14 ditional verifications, and the verification of the CAP. .

15 , A field verification was performed for the purpose of deter-  !

I l j mining if an SSC was configured in the manner for which it was 16 l  :

qualified. The word " configured" rias used in the IDVP program ,

17 l 18 plans to emphasize that the field verification was a part of the 19 , design verification process and that there was no intention to 20 include the aspect; of material selection and application, fabri-21 (

l cation, examination, or inspection. The purpose was to gain 22 reasonable assurance that the as-built dimensions were properly a

23 d established and used in the design process or in the verification  !

ij As with all IDVP activities, the IDVP applied the 24 program.

criteria on configurations which were intended to be used during 25]! the licensing process. For example, in evaluating the as-built j 26 I

27 l configuration of piping systems, the acceptance criteria were 28 those used with I&E Bulletin 79-14.

l 5-2

i t

• .  %. i l

- 1 i

h The specific field verifications performed are described in 1[ l 2 detail in the various seismic-related ITRs. 'Of ' particular. sig- l 8 f nificance in this regard, because the CAP effort superseded the i earlier activities as described in A.17 of the Testimony on Con-  !,

4}l tentions 1 and 2, are the ITRs numbered above -50, with the l l_ 5 l[l 1 l

6 exception of ITR-68. In each case the field verification was -

l 79 performed by a joint Rt.CA-TES team working with specific check-8 ,

lists. Field verifications were performed as required with 9 respect to the specific DRPs being verified, were sometimes per-10 formed before selection of the DRPs either to assist -in the 11 IDVP's understanding of the methodology or to help to select the 12 , DRPs, and were performed as a part of the " completion sample" to i i 18 assure that intended modifications had been implemented. -1 i .

l' 14 Q.5: Did the IDVP include within its scope any other veri- ,

15 j ^

~fication relating to the conformance of the DCNPP-1 "as-built" to 1 l

16 design drawings? l 17 A.5: (WEC, RFR) Yes. As part of the audit of the implemen-18 tation of the CAP, RFR audited the procedures for engineering l_

19 } review of design changes recommended in the field and the related i  !

( 20 ; procedures for incorporating field changes into the final design l

21 drawings. The audit of implementation of the CAP' process for  !

i 22 h- controlling the-as-built update of engineering documents included 23 both the_ method for controlling design changes and the update of

( 24 ' . documents to as-built conditions. The interfaces involved both 25 DCP internal activities (among engineering design groups and 26 , between engineering and construction) and DCP external activities L27 (between PGandE and outside contractors). ITR-41 concluded that

^

28 5-3

L i

e 1 this portion of the QA program was being implemented in a full 2 and effective manner..

a 8, -Q.6: Based upon the work performed by the IDVP, what con-  !

I; '

44, clusions has- the IDVP. reached with . respect to whether the "as-5 built" condition of the DCNPP-1 conforms to final design docu- i i!

ments?

6 (' '

7 A.6: (ALL) The IDVP has not performed an as-built walkdown 8 of DCNPP-1. However, the IDVP has determined that the as-built 1

9l condition .of those aspects of the DCNPP-1 that it field-verified  :

d  ;

10 [j properly implement the essential design elements reviewed by the j 1 '

11 ' ~ IDVP.

12 l o 13 II 14 i h -

4 15 h L

16 R i 1

1 17- y

.18

-19 1

-1 20 '

21 4

22 .d I 23 ! t 4 24 ji ,

25 II l

1 ,

i 26 -

I gg 7 .

28 U

5-4 4

j!i

. . y ,

b 1' CONTENTION 6 a

4 2 "The verification program failed to verify that the design of safety related equipment supplied to PGandE by Westinghouse 3 met licensing criteria."

44 Q.1: Did the IDVP verify that the design of safety-related 5 equipment provided to PGandE by Westinghouse met licensing cri-6 teria?

7. A.1: (ALL) No. However, the IDVP did verity the 8> Westinghouse /PGandE interfaces. This verification was initially 9 performed in response to E0Is 976, 978 and 1004 which were opened 10 because of concerns identified by RLCA in its November 1981 Pre-11 -

liminary Report. The specific issues included questions concern-12 ing transmittals of information and the Westinghouse use of a 13 tau-corrected spectrum in computing a vertical design response 14 spectrum, rather than the uncorrected spectrum as required by the 15 Hosgri. Report. The need for verification of this interface was 16 also recommended by the NRC Staff in SECY-82-414, and this recom-17 mendation was approved by the Commission. Since the non-seismic 18 Phase II efforts described below were also in progress at the 1 19 ' time the Staff recommendation was made, the IDVP did not consider

. 20 this Commission-approved Staff recommendation to be an expansion 21 of its planned program. Rather, it was considered as further 22 assurance that the IDVP plans were consistent with the NRC 23 requirements.

24 ITR-ll reports the Phase I verification of this interface 25 with respect to seismic considerations. This ITR was prepared by 26 - TES based upon an in-house audit of Westinghouse and subsequent 27 " review of the information obtained from Westinghouse. The veri-28 ficatioa included the interface for transmittal of the Hosgri 6-1

-r yy, v-ee- w -, - . . _ - - - ,

v

r' x -* ,

t 1- spectra and the review, on a sampling basis, of the Westinghouse 2 use of the Hosgri spectra in its qualification and evaluation 8 process. ITR-11 concluded that the Hosgri spectra were being 4 properly transmitted by PGandE and properly received, controlled, 5 and applied by Westinghouse. This verification pr6(ides reason-60 able assurance that this aspect of the design of Westinghouse-7, supplied equipment was properly performed.

8[ In the Phase II Program; the IDVP verified that Westinghouse 9 obtained from PGandE and used the correct design parameters for 10 the AFW in its analysis of accidents identified in Chapter 15 of 11l the FSAR. (See ITR-22 and IDVP Final Report, Section 4.1.3.) The 12 IDVP also performed independent calculations to verify that con-13 ' densate storage tank capacity and required AFW flow rates speci-fied by Westinghouse were met by PGandE's design. In addition, 14 "

15 i .RFR's Phase II QA audit and review also included an examination 16 of the interface between PGandE and Westinghouse. (See ITR-42 17 and IDVP Final Report, Section 4.1.3.) Based upon the work de-18 scribed above, the IDVP verified that the PGandE/ Westinghouse in-19 terface for the NSSS system included appropriate controls for the l 20 transfer of design information and that the NSSS vendor used the 21 applicable information.

22 Q.2: Why was the design of Westinghouse equipment excluded 23 from the scope of the IDVP7 24 A.2: (WEC) The Commission Order and the Staff Letter re-25 quired an independent verification of the design. work of PGandE 26 and service-related contractors. This was interpreted as not in-27 cluding design work of vendors of systems and equipment, such as 28 ,

Westinghouse. Accordingly, the Program Plans submitted to, and 9

! 6-2 1

4

r

'o '.

1 approved by, the Comission specifically exciuded design work 2 performed by Westinghouse.

'3 4

5 6

7 8

9 10 11 12 13 14 15 16

! 17 18 19 l

20 l 21 22 23 l

l 24 25 I

26 27 28 6-3

1 CONTENTION 7 2 "The verification program failed to identify the root causes >

for the f ailures in the PGandE design quality assurance program 3 and failed to determine if such failures raise generic concerns."

4 Q.1: Did the IDVP ascertain the " root" or " basic" causes of 5 the design errors it identified during the Program?

6 A.1: (ALL) Yes. The Commission Order and the Staff Letter 7 directed that the IDVP assess and report the basic causes of all 8 design errors identified during the program. This was done close 9 to the conclusion of the IDVP program and was based upon a back- ,

f 10 ward look at all of the deficiencies identified by the IDVP. The 11 IDVP's determinations of basic cause are reported in the IDVP 12 Final Report, Section 6.3.

13 Q.2: In the judgment of the IDVP, what were the basic 14 causes of the design errors it identified?

15 A.2: (ALL) The two basic causes of design errors identified 16 by the IDVP, in addition to random causes, were control of design 17 interfaces and documentation ard interpretation of design.

18 However, the basic causes can only be properly addressed in light 19 of several underlying factors that, in combination, contributed 20 significantly to most of the design problems. These factors are 21 identified in the IDVP Final Report as follows:

22 (1) Safety-related systems were seismically designed twice 23 to meet two sets of criteria, with a substantial time 24 interval between the two design efforts.

25 (2) The plant had substantial design work performed as a 26 result of I&E bulletins and TMI requirements.

27 (3) The design work was performed over a period of 15 28 years.

7-1

1 (4) Seiv:ic design methodology and criteria changed signif-2 icantly during the 15 years from a rudimentary to a 3 reasonably mature, systematic, and sophisticated 4 process.

5 (5) Nuclear plant design naturally requires the transfer of 6 large amounts of information from one design group to 7 another; such design interfaces existed in especially 8 hrge numbers both within PGandE and between PGandE and 9 its service-related contractors.

10 (6) Design control practices acceptable during the pariod 11 of the initial design process were not consistent with 12 the eventual duration and complexity of the reiterative 13 design process required at DCNPP.

14 Q.3: Is the IDVP satisfied that the consequences of these 15 basic causes were identified and corrected?

16 A.3: (ALL) Yes. Although the basic causes were not ex-17 plicitly identified until late in the program, they involved 18 aspects of the design process which had been carefully reviewed 19 throughout the program.

20 Because of the known concerns about control of design inter-21 faces, the IDVP had paid particular attention to review of the 22 flow of ' information among PGandE and its contractors and within 23 PGandE. ibis concern was addressed by both QA and design process 24 verification efforts and, in the case of the CAP, by the " design 25 office verification" procedure developed specifically by the IDVP 26 to assure that the QA procedures and their implementation were 27 adequate to the specific design aspects.

28 7-2

I l

1 With respect to the documentation and interpretation of de-2 sign, the IDW was sensitive to the possibility that any identi-3 fled deficiencies in these areas could have generic impacts.

4 Thus, throughout the verification efforts, criteria and method-5 ology were carefully defined and documented so as to assure that

'6 generic concerns associated with problems in documentation and 7 interpretation of design were identified and resolved.

8 Q.4: Did the IDVP identify generic concerns associated with 9 design errors identified during its program?

10 A.4: (ALL) Yes. The IDVP reviewed every E0I resulting from 11 the verification effort for generic concerns and resolved all 12 such generic concerns as part of the verification effort. As 13 discussed in A.22 of the Testimony on Contentions 1-2, the 14 identification of generic concerns was an important part of the 15 IDVP.

16 Q.5: Did the identification of basic causes later in the 17 program result in any new generic concerns?

(ALL) No. The verificction effort for the initial 1

18 A.5:

19 samples and additional sample / verification were performed under 20 the assumption that. design QA was deficient, and the basic ct.uses 21 identified turned out to be design QA related. Since the IDVP 22 assumed inadeauate design QA in developing the IDVP programs, the 23 identification of root causes which were actually associated with 24 QA deficiencies was no surprise to the IDVP and did not result in 25 a requirement for additional expansion.

26 Q.6: In his answers to interrogatories (e.g., Answer No. 66 27 to Applicant's Second Set of Interrogatories), Governor 28 Deukmejian appears to criticize the IDVP for allegedly failing to 7-3

', 'o 1, identify the underlying cause for any E01. Did the IDVP ignore 2a causation in resolving E0Is?

A.6: (ALL) No, In resolving every E01, the IDVP not only 3f 44 disposed of the specific concern raised by the E01, but determin-5 ed whether there existed a generic concern, as described in A.22 6 of the Testimony on Contentions 1 and 2. Obviously, in some 7 cases it was necessary to examine the cause of the E01 as part of 8 the specific concern which had to be remedied; while in otiser 9 instances the cause of the E01 led to its being designated as a 10 generic concern. Although the IDVP documentation did not neces-11 sarily include a specific label for "cause", in the case of each 12 E0I the IDVF determined whether the factors relating to the cause 13 of the E01 required that any additional action be taken, 14 To the extent that Governor Deukmejian is suggesting that 15 the IDVP, in addition to dealing with causation as described 16 above, should also have separately identified the " basic cause" 17 of each and every E01, the IDVP believes that such an exercise 18 was wholly unnecessary. In the IDVP's view, assessment of basic l 19 cause (as such term was used by the IDVP) is more meaningful when 20 it can encompass a review of all the deficiencies identified in 21 an entire program, rather than by focusing on isolated items.

22 This is what the IDVP did as reported in Section 6.3 of the Final 23 Report.

24 Q.7: Has the IDVP neglected "to identify the root causes 25 for the failures in the PGandE design quality assurance program,"

26 as alleged in Contention 7?

27 A.7: (ALL) As explained in A.1 above, the IDVP identified l

28 two basic causes for the desigt errors identified by it. Each of 7-4

, 's 1 these causes related to some extent to a QA function: control of 2 design interfaces and inadequate documeatation of design. If 3 this ambiguous contention is alleging that the IDVP should have 4 ascertained the basic causes associated with QA deficiencies, the 5 IDVP has in part done so in its discussion of basic causes and 6 the underlying factors which contributed to them. (See A.2 above 7 and discussion of " Fundamental Factors" in IDVP Final Report, 8 Section 6.3.1.)

9 However, if the contention alleges that the IDVP should 10 eutomatically have ascertained the basic cause (as such term was 11 used by the IDVP) of each identified deficiency in the PGandE 12 design QA program, this was neither done nor necessary, as dis-13 cussed in A.6. Moreover, as discussed in A.5, the IDVP program 14 for verification of design was structured to verify conformance 15 of the design of DCNPP-1 te license criteria without reliance on 16 the effectiveness of a design QA program. Thus, no purpose would 17 have been served by inquiry by the IDVP into the basic causes of 18 design QA deficiencies.

~

19 Q.8: Does this mean that the IDVP may have failed to ident-20 ify generic concerns with the design of the DCNPP-1 that could 21 have resulted from failures in the PGandE design QA program?

22 A.8: (ALL) No. IDVP's confidence that this has not 23 occurred is based upon the IDVP's exhaustive review which, as 24 stated above, included a detailed search for the type of generic 25 concerns which could result from design QA deficiencies (e.g.,

L 26 concerns relating to interface control, checking of calculations, 27 etc.).

28-7-5

. '. 3 l

1.

"The ITP failed to develop and implement in a timely manner a design quality assurance program in accordance with 10 CFR Part 50, Appendix B to assure the quality of the recent design %difi-3 cations to the Diablo Canyon facility and the IDVP faiied to ensure that the corrective and preventative action programs 4 implemented by the 11P are sufficient to assur6 that the Diablo

- Canyon facilities will meet licensing criteria."

5 6h Q.1: Did the IDVP perform an audit of the implementation of 7 the OCP design QA program for the ITP?

l 8 A.1: (WEC, RFR) RFR audited that portion of the ITP work 9 which was performed as part of the CAP. Other work performed by 10 the ITP was outside of the RFR audit scope, as specified in ITR-11 -

8.

12 Q.2: Why was this audit performed?

13 ' A.2: (WEC, RLC, RFR) Both the Phase I and Phase II IDVP 14 Program Plans required the IDVP to verify any PGandE corrective 15 action resulting from the design verification performed by the 16 IDVP. The CAP was considered such a corrective action, and the 17 IDVP issued ITR-8 to describe the IDVP's verification of CAP 18 activities. ITR-8 committed the IDVP to perform an audit of the 19 DCP QA program implementation commencing August 20, 1982.

20 Q.3: When was the audit performed?

21 A.3: (RFR) An initial audit of the CAP was performed during 22 the period of November 11, 1982 through December 7, 1982. A 23 follow-up audit was performed on March 17, 1983.

24 Q.4: Why was the initial audit not performed until November 25 11, 1982?

26 A.4: (WEC, RFR) The DCP QA program, initially submitted for 27 NRC review and approval on June 18, 1982, was found acceptable by 28 the NRC on August 2,1982, and was approved contingent upon DCP 8-1

t l;

l 1 submittal of revisions which addressed NRC comments. The DCP 2 response to the NRC comments was submitted on August 13, 1982.

3 ITR-8 was issued on October 5, 1982. On October 27, 1982, a ,

a 4' pre-audit scoping meeting was held between the IDVP and DCP for 5 the purpose of reviewing the status of DCP work which was per- -

6 formed as part of the CAP and which was, therefore, within the

-7 audit scope. As a result of this meeting, RFR scheduled the 8 initial audit on November 11, 1982 in order to provide an early 9 evaluation of the effectiveness of the CAP's implementation of 10 the DCP design QA program.

11 Q.5: Please explain how RFR prepared for the initial audit.

12 - A.5: (RFR) Preparations for the audit occurred in several 13 steps. Initially, RFR obtained and reviewed the DCP QA manual 14 and implementing procedures. An audit team was selected, con-15 sisting of experienced design control auditors, all of whom were 16 qualified to ANSI 45.2.23. After the October 27 meeting with 17 representatives of the DCP, audit checklists were prepared using 18 the DCP QA manual and implementing procedures as the basis to 19 cover every significant commitment of the DCP QA program.

20 Two checklists were developed: one was designed to audit 21 CAP internal design activities and the other to audit internal 22 and external interface controls. During the preparation of these 23 checklists, RFR also reviewed the QA procedures for conformance 24 to the commitments of the DCP QA manual. Finally, members of the 25 audit teams were instructed as to the checklists and assigned 26 audit areas by the team leaders.

27 Q.6: Please explain how RFR conducted the initial audit.

28 8-2

1 A.6: (RFR) A pre-audit conference was held with representa-2 tives of the DCP on November 11, 1982 to discuss the audit scope.

3 For the actual audit, the audit team was then split into four 4 sub teams consisting of civil / structural, electrical and instru-5 mentation and controls (I&C), mechanical / piping, and adminis-6 trative controls. The audit team for each engineering discipline 7 then selected representative design activities within that team's 8 area. Using the design activities associated with each dis-9 cipline, each audit team determined whether the CAP had complied 10 . with the checklist items by reviewing design documents, memos, 11 letters, audit reports, E01s and other DCP documentation. At the 12 conclusion of each day of auditing, an administrative meeting to 13 discuss audit status and schedule was held between the audit team 14 members and representatives of the DCP.

15 Q.7: Please describe the results of the initial audit.

16 A.7: (RFR) The initial audit showed that a number of design 17 and QA activities were incomplete at the time of the audit or not 18 yet fully documented. As a result, insufficient completed docu-19 mentation was available to determine accurately the adequacy of 20 the DCP QA program implementation. Twenty-four (24) conditions 21 or areas that were found to be incomplete were identified in the 22 first audit for subsequent follow-up by the IDVP.

23 Q.8: Did the IDVP consider that the DCP did not implement 24 ,

its design QA program in a timely fashion because of the aspects 25 of the design QA program that were not fully implemented at the 26 time of the IDVP's first audit?

27 A.8: (WEC, RFR) No. The QA program was determined to be 28 implemented in a timely manner.

8-3

1 Q.9: When did the IDVP conduct its follow-up audit?

2; A.9: (RFR) The follow-up audit was conducted on March 17, 3j 1983.

4' Q.10: Why did RFR wait until that time?

5 A.10: (RFR) RFR waited to conduct a follow-up audit to 6 allow for design activities performed by the CAP to progress to a 7 point where a sufficient volume of documentation had been com-8 pleted that could then be reviewed to assess adequately the 9 overall implementation of the QA program. During the period be-10 tween the two audits, RFR was in communication with the other 11 ,

IDVP organizations and, through this communication, was able to 12 select the earliest date for a follow-up audit which was con-13 sistent with the required status of completion of CAP design 14 activities.

15 Q.11: Did RFR prepare for and conduct the follow-up audit 16 in the same manner as the initial audit?

17 A.11: (RFR) Yes, except for a few differences. Initially, 18 the follow-up included a specific review of the 24 conditions 19 noted during the first audit. For each of these conditions the 20 documentation looked at earlier was again requested and reexamin-21 ed to determine the adequacy of correction or completion, and 22 documents not available initially were requested and examined to 23 determine compliance with QA program commitments. Finally, 24 responsible DCP personnel were questioned to determine whether 25 they understood che requirements of the QA program.

26 Q.12: Please describe the results of the follow-up audit.

27 A.12: (RFR) RFR's conclusion, based upon the information 28 obtained during the follow'-up audit, was that the open or unre-8-4

l 1 solved items from the previous audit were satisfactorily re-2 solved, and no new items of non-compliance were identified.

3, Q.13: Based upon the results of the audits of the CAP, did 4 the IDVP identify any generic concerns as to the overall DCP QA 5 program?

6 A.13: (WEC,RFR)No.

7 Q.14: Did the IDVP conduct any further audit of the imple-8 mentation of the DCP QA program?

9 A.14: (wEC, RFR) No. The audits of the CAP showed that the 10 DCP QA program, under which all ITP work was being done, was 11 ,

being effectively implemented, and it was therefore determined 12 that no further audits were necessary. This is standard practice 13 ,

for the conduct of QA audits.

14 Q.15: In addition to auditing the performance of the CAP QA 15 program, did the IDVP also verify the DCP's control of informa-p; tion across design interfaces?

17 A.15: (RFR) Yes. Design interface controls were verified lg during the CAP audit conducted on December 6 and 7,1982, and as 19 part of each of the Design Office Verification (D0V) audits.

20 Q.16: Please describe the D0V audits performed by the IDVP.

21 A.16: (WEC, RLC, RFR) ITR-8 required that interface control 22 and project indoctrination be verified by the IDVP for each 23 subject where design process verification was required. RFR per-24 i formed these aspects of the D0V between December 20, 1982 and 25 March 11, 1983. Audit teams verified technical interface con-26 trols and project indoctrination in order to assure that the 27 Hosgri and non-Hosgri seismic design inputs were correctly trans-28 lated into applicable design documents and across design inter-8-5

. . y 1 faces using the most recent inputs. The audit was performed by 2h tracking seismic inputs from the ground acceleration values to 3 each seismic Category I structure and to the building floor 4 f' . spectra applicable to the piping design documents sampled. The 5 00V also verified that computer programs used in the seismic 6 '

design analyses had been verified by the DCP. As described in 7 ITR-41, the DOV was performed in the areas of mechanical equip-8' ment, the auxiliary building, the intake structure, large bore 9 piping and supports, instrument tubing and supports, the fuel 10 handling building, the turbine building, the HVAC system, 11 electrical equipment and instrumentation, small bore piping and 12 supports, electrical raceway supports and the containment struc-13 ture. The D0V was conducted by selected professionals experi-14 enced in design control and qualified to ANSI N45.2.23 . The 15 audit team used a checklist based upon ITR-8 and the DCP QA 16 program procedures applicable to the control of the design inter-17 faces, training and the verification of computer programs.

18 Q.17: What were the results of the D0V?

19 A.17: (WEC, RFR) The D0V showed that control of internal 20 -and external interfaces was adequate to assure the use of correct 21 seismic inputs and the correct translation of seismic inputs into 22 corresponding design documents. The auditors also determined 23 that design personnal using seismic information were aware of the 24 applicable QA ' program controls and that computer programs that 25 , were used by the DCP were appropriately verified.

26 Q.18: What are the overall conclusions reached by the IDVP 27- on the basis of its audit of the DCP QA program and the D0V?

28 8-6 e-n-es

1 A.18: (WEC, RFR) As a result of the CAP audits and the D0V, ,

2 the IDVP concluded that the DCP QA program was effectively imple-3 mented. The IDVP's conclusions are reported in ITR-41 and in the 4 IDVP Final Report, Section 4.2.

5 Q.19: Did the IDVP also verify the engineering work of the 6 ITP as applied to corrective actions apart from its verification 7 of the DCP QA program?

8 A.19: (WEC, RLC, JEK) Yes. The IDVP conducted a detailed 9 engineering peer review on a sampling basis, similar to that per-10 formed in the' verification of the initial samples, and in 11 accordance with the Program Plans. The peer review, conducted by j

12 RLCA, TES, and SWEC, was conducted in accordance with the method 13 prescribed ir. the Program Plans. The areas where this verifica- i 14 tion was to be performed, along with the approach to be used,

! 15 were specified in ITRs -8, -34, and -35. The results of the IDVP

'~

16 review of DCP corrective actions is presented in the series of

! 17 corrective action ITRs (ITRs -45 to -49, -51, ~54 to -61, -63, -

18 65, -67, and -68) issued to document the results of the IDVP peer 19 review.

20 Q.20: What were the results of the IDVP's peer review of 21 the ITP?

22 A.20: (WEC, RLC, JEK) The IDVP determined that the ITP has i

23 been effective in resolving earlier E0Is and in reviewing the 24 seismic design of the DCNPP-1. The IDVP's verification of the 25 activities of the ITP resulted in 26 new E0Is, each of which was 06 subsequently resolved and closed.

27 28 4

8-7

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1 Q.21: In the judgment of the IDVP, does the issuance of 2 these E01s indicate that the design work performed by the ITP was 3 ,' not being performed in a competent manner?

4 A.21: (WEC, RLC, JEK) No. The E0Is do not necessarily 5 represent a confirmed violation of license criteria, but rather 6 are a vehicle established by the IDVP to indicate an area which 7 requires further investigation before the IDVP can reach a deci-g sion on whether it will impact on the satisfaction of licensing 9 criteria. Of the 26 E01s identified in this portion of the 10 program only I was later designated as a Finding. Thus, of the 11 tremendous volume of design work reviewed, the IDVP found only a 12 very limited area where the ITP did not initially demonstrate 13 commpliance with the licensing criteria.

14 Q.22: In the judgment of the IOVP, does the issuance of 15 these E0Is indicate that the ITP was not implementing its design 16 QA program properly?

17 A.22: (ALL) No. The fact that an E01 file was opened as to <

18 a technical issue does not necessarily mean that there is either 19 a design error or a breakdown in the DCP QA program - only that a 20 technical question exists. No E0Is were issued by RFR identify-21 ing any inadequacy in the DCP QA program implementation.

22 Q.23: In the judgment of the IDVP, has the ITP developed 23 and implemented in a ti nly manner the design QA program approved 24 by the NRC?

25 A.23: (ALL) Yes. The IDVP's conclusion is based upon the 26 audits and verifications it has performed, as described in this 27 testimony. The E01s issued by the IDVP do not detract from the 2g conclusion reached by the IDVP.

8-8