ML20081B435
| ML20081B435 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/05/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8403090128 | |
| Download: ML20081B435 (19) | |
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- o, w e UNITED STATES OF AMERICA $,$ED NUCLEAR REGULATORY COMMISSION 3/5/84 ,
BEFORE THE ATOMIC SAFETY AND LICENSIWW -8 A!0:13 In the Matter of I '
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TEXAS UTILITIES GENERATING l Docket'liodM M $ Wd COMPANY, et alc l ~ 50-446 i
(Comanche Peak Steam Electric Station i Station, Units 1 and 2) l CASE'S ANSWER TO APPLICANTS' PLAN TO RESPOND TO MEMORANDUM AND ORDER (OUALITY ASSURANCE FOR DESIGN)
On February 3, 19'4, 8 Applicants filed their Plan to Respond to .the Licensing Board's Memorandum and Order (Quality Assurance for Design). On 2/10/84, CASE sought and was granted an extension of time until 3/5/84 in which to respond to Applicants' Plan (see CASE's 2/10/84 Motion for Extension of Time to Answer Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design)). At the request of the Board Chairman, CASE did file, however, a partial response indicating whether or not CASE believed Applicants' Plan is on the right track (see .
CASE's 2/10/84 Partial Answer to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design)).
In its 2/10/84 Partial Answer, CASE discussed the 8403090128 840305 PDR ADOCK 05000445 PDR g
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I'. appropriateness and unfairness of allowing Applicants to relitigate closed Walsh/Doyle matters (pages 2-5). The Board is well aware of CASE's concerns and position in this regard, and we will not reiterate them at this time.
CASE also discussed additional shortcomings and inadequacies in Applicants' Plan, and concluded that Applicants' proposal is totally inadequate and non-responsive to the Board's concerns.
The Board appeared to share CASE's conclusion, at least in part, as demonstrated by the strongly worded scatement and caution to the Applicants by the Board at the conclusion of the hearings on Friday, February 24, 1984.
In its 12/28/83 Order, the Licensing Board strongly recommended that Applicants institute an independent design review with cartain specific characteristics. As discussed herein Applicants' proposed Plan fails to meet even those charact.aristics.
A.id, as stated in our 1/10/84 Partial Answer, what is needed now is very detailed and specific criteria, which has already been hammerad out at several plants which have produced audits of quality that have ended up saying how many and which problems there were, how long it would take to fix them, etc. Such an audit would provide the Board with exactly the information it is t
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The Licensing Board should not allow Applicants tot pursue the inadequate and unacceptable Plan they have proposed. To do so would not alleviate the Board's concerns or resolve their
. doubts about the design and construction of Comanche Peak.
Further, if Applicants are allowed to parsite the Plan they have proposed, it would subject CASE and its witnesses, with our severely limited resources, to yet another round of hearings --
- hearings which, CASE is convinced, are unnecessary and which would ultimately lead the Board to conclude that it still has sufficient uncertainty about the design and construction of Comanche Peak to prevent it from granting an operating license.
CASE therefore urges that the Board, rather than allowing Applicants to rursue the Plan they have proposed, require Applicants instead to have an in-depth, thorough independent design verification and management audit based on the criteria discussed hereia. CASE offers the following specifics in support of its proposal.
I. Applicants' proposed Plan does not meet the Board's suggested criteria:
The Board's first criteria (as set forth in its 12/28/83 Memorandum and Order (Quality Assurance for Design), page 73) is:
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" Independence and Qualifications. The review organization should.
be composed of individuals with the ccmbined ability to review design problems in the construction of a ncelear power plant."
In contrast, Applicants state (page 8 of their 2/3/84 Plan) "In accordance with the Board's suggestion that an independent design review be conducted, Applicants intend to commission Cygna Energy Services to perform such a review. This review will be accomplished by expanding the scope of the Independent Assessment Program issued by Cygna on November 5, 1983. . '. Cygna will be requested to employ the same methodology and tct retain the same independence and reliability that it utilized for the prior effort." (Emphasis added.)
During the February 1984 licensing hearings, Cygna testified that it was their usual practice to provide prenotification of documents it planned to review. It should be noted that this
, practice does not meet any of the NRC's criteria regarding l independence.
In addition, because Cygna has or will have done a prior assessment at Comanche Peak (which is currently being litigated),
I what it would be doing this coming time would be reviewing its own prior work -- i.e., Cygna would be reviewing Cygna's original assessment, creating a conflict of inte re s t. It would te l
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. w-b Linclined tx> ensure that future findings on other systems would parallel ~ prior findings -- or at least would not contradict prior findings and make them no longer valid.
Further, Cygna representatives in the February hearings did not demonstrate the ability to adequately review and assess design problems. To the contrary, this is still unproven and under litigation. Clearly the Licensing Board must have had some concerns .itself in this regard; othe rwise , Cygna's first assessment would have been cufficient to satisfy the Board's concerns and it would not have felt it necessary to strongly recommer.d an additional assessment be undertaken. If Cygna co'uld not handle the limited scope of the original assessment program, how could it adequately handle an expanded scope? CASE submits that it is unreasonable to assume, absent further proof, that it could do so. -
Even were Cygaa able to overcome the problems discussed in ,
the preceding, under this first criteria, the Board also said "There thould de no lasting financial ties between the reviewing organization and applicant." While the Board stated in its 12/28/83 Order that it felt that Cygna " appears to meet this criterion," CASE is not convinced that that is the case. It appears that the continuation of using Cygna to do additional 5
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. s review following last year's Independent Assessment Program (which was a very positive evaluation for Applicants' position --
bu' t which the February hearing demonstrated, was an evaluation which- appears to be built more on engineering judgement than on calculations and documentation) may result in a violation of this criterion. Again, Cygna has good cause to ensure that new findings maintain the warm glow of earlier reports.
The Board's second charac te ristic is " Organizational Independence." The Eoard said "During the conduct of the review, there should be no undocumented oral discussions between applicant and. the reviewing organization concerning findings.
The reviewing organization should obtain all its information from: observations of documents or hardware; written answers to written questions; or transcribed conferences open to all parties."
Again Cygna demonstrated a lack of independence in the ,
Independent Assessment Program (IAP)- review -- to the extent that they provided lists of documents to the Applicants the day before i Cygna personnel reviewed them. In addition, Cygna i
representatives did not treat requests for data, or responses of data .from Applicants, as being subject to the rules of protocol which were put into effect af ter the review began. There were 6
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undocumented conversations and oral. discussions with Applicants e.
-- and' (for the report) not all information was obtained strictly from observations of documents and hardware. Nor were all conferences open to all parties at all times. CASE was never ,
informed of any such conferences between Applicants and Cygna (other than those held with the NRC). Cygna has already
' demonstrated its loss of objectivity -- and once lost, CASE does not believe that it can be regained. Cygna and its methodology are committed to demonstrating that hardware and design problems at Comanche Peak either do not exist or that they are insignificant. In its original Report, Cygna's aim (as testified ,
to in the February hearings) was to " prove the adequacy of the
' design" -- not to objectively evaluate data to see if the design is ' adequate fg; inadequate, or whether fy; not the hardware is properly ~ installed and/or meets specifications. Cygna's methodology asks the wrong question -- therefore, Cygna arrives at a predetermined, self-fulfilling answer. .
The Board's third characteristic, " Reliability," concerns coordination among the reviewers assigned to the review. Cygna has not established inter-reviewer reliability. Applicants' Plan again says that it will depend on Cygna's past performance; it does not delineate a goal of reliability per se.
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The Board's fourth characteristic, " Sample," suggests that "One or more segments of important safety systems should be studied." (Emphasis added.) Applicants' Plan (page 8) states
'.nat " piping and pipe support systems on a segment of the cosp nent cooling water system" and " piping and pipe support systems on a main steam line from the steam generator to the main steam isolation valve" will be studied. Applicants claim that the reason they selected those systems is that "they represent systems which contain moct configurations alleged to be inadequate or improper." But looking at piping and pipe support i-systems again is merely a rehash of Walsh/Doyle allegations. All parties are well aware of the problems in the piping and pipe support systemc. The Board's questions and concerns seem to be regarding whether or not similar problems exist in other plant sys tems as well -- e.g., systems other than piping and pipe supports. Applicants wc91d have Cygna tread no new ground; there -
is no provision in Applicants' Plan for the possibility of ent.argement of the scope of the study should additional problems
- be detected. (The fact that Applicants choose to deal again with pipes and pipe supports practically makes enlargement of the scope impossible, for Messrs. Walsh and Doyle have already
-brought many, perhaps most, of the problems with those systems to the Board's attention already.)
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l s-Regarding the Board's fif th characteristic, " Scope," the Beard recommends that the reviewers respond "in detail, to each allegation of CASE concerning hardware design problems." CASE believes that this should be done by addressing all Walsh/Doyle
. allegations (as discussed in CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations)) -- n o t
. merely those sixteen which Applicants chose to address (pages 5-7 af Applicants' Plan). In the February 1984 hearings, Cygna representatives were unable to present detailed answers to CASE's cross-examination questions and even stated that they would not
" parade" their engineers to do so. In fact, not only were they unable to provide calculations or documentation on specific data which they had supposedly already reviewed for the November study, but CASE has just received (on 3/5/84) responses to only three questions (with the promise that Cygna is " continuing to complete the remaining responses and anticipate sending another partial set next week") -- although it was stated' during sthe d
hearings that Cygna's engineers were already wording on them.
Thus, Cygna. has already had almost two weeks, with a staff of engineers working con '
'the hue'stions, in whichito provide the u - -- - .
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sought-af ter - calculations , = documsntation, , or other answers. It should be noted7thht this will mean 'that CASE'c two engineers
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r, will have considerably less than two weeks in which to receive the materials provided, review them, send a response to Cygna, and prepare for the upcoming hearings scheduled for the week of darch 19. CASE submits that to proceed with the hearings on Cygna under these circumstances is totally unfair and extremely prejudicial to CASE and to Messrs. Walsh and Doyle. Further, it appears that the Licensing Board's time will again be unnecessarily wasted, as happened in the February hearings.
How can the Board rely on Cygna's ability to provide an adequate response to each Walsh/Doyle allegation when Cygna could not even produce (and in fact has not yet produced) the calculations and documentation forming the basis for the conclusions of the November study? Applicants only commit to
" provide detailed testimony and/or documentary evidence, as appropriate, on each of these issues to assure that the record is clear and complete." (Page 5 of Applicants' Plan.) ("These issues" again are not all of the Walsh/Doyle allegations -- only Applicants' selected sixteen.) This does not commit them to the Poard's recommendation that responses " indicate the criteria that l
are applied, where they are derived from and how each criterion is met." (Board Order at 74.)
The Board's sixth characteristic (page 74) is " Documentation l
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and Presentation." Applicants' Plan does not commit them to documenting each analysis of an observed potential deficiency in the report -- without referring to " vague assertions such as 'We have been assured.'" CASE maintains that " engineering judgement" without adequate supporting calculations or documentation is a similarly nonresponsive reply and does not constitute properly documenting the resolution of deficiencies as desired by the Board. Neither Applicants nor Cygna is committed to providing extensive documentation -- nor are scoping calculations or analyses provided for.
The Board's seventh characteristic, " Review," is not met by Applicants' promise to attempt to seek stipulations on Walsh/Doyle allegations with CASE based on tests and analyses (which have not yet been provided to Messrs. Walsh and Doyle and
. which may or may not be available in full enough form for them to properly evaluate).
Applicants' incredibly optimistic schedule of total time of two months for this review bears little resemblance to the amount of time required for Cygna's original assessment, much less to the Board's suggestion of a review process which would be discussed by all parties at each " stage" of the review, returned
-to the reviewer with comments, etc. Applicants' proposal seems 11
r-to defeat the Board's intent not only concerning the issue of timeliness, but also of " carefully reasoned, documented obj ections to these segments" of the review. (Board Order at 74.) Applicants' Plan precludes the time needed for reasoned responses by all engineers -- including Applicants', the NRC's, and CASE's. All are going to need time to receive and review calculations and other documentation. (And apparently additional time will need to be allowed for Cygna to provide responses, based on the amount of time which is being used to response to Messrs. Walsh and Doyle's summary of cross-examination questions.) Without adequate time for the engineers to properly review, evaluate and respond, this " review" would be a costly, time-consuming, and totally meaningless exercise.
In addition, the Board suggested that the design review group .should " respond fully to each of these comments" (by the other parties). In effect, what the Board suggests is a dialogue between teams of engineers -- a dialogue centering on calculations and documentation -- a dialogue that will, at a minimum, allow the airing of different views regarding the assumptions underlying differing calculations, etc., so that the Board will be able to make its decision after the engineers have attempted to resolve their differences (thereby avoiding wasting 12
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valuable Board time).
The Walsh/Doyle allegations are not new, and any resolution of. those issues will in all likelihood take more than one exchange to resolve. (In addition, Applicants propose to provide "similar input" to the NRC Staff -- but this does not necessarily mean that they will provide all identical input to CASE and to the Staff.)
In the eighth and final characteristic recommended by the Board (pages 74 and 75 of the Board's 12/28/83 Order), " Hearing Process," the Board outlines a reasonable hearing schedule -- one which begins 30 days (40 days for the Staff) after final publication of the document within which to file written exceptions, with additional time for responses, etc. In contrast, Applicants' Plan calls for hearings to be scheduled for April 23-27 and May 1-3 for " litigation of the matters encompassed by the Plan." It is obvious to CASE (and it must be equally obvious to Applicants;) that this is not " ample opportunity" for all parties to prepare for the hearings (contrary to Applicants' claim on page 9 of the Plan). It is, instead, an utterly impossible schedule to do anywhere near an adequate review -- much less to respond! Applicants' Plan does not provide the mechanism for assuaging the Board's concerns.
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The issues raised here are important safety issues which should be of great concern to the Board and all parties. While they should be dealt with in a timely manner, they must at the same time be dealt with with great care and precision. The goal of the Board (to determine whether or not Comanche Peak has been designed and constructed such that the public health and safety will be protected should the Board grant an operating license) will not be achieved by undue and unnewssary haste at this point in time. In fact, issues covered too hastily in the name of expediency could result in achieving the opposite from the Board's goal.
II. The Board should order Applicants to have a 100%
reinspection, design verification, and management audit conducted using the more stringent NRC criteria.which has been adopted g other plants.
As mentioned previously, what is needed now is very detailed and specific critaria, which has already been hammered out at several plants which have produced audits of quality that have ended up saying how many and what problems there were, how long it would take to fix them, etc. Such an audit would provide the
. Board with exactly the information that is seeking.
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In this regard, we refer the Board to the following specific documents, copies of which are attached:
February 1, - 1982, letter to the Honorable John D. Dingell, Chairman, Committee on Energy and Commerce, U. S. House of Representatives, Washington, D. C., from Nunzio J.
Pa.lladino, Chairman, U. S. Nuclear Regulatory Commission, Washington, D.C.
February 1, 1982, letter to the Honorable Richard Ottinger, Chairman, Subcommittee on Conservation and Power, Committee on Energy and Commerce, U. S. House of Representatives, Washington, D. C. , f rom Nunzio J. Palladino, Chairman, U. S.
Nuclear Regulatory Commission, Washington, D. C.
October 13, 1982, NRC SECY-82-414, Policy Issue (Notation Vote), for: The NRC Commissioners, from: William J. Dircks, NRC Executive Director for Operations, subject: Diablo Canyon . Design Verification Program - Phase II Recommendations September 29, 1983, letter to James W. Cook, Vice President, Midland Pr oj ect , Jackson, MI, from James G. Keppler, Regional Administrator, NRC, Region III, Glen Ellyn, Illinois CASE is attempting to ascertain whether or not there are other similar documents which the Board should have in arriving at their decision regarding CASE's request for a 100%
reinspection, design verification, and management audit. (As the Board is auare, CASE's primary representative, Mrs. Ellis, has been ill ever since the close of the last hearings, and is just now beginning to recover. CASE had hoped to have all the research completed regarding this matter in time to include with 15 L
O 1 this pleading, but we have been unable to accomplish this.)
We assume that the Board would (as is its usual practice) thoroughly research this matter should it believe that there is the possibility that it might grant CASE's request. Should we find, upon further review, that there are additional such documents, we will forward them in the next few days for the Board's consideration.
As a review of the attached documents will indicate, the first three concern the reinspection and design verification of the Diablo Canyon nuclear power plant; the fourth primarily concerns the independence and compe'tence criteria for third party reviewers required for the Midland nuclear power olant. As discussed in those documents, the NRC in those instances adopted very stringent requirements to assure that independence and competence were maintained. It is this sort of criteria which CASE urges the Board require Applicants to adopt.
III. Cygna should not be allowed to perform the independent desi g review as proposed by Applicants.
As has already been discussed, CASE does not believe Cygna should be allowed to perform tha independent design review as propo-ed by Applicants, primarily because of their lack of 16
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- a independence arid because. they have failed to prove their reliability. (fee also CASE's 2/1/84 Answer to Motions for ,
Reconsideration of Board's Memorandum and Order (Quality
' Assurance for Design) by Applicants'and NRC Staff; CASE's 2/10/84 Partial Answer to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design), especially pagen 7-8; and especially CASE's 2/16/84 Expected Findings of Fact.?
As can bc readily seen from reviewing the attached documents, Cygna does not meet the more stringent requirements which the NRC has recently required for other nuclear plants.
Irt conclusion, CASE does not believe that Applicants' proposed Plan can satisfy the Board's concerns regarding the design and construction of Comanche Peak, and we urge the Board to reject Applicants' Plan. We further urge that the Board require Applicants to have a 100% reinspection, design -
verification, and management audit using the strict requirements which have been adopted by the NRC' recently regarding other nuclear power plants.
Respectfully submittcd ,
AU fD D gpkrs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 73224 214/946-9446 17 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATQilC SAFETY AND LICENSING BOARD In the Matter of l i
-TEXAS UTILITIES GENERATING i 'ocket Nos. 50-445 and COMPANY, et al. l 50-446 I
(Comanche Peak Steam Electric Station i Station,' Units 1 and 2)- l CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE'S ANSWER TO APPLICANTS' PLAN TO RESPOND TO MEMORANDUM AND ORDER (QUALITY ASSURANCE FOR DESIGN); AND AFFIDAVIT OF JACK D0YLE CLARIFYING TESTIMONY have been sent to the names listed below this 5th day of March , 198 4 ,
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by: Express Mail where indicated by
- and First Class Mail elsewhere.
(Attachments sent only to Parties, Board, and Docketing and Service)
- Administrative Judge Peter, B. Bloch Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Panel 4350 East / West Highway, 4th Floor U. S. Nuclear Regulatory Commissico Bethesda, Maryland 20814 Washington, D.'C. 20555
- Dr. Kenneth A. McCollom, Dean Alan S. Rosenthal, Esq., Chairman Division of. Engineering,- Atomic Safety and Licensing Appeal ~
Architecture and Technology Board Oklahoma State University U. S. Nuclear Regulatory Commission Stillwater, Oklahoma 74074 Washington, D. C. 20555
- Dr. Walter H. Jordan Dr. W. Reed Johnson, Member 881 W. Outer Drive Atomic Safety and Licensing Appeal Oak Ridge, Tennessee 37830 Board U. S. Nuclear Regulatory Commission
- Nicholas S. Reynolds, Esq. Washington, D. C. 20555 Bishop Liberman, Cook, Purcell
& Reynolds Thomas S. Moore , Esq. , Member 1200 - 17th St., N. W. Atomic Safety and Licensing Appeal Washington, D. C. 20036 Board U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq. Washington, D. C. 20555
-0ffice of Executive Legal Director U. S.= Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Maryland National Bank Building Panel
-7735 Old Georgetown _ Road - Room 10105 U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D. C. 20555
o 0 Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Renea Hicks, Esq.
Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 John Collins Regional Administratcr, Region IV U. S. Nuclear Regulatory Caumission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 D.~. David H. Bol tz 2012 S. Polk Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 R. J. Gary, Executive Vice President Texas Utilities Generating Co.
2001 Bryan Tower Dallas, Texas 75201 l
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e s. "Juanita Ellis, President CASE (Citizens Association for Scund Energy) 1426 S. Polk
. Dallas, Texas 75224 214/946-9446
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~g UNITED STATES 84 n NUCLEAR REGULATORY COMMISSION 5, ,E WASHINGTON, 0. C. 20555 .
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""** February 1,1982 CHA1RMAN ...--..q.. -
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3 The Honorable John D. Dingell, Chairman 0.. .
9 Committee on Energy and Commerce United States House of Representatives 7, , 4,/Q '~
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Dear Mr. Chairman:
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'3'. T98 # etter regarding the implication of the recent seismic design errors detected at the Diablo Canyon nuclear power plant. The implication of these errors has been and will be thcughtfully considered by the Commission.
The tiiming of the detection of these errors, so soon after authorization k' l ' 4 for icw-power operation, was indeed unfortunate and it is quite understandable that the Congress' and the public's perception of our licensing process has been adversely affected. Hao this information been known to us on or prior to September 22, 1981, I at sure that the facility license would not have been issued until the questions raised by these disclosures had been resolved.
Because of these design errors, on November 19, 1981 we suspended Pacific Gas and Electric Company's (PG&E) license penoing satisfactory -
completion of the following:
- 1. The conduct of an independent design review program of all safety-related activities performed prior to June 1,1978 under all seismic-related service contracts used ir the design of safety-related structures, systems and components.
.2. A technical report that fully assesses the basic cause of all
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- design errors identified by this program, the significance of the errors found and their impact on facility design.
- 3. PG&E's conclusions of the effectiveness of the design verification program in assuring the adequacy of facility design.
- 4. A schedule for completing any modificat, ions to the facility that are required as a result of the design verification program.
In addition, the Commission ordered PG&E to provide for NRC review and l ,
approval:
- 1. A description and discussion of the corporate qualifications of the l company or companies that PG&E wculd propose to carry out the l . , . . . - ,: ..
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2 independent design verification program, including information that demonstrates the independence of these companies.
- 2. A detailed program plan for' conducting the design verification program.
In recognition of the need to assure the credibility of the design verification program, ilRC will decide on the acceptability of the companies' proposed by PG&E to conduct this program after providing the Governor of California and Joint Intervenors in the pending operating licensing proceeding 15 days for comment. Also, the t1RC will decide on the acceptability of the plan proposed by PG&E to conduct the program, after providing the Governor of California and the Joint Intervenors in the pending operating license proceeding 15 days for comment.
Prior to authorization to proceed with fuel loading, the flRC must be satisfied with the results of the sei'smic design verification program and with any plant modification resulting from that program that may be f
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necessary prior to fuel loading. The fiRC may impose additional requirements prior to fuel loading necessary to protect health and safety based upon its review of the program or any of the information provided by PG&E. This may include some or all of the requirements specified in the letter to PG&E dated flovember 19, 1981.
Responses to each of the four questions in your letter are enclosed.
A decision to permit PG&E to proceed with~ fuel loading will not be made until all the actions contained in the Conmission's flovember 19, 1981 Order are folly satisfied.
Sincerely, l
f4unzio J. Pallacino (
cc: Rep. Carlos Moorhead ,
Enclosures:
- 1. Commission Order, dated 11/19/81
- 2. Ltr from Office of fluclear Reactor Regulation,flRC to PG&E dated 11/19/81
- 3. Responses to Questions c
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NUCLEAR REGULATORY COM'MISSION WASHINGTOff. D. C. 20555 CHAIRMAN February 1, 1982 r----'----
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Subcommittee on Conservation and Power Committee on Energy and Comerce United States House of Representatives Washington, D.C. 20515 -
Dear Mr. Chairman:
We share the concerns expressed in your November 13, 1981 letter regarding the implication of the recent seismic design errors detected
( at the Diablo Canyon nuclear power plant. Ne implication of.these arrors has been and will be thoughtfully considered by the Commission.
The timing of the detection of these errors, so soon after authorization for low-power _ operation, was indeed unfortunate and it is quite <
understandable that the Congress' and -the public's perception of our licensing process has been adversely affected. Had this information been known to us on or prior to September 22, 1981, I am sure that tbe facility license would not have been issued until the questions raised by these disclosures had been resolved.
Because of these design errors, on November 19, 1981 we suspended Pacific Gas and Electric Company's (PG&E) license pending satisfactory completion of the following:
- 1. The conduct of an independent design review program of all safety-related activities performed prior to June 1,1978 under all
(- ' seismic-related service contracts used in the design of safety-related structures, systems and components.
- 2. A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of the errors found and their impact on facility design.
- 3. PG&E's conclusions of the effectiveness of the design verification program in assuring the adequacy of facility design.
, 4. A schedule for completing any modifications to the facility that are required as a result of the design verification program.
In addition, the Commission ordered PG&E to provide for NRC review and approval:
- 1. A description and discussion of the corporate qualifications of the company or companies that PG&E would propose to carry out the n!!9391-
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independent design verification program, including infbrmation that demcnstrates the independence of these companies.
- 2. A detailed program plan for conducting the design verification program.
In recognition of the need to assure the credibility of the design verification program, NRC will decide on the aceptability of the companies proposed by PG&E to conduct this program after providing the Governor of California and Joint Intervenors in the pending operating licensing proceeding 15 days for comment. Also, the NRC will decide on the acceptability of the plan proposed by PG&E to conduct the program, after providing the Governor of California and the Joint Intervenors in the pending operating license proceeding 15 days for comment.
Prior to authorization to proceed with fuel loading, the NRC must be satisfied with the results of the seismic design verification program and with any plant modification resulting from that program that may be necessary prior to fuel loading. The NRC may impose additional .
requirements. prior to fuel loading necessary to protect health and safety based upon its review' of the program or any of the information (.
provided by PG&E. This may include some or all of the requirements specified in the letter to PG&E dated November 19, 1981.
Responses to each of'the. four questions in your. letter are enclosed.
A decision to permit PG&E to proceed with fuel leading will not be made until all the actions contained in the Comission's November 19, 1981 Order are fully satisfic Sincerely, Nunzio J. Palladino
(
cc: Rep. James T. Broyhill l, '
Enclosures:
- 1. Commission Order, dated 11/19/81
- 2. Ltr from Office of Nuclear. Reactor Regulation, NRC to PG&E dated 11/19/81
- 3. Responses to Questions i-
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SECY-82-414 sp ;
POLICY ISSUE FOR: The Commissioners
. (Notation Vote)
FROM: William J. Dircks, Executive Director for Operations ,
SUBJECT:
DIABLO CANY0H DESIGN VERIFICATION PROGRAM - .
PHASE II RECOMMENDATIONS PURPOSE: ,
In accordance with the Commission's request (CCMJA-82-6) of July 27, 1982, this pap e~ r provides the staff recommendations regarding Phase II of the Diaolo Canypn Independent Design Verification Program (IDVP)' and its relationship to the ongoing Phase I program.
DACKGROUND: By memorandum dated September 24, 1982, we provided you with a Status Report of ongoing activities associated with the verification of the seismic design of Diablo Canyon Unit 1. The nemorandum noted that findings from Phase I of the IDVP and other recent developments may influence the staff's conclusions with regard to the Phase II Program Plan which was submitted to the NRC for approval on June 18, 1982. We have continued to pursue those matters and have developed our recommendations with regard to the Program Plan. The staff findings and recommendations are discussed below.
DISCUSSION: We have summari::ed in Figure 1 the elements of the Order I and letter of November 19, 1981. The original requirements I
needed to support a fuel-load / low-power (FL/LP) decisica l have become known as Phase I whereas items originally requiring completion before a decision regarding power levels greater than 5". were defined as Phase II. It is imocrtant to note that although they were defined as such at the time, both the Phase 10roer and the Phase II letter
- acknowledged that an expansion of either or both efforts may be necessary. In this context, the staff examined
- the overall findings to date and a number of recent
. developnents to determine if any modifications to the l originally defined scope of Phase I and Phase II need be made.
Centact:
'. Eisenhut, NRR/DL X27672 l
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Overall Findinos to Date As of September 24, 1982, th'e IDVP had identified 199 technical concerns requiring resolution. A number of these have subsequently been. resolved and 13 have been classified as "A/B" errors. These are errors in which design criteria or operating limits of safety-related equipment could have been exceeded and physical modifications, changes in op1 rating procedures, more realistic calculations, or retesting are required to bring the plant into conformance with the original design. These technical concerns can be summarized as follows:
Fully resolved: 147 Errors:. 3 (3 A/B errors)
No design criteria or operating limits exceeded: 144 Review continuing: 52 by PG&E: 28 (9 A/B errors) by IDVP: 24 (1 A/B-errors)
Total 199 fE3'A/B errces)
'Furthermore,1&E has identified 33 concerns within their Internal Tectif cal Program (ITP). Six have been resolved and 27 concerns have been classified as A/B errors.
These errors are not directly additive because there exists some overlap between the IDVP and ITP errors.
As of September 15, 1982, PG&E had completed 344 modifica-tions as folicws:
Modifications Pipe supports 257 Other supports 43 Annulus struc ure 38 other 6 Total 344 It should be noted tnat not all A/B errors will necessiate modifications and that a single error may result in a number of modifications. In addition some of these modifications, made to date, were a result of tne errors from either, or both, the IDVP and ITP and some were modifications undertaken by PG&E even though they believe the error could have been shown acceptable by detailed calculations.
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During a meeting on September 1,1982 the staff discussed the modifications made to that date with PG&E. With respect to those modifications, PG3E stated that:
- 1. Ltost modifications flow from their Internal Technical Program and not the IDVP,
- 2. All modifications are to restore margins or to meet design criteria.
- 3. Nothing has been found which would have prevented a system, structure or component from performing its intended safety function in the event of the postulated Hosgri earthquake. ,
Staff Evaluation of Recent Develcoments During recent months, a number of significant developments and findings have occurred whicn influenced our recommendations regarding. the scope of the Phase II Progran Plan as proposed.
For your reference, we have graphically summarized in Figure 2 the functioning of Phase I of the IDVP, the functioning of Phase II of the IDVP, and various activities undertaken '
by PG&E and their relationship to the IDVP. The developments-examined by the staff were briefly discussed in our September 24, 1982 memorandum to yce and are further discussed in enclosures to this memorandum. The developments include:
- 1. IDVP Phase I Results:
- a. The identification of a larger than originally expected number of errors or open items (E0Is) from both the IDVP and the PG3E ITP as discussed above. A list of these errors e;J open items were provided to you as attachments to the September 24, 1982 memorandum.
- b. The issuance of eight Interim Technical Reports (ITR),
as of October 5,1982, including ITR 1, wnich suggested that the sample for the reverification orogram must be exoanded, and ITR 2, which identified deficiencies in QA controls for certain design activities. The staff evaluations of ITRs 1 through 5 are provided in Enclosure 1.
The staff found the,IDVP procedures and verification methods accept">1e and concurs witn the IDVP approach and recommendations.
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- c. The results from an independent analysis performed by
.the staff's contractor, Brookhaven National Laboratory, raised a number of seismic concerns regarding PG&E original seismic analysis of the containment annulus structure. BNL developed a three dimensional vertical model and identified concerns regarding the distributed
- masses, modeling of joints, as-built dimension variations, spectra-smoothing techniques, modeling of piping benos and calculated piping support forces used in PG&E's original analysis. These concerns were forwarded to TES for consideration of their generic implications by the IDVP. PG&E has indicated that a majority of these concerns had been separately identified by the IDVP and/or PG&E. The staff Will audit the IDVP resolution of these concerns. Enclosure 2 provides additional discussion.
- d. Region Y inspection 'of the ongoing activities icentified a number of open inspection issues. These issues include verification that the seismic analysis model adequately characterizes the seismic responses of the Auxiliary Building, Intake Structure and various equipment and components. .Some of these issues had been previously identified by the IDVP.
These issues are being closed out by'both Region V and NRR personnel via their consideration in the in the ITP and 1DVP. A summary of these issues
, is provided in Enc,losure 3.
- e. The original Phase ! IDVP proposed, and the HRC accepted, to include a reevaluation of. the Hosgri analyses only. The remaining seismic analyses will be examined by the IDVP in the Phase II program.
I The staff discussion of this action is provided U in Enclosure 4.
- 2. IDVP Phase II Results:
4
- a. Preliminary results from the R. F. Reedy Phase 11 0A audit indicated that there exist deficiencies in the QA. controls of the PG&E design progran and of certain of their contractors.
- b. The results from the PG&E initiated QA audits of their in-house design activities and their safety-related service contractors are summarized in Enclosure
- 5. The PG8E findings are consistent with the preliminary results from the R. F. Reedy Dhase II OA audit ( discussed in a. aoove) . Region V attended the R. F. Reedy, Inc. audit exit meeting and subsecuently audited the PG&E self-review. A memorandum discussing
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e the Region's comments oa both of these activities is provided as Enclosure 6. The ' staff has also forwarded the e comments to TES for their consideration in the IDVP, in particular with respect to the scope of the audit as. compared to the scope delineated
, in the NRR letter of. November 19, 1981.
- 3. PG&E Actions:
- a. The establishment by the PG&E/Bechtel Project Team of a corrective action program that includes a
. seismic reevaluation encompassing all safety-related
. structures, systems, and components. The scope of the effort is discussed in more detail in Enclosure 7.
The IDVP will audit and consider the results of the corrective action program,
- b. The completion of modifications, as necessary, to restore the "as-built" plant to the "as-designed" condition. A listing of modifications made to date, and a listing of anticipated additional modifications, are included in Enclosure 8.
- c. The undertaking of a review, to determine the adequacy of the seismic evaluation originally done by Blume,
, called the Blume Internal Report (BIR). Speci fically, the BIR includes an internal technical review, conducted by Blume, of :ivil/ structural work performed with particular attention to the work for the Hosgri evaluation in the 1977-1978 time frame. The results of this review have been documented by Blume in a report and submitted to the staff in early October 1982.
- d. The recognition by PG&E that there is probably no step-wise distinction between pre-1978 and post-1978 activities as was assumed in the issuance of the Ccmmission Order'and the NRR Letter of November 19, 1981.
- e. The decision by PG3E to undertake a reevaluation of construction QA proposed as part the IDVP.
While PG&E has stated tnat they have no reason to cuestion the quality of construction, they also stated that such a program is needed to remove any doubts. The IDVP has recently submitted a program plan for review of these activities. Region V has reviewed this proposed program ~ and found it to be satisfactory and consistent with previous Region V recommendations.
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The decision by PG&E to undertake a walkdown of
'as-built safety-related structures, systems, and components to increase confidence that as-built conditions are identified and evaluated.
9 The PG&E pro'posal for staged licensing is discussed in Enclosure 9. This proposal is to complete, prior to fuel loading, the review, analysis, and modifications for those systems required for fuel load. The remainder of the systems will be examined subsequently. The staff has reviewed the PG8E proposal and concurs in their identi.fication of systems with some additions to the " supportive" list of equiprent.
4.
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IDVP/ITP Interface:
The IDVP has presented plans to include the results of the expanded PG&E activities as inputs to the IDVP j- program. This proposal is included in the Figure 2
,' flow chart.
Proposed Phase II Program With regard to the contractors for Phase II of the IDVP, PG&E has proposed to retain Teledyne Engineering Services (TES) as~the IDVP program manager. The principal subcontractors to TES are Robert L. Cloud Associates (RLCA), R. F. Reedy, Inc. (RFR), and Stone & Webster Engineering Company (SWEC).
The staff has examined the financial independence of the Phase II contractors from both PG&E and Bechtel in addition to the independence of individual employees assigned to the i
IDVP. The criteria used by the staff in its evaluation are the same as those used in the Phase I evaluation. The staff also has reviewed the technical qualifications of the IDVP contractors. Enclosure 10 summarizes the staff review l and our findings, determining that the contractors are technically qualified and are independent.
The adecuacy of the Phase II Program Dlan was reviewed by the staff against the requirements of our November 19, 1981 letter. Enclosure 11 describes the proposed program 1 .
and presents the staff findings on that program.
CONCLUSIONS: Based on our review of the proposed Diablo Canyon Phase II IDVP, the status and results of other ongoing activities, as discussed above, and consideration of comments of the intervening parties to this proceeding, we have reached the following conclusions:
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- 1. With respect to the amount of reevaluation activities required prior to any decision regarding fuel-load / low-power, we have concluded' that, in addition to the require-
.ments of the November 19, 1981 Order, review and evaluation <
efforts for Phase II activities should be sufficiently complete.to provide confidence that no major deficiencies '
exist. We therefore require that an interim report on Phase II, summarizing the IDVP conclusions and
. results to date, be submitted prior to the FL/LP decision. ,
We recognize that certain plant inodifications will i likely not be needed prior to fuel loading, and accordingly we conclude that selected modifications could be deferred until af ter fuel load. Similarly, we recognize that completion of the Phase II program and other activities proposed by the IDVP and PG&E to provide additional assurance that the plant is b'uilt in accordance with the application, need not be completed prior to a fuel-load / low-power decision. Figure 3 summarizes the staff's proposal .
- 2. With respect to the competence of the contractors l
proposed by PG4E project to carry out the Independent Design Verification Program, we conclude that the necessary experience and technical skills are being provided.
- 3. With respect to the independence of the contractors proposed we conclude that the independence of the
, IDVP individuals are acceptable in view of those independence criteria providea in the Commission's February 1,1982. responses to Congressmen Dingell and Ottinger.
- 4. In. recognition of the expanded PG&E Frogram, we believe it-l is appropriate that the ongoing IDVP alter its aoproach to
[' include a sampling of all of PG&E's efforts to gain overall '
l confiderice in that reverification effort.
It
s- e RECOMMENDATIONS: That the Commission:
- 1. Acorove the Phase II Program Plan and contractors as modified by the staff conclusions in Enclosure 11.
- 2. Approve the redirection of the Phase I/ Phase II division to require that the Phase II review / evaluation efforts be sufficiently completed, as identified in Figure 3, prior to a fuel-load / low-power decision.
(.. %!
.'. ; William J . Dircks Executive Director for Operations
Enclosures:
As stated Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Thursday, October 28, 1982.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Thursday, October 21, 1982, with an information copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commi.ssioners and the Secretariat should be apprised of when comments may be expected.
This paper is tentatively scheduled for consideration at an Open Meeting during the Week of October 18, 1982. Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.
DISTRIBUTION:
Commissioners OGC OPE OCA OIA OPA REGIONAL OFFICES EDO ELD ACRS ASLBP ASLAP SECY
FIGURE 1 NRC NOVEMBER 19, 1981 REOUIREMENTS "
PHASE I__
COMMISSION ORDER (CLI-81-30) e Suspended fuel loading and low power testing license.
e Required:
- 1. Results of an IDVP for all_ S3R contracts prior to 6/78.
See Note (i) below.
PHASE II STAFF LETTER e Activities required prior to a decision regarding power levels above 5%
- 2. IDVP for NSSR contracts prior to 6/78.
- 3. IDVP for PGE internal QA, and ,
4 IDVP for all service related contracts post 1/78.
See Note (1) below.
NOTES:
(i) Items -1, 2, 3, and 4 each require:
- a. A technical report of the basic cause of the errors, their significance, and their impact on facility design.
- b. PGE's conclusion on effectiveness of IDVP, and
- c. A schedule for modifications; including a basis for any deferred beyond a fuel load decision.
- Both Phase I and Phase II activities must be performed by a qualified.
independent organization.
Both-Phase I and Phase Il required that a Program Plan be submitted for:our review and approval, and Both Phase I and Phase II were necessary, but not necessarily sufficient, activities for the appropriate approvals.
NOMENCLATURE:
IDVP = Independent Design Verification Program SSR = Seismic Service-Related NSSR = Non-Seismic Service-Related
- Figure 2: 'VP/PGAE PG&E Act. les Actis s
_j .
- -l 4A l-ITP BIR lS L._ .l I I._.I_ elf. Assessment '
l PilASE I (in' solid lines)
PG&E - Existing 1. IDVP of all SSR prior
. Criteria to 6/78
. Analysis
. Design a. Basic Cause Report
- b. PG&E Concl. re:
E f fectiv.eness
..v ..
a . . . . . . . ._ c. Schedule for Mods.
IUVP Phase 1 & 11 . Construc-__
TES etion QA ,
l.
P i a i. 1 RCLA RFR S&W.i I PilASE II (in " dotted" lines)
. 1. IDVP for NSSR prior to Sampling 6/78 Check Calcs.
- 2. IDVP for PG&E internal
-Independent QA Cales.
- As-built 3. IDVP for all SR' post 1/78 y,,_. _
E01s Resul ts I for each of 2, 3, "4
- a. Basic Cause Report '
ITRs b. Effectiveness Deci'sion
- c. Schedule for Hods.
Basic Cause i Other additional activities
-Resolution of Generic implications undertaken or prop _osed by E01s PG&E. (dashed lliies) l Final Report
_ o 4 PG&E j)ffe'ct*venessreport > tlRC I Ce litisin I rs f tie- f t.ide -
Figure 3: Surm:ary of Staff Procosal STAFF-PROPOSAL ACTIVITIES During Prior to Prior to FP Decision Operation A. Phase I November 19, 1981 Order FL/LP (Prior to FL and i D)
- 1. IDVP of all SSR prior to 06/78 (interpreted to be Hosgri)
B.. Phase II November 19, 1981 Letter (P~rior to exceedino 5%)
- 1. IDVP for NSSR prior to 06/78 bInterim /
Report
(see
- 3. IDVP fon all SR post 01/78 /
C. Other Interim
- 1. -ITP QA Program Report /
(see note) Interim 7
- 2. Construction QA Report (see y
- 3. As-built walk-down note)
- 4. Modifications completed, as # '
/
necessary
/
- 5. PG&E/W interface evaluation
~
- 6. Determination of correct Hosgri /
spectra Interim
- 7. IDVP for all SSR (non-Hosgri)
- Report "
(prior-to C6/78) (see note)
NOMENCLATURE:
/ activity complete SSR: Seismic service-related contracts NSSR: Non-seismic service-related contracts SR: Service-related contracts Note: For each of these acti'vities, an Interim Report is required to
. demonstrate that activities are suf ficiently complete to ensure that no major unidentified defic'iencies are likely to exist. 7ne Interim Recor_t_ is also required to set forth a justification for deferring a portion of that activity.
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List of Enclosures
- 1. Staff Evaluation of Interim Technical Reports
- 2. BNL Indeoendent Analysis
- 3. Diablo Canyon IDVP Open Inspection Issues
- 5. PG8E Look Back Review of Service Contractors' Quality Assurance Prograns
- 6. .R. F. Reedy and PG8E Review of Diablo Canyon Design
- Quali ty Assuran'ce ,
- 7. PG&E Corrective Action Program
- 8. fiodifications Resulting from IDVP and ITP .
- 9. PG&E Proposal for Staged Licensing
- 10. Staff Evaluation of Phase II Contractors
- 11. Staff Evaluation of IDVP Plan - Phase II I
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-STAFF EVALUATIONS OF INTERIM TECHNICAL REPORTS ITR l_(ADDITIO AL-VERIFICATION AND AD01.TIONAL SAMPLING)
Introduction ~ ~ / -c m-ITR 1 was developed as a/ status reportion the' original generic sample. In some areas (e.g.3, buildings and'large-bore' piping), the results from the original sample weresnot felt to be sufficient to.close the item. Problem areas were identified and .2dditional . sampling was judge'd necessary to fully define the scope and saverity of theEproblem Analyses of' ocner samples were completed with results_that vere judgedfsufficient to close the item under review (e.g.,
tanks and;ITRs* on; thatispecific subject)..are shown as being in preparation.
Still other;ireas (e.g., HVAC and conduit ' support) were under review at the time the report was released.
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Subsequen't to the publication of ITR 1, PG&E announced that their Internal ~
Technical. Program._(ITP)^was to be-expanded with the development of a joint PG&E/Bechtel program and that inany of the _ items neld open in ITR 1 were to be
~
included. ;The,s'taff has received.7some-information concerning the scope and content of the PGAE/Bachtel progran.. The current staff 1 understanding of those recommendations of.ITR l~that~are included in the PG&E/Bechtel program is re-flected in the fc~ lowing susmary and status for each of the nine items discussed in the1 report.
~' ~
-Summary of Reo' ort 5 ,
Buildings
-Thereviewfof7thebuildingstasbNsedonasampleoftheauxiliary/ fuel handling building for indepeadent analysis, Six issues were raised either as error or o' pen items (E0Is) or generic concerns. ITR 6 on the auxiliary / fuel
~
handling building has just recently been. issued, and a total of 16 E0Is has been identified. , c.
As a result oflthe concerns raised about the seismic analysi's of the buildings relating to theastructdral' configuration, the IDVP recommended that all of the safety-related buildings.ge reviewed to assess the impact of design changes on
'the analysis. .In addition, selected changes would be field verified.
PG&E has hommitted to-incorpcrate th'is.compo'nent in their corrective action plan (ITP) sections 2 l'.1 througn 2.1.5. ; Verification of this' item will be performed by the IDVP. .
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' Piping. ,
, .The review of ilarge-bore piping discussed in ITR J was. based on a sample of ten
'i
' piping analyses chosen for independent analysis. Approximately 40 issues were
' raised.either as COI or generic concerns.
- As a result of'the.l'arge number of concerns identified, tha IDVP recommended that.the IDVP undertake a larger sample for purposes of further defining the
- scope,.and extent of problems that might require corrective action. The larger i sample would havE Consisted of five additional piping analyses that would represent lines connected' to large pipe analyzed byothers, other systems, 'and L field-run computer-analyzhd pipe. In. addition, with regard to the as-built configuration, the IDVP also recommended that PG&E " review and revise as necessary all piping design *eview isometrics" and further that PG&E " review and revise pipe and pipe support analyses as required."
The:IDVP recommendations however have been incorporated in the PG&E corrective action plan ~(ITP) section 2.2.1 and the results are scheduled to be sumbitted
- Lin November 1982. Verification of the disposition of these recommendations by the _PG&E corrective action plan will be performed by the IDVP.
- ,
- Pipe Supports
. The review of pipe supports was based on a sample of twenty supports chosen for
- field verification and independent analysis. The field verification is l' complete and the analysis is continuing. Three issues were raised as either E0Is or generic-concerns. The most pressing concern is the apparent' omission of certain ! pipe inertia loads on the supports.
As a result of this concern for inertia' load. omission the IDVP recomended that
, the IDVP do additional investigation. This investigation would have consisted of documenting the method used oy the selected computer programs, running
. simple problems.to ~ verify the conclusions, and reviewing one or more of the initial pipe samples.
- .The IDVP recommendations however have been inclu.ded as a portion of the PG&E corrective-action plan (ITP) section 2.2.1 and the results 'are scheduled to be
- sub'nitted in~ November
.- 1982. Verification of the disposition of this item by the corrective acti'on plan will' be performed by the IDVP.
3 Small-Bore Piping
. . The review of-small-bore Dioina was based on a samole of three runs chosen for field verification and a review of the support spacing criteria. Approximately 10-issues were raised, either as E0Is or generic concerns.
i-As a result of these findings, additional verification was recommended by the
. I.DV P . This-verification would have consisted of reviewing and revising, as necessary, the isometrics and spacing criteria. It was recommended that RLCA analyze five examples of axial pipe runs and lug design and five examples of small_-bore lines to verify the adequacy of the " engineering judgement" used
.in treatment of conditions other than those covered by PG&E criteria.
- . 1-2
Tne IDVP recommendations however have been included in the PG&E corrective action plan (ITP) section 2.2.2. Verification of the. disposition of this item will be performed by the IDVP. The PG&E results are scheduled to be submitted in November 1982. ,
Equipment The review of the six equipment types was based on a sample of two valves, two items of electrical equipment, three tanks, one bett exchanger, three pumps, and two HVAC components chosen for independent analysis. Eleven issues were raised as either E0Is or generic concerns. The resul.ts and recommendations of the original tank' sample have been reported in ITR 3.
As a result of the concerns identified in the above review, the IDVP recommended that the IDVP undertake a larger sample be reviewed uso that the scope and extent of the problem could be better defined. The larger sample would have consisted of the main control board, the remaining two Hosgri required tanks, the two remaining Hosgri safety-related pumps, and an addition 51 sample of two HVAC components.
PG&E is addressing these IDVP concerns in their corrective action plan (ITP) section 2.3 and the results are scheduled to be submitted in October 1982.
Verification of the desposition of this item will be performed by the IDVP.
Shake Table The review of the seismic qualification of equipment by shake table testing was based on a sample of 44 items divided into seven groups. The grouping was based on seismic inputs, test procedure, location, and mounting. Five issues were raised either as E0Is or generic concerns. The results and recommendations of this original sample have been reported in ITR 4.
As a result of this sample, the IDVP recommended that the IDVP undertake verifying the field locations and mounting of all the equipment excluding the NSSS vendor equipment, and verifying the use of the correct test spectra.
PG&E is addressing the IDVP concern in their corrective action plan (ITP) section 2.3.2.3.3 and the results are scheduled to be submitted in October 1982. Verification of the disposition of this item will be performed byl the IDVP.
Conduit Supports -
The review of the conduit supports consisted of a sample of twenty supports for field review and a sample twenty supports for analysis. The field review has been completed; however, the twenty analysis samples have not been selected or analyzed. Three EDIs and three generic concerns were raised as part of the field review. ,
As a result of the field review findings, PG&E committed to perform a complete reevaluation of all of the supports and the results are scheduled to be submitted in October 1982. Pending completion of the PG&E reevaluation the IOVP will selec'tively verify the PG&E program including analysis.
4
a s HVAC Duct The review of the HVAC ducts consisted of a sample of two sections for field review and independent analysis. The field review is complete, and the independent analysis is currently under way. Two EDIs have been issued and no generic concern has been identified to date.
PG&E is addressing HVAC ducts on a generic basis in their corrective action plan (ITP) section 2.5 and the results are scheduled to be submitted in October 1982. Verification of the PG&E work will be performed by the IDVP.
Hosgri Spectra The review of the seismic inputs into the design consisted of identifying and
' checking the spectra. Approximately 20 issues were raised, either E01s or generic.
As a result of this review, the IDVP recommended that PG&E assemble and issue a controlled set of design spectra that will carry a unique number for each spectra figure.
The IDVP also recommended that PG&E review all Hesgri qualifications against this set of spectra, including the nuclear steam supply system (NSSS) vendor.
A set of controlled spectra has been issued by PG&E as DCM-17. The IDVP will selectively verify the applicability of the controlled. spectra.
EVALUATION:
ITR 1 presents the first compilation of the error and open item (E0I) repor'ts developed by the IDVP. The grouping of the E0I's with the corresponding IDVP task from Phase I program plan Section 5.4.2, as given in Figure 3-2 through 3-9, provides- an effective summary of the IDVP. Although t.he IDVP review for a number of items has not been completed, ITR 1 offers substantial evidence that
.the initial sampling plan is an effective means of examining the seismic adequacy of tae Diablo Canyon plant features considered in the sample.
It appears that the majority, if not all, of the concerns identified in.ITR 1 have been forwarded inta the PGE/Bochtel internal technical program (corrective action plan). Confirmation of this should be accomplished by further IDVP activities.
ITR 2 (QUALITY ASSURANCE PROGRAM)
The second interim technical report (ITR 2) for Diablo Canyon IDVP evaluates the quality assurance program and its implementation of PG&E and of six seismic service related contractors within the scope of Phase I. The report provides
-TES' conclusions on the IDVP with respect to the QA-related work performed by R. F. Reedy, Inc. (RFR) in accordance with Sections 3.0 and 4.0 of the Phase I Engineering Program Plan (DCNPP-IDVP-001). The report was suomitted by W. E.
Cooper, Teledyne Engineering Services, by letter dated June 24, 1982.
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TES' conclu'sion in ITR 2 is, basically, that no additi'onal verification or sampling, beyond that.specified in ITR 1,* is required in response to-the RFR report, in spite of the reported general lack of qual.ity assurance controls during the safety-related design activities performed prior to June 1, 1978.
ITR 2 indicates that additional design verification and additional sampling was already specified in ITR 1 both in the knowledge of the lack of QA controls, and based (primarily) on the design verification that had been previously completed (ITR 2, page 5). However, certain exceptions are identified for the Cygna (ITR 2, p. 33), HLA (ITR 2, p. 33), and URS/J. A. Blume (ITR 2, p. 34) areas of work. The conclusion (ITR 2, pages 32-35) is drawn, therefore, that no additional verification or sampling beyond that already identified is required solely on the basis of the reported lack of QA cnntrols.
ITR 1, submitted by Robert L. Cloud Associates, Inc. (RLCA), recommends 30 additional review, checking, verification or sampling activities based on the results of Phase I of the IDVP. These recommendations are, again, based primarily on the Phase I design verification that had been completed but with the knowledge of the results of the RFR findings reg'arding QA deficiencies.
The recommendations appear to broaden'the scope.of the Phase I effort to pro-vide reasonable assurance that the plant meets the technical critoria for licensing for the areas covered by Phase I. The recommendations include some field verification effort.
The staff concludes, with respect to the Reedy findings for Phase I of the IDVP
'as discussed in ITR2 that, despite the g'eneral lack of certain quality assurance controls for PG&E and several of its subcontractors as identified by the RFR review, the recommendations of ITR 1 and the exceptions noted above in ITR 2 (pp. 33 and 34), when properly carried out and with proper followup, should adequately demonstrate the acceptability of the design effort addressed by Phase I of the IDVP and should resolve our concerns resulting from the lack of QA controls for certain design phase activities.
ITR'3 (TANKS)
Introducticn The-third interim technical report (ITR 3) for the Diablo Canyon IOVP has been reviewed by the staff. The report was also selected as a vehicle for a staff audit of the 'ICVP process and the activities of RLCA in particular. The audit was conducted on September 8, 9 and 10, 1982, at the offices of R. L. Cloud Associates in Berkeley, California.
ITR 3 s'ummarizes the independent analysis and verif,ication of the initial j
sample of tanks at Diablo Canyon Nuclear Power Plant. The tank sample consists i
of the boric acid, starting air receiver, and the diesel generator oil priming
' tanks.
Based on the initial task sample, the IDVP concludes that the tasks repeated by the sample at Diablo Canyon meet the applicable licensing criteria and that
- Additional Verificiation and Additional Samoling, June 10, 1982, Rev. O.
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consequently no further sampling is required. Based dn the staff review of ITR 3, in conjunction with the audit of the technical information assembled at R. L. Cloud Associates for their review, the staff concurs in this conclusion.
In addition, the audit referenced above allowed the staff to trace, in detail, the review process used at RLCA and to assess that process and the level of confidence that this position of.the IDVP provides. .The staff conclu.'es that the RLCA review was thorough and of high technical competence, and was well documented and carried out in full compliance with the-approved program plan.
-Summary of Report .
The tank sample consisted of the three tank types located inside various structures, namely the boric acid tank, the diesel generator starting air receiver vertical tank, and the diesel generator oil priming tank. This sample represents the spectrum of tank configurations within the plant.
The-boric acid tanks are used to store a boric ~ acid sclution that will be injected into the reactor primary coolant loop in the event rapid shutdown of the reactor is required. The tanks shells are 3/8 in. thick and the material is ASME SA-240 Type 304 stainless steel. Each tank is 10 ft in diameter and 15 ft 9 in. in height with a' semi-elliptical bottom and a flat top. Each tank rests on.a skirt 3/8 in, and 4 ft 6 in. tall. The plant contains four such tanks located in the auxiliary building on the el 115 ft floor. The tanks are normally filled with a boric acid solution to within 1 ft 3 in. of the top.
The tank' weighs 9000 lb empty and 76400 lb when full. The skirt is anchored to
' the concrete floot by 36 1-in.-diameter ASTM A-307 bolts distributed evenly along the skirt perimeter and are cast into the concrete floor. The boric acid is moved to and from the tank by attached piping.
The six diesel generator starting air receiver vertical tanks are used to store compressed air at 250 psi for starting the diesel engines. Two tanks are located on opposite sides of each diesel generator unit, which are positioned at the northwest corner of the turbine building. Each tank consists of a 3-ft-diameter,1/2-in.-thick cylinder with a 1/2-in. thick elliptical head at both the top and bottom. Overall height is 8.5 ft and total weight is 2045 lb.
The material is ASTM A-515 grade 70 stainless steel. Each tank is supported by a skirt connected to a base plate anchored to the el 85 ft concrete floor by four 7/8-in.-diameter bolts cast into the concrete floor.
The three diesel generator oil prieing tanks are located at the northwest corner of Unit 1 turbine building at el 85 ft. Each tank consisted of a 16-in.-diameter stainless steel cylinder 13.25 in. tall with a flat top and bottom. The tanks are mounted on top of an 83-in.-tall, 4-in.-diameter schedule 40 ASTM A-53 steel pipe. The tank is supported laterally by two horizontal perpendicular braces anchored to the adjacent walls at el 92 ft.
Each tank has a level indicator mounted externally to the cylinder. Each tank assembly weighs 198 lb when full of fuel oil and the support pipe weighs 93 lb.
The pipe support is anchored to the concrete floor at el 85 ft by four bolts.
The procedures and methodology used by RLCA to evaluate the tank sample are summarized in the following steps:
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(1) Acquire drawings and specifications and trace quality assurance for each document.
(2)_ Establish design criteria (FSAR,.Hosgri criteria', codes, Regulatory Guides).
.(3) Establish envelope response spectra for each tank considering all tank locations, using the Hosgri Report response spectra and damping.
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(4) Perform field inspections to confirm tank locations, mounting, appurtenance, and other design features."
(5) Estimate fundamental natural frequency csing a simple single-lumped mass single-spring model. (The slashing effect of the contained fluid was accounted for by using procedures from TID 7024 chapter 6.)
(6) Using the fundamental frequency estimates, determine the corresponding acceleration from the envelope response spectra established above.-
(7) Compare the seismic loading to that used in the' original design and adopt the more conservative loading.
(8) Use the equivalent static load method'to evaluate the structural adequacy of the tarks by
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(a) _-Applying horizontal and vertical seismic loads.at the center of gravity of the tanks.
(b) Evaluat'ing the stresses at critical locations (based on the analyst judgments) using_ standard engineering hand calculation formula and/or a finite element computer program.
(9) Compare the computed stresses with allowable based on FSAR commitments as modified by the Hosgri Report.
(10) Compare the computed stresses with those presented in the design reports.
Each step above was performed by one individual and checked by another. A complete documentation file was maintained.
Evaluation I
~In the course of this evaluation, the staff and tneir consultant firms reviewed ITR 3 on its own merits and then developed audit questions based on the review.
In some instances 'the RLCA calculations were more detailed and comprehensive than the PG&E design calculations; i.e., RLCA computed stresses at more 1,ocations or considered more design features than did PG&E in their. original i
design calculations. Specific examples includes:
-(l) The evaluation of the diesel generator starting air receiver tank support skirt for buckling, in which RLCA considered the combined vertical and horizontal loads while PG&E considered only the vertical loads.
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(2) The evaluation of str sses in the weld between the diesel generator
' starting air receiver ' tank support skirt and the lower head, in which RLCA dev' eloped a detailed axisymmetric finite element model of the skirt-tank
. head region whereas PG&E relied on the composite overall tank model to produce the stress fields.
It should be noted, however, that the tanks were originally designed to meet Section VIII of the ASME Boiler and Pressure Vessel Code which could, by usual practice at the time of original design, be interpreted to not fecuire as comprehensive an analysis as the one performed by RLCA. RLCA followed good current engineering practice while performing this review.
The staff finds, after the ITR review and tne audit in the offices of RLCA, that the evaluation procedures and methodology are acceptable. The evaluation, although based on' simplified seismic models, hand calculations, and limited computer analysis, is in general more comprehensive than the original design calculations. In addition,'the calculations are supported by field verifications of the tank configuration and good quality control of the evaluation basis. The staff concludes that the procedures used by RLCA to verify the tanks are technically sound and the conclusions reached by RLCA are 4
supported by the facts developed.
ITR 4 (SHAKE TABLE TESTING)
Introduction The fourth interim technic _: report (ITR 4) for the Diablo Canyon IDVP has been reviewed by the staff. Th's report was also selected as a vehicle for a staff audit'of the IDVP process and the activities of R. L. Cloud Associates in particular. The audit was. conducted on September 8, 9 and 10, 1982 at the offices of RLCA in Berkele;, California.
The purpose of ITR 4 was to determine if the seismic testing procedure used for Diablo Canyon conformed with the licensing' criteria. The equipment considered
. in ITR-4 was the Class 1E electrical equipment and instruments listed in l Table 10-1 of the Hosgri Report that were qualified by PG&E or a seismic service-related contractor. The content of the report is not entirely consistent with the title. ITR 4 addresses only verification that spectra identified for use in the test programs were appropriate. The title may infer to some a complete verification of shake test methods, including equipment test mounting and its correspondence to field conditions, test anomalies, and test procedures. The staff understands that these matters will be the subject of a subsequent ITR.
Summary of Reoort Seven groups of items tests at Wyle Laboratories were chosen as the sample.
The individual groups contained items from a commcn plant location. Forty-four individual items were evaluated.
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The seven groups are listed below. -
Group I --
Switchgear area of the turbine building el 119 ft Group II. -- Diesel generator area of the turbine building el 85 ft Group III -- Cable spreading and control room area of the auxiliary building el 128 and 140 ft Group IV --
Battery area of auxiliary building el 115 ft Group V --
.Switchgear area of the auxiliary building el 100 ft Group VI --
Adjacent to switchgear areas of turbine building el 119 ft Group VII -- Control room of. auxiliary building el 140 ft The verification of spectra used for shake table testing purposes was undertaken following the compilation of the spectra set. The procedures and methodology used by RLCA to evaluate the shake table testing sample are summarized in the following steps.
(1) Acquire a list of all PG&E equipment and their contractor-supplied equip-ment qualified by shake table testing.
-(2) Determine the locations of all equipment.
(3) Field verify all equipment locations.
(4) Establish worst-case spect'ra for each equipment group by:
(a) 'Following the PG&E procedures in which all equipment was segregated into seven groups.
(b) Selecting a spectra that exhibits the greatest amplification considering all equipment locations.
(c) Using a Hosgri Report damping value or the one selected by PG&E if the PG&E value is more conservative. In some cases, PG&E used a lower damping value that would produce a higher load which is, therefore, more conservative.
(5) Compare worst-case spectra with PG&E test spectra:
(a) Test spectra were considered acceptable if a line drawn through minimum spectral acceleration values enveloped the worst-case spectra by a margin of 10% in acceleration at all frequencies, except those frequencies less than 2 Hz. Motion at frequencies less than 2 Hz was judged.to be unimportant in the qualification of equipment for Diablo Canyon because either the recuired spectra has a very low acceleration value at less than 2 Hz or because the equioment did not have'a significant modal frequency at less than 2 Hz.
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(b) For those frequencies where the 10% rule was violated, the test spectra was accepted if a line drawn throujh the local mean of the tests spectra exceeded the worst-case spectra by 10% (peak accelera-tions with significant frequency span were' grossly underestimated by the minimum curve).
(6) Compare worst-case spectra with PG&E target spectra.
Evaluation Based on staff review of ITR 4 and subsequent audit of the evaluation procedures and methods used by RLCA, the staff concurs with the IDVP concluding that the response spectra used for shake table testing of Class 1E electrical equipment were correctly used. The evaluation is based on RLCA compilation of Hosgri spectra and supoorted by field audit of the equipment location and configuration. RLCA had instituted a good quality control program to track the comprehensive documentation used as the evaluation basis. The staff concludes that the procedures used by RLCA to verify the shake table testing of the Class 1E electrical equipment are technically sound, and the conclusions reached by RLCA are supported by the facts developed.
ITR 5 (DESIGN CHAINS)
Introduction The fif th_ interim technical report '(ITR 5) fo- the.Diablo Canyon IDVP has been reviewed by the staff.
ITR 5 presents the Phase I design chains for .iablo Canyon. It also summarizes the methods used by RLCA to-develop the design chains. The design chains defined by RLCA illustrate structure of PG&E's evaluation of buildings, equip-ment, and components for the postulated 7.5M Hosgri earthquake.
The purpose of the design chains is to show internal and external PG&E inter-faces, describe information passing between interfaces, and list the responsi-bilities of seismic service-related contractors and PG&E internal design groups prior to June 1978.
The design chains were developed by RLCA between October 1981 and March 1982.
l Six seismic service-related contractors emolored by PG&E prior to June 1978 were identified. These contractors became the basis for the cuality assurance l audit performed by R. F. Reedy, Inc. (RFR), wnich was also specified in the Phase I plan and was the subject of ITR 2.
Summary of Reoort RLCA developed the design chain using the following metnod. First, the Hosgri Report was reviewed to define the sample space. Second, a PG&E saismic l service-related contractor list was developed. Third, a selection process was used.that screened out those contractors who had no significant effect on the final Hosgri plant uesign. Also eliminated were cont actors wno performed work I
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to establish Hosgri criteria or were involved in cortstruction or field modificatians.
In early October 1981, RLCA met with PG&E management and engineering personnel to develop an initial list of PG&E contractors who performed analysis, design, or testing for the plant from the project inception to June 1978.
As a result of these meetings, a list was established that consisted of PG&E contract numbers, start and end dates, and a brief description of work scope.
This list served as a basis for additional meetings to discuss contractor work scope in detail. For each of the contractors, RLCA attempted to meet with the staff member responsible for the PG&E interface. In many cases, the exact scope of the contractor's work could not be established. Five slightly different preliminary lists were also developed by PG&E between October 1981 and March 1982. RLCA compared these lists with the initial list. When differences were encountered, RLCA resolved them through further meetings and discussions. -
In April 1982, PG&E formally issued a list of contractsjentitled "Diablo Canyon Consultant Contracts - Revision 2." This list included the contract number, work scope, contract dollar amount, PG&E department interface, and an indication as to whether the work was safety related. RLCA verified that PG&E's formal list was consistent with the previously gathered information and adopted the formal contractor list for the design chain.
The design chains presented in ITR 5 are organized according to the items evaluated oy PG&E for the postulated Hosgri earthquake. Each chain represents the sequence for the evaluation of major groups of items. Design chains for the sixteen groups listed below are provided:
Buildings Electrical equipment Piping Instrumentation Pipe supports Outdoor water storage tanks i
Heat exchanger Buried piping Tanks Buried tanks l Pumps HVAC duct supports l-HVAC equipment Cranes Valves Electrical raceway supports In general, the chain begins with the supplier of the drawings and response spectra generated by URS/Blume and ends with qualification. Internal and external PG&E interf aces are shown in relation to the information they transmit, review, analyze, or test.
ITR 5 presents the IDVP' conclusion that only the following six contractors had a significant effect on the seismic design and qualifications of the Diablo Canyon piant:
Applied Nucleanics Incorporated (ANCO)
Cygna Energy Services (EES)
EDS Nuclear, Inc. (EDS)
Harding Lawson Associates (HLA)
URS/ John A. Blume and Associates, Engineers (Blume) 1-11 L
Wyle Laboratories (Wyle) .
Evaluation
.The staff concurs _ that the format and general content of ITR 5 satisfies the NRCfrequirement for definition of the design chain network required in Phase I of the IDVP. In the course of the staff review, inquiries were made with RLCA to ascertain the criteria for excluding seismic service-related contractors
-that were judged to~have no significant effect on final plant design. RLCA
' identified two_ broad categories for excluded contractors.
The first included highly specialized consultants who only participated at- random times and for
-small dollar-value contracts. The second category included consultants or contractors whose work had been superseded by PG&E efforts or others. The staff concludes that these were appropriate criteria for exclusion. The staff therefore also. concurs that the group. of six contractors is the appropriate
. group'to be considered in the independent quality assurance and design qualification review.
The following additional ITR's have been issued and are currently under staff review:
ITR 6 - Auxiliary Building ITR 7 - Electrical Raceway Supports ITR 8 - Verification Program for PGLE Corractive Action O
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a Enclosure 2 BNL INDEPENDENT ANALYSIS During the early ' stages of evaluating t'be so called " diagram error" the staff felt that the complexity of the situation warranted an independent-analysis for the containment annulus region in question. With this objective in mind,
-the ~ staff requested the assistance of Brookhaven National Laboratory (BNL) to perform a best available analysis without reference to the time when the original analysis was done nor the technique's used at that time. The BNL staff developed a three dimensional vertical seismic analysis model fer the contain-ment annulus. structure based entirely on the information obtained from PG&E.
BNL has since completed the analysis and published their report as_NUREG/CR-2834, entitled Independent Seismic Evaluation of the Diablo Canyon Unit 1 Centainment Annulus Structure and Selected Piping Systems." Our initial review of the repc' t-lead the~ staff to co,nclude, as a minimum that the following items required fur .e r exploration' and assessments as to their generic implications.
- 1. The distributed masses of the steel members comprising the annulus struc-tuscs apparently were not included in the mathematical model used in the original seismic analysis.
- 2. The mathematical model used in the original analysis apparently considered the joints between the beams and columns to be rigid whereas the BNL inter-pretation of the drawings indicate these joints are more appropriately considered flexible (shear carrying only).
- 3. Statements in the URS/Blume report "Diablo Canyon Nuclear Plant Unit 1-Containment Structure, Dynamic Seismic Analysis for 7.5 M Hosgri Eartn-quake," May 1979 (page 11), concerning the structural connections may not be consistent with the mathematical model used in the original analysis.
- 4. The response spectrum smoothing techniques employed in the original analyses appear inconsistent with the FSAR commitments. -
- 5. Design dimensions were apparently used instead of the as-built dimensions l
in the two piping problems sampled (PG&E piping models, 6-11 and 4A-26).
- 6. The SD bends in the piping analysis were apparently modelled as long l radius bends. This has the effect of softening the model and recucing the natural frequencies.
l- 7. The piping support forces computed by 'the BNL model are much larger than those computed by the PG&E model.
The BNL report was transmitted T.o tne IDVP by letter from H. Denton to l W. Cooper dated July 1, 1982 recommending that the report be treated as an li f
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input to the IDVP decision making process regarding seismic adequacy of Diablo Canyen Unit 1. In addition, it was requested that IDVP inform us of their views regarding the validity of the BNL results and an assessment of their generic implication.
The staff has requested continued participation by BNL in the staff review of the IDVP. In addition to BNL support through various technical assistance programs that provide continuing input to the staff review in the structural, mechanical and equipment qualification review areas, NRC has specifically used Dr. Paul'Bressler of BNL has been retained as,*the reviewer for the Mechanical Engineering Branch. In addition, NRC intends to use other 3NL staff and their
- consultants as appropriate to assist in auditing future IDVP efforts with respect to the PG&E corrective action plan (see Enclosure 7).
In conjunction with the staff review, BNL will undertake the following additional independent analyses.
- 1. independent horizontal seismic analysis for the annulus structure.
- 2. seismic and str'ess analyses of one buried diesel oil- tank, and
- 3. independent analyses for two additional piping problems (one of Westinghouse scope and one of PG&E scope).
These areas were chosen to provide the staff with confirmatory information in areas that either are not being included in the PG&E/Bechtel corrective action plan or to complete previous BNL analyses efforts. These efforts are anticipated to be completed in January.
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4 ENCLOSURE 3
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Enclosure 3 DIABLO CANYON IDVP OPEN INSPECTION ITEMS
- 1. Auxiliary Building - Verify that the seismic analysis model adequately characterizes the seismic responses of the structure and the in-situ stru'cture masses and stiffnesses. This matter will be resolved by the IDVP and the NRC staff.
- 2. Criteria for Measurement Tolerances and Piping Supports - This matter will be resolved by the ITP and reviewed by the IDVP and the NRC staff.
- 3. Examine Changes to IDVP - This matter will be resolved by the NRC staff.
A. Piping As-Built Discrepancies - Verify the piping models reflect as-built configurations. This matter will be resolved IDVP and the NRC staff.
- 5. Intake Structure - Verify that all safety related components were designed considering appropriate response spectra corresponding to their attachment points. This matter sill be resolved by the IDVP and the NRC staff.
- 6. Containment Polar C'rane - Verify the structural integrity and response of the polar taking int' account the 3-D seismic excitation of the crane and the flexibility < ' the seismic stop support structures. This matter will be resolved by the ITP and reviewed by the IDVP and the NRC staf f.
- 7. Dome Service Crane - Verify the structural integrity of this crane considering appropriate response of the supporting polar crane. This matter will be resolved by the NRC staf f.
i 8. Piping and Support - Verify that piping analysis procedures include the load combination or stress allowable criteria and that appropriate snubber flexibilities are included in the RCLA analyses. This matter will be resolved by the NRC staf f.
'! 9. Main Annunciator Cabinet - Verify the adecuacy of RCLA equipment calculations, the PCuE cabinet response calculations and the in-si tu adequacy ofthe cabinat construction. This matter will be resolved by the IDVP and the NRC staff.
- 10. Flexibility of Certain Containment Structures - Verify the aceauacy of the structures and the attached piping, equipment and components considering the flexibility of the steam generator and pressurizer enclosures, containment pipeway and exhaust vent. This will be resolved by the IDVP and the NRC staff.
- 11. Annulus Spectra Revisions - Verify that piping attached to annulus have been analyzed for appropriate response spectra. This matter will be resolved by the IDVD and the NRC staff.
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- 12. Blume Internal Review - Followup - This matter will be resolved by the ITP, IDVP and the_ NRC staff. .
- 13. ' Response Spectra Document Control Manual = (DCM) Adequacy - This rnatter will be resolved by the IDVP and the NRC staff.
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ENCLOSURE 4
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. Er. closure 4 SCOPE OF REEVALUATION OF DESIGN AND DOUBLE DESIGN EARTHQUAKE The original earthquake design basis for Diablo Canyon Units 1 and 2 was based on a set of 4 earthquakes which varied in magnitude and distance from the plant site. These four earthquakes produced varicus acceleration values and frequency content at the plant site. The response spectra of these four earthquakes were compared and enveloped to produce the design response spectra. The hypothetical earthquake (based on the set of 4) that produced tne design response spectra anchored at 0.2g for 2% damping was defined to be the Design Earthquake (DE).
Structures and equipment vital to safe shutdown and required to maintain the integrity of the reactor coolant boundary without loss of function were designed to a design response spectrum anchored at 0.4g which had for all periods twice the DE spectral values, however for 5% damping. The earthquake that produced this design respon'se spectrum was defined as the Double Design Earthquake (DDE).
In 1971 a published report by two geologists (Hoskins and Griffiths) shcwed a fault passing within 3 miles of the plant site. This fault was considered
" capable" and it was postulated to produce a ground motion that was characterized by a Regulatory Guide 1.60 spectrum anchored at 0.75g. This earthquake was defineo as the Hosgri earthquake (HOSGRI).
There are a number of differences between the analyses performed for the DE,
! DDE and H0SGRI earthquake. These differences occur in the areas of ground design spectra and associated acceleration time histories, damping values,
! models, analytical techniques, acceptance criteria, etc. For example, no vertical seismic analyses were performed in the DE and DDE analyses, whereas in the HOSGRI evaluation a vertical analysis was performed for each structure.
Primarily because of the low damping values used in the original DE and DDE analyses the design of some structural members, piping, and equipment at Diablo Canyon was controlled by either the DE or DDE, even though the HOSGRI input design spectra were higher than either the DE or DDE spectra.
The scope of the IDVP initially was limited to review the Hosgri analyses. As a result of the receqtly instituted corrective action program (see Enclosure 7) the IDVP will include a review of the non-Hosgri analyses as part of the Phase II program. The staff finds this to be acceptable.
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ENCLOSURE 5 LOOK BACK REVIEW OF SERVICE CONTRACTORS' QUALITY ASSURANCE PROGRAMS -
INTRODUCTION The PG&E Quality Assurance Department has reviewed the quality assurance '
programs and practices used by PG&E's service contractors during the Phase I and Phase II time periods. The time frames encompassed by Phase I and Phase II are those defined by the NRC Order of November 19, 1981.
The purpose of these reviews was to ascertain if there were shortcomings in the quality' assurance activities relating to these contractors which could
. impact adequacy of the Diablo Canyon Plant design. Areas of investigation covered contractor quality assurance pr0 grams and implementation of same.
Special attention was directed toward interface controls between the' contractor and PG&E. A summary of the findings are as follows:
' PHASE I SERVICE CONTRACTORS
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The contractors reviewed du' ring the Phase I time period were:
- 1. ANC0 Engineers
- 2. CYGNA (EES)
- 3. EDS Nuclear
- 4. Harding-Lawson Associates
- 5. URS/Blume
- 6. WYLE Laboratories
SUMMARY
The review team found that some contractors had implemented a satisfactory quality assurance prcgram and that others had deficiencies in implementation of their programs. In two cases,.no formal quality assurance programs were
, applied to the work.
The following areas of concern were found among those contractors who had deficiencies in implementation of their quality assurance program:
- 1. External Design Interface Control
- 2. Document Control
- 3. Identification and Maintenance of Quality Assurance Records 4 Test Control
- 5. Design Verification
- 6. Instructions, Procedures, and Drawings r 7. Training Note: Ine enclosure is an excerpt of Attacnment 5 to PG&E letter dated September 15, 1982.
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PG&E was found to be deficient in the contracts issued to several of the contractors in the following areas of concern:
- 1. - Disposition of. Quality Assurance Records
- 2. Interface Control
- 3. Control of Purchased Services
- 4. Control of Transmitted Information These areas of concern are the items referred to as deficiencies in the following summaries.
RESULTS Our review indicated that the following-two (2) contractors had satisfac-tory quality assurance programs in place at the time they performed work for PG&E as we identified very few' if any, deficiencies in their documentation:
- 1. EDS Nuclear
- 2. CYGNA (EES)
.The following two (2) contractors were found to have deficienc.*es in the implementation of their quality assurance program:
- 1. ANCO Engineers
- ANCO Engineers had not satisfactory implemented several require-ments in their quality assurance program. Seven deficiencies were identified; however, one was attributed to PG&E.
- 2. WYLE Laboratories WYLE had not satisfactorily implemented several requirements in their quality assurance program. Six deficiencies were identified; however, two were attributed to PG&E.
The following two (2) contractors were found to have no formal quality assurance programs applied to their past work that occurred within the timc period of our Phase I review:
- 1. Harding-Lawson Associates
- 2. URS/Blume
PHASE II SERVICE CONTRACTORS The contractors listed below were reviewed for work performed during the Phase II time period:
- 1. ANC0 Engineers
- 2. CYGNA (EES)
- 3. EDS Nuclear
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- 4. Garretson-Elmendorf-Zinov -
- 5. General Electric
- 6. Grinnell Fire Protection Systems
- 7. Harding-Lawson Associates
- 8. HUS Corporation
- 9. NUTECH
- 10. . Quadrex Corporation (NSC)
- 11. Radiation Research Associates
- 12. Robert L. Cloud Associates
- 13. STAFC0
- 14. Teledyne Engineering Services
- 15. Western Canada Hydraulic. Laboratories
- 16. Westinghouse
- 17. WYLE Laboratories
SUMMARY
The review process F. gain noted a range of program implementation during the Phase 11 portion of the Look Back Review effort. There was a noted improve-ment in the quality assurance contractual requirements since 1973 as compared to the Phase I and there was also improvement in actual overall implementation.
The following areas of concern were found among those contractors who had
~ deficiencies in implementation of their quality assurance program:
- 1. External Design Interface Control
, 2. Document Control l 3. Identification and Maintenance of Quality Assurance Records l' 4.1 Test Control 5.- Design Verification PG&E was found to be deficient in the contracts issued to several of tne j contr. actors in the following three (3) areas:
- 1. Disposition of Quality Assurance Records
- 2. Interface Control l . 3. Control of Purchased Services l These areas of concern are the items referred to as deficiencies in the following summaries.
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-RESULTS Our review indicated that the following seven (7) contractors had satisfac-tory quality assurance prograns in place at the time they performed work for PG&E as we identified very few, if any, deficiencies in their documen-tation:
- 1. CYGNA (EES)
- 2. EDS Nuclear
- 3. NUS Corooration
- 4. NUTECH
- 5. Quadrex Corocration (NSC) .
- 6. Teledyne Engineering Services 1 7. Westinghouse The following four (4) contractors were found to have deficiencies in the implementation of their quality assurance program:
- 1. ANC0 ANCO had not satisfactorily implemented several requirements in their quality assurance program. Seven deficiencies were identified; however, one was attributed to PG&E.
- 2. Radiation Research Associates Radiation Research had not satisfactorily implemented several require-ments in their quality assurance program. Six deficiencies were identified; however, one was attributed to PG&E.
- 3. STAFC0 l
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' i- STAFC0 had not satisfactorily implemented several requirements in their quality assurance program. Six deficiencies were identified; however, one was attributed to PG&E.
- 4. WYLE Laboratories 4
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WYLE had not satisfactorily implemented several requirements in their quality assurance program. Five deficiencies were identified; however, one was attributed to PG&E.
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,1 The following six (6) contractors were found to have no formal quality assurance programs applied to their past work that came under the parameters of our Phase II review:
- 1. Garretson-Elmendorf-Zinov
- 2. General Electri_c_
- 3. Grinnel Fire Protection Systems
- 4. Harding-Lawson Associates
- 5. Robert L. Cloud Associates
- 6. Western Canada Hydraulic Laboratories r
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EflCLOSURE 6 gog\ UNITED STATES
[y > s ; t $ NUCLEAR REGULATORY COMMISSION REGloN V
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CEP 151922 MEMORAftDUM FOR: H. R. Denton, Director, Office of Nuclear Reactor Regulation FROM: R. H. Engelken, Regional Administrator
SUBJECT:
R. F. REEDY AND PG&E REVIEW 0F DIABLO CANYON DESIGN QUALITY ASSURAfiCE On September 10, 1982, R. F. Reedy, Inc. ,(a Diablo Canyon Independent Design Verification, IDVP, contractor) conducted his audit exit meeting with representatives of the licensee. A member of our staff (T. W. Bishop) attended this meeting. Following the Reedy meeting Mr. Bishop met with licensee representatives to review their audits of PG&E in-house design activities and safety-related consultants.
A summary of these audits and related coments are provided below.
j R. F. Reedy IDVP Phase II Desian OA Audit R. F. Peedy, Inc. , conducted design quality assurance audits of PG&E and some of their safety-related design contractor's who were not examined during the Phase I activities. Reedy audited five of the safety-related design organizations, these were: PG&E; EDS Nuclear; Radiation Research Associates (RRA); Quadrex/NSC; and Garretson-Elmendorf-Zinov (GEZ). The design activities audited were those related to the hardware samples discussed in the IDVP Phase II Program Plan. Reedy approached the audits in one of two ways. If the organization had developed and implemented a satisfactory design quality assurance program, then a " routine" design QA audit was performed -(this approach was used for EDS and RRA). If a satisfactory i- design QA program was not evident, then Reedy conducted an audit of design cuality assurance " practices", evaluating the organizations' practices against criteria identified in IDVP procedure No. DC*lPP-IDVP-PP-002, Section 5.7. Due to a lack of adeouately documented design QA programs Reedy chose to audit PG&E, Quadrex, and GEZ using
- this approach. Audits of design practices were subdivided into six categories: design inputs; design processes; design analyses; design outputs; change control; and interface control.
Iiote: Inis memorandum was forwarced to Teledyne Engineering Services by letter from D. G. Eisenhut, dated October 6, 1982.
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H. R. Denton .
During the exit meeting Reedy provided tne following " generic" comnents based'cn his' audits:
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Design Inputs - lack of evidence of dccumentation for design input data Design Processes - processes' were ' generally adequate Design Analyses - lack of' evidence of independent checking of calculation sheets and computer analyses Design Outputs - outputs were generally adecuate Change Control - lack of evidence of control of changes to calculations; drawing change control was found .to be adequate Interface Control - no generic problems were identified with internal interface control; tnere was lack of evidence of external interface c:ntrol EDS Nuclear:
EDS appeared to have established and ~ adequately implemented a design QA program.-
Radiation Research Associates (RRA):
RRA appeared to have established and adequately -implemented a design QA program.
Quadrex/f1SC:
Quadrex/NSC had not established a design QN program for their PG&E work; In general, however, Quadrex was found to have adequate design control practices Garretson-Elmendorf-Zinov (GEZ)-
GEZ had not establ'ished a design OA program for their PG&E work.
GEZ design practices exhibited three " generic" problems.
- lack of evidence of control of design inputs
- lack of evide.nce of independant.: necking of calculations
- lack of identification of cnanges in design calculations
. Reedy stated that he had not yet_ categorized his findings (e.g. as errors or open items), nor fully assessed the implication's of the findings. He anticicated these actions would be comoleted following discussior.with other IDVP members (Teledyne and Stone & Wecster).
Reedy expects to_ issue nis report at the end of October, '.352.
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PG&E Look Back Reviews .
In response to the original (September 1931) concerns regarding design interface control the licensee initiated audits of their in-house design activities and their safety-related consultant contracts (involving 18 contractors). The proposal to conduct these audits was discussed by the licensee in a transcribed meeting with the NRC staff on November 3, 1981. The licenses refers to these audits as "Look Back Reviews" since most of the activities examined involved closed contracts. The stated purpose of the reviews was to " verify all design activities comply'with quality procedures and NRC regulations..." The licensee's QA organization was responsible for completion of the reviews and the Engineering Quality Control organization was resconsible for resolution of the review of findings. The audits were initiated November 30, 1981 and were completed April 2, 1982. In June 1982 the licensee decided that an additional contractor (Garretson-Elmendorf-Zinov) should be audited since werk performed by the contractor (HVAC) involved a safety i function (the contract had been designated non-safety). This final audit was ccmpleted July 23, 1982.
All items which were found to be of " questionable status" were documented on "Look Back Deficiency Notices" (LSDN.). 159 LSON's were issued as a result of the reviews. 82 of the LSDN's pertained to licensee consultants, while 77 related to in-house design ac-ivities.
In addition, a few Ncnconformance, Deficiency, and Open Item Reports were issued to document the review findings. Many of the review items are similar to the R. F. Reedy findings. The look Back Review items include:
In-House design - loads added to battery systems without effects ,
analysis; design calculations / verifications not completed; uncontrolled enanges to design; unapproved specification changes; inconsistencies with the FSAR; design change notice reviews not controlled by procedure; FSAR not maintained i
as a controlled document; instrument set points not controlled.
Contractor design - quality assurance program not soecified as a requirement; quality assurance program not applied; drawing inconsistent with FSAR data; reccmmended " design assumotion" tests not performed; calcula-ions not controlled The above examples are not representative of all the Look Sack Review findings but do illustrate the similarity between the "ceneric" Reedy l
findings. and the licensee's audit findings. This becomes significant since some of the licensee findings were identified in areas wnicn were not specifically reviewed by Reedy (e.g. comoonent coolin: nater system, 125V DC system).
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Recion V Coc=ents ,
In consideration of the above, we offer the following comments and questions.
- 1. Did R. F. Reedy Inc. , comoly with the requirements of the NRR letter of November 19, 1981 regarding scope and approach?
t The November 19, 1981 letter required quality assurance reviews of all service related contractors. R. F. Reedy, Inc., narrowed the scope of the reviews to contractors with significant safety-related design responsibilities, auditing enly a portion of the safety-related service contractors. Service-related centractors such as Stafco, Inc. (responsible for quality "Q-list" and FSAR updating) and Western Canada Labs, Inc. (tank vortexing study) ,
were not examined 'by R. F. Reedy. It apoears that the cmission of certain service-related contractors is inconsistent with the NRR letter.
During the conduct of the audits, once the lack of an effective QA program or implementation was identified, R. F. Reedy chose to initiate a review of " design practices". Further assessments of programmatic (procedural) controls were discontinued. The -
NRR letter requires a review to determine whether quality assurance procedures and controls were fully and effectively implemented.
Witnout thoroughly examining the extent and implementation of
. the programmatic controls, an assessment of generic findings is inhibited (especially in the area of design control consistency).
An evaluation of the need to complete the programmatic reviews may be appropriate.
- 2. How should the PG&E Look Back Review findings be used?
The IDVP Phase II Plan states that the crimary IDVP purpose of
, the R. F. Reedy, Inc. , audits is to cbtain information which impacts the extent of design process verification. The plan further states tnat negative audit results reveal the potential for a lcw level of design control consistency and indicate the possible need for additional verification. We concur with IDVPs proposed use of the Reedy findings. Consistent with this, the PGAE took Back Review findings _ provide further data which may be useful in assessing the neec for additional verification. This is particularly valid since the sample of tne Look Back Reviews 4
was different from that of R. F. Reedy, Inc. , in some cases.
Accordingly, it is recommended that the detailed results of the Look Back Revew be provided to the IDVP for their use ir. future decisions en additional verifications.
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- 3. Should the scope of the IDVP Phase II Program Plan be reexamined in light of the R. F. Reedy and PG&E findings?
The IDVP Phase II Plan currently provides for expansion of the verification program if warraated.by design cuality assurance audit findings. Although the R. F. Reedy findings are preliminary and may not accurately represent the final evaluation, their ccmbination with the licensee audit findings suggests the possibility of broad programmatic deficiencies in the licensee's design program and certain of their contractors. Based on this condition, it may oe appropriate to reexamine the scope of the initial verification sample defined in the Phase II Program Plan.
It is ' suggested that the above comments be provided to -the IDVP for their timely use in completing the verification program. We would be pleased to discuss the above comments with you further (contact T. W. Bisnop FTS 463-3751).
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R. H. Engelken Regional Administrator cc: R. DeYoung D. Eisenhut R. Vollmer E. Case L. Chandler ,
J. Knight T. Novak F. Miraglia H.-Schierling J. Kerrigan t
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4 ENCLOSURE 7 4
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Enclosure 7
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PG&E CORRECTIVE ACTION PROGRAW PG&E is co' n ducting a separate , internal technical pr'ogram (ITP) in accordance l
with its responsibility as thelicensee for the Diablo Canyon Power Plant to ensure that it is designed and constructed in accordance with the licensing criteria. The ITP plan as described by PG&E in a March 25, 1982 meeting was approved (NRR letter to PG&E, dated April 27,1982) and i'cs activities are reported in the PG&E semimonthly reports. Ir. a meeting on August 6, 1982, FG&E advised the staff that, as a result :f findings by the IDVP and the ITP, a -
corrective action program (CAP) had oeen initiated as part of the ITP. Within the program, a complete review of certain major areas of the plant seismic design is being perfonned including (1) all major safety-related structures (contain-ment building, auxiliary / fuel handling building, turbine building and intake structure); (2) verification of all large-bore safety-related ~ piping, including complete walkdown of piping systems; (3) review of small-bore piping systems and complete reanalyses where found necessary. .
The CAP will also include the resolution of open items in these specific areas as identified by the IDVP and ITP, including appropriate analyses and plant modifications. PG&E will issue a final report for the Phase I design verification program that will include the scope, criteria, methodology, findings, and con-
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clusions for the corrective action program.
The IDVP will review and evaluate the findings of the CAP with respect to the need for additional verification or additional sampling.
' Separate from the IDVP, which is performed by organizations independent.of PG&E under the management of Teledyne Engineering Services.
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ENCLOSURE 8
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, o Enclosure S MODIFICATIONS RESULTING FROM IDVP AND ITP (Per PG&E Subnittal date September 15,1982)
System / Component Modification (s)
A. Pipe Supports (257 total)
Structural modifications 121 (large and small bore)
Base plate / anchor bolts 18 (large bore)
Additions (large and small bore) 27 Spring or seismic limiter settings 3 Gap adjustment (large and small bore) 46 Rod supports'(small bore) 42 B. Other Supports (43 total)
Valves 1 Containment fan' cooler 1 Instrument testing 2
-(non-safety-related) .
Annunciator cabinet 1 Raceways (various types) -
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- C. Annulus Structure (38 total) l Wide flange corrections 27 Members 11 D. Other (6 total) 125-V dc breakers 6 E. Anticipated Additional Modifications HVAC ducts and supports 8-1
System / Component Modification (s)
Equipment in various locations Piping rerouting in containment and auxiliary buildings Pipe supports in various buildings Polar crane and dome service crane Electrical power supply to control room HVAC Raceway supports !
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e ENCLOSURE 9 b.
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e Enclosure 9 PG&E PROPOSAL FOR STAGED LICENSING At a meeting on August 6,1982, Pacific Gas and Electric Company (PG&E) provided the staff with a proposed schedule for the completion of Phase I of the Indepe-ndent Design Verification Program (IDVP), including a proposed date for initial fuel loading of November 30, 1982. PG&E has provided a listing of all systems, components, and structures required to support initial fuel loading including the~ rationale for the listing. PG&E provided information in submittals dated August 24, 1982 and September 8, 1982. PG&E made the following assumptions for activities up to and including fuel loading:
- 1. No decay heat and no fission product inventory will be generated.
- 2. The steam generators will remain in dry layup throughout the period.
- 3. Other systems and components not included in the listing will be available and may be used if necessary or desirable.
- 4. All instrumentation associated with the required systems will be available.
- 5. Building and structures that contain' or support the required systems and equipment will be available.
PG&E provided lists of ecuipment " required" for fuel loading and equipment which would provide operational " support." The equipment in the " required" ,
list will be seismically requalified, whereas the equipment in the " support" l
list will be' verified operationally but would not necessarily be requalified by their proposed fuel loading date.
The systems identified by PG&E as required for fuel loading and for which seismic requalification modifications will be complete were selected based on FSAR Chapter 15 analyses for core and system conditions which would exist during initial loading (e.g., no decay heat or fission product inventory). Only in-advertent baron dilution was determined to require protection equipment. In-advertent control rod withdrawal cannot occur since the trip breakers will be deenergized.
The staff has reviewed _the PG&E proposal and concurs _with the identification of systems by PG&E. The staff reviewed the list of equipment required to protect against boron dilution events (FSAR page 15.2-20) and concludes that this equipment is included in the list. The staff notes that fire protection and control rocm habitability equipment is also included. The staff also reviewed tne current Diablo Canyon Technical Specifications for equipment required for loading of ,
unirradiated fuel. The staff notes that the following supportive equipment is required by the current Technical Specifications which is not listed in either PG&E's list of " required" equipment, or the list of " supportive" equipment:
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- 1. containment ventilation isolation equipment, -
- 2. equipment for communication between the control room and the refueling station, and
- 3. containment ventilation system.
The staff believes that this equipment should also be verified as operable before fuel loading. This equipment need not be seismically requalified prior to fuel loading since the occurrence of a large earthquake simultaneously with the fuel-ing operations would be unlikely. Moreover, no fission product release could occur during initial fuel loading unless a reactivity transient resulting in '
fuel damage also occurred. .This would also be unlikely since PG&E will have available seismically requalified equipment to protect against reactivity excursions.
' With the above additions to the supportive equipment list, the staff finds that the li3ts of equipment identified by PG&E as " required" and " supportive" for
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fuel loading are acceptable. We will assure that in accordance with the Commission's Order of November 19, 1981, a adequate basis for not completing other modifications prior'to fuel load has been provided.
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ENCLOSURE 10
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Enclosure 10 STAFF' EVALUATION OF PHASE II CONTRACTORS Technical Oualifications of Contractors '
The principal subcontractors to Teledyne Enginbering Services (TES) for the Phase II program are Robert L. Cloud Associates (RLCA), R. F. Reedy, Inc. (RFR),
and Stone & Webster Engineering Company (SWEC).
Phase II seismic structural and mechanical review is designated largely for RLCA. This is the same role that they played in Phase I, and the staff sees no reason i.o question the. continued participation of RLCA in this capacity. The.
quality assurance aspects are assigned to RFR. Since the same assignment was given to RFR during Phase I, the staff also sees no reason to change their con-tinued participation in Phase II. In summary, the technical qualifications of RLCA and RFR were we'll established prior to Phase I and have. been amply verified by their activities to date.
The SWEC scope includes the selection of representative samples of safety-related system designs and analysis performed by Pacific Gas and Electric Company (PG&E) and service contractors, the development of the design chain for the sample activities, a review of the selected sample systems, any performance of repre-sentative calculations for the purpose of design process verification. The verification program. includes review of the safety-related system design require-ments, including the electrical and control design requirements, equipment envi-ronmental qualification, and design analyses.
The staff has reviewed numerous facilities designed by SWEC and audited their design process both at the quality assurance and technical levels. SWEC had full responsibility for the concept, design, and installation of systems similar to those available for sampling at Diablo Canyon. Based'en this experience, the staff concluded that SWEC is fully qualified to perform the functions assigned in the Phase ".I Independent Design Verification Program
! (IDVP) for Diablo Canyon.
In addition Teledyne has identified (Semi-Monthly Report, dated August 27, 1982) l the following consultants that will provide assistance to the IDVP in specialized l area.:
Hansen, Holley and Biggs (civil / structural) i General Dynamics (radiation)
Alexander Tusko Inc. (electric power)
Foster Miller Associates (instrumentation and control)
J. W. Wheaton (electric power team leader)
Abendruh Inc. (soils).
Indeoendence of Contractors During Phase I, the staff concluded that TES, RLCA, SWEC and RFR were independent from PG&E. Mr.'Howard Friend, the Diablo Canyon Project Manager has informed the NRC staff that all of Bechtel's stock is held by the Bechtel family or officers 10-1
of the company and is not available to these or other subcontractors. In addition,
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he does not believe that Bechtel does any business with any of the subcontractors listed above with the exception of TES. He estimates that Bechtel's business accounts for aoout 2% of TE5's annual revenues.
The staff has requested written verification from both TES and Bechtel regarding any business dealings between PG&E and Bechtel and the Phase II subcontractors.
Based on the above, however, it appears that no financial conflicts of interest exist among the IDVP subcontractors, PG&E and Bechtel.
Verification of Independence for Technical Reviewers TES has developed during Phase I_of the IDVP a procedure to assure the finan-cial and professional independence of individuals assigned to the IDVP. The
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staff reviewed the procedure and approved it by letter dated September 8, 1982.
The procedure applies to TES and subcontractor employees and includes a con-fidential conflict of interest statement.
Region V has initiated a program to routinely verify the independence of IDVP technical reviewers. The purpose of this program is to assure that the indi-viduals performing the IDVP will provide an objective, dispassionate technical judgment, based solely on technical merit. The following factors were considered in evaluating the question of independence:
(1) Whether the individuals' involved had been previously hired by PG&E or BPC to do similar design work. .
(2) Whether any individual involved had been previously employed by PG&E or BPC (and the nature of the employment).
(3) Whether the individual owns or controls significant amounts of PG&E or 8PC stock.
(4) Whether members of the present household of individuals involved are employed by.PG&E or BPC.
(5) Whether any relatives are employed by PG&E or BPC in a managment capacity.
The organizations involved in the IDVP (TES, SWEC, RLCA, RFR) developed " conflict of interest statements" for their applicable employees to sign. The statements were used to screen the proposed participants for any potential or apparent l conflicts of interest-with respect to.the IDVP. Originally, the conflict of interest statements referred only to PG&E; however, BPC has recently been added to the statement. In addition to signing the original statements, the partici-
- pants will be required to sign the revised statements reflecting the current Bechtel involvement in Diablo Canyon.
To verify'that the individual participants meet the established independence criteria, the staff has reviewed conflict of interest statements, reviewed resumes and confidentially interviewed participants. The following is a summary of that effort:
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- (1) Conflict of Interest Statement--The Region V staff reviewed conflict of interest statements of all of the key TES' participants (44 statements). These 44 state-ments included statements of six individuals employed by consultants to TES.
The organizations that these individuals represent are J. W. Wheaton Tecnlology; Hasen, Holley, Biggs, Inc.; Alexander Kusko, Inc.; and Foster-Miller Associates.
The-conflict of interest statements signed by these individuals indicated that none of the individuals have any significant past or present involvement with PG&E or Diablo Canyon. The conflict of interest statements did not include BPC. Recently, Bechtel has been added to the statements. The revised statements will be signed by the individuals involved.
Region V has completed independence reviews of R. F. Reedy Inc. and R. L. Cloud Associates. The reviews has established that two senior managers from R. F. Reedy Inc., were previously. employed by Bechtel Power Company. During the Teledyne/
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PG&E/NRC meeting of October 7,1982, it was determined that Teledyne intends to have R. F. Reedy, Inc., examine the PG&E/Bechtel design quality assurance applied to the corrective action program. Region V has identified to senior PG&E manage-ment the possible " conflict of interests" in this matter. PG&E management has stated that they will tah appropriate action to assure that there will be no
'" apparent" conflict of interests in the quality review of corrective actions.
In addition to the conflict of interest statements of the TES individuals, the staff has reviewed the conflict of interest statements of the SWEC participants in the IDVP. Sixty-six conflict of interest statements were reviewed and included all of the SWEC participants with the exception of two individuals whose state-ments were not available at the time of the review. The conflict of interest statements signed by these individuals indicated that none of the individuals
. have any significant past or present involvement with PG&E or Diablo Canyon.
Similiar to the TES conflict of interest statements, the SWEC statements did not include Bechtel; the statements will be revised to include Bechtel and will be re-signed by the SWEC participants.
(2) Resumes--The professional resumes of key TES and SWEC participants have been reviewed by the staff to give additional information regarding the question of independence. .This effort included 34 resumes of TES personnel (including consultants) and 36 resumes of SWEC personnel. The resumes indicated no employ-ment history with either PG&E or Bechtel.
In addition, the resumes were used to evaluate the professional experience and competence of the participants. The staff concluded that the TES and SWEC individuals involved in the IDVP are competent and experienced in the matters under review.
(3) _C_onfidential Interviews--To further evaluate the ouestion of independence, the staff selected key participants in the IDVP and conducted condftdential inter-views with them. This effort included interviews with thirteen TES personnel, nine SWEC personnel, and approximately 50% of the RLCA participants from their West Coast office. In addition to the question of independence, the line of questioning by the staff included the possiblity of pressure being applied to suppress findings. Based on these interviews, the staff concluded that there is no conflict of interest between the participants in the IDVP and t)G&E and Bechtel, and the participants feel no pressure to suppress possible findings.
Interviews with TES West Coast employees, RFR employees, and RLCA East Coast employees are currently in progress i
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ENCLOSURE 11 f
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'[. . Enclosure 11 STAFr' EVALUATION OF IOVP PLAN - PHASE II
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I. TES Program Plan '
The-Teledyne Engineering Services IDVP-Phase II plan, dated June 18, 1982, is intended to respond to the. requirements of the Commission Order and the November 19, 1981 letter from H. Denton to Mr. M. H. Furbush.
The program pl'an includes the following'f,eatures: '
- 1. . Selection of r'epresentative samples of safety. related systems, designs and analyses performed by"PG&E and service contractors.
- 2. Development of the design chains for all non-seismic safety-related actitivies performed by service contractors prior to June 1978, for safety related activities for samples performed by service contractors after January 1978 and for PG&E internal design activities
.for selected samples.
- 3. ' QA audits and reviews of the organizations identified through the design chain utilizing essentially the same methods and criteria applied in Phase I.
- 4. Review of design control practices where deficiencies at either the program level or implementation level are discerned during the QA audits.
- 5. Review of design ~ requirements for the sampled systems and components
-including electrical and control design requirements, equipment envi-ronmental qualification and design analyses.
- 6. Verification of the design process for each selected sampled to include as a minimum:
correct selection and incorporation of design input into the l design, reasonableness of assumptions used in the design, identification of applicable codes, standards, and regulatory requirements to be used as a basis of design as committed to in the approved DCNPP-1 licensing documents, correctness of design interface information used in the design, adequacy of design or calculation method used, reasonableness of the outputs compared to the inputs, adequacy of equipment for the required application,
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review of completed pre-operational tests when acolicable to l- evaluate system and component operating performance,
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review of the sample system design requirements for compatibility with the Technical Specifications, review of redundancy to determine if the system design satisfies the single failure criteria as defined in the DCNPP-1 licensing documents, review of the fire protection provided;for the selected sample systems for conformance with th,e plant's licensing commitments, and verification that the system as designed and analyzed is equivalent to the licensed design and that adequate separation (distance, barriers, or restraints) exists to accommodate poten-tial piping failure results (pipe whip, fluid jet, flood'ng, environment) and/or internally generated missiles such that the system can accomplish its designed safety related function during exposure to such pipe break / cracks or missiles.
The Governor of"the State of California and Joint Intervenors provided comments to the staff on the Phase II plan, which were discussed at a meeting on September 9,1982 and which are summarized in Attachment 8 to the September 24, 1982 memorandum from the Executiva Director for Operation's to the Commission.
II. Staff Findinos and Resolution of Comments' Based on the staff's review of the Phase II program plan proposed by TES and review of the ccT.ments provided by the intervening parties it is concluded that:
- 1. The proposed Phase II program as modified by the September 17, 1982 letters and the additional requirements noted in this attachment should provide adequate identification and evaluation of significant design errors in the selected sample and an adequate understanding of the root cause.
- 2. The sample selected and the provisions 'for additional sampling should provide adequate assurance that the full significance of any design errors disclosed in Phase II will be developed.
- 3. The Phase II program plan should be expanded con:;istent with the aoreement of the IDVP and PG&E to include construction QA activities.
- 4. The Phase II program plans should be expanded to explicitly include the TES and PG&E commitment to provide for IDVP review of the PG&E corrective action plan.
- 5. The distinction between work' performed under Phase I and Phase II as a basis for restoration of the low power license is no longer appropriate.
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- 6. Rigorous statistical techniques are largely inappropriate for a design verification program.
A description of the IDVP plan for Phase II, including the results of the staff review, are presented in Sections III through V of this enclosure.
III. Initial Samole' Selection The Auxiliary Feedwater (AFW) system, and the Control Room Ventilation and Pressurization (CRVP) system and the, safety-related portion of the 4160 V Electric Distribution System are selected in the Phase II Program Plan as the initial systems for which independent verification will be performed.
The AFW system includec the condensate storage tank and/or the seismic Category I water supply, valving and cross-connects, connections with the steam generators which include the safety Class 2 (safety-related) portions of the main feedwater system and the safety-related steam supply system'to the turbine driven pump. The AFW system also includes all equipment and interconnections with other systems whose failure could affect the safety functions of the AFW system. As a basis for selecting the AFW system TES noted that the design process involved interfaces with NSSS vendor criterit (Westinghouse) with containment design criteria, and with PG&E internal design organizations. TES also noted that the AFW system design represents a typical example of the methodology of determining a water system's mechanical, electrical and control component design requirement. The staff concurs with these bases fo'r selection.
The CRVP system includes' all mechanical components which constitute the safety-related portion.of the sytsem as well as all equipment and cross-connects whose' fail.ure could affect the safety functions of the CRVP system.. As bases for selection of the CRVP system TES noted that deign of the CRVP system also represents an interrelationship of several design criteria and interfaces. Specifically, it involves interface with several service contractors, interface of PG&E internal design organiza-tions, and interface with the control room habitability criteria.
Experience gained by the staff in the review of IDVP's recently conducted for a number of plants has shown that significant differences frequently exist between the methods and approach to design employed for air systems as compared to water systems. The staff therefore concludes that the selection of the CRVP represents a significant adoition to the initial sample for Phase II.
Integrated radiation dose analyses as well as the temperature, pressure and humidity analyses which were employed to develop equipment specifica-tion will be revi.ewed at two representatives locations outside contain-ment. One location will be associated with the- Auxiliary Feedwater Sy'sta'm, while the oth'er will be associated with the Control Room Ventilation and Pressurization System. These analyses cerformed by several service-related contractors were different and tneir work involved a. flow of design information through PG1E engineering groups.
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The electrical design of safety-related equipment incluoed.in the AFV and CRVP systems as well as the safety related insErumentation and Controls (I&C). portions of these systems will be also re, viewed under the proposed Phase II program plan. The electrical review will include the loads, feeders, raceways, and protective devices which are part of these systems.
The I&C design review will include monitoring and alarming criteria and design implementation, system control device criteria and design imple-mentation, review of design documents and installation drawings for
- compliance with regulatory and vendor equipment requirements, review o'f equipment environmental qualifications and review of process functions.
, The safety related portion of the 4160 V Electrical Distribution System (4160 V system) includes class IE buses, the stand-by start-up and unit auxiliary transformer supply connections to these buses, the diesel generators _ connected to the buses, and the cable feeders and bus duct connecting this equipment. As a bases for selectior TES notes that the
-safety related portion of the 4160 V system .is the basic power supply fon
. safety-related electrical equipment. It also represents an interrelation-ship of several design criteria and involves the interface of several PG&E internal design organizations. The staff concurs in the selection of the 4160 V system and we conclude that this relection in conjunction with'the electrical and I&C reviews discussed above previde an adequate initial sample of the design process for electricil and instrumentation and control systems.
IV. Pioing and Eouipment The Phase li!DVP methodology for the verification of piping will consist of the foiiuwing step's:
field verification of sample lines in the AFW system, development of models from RLCA field verified drawings, analysis by methods that wiil in general parallel those used for the design analysis of the piping, and independent verification of postulated AFW pipe break locations.
Based on the experience gained in Phase I of the IDVP a modified criterion will be employed for evaluation of the independent analyses for piping.
In-both the verification and design analysis all points in the line that are stressed to 70% of allowable s'.ress or more will be selected as reference locations. If fewer than > such coints are found; the 5 most highly stressed points will be selected as reference locations. If, for either the design or verification analyses, the stresses at the reference locations differ by more than 25% or exceed allowable stress additional ve'rif'ication will be ' required.
Selected pipe and pi'pe rutpure supports will be chosen for a field verifi-cation of. consistency with design configuration and f0r comDarison of the loads calculated from the independent analyses with those calculated in original design analyses. Loads differing by 25% or loacs ever allowaole 9 9 , 9
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values will require issuance of an Open Item Report and additional verifi-cation to resolve the Open Item.
~
Based on our review of the Phase I results to date the staff concurs that the use of a 25% criterion is appropriate. In our acceptance of a 15%
criterion for the Phase I portion of the IDVP for Diablo Canyon we noted that deviations of up to fifteen percent are considered normal and have been implicitly accounted for by the design factors approved for usage in design criteria for nuclear plants. The same is largely true of twenty-five percent deviation when taken in the. context of reasonable variations in modeling and allowable tolerances in location of supports and restraints.
The fifteen percent criterion used during Phase I frequently led to the designation of open items whose root cause was differences in dimensions use'd in the piping models that were within allowable tolerances. The staff concludes therefore that the purpose of the IDVP for Diablo Canyon is best served by use of the more significant 25% criterion.
The original design of pipe supports required each support to have a minimum natural frequency of 20 Hz considering the stiffness of the support and the mass of the supported pipe. Selected supports will be verified and the first mode frequency of the pipe supports will be verified to be equal to or greater than 20 Hz. During review of the Phase II pro-gram plan the staff requested clarification of this criterion with respect to any allowed error band. In response to the staff request, representa-tives of RLCA indicated that any calculated frequency below 20 Hz would be considered an open item. The staff finds this criterion acceptable.
For equipment such as cooling coils, condensate storage tank, pumps, valves / dampers, electrical panels and cabinets, fans and filters, design drawings will be field. verified and . stress analysis methods used for verification of the equipment qualification. Verification analyses will consider stresses in the equipment itself as well as equipment supports and support structure including the anchorage. The loading combinations and structural criteria' for both the mechanical equipment and supports will be compred to those given in the License Application and differences reported. The staff finds this approach and the related criteria acceptable.
V. Additional Verification and Additional Samoling The Phase II program plan contains explicit provision for additional veri-fication or additional sampling to be performed when engineering evaluation determines its necessity based upon the nature (generic / specific) of an identified deficiency. Generic deficiencies, wnich could be propagated throughout the engineering work reviewed will require additional verifica-tion to resolve the generic concern. The plan recognizes that generic deficiencies may be a function of engineering methods, engineering personnel or contractors and that deficiencies may result not only from th'e e'ngineering' design verification, but also from the Quality Assurarfce (QA) verification. The plan also provides that QA and Design Control Practices deficiencies that are generic may trigger additional engineering verification. The staff concludes that.the additional samoling provisions of the Phase II program plan adequately provides for treatment of possible generic findings and is therefore acct:ptable.
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'83 Ci 12 P7:12 Docket No. 50-329 .
- Docket NoP50-330 ! \\ p. - ,
Consumers Power Company I
ATTN: Mr. James W. Cook '
Vice President Midland Project
-1945 West Parnall Road Jackson, MI 49201 Gentlemen:
f We have reviewed your proposal to have the Stone and Webster Corporation
.( (S&W) perform the third party independent overview of the Construction Completion Program (CCP). Our evaluation is enclosed.
The staff has considered the qualifications of both the S&W organization
- and the individuals proposed as team members to conduct the Construction Implementation Overview (CIO) of Consumers Powel Company's (CPCo) Construction Completica Program. Inputs to this review included the information supplied by S&W,'as set forth in the April 6, 1983, April 11, 1983, and May 19, 1983 submittals, the staff's existing knowledge of S&W performance at other nuclear' power plants, and information as to S&W personnel competence.
The CIO program described by S&W in the August 30, 1983, and September 9, 1983, submittals and at the August 25, 1983, meeting has been reviewed by the NRC staff and found to constitute an acceptable third party overview program.
The NRC staff has reviewed the CIO activities performed to date and has found this overview to have been adequate. _
(. Based on NRC review of the documentation submitted by CPCo and S&W, followup checks, and consideration of comments by members of the public, we conclude that S&W meets the independence and competence criteri.a for third party reviewers and that S&W's proposed CIO program is adequate to provide for an assessment of the Construction Completi6n Program (CCP). -
This letter constitutes NRC approval of S&W to perform the CIO.
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Consumers Power Company 2 SEP 2 9 G83 i
Should you have any questions regarding this letter please contact Mr. R. F. Warnick of my staff.
Sincerely, Cri;*ns.1 0' 5~ 3 h'l y . . z, - :
James G. Keppler Regional Administ'rator
Enclosure:
As stated cc w/ encl:
(\ .DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralpb S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan .
Public Service Commission Myron M. Cherry Barbara Stamiris ,
Mary Sinclair Wendell Marshall Colenel Steve J. Gadler-(P.E.)
Howard Levin (TERA)
Billie P. Garde, Government - -
( Accountability Project
-Lynne Bernabei, Government Accountability Project S
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STAFF INALUATION OF CONSUMERS POWER COMPANY PROPOSAL TO USE STONE AND WEBSTER MICHIGAN, INC.
- TO CONDUCT THE THIRD PARTY CONSTRUCTION. IMPLEMENTATION OVERVIEW OF THE MIDLAND NUCLEAR PLANT Purpose and' Background The ' purpose of this document is to provide an evaluation of the Consumers Power Company's (CPCo) proposal to use Stone and Webster (S&W), Michigan, Inc.
to conduct the third party overview of the Construction Completion Program at
' Midland.
in responseConsumers' to.the NRC'sproposal March is documented in their letter of April 6, 1983, 28, 1983, request for additional information.
The CPCo commitment to provide for an independent third party Construction Implementation Overview (CIO) has been reviewed and found acceptable. This
- evaluation provides the basis of the NRC's acceptance of Consumers proposal.
( The purpose of the CIO is to provide an independent overview of the Construction Completion implemented. Program (CCP) to assure the program is adequate and will be properly This is to ensure that the construction of the facility can be completed in conformance with the Commission's regulations and the construction permits.
The S&W overview of the CCP will be independent from and supplemental to the normal NRC inspection program.
^
' inspectors will monitor and review the S&W CIO.As part of their inspection program, the NRC The use of S&W as the third party overviewer will provide additional assurance of proper implementation of the quality program. In addition, it will function as a mechanism to allow members of'the public and the NRC to regain confidence in the program.
- _The results of the overview program will be submitted to the Regional k Administrator in a weekly report of CCP activities overviewed and any problems identified.
, The NRC has required communications between CPCo and S&W to follow a protocol to assure S&W's independence is being maintained and to assure public and
' NRC' knowledge of S&W activities and correspondence. It should be noted that the protocol provides for a monthly meeting, open to the public for observation, to review identified by the overview. S&W activities for the month and to discuss problems CPCo's Proposed Third Party Reviewer
{PCo has proposed that Stone and Webster perfoon an independent overview of I
the Midland project CCP. The NRC staff has considered CPCo's submittal of April 6, 1983, and responses to Region III questions, public comments, and the clarification of submitted comments and additional comments received at N-y g w< ~,p e- yy,w w-e~--e,. - - - - . s.wa. ---r-.m.- -
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. . o public meetings held in Midland, Michigan on February 8, 1983, and August II, 1983. In addition, the staff conducted numerous,meegings and telephone conversa-tions with. representatives of the Government Accountability Project (GAP) and the intervenors. In considering CPCo's proposal, the staff has used as guidance the letter of February 1,1982, from Chairman Palladino to Congressmen Ottinger and Dingell, (attached) which sets forth the " competence and independence" standards that have been applied by the Commission in determining the accept-ability of proposed third-party reviewers.
S&W Competence The staff has considered the qualifications of both the S&W organization and the individuals proposed as team members to' conduct the independent overview of the Midland project. Input to the staff's review included the information supplied in CPCo's submittal, the responses to the staff's inquiries, the S&W submittals,'and the staff's existing knowledge of S&W performance at other nuclear power plants.
f The staff has reviewed S&W's experience in assessing nuclear construction
( projects, particularly its performance in independent reviews of design, construction, and quality assurance undertaken for utilities as input to the NRC's operating license reviews.1 The staff has also reviewed the qualifications of the key persons proposed for the project,. as set forth in the April 6,1983, April 11,1983, and May 19, 1983, submittals, and has concluded that the team has significant stated experience in QA/QC matters, nuclear plant construction, and management systems. These are the skills which we find necessary to carry out the third party overview.
Through_ reference checks and/or discussions with NRC staff members familiar with the key personnel, we have verified their experience and competence in these areas.
4
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Based upon its review, the staff co'ncludes that the S&W organization and the individual overview team members are competent to conduct the Construction Implementation Overview and meet the technical competence standards set forth
- g. In 'the Ottinger/Dingell letter.
\.
S&W Independence The staff believes that for an organization to be acceptable to conduct this b' program the organization must be independent of the utility which owns Midland L and. independent of contractors whose work will be subject to the third party
! ove rview. Independence has been defined by the Commission as being the ability ". . . to provide an objective, dispassionate technical judgement, provided solely on the basis of technical merit...." (Page 1 of Response to Questions,- attached to Ottinger/Dingell letter.) The Commission further j defined the term by stating that the company approved to conduct an independent review must be one "...not previously involved with the activities...that they will now be reviewing..." Id.
3 Reference Secy 82-414, "Diablo Canyon Design Verification Program Phase II l , Recommendations"
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.The'htaffhasreviewedtheinformationprovidedbyCPboandS&Wregarding
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L previous work performed by :S&W for the Midland site and the principal r(contractors :for the Midland project. Previous work at Midland consisted of limited' activities (one person) in the planning phase of providing interface i
controls going fr.om construction /preoperation testing into operations and is 5not considered to violate the independence criteria.
.To the best of our knowledge, all the professional personnel assigned to work on the-Midland Construction Implementation Overview have provided the NRC with sworn statements regarding their independence. S&W has stated that none of the staff. expected to be assigned to the Midland review has any prior work Lexperience,with CPCo or on Midland.
' 11 Based on $his information and the assessment of S&W to perform work as defined in'Secy 82-414,,the staff has no basis to believe that S&W is not
-sufficiently independent'of.CPCo.
The sta'ff concludes that.S&W and the key personnel who have been identified for g the conduct of the r_eview, meet the standards of independence outlined in the LA - Ottinger/Dingell letter.
fs - S&W's ' Oveiview Program The. purpose'of thes independent third party overview is to provide additional 4s-~ursnce s that the CCP is adequate and will be properly implemented. This joverview requirement was necessitated by the loss of NRC staff confidence in CPCo.tc implement'successfully the Quality Assurance Program. The CIO,will recain in place at.the Midland site until the'necessary confidence level has
> - -been' restored to -the satisfaction of the NRC staff. CPCo also has the option 4
.g .to : continue the CIO as- an ! additional system of checks and balances, beyond any period-of time. required by the' staff.
. lThe writ' ten CIO program is controlled by site originated program documents and by[S&W corporate program documents as follows:
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A. 1The documents writtencexpressly for the CIO include:
. CIO' Prograra Document dated April 1,1983 7
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CIO' Quality Assurance Plan
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- . "Ihich Party CIO-Plan
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'*- 't ,) . . CIO Assessment Procedure, 10.01 t
.. 'Nonconformance Identification and Reporting Procedure, 15.01
.e v ii~ . A-detailed attribute checklist for each CPCo Project Quality Control
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't . :o 6 j 8, l A detailed checklist to review generic types of requirements (for non-PQCI activities); e.g., QA Audits and Surveillances Additional Quality Control Instructions as needed to provide adequate overview control
, B. The following S&W corporate master program dccuments will also be utilized for the CIO, as required:
QA Topical Report SWSQAP I-74A, S&W Standard Nucleor Quality Assurance Program
. S&W Quality. Standards; e.g., for quality sampling
. S&W Quality Assurance Directives The NRC met with S&W on August 25, 1983, to gain additional insight into the total-S&W program. This meeting was held in Midland, Michigan and was open to the public. Questioning by.the public on the CIO was permitted at the end of
(
7-the meeting. Subsequent to this meeting, S&W submitted on August 30, 1983,
'to the NRC copies of the material presented at the August 25, 1983, public meeting and on September 9, 1983, submitted a summary of the program presented at that same meeting.
The program described by S&W in the above documents and at the August 25, 1987, meeting has been-reviewed by the NRC staff and found to constitute an accept-
.able third party overview program. The_CIO program will be audited indepen-dently by th'e S&W corporate QA staff from Boston and on a routine inspection effort by the NRC.
S&W personnel onsite for the CIO will vary with the demand of the work Eactivities to be overviewed. S&W's CIO staffing plan currently has nine people
- assigned at the Midland site and there are currently planned increases to 32 .
people as-work activities dictate. These numbers, however, are only estimates i
' and.S&W will commit whatever personnel is necessary to conduct the CIO. The number of personnel used is not subject to limitation by CPC0.
'The S&W overview activities of the CCP to date have been somewhat limited, since the-CCP has not yet been approved and work in progress is therefore limited. Activities being overviewed were pre-Phase I. The activities being
.overviewed have included the following CCP and non-CCP activities:
. Program and procedure review
. Review of MPQAD QA/QC personnel training and certification Review o.f general training of CPCo and Bechtel personnel, including construction craftspersons
. Review of CCP Management Reviews i b 4
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. Review of System Interaction Walkdowns -
. Review of Design Documents
'The above reviews have identified various concerns and one nonconformance that required CPCo actions to resolve. The NRC staff has reviewed the CIO activi-ties performed to date and has found this overview, including actions taken by CPCo, to'have been adequate.
.,.. . Summary and Conclusion Based on NRC. review of the documentation ~ submitted by CPCo and S&W, followup checks, and consideration of comments by' members of the public, we conclude that S&W meets the independence and competence criteria for third party reviewers and that-S&W's proposed CIO program is adequate to provide for an assessment of the Construction Completion Program (CCP).
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