ML20151H132
| ML20151H132 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/17/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20151H112 | List: |
| References | |
| FOIA-88-104 NUDOCS 8112090239 | |
| Download: ML20151H132 (14) | |
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The Coralss1oners U
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William J. Dircks, Exect 've of rector for Operat
SUBJECT:
DIABLO CANYON UNIT 15EISHIC OCSIGN ISSUES PURPOSE:
To obtain Commission approval for transatttal of the attached letter to the Pacific Gas & Electric Company OlSCUSSION:
In SECY41436 and 5CCY41436A. the staff forwarded draf t 50.54(f) letters to Pacific Gas & CIMtric tempany (PGAC) for Countssion consideration. The Commission was briefed on these satters on Noveder 9 and 16.1981. The draft letter has been revised to reflect the discussions of the movember 16 Consission Meetins and is believed to be ccapatible with the Order being prepared by 00C.
REcoletMDATION:
It is roccamended that the Coquission approve transmittal of the letter to PG4C.
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Docutive Director for Operations Enclosure As stated cc SECY OPE occ n
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Mr. Malcolm H. Furbush Vice President = General Counsel Pactfle Gas & tiectric Company P. O. Box 7442 San Francisco, Californf a 94120 BilFMF FWFBWlhi The Ccamission's Memorandus and Order (cf.! ) dated November
, 1981 suspends your license to load fuel and operate Diablo Canyon Unit 1 at power levels vp to 55 ef full powr, and specf fles the programs tA4s sust be satisfactorily ccepleted before Itcense suspension will be lif ted.
Also, based upon recent WRC inspections conducted at PGat and the Blume offices in San Francisco, the WRC 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 PMt of applicable criteria of Appendix 8 of 10 CFR Part 50. nie have preltsinarily concluded that:
the PMt QA Progran did not appear to effectively exercise a.
control over the review and approval of design information passed to and received from Blume.
b.
the PG4C QA Progras did not appear to adequately control the distribution of design information free Blume within affected internal PMt design groups, and The PMt QA Progras did not appear to define and implement c.
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 infomation, under oath or affirmation, for WRC review and consideration prior to issuance of any operating Itcense authorising operation of Diablo Canyon Unit 1 above n power:
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For All Non Setsnic Service - Related Contracts Prior to June 1978 (a) The results of an independent design vertftcation progras l
of all safety-related activities performed prior to June 1,1978 under all non seisate strytte contracts uttitzed in the design process for safety-related structures, systems and ccaponents.
Information concerning this program should add:'ess quaitty assurance procedures, controls and practices concerning the development, cccuracy, transatttal, and use of all safety related informatten both within P64t and within each contractor's organtastion, as well as the transaltta) of information between put and each contractor.
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also include performance of a seitable aus6er of s4eple 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 vertftcation progran should be based on and include the results of conducting the progras elements set forth in Enclosure A.
(b) A technical report that fv11y assesses the basic cause of a11 design errors identified by this program, the significance of design errors found, their tapact on factitty design.
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(c) Put's conclusions on the effectiveness of this design verification progran in assuring the adequacy of fact 11ty design.
(d) A schedule for completing any modifications to the fact 11ty that are required as a result of this program. For modtfications that you propose not completing prior to operations above 65 power, the bases for proceeding should be provided.
2.
For PG4E Internal Detten Activities (a) The results of an independent design verification program of PMt internal design activities perfomed on Olablo Canyon Unit i relsted to the development of the design of a suitable unple of safety-related structures, systans or coeponents.
The extent of the information provided reisted to this progran l
should be that shlen is neesssary to deterntne whether the overall PMt qualf ty assurance procedures and controls de-scribed in its QA P. anus) and associated procedures since 1970, have been fully and effectively toplemented. This information shoold aise inslede a tai 1461e awter ef seaple calsu14Lfeai to verify the adequacy and accuracy of the tut interne) 4 design activities for the sample of safety related structures.
systees, or compoMats. The information to be provided con.
corning this design verification progree shov14 be based on and include the results of conducting the progree elements ut forth in Enclosure S.
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4 (b) A technical report that fully assesses the basic cause t
of all design errors identified by this program, the i
significance of design errors found, and their tapact on factitty design.
(c) Put's twc19sions on the effectiveness of this design vertftcation progree in assuring the adequacy of factitty design.
(d) A schedule for complettag any so41ficattens to the i
fact 11ty that are required as a result of this program.
For modtficattens that you propose not completing prior to operations above 65 power, the bases for proceeding l
should be provided.
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For A11 Service Related Contracts Post-January 1.1978 is) ine reiviii of an inapenant d413. verification progra.
of a suitable sample of the activities performed on Otable Canyon Unit I by each Mrvice-related contracter that wre completed subsequent to January 1.1978 related to the development of the design of safety related 1
structures, systees and components. The enter.t of the
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informallen provided related to this progran should be that etch is necessary to determine eether the overall contractor and put quality assurance procedures and centrols that wre in effect during this time period were fv11y and effectively (splemented.
This information should also inc19de a suitable number of sample calculations
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to verify the adequacy and accuracy of the sample con-iretter and pME design selfvf tfes for safety,related structures, systems and components. The information to be provided concernfog this design verification program should be based on and inelvde the retulls of conducting the progrta elements set forth in Enclosure C.
(b) A tuhnical report that fully assesses the basic cause of all design errors identified by this progras, the significance of design errors found, and their impact on fact 11ty desfgn.
(c)
PHI's conclustons on the effectiveness of this design vertitcation program in assuring that the adequacy of facility design.
(d)
A schedu.e for completing any modifications to the facility that are required as a rssult of this program.
For modifications that yw propose act completing prior to operations above il power, the bases for proceeding should be provided.
In addition to the above, we require that you provide the follwing in-formation for MAC staff review and approva) 45 Soon as practic6blet*
4.
Qualtfications of Compantes proposed to Con 6ct ladopendent Rev A deuription and dlwussion of the corporate quellfications of the company or companies that PMt would propose to carry out the various Independent design vertf tcation prograal diuvised in 1 ac win sake its decision on these proposed coepantes af ter pro e
proceeding Il days for comment,the Governor of California and oth
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-s-through 3 above, including information that demonstrates the independence of these compantes.
Within 20 days of the dates of NRC approval of the company or compantes to conduct the various independent design verification programs, provide the following information for WRC staff review and approvalt' 5.
Program Plan For the Design Vertfication Programs A detailed progran plan for conducting the various design vertfication programs discussed in 1 through 3 above. The infonsation provided should include the baus for the criteria proposed to be used for selection of a suitable number and type of sample calculations to be performed under these prograns and the bases for the criteria proposed to be used for expanding the sample size based upon the results of the initial staples.
In addition, the criteria for Hlecting the sample safety re-lated structures, systems and components and sample contractor activities in the design vertftcation progras?.nder 2 and 3 above should be provided.
To keep the NRC currently infomed regarding your progress on the ite:as discussed in 1 through 3 above, you should provide sent-monthly status reports on the ongoing reanalysis efforts design verification programs being conducted by and for PG4t. These status reports 'ahould be submitted on the second and fourth Friday of each month to the Regional Administrator, Region V and the Otrector Office of Woclear Reactor Regulation.
Should these reports or any other information that becomes available to the NRC NRG wm sake its dectston on the acceptability of the program plan af ter
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providing the Governor of Callfornia and other parties to the operating iteense proceeding 15 days for comment.
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7 indicate that the WRC requirements described in this letter should be expanded or supplemented. PME will be promptly informed.
In ths interest of efficient ev&1uation of your subetttals, we request that you submit as soon as practicable a response to the request for addittoul information that was enclosed in the Staff's Meeting 3ussary dated October 19, 1981, on the October 14-16 settings with PME.
Sincerely.
Harold R. Denton Office of helear, Director Reactor Regulation
Enclosures:
As stated I
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.tNCLOSURE A Elements Which should be included in the Detten Veriffestfon Program of Won.5ellalc 5ervice Related contracts Prior to June.19*8 1.
A re"tew of all quality assurance procedures and controls used by each pre June 1978 non selsaic service contractor and by PG4C with regard to that contract} a comparison Of these procedures and controls wtth i
the related criteria of Appendia t to 10 CFR 50s and an identification of any deficiencies or weaknesses in the quality assurance procedures and in controls of the contractor and PG48.
2.
Development of a network for the destpa chefs for all safety related structures, systess, and components involved.
Thf a should faclude all interfaces where design information was transettted between PG4L internal design groups and each contractor.
3.
A review of the implementation of quality assurance procedures and Gen %Feln unit by 4R4 ftpl o PG4( internal dosten groups o each contractor internal design group (s) o t,ransaltta) of information between PG4,8 and each contractor o transmittal of contractor developes inforsetton within PG4C and identification of any deflatencies or weaknesses in the taplementation of quality assurance procedures and controls by each contracter and by PG&t.
4.
Developuent of criteria for the conduct of this assign verification progran should consider the guidelines contained in ANll h41.t.11, Section 6.3.1.
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e Enctosure A (cont'd) 2-5.
Development of criteria for selection of a sultdle number and type of staple calculations related to the design of safety related structures, systems and components involved.
Tree purpose of trese sample calculations should be to vertfy the design process, particularly in the areas of any identified contractor or PG4C quality assurance weaknesses or deficiencies as detereinte from the procedure and taplementation reviews discussed in steps I through 3 above. Criteria for expanding the sample size when probless in verification are encountered should also be developed.
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1 ENCt.05URE 8 Llements Which Should be included in the Destqn Vertfication Program of FGaL Internal Design Actly ties 1.
A review of all quality assurance procedures and controls used by internal PG4E design groups by selecting for detailed examinetton certain safety related structures, systees or components as representative samples of the overall facility design. A cooperison of the PG4E 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 cf any deficiencies or weaknesses in these PG4E quality assurance procedures and controls.
2.
Development of a network for the design chains for the sample structures, systems or components involved. This should faclude all interfaces where design inforsation was transmitted between internal PGat design groups.
3.
A review of the implementation of quality assurance procedures and controls used in the design of the sample structure, systees or components by i
internal PG4C design groups, and an identification of deficiencies or wennesses in the taplementation of quality assurance procedures and controls by interna) PG4E design groups.
4.
Development of criteria for the conduct of this 4Glign vertf tcation program should constoer the guidelines contained in Ahn! N45.t.11, 5ection 6.3.1.
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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 caleviations should be to verify the design process, particularly in the areas of any identified PG4E quality assurance weaknesses or deffcfencies 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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tiemnts Which Should_be Ine19ded in the Detten Verification
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Program of 5ervice.Relett6 Contracta Af terianuary 1.1978 ~
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- s selecting for detafled exaafnetton certain activities of the contractor as representative samples of the entfre activitte cartfed 0918 a comparison of the procedures and controls used,b the contractor and g
Put for the sample activities with, the related criterta of Appendfx B C
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to 10 CFR Part 50; and an identf ffca'tfon of sy ileff'cfencies or weakusses in the quality assurance controls of the contractor and PMt b
E Development of a network for the design chafn for the structures, systees 2.
y, or coeponents involved with the sample activf tfes. This should faclude h.
all interfaces where design information was transattted between PMt internal design groups and each contractor.'
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A review of the fsplementation of quality assurance prxedurts and controls used in the conduct of the sosple actfvities by and fers
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o PMI fatarm1 design groups j
o each contractor faterM1 design group (s) 4; o transatttal of faformation between PG48 and each contractor o,transatttal of contracter developed fafernetton v!thf a Put and an identificatfon of av deff tfencies er weakmsses la the i
i fsplese.)tation of quality ensurance procedures and controls o
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j Development of criteria for the condWct of this deste veriffcation 4.
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program should consider the pids11Ms tent 4fMd fa M31 N45.t.11
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Development of criterta for Hlectfos of 4'sultable pushr and type of y
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purpose of these sample calculatten should be.to M'rtfy the design process.
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assurance wtakusses er deffelencies,as deterstned from the procedure and tsplementstion reviews discusud*12 stepsi throwsh 3 above..Critorf a y
for expanding the sample sfge Wwn probless la Mrffication are encountered
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Executive Director for Operations,
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rRat Harold R. Denton. Director' Office of N0:184r Reestor Replation i
WsJtets fitMSM!ffAL OF CSet!!l!0N PAMA MGMD!llo THE MC(NT DIAal.0 CANT 04 SEIIMIC Illut8 s..e" s.:.
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y As requeated by the Comei s1on enclosed is a draft letter to
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Pac 1fIc Ga: and Electric Company. It has been revised to reflect
.1 discussions of the Ihnes6er 16,1941 Consistfon Meeting and is believed to be compatible with the Order bein,g prepared by OCC.
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Here1J R. Danten Office of Nuclear. Director Reactor Regulation i.
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MDeRMOUM FOR: W111f as J. Otrcks Executive Ofrector for Operations FROM:
Harold R. Destes. Director offfce of thclear Reactor Regulation
$UBJECT:
TRM5MITTAL W CMISSION PAMA RIGARDlWQ THE RICtWT DIA8LO CMTON StilRIC 155W8 As requested by the Comeisstes enclosed is e draft letter to Pac 1ffe Ga: and Electrfc Company. It has hb revf see to reflect dliculltons ef the 1801 ember ll,1961 Cometsatte Mettfng and is beltmd to be cospettble with the Order befal prepared by OGC.
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Mereld R. Destes Office of thsclear Director Reactor Regulation 1
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