ML20197F922

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Forwards Input for Unit 1 SALP Evaluation Re Design Verification Effort.Design Verification Should Be Appended to & Included in NRC 830330 Evaluation
ML20197F922
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 03/24/1983
From: Schierling H
Office of Nuclear Reactor Regulation
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20197F919 List:
References
FOIA-86-489 NUDOCS 8304010002
Download: ML20197F922 (4)
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/I t, * ' UNITED STATES

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Maa 2 41983 Docket Nos.: 50-275 and 50-323 .

MEMORANDUd FOR: Darro11 G. Eisenhut, Director Division of Licensing THRU: Thomas M. Novak, Assistant Director for Licensing Division of Licensing Gtorge W. Knighton, Chief /

Licensing Branch No. 3 <-.9 .l Division of Licensing ,/ -

FROM: Hans Schierling, Project Manager Licensing Branch No. 3 Division of !.icensing

SUBJECT:

DIABLO CANYON UNIT 1 SALP EVALUATION Enclosed is the NRR input for the Diablo Canyon Unit 1 SALP evaluation with respect to the design verification effort. Since this effort accounted for a major portion of NRR activities (both technical review and project manage-ment) it was decided to prepare = more detailed evaluation than had previously

" been provided in a memo to you oded "obruary 15, 1983. We recommend that the enclosed SALP evaluation for t;n Jesign verification effort be appended in its entirety to our previous evaluation and be included in the NRC evaluation of March 30, 1983 under Section Vl-9 (Performance Analysis of Functional Areas - Operational; Licensing Activities).

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Hans Schierling, Project Manager Licensing Branch No. 3 Division of Licensing Enclo M re:

As stated cc: D. Kirsch, Region V D. Sternberg, Region V  :

J. Crews, Region V B. Buckley, DL G

. Enclosure Appendix to NRR Input for SALP Evaluation (tiemorandum to D. G. Eisenhut from B. Buckley and H. Schierling, dated 2/15/83.'

IV Perfort:ance Analysis - Desicn Verification Effort The design-verification effort for Diablo Canyon Unit 1 is an activity that was caused by the detection of the so called " mirror image problem" in September 1981 and which resulted in the Commission Order and NRR letter of November 1981. The effort consists of an Independent Design Verification Program (IDVP) and the PG&E Internal Technical Program (ITP). The majority (approximately three quarters) of all NRR licensing activities (both technical review and project management) during the evaluation period were associated with the design verification activfties for Diablo Canyon Unit 1. A separate performance evaluation is prepared for the appropriate attributes of this activity. The elements listed in NRC Manual Chapter 0916 were found to be insufficient and not appropriate because of the uniqueness and scope of'the

- design verification effort. Instead this evaluation is based on specific examples of activities. -

The design verification effort by the licensee has shown continuous improvement in quality of work performed, understanding of issues and management commitment.

In the beginning, the licensee had some difficulty in developing'a clear definition of the program and its scopt. Since about May 1982, both the IDVP and ITP have demonstrated excellent performance. An evaluation of the licensee's' performance with respect to the appropriate attributes listed in the Manual Chapter is provided below. Based on these evaluations the overall performance for the design verification program-is Category 2.

A. Management Involvement a'nd Control in Assuring Quality .

PG&E management has been actively involved in the development and evaluation of the design verification program. The immediate notification of the NRC of the initial " mirror image" problem in September 1981 and the licensee's commitment, prior to issuance of the NRC Order, not to commence fuel loading shows prompt management attention to a safety issue. For a brief period thereafter some management actions reflected imcomplete information from its staff (e.g. unawareness of necessary' scope and of importance and implication of independence issue). However, because of its involvement r the licensee'srexecutive management recognized' the need to strengthen its own staff with outside upper management and technical expertise. This resulted in the employment of the Bechtel organization and the formation of the Diablo Canyon Project. This step demonstrated PG&E management involvement and interest for a quality program. Throughout the evaluation l

period, PG&E management has demonstrated an eager. ness and willingness i to communicate with the NRC management regarding any issue. Examples j

are the initiation of the PG&E "look back" evaluation of its QA program j

and implementation and its commitment to perform an audit of QA activities during the construction phase. Based on NRR interaction with the licensee, we rate the PG&E nenagement involvement and commitment to quality in the design verification effort as Category 1.

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L B. Approach to Resolution of Technical Issued From a Safety Standpoint The licensee's staff originaly underestimated or did not envision the required scope of the design verification effort. After full idplementation of the IDVP, as required by the Commission Order, technical issues were more clearly identified. The subsequent formation of the Diablo Canyon

~ Project in conjuction with the employment of Bechtel resulted in a PG&E effort and commitment to resolve all technical safety issues to the satisfaction of the NRC as well as its own satisfaction. The expansion of the original program from a sample basis to a complete reanalysis of the seismic aspects of all safety related structures, systems, and components and the commitment .of extensive manpower resourcessto the resolution of the safety issues demonstrate the necessary and proper approach to the resolution of the issues. Another 6xample of appropriate action is the recalculation of pressure and temperature enviror.ments for

, safety related components. In summary, the design verification program now in place (both IDVP and ITP) is an excellent program for the r,esolution of technical issues, has the full support of PG&E managements and meets our requirements. However continued NRR involvement in the execution of the program is required, such as attendance at PG&E/Teledyne meetings. Considering the entire evaluation period. We rate the " Approach to Resolution of Technical Issues *From a safety Standpoint" as Category 2.

C. Responsiveness to NRC Initiatives The Commission Order and the NRR letter of November 19, 1981 are the NRC actions that initiated the entire design verification effort. The licen'see's response to the requirements was prompt ,and positive in.the development and implementation of program. plans for Phase I and Phase II.

The licensee responded at all times to modifications to the program and '

additional NRC initiatives ~, for example, the audit of QA activities related to construction and the expansion of the initial sample. The licensee has also been responsive in the resolution.of issues identified by the IDVP. The licensee has stated at various meetings and in submittals to the staff its commitment to respond to all NRC requirements.

As part of the staff evaluation Brookhaven National Laboratory performed a detailed seismic analysis of the annulus steel structure inside containment.

This resulted in requests for additional information from PG&E. The '

responsiveness to such requests were not as prompt as desired. The licensee's performance in thisattribute of " Responsiveness to NRC Initiatives" is rated Category 2 for the design verification program.

E. Enforcement History no input

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D. R'eporting and Analysis of Reportable Events The " mirror image problem" was reported promptly to the liRC after its detection. Initally this problem was thought to be an isolated case and immediate action was taken to determine the circumstances and bases for the problem. After issuance of the tiRC Order and letter, a program plan was developed that includes specific procedures for identifying and resolving additional deficiencies and concerns by the IDVP and the ITP.

The events are reported periodically and effectively to the NRC through semi-montly reports. We rate the perfonr.ance for " Reporting and Analysis of Reportable Events" as Category 2, however a definite improvement during the last six months of .the reporting period is evident.

E. Staffing (Including Management)

At the outset of the design verification program the licensee intended to use P.. C. Cloud Associates for the perfonnance of the NRC directed Independent Design Verification Program (IDVP) and the PG&E staff for the Internal Technical Program. After recognition of the required scope of the program the licensee took positive actions to devote all the necessary resources to this effort. Teledyne was selected as the IDVP program manager with R. F. Reedy Inc., Stone & Webster Engineering Services and R. L. Cloud Associates as subcontractors. Additional technical consultants were also employed. In March of 1982 Bechtel =

vias employed in a program management and technical support futtion.

Since early 1982 the licensee has always dedicated' the necessary resources, both management and technical staff, to the design verification effort. We rate this attribute as Category 1. -

F. Training

. Not applicable.

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