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',i NUCLEAR REGULATORY COMMISSION
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MAR 2 91992 f
N MEMORANDUM FOR: Chainnan Palladino Comissioner Gilinsky Comissioner Ahearne Comissioner Roberts FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
In the near future, we will be sending the Comission a proposal for a possible upgrade of requirements for QA. As part of that effort, the staff will be addressing the QA review program for operating license (OL) applicants. While that effort is underway, over the past few months we have been utilizing an interim arrangement whereby special QA assessments for OL applicants are conducted on a case-by-case basis. The purpose of this memorandum is to outline this interim approach and its results to date.
The NRC staff is conducting special QA assessments for the seventeen applicants with OL decision dates in 1982. The applicants selected were on the basis of February Bevill action dates. These assessments, although conducted against existing Appendix B requirements, are augmented by a senior management (NRR, IE, Region) review of a number of aspects of the overall QA effort. These senior management reviews (which usually include the NRR Office Director and the Regional Administrator) are conducted through meetings that are very intensive and focus on the assurance that the subject plant has been designed and built in accordance with the application, i.e., the FSAR. Limited attention is given in the meetings to operations QA. A listing of the plants is given in Enclosure 1, as well as the schedule being followed for this effort. Presently, the staff has met with six applicants, i.e.,
applicants for San Onofre 2/3; LaSalle 1/2; Grand Gulf 1/2; Summer 1; Susquehanna 1/2; and Shoreham 1.
These are, of course, in addition to Diablo Canyon 1 for which the Comission has established a special evaluation effort.
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The purpose of these meetings is to obtain information from each applicant about the process followed to assure proper design and construction.
Particular aspects relating to design control, design verification and subsequent construction are included in the presentations and discussions.
More important than the applicant's program is his experience and the effectiveness of his program, e.g., how many times the applicant required work to be stopped.
In addition, the staff gives consideration to several other factors in determining whether additional measures (such as third party audits) should be required to further ensure confidence in the applicant's QA program. These other factors include: previous nuclear experience, utility size, degree of utility (as opposed to AE) involvement in the QA program, and QA staff size / audit capability. The extent of additional measures that are necessary has varied from applicant to applicant, based on our evaluation of these factors.
The staff has required that proper documentation to support his presentation and review efforts be submitted for our review. The staff has found that applicants can, prior to fuel load, present a reasonable case of their particular historical and ongoing program, can provide a signed affidavit stating that the plant is designed and constructed in accordance with the application, and, generally can provide an interim report on an independent, verification study for full power. Subsequently, for operation above 5% in those cases where the staff has accepted an applicant's proposal to acquire and convey additional confidence through the use of an independent review by an outside firm, a final report is required to be submitted to the NRC for our review and approval prior to a decision regarding the OL. A summary of current actions is given in Enclosure 2 (Signed) William 1.Olreks William J. Dircks Executive Director for Operations I
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Enclosures:
QA Meetings on Near Term OL Plants Summary Status of QA Actions on Recent OL's cc: SECY OPE OGC l
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- Enclosure 1 PLANTS WITH OL DECISION DATE IN CY 82 (from February 1982 Bevill Report) i Commission Construction Completion Date Initial Plant Decision Date Applicant NRC QA Meeting 1.
LaSalle 1 02/82 03/82 03/82 12/29/81 C 2.
Grand Gulf 1 02/82 04/82 06/82 02/08/82 C 1
3.
San Onofre 2 03/82 02/82 C 02/82 C 11/18/82 C 4.
Sumer 1 05/82 03/82 04/82 02/22/82 C 5.
Watts Bar 1 05/82 08/82 08/83 TBD 6.
Diablo Canyon 1 05/82 03/81 03/82 Ongoing 7.
Diablo Canyon 2 05/82 07/82 12/82 Ongoing 8.
Susquehanna 1 05/82 07/82 08/82 03/01/82 C 9.
LaSalle 2 06/82 01/83 01/83 06/21/82
- 10. WNP-2 07/82 03/83 02/84 TBD
- 11. Zimer 1 07/82 12/82 01/83 06/07/82
- 12. San Onofre 3 08/82 11/82 02/83 11/18/82 C
- 13. Fenni 2 09/82 11/82 02/84 TBD
- 14. Shoreham 09/82 09/82 12/82 03/15/82 C
- 15. St. Lucie 2 10/82 10/82 10/82 04/27/82
- 16. Palo Verde 1 11/82 11/82 03/83 05/10/82
- 17. Waterford 3 11/82 01/83 01/83 05/17/82 C = Complete TBD = To Be Detennined m_.. _ _ _, _ _.
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ENCLOSURE 2
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SAN ONOFRE UNITS 2 AND 3 1
1.
Summary of Initial Review with Applicant.
l-j Initial meetings with the applicant were held on November 18 and December 3,1981. The applicant stated that they were confident l
that the design of San Onofre 2 and 3 was correctly performed because of the numerous QA audits conducted by the NSSS vendor.
i CE, the A/E, Bechtel, the applicant SCE, and the NRC. Also, the plant seismic design basis was not changed during the design process.
1 SCE stated at the December 3, 1981 meeting that General
- Atomic Company (GA) had been hired to do an independent verification of the San Onofre i
i 2 and 3 seismic design. This was described in the GA proposal and program plan submitted by SCE letter dated December 29, 1981. The l
program plan called for an interim report to be issued by GA in j
January 1982 and a final report to be issued by March 31, 1982. The interim report was transmitted to NRC by SCE letter of January 25 j
1982. The interim report concluded that the San Onofre 2 and 3 seismic design was adequate. The NRC staff reviewed the interim report and supporting documentation and concluded in Supplement No. 5 to the San Onofre 2 and 3 Safety Evaluation Report that GA was acceptably independent and technically qualified, and that the interim results of l
the program did not cause the staff to cha'nge its previous conclusions I
that the San Onofre 2 and 3 quality assurance and seismic design are j
acceptable.
I 2.
Low Power License Design Verification Prerequisites.
i The staff issued a low power license to San Onofre 2 on February 16, 1
1982 based, in part, on the successful completion of the GA report and
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the completion of the staff's favorable review of it.
3.
Full Power License Design Verification Prerequisites.
Prior to issuance of a full power license for San Onofre 2 the GA design verification program must be completed to the satisfaction of the NRC staff. The San Onofre 2 low power license issued February 16, 1982 contains a condition requiring that this be accomplished prior to j
exceeding 5 percent power.
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Certification of Conformance to Application,Regarding Design and Constrytion.
j By letter dated February 9,1982, the SCE Vice President of Nuclear i
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Engineering and Operation stated that he. concludes, and SCE senior management agree, that San Onofre Unit 2 design and ' construction are in
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accordance with the application.
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SUMMARY
OF STATUS OF DESIGN VERIFICATION ACTIONS ON SHOREHAM 1.
StM4ARY OF INITIAL REVIEW WITH APPLICANT-On March 15, 1982, The Long Island Lighting Company (LILCO) manage-ment provided a presentation to the NRC staff which described its design control program for Shoreham. The basis for this discussion was a 40 page handout prepared by LILCO.
Stone and Webster (S&W), as agent for LILCO, has overall responsibility, for the Shoreham QA - even over the MSSS (GE). The S&W Topical Report on QA (1974) used Shoreham as a model. LILC0 has an independent corporate QA Department reporting to a separate vice president than the vice president responsible for.the design and construction of i
Shoreham. LILCO's QA organization was established in 1969 and its QA manual was completed in 1970.
With respect to design control and verification, LILCO cited seven examples of its involvement in the process. LILCO also cited five examples where independent " third party" reviews and audits have been or are being performed for Shoreham.
At the conclusion of the meeting, the NRC staff requested LILCO to provide specific infomation on how the LILCO QA, design content and verification efforts to date have had measurable impact on the plant's design and construction. Mr. Pollock, Vice President of LILCO's Office of Nuclear, agreed to compile such specific information and the NRC staff plans to meet again with LILCO to discuss the specific l
"results" oriented information. This second meeting is expected to take place in late March or early April 1982.
2.
LOW POWER LICENSE DESIGN VERIFICATION PREREQUISITE 1
l To be estabitshed following additional discussions with the applicant.
3..
FULL POWER LICENSE DESIGN VERIFICATION PREREQUISITE To be established following additional discussions with the applicant.
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CERTIFICATION OF CONFORMANCE TO THE APPLICATION REGARDING DESIGN AND CONSTRUCTION At the meeting on March 15. Mr. Pollock, Vice President for Nuclear, was asked to provide, prior to licensing, a letter which documents LILCO's findings that Shoreham meets the requirements of the FSAR.
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e STATliS OF DESIGN VERIFICATION ACTIONS ON LA SALLE' COUNTY -
STATION UNITS 1 AND 2 1.
SUPMARY OF INITIAL REVIEW WITH APPLICANT i
i On December 29, 1981, NRR Senior Management met with representatives of the Commonwealth Edison Company Sargent and Lundy and the General Electric Company to discuss the design control measures /that have'been taken for the La Salle County Station.- At this meeting, the applicant.
presented its case of having a good Q/A program in place.-having direct
. involvement in the design control process, luving an experienced Engineer-ing project group, having received ASM certification for adequate design control, and having performed extensive Q/A auditing. In addition to
. these actions, Commonwealth Edison had independent reviews of its Q/A activities by an outside consultant (Energy Incorporated). Al so, for -
l critical areas, its Nuclear Safety Department conducted an independent
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design review for the la Salle County Station. At this meeting, the applicant submitted its presentation in a draft report and transmitted this report formally to us on January 4,1982.
l As a result of this formal report submittal, another meetiing was held on January 22, 1982 for the applicant to further amplify its initial 4
- presentation. At this meeting, the applicant presented and reviewed
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some of the independent reviews. We indicated that as a result of reviewing their report and its Q/A program, we concluded its quality assurance program had been acceptably implemented. However, we suggested that the applicant should provide further design verification based on a more detailed examination of a portion of the design process.
The applicant agreed to arrange for an independent review of the mechani-1 cal and structural. design of the Loop C residual beat removal system, excluding all branch piping less than 3 inches, in the functioning mode of the low pressure injection system using loads resulting from the l
actuation of the ADS in conjunction with 08E. This review is to verify that this system has been designed and constructed in accordance with the application and that the NRC requirenents have been satisfied. We specified that this review must be performed by an independent contractor hired by Commonwealth Edison and approved by the NRC staff. For the independent contractor, the applicant has contracted the Teledyne t
Engineering Services.
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2.
LOW POWER LICENSE DESIGN VERIFICATION PREREQUISITE The independent contractor must be hired,by Commonwealth Edison, l
be approved by the NRC staff, and work be initiated.
In a letter dated March 5,1982, the NRC staff has approved the applicant's contractor, Teledyne Engineering Services.
In addition Teledyne Engineering Services has initiated work to perform this independent review.
3.
FULL POWER LICENSE DESIGN VERIFICATION PREREQUISITE The independent design verification shall be completed to the ' :.'
satisfaction of NR.C staff.,
4.
CERTIFICATION OF CONFORP.ANCE TO THE-APPLICATION REGARDING DESIGN AND CONSTRUCTION In a ' letter dated January 4,1982, Mr. Cordell Reed, Vice President,
. Nuclear Operations, documented that the design and construction of La Salle County Stat' ion meets the requirements of the Final Safety Analysis Repcrt and the Safety Evaluation Report.
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SUMMARY
STATUS OF DESIGN VERIFICATION ACTIONS ON GRAND GULF 1.
SUMMARY
OF INITIAL MEETING WITH APPLICANT On February 8,1982, the applicant met with senior management personnel from NRR and Region II (Atlanta) and discussed the overall Grand Sulf Quality Assurance Program and -the key design control and verification activities. The basis for this discussion was a 60 page handout that
. had been prepared by Mississippi Power and Light. Design and construc ~
. tion quality assurance programs were performed by the architect-
- --: engineer /const'ructor'(Bechtel) Nith audits,by MP&L,-Middle South Services and NRC. No independent r,eviews we,re performed 6y the applicant.
At the conclusion of the meeting, NRC requested that MP&L propose a vehicle for providing additional assurance that they meet Appendix 3 i
Requirements. - We strongly recommended that a way of accomplishing this i
would be through.an independent contractor to verify the following design / construction activities:
1 (1) In the area of General Electric New Loads; proposed for LOCA-considerations.in March 1978, the contractor should verify the QA-QC activities of the design changes handled through the'BechteleProject Coordinator:from March 1978 to the present-1 l
(2) On a given piping system that required modification due to GE New Loads, the contractor should verify that the actual built as designed.
For Grand' Gulf, the systes system is,d for review is the Low Pressure Core Injection designate (LPCI), Loop C of RHR, as designed for 08E and :SRY loads.
l The applicant has selected Cygna Energy Services (formerly Earthquake Engineering) of San Francisco, California as an " independent" contractor to perform this study pending approval by NRC. The staff is reviewing the qualifications and independence of the selected contractor.
2.
LOW POWER LICENSE DESIGN VERIFICATION PREREQUISITE,
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Prior to fuel load and low power operation, MP&L must formally submit the contents of the meeting handout along with a listi.ng of specific QA-QC examples showing how the system was functioning. Also, we requested the details of the proposed independent design vertftcation program for review and approval. A status report of this pr.ogram should be provided by fuel load and low power Itcensing.
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3.
FULL POWER LICENSE DESIGN VERIFICATION PREREQUISITE i
The independent design verification shall be completed to the satis-faction of the NRC staff prior to a decision on a fuel load license.
4.
CERTIFICATION OF CONFORMANCE TO THE APPLICATION REGARDING DESIGN AND CONSTRUCTION At the meeting on February 8,1981, Mr. Norris Stampley, Senior Vice President-Nuclear, stated that a letter would be provided by MP&L to ~ -
.i document that the design and construction of the Grand Gulf Nuclear--
Station meets the requirements of the Final Safety Analysis Report and the Safety Evaluation Report.
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- STATUS OF DESIGN VERIFICATION ACTIONS ON j
VIRGIL C. SLAMER NUCLEAR STATION l
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1.
SUPNARY OF INITIAL REVIEW WITH APPLICANT On February 22, 1982, representatives of the Virgil C. Sumer Nuclear Station met with senior management personnel from NRR and Region II and discussed the Sumer Quality Assurance Program with emphasis on their design control and verification activities presented in their i
report, " Design / Design Interface Control Reflected in the Virgil C.
Summer Nuclear Station.".
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Some of the significant features of the Quality' Assurance program were as follows:
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(1) The QA program is written and directed by applicant's management.
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(2) QA/QC is directed by a senior management official who reports'directly to the Vice President and 4
r Group Executive for Nuclear Operations.
i (3) QA/QC functions are independent of engineering.
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cotistruction, and operations.
l (4) The Summer Station staff reviews each request for i
proposed design changes.
The applicant stated that independent reviews had been perfomed by INPO l
and the Combined Utility Assessment of the adequacy of the SCG&E QA l
program.
3 The staff believes that further assurance in design verification is needed prior to the issuance of a full power license. The staff proposed that this can be accomplished best by an independent design reviet of the seismic design of the turbine-driven portion of the emergency feedwater system including the pumps, piping and valves. Further discussions with the applicant will be scheduled to resolve this issue.
l 2.
LOW POWER LICENSE DESIGN VERIFICATION I
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To be established following additional discussions with the applicant.
l 3.
FULL POWER LICENSE DESIGN VERIFICATION PREREQUISITES l
To be established following additional discussions with the applicant.
I 4.
CERTIFICA1LON OF CONFORMANCE TO THE APPLICATION REGARDING DESIGN AND CONSTRUCTION.
SCG&E has not submitted documertation of this conformance to the l
application regarding design and construction. The staff has i
requested that the applicant provide this documentation prior to issuance of a low power license.
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4 STATUS OF DESIGN VERIFICATI0'N ACTION ON SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 4
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1.
SUMARY,0F INITIAL REVIEW WITH APPLICANT i
On March 1,1982. Pennsylvania Power & Light (PP&L) provided a presen-
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tation to the NRC staff which described their design control program.
In this presentation PP&L described their policy of requiring high 1
standards of design quality, PP&L's role in maintaining their involve-ment and control in the quality of design work, a description of the basic design control program and its special features, and their i
i methods of maintaining an effective design verification program through-out the project. PP&L has had independent reviews conducted by outside consultants on various design and quality assurance activities. These consultants included EG&G-WASC, Inc.; Teledyne Engineeri.ng Services, Inc.; EDS Nuclear; MPR Associates; Failure Analysis Association, Inc.;
and SRI International.. At this meeting, the applicant submitted the
- Independent Assessment of Jet Impinoement Targets and Safety Impact Items report conducted by NDS Nuclear, Inc. and A Quality Assessment of
'tTe Tusouehanna Steam Electric Station Advanced Control Room report 1
conducted by EG&G-WASC, Inc. The applicant has committed to formally l
submit its presentation in a report to the NRC staff.
t In discussing their future QA efforts, the applicants committed to an i
independent study review of the safety Category I piping of the feed-water system. This review is being conducted to verify that this j
system has been designed and constructed in accordance with the applica-i tion and that the NRC requirements have been satisfied. The applicant i
will provide a letter on the proposal for the independent audit including i
the selected outside consultant, subject to NRC approval.
7 The applicant provided a letter dat'ed March 16, 1982, on their proposal for the independent design review of the Feedwater System located inside 7
containment extending from the Reactor Pressure Vessel (RPV) nozzles to the containment penetration. The independent review organization chosen by PP&L for this task is Teledyne Engineering Services.
j 2.
LOW POWER LICENSE DESIGN VERIFILATION PREREQUISITES i
The independent contractor must be hired by Pennsylvania Power & Light Company, subject to NRC approval, and work be initiated. An interim report on the Independent study is required to be submitted to the NRC l
staff.
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In a PP&L letter dated March 16, 1982 PP&L identified Teledyne Engineer-ing Services as their choice for the independent contractor. An interim report is to be provided, concurrently to 1[he NRC, 8echtel Power Corpora-tion *aYd PP&L, midway through the scheduled review process and is in-l tended to reflect review completeness and preliminary results.
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3.
FULL POWER LICENSE DESIGN VERIFICATION PREREQUISITES The independent de' sign verification shall be completed to the satis-faction of the NRC staff.
A final report documenting the independent design review findings is scheduled to be provided by June 1,1982.
4.
CERTIFI' CATION OF CONFORMANCE TO THE APPLICATION REGARDING DESIGN AND CONSTRUCTION PP&L has not submitted documentation of this.conformance to the appli-
' cation regarding design and construction The applicant has committed to provide this documentation prior to issua,nce of a low power license.
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