ML20153D575

Final Response to FOIA Request Re SECY-82-414.Forwards App B Document.Encl Also Available in PDR

ML20153D575
Person / Time
Site:	Diablo Canyon
Issue date:	04/29/1988
From:	Grimsley D NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:	Weissman S CALIFORNIA, STATE OF
References
FOIA-88-101 NUDOCS 8805090201
Download: ML20153D575 (2)

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~PART't.-RICORDS RELI ASED OR NOT LOCATED ISee checard bensi No agency records hbpct to the roovest have been loca'od No addite: mal agency records subpct to the roovest have been bcated.

Agency recorde tubect to the reqwest that a<e coetied e Appendea a's alreah av6.Lable for pwWic especton and cooveg e the NRC Pubhc Document Room.

1717 H Street. N W.. w ashecton. OC .

Agency records swbre ct to the request thrt are dentded e Append 4a _ _ _ are be ag made as adaNo for pwbhc especton and copyeg e the NRC PwN< Document Koom.1717 H Street. N W . Wuhegton. OC. e a folder under the FOWowmber and rea wester nam i

The nonproprotary verson of the proposaus) that vow ag eed to accept e a te.ephone conversaten with a mornber of my staM e now teng made avadaNo for owbhc especten and c4yes at the NRC Pubhc Docwment Room.1717 H Street. N W . Wash.rsgtcA DC. e a folder under the FOi A under and reowester name Enclosed e eformaton on how vow may obta.n access to and the cha ges for coomg records paaced e tM NRC Pow-c Document Room.1717 H Street, N W . Washegton. OC Agency records Abrect to the reQvest are enclosed Any apphCab60 Charge for Copes of the records prowded and payNat procedw+es are noted an the Comments secton.

Records sobrect to the roovest %e been re' erred to ano+er Federa agencyhest for reve* and d. rect respoese to you in view of NRC's response to the reowest. no twether acton a beeg taken on appeal letter dated PART 11 A-INFORMATION WITHHE'.D FROM PUBLIC DISCLOSURE Certa 4n eformaton in the reavestes records e te.ng wrtu eid from pubhc dsciosure pwesvant to the FOf A esemptons descnbed e and for the reasces stated e Pa*t ti, sec.

tons 8. C. aawf D Any rersesed portoes of the documents for *hech ordy c.aq of the record a beeg *fthheld a*e bem mese avataNo for owbhc esrecten and copying e the NRC Pubhc Document Room.1717 H Street. N W . Washegton. DC. e a fo6 der under this FOi A nwmter end reawester na *e Cc =-- O l

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APPENDIX

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RECORDS MAINTAINED IN THE POR UNDER THE ABOVE REQUEST NUMBER ,

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PUBLIC UTilfilES CCMAMISSK)N l MS VAN MM AWNW SAN FR ANC15CO. CA 94102 3299 February 8, 1988 fBDEDOM OF INFORMATKM ACI REQUEST Mr. Donnie H. Grimsley, Director Division of Rules and Records g y _jy g/ j Office of Administration and Resources Management t g g,,,jeg ,,g U.S. Nuclear Regulatory Commission '

Washington, D.C. 20555 RE: FnIA Request for Staff Requirement Memoranda

Dear Mr. Grimsley:

Pursuant to the Freedom of Information Act and 10 CFR Part 9, Subpart A, "Freedom of Information Act Regulations", please make available at the Commission's Washington, D.C., Public Document Room single copies of records in the following categories:

A. All concurrence sheets--e.g. each page on which concurrence is indicated by signature, initials, dates or other means--for SECY-82-414, as approved by the Commission on March 4, 1982.

B. Any drafts, revisions, annotated copies, etc. of the document which became SECY-82-414. This request includes any attachments to these documents. Please provide any concurrence sheets--as defined above--for any of these documents.

C. Commission request COMJA-82-6, cited in SECY-P1-414.

We request a waiver of fees pursuant to 10 CFR 9.41 because the documents will be used by a state agency as part of an official investigation.

If you or any members of your staff have any questions concerning this request, please contact the undersigned directly by telephone at (415) 557-0168. It is requested that, if documents are identified which are releaseable under this request, partial responses be made as appropriate. Your prompt attention to this request will be appreciated.

Si rely, ,

ven Weissman Staff Counsel SW:bjk "y YON lSU(0

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OCT 131982.

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FOR: The Comissioners 50-2 b FPM: William J. Dircks, Executive Director for Operations SUNECT: DI ABLO CANYOff M51Gy '.'ERIFICATI0t PROG %M -

PNASE !! PLCH 3 D,MT10!.'S PURPOSE: In accordance with the Corr.ission's request (COFUA *2-6) of July 27, 1962, this paper provides the staff recomendations regarding Phase !! of the Diablo Canyon Independent Desiqn Verification Program (IDVP) and its relationship to the ongoing Phase I progran.

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By eenorandum dated September 24, 1982, we provided you with a Status Report of ongoing activities associated with the verification of the seismic design of Otablo Canyon Unit 1. The memorandufs noted that findings fron Phase ,

i l of the 10VD and other recent developments may influence the staff's conclusions with regard to the Phase !! Program Plan which was submitted to the NRC for approval on June 18, 1982. We have continued to pursue those matters and have developed our recomendations with regard to the Program Plan. The staf f findings and recomendations are discusseri below.

015CU55109: Ve have sutrarized in Figure 1 the elements of the Order and letter of t:ovember 10, 1981. The original requirerents needed to suoport a fuel-load / low-power (fl./LP) decision bave becore known as Phase I whereas iters originally rer.uiring completion before a recision regarcice never levels greater than M were definec as Phase !!. It is important to note that although they were defirec as such at the tine, both the Phase I Order and the Phase !! letter acknowledged that an expansiese of either or beR efforts may be necessary. In this context, the staff examiined the overall findinas to date and a number of recent develop ents to determine if any modifications to the originally cefined scope of Phase I and Phase 11 need j N he feRtt M$59i pp. made.

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v Overall Findings to Date As of Septerter 24, 1982, the IDVP had identified 199 technical concerns requiring resolution. A nuder of these have subsequently been resolved and 13 have been

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classified as 'A/B' errors. These are errors in which design criteria or operating limits of safety-related  ;

equipment could have been exceeded and physical modifications, changes in operating procedures, more realistic calculations, or retesting are required to bring the plant into conformance )

with the original design. These technical concerns can i be sumarized as follows: i Fully resolved: 147 Errors: 3 (3 A/B errors)

No design criterfs, or operating limits exceeded: 144 Review continuing: 52

by PG4E: 28 (9 A/B errors) by IDVP: 24 (1 A/B errors)

Total IN~ TIT A/B errors)

Furthermre, PG&E has identified 33 concerns within their Internal Technical Program (ITP). Six have been resolved j and 27 concerns have been classified as A/B errors. i These errors are not directly additive because there exists sore overlap between the 10VP and ITP errors.

As of September 15,1992, PG8E had cocpleted 344 rodifica- )

tions as follows:

Modifications Pipe supports 257 Other supports 43 Annulus structure 34 Other 6

. Total 344 It should be noted that not all A/B errors will necessiate modifications and that a single error may result in a nu2er of sodifications. In addition so.Te of these modifications, nace to date, were a result of the errors from either, or both, the IDVP and ITP and some were modifications unMrtaken by PC&E even though they believe the error could have been sh%n acceptable by c'a tai l e d calculations.

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During a meeting on Septer6er 1,19F2 the st4ff discussed the modifications made to that date with PG4E. With respect to those modifications, PG4E stated that:

1. Most modifications flow from their Internal Technical Program and not the IDVP.

2. All modifications are to restore margins or to meet design criteria.

3. Nothing has been found which would have prevented a system, structure or component from performinn its intended safety function in the event of the postulated Hosgri earthquake.

Tht staff has amined no ificatio comple date and' as conclu ti that the are gen ally min nature; phwhile have no done a de iled eva uation o ea p we belt e that ha the nodt ations t been de, s

facility Id like have with tdod an unacceptable onsequen es. \ rthqua e without

Staff Evaluation of Recent Develoosents During recent months, a number of significant developments and findings have occurred which influenced our recomendations regarding the scope of the Phase 11 Program Plan as proposed.

For your reference, we have graphically summarized in l Figure 2 the functioning of Phase I of the !DYP, the functioning of Phase 11 of the IDVP, and various activities undertaken by PG8E and their relationship to the IDYP. The develoosents exanined by the staff were briefly discussed in our Septercer 24, 1982 memorandum to you ano are further discussed in enclosures to this renorandun. The developnents include:

1. IDYP Phase ! Results:

a. The identification of a larger than originally expected number of errors or open itens (E015) from both the IDVP and the PGaE ITP as discussed above. A list.cf these errors and open itees were provided to you_ as attachmenp to the September 24,1982 memorandue.

b. The issuance of eicht Interim Technical Reports (ITR),

as of October 5,1982, including ITR 1, which suggested i that the sample for the reverification program must be l expanded, and ITR 2, which identified deficiencies in l QA controls fcr certa 19 resign activities. The staff evaluations of ITRs 1 t'irough 5 are province in Enclosure 1. ,

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c. The results from an independent analyIts nerforved by the staff's contractor, Brookhaven National I.aboratory, raised a numer of seismic concerns regarding PG&E original seismic analysis of the containment annulus structure. BNt. developed a three dimensional vertical nodel and identified concerns regarding the distributed masses, modeling of joints, as-tuilt dimension variations, spectra-smoothing techniques, modeling of piping bends and calculated piping support forces used in PG4E's original analysis. These concerns were forwarded to TES for consideration of their generic implications by the 10VP. PG4E has indicated that a majority of these c'ancerns hao been separately identified by the 10VP and/or P6aE. The staff will i audit the 10VP resolution of these concerns. Enclosure '

2 provides additional discussion.

d. Region V inspection of the ongoing activities identified

- a nutter of open inspection issues. These issues include verification that the seismic analysis

model adequately characterizes the seismic responses 1 of the Auxiliary Building, Intake Structure and i various equiprnent and components. Some of these issues had been previously identified by the IDVP. l These issues are being closed out by both Pegion V i and WRR personnel via their consideration in the in the ITP and 10YP. A sumary of these issues is provided in Enclosure 3.

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e. The ortoinal Phase ! IDVP proposed, and the NRC I accepted, to include a reevaluation of the Hosgri l analyses only. The remaining seisr.ic analyses {

will be examined by the IDVP in the Phase !! program.

The staff discussion of this action is provided in Enclosure 4.

2. IDYP Phase !! Results:

a. Preliminar.y results from the P., F. Reecy Phase !!

QA audit indicated that there exist deficiencies in the QA c6ntrols of the PGAE design program and of certain of their contractors.

b. The results from the PGl.E initiated OA audits of I their in-house design activities and their safety- 1 related service contractors are sumarized in Enclosure

5. The PG4E findinos are consistent with the oreliminary results fron the n. F. Peedy Dbase !! f.6 aucit (discussed in a. above). Region V attencad the

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the Region's coments en both of the4e' activities is provided as Eaclosure 6. The staff has also forwarded these coments to TES for their consideration in the 10VP, in particular with respect to the scope of the audit as corpared to the scope delineated in the NRR letter of Nove4er 19,1961.

3. PG&E Actions:

a. The establishment by the PG4E/Bechtel Project Tean of a corrective action progran that includes a seismic reevaluation encompassing all safety-related i structures, systems, and components. The scope '

of the effort is discussee in rcre detail in Enclosure

7. The 10VP will audit and consider the results af the corrective action program.

b. The completion of modifications, as necessary, to restore the "as-built' plant to the "as-designed" condition. A listing of modifications made tp date, and a listing of anticipated additional '

Mdifications, are included in Enclosure 8.

c. The undertaking of a review, to determine the adequacy

' of the seismic evaluation originally done by Blume, called the Blume Internal Report (BIR). Specifically, i

the BIR includes an internal technical review, conducte.1 I

by Blume, of civil / structural wort performed with l particular attention to the work for the Hosgri i'

evaluation in the 1977-1978 time frame. The results of this review have been documented by Blume in

] a report and submitted to the staff in early October 1982.

d. The recognition by PG&E that there is probably no step-wise distinction between pre-1978 and post.

1978 activities as was assured in the issuance of the Connission Orcer and tte MR t.etter of Neverter 19, 19D1.

e. The decis109 hy PGAE to undertake a reevaluation i of construction QA proposed as part the IDVP.

j While PG8E has stated that they have no reason to l

ouestion the quality of construction, they also i

stattd that such a progran is needed to renove any doubts. The 10VP has recently submitted a progran plan for review of these activities. Region i Y has reviewed this oroposed progran and found it to t+ satisfactory and consistent with previous D,eaton V )

] reco w ndations.

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f. The decision by PGaE to undertake9a wikdown of as-built Safety-related structures, systees, and components to increase confidence that as-built conditions are identified and evaluated.

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g. The PGAE proposal for staged licensing is discussed in Enclosure 9. This proposal is to complete, prior to fuel loading, the redew, analysis, and modifications for those systems required for fuel load. The remainder of the systees will  !

be examined subsequently. The staff has reviewed the PGAE proposal and concurs in their identification of systens with some additions to the "supportive" list of equipment.

4 IDVP/ITP Interface:

The IDYP has presented plans to include the results l of the expanded PG8E activities as inputs to the IDVP i progran. This proposal is included in the Figure 2 i flow chart.

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Proposed Phase 11 Program 1

With regard to the contractors for Phase !! of the IDVP,  !

PGat has proposed to retain Teledyne Engineering Services j (TES) as the IDYP program manager. The principal subcontractors to Inc.TES (RTR), are andRobert Stone & L. Cloud Webster Associates Engineering Company (RLCA), (SWEC R. F. Reedy l.{

The staff has examined the financial independence of the Phase 11 contractors frori both PG&E and Bechtel in addition to the independence of individual ecoloyees assigned to the IDYP. The criteria used by the staff in its evaluation are the same as those used in the Phase ! evaluation. The staff also has reviewed the technical qualifications of the .

IDYP contractors. Enclosure 10 sumarizes the staff review I and our findings, oeterrnining that the contractors are  !

technically qualified and are indepenoont.

The adeouacy of the Phase !! Prograr Plan was reviewed by the staff against the requirements of our November 19, 1981 letter. Enclosure 11 describes the proposed program and presents the staff findings on that program.

CONCLUSIONS: Pased on cur review of the proposed Diablo Canyon Phase 11 IDYP, the status and results of other ongoing activities, as discussed above, and consideration of coments of the intervening parties to this proceeding, we have reached the following conclusions:

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1. With respect to the amount of reevaluation activities required prior to any decision regarding fuel-load / low-power, we have concluded that, in addition to the require-ments of the November 19, 1981 Order, review and evaluation efforts for Phase II activities shoJld be sufficiently complete to provide confidence that no major deficiencies exist. We therefore require that an interim report on Phase II, summarizing the IDYP conclusions and results to date, be submitted prior to the FL/LP decision.

We recognize that certain plant modifications will likely not be needed prior to fuel loading, and accordingly we conclude that selected modifications could be deferred until af ter fuel load. Similarly, we recognize that completion of the Phase !! program and other activities proposed by the IDVP and PGaE to provide additional assurance that the plant is b!:*lt in accordance with the application, need not be cocipleted prior to a fuel-load / low-power decision. Figure 3 summarizes the staff's proposal.

2. With respect to the competence of the contractors proposed by PG4E projcct to carry out the Independent Design Verification Program, we conclude that the necessary experience and technical skills are being provided.

3. With respect to the independence of the contractors proposed we conclude that the independence of the IDVP individuals are acceptable in view of those independence criteria provided in the Comission's February 1,1982 responses to Congressmen Dingell and Ottinger.

4. In recognition of the expanded PG4E Program, we believe it is appropriate that the ongoing 10VP alter its approach to include a ,arpling of all of PG&E's efforts to gain overall confidence in that reverification effort.

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v l RECOMMENDATIONS: That the Cemistion: l l

1. Approve the Phase II Program Plan and contractors as modtfled by the staff conclusions in Enclosure ,

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2. Approve the redirection of the Phase I/ Phase 11 division to require that the Phase II review / evaluation efforts -

be sufficiently conpleted, as identified in Figure 3, prior to a fuel-load / low-power decision.

(SignediWilliam J. Ol@

William J. Dircks Executive Director for Operations

Enclosures:

As stated 1

NOTE: Comission connents should be provided directly to the Office of the Secretary by c.o.b.

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,Gffffp;ENDAY10!!5: That the Comission: l l

1. Approve the Phase II Prgram Plan and contractors as roodified by the staff conclusions in Knclosure 11.

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2. Apyrove the redirection of the Pha$e I/ Phase !! division l To require that the Phase II review / evaluation efforts be sufficiently completed, as identified in Figure 3 ,

prior to a fuei-load / low-power dec1sion. l 1

Williata J. Dircks Fxecutive Director for Operations Fnclosures: .

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90TE: Cc.nsission corrents should be provided directly to tho Office of the Secretarj by c.o.b. l p.

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