ML20204E919
| ML20204E919 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/13/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20204E925 | List: |
| References | |
| FOIA-87-127, TASK-PICM, TASK-SE SECY-81-636A, NUDOCS 8112100045 | |
| Download: ML20204E919 (18) | |
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November l'3,1981 SECY-81-636A POLICY ISSUE (Commission Meeting)
FOR:
The Cometssioners FRON:
William J. Dircks, Executive Director for Operations
SUBJECT:
DIABLO CANYON UNIT 1 SEISHIC 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 Comparty (PG&E). The Consission 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.
RECOPNENDATION: It is reconsended that the Commission approve the transmittal of the attached letter to PG&E.
S
.s it'q l u h i William J. Dircks.
Executive Director for Operations Enclosure cc:
SECY DISTRIBUTION OPE Connissioners OGC Connission Staff Offices OCA Exec Dir for Operaticns
'.xec Legal Director
Contact:
ACRS e
Frank J. Miraglia, NRR ASLBP i9
(),'y X27243 ASLAP Secretariat A"/
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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 containment annulus of Diablo Canyon Unit 1 was detected by Pacific Gas and Electric (PG&E) and reported to the NRC. PG4E 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 meetjng between PG4E and the NRC staff, we requested that PG4E complete the [ollowing activities and submit the document'ng 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 Canyon Unit 1 and any modifications resulting from the reanalysis.
(2) A verification of all safety-related seismic design activities performed under the PGAE/Blume 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 2-Based upon recent NRC inspections conducted at PG8E and the Blume Offices in San Francisco, the MtC 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 PG8E of applicable criteria of Appendix B of 10 CFR Part 50. We have preliminarily concluded that:
the PG8E QA program did not appear to effectively exercise control a.
over the review and approval of design infomation passed to and received from Blume, b.
the PG8E QA Progras did not appear to adequately control the distribution of design infomation from Blune trithin affected internal PG8E design groups, an?
The PG8E QA Program did not appear to define and implement adequate c.
quality assurance procedures and controls over other service-related contracts.
A follow-up meeting was held on November 3,1981 between PG8E and the NR0 staff to further 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 PG8E to the NRC.
Accordingly, you are requested in accordance with 10 CFR 50.54(f), to submit written statements signed under oath or affimation concerning these matters to enable the Connission to detemine whether or not your Itcense should be modified, suspended or revoked.
Specifically, you are requested to submit the following infomation to i
the NRC on d.e schedules indicated below:
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I M. H. Furbush !
1.
At least 45 des 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 safety-related activities performed prior 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 assurance procedures, controls and practices concerning the development, accuracy, transmittal, and use of all safety-related information both within PG4E and within each contractor's organization, as well as the transmittal of tr. formation between PG&E and each contractor. It should also include performance of a suitable nusber 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 I
in Enclosure A.
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M. H. Furbush 1 (b) A technical report that fully assesses the basic cause of I
all design errors identified by this program, the significance j
of design errors found, and their impact on facility design.
(c) PG4E's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility design.
l (d) A schedule for completing any modifications to the facility that are required as a result of this program. For modifica-
-!I tions that you propose not completing prior to fuel load, the bases for proceeding should be provided.
2.
At least 45 days prior to the date you plan to proceed with operations above 55 power, provide the following information:
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(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, systens and components.
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E 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 PG6E and each contractor.
It should also include performance of a suitable number i
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.
(2) A technical report that fully assesus the basic cause of all design errors identified by this program, the significance of design errors found, the their impact on facility design.
(3) PG4E's conclusions on the effectiveness of this design verification program in assuring the adequacy of facility l
design.
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(4) A schedule for completing any modifications to the i
facility that are required as a result of this program.
For modifications that you propose not completing prior to operations above 95 power, the bases for proceeding should be provided.
4 (b) For PGaE Internal Design Activities (1) The results of an independent design verifict.tton program of PG8E internal design activities performed on Diablo Canyon thit 1 related to the development l
of the design of a suitable smole 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 PG4E quality assurance procedures and controls described in its 04 Manual and associated procedures since 1970, have been fully and effectively impl emented. This information should also include a suitable number of suple calculations to verify the adequacy and accuracy of the PG8E internal design activities for the sasple of safety-related structures, systems, or components. The infomation 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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(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) PG&E'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
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completing prior to operations above 55 power.
the bases for proceeding should be provided.
(c) For All Service-Related Contracts Post-January 1,1978 l
(1) The results of an independent 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, systens and components. The extent of the information provided related to this program should be that which is necessary to determine whether the overall contractor
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M. H. Furbush and PGAE 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 PG4E design activities for safety-related structures, systems and components.
The informattor. to be provided concerning this design verification program should be based on and include the results of conduct 1.?g the program elements set forth in Enclosure C.
(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) PG4E'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 factitty 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.
M. H. Furbush 3.
Within 30 days of the date of this letter, provide the following infomation for NAC review and approval:
Qualifications of Companies Proposed To Conduct Independent Reviews A description and discussion of the corporate qualifications of the companies that PGAE 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 d4ys 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:
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Program Plan For the Design Verification Programs
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A detailed program plan for conducting the various design verification programs discussed in 1 and 2 above. The infomation i
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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 l
related structures, systems and components and sample contractor activities in the design verification programs under 2(b)
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t and 2(c) above should be provided.
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M. H. Furbush 5.
Status Reports Starting on Friday, November 27, 1981, a seet-monthly status report on the second and fourth Friday of each month, on the ongoing reanalyses efforts and design verification programs being conducted by and for PGAE, should be submitted to the Regional Administrator, Region V and the Director, Office of Nt. clear Reactor Regulation.
In the interest of efficient evaluation of your submittals, we request that you subatt as soon as practicable a response to the request for additional information that was enclosed in the Staff's Meeting Summary dated October 19, 1981, on the October 14-16 meetings with PG8E.
Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
As ' stated 1
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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 PG4E with regard to that contract; a comparison of these procedures and controls with the related criteria of Appendix 8 to 10 CFR 50; and an identification of any deficiencies or weaknesses in the quality assurance procedures and in controls of f
the contractor and PG8E.
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 PG4E internal
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design groups and each contractor.
3.
A review of the implementation of qua111;y assurance procedures and l
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 PGaE and toentification 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 (mnt'd) 5.
Development of criteria for selection of a suitable number and type of sample calculations related to the design of safety related structures, systes and components involved. The purpose of these suple calculations should be to verify the design process, particularly in the areas of any identified contractor or PGAE quality assurance weaknesses or deficiencies as determined from the procedure and implementation reviews i
discussed in steps 1 through 3 above. Criteria for expanding the sample size when probless in verification are encountered should also be developed.
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ENCLOSURE B Elements Which Should be included in the Design Verification Program of PGE. Internal Design Activ1tles 1.
A review of all quality assurance procedures and controls used by internal PG8E 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, systsas or components with the related criteria of Appendix B to 10 CFR 50; and an identification of any deficiencies or weaknesses in these PG8E quality assurance procedures and controls.
2.
Development of a network for the design chains for the saaple structures.
systems or components 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 sanple structure, systems or compo.ents by internal PG8E design groups, and an identification of deficiencies or l
weaknesses in the implementation of quality assurance procedures and controls by internal PG8E design groups.
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 B (cont'd) '
5.
Development of criteria for selection of a suitable number and type of 3caAe calculations related to the design of the sample structures, sy.
>< cr ecaponents involved. The purpose of these sample calculations shouls. '.:
- verify the design process, particularly in the areas of any '.e.itified PG&E quality assurance weaknesses or deficiencies as detemined fmm the procedure and implemenation 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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l EHCLOSURE C Elements Which Should be Included in the Design Verification Program of Service-Related Contracts After 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 i
as representative samples of the entire activities carried out; a comparison of the procedures and controls used by the contractor and PG8E for the sample activities with the related criteria of Appendix 8 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 oesign chain for the structures, systems
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or components involved with the sample activities. This should include
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all interfaces where design information was transmitted between PG&E internal design groups and each contractor, i
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A review of the implementation of quality assurance procedures and controls used in the conduct of the sample activities by and for:
o PG4E internal design groups o each contractor internal design group (s) o transmittal of information between PG8E and each contractor o transmittal of contractor developed information within PG&E and an identification of any deficiencies or weaknesses in the implementation of quality assurance procedures and controls by each contractor and by PG&E
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Enclosure C (cont'd) 4 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.
5.
Development of criteria for selection of a suitable number and type of suple calculations related to the suple activities involved. The purpose of these sample calculations should be to verify the design process, particularly in the areas of any identified contractor or PG8E quality assuran:e weaknesses or deficiencies as detemined 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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