ML20127B734
| ML20127B734 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/12/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| Shared Package | |
| ML20125D664 | List: |
| References | |
| FOIA-84-740 NUDOCS 8406210040 | |
| Download: ML20127B734 (13) | |
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JUN 12 GE4 t
MEMORANDUM FOR:
Carlton Kammerer, Director, Office of Congressional Affairs FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
.1UNE 14,1984, UDALL HEhRINGS ON DIABLO CANYON Attached are responses to Henry Myers cuestions dated April 10, 1984. These responses are for inclusion in the Chairman's briefing book forwarded to you or. June 7,1984 and for forwarding separately to Dr. Myers.
1111am J. Dircks Executive Director 4 for Operations i
Attachment:
As stated 1
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DR. MYER'S QUESTIONS (DATED 4/10/84) WERE FIRST RECEIVED ON APRIL 11, 1984, SHORTLY BEFORE THE COMMISSION MEETING REGARDING DIABLO CANYON UNIT 1 LOW POWER TESTING.
A LICENSING BOARD NOTIFICATION WAS MADE ON APRIL 12, 1984. MOST OF THE TOPICS REFERENCED BY THE QUESTIONS WERE DISCUSSED IN THE COMMISSION MEETING ON APRIL 13, 1984.
DURING THAT MEETING THE TOPICS WERE ADDRESSED BOTH I
BY THE STAFF AND THE LICENSEE,.IN ADDITION, THE LICENSEE HAD PREVIOUSLY j
SUBMITTED MATERIAL TO THE ATOMIC SAFETY AND LICENSING BOARD (IN 1983) WHICH 1
. RELATES.TO THESE TOPICS.
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NRC STAFF EXAMINATION OF THE NSC AUDIT, AND RELATED ACTIONS, WAS PERFORMED PRIMARILY TO PROVIDE THE NEW NRC REGIONAL ADMINISTRATOR INSIGH_T INTO THE MANAGEMENT AND QUALITY PRACTICES EMPLOYED IN THE EARLY CONSTRUCTION OF DIABLO CANYON.
EXAMINATION OF THE NSC AUDIT PROVIDED THE VEHICLE.
THE STAFF FOLLOWED THE PATH REPORTED BY THE NSC AUDIT,' APPROPRIATELY EXPANDING UPON AREAS OF QUESTION, TO DETERMINE-THE VALIDITY OF THE NSC FINDINGS. THE NRC STAFF DID NOT PERFORM A COMPLETE' RECONSTRUCTION OF ALL PULLMAN POWER CONSTRUCTION ACTIVITIES AT THE SITE OVER THE YEARS.
BASED UPON THE STAFF'S FINDINGS RELATING TO THE NSC-AUDIT, A-RECONSTRUCTION OF THIS TYPE IS NOT WARRANTED,.AND IS NOT CONSIDERED;TO-BE AN APPROPRIATE EXPENDITURE OF NRC STAFF i
RESOURCES'.
CERTAIN ASPECTS OF THE QUESTIONS LISTED BELOW'CANA0T BE SPECIFICALLY ANSWERED SINCE TOTAL RECONSTRUCT, ION OF A,LL" ASPECTS.WAS NOT PERFORMED, AND, AS STATED, IT'DOES:NOT APPEAR THAT FURTHER-EFFORTS IN THIS AREA ARE MERITED.
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THE NSC AUDIT OF PU'.LMAN APPEARS TO HAVE BEEN UNDERTAKEN IN RESPONSE TO CONCERNS EXPRESSED BY PG&E AS TO WHETHER THE DIABLO REACTORS HAD BEEN CONSTRUCTED IN A MANNER THAT COMPLIED WITH THE COMMISSION'S REGULATIONS.
PG&E AUDIT 80422 (P. 2) STATES: "SEVERAL APPARENTLY* GENERIC DEFICIENCIES'IN WORK PERFDRMED BY PULLMAN WERE PREVIOUSLY IDENTIFIED BY THE GENERAL CONSTRUCTION DEPARTMENT."
a WHAT " GENERIC DEFICIENCIES" HAD BEEN IDENTIFIED BY THE GENERAL CONSTRUCTION DEPARTMENT 7-HAD THESE."GENERfC. DEFICIENCIES" BEEN REPORTED TO THE AEC/NRC?
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ANSWER 1:
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AS DISCUSSED IN THE APRIL 13, 1984, COMMISSION MEETING TRANSCRIPT, THE LICENSEE PERFORMED ITS AUDIT (NO: 80422) TO SAMPLE THE ADEQUACY OF HARDWARE I
ANDOBTAINANASSESSMENTOFPULLMANACTIVITIESDUETOTHE(APPARENTLY)
IMPENDING LICENSING OF THE PLANT. THE BEST THAT THE STAFF WAS ABLE TO RECONSTRUCTREGARDINGTHE"GENERICDEFICIENCIES"(REFEREDTOINAUDIT80422)~
RELATE PRIMARIL?.70 TWO SPECIFIC PROBLEMS AND A M0'RE GENERALIZED PROBLEM WITH REWORK. THE' STAFF HAD BEEN INFORMED OF THER.P)t0BLEMS.'
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THE FIRST SPECIFIC PROBLEM RELATED TO DEFICIENCIES IN ANCHOR BOLT INSTALLATIONS WAS DETECTED IN EARLY 1977.
EXTENSIVE RESEARCH, TESTING, AND REWORK WAS ASSOCIATED WITH THIS ISSUE TO IMPROVE CONTROLS FOR INSTALLING AND O
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THE NR" STAFF WAS :NFORMED OF THIS PROBLEM.
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- .SFECTING ARCHO~. 50LTS.
FACT, MUCH OF THE WORK DONE IN THIS AREA WAF ui!LIZED BY THE STAFF IN MArIN3 ASSESSMENTS OF ANCHOR BOLT ADEOUACY AT OTHER FACILITIES, IN THAT, THESE PROBLEMS WERE FOUND TO BE SOMEWHAT GENERIC IN THE INDUSTRY.
THESE FINDINGS
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I PROVIDED A BASIS FOR THE ISSUANCE OF IE BULLEf1N 79-02.
THE SECOND SPECIFIC PROBLEM RELATED TO UNDERSIZED SOCKET WELDS ON SCHEDULE 160 PIPING.
i DEFICIENCIES IN THIS AREA LED TO THE REINSPECTION OF ALL SCHEDULE 160 SOCKET
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WELDS AND'THE ADDITION OF WELDMENT TO THOSE WHICH WERE FOUND TO BE UNDERSIZED.
l IN 1977, THE LICENSEE ALSO NOTED THAT THE VOLUME OF REWORK BY THE PULLMAN 3
CONTRACTOR WAS INCREASED OVER PREVIOUS PERIODS. - THIS INCLUDED NOT ONLY ANCHOR BOLTS, AND SOCKET WELDS, BUT ALSO REWORK RELATED TO RADIOGRAPHS.
l OUESTION 2r t
I THESCOPESfATEMENTOFTHENSCAUDITENCOMPA5 SED"WORKMANSHIPOFTHE FIELD-FABRICATED AND INSTALLED ITEMS." THE JUNE 16, 197.8 LETTER FROM i
i MR. WISCHOW TO MR. BAIN TO WHICH THE PG&E REVIEW OF THE NSC AUDIT 'AND PULLMAN 4
RESPCNSE THERETO WERE ATTACHED, STATED THAT THE NSC AUDIT "DID NOT ADDRESS ITSELF TO THE VERIFICATION OF THE ADEQUACY OF THE INSTALLED-HARDWARE. THE NSC AUDIT WAS SUPERFICIAL:WITH-RESPECT TO THE HARDWARE...."
t DID NSC FULFILL-ITS CCNMITMENT:-T0 VERIFY THE ADEQUACY, OF INSTALLED HARDWARE?
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IF NOT, WHAT WAS THE REASON FOR ITS NOT HAVING DONE 507 WHAT WAS DONE TO 1
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SATISFY PG&E'S ORIGINAL CONCERN THAT THERE EE AN AUDIT TO VERIFY THE ADEQUACY j
OF INSTALLED HARDWARE 7 I
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5ASED ON OUR REVIEW 0F THE SCOPE OF WORK ASSIGNED TO NSC, IT CLEANLY LOOKS AS IF.NSC SHOULD HAVE FOCUSED ON INSTALLED HARDWARE.
AS EVIDENCED BY THE NSC REPORT THE VAST MAJORITY OF THE NSC EFFORT FOCUSED ON THE " PAPER-TRAIL" ASSOCIATED WITH THE' WORK, AND NOT THE WORK ITSELF.
AS MENTIONED PREVIOUSLY, 2
THE STAFF DID NOT PERFORM A COMPLETE RECONSTRUCTION OF ALL NSC ACTIONS. THE STAFF DOES NOT KNOW THE PRECISE REASONS NSC DID NOT DIRECT THEIR AUDIT TOWARD 1
HARDWARE.
RECONSTRUCTION WOULD BE LARGELY SPECULATIVE. NEVERTHELESS, THE I
LICENSEE FELT'THAT A DIRECT HARDWARE AUDIT SHOULD BE' PERFORMED. THE LICENSEE 4
j FIRST REQUESTED THAT PULLMAN PERFORM SUCH AN AUDIT AS.A PART OF THE FOLLOWUP 4
TO THE NSC AUDIT.' THIS FOLLOWUP HARDWARE AUDIT WAS. PERFORMED BY A SINGLE INDIVIDUAL '. LICENSEE OVERVIEW OF THIS ACTIVITY CONCCUDED THAT THIS AUDIT WAS DEFICIENT. ACCORDINGLY,.THE LICENSEE DIRECTED THAT PULLMAN PERFORM A MORE EXTENSIVE,.IN-TEPTH' AUDIT 0F HARDWARE.
THIS AUDIT (NO. 71-77-3-78)WAS SATISFACTORILY PERFORMED IN JULY 1978, AND IDENTIFIED 43 ITEMS WHICH WERE i
APPROPRIATELY ADDRESSED AND RESOLVED TO THE LICENSEE'.S SATISFACTION.
i QUESTIONS 3:
PG&E UNDERTOGK~ AUDIT.80422 TO VERIFY THE. ADEQUACY OF PULLMAN'S QA PROGRAM; TO REVIEW THE VALIDITY OF THE NSC FINDINGS AND'TO DETERMINE THE ACCURACY AND APPROPRIATENESS OF PULLMAN'S RESPONSE; AND T0,.0BSERVE THE AS-INSTALLED CONDITION OF COMPONENTS AND PULLMAN'S ADHERENCE TO APPLICABLE SPECIFICATIONS,
- DESIGN DRAWINGS, AND QUALITY STANDARDS.
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E0:22 EVALUATED A PULLMAN CORPORATE A:.'::T CC:: DUCTED ::; FEBRUAPv 1978.
AL'DIT EC122 FOUND DISCREPANCIES IN ITEMS T.AT HAD EEEN INSFECTED BY PULLMAti AUD:TOF.5 WHO NOTED NO DISCREPANCIES.
ACI D422 CONCLUDED THAT "IN LIGHT OF THE NUMEER OF DISCREPANCIES NOTED, IT IS A~PA?.ENT THAT THE PULLMAN AUDIT DID UOT EFFECTIVELY EVALUATE THE QUALITY OF THEIE WDRK."
WHAT ADD IIOittd AUDITS WERE CONDUCTED II; L:G:-T OF THE FINDING THAT PULLMAN'S
" AUDIT DID NOT EFFECTIVELY EVALUATE THE QUALITY OF THEIR WORK?"
IN LIGHT OF 1
THIS FINDING WHAT HARDWARE INSP CTIONS WERE CONDUCTED TO DETERMINE THE ADEQUACY.OF PULLMAN'S WORK? HOW MANY DISCP.EFANCIES WERE NOTED AS THE RESULT OF ADDITIONAL. AUDITS.AND INSPECTIONS CONJUCTD !N THE WAKE OF-AUDIT-80422?
WHAT WAS DONE.TO DEiERMINE WHY THE DEFICIEr.T CONDITIONS NOTED I.N M.-3725 AND M-3726 HAD NOT BEE!LDISCOVERED IN THE C0'JRSE OF THE ORIGINALIINSPECTION PROCESS?.WHAT.WAS.THE" REASON THESE DEFICIENT CONDITIO.NS HAD.N.O.T BEEN NOTED DURING THE COURSE OF THE ORIGINAL INSPECTION PROCESS 7 WHAT WAS DONE TO DETERMINE WHY THE PULLhIAN CORPORATE ' AUDIT HA[NOT NOTED THE DISCRE
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NOTED BY AUDIT 80422? WHY DID THE PULLMAN CORPORATE AUDIT NOT. DISCOVER THE DISCREPANCIES? WHAT WAS THE BASIS FOR THE B~-37 FINDING (STATED ON PAGE 40)
THAT PULLMAN HAD PERFORMED ADEQUATE CORPORATE AUDITS? WHAT WAS THE BASIS FOR THE 83-37 FINQING:(ID;). THAT PULLMAN'S IliTERNAL AND CORPORATE-AU&ITS HAD INDICATED.THAT NO FUNDAMENTAL QA PROGRAM BP.EAKDOWN HA.D OCCURRED? -[E.G. SEE 1978-79 [INDINGS RE PIPE RUPTURE RESTRAINTS FER NC'R'S DC1581RM-008, o
DCl-78-RM-009,.DC1-79-RM-003,ETC.]
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AiiSWER 3:
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AS STATE: IN RESPONSE TO QUESTION 2, AE0VE, THE LICENSEE PROPERLY DETERMINED THAT DL'LLKAN'S INITIAL AUDIT WAS DEFICIENT. THIS WAS A SECOND FALSE START (THE FIRST BEING NSC'S FAILURE TO FOCUS ON THE HARDWARE). THE UTILITY THEN TOOK ACTION WITH PULLMAN TO GET A THOROUGH HARDWARE AUDIT.
THIS PULLMAN AUDIT (NO. 71-77-3-78) ACCOMPLISHED THE LICENSEE'S GOAL.
PULLMAN IDENTIFIED 43 ITEMS IN THEIR AUDIT.
THE KINDS'0F DEFICIENCIES FOUND BY THE LICENSEE (IN M-3725 AND M-3726) AND THE PULLMAN AUDIT WERE MOSTLY MINOR IN NATURE AND NOT ATYPICAL OF WHAT IS FOUND ELSEWHERE.
IT IS NOT POSSIBLE TO ACCURATELY STATE AT THIS LATE DATE, WHY THE FIRST LINE QC INSPECTORS DID NOT DETECT THESE ANOMALIES. COMMENT ON WHY THE PULLMAN INITIAL AUDIT WAS INADEQUATE WOULD BE LARGELY SPECULATIVE. THE AUDIT WAS CONDUCTED BY A SINGLE AUDITOR. WHAT IS IMPORTANT IS THAT PG&E RECOGNIZED THE PROBLEM, TUGK FORCEFUL ACTION WITH PUL'LMAN MANAGEMENT, AND A MEANINGFUL HARDWARE AUDIT WAS OBTAINED.
AS INDICATED, THE FINDINGS FROM THE LICENSEE AND PULLMAN AUDITS WERE NOT OF THESIGNIFICANCETHATWOULDINDidATEAFUNDAMENTALQUALITYASSURANCEPROGRAM BREAKDOWN. AND, AS STATED IN STAFF REPORT 83-37, THE COMBINATION OF PULLMAN CORPORATE AND INTERNAL AUDITS ~PROVIDED ADEQUATE AUDIT-COVERAG~E TO MEET THE REQUIREMENTS OF 10 CFR 50, APIPENDIX B.
QUESTION 4:
TO WHAT EXTENT DID RECOMMENDATIONS LISTED ON PAGE 11 - 12 0F AUDIT 80422
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CORRESPOND TO DEFICIENCIES NOTED IN THE NSC AUDIT?
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I WHILE THERE IS SOME COMMONALITY IN GENERAL SUSJECT MATTER (E.G., THE GENERAL TOPICS OF INSPECTORS' CERTIFICATION AND REFERENCE TO PROCEDURE KFPS-7) THE LICENSEE'S RECOMMENDATIONS ON PAGES II AND 12 0F AUDIT 80422 DO NOT HAVE A ONE i
F0~. ONE CORRELATION TO THE NSC FINDINGS.
THE NSC AUDIT RELATED PRIMARILY TO PAPER WORK WHILE THE LICENSEE'S AUDIT INCLUDED HARDWARE INSPECTIONS.
00ESTIONS 5:
A MAY 29, 1979 MEMORANDUM FROM K. FREED TO E. GERWIN ADDRESSES PIPE RUPTURE RESTRAINT PROBLEMS. WHY HAD WELDER DEFICIENCIES NOT BEEN DETECTED AND CORRECTED AT AN EARLIER DATE BY PULLMAN'S QC/0A PROGRAM? TO WHAT EXTENT ARE THE NOTED WELDING DEFICIENCIES SIMILAR TO THOSE SPECIFIED BY THE NSC AUDIT?
ANSWER 5:
THERE APPEARS TO BE SOME CONFUSION ABOUT THE SIGNIFICANCE OF THE MAY 29, 1979 MEMO.* THE PROBLEM WHICH IT DISCUSSES WAS DETECTED MUCH EARLIER THAN THE DATE OF THE MEMO. THE LICENSEE AND PULLMAN HAD PROPERLY DOCUMENTED THE PROBLEM THROUGH'THE QC/QA SYSTEM, AND HAD BEEN EVALUATING THE EXTENT OF THE PROBLEM FOR SEVERAL MONTHS.
IT WAS OFFICIALLY REPORTED TO THE NRC kS A 50.55(E)
DEFICIENCY OR APRIL 4, 1979. THE MAY 29, 197,9 MEMO WAS Aff INTERNAL PULLMAN DCCUMENT ADDRESSED TO THE PULLMAN QA MANAGER.
IT REPRESENTED AN EARLY ATTEMPT BY PULLMAN TO ASSESS THE CAUSES OF THE PROBLEM.
THE MEMO WAS SOMEWHAT PREMATURE IN THIS REGARD SINCE THE LICENSEE WAS CONDUCTING EXTENSIVE EVALUATIONS WHICH LASTED OVER AN EXTENDED PERIOD. THESE EVALUATIONS INCLUDED: NONDESTRUCTIVE
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b E;.AM!t.ATIONS; EXAINATION OF i: ELD RECCRDS; DEITRUCT!vE TESTING; ANC FAILU:.E MODE DETERMINATI0i..
A FINAL REPORT ON THIS SUEJECT WAS ISSUE; TO THE NRC In DECEMBER 1980. THIS TOPIC WAS HEAVILY INSPECTED SY.THE NRC STAFF AND IS ADDRESSED IN SIX STAFF INSPECTION REPORTS.
THE ANALYSIS OF THE PROBLEMS DISCLOSED THAT THE CAUSES WERE COMPLEX AND UNIQUE i0 THE TYPE OF WELDING BEING PERFORMED.
THE RUPTURE RESTRAINT SITUATION WAS UNIQUE IN THAT THE COMPONENTS INVOLVE HIGH STRENGTH MATERIALS, VERY THICK WELD SECTIONS, AND HIGHLY RESTRAINED JOINT CONFIGURATIONS, NOT NORMALLY FOUND IN NUCLEAR PLANTS. THE COMPONENT FAILURES WERE FIRST DETECTED AS LAMELLAR TEARS OUTSIDE OF THE WELDS THEMSELVES. THE ORIGINAL INSPECTION PROCESS SPECIFIED FOR THESE WELDS DID NOT ANTICIPATE THIS TYPE OF FAILURE AND WAS NOT SUITABLE i
FOR THEIR DETECTION. THEREFORE, EVEN THOUGH THE QC INSPECTORS PERFORMED THEIR INSPECTIONS PROPERLY THEY.WERE NOT ABLE T0' DETECT THE FLAWS DUE TO THE INSPECTION TECHNIQUE SPECIFIED.
THE PROBLEM WAS ULTIMATELY IDENTIFIED WHEN PERFORMING ROUTINE REPAIRS TO THE RESTRAINTS.
A SUITABLE NONDESTRUCTIVE EXAMINATION METHOD WAS SPECIFIED AND APPLIED AS A PART OF THE CORRECTIVE ACTION PROGRAM.
THE CONDITIONS RELATED TO THE RESTRAINTS ARE QUITE DIFfERENT THAN THOSE
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ADDRESSED BY THE NSC AUDIT (WHICH. FOCUSED ON PAPERWORK RELATED TO PIPE AND
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PIPE SUPPORT WELDING). REFER TO QUESTION 6 FOR AUDITIONAL ISCUSSION IN THIS AREA.
l 00ESTION 6:
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..'. - *J::TS AN3/3R REINSPECT:0NS OF HANGERS JERE CON 7JCTE: TO DETERMINE WHE MER ME YFES OF DEFECTS FOUND Ih THE PIPE RUPT'JRE RESTRAINTS EXISTED WITH RESPECT T ?!?E MANGERS?
WHAT IS THE SASIS FOR A DETERMINATION THAT DEFECTS FOUND IN
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FI?E RUFTURE RESTAINTS DID NOT EXIST WITH RESPECT TO PIPE HANGERS?
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THE PROBLEMS ASSOCIATED WITH RUPTURE RESTRAINT FABRICATION WERE FOUND TO BE DUE PRIMARILY TO THE U'SE OF HIGH STRENGTH STEEL, IN HEAVY THICK SECTIONS, WITH RESTRAINED JOINT CONFIGURATIONS.
THESE ARE NOT THE TYPE OF CONDITIONS ENCOUNTERED IN PIPE HANGER FABRICATION, WHICH TYPICALLY INVOLVES MILD STEEL, SKALLER MATERIAL SECTIONS, WITH LESS CONCERN WITH RESTRAINED JOINT CONFIGURATIONS.
SINCE,THE PROBLEMS ASSOCIATED WITH THE FABRICATION OF THE
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HEAVY RESTRAINTS UERE NOT APPLICABLE TO PIPE HANGERS THERE WERE NO SPECIFIC AUDITS OR REINSPECTIONS PERFORMED RELATIVE TO THIS TOPIC. HOWEVER, FOR OTHER REASONS (SUCH AS IE BULLETIN 79-14) THERE WEPE REINSPECTIONS OF PIPE HANGERS.
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BRIEFING PAPER 10 CFR 2.206 Petitions re Diablo Canyon On April 16, 1984, Office of the General Counsel forwarded to the Office of Inspector and Auditor (0IA), a Comission Memorandum and Order dated April 13, 1984, which had attached to it an April 12, 1984, 2.206 Petition from the intervenor group, Government Accountability Project (GAP). Within its Peti-tion, GAP called upon the Commission to have OIA investigate to determine:
.(a) whether there have been misleading or material false statements by the NRC staff to the Commission during the March 19, 26, or 27 briefings, or in Supplemental Safety Evaluation Reports SSER-21 (December 1983) or SSER-22 (March 1984); and (b) the causes of the QA breakdown within the NRC staff responsible for Diablo Canyon.
The Petition wen,t on to outline various facts which GAP believed were in support of these two " allegations."
In its Order, the Comission noted that it had "reques'ted OIA to review the Petition and to take whatever actions it deems nqcessary.". -
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On May 15, 1984, James Lieberman, ELD, forwarded to 0I'A a second GAP 2.206 Petition dated May 3,.1984, for 0IA's "use as appropriate." Within that Peti-tion, GAP repeated word for word the earlier " allegations" addressed above.
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.e 01A is currently reviewing the GAP submissiens to detemine wnat specific information the Petitions contain in support of these " allegations."
It is anticipated that Thomas Devine (signer of the two Petitions) will be inter-viewed to detemine if he has provided all relevant infomation available to him regarding these matters. Further interviews / investigation will then be accomplished, as appropriate.
In addition as to the second " allegation," more specific information must be forthcoming which would indicate the possibility of specific misconduct on the part of NRC employees, in contrast to GAP's apparent expression of general disappointment with NRC actions, before OIA will be in a position to conduct an investigation as to this matter.
These impressions are preliminary only an'd'therefore are subject to modifica-tion should new or different infomation come to light.
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