ML20151H107
| ML20151H107 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/05/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20151H112 | List: |
| References | |
| FOIA-88-104 NUDOCS 8111300526 | |
| Download: ML20151H107 (11) | |
Text
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c> r l Ss-275 -s V November 5,1981 g_h3y A it FOR: The Comissioners % k. FROH: litiltam J. Dircks, Executive Director for Operations g-
SUBJECT:
RE-{ VALUATION OF SEISMIC DESIGN OF CONTAINMENT ANNULUS EQUIP' TENT OF DIABLO CANYON UNIT 1 AND RELATED DESIGN REVERIFICATION PROGRAM PURPOSE: To obtain Comission approval for transmittal of the attached 10 CFR 50.44(f) letter to the Pacific Gas & Electric Company DISCUSSION: In late September 1981 errors in the seisnic design of contairraent annulus equipment of Diablo Canyon Unit 1 and were detected by Pacific Gas and Electric Company (PG&E) and reported to the NRC. As a result PG&E has initiated a reanalysis effort of the seismic design of containment annulus equignent. Meetings on this matter were held with PG&E in Bethesda, Maryland, on October 9 and %venber 3, 1981. A preliminary audit of PGIE's reanalysis efforts were conducted by the staff in San Francisco on October 14 through 16, 1981. In addition, recent inspections were conducted by NRC Region Y at PGSE and its seismic consultant URS/Blum. As a result of these activities,
Contact:
Frank J. Miraglia, NRR X27243 N ON lly s l
e;" A G 2 the staff has developed a proposed design reverification program to be conducted by PG8E. The principal elements of this program were discussed with PG8E at the November 3, 1981 meeting. The attached letter provices PG&E with details of the proposed design reverification program and fomally requests PG&E to provide the infomation resulting from the conduct of this program. It should also be noted that as a result of these recent activities the Governor of California has provided the Comission his views on the matter in a letter to the Chaiman dated October 30, 1981. REC 0!EDIDATION: It is recomended that the Cocnission approve the transmittal of the attached letter to PG8E. (Signed Nias J.Dirsks William J. Dircks, Executive Director for Operations cc: SECY OPE OCC OCA j l / \\ ceries) DL: B#3 DL:L 3 /L 0 ELD D-
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.e-( Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas & Electric Company P. O. Box 7442 San Francisco, California 94106
Dear Mr. Furtush:
Subject:
10 CFR 50.54(f) Request for Statements Concerning the Re-evaluation of Seismic Design of Contaiment Annulus Equipment of Diablo Canyon Unit 1 and Related Design Reverification Program In late September 1981 errors in the seismic design of equipment in the containment annulus in the Diablo Canyon Unit 1 were detected by Pacific Gas and Electric (PGaE) and reported to the NRC. As a result PG8E has initiated a reanalysis effort of the seismic design of this equipment. To date the following errors have been detected: o Inappropriate application of a containment annulus "diagram" o Incorrect distribution within PG&E of correct seismic ) response spectra o incorrect weight and weight distribution of various equipment, components and piping at different elevations in contaiment annulus area. P At the October 9,1981 meeting betWen PGaE and the NRC in Bethesda, Maryland, on this subject, PG&E was requested to provide the NRC the following reports: (1) A technical report that discusses the re-analysis of the seismic design of the structures, systems and canponents in the containment annulus of Diablo Canyon Unit 1. This technical report would provide the basis for concluding that the proposed modifications to the design of affected equipment and components in the containment annulus would assure that the original acceptance criteria for the facility have been met.
@E - 2 (2 ) A reverification of the seismic design of all safety-related seismic design activities performed under the PG8E-URS/Blume contract as they relate to the Hosgri reanalysis. (3) A reverification of the seismic design of all safety-related structures, systens and components. A program plan for this reverification effort was to be provided for EC staff rtview at an early date. Based upon recent NRC Region V inspections conducted at PG4E and tRS/Blume Offices in San Francisco, the NRC has identified the following Quality Assurance program weaknesses related to these errors and to the perfomance of the Diablo Canyon Unit 1 facility design and the implenentation by PG&E of applicable criteria of Appendix B of 10 CFR Part 50. o the PG8E Quality Assurance Program did not appear to effectively excercise control over the review and approval of information i passed to and received from URS/Blume o the PG&E Quality Assurance Program did not appear adequately to control the distribution of design infomation within affected PG&E design groups j j o the PG8E Quality Assurance Program did not appear to define j and implement adequate Quality Assurance controls on other service j related contracts. As a result of the above and our discussions with you at our November 3,1981 meeting, on this subject, you are requested to sutnit written Statenents
t 8 4 signed under oath or affirmation, in accordance with 10 CFR 50.54(f) of the Commission's regulations, to enable the Conmission to determine t W whether or not your license should be modified, suspended or revoked. Specifically, you are requested to submit the following information to the NRC on the schedules indicated below: d (1) At least 30 days prior to the date you plan to proceed with fuel i loading and operations up to 5% power, provide the following 1 information: (a) The results of an independent and canplete design review and verification program of all safety-related activities performed under the PG&E-URS/Blume contract as they relate to the Hosgri j reanalysis. This information should address the development, accuracy, transmittal, and use of information both within PG&E and within URS/Blume, as well as the transmittal of information between PGAE and URS/Blume. (b) A technical report that fully assesses the basic cause of all errors identified and their impact upon the final design of the
- facility, i
(c) A schedule for completing any modifications to the facility that are required as a result of the design review described in (1)(a) above. For modifications that will not be completed prior to fuel load, the bases for proceeding shall be provided. (2) At least 30 days prior to the date you plan to proceed with operations above 5% power, provide the following information:
( hh)') , ( a) The results of an independent and complete design review I and verification program of all safety related structures, systems, and components that received design input infomation or data developed by PG&E service-related contractors prior to June 1,1978. This review should address all activities involved in the development, accuracy, transmittal, and use of safety-related information, both within the PG AE organization and within each contractor's organization, as well as the transmittal of information between PG&E and each contractor. Information to be provided as a result of this design review program should include the following: (1) Your review of overall quality assurance procedures used for all safety-related service contractors (pre-1978), with particular emphasis on the applicable criteria of Appendix B. of 10 CFR Part 50. Areas where weaknesses exist should be identified. Steps taken by PGAE to correct these weaknesses, if any, also should be identified. (ii) The development of a network for the design chain for the safety-related structures, systens, and components involved. This should include all interfaces you have identified where design infomation was transmitted between PGAE design groups and contractors. 4 -f
(iii) Your review of the implementation of design verification procedures used by and for: o PG4E internal design groups J o contractors o transmittal of infomation between PGSE and contractors o transmittal of infomation within PG4E design groups In addition the infomation should be sufficiently complete to enable a detemination as to whether or not the procedures confom to Appendix B quality assurance requirements and whether or not specific areas of weakness in the design process have been identified. (iv) The criteria for the selection of a sample of safety-related structures, systems and components for reverifying l the design process. The sampling criteria provided should i be based on verifying the design in the areas of identified weaknesses from the procedure review discussed in (2)(a)(1) through (iii) above. Criteria for expanding l the smple size when problems are identified should also be provided. l 5
-y .. ;, 4 (v) The development of conclusions on the effectiveness of this design verification progra, the significance of design errors found, and their impact on facility design. (vi) A schedule for completing any modifications to the facility that are required as a result of the design review program described in (2)(a) above. For modifications that will not be completed prior to operation above 51 power, the basis for proceeding shall be provided. (b) The results of an independent design smpling review and verification program of PG&E internal design activities that have been perfomed on Diablo Canyon Unit I related to the development of the design of safety related structures, system, and cmponents. The extent of the information provided related to this program should be that which is necessary to confirm that the PGAE quality assurance controls described in their QA Manual and associated procedures since ~ 1970, have been fully and effectively implemented. This design review program should include the following: ) (1) Your review of overall quality assurance procedures used in the area of design verification for safety-related structures, systems and cmponents. Material proviaed j related to your review should include areas where weaknesses may exist. A network for the design chain for the safety-related structures, systems
g c.:.q v -- . and components should be identified, including all interfaces where design infomation was transmitted between PG4E design groups. You should provide information concerning your review of the implementation of the design verification program within the various design groups, including the specific procedures for verification and transmittal of design information internal to PG&E. (ii) The criteria for the selection of a sample of safety-related structures, systems and components to verify the i implementation of QA controls on the design process. The statements to be provided concerning this sampling criteria should be based on verifying the design in the areas of identified weaknesses from j the procedure review discussed in (2)(b)(1) above. Criteria for expanding sample size should also be established as discussed in (2)(a)(iv) above. (iii) the development of conclusions on the effectiveness of the design verfication prograri, the significance of design errors found, and their impact on facility design. (iv) Statements to be provided should include your schedule for ccnpleting any modifications to the facility that are required as a result of the design review described in (2)(b) above. For modifications not to be completed before operation above 5% power, the bases for proceeding shall be provided.
p:,( opC', c .o~ .g. ) i (c) You also should submit infomation concerning the the results of an independent design sapling review and verification of all PG4E service related contractor work that was completed subsequent to January 1,1978 and that has been or will be used as input into the the design of safety related structures, systems, and components. The extent of this infomation should be that which is necessary to confim that the contractor and PG&E quality assurance controls l and procedures that were in effect during this time period were fully and effectively implemented. Statements concerning this design review program should address all interface activities associated with the work, both internal to the contractor and within PG&E. The statements should also include the items discussed in (2)(b)(1) through (iii) above, and a schedule for ccupleting any modifications to the facility that are required as a result of the design review program described in (2)(c) above. For modifications that will not be completed prior to operation above 5% powr, the bases for proceeding shall be provided. I ] (3 ) At least 60 days prior to the date you plan to proceed with operations ] above 5% pwer provide: j (a) Infomation concerning a detailed program plan for conducting the design reverification review progras discussed in (2)(a) through (c) above. This plan should provide the bases for the service-related contracts and safety-related structures, systes and components selected for review, the selection of smpling plans to be used, and the criteria for modifying saple sizes. _ - - _ ~
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9 (b) A description of the qualifications of the personnel and contractors who are to perform the independent design reviews discussed in (2)(a) through (c) above. (4) Starting on Friday November 13, 1981, a seei-monthly status report on the second and fourth Friday of each month, on the ongoing reanalysis and reverification efforts being conducted by PG4E. In the interest of efficient evaluation of your submittals, we request that you submit, as soon as practicable, a response to the request for additional information that was enclosed in the Staff's Meeting Summary dated October 19, 1981. of the October 14-16, Meetings with PG8E. Si ncerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation d l 1 i 4
m .. n ,mr .o ( y I NOV 5 1981 i FOR: The Conriissioners FROM: William J. Dircks, Executive Director for Operations
SUBJECT:
RE-EVAL.UATION OF SEISMIC DESIGN OF CONTAINMENT ANNULUS EQUIPMENT OF DIABLO CANYON UNIT 1 AND RELATED DESIGN REVERIFICATION PROGRAM PURPOSE: To obtain Comission approval for transmittal of the attached 10 CFR 50.44(f) letter to the Pacific Gas & Electric Company DISCUSSION: In late September 1981 errors in the seismic design of containment annulus equipment of Diablo Canyon Unit 1 i and were detected by Pacific Gas and Electric Company (PG8E) and reported to the NRC. As a result PG4E has initiated a reanalysis effort of the seismic design of containment annulus equipment. Meetings on this matter were held with PG&E in Bethesda, Maryland, on October 9 and November 3, 1981. A preliminary audit of PG&E's reanalysis efforts were conducted by the staff in San Francisco on October l 14 through 16, 1981. In addition, recent inspections were conducted by NRC Region Y at PG&E and its seismic i consultant URS/Blume. As a result of these activities,
Contact:
Frank J. Miraglia, NRR X27243 l " N I B ooST~ d ~ w
f >,f, I 4 i 2-the staff has developed a proposed design reverification program to be conducted by PGAE. The principal elements of this program were discussed with PG&E at the hvember 3,1981 meeting. The attached letter provides PG&E with details of the proposed design reverification program and fomally requests PG&E to provide the infomation resulting from the conduct of this program. It should also be noted that as a result of these recent activities the Governor of California has provided the Comission his views on the matter in a letter to the Chaiman dated October 30, 1981. RECOMENDATION: It is recomended that the Comission approve the transmittal of the attached letter to PG AE. William J. Dircks, Executive Director for Operations cc: SECY OPE OGC OCA l l i l l 1
.c) m N. Malcolm H. Furbush Vice President - General Counsel Pacific Gas & Electric Company P. O. Box 7442 S.an Francisco, California 94106 Deer Mr. Furbush: Sej ect: 10 CFR 50.54(f) Request for Statements Concerning the Re-evaluation of Seismic Design of Contaiment Annulus Equipment of Diablo Canyon Unit 1 and Related Design Reverification Program In late September 1981 errors in the seismic design of equipment in the containment annulus in the Diablo Canyon Unit 1 were detected by Pacific Gas and Electric (FG8E) and reported to the NRC. As a result i PG8E has initiated a reanalysis effort of the seismic design of this equipment. To date the following errors have been detected: o Inappropriate application of a containment annulus "diagram" o incorrect distribution within PG8E of correct seismic response spectra o incorrect weight and weight distribution of various equipment. caponents and piping at different elevations in contaiment annulus area. At the October. 9,1981 meeting between PG AE and the NRC in Bethesda, j Maryland, on this subject, PG&E was requested to provide the NRC the following reports: (1) A technical report that discusses the re-analysis of the seismic design of the structures, systes and cmponents in the 1 containment annulus of Diablo Canyon Unit 1. This technical report would provide the basis for concluding that the proposed 4 modifications to the design of affected equipment and components in the contairnent annulus would assure that the original acceptance criteria for the facility have been met.
( 7< i i 2 (2 ) A reverification of the seismic design of all safety-related seismic design activities perfomed under the PGAE-URS/Blume contract as they relate to the Hosgri reanalysis. (3) A reverification of the seismic design of all safety-related structures, systems and components. A program plan for this t reverification effort was to be provided for MtC staff review at an early date. i f Based upon recent NRC Region V inspections conducted at PGAE and tRS/Blume Offices in San Francisco, the NRC has identified the following Quality Assurance program weaknesses related to these errors and to the perfomance of the Diablo Canyon Unit 1 facility design and the implementation by PGAE ~ of applicable criteria of Appendix B of 10 CFR Part 50. i i l I o the PGAE Quality Assurance Program did not appear to effectively excercise control over the review and approval of information passed to and received from URS/Blume o the PG&E Quality Assurance Program did not appear adequately l to control the distribution of design infomation within affected l i PGAE design groups e i i o the PG AE Quality Assurance Program did not appear to define and implement adequate Quality Assurance controls on other service related contracts. 1 As a result of the above and our discussions with you at our hvember 3,1981 3 l meeting, on this subject, you are requested to submit written statements i
^ I.,, D m. 3-signed under oath or affimation, in accordance with 10 CFR 50.54(f) of the Comission's regulations, to enable the Comission to determine whether or not your license should be modified, suspended or revoked. Specifically, you are requested to sthmit the following information to the NRC on the schedules,,,1cated below: (1) At least 30 days prior to the date you plan to proceed with fuel loading and operations up to St power, provide the following infomation: (a) The results of an independent and complete design review and verification program of all safety-related activities perfomed under the PG&E-URS/Blume contract as they relate to the Hosgri reanalysis. This infomation should address the development, accuracy, transmittal, and use of infomation both ] within PG&E and within URS/B1tane, as well as the transmittal of infomation between PG&E and tRS/Blume. (b)' A technical report that fully assesses the basic cause of all errors identified and their impact upon the final design of the facility. \\ n l (c) A schedule for completing any modifications to the facility that are required as a result of the design review described in (1)(a) above. For modifications that will not be completed prior to fuel load, the bases for proceeding shall be provided. j l (2) At least 30 days prior to the date you plan to proceed with operations above St power, provide the following infomation: l I
.. ~, I r 4 (a) The results of an independent and complete design review and verification program of all safety related structures, systems, and components that received design input information or data developed by PGAE service-related contractors prior to June 1,1978. This review should address all activities involved in the development, accuracy, transmittal, and use of safety-related infomation, both within the PG8E organization and within each contractor's organization, as well as the transmittal of infomation between PGAE and each contractor. Infomation to be provided as a result of this design review program should include the following: .l (1) Your review of overall quality assurance procedures used for all safety-related service contractors (p-e-1978), with particular emphasis on the applicable criteria of Appendix B. of 10 CFR Part 50. Areas where weaknesses exist should be identified. Steps taken by PGAE to correct these weaknesses, if any, also should be identified. (ii) The development of a network for the design chain for the safety-related structures, systens, and components involved. This should include all interfaces you have identified where design infomation was transmitted between PG8E design groups and contractors.
-q y,, i 5-L 1 (iii) Your review of the implementation of design verification procedures used by and for: j o PG AE internal design groups o contractors o transmittal of information between PGAE and contractors o transmittal of information within PG4E design groups In addition the infonnation should be sufficiently complete to enable a detennination as to whether or not the procedures conform to Appendix B quality assurance requirements and whether or 4 not specific areas of weakness in the design process have been identified. (iv) The criteria for the selection of a sample of safety-related l structures, systens and ccnponents for reverifying I the design process. The sampling criteria provided should be based on verifying the design in the areas of identified weaknesses from the procedure review discussed i in (2)(a)(1) through (iii) above. Criteria for expanding the sample size when problems are identified should also be provided. i 1 l ) l i i - -.. ~... -
7 6-l (v) The development of conclusions on the effectiveness of this design verification program, the significance l of design errors found, and their impact on facility design. i (vi) A schedule for completing any modifications to the facility that are required as a result of the design review program f described in (2)(a) above. For nodifications that 1 ] will not be completed prior to operation above 51 powr, the basis for proceeding shall be provided. (b) The results of an independent design smpling review and verification program of PG&E internal design activities [ l that have been performed on Diablo Canyon Unit 1 related l to the development of the design of safety related structures, i syste, and components. The extent of the information provided related to this program should be that which is necessary f to confirm that the PG&E quality assurance controls described in their QA Manual and associated procedures since 1970, have been fully and effectively implemented. i This design review program should include the following: (1) Your review of overall quality assurance procedures used in the area of design verification for safety-related structures, systerss and components. Material provided related to your review should include areas where weaknesses may exist. A network for the design l chain for the safety-related structures, systems .J .-n ,v. -,---r--------.-.,y.. nn ,-----,e-.
A ^ 1 and components should be identified, including all interfaces where design information was transmitted between PG AE design groups. You should provide infomation concerning your review of the ispimentation of the design verification progrm within the various design groups, including the specific procedures for verification and transmittal of design infomation internal to PG4E. (11) The criteria for the selection of a sample of safety-related structures, systems and components to verify the implementation of QA controls on the design process. The statements to be provided concerning this l sampling criteria should be based on verifying the design in the areas of identified weaknesses from the procedure review discussed in (2)(b)(1) above. Criteria for expanding smple size should also be established as discussed in (2)(a)(iv) above. (iii) the development of conclusions on the effectiveness of the design verfication program, the significance of design errors found, and their impact on facility design. (iv) Statements to be provided should include your schedule for completing any modifications to the facility that are required as a result of the design review described in (2)(b) above. For modifications not to be completed before operation above 55 power, the bases for proceeding shall be provided.
O _a. (c) You also should submit infomation concerning the the results of an independent design sampling review and verification of all PG4E service related contractor work that was completed subsequent to January 1,1978 and that has been or will be used as input into the the design of safety related structures, systems, and components. The extent of this information should be that which is necessary to confirm that the contractor and PG8E quality assurance controls and procedures that were in effect during this time period were fully and effectively implemented. Statements concerning this design review program should address all interface activities associated with the Urk, both internal to the contractor and within PG&E. The statements should also include the } items discussed in (.2)(b)(1) through (iii) above, aiid a schedule for completing any modifications to the facility that are required as a result of the design review program described in (2)(c) above. For modifications that will not be ccinpleted prior to operation above 5% power, the bases for proceeding shall be provided. (3 ) At least 60 days prior to the date you plan to proceed with operations above 55 power provide: (a) Information concerning a detailed program plan for conduct.ing the design reverification review programs discussed in (2)(a) through (c) above. This plan should provide the bases for the service-related contracts and safety-related structures, systems and components selected for review, the selection of sampling plans to be used, and the criteria for modifying sanple sizes. _. _ - ~ _._ _
4 ,.r-9 (b) A description of the qualifications of the personnel and contractors who are to perform the Independent design reviews discussed in (2)(a) through (c) above. (4) Starting on Friday November 13, 1981, a seni-monthly status report on the second and fourth Friday of each month, on the ongoing reanalysis and reverification efforts being conducted by PG8E. In the interest of efficient evaluation of your submittals, we request that you submit, as soon as practicable, a response to the request for additional information that was enclosed in the Staff's Meeting Summary dated October 19, 1981. of the October 14-16, Meetings with PG8E. Si ncerely, I Harold R. Denton, Director Office of Nuclear Reactor Regulation - -,}}