ML20085E311
| ML20085E311 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/27/1983 |
| From: | Axelrad M LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | CALIFORNIA, STATE OF |
| Shared Package | |
| ML20085E309 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8308010263 | |
| Download: ML20085E311 (22) | |
Text
,
/i "
'. 'N L
/$
t# s UNITED STATES OF AMERICA
}
L'd JUL 20 GB31 NUCLEAR REGULATORY COMMISSION
\\s L<-
/'!
\\ '$
- n. e v N hs
\\y tgg W-g0/
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD.s.
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 OL
)
50-323 OL (Diablo Canyon Nuclear Power Plant
)
Units Nos. 1 and 2)
)
RESPONSE OF THE INDEPENDENT DESIGN VERIFICATION PROGRAM TO GOVERNOR DEUKMEJIAN'S SECOND SET OF INTERROGATORIES RESPONSE TO INTERROGATORY 1:
In accordance with Instruction A in Governor Deukmejian's Second Set of Interrogatories to the IDVP, the IDVP states that it is not able to provide a response in the form re-quested because it has aggregated information differently in the course of its review.
As stated in the IDVP Program Management Plans, the IDVP's review of QA controls for seismic design work for the Diablo Canyon Nuclear Power Plant, Unit One (DCNPP-1) con-sisted of a review of the QA programs employed by service-related design contractors and PGandE, as well as the imple-mentation of those programs.
These programs were reviewed against the applicable criteria of 10 CFR Part 50 Appendix B.
830e010263 830727 PDR ADOCK 05000275 PDR O
The results of this review are reported in detail in the IDVP Final Report (Section 4.2.2 and 4.2.3).
No specific determi-nations concerning compliance with Appendix B were made on a system-by-system, structure-by-structure, or component-by-l component basis.
RESPONSE TO INTERROGATORY 2:
See Response to Interrogatory 1.
RESPONSE TO IN'TERROGATORY jl:
In accordance with Instruction A in Governor Deukmejian's Second Set of Interrogatories, the IDVP states that it is not able to provide a response in the form requested because it has aggregated information differently in the course of its
- review, As described in ITR-8, the IDVP performed a QA evaluation f
of the DCP's implementation of the NRC-approved QA program applied to the DCP Corrective Action Program (CAP).
No specific determinations concerning compliance with Appendix B were made on a system-by-system, structure-by-structure, or j
ccmponent-by-component basis.
l The IDVP's evaluation of the CAP consisted of verifying l
i whether the DCP had properly implemented the NRC-approved QA I
I s
program e,stablished for the CAP.
The IDVP did not re-review the NRC-approved QA program.
The scope and method of review of the CAP by the IDVP are set forth in ITR-8.
The overall results of the IDVP's QA evaluation of the CAP are reported in detail in ITR-41 and Section 4.2.3.2.c of the IDVP Final Report.
RESPONSE TO INTERROGATORY 4:
See Response to Interrogatory 3.
RESPOMSE TO INTERROGATORY 5:
In accordance with Instruction A to Governor Denkmejian's Se.cond Set of Interrogatories, the IDVP states that it is not able to provide a response in the form requested because it has aggregated information differently in the course of its review.
As stated in the IDVP Phase II Program Management Plan, the IDVP reviewed the QA programs, and the implementation of those programs, by PGandE and the service-related non-seismic design contractors performing final design work for the DCNPP-1 prior to June 1978.
A list of the contractors reviewed is set forth in ITR-9 and in Section 4.1.4 of the IDVP Final Report.
The QA programs were compared against all of the applicable criteria of 10 CFR Part 50, Appendix B and, where necessary O
w
--.m
as described in Section 4.2.1 of the IDVP Final Report,.
against the " design control practices" developed by the IDVP.
For service-related contractors performing non-seismic design work for the DCNPP-1 after June 1978, the IDVP Phase II prcgram included an assessment only of the QA programs for those contractors who worked on systons within the sample analyzed by Stone & Webster Engineering Corporation during their Phase II program.
These QA programs were reviewed agaiast all of the relevant criteria of 10 CFR Part 50 Appendix B ard, where necessary as described in Section 4.2.1 of the IDVP Final Report, against the " design control practices" developed by the IDVP.
The results of the IDVP's QA review of PGandE and service-related non-seismic design contractors are set forth in ITR-42 and in the IDVP Final Report (Sections 4.2.2 and 4.2.3).
R3SPONSE TO INTERROGATORY 6_:
i l
See Response to Interrogatory 5.
RESPONSE TO INTERROGATORY 7:
See Response to Interrogatory 3.
The IDVP did not distinguish between seismic and non-seismic design activities for purposes of verifying the implementation of the QA programs of the CAP.
RESPONSE TO INTERROGATORY 8:
See Response to Interrogatory 7.
RESPONSE TO INTERROGATORY 9:
~
It is difficult for the IDVP to anrger this Interrogatory, because the Interrogatory does not specify what is meant by the atatement "each and every Quality Assurance requirement of Appendix A."
In the view of the IDVP, the only language set forth in 10 CFR Part 50, Appendix A which might constitute a " Quality Assurance requirement" is found in General Design Criterion 1.
To the extent that GDC-1 is interpreted as establishing a distinct QA requirement applicable to the design of safety-related SS&C's, the IDVP believes it is fully implemented by a Quality Assurance program which meets the applicable criteria of 10 CFR Part 50, Appendix B, or the
" design control practices" developed by the IDVP.
Therefore, although the IDVP made no direct and explicit determinations with respect to this portion of Appendix A, GDC-1 was implicitly considered in the IDVP's review of QA programs of PGandE and service-related design contractors (as set forth in the responses to Interrogatories 1-8).
RESPONSE TO INTERROGATORY 10:
See Response to Interrogatory 9.
l l
l
RESPONSE TO INTERROGATORY ll:
See Response to Interrogatory 9.
RESPONSE TO INTERROGATORY 12:
See Response to Interrogatory 9.
RESPONSE TO INTERROGATORY 13:
See Response to Interrogatory 9.
This Interrogatory raises a distinction between the design of SS&C's defined by this group of Interrogatories as "important to safety" and those defined as " safety-related."
In preparing the IDVP Program Management Plans, which were subsequently approved by the Commission, the IDVP interpreted the Commission's Order of November 19, 1981, and the Staff's letter of that same date, to require only a verification of the design work of PGandE and service-related design contractors performing design work on safety-related SS&C's as defined in the FSAR.
The IDVP does not know whether any of the design work that it re-l viewed pertains to SS&C's defined by these Interrogatories as "important to safety but not safety-related."
l RESPONSE TO INTERROGATORY 14:
l l
See Response to Interrogatory 13.
i
1 RESPONSE TO INTERROGATORY 15:
See Response to Interrogatory 13.
I RESPONSE TO INTERROGATORY 16:
See Response to Interrogatory 13.
RESPONSE TO INTERROGATORY 17:
1 No.
RESPONSE TO INTERROGATORY 18:
See Response to Interrogatory 17.
RESPONSE TO INTERROGATORY 19:
As required by the Commission's Order of November 19, 1981, and the Staff's letter to PGandE of the same date, the IDVP evaluated the QA programs of PGandE and the service-re-lated contractors within the scope of the IDVP program against 10 CFR Part 50, Appendix B.
In so doing, the IDVP used some ANSI standards as guidance to help develop the QA checklists and to assess the adequacy of the QA programs and their implementation.
This was especially the case with respect
]
to the use of ANSI N45.2.11 as guidance.
However, the IDVP did not incorporate the language of any ANSI standards into its
checklists and did not make any direct and explicit deter-minations with respect to whether particular ANSI standards listed in this Interrogatory were met, with one exception.
The exception is with respect to the programs employed by EDS Nuclear which the IDVP determined met ANSI N45.2.11 (Final Report S 4.2.2.4).
RESPONSE TO INTERROGATORY 20:
See Response to Interrogatory 19.
RESPONSE TO INTERROGATORY 21:
See Response to Interrogatory 19.
RESPONSE TO INTERROGATORY 22:
l See Response to Interrogatory 19.
RESPONSE TO INTERROGATORY 23:
In performing its QA review, the IDVP did not make any direct and explicit determinations whether PGandE and its service-related design contractors complied with the Reg.
l Guides cited in this Interrogatory.
However, the Reg. Guides
' cited in this Interrogatory endorse corresponding ANSI i
i l
I
standards (similarly lettered) set forth in Interrogatories 19-22, and therefore the Responses to those Interrogatories are applicable to this Interrogatory.
RESPONSE TO INTERROGATORY 24:
See Response to Interrogatory 23.
RESPONSE TO INTERROGATORY 25:
See Response to Interrogatory 23.
RESPONSE TO INTERROGATORY 26:
See Response to Interrogatory 23.
RESPONSE TO INTET MOGATORY 27:
No.
RESPONSE TO INTERROGATORY 28:
i l
(a)
The scope of the IDVP's verification of seismic l
design work prior to institution of the CAP, and the methodology employed by the IDVP to identify SS&C's to be verified for the l
l DCNPP-1 are described in Section 4.1 of the IDVP Final Report.
The basic methodology employed by the IDVP was to verify a selected sample of the design work of PGandE and each of the
\\
' 19 -
r This service-pelated design contractors for the DCNPP-1.
involved several steps:
(1) identification of each of the seismic design contractors and the scope of their work; (2) identification of the scope of PGandE's seismic design work; (3) preparation of design chains for safety-related SS&C's; and (4) selection of a sample of the design work for verifi-cation.
The IDVP did not verify the seismic design work of the NSSS or other vendors not in the service-related con-tractor design chain for the DCNPP-1 except that the design interface between PGandE and Westinghouse was verified.
(IDVP Final Report, Section 4.1.3).
The seismic design of SS&C's done by service-related contractors was verified on a sampling basis as discussed above.
The safety-related SS&C's designed by PGandE are listed in Section 4.1.2 of the Final Report.
The safety-related SS&C's designed by the service-related contractors are listed in Section 4.1.5 of the Final Report.
The design ch-ins for-m safety-related SS&C's are reported in ITR's 5 and 29, and in Section 4.1.5 of the Final Report.
The IDVP has not identified In addition, every SS&C designed by the NSSS or other vendors.
l the IDVP's effort did not include an identification of every SS&C which it did not include within its sample of SS&C's veri-fied.
i
.,m.-
11 -
(b). Any SS&C's and design groups not reviewed by the IDVP were either beyond the scope of the IDVP program or outside the sample selected by the IDVP.
(c)
The original samples for the verification of seismic design were developed by RLCA and reviewed and approved by TES.
Selection of this sample was subsequently reviewed and approved by the NRC.
The individuals responsible for these selections were Robert L. Cloud (RLCA) and William E. Cooper (TES).
The original samples were expanded as appropriate in accordance with the IDVP Program Management Plan.
' (d) & (e)
The IDVP has not formed any opinions with respect to specific SS&C's, the design of which was not verified by the IDVP.
The IDVP's overall conclusions with respect to whether PGandE has met its licensing commitments are stated in Sections 2 and 6 of the IDVP Final Report.
RESPONSE TO INTERROGATORY 29:
No.
RESPONSE TO INTERROGATORY 30:
I l
(a)
The identity of the SS&C's designed since institu-tion of the CAP can te found in the PGandE DCP Final Report.
l l
As stated in ITR's 8 and 35, the IDVP verified the work of
--m,
,.,--,.e.,---.--
,,,-y
,---w
..-q.
-p
,-w.--,,
,w-
-... -. - +
.-,y,..,,,-
~,,,, - _,,
7--.
-a.-,
. c.
the CAP on a sampling basis.
A list of all the design work verified by the IDVP can be compiled from ITR's 51 and 54-68 when those ITR's are completed and issued by the IDVP.
The IDVP's effort did not include ' identification of every SS&C designed since institution of the CAP which was not verified by the IDVP.
(b)
Any SS&C's and design groups not reviewed by the IDVP were either beyond the scope of the IDVP program or outside the sample selected by the IDVP.
(c)
The sample of CAP work reviewed by the IDVP was chosen by RLCA with the assistance and approval of TES.
The i
individuals responsible for this selection were Robert L. Cloud and Edward Denison (RLCA) and William E. Cooper and Ronald Wray (TES).
(d) & (e)
See Responses to Interrogatories 28 (d) and (e).
RESPONSE TO INTERROGATORY 31:
No.
RESPONSE TO INTERROGATORY 32:
(a)
Since the definition of " procured components" in the Interrogatories is not clear, the IDVP interprets " procured i
.g..,
,,m,e,
,m--
,e--
components" as components for which analysis was performed by groups (NSSS or other vendors) other than PCandE or service-related contractors.
This analysis would have been included as part of the design analysis of record following acceptance by PGandE as licensee.
The IDVP Program Management Plans did not include " procured components" because the IDVP scope, as set forth in the Commission Order of November 19, 1981, and the Staff letter of the same date, included only design work The performed by PGandE and service-related contractors.
IDVP's effort did not include identification of all " procured components" for the DCNPP-1.
(b)
The IDVP's effort did not include identification of the vendors of all " procured components."
(c)
See Response to Interrogatory 32(a).
The exclusion of " procured components" was established (d) by the Commission Order of November 19, 1981, and the Staff i
i letter of the same date.
(e) s (f)
The IDVP has formed no opinions with respect to the qualification of " procured components."
RESPONSE TO INTERROGATORY 33:
4 No.
l l
- -~
w
-w
RESPONSE-TO INTERROGATORY 34:
(a)
In Phase I, the IDVP verified a sample of the seismic design work of PG' E and its service-related seismic design contractors for cc lance with the Hosgri design earthquake.
Additionally, in the IDVP's verification of the design work of the CAP, the sample of seismic design work established in accordance with ITR-8 was reviewed for com-pliance with the Hongri earthquake, and the sample established in accordance with ITR-35 was reviewed for compliance with the DE and DDE.
Much of the sample was the same under both ITR's 8 and 35, and therefore in much of the verification of design work of the CAP, all three design earthquakes were considered.
l (b)
See Response to Subpart (a).
(c)
The IDVP performed its verification in accordance with the IDVP Program Management Plans.
(d)
See Responses to Interrogatories 28(c) and 30 (c).
(e) & (f)
See Responses to Interrogatories 28 (d) and (e).
1 RESPONSE TO INTERROGATORY 35:
See Response to Interrogatory 32(a).
e e
% IS
1 l
RESONSE TO INTERROGATORY 36:
(a)
The IDVP did not review the seismic qualification of " procured components", as stated in the Response to Interrogatory 32.
(b)
See Response to Interrogatory 32 (a).
(c)
See Response to Interrogatory 32(a).
(d)
See Response to Interrogatory 32(a).
(e)
See Response to Interrogatory 32(d).
(f) & (g)
See Responses to Interrogatories 32(e) and (f).
RESPONSE TO INTERROGATORY 37:
No.
RESPONSE TO INTERROGATORY 38:
(a)
As stated in the IDVP Phase II Program Management Plan, the IDVP's verification of non-seismic design work was based upon a sample of design work in three types of systems:
(a) a fluid system; (b) an air syste n; and (c) an electrical system associated with one of the above.
Accordingly, the IDVP's verification consisted of a review of the Auxiliary Feedwater System, the Control Room Ventilation and Pressuriza-tion System and the 4160 V Safety-Related Electrical System.
9 4
6 g
--_s-----,,-..--.-_..-_r<v
-,,---.---.e.-
Design work outside of these three systems was verified when generic concerns were identified in the IDVP's verification of these three systems.
(See IDVP Final Report, Section 4.8).
In addition, as stated in ITR-35, the IDVP reviewed non-seismic design work performed by the CAP in cases where non-seismic design governed.
To date, the sole such IDVP verification involved tornado-generated missiles designed for the intake structure vent.
The IDVP's effort did not include identification of every SSsc, nor every design group, whose work was not reviewed.
(b)
Any SS&C's and design groups not reviewed by the IDVP were either beyond the scope of the IDVP program or outside the sample selected by the IDVP.
(c)
The sample of non-seismic design work verified by the IDVP was selected by RLCA or SWEC, and reviewed and The individuals responsible for this selection approved by TES.
were Robert L. Cloud and Edward Denison (RLCA), Frank Sestak and John Krechting (SWEC), and William E. Cooper (TES).
l (d) & (e)
See Responses to Interrogatories 28(d) and (e).
RESPONSE TO INTERROGATORY 39:
(a)
Several of the questions asked in this Interrogatory indicate a misunderstanding of the nature of many EOIs since This they assume that every EOI is based upon an " event."
1
- 17'-
s is not the case for many, if not most, of the EOIs issued e
by the IDVP.
Each time an EOI file was opened an Open Item Report was issued and the EOI was reported in the Semimonthly Reports issued by the IDVP participants.
The basis for each EOI is described in the Open Item Report, and its status was tracked in the Semimonthly Reports.
However, the IDVP generally did not, even when applicable, attempt to determine the exact date of an " event" giving rise to the EOI.
Each of the ITR's, other than programmatic ITR's, provides addi-tional information about the EOIs, as does the IDVP Final Report.
The IDVP has provided a list of each EOI in Appendix D of the IDVP Final Report.
Appendix E of the IDVP Final l
Report cross references every EOI to the ITR(s) in which it is discussed, and the Final Report Section in which the ITR's l
l are dis ussed.
i (b)
For those EOIs which are based upon a potential concern about a particular contractor's, or PGandE's, QA program or program implementation, the aspect of the program involved is set forth in the EOI and reported in the Semi-monthly Reports.
Additional information concerning QA-based EOI's can be found in ITR's 2, 41 and 42 and in the IDVP Final I
Report.
In addition, where an EOI is based upon a potential I
l 1
. ~
concern with the design or the design process, to the extent that the IDVP ascribed the potential concern to a particular QA program or program implementation deficiency, this information was set forth in the EOI forms issued by the IDVP participants.
(c)
See Response to Subpart (b).
(d)
See Response to Subpart (b).
(e)
See Response to Subpart (b).
(f)
For every EOI or series of EOIs which the IDVP determined had generic implications, the IDVP's opinion in this regard is set forth in the ITR and in the Final Report Section which discusses the EOI.
The basis for the IDVP's determinations with respect to the generic implications of EOIs or groups of EOIs is also set forth in the various ITR's and the IDVP Final Report.
Those EOI's which generated and the evaluation of those generic concerns, generic concerns, are specifically discussed in Section 5 of the IDVP Final Report.
(g)
See Response to Subpart (f).
(h) on a programmatic basis, the precedures used by the IDVP to determine whether appropriate corrective action was taken are set forth in the IDVP Program Management Plan.
With respect to individual EOIs, this information is part of the EOI files and EOI completion reports which are reported 3
3-2
~
}.e: '
~
,:s A
.s
>x 19 -
k 4.,
m N7
- 4, 4
- w-s in the Semimonthly Reports.
The actions takIen by the IDVP to verify that corrective action ds taken are further_,
summarized in Section 5 Cf the IDVP Final Report, with.-
,e
~
/
cross-references.tdtheappropriatNITR'sandotherFinal e
Report Sections.'
s
/v (i) (1) & (2)- The IDVP activities devaluat!*ons, and other
")
sy items not yet completed are summarized id# Table 7.4il of the y
IDVP Final Report. 'i'his tabulated summary' hts bee'n updated
,o as of July 20, 1983. in Table A-2 of the IDVP Semimonthly Report of July 22, 1983.
Since that date a C,ompletion' Report g
~
has been issued for EOI 1124.
Section 3.4.2 of the IDVP Semimonthly Report, of s
July 22, 1983, itemizes the major tasks to b) complyted,
,c
~.
the scheduled date of completion, and the PGandE requirements i
needed to effect that completion.
Furt,her detail will be S.[7 q.
developed during the "open meeting" scheduled for July 27-28), -:
1983, and this response will be supplemented, based on that[ *~,
N meeting, on or before August 5, 1983.
s, s
\\ a
\\~'
RESPONSE TO INTERROGATORY 40:
37
,.n y
The information requested in this Interrogat'ory k.
V
,I' (a) & (b)
~ s w
can be found in the same manner as for Interrogatory 39 (i).
,'~
The IDVP will provide a similar update for this Interrogatory f.T on or before August 5, 1983.
4 S. I4
j%
T'.
Ws N
~
~
20 -
- c u
. ~.-
t
~.
1<
RESPONSE TO I_'ITERROGATORY 41:
f n'
All of the ab6ve anGwers were provided with respect to DCNPP-1, including a!.y SS&C's within the IDVP's verification
~.,
~
The IDVP sample which were cow.on to DCNPP-1 and DCNPP-2.
s s.
has not otherwise. verified the design of DCNPP-2.
M,, -
s RESPONSE TO INTERROGATORY-42 :'
%=
(a)
In addition to coun6N1 for the IDVP, the following individualsparticipated[inanswering,theseInterrogatories:
s w
y' Interrogatories'l-25:
William E, Cooper, TES;
-(
Roger F. Reedy, RFR; Bruce Norrit;. RFR; Mark Revett, TES.
William E. Cooper, TT:S;
^
s.
' Interrogatories 27-36:
+
y s
N Jtobert L. Cloud, RLCA; Edward Denison, RLCA; Ronald
,e
~. -
d'
'\\
ray, TES.
~,
(
g s
,illiam E. Coop'cy,,TES; Dean v,interroq3 opies'37-38:
W i
. A.
Stratouly, TES; Robert %. Cloud, RLCA;sEdward Denison,
~
s RLCA.
N N-Interrogatories.39-42:
William E.' Cooper, TES; Ronald s
-,(
Wray, TEST k-s
'g-e e, %
s
(
a s.
l s,_
w
(b)
The following documents were relied upon in pre-paring Interrogatory responses:
1.
The IDVP Final Report.
2.
ITR's 2, 5,
8, 9, 29, 35, 41, 42.
3.
Commission Order dated November 19, 1981.
4.
NRC Staff Letter to PGandE dated November 19, 1981.
5.
IDVP Phase I and Phase II Program Management Plans.
6.
April 1, 1983 Transcript of " Meeting With PGandE To Discuss Seismic Design Review, Diablo Canyon Unit 1."
7.
IDVP Semimonthly Report dated July 22, 1983.
Respectfully submitted, Maurice Axelrad l
David Raskin Attorneys For The Independent Design Verification Program i
l f
Date:
July 27, 1983 l
I 4
i l
l
4 STATE OF MASSCHUSETTS SS:
COUNTY OF MIDDLESEX The undersigned, William E. Cooper, being duly sworn this 25th day of July, 1983, upon his oath states that he is employed by Teledyne Engineering Services (TES) as a Consulting Engineer and is assigned as Project Manager for the DCNPP-1 IDVP for which Teledyne Engineering Services is the Program Manager, that he is informed on the matters of inquiry of the Second Set of Interrogatories Propcunded to the Independent Design Verification Program by Governor Deukmejian; that in answering the above and foregoing Interrogatories, he has caused information to be gathered from employees and officers of Teledyne Engineering Services, Robert L. Cloud Associates, and R. F.
- Reedy, Inc.; and that the answers to the above and foregoing interrogatories are true and correct as he has been informed and verily believes.
O
[ %,
William E. Cooper July 25, 1983
-ye
- +
..e
,,