ML20151H124

Draft Commission Paper Re Transmittal of Encl Ltr to PG&E Re Required Design Verification Programs

ML20151H124
Person / Time
Site:	Diablo Canyon
Issue date:	11/19/1981
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20151H112	List: IA-88-104, Final Response to FOIA Request for Documents Re SECY-81-636. Forwards App B Documents Subj to Categories A-E & G of Request.Documents Also Available in PDR ML20151H107 ML20151H117 ML20151H121 ML20151H124 ML20151H128 ML20151H132 ML20153C868
References
FOIA-88-104 NUDOCS 8112090233
Download: ML20151H124 (15)

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Q FROM: William J. Otreks Executive Director for Operations 4/fT SURJECT:

0!A81.0 CANYON t/MIT 1 DESIGN VERIFICATION PROGRAMS PURPOSE: To obtain Coastssion approval for transmittal of the attached letter to the Pacific Gas and Electric Company concerning required design vertfication programs.

DISCUSSION:

ln SECY.81-636*and SECY 81-636A the staff forwarded draft 50.54(f) letters to Pacific Gas and Electric 4

Company for Coesntssion consideration. The Comission us briefed on these matters on November 9.16'and

18. 1981. The draft letter has been revised to reflect the discussions of the flovember 18 Comission Meeting and is believed to be completely consistent with the Order being prepared by OGC.

RECOMMENDATION: It is recomedded that the Comission approve transmittal of the letter to PG&E.

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.[n/ William J. Dircks V Executiva Of rector for Operations

Enclosure:

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NUCLEAR REGULATORY COMMIS$10N i; s  ! -

wAsumotow.o.c. nous s November 19, 1981 Docket No. 50-275 1, , .

Mr. Malcolm H. Furbush .

Vice President - General Counsel Pacific Gas & Electric Company P. O. Box 7442 San Francisco, California 94120

SUBJECT:

O!ABLO CANYOW UNIT 1 - INDEPENDENT DESIGN,YERIFICATION PROGR/MS The Commission's Memorandum and Order (CLI-81-30) dated Hovember 19, 1981 (suspends your license to load fuel and operate Diablo Canyon Unit 1 at power levels up to 55 of full power, and specifies the programs that must be satisfactorily completed before license suspension will be lifted.)

(requires PG&E to show cause why its license to operate Diablo Canyon Unit 1 should not be suspended, suspends the authority to load fuel, and specifies the programs that must be satisfactorily completed before the suspension will be lif ted.)

Also, based upon recent WRC inspections conducted at PG&E and the Blume Offices in San Francisco, the NRC staff has identified a number of serious Quality Assurance (QA) program weaknesses related both to the errors in the Unit 1 seismic design and to the implementation by PG8E of applicable I criteria of Appendix B of 10 CFR Part 50. We have preliminarily concluded l that: ,

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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 information from Blume within affected internal PG8E 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 particularly in the pre-June 1978 time period.

Accordingly, you are required to provide the following additional infoms-tion, under oath or affimation, for NRC review and consideration prior to issuance of any operating license authorizing operation of Diablo Canyon Unit 1 abote Si power:

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'i l k 1. For All Won-Seismic Service - Related Contracts Prior to June 1978 4

(a) The results of an independent design verification program of all safety-related activities performed priorto -

t, June 1,1978 under all non-seismic service contracts

- utilized in the design process for safety-related structures, systems and components.

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- Information concerning this program should address quality assurance procedures, controls and practices concerning

- the development, accuracy, transmittal, and use of all safety-related infomation 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 performance 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 stru:tures, systems and components. The infomation to be ,

provided concerning this design verification program should i be based on and include the results of conducting the. program elements set forth in Enclosure A. .

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(b) A technical report that fully assesses the basic cause of all design errors identified by this program, the significance i of design errors found, their impact on facility design. l l

. (c) PG&E's conclusions on the effectiveness of this design i verification program in assuring the adequacy of facility I design.

(d) A schedule for completing any modifications to the facility l that are required as a result of this program. For modifications that you propose not cocpleting prior to i

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operations above 57, power, the bases for proceeding should l

,be provided. )

2. For PG5E Internal Design Activities (a) The results of an independent design verification program of PG5E internal design activities perforced on Diablo Canyon Unit i r, elated to the development of the design of a suitable sample of safety-related structures, systems or cocponents.

The extent of the information provided related to this program should be that which is necessary to detemine whether the overall PG&E quality assurance procedures and controls ,de-scribed in its QA Manual and associated procedures since 1970, have been fully and effectively impiecented. This infomation should also include a suitable nu ber of sample calculations to verify the adequacy and accuracy of the PG&E internal design activities for the sample of safety-related structures, systems, or components. The infomation to be provided con- l cerning this design verification program should be based on l and include the results of conducting the program elements '

set forth in Enclosure B.

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T (b) A technical report that fully assesses the basic cause s of all design errors identified by this program, the t significance of desi p on facility design. gn errors found, and their impact

$ (c) PG&E's conclusions on the effectiveness of this design ,

s. verification program in assuring the adequacy of facility i design.

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(d) A schedule for completing any modifications to the 7 facility that are required as a result of this program.

3 For modifications that you propose not completing prior i i to operations above 55 power, the bases for proceeding should be provided. ,

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! 3. For All Service-Related Contracts Post-January 1,1978 '

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(6) The results of an independent design verification program )

of a suitable sample of the activities performed on J Diablo Canyon Unit 1 by each service-related contract 0r ,

that were ccepleted subsequent to January 1,1978 related to the development of the design of safety-related structures, systems and components. The extent of the information provided related to this program should be that which is necessary to determine whether the overall

', contractor 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 a to verify the adequ'acy and accuracy of the sample contractor and PG&E design activities for safety-related structures, i

systems and components. The inforniation to be provided concerning this design verification program should be based j on and include the results of conducting the program I

. elements set forth in Enclosure C. ]

i (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 vertftcation 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 modifications that you propose not completing prior to operations above 5% power, the bases for proceeding should be provided.

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I In addition to the abdve, we require that you provide the following in-formation for NRC staff review and approval as soon as practicable. -

4. Qualifications of Companies Proposed to Conduct Independent Reviews A description and discussion of the corporate qualifications of the company or companies that PG&E would propose to carry out the l various independent design verification programs discussed in 1 l through 3 above, including infomation that demonstrates the l independence of these companies. .

I NRC will make its decision on these proposed companies after providing )

the Governor of California and Joint Intervenors in the pending operating iteense proceeding 15 days for comment.

I1 As soon as practicable following NRC approval of the company or companies )l to conduct the various independent design verification programs, you should also provide the following information for NRC staff review and approval. >

5. Program Plan For the Design Verification Programs A detailed program plan for conducting the various design verification programs discussed in 1 through 3 above. The infomation provided should include the bases for the criteria -

proposed to be used for selection of a suitable number and type of sample cale'ulations to be perfomed under these pro-grams 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 pro-grams under 2 and 3 above should be provided.

l HRC will make its decision on the acceptability of the program plan af ter

. providing the Governor of California and Joint Intenvenors in the pending operating license proceeding 15 days for comment, i To keep the NRC currently informed regarding your progress on the items discussed in 1 through 3 above, you are required to provide semi-monthly status reports on the ongoing reanalysis efforts and design verification I'i I

programs being conducted by and for PG&E. These status reports should be submitted on the second and fourth Friday of each month to the Regional Administrator, Region V and the Director, Office of Nuclear Reactor. .

Regulation. Should these reports or any other infomation that becomes i available to the WRC indicate that the NRC requirements described in . .

this letter should be expanded or supplemented, PGlE will be promptly l

i nformed.

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In the interest of efficient evaluation of your subetttals, we request that you submit as soon as practicable a response to the request for additional infonnation that was enclosed in the Staff's Meeting Sumary dated October 19, 1981, on the October 14-16 meetings with PGAE. ,

Sincerely.

Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

As stated cc: See Next Page I

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DIABLO CANYON i

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Hr. Halcolta H. Furbush .

Vice President - General Counsel i

Pacific Gas & Electric Ccnpany -

P.O. Box 7442 San Francisco, California 94120 cc: Philip A. Crane, Jr., Esq.

• Pacific Gas & Electric Company P.O. Box 7442 San Francisco, California 94120 Janice E. Kerr, Esq. .

California Public Utilities Coenission 350 M:Allister Street San Francisco, California 94102 ,

Itr. Frederick Eissler, President Scenic Shoreline Preservation Conference, Inc.

4623 More Mesa Drive Santa Barbara, California 93105 Ms. Elizabeth Apfelberg 1415 Cotadero San Luis Obispo, California 93401 lir. Gordon A. Silver Ms. Sandra A. Stiver 1760 Alisal Street

, San Luis Obispo, California 93401 Harry M. Willis, Esq.

Sep our & Willis 601 California Street, Suite 2100 San Francisco; California 54108 Mr. Richard Hubbard

!!HS Techritcal Associates Suite X i 1723 Hamilton Avenue l San Jose, California 95125 lir. John ttirrs, Managing Editor i San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P. O. Box 112 San Luis Obispo, California 93406 ,

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Mr. Halcolm H. Furbush 1 cc: Resident Inspector /Diablo Canyon NPS c/o U. S. Nuclear Regulatory Cornission ..

P. O. Box 369 ' ,

l Avila' Beach, California 93424 .

l Ms. Raye Fleraing I

1920 Mattie Road . -

l Shell Beach, California 93440 , ,

Joel Reynolds, Esq.

John R. Phillips, Esq. ,

Center for Law in the Public. Interest 10951 West Pico Boulevard '

Third Floor .

I Los Angeles, California 90064 )

Paul C. Valentine, Esq'. - '

321 Lytton Avenue 1 Palo Alto, California 94302  ?

Mr. Byron S. Georgiev Legal Affairs Secretary l Governor's Of fice '

State Capitol Sacramento, California 95814 Herbert H. Brown, Esq. -

Hill, Christopher & Phillips, P.C. .

l 1900 M Street, N.W. -

Washington, 0.C. 20036 .

Mr. Richard E. Blanke'nburg, Co-Publisher .

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Mr. Wayne A. Soroyan.11ews Reporter .,

South County Publishing Cerapany . .

P. O. Box 460 ,

Arroyo Grande, California 93420 -

Mr. James 0. Schuyler ,

Vice President - Nuclear Generation Departraent .

Pacific Gas & Electric Compan'y .

P.O. Box 7442 -

San Francisco, California 94120 Bruce IJorton, Esq. .-

Suite 202 I

3216 North 3rd Street

) Phoenix, Arizona 85312 i

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h- - Mr. W. C. Gangloff Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230  ;

David F. Fleischaker Esq.

• Suite 709 1735 Eye Street, R. W. *

• Washington, D. C. 20006 g

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ENCL.05URE A Elements Which Should be included in the Design Yerification i Program of Non-Selsmic Service Related Contracts Prior to June,1978 l

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1. A review of all quality assurance procedures and controls used by each 1

pre-June 1978 non-seismic service contractor and by PG8E with regard to l

that contract; a comparison of these procedures and controls with 1 1

the related criteria of Appendix B to 10 CFR 50; and an identification I of any deficiencies or weaknesses in the quality assurance procedures and in controls of 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 PG8E internal design groups and each contractnr.

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3. A review of the implementation of quality assurance procedures and controls used by and for:

o PG8E Internal design groups, o each ce6 tractor internal design group (s),

l o transmittal of infomation between PG8E and each contractor, o transmittal of contractor developed infontation within PG&E; and l an identification of any deficiencies or weaknesses in the i=plementation nf quality assurance procedures and controls by each contractor and by PG&E.

4. Development of criteria for the conduct of this design verification progra1: should consider the guidelines contained in ANS! N45.2.11, Section 6.3.1.

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Development'of criteria for selection of a suitable nu:ber and type of .

} sample calculations related to the design of safety related structure's, i

systems and components involved. The purpose of these sar?. calculations should be to verify the design process, particularly in the areas of .-

any identified contractor or PG1E quality assurance weaknesses or deficiencies as determined from the procedure and implementation reviews

. discussed in steps 1 through 3 above. Crfteria for expanding the sample.

size when problems in verifica' tion are encoyntered should also be developed.

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_ ENCLOSURE B Elecents Vhich Should be Included in the Design Yerification

. Program of PG&E Internal Design Activities

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1. A review of all qualt'ty 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 samples of the overall facility design. A comparison of the PG8E procedures and controls used for the sample structures, systems or components 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.

2. Development of a network for the design chains for the sample structures, systems or componerts involved. This should include all interfaces where design information was transmitted between internal PG8E design groups.

3. A review of the implementation of quality assurance procedures and controls used in the design of the sample structure, systems or components by internal PG5E design groups, and an identification of deficiencies or  ;

weaknesses in the implementation of quality a's'surance procedures and controls by internal PG8E design groups. 1 1

4. Develope 4nt of criteria for the conduct of this design vertf tcation I program should consicer the guidelines contained in AliS! N45.2.11, Section 6.3.1.

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Development of criteria for selection of a suitable number and type o'f 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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ENCt.05URE C Ele.ments Which should be Included in the Design Yerification Program of Service-Related 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 j selecting for detailed examination certain activities of the contractor I as representative samples of the entire activities carried out; a cmparison of the procedures and controls used by the contractor and l PG8E for the sample activities with the related criteria of Appendix B l t

to 10 CFR Part 50; and an identification of any deficiencies or weaknesses j

in the quality assurance controls of the contractor and PG8E l

2. Develop. ment of a network for the design chain for the structures, systens or components involved with the samole activities. This should include all interfaces where design infomation was transmitted between PG&E internal design groups and each contractor.

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3. A review of the implenentation of quality assurance procedures and controls used in the conduct of the sample ac'tivities by and for

o PG8E internal design groups,

! o each contractor internal design group (s),

o transmittal of infomation between PG8E and each contractor, o transsittal of contractor developed infomation within PG8E; and an identification of any deficiencies or weaknesses in the implementation i

of quality assurance procedures ano controls by each contractor and I

i by PGAE.

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4. Development of criteria for the conduct of this design verification '

l program should consider the guidelines co'ntained in ANSI N45.2.11, Section 6.3.1. ,,

5. Development of criteria for selection of a suitable nueber and type of .'

sample calculations related to the sample activities involved. The purpose of these sample calcul,ations should be to verify the design process, particularly in the areas of any identified' contractor or PG8E 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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