ML20151H121
| ML20151H121 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/13/1981 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20151H112 | List: |
| References | |
| FOIA-88-104 NUDOCS 8112030084 | |
| Download: ML20151H121 (19) | |
Text
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b UNITEDSTATES
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a WASH:NOTON. O. C. 20HE g
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ttovember 14, 1981 MEMORANDUM FOR: William J. Dircks, Executive Director for Operations FROM:
Harold R. Denton, Director, Office of Nucler Reactor Regulation
SUBJECT:
TRANSMITTAL OF COMISSION PAPER REGARDING THE RECENT DIABLO CANYON SEISMIC ISSUES As requested by the Comission enclosed is a 10 CFR 50.54(f) letter to Pacific Gas and Electric Company.
It has been revised to reflect discussions of the November 9,1981 Commission Meeting.
It is our understanding that the Comission will consider this letter in a meeting scheuled for 1
November 16, 1981.
i Harold R. Denton, Director Office of Nuclear Reactor Regulation i
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1 FOR:
The Commissioners FROM:
William J. Dircks, Executive Director for Operations SUBJ ECT:
DIABUD CANYON UNIT 1 SEISMIC DESIGN ISSUES PURPOSE:
To obtain Commission approval for transmittal of the ' attached 10 CFR 50.54(f) letter to the Pacific Gas & Electric Company DISCUSSION:
In SECY-81-636, the staff forwarded a draft 50.54(f) letter to Pacific Gas & Electric Company (PG&E). The Connission was briefed on this matter on November 9,1981.
Based upon discussions during that meeting, the draft 50.54(f) letter to PG&E was revised.
REC 0t4'4ENDATION: It is recommended that the Commission approve the transmittal of the attached letter to PG&E.
William J. Dircks, Executive Director for Operations Enclosure cc:
SECY OPE DGC OCA '
Contact:
Frank J. Miraglia, NP,R X27283
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Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas & Electric Company P. O. Box 7442 San Francisco, California 94120
Dear Mr. Furbush:
In late September 1981 an error in the seismic design of equipment and piping in the containnent annulus of Diablo Canyon Unit 1 was detected by Pacific Gas and Electric (PG&E) and reported to the NRC.
PG&E initiated a reanalysis of portions of the seismic design of the facility. As a' result a number of different additional errors have been found.
At an October 9,1981 l
meeting between PG&E and the NRC staff, we requested that PG&E complete l
the following activities aad submit the documenting reports to the NRC:
(1) A technical report that discusses the reanalyses conducted of the seismic design of the structures, systems and components in the containment annulus of Diablo Canysn Unit 1 and any modifications resulting from the reanalysis.
(2) A verification of all safety-related seismic design activities performed under the PG&E/Blune contract as they relate to the Hosgri reanalysis.
(3) A verification of the seismic design of all safety-related structures, systems, and components. A program plan for this effort was to be provided for NRC staff review.
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M.'H. Furbush '
Based upon recent NRC inspections conducted at PG&E and the Blume Offices in San Francisco, the NRC has identified a number of Quality Assurance (QA) program weaknesses related both to these errors in the Unit 1 seismic design, and to the implementation by PG&E of applicable criteria of Appendix B l
of 10 CFR Part 50. We have preliminarily concluded that:
a.
the PG&E QA program did not appear to effectively exercise control over the review and approval of design infomation passed to and received from Blume, b.
the PG&E QA Program did not appear to adequately control the distribution of design infomation from Blume within affected internal PG&E design groups, and c.
The PG&E QA Program did not appear to define and implement adequate quality assurance procedures and controls over other service-related contracts.
1 A follow-up meeting was held on November 3,1981 between PG&E and the NRC staff to furth'er discuss these seismic design errors and related quality assurance program deficiencies.
Based on these discussions and our review to date, we have detemined there is a need for additional infomation to be provided by PG&E to the NRC. Accordingly, you are requested in accordance with 10 CFR 50.54(f), to submit written statements signed under oath or affirmation concerning these matters to enable the Cornission to determine wtiether 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:
1 I
M. N. Furbush l 1.
At least 45 days prior to the date you plan to proceed with fuel loading, provide the following information:
For All Seismic Service-Related Contracts Prior to June 1978 (a) The results of an independent design verification program of all safet;y-related activities performed prlor to June 1, 1978 under all seismic-related service contracts utilized in the design process for safety-related structures, systems and components.
Information concerning this program should address quality i
assurance procedures, controls and practices concerning the development, accuracy, transmittal, and use of all safety-related information both within PG&E and within each contractor's organization, as well as the transmittal of information between PG&E and each contractor. It should also include perfonnance of a suitable number of sample calculations related to each contract to verify the adequacy and accuracy of the design process for affected safety-related structures, systems and components. The information to be provided concerning this design verification program should be based on and include the results of conducting the program elements set forth in Enclosure A.
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M.' H. Furbush 4-(b) A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of design errors found, and their impact on facility design.
(c) PG&E's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility design.
( d) A schedule for completing any modifications to the facility that are required as a result of this program. For modifica-tions that you propose not completing prior to fue~l load, the bases for proceeding should be provided.
2.
At least 45 days prior to the date you plan to proceed with operations above 5% power, provide the following information:
(a) For All Other Service - Related Contracts Prior to June 1978 (1) The results of an independent design verification program of all safety-related activities performed prior to June 1,1978 under all non-seismic service contracts utilized in the design process for safety-related structures, systems and canponents.
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M. H. Furbush Information concerning this program should address quality assurance procedures, controls and practices concerning the development, accuracy, transmittal, and use of all safety-related information both within PGAE and within each contractor's organization, as well as the trans-mittal of information between PG&E and each contractor.
It should also include performance of a suitable number j
of sample calculations related tb each contract to verify the adequacy and accuracy of the design process for affected safety-related structures, systems and components.
The information to be provided concerning this design 1
verification program should be based on and include the results of conducting the program elements set fort'h in Enclosure A.
(2) A technical report that fully assesses the basic cause of all design errors identffied by this program, the significance of design errors found, the their impact on facility design.
(3)
PG&E's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility design.
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(4 ) A schedule for completing any modifications to the facility that are required as a result of this program.
For modifications that you propose not completing prior to operations above 5% power, the bases for proceeding should be provided.
( b) For PG&E Internal Design Activities (1) The results of an independent design verification i
program of PG&E internal design activities performed on Diablo Canyon Unit 1 related to the develcpment
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of the design of a suitable suple of safety-related structures, systems or components.
The extent of the infomation provided related to this program should be that which is necessary to determine whether the overall PG&E quality assuranca procedures and controls described in its QA Manual and associated procedures since 1970, have been fully and effectively impl emented. This information should also include a suitable number of sample calculations to verify the adequacy and accuracy of the PG&E internal l
design activities for the smple of safety-related structures, systems, or components.
The information i
to be provided concerning this design verification program should be based on and include the results of conducting the program elements set forth in Enclosure B.
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S H. Furbush (2 ) A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of design errors found, and their impact on facility design.
(3) PG8E's conclusions on the effectiveness of this 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 this program. For modifications that you propose not-completing prior to operations above 5% power, the bases for proceeding should be provided.
( c) For All Service-Related Contracts Post-January 1,1978 (1) The results of an indepen, dent design verification program of a suitable sample of the activities performed on Diablo Canyon Unit 1 by each service-related contractor that were completed subsequent to January 1,1978 related to the development of the design of safety-related structures, systems and components. The extent of the infoniation provided related to this program should be that which is necessary to determine whether the overall contractor y
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. M. H. Furbush
- and PG&E quality assurance procedures and controls that were in effect during this time period were fully and effectively implemented. This information should also include a suitable number of sample calculations to verify the adequacy and accuracy of the sample contractor and PG&E design activities for safety-related structures, systems and components.
The information to be provided concerning this i
design verification program should be based on and include the results of conoucting the program
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i elements set forth in Enclosure C.
(2) A technical report that fully assesses the basic 1
cause of all design errors identified by this program, the significance of design errors found, and their impact on facility design.
(3)
PG&E's conclusions on the effectiveness of this design verification program in assuring that the adequacy of facility design.
(4) A schedule for completing any modifications to the facility that are required as a' result of this
,. program.
For modifications that you propose not completing prior to operations above 55 power, the I
bases for proceeding should be provided.
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'H. H. Furbush '
3.
Within 30 days of the date of this letter, provide the following information for NRC review and approval:
Qualifications of Companies Proposed To Conduct Independent Reviews A description and discussion of the corporate qualifications of the companies that PG&E would propose to carry out the various independent design verification programs discussed in 1 and 2 above, including information that demonstrates the independence of these companies.
4.
Within 20 days of the dates of NRC approval of the companies to conduct the various independent design verification programs, provide the following information for NRC review and approval:
Program Plan For the Design Verification Programs A detailed program plan for conducting the various design verification programs discussed in 1 and 2 above.
The information provided should include the bases for the criteria proposed to be used for selection of a suitable number and type of sample calculations to be performed under these programs and the bases for the criteria proposed to be used for expanding the sample size based upon the results of the initial samples.
In addition, the criteria for selecting the sample safety related structures, systems and components and sample contractor activities in the design verification programs under 2(b) and 2(c) above should be provided.
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5p M. H. Furbush 5.
Status Reports Starting on Friday, November 27, 1981, a semi-monthly status report on the.second and fourth Friday of each month, on the s
ongoing reanalyses efforts and design verification programs
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being conducted by and for PG&E, should be submitted to the Regional Administrator, Region V and the Director, Office of Nuclear Reactor Regulation.
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 Sumary dated October 19, i
1981, on the October 14-16 meetings with PGAE.
Si ncerel y, i
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
As stated n..,-
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ENCLOSURE A Elements Which Should be Included in the Design Verification _
Program of Service Related Contracts Prior to June,1978 1.
A review of all quality assurance procedures and controls used by each pre-June 1978 service contractor and by PGaE with regard to that contract; a comparison of these procedures and controls with the related criteria of Appendix B to 10 CFR 50; and an identification of any deficiencies or weaknesses in the quality assurance procedures and in controls of
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the contractor and PG&E.
2.
Development of a network for the design chain for all safety-related structures, systems, and components involved. This should include all interfaces where design information was transmitted between PG&E internal design groups and each contractor.
3.
A review of the implementation of quality assurance procedures and controls used by and for:
o PG&E internal design groups o each contractor internal design group (s) o transmittal of information between PG&E and each contractor o transmittal of contractor developed information within PG&E and identification of any deficiencies or weaknesses in the implementation of quality assurance procedures and controls by each contractor and by PG&E.
4.
Development of criteria for the conduct of this design verification program should consider the guidelines contained in ANSI N45.2.11, Section 6.3.1.
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Enclosure A (cont'd) 2-5.
Development of criteria for selection of a suitable number and type of sample calculations related to the design of safety related structures, systems and components involved. The purpose of these sanple calculatio,ns should be to verify the design process, particularly in the areas of any identified contractor or PG&E quality assurance weaknesses or deficiencies as determined from the procedure and implenentation reviews discussed in steps 1 through 3 above.
Criteria for expanding the sanple size when problems in verification are encountered should also be developed.
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ENCLOSURE B Elements Which Should be Included in the Design Yerification Program of PG5E Internal Design Activities e
1.
A review of all quality assurance procedures and controls used by internal PG&E design groups by selecting for detailed examination certain safety related structures, systems or components as representative sanples of the overall facility design. A comparison of the PGAE procedures and controls used for the sample structures, systems or compon'ents with the related criteria of Appendix B to 10 CFR 50; and an identification of any deficiencies or weaknesses in these PG&E quality assurance procedures and controls.
4 2.
Development of a network for the design chains for the sample structures, systems or ccuponents involved. This should include all interfaces where design infomation was transmitted between internal PG8E design groups.
3.
A review of the implementation of quality assurance procedures a4 controls used in the design of the sample structure, systems or components by internal PG&E design groups, and an identification of deficiencies or weaknesses in the implementation of quality assurance procedures and controls by internal PG&E design groups.
4.
Development of criteria for the conduct of this design verification program should consider the guidelines contained in ANSI W45.2.11, Section 6.3.1.
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E5 closure B (cont' d) 4 5.
Development of criteria for selection of a suitable number and type of sample calculations related to the design of the sample structures, systems or components involved. The purpose of these sample calculations should be to verify the design process, particularly in the areas of any identified PG&E quality assurance weaknesses or deficiencies as determined from the procedure and implementation reviews discussed in steps 1 through 3 above. Criteria for expanding the sample size when problems in verification are encountered should also be developed.
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EWCLOSURE C Elements Which Should be Included in the Design Verification i
Program of.5ervice-Relate'd Contracts Af ter January 1,1978 1.
A review of quality assurance procedures and controls used by each post January 1,1978 contractor and by PG&E with regard to that contractor by selecting for detailed examination certain activities of the contractor as representative samples of the entire activities carried out; a comparison of the procedures and controls used by the contractor and PG&E for the sample activities with the related criteria of Appendix B to 10 CFR Part 50; and an identification of any deficiencies or weaknesses in the quality assurance controls of the contractor and PG&E 2.
Development of a network for the design chain for the structures, systems or components involved with the sample activities. This should include all interfaces where design information was transmitted between PG&E internal design groups a'nd each contractor.
3.
A review of the implementation of quality assurance procedures and controls used in the conduct of the sample' activities by and for:
o PG&E internal design groups o each contractor internal design group (s) o transmittal of information between PG&E and each contractor o transmittal of contractor developed information within PG&E and an identification of any deficiencies or weaknesses in the
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implementation of quality assurance procedures and controls by each contractor and by PG&E w
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<3 Enclosure C (cont'd) 2-4.
Development of criteria for the conduct of this. design verification program should consider the guidelines contained in ANSI N45.2.11, Section 6.3.1.
S.
Development of criteria for selection of a suitable number and type of. l sample calculations related to the sample activities involved. The purpose of these sample calculations should be to verify the design process, particularly in the areas of any identified contractor or PG&E quality assurance weaknesses or deficiencies as detennined from the procedure and impleraentation reviews discussed in steps 1 through 3 above. Criterfa for expanding the sample size when problems in verification are encountered should also be developed.
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November 13, 1981 1
l NEll0RANDull FOR: William J. Dircks, Executive Director for Operations FRON:
Harold R. Denton, Director, Office of Nucler Reactor Regulation
SUBJECT:
TRANSMITTAL OF COM41SS10N PAPEh REGARDlHG THE RECENT DIABLO CAhYOH SEISti!C ISSUES As requesteo by the Cor.snission enclosed is a 10 CFR 50.54(f) letter to Pacific Gas and Electric Company.
It has been revised to reflect discussions of the November 9,1981 Cormiission Meeting.
It is our understanding that the Comission will consider this letter in a neeting scheuled for November lo, 1981.
%ndMN,
.wnJ Harold R. Denton, Director Office of Nuclear Reactor Regulation i
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