ML20209B134
| ML20209B134 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/17/1981 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML16340C148 | List:
|
| References | |
| FOIA-86-151 NUDOCS 8112090242 | |
| Download: ML20209B134 (15) | |
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UNITED STATES L
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MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
TRANSMITTAL OF COMMISSION PAPER REGARDING THE RECENT DIABLO CANYON SEISMIC ISSUES As requested by the Commission enclosed is a draft letter to Pacific Gas and Electric Company.
It has been revised to reflect discussions of the November 16, 1981 Commission Meeting and is believed to be compatible with the Order being prepared by OGC.
/W Harold R. Denton, Director Office of Nuclear Reactor Regulation
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FOR:
The Commissioners FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
DIABLO CANYON UNIT 1 SEISMIC DESIGN ISSUES PURPOSE:
To obtain Commission approval for transmittal of the attached letter to the Pacific Gas & Electric Company DISCUSSION:
In SECY-81-636 and SECY-81-636A, the staff forwarded draft 50.54(f) letters to Pacific Gas & Electric Company (PG&E) for Commission consideration. The Commission.was briefed on these matters on November 9 and 16, 1981.
The draft letter has been revised to reflect the discussions of the November 16 Commission Meeting and is believed to be compatible with the Order being prepared by OGC.
RECOMMENDATION:
It is recommended that the Commission approve transmittal of the letter to PG&E.
William J. Dircks, Executive Director 'for Operations
Enclosure:
As stated cc:
Contact:
Frank J. Miraglia, NRR X27243 l
q Mr. Malcolm H. Furbush 1
Vice President - General Counsel i
Pacific Gas & Electric Coupany P. O. Box 7442 San Francisco, California 94120
Dear Mr. Furbush:
The Commission's Memorandum and Order (CLI ) dated November 1981 suspends your license to load fuel and operate Diablo Canyon Unit 1 at power levels up to 5% of full power, and specifies the programs that must be satisfactorily completed before license suspension will be lifted.
Also, based upon recent NRC inspections. conducted at PG&E and the Blume Offices in San Francisco, the NRC staff has identified a number of serious Qua'.ity Assurance (QA) program weaknesses related both to the 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:
a.
the PG&E QA Program did not appear to effectively exercise control over the review and approval of design information passed to and received from Blume.
b.
the PG8E QA Program did not appear to adequately control the distribution of design information from Blume within affected internal PG&E design groups, and the PG&E QA Program 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 information, under oath or affinnation, for NRC review and consideration prior to issuatice of i
any operating license authorizing operation of Diablo Canyon Unit 1 above 5% power:
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O 1.
For All Non-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 non-seismic service contr6 cts 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 PG8E and within each contractor's organization, as well as the transmittal of information between PG&E and each centractor.
It should l
also include performance of a suitable number of sample calculations related to each contract to verify the adequacy and accuracy of the design prccess 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 4
elements set forth in Enclosure A.
(b) A technical report that fully assesses the basic cause of all design errors identified by this program, the significance j
of design errors found, their impact on facility design.
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3-(c) PG8E's conclusions on the. effectiveness of this desi.gn verification 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. Fer modifications that you propose not completing prior to operations above 5% power, the bases for. proceeding shou?d be provided.
u 2.
For PG&E Internal Design Activitier (a) The results of an independent design verif t:3 tion program of PG&E internal design activities performed on Diablo Canyon Unit i related to the development of the -design of a sJitable sample of safety-related structures, systems or toitponents.
The extent of the it. formation provided related to this program should be that which is necessary tp determif.e whether the overall PG&E quality as~ urance procedures and cor.trols de-s scribed in its QA Manual and associated precedurst since 1970, have been fully and effcctivel,Y impl4mer.ted.
This information should also include a su1 table nunbar of sample calculations
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to veri fy the adequacy and accuracy of the PG&E internal design activities for the sample of safety-related structures, systems, or components.
The information to be previded ' con-cerning this design verification program should bb Dased or,
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and include the r.esults of conducti~ng the prog?hm cicments set forth in Enclosure B.
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(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 t
on facility design.
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{c) PG8E's conclusions on the effectivenest of this design verification program in assuring the adequacy of facility
- design,
{d)
A schedule for completing any modificatio'ns to the facility that are recuired as a result of this program.
Fct modifications that ycu propose not completing prior to operations above 5% power, the beses for proceetiing should bf! provided.
3.
For All Service-Related Contracts Post-January 1,1978 (a) The results of an independent design verification prcgram of a suitable sample of the activities performed on
-Diablo Canyon Unit 1 by each service-related contractor that were cc;mpleted 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 f
that wht:h is necessary to detemine whether the ovsrall contractor and PG1E quality assurance procedures and O
cont ols that were in effect during this time period were ' fully and effectively implemented.
This infomation should also include a suitable number of sanple calcu'lations
5-to verify the adequacy and accuracy of the cample con-tractor and PG&E design activities fc7 safetyrrelated 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 En:losure C.
s (b) A technical report that fully asse.tses the basic cause of all design errors identified by this program, the significance of design err. ors found, (nd their impact on facility design.
(c) PG&E's conclusions on~ the effectiveness cf this design verification program in assuring that the adequacy cf facility design.
(d) A schedule for completing any modificttiot.s to the facility that are requireo 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.
In addition to the above, we require that you l provide the following ia-formation for NRO staff review and approval as soon as practicable:*
i 4.
Qualifications of Companies Proposed to Conduct Independent Reviews A description and discussion of the corpo* ate qualifications cf tha company or companies that PG&E would propose to carry :aut the various independent design verificatien programs oiscussed in 1 T' NR; will make its decision on these prOpofEd. Companies afte? provid4ng the Governor of California and other parties to the opcrating license proceeding 15 days for comment.
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4 through 3 above, including information that demonstrates the ir:dependen:e of these companies.
Within 20 d6ys of the dates of NRC approval of the ccmpany or colapanies tc ccnduct the varicus independent design verificction prcgracs, provide f.he following inforr.ett'an for NRC staff review anc approval:*
6.
Pregram Plan Fcr the Desion herification Proc, rams A detailed prcgrani plan for conducting tne variouc desigh verification progra:a5 discussed in 1 through 3 above, The information provided rhould fnclude tae bases for the crit.eria proposed to be U. sed for selection of a suitable number and ty:pa o? sample ca*.colations to be performed under these programs and the bases for tne criteria propered to be used for expanding the semple size bat 2d upon the results raf ths initial samples, w
Ir. additi:n, the criteria for selecting the sample safety re-lated strt:ctures, systems and compor.ents and sample coa?.racto-activities in the de. sign vurific2ticr. programs under 2 cr.d 3 6
above should be prcvided.
To keep the NRC currently infor.ned regarding your progress on the it6,ns discussed in I throuDh 3 above, you sr.culd provide setti-monthly status reoorts on the ongstr.g reanalysis efforts design verificati;n programs bein,g conducted by and for PC&E.
Ttes.e status r6 ports should be submittec on the 'secch:1 and foGrth Friday of ea:h nonth to the Regional Administrater, Region Y ar.d the Director, Office of Nuc1har Rea: tor Reguiction.
Should these reports or any othcr information tha: becomes available ta the NFC 4 WRC w*ilT kake its decision on the.teceptabiiity of the program plan after providir.g the Governor of California and other parties to the opefating 11cen:o precteding 15 deys for comment.
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indicate that the NRC requirements described in this letter should be expanded or supplemented, FG&E will be promptly infor.Ted.
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In the interest of efficient evaluatica of your submittals, we regtest that you sutmit as soon Ls prheticable la response to the request for additional infomation that was enclosed in the ' Staff's Meeting Sumary dated October 19, 1981, on the October.14-16 meetings with PG&E.
Sinctrely, l
Harold R. Dantor, Director Office of Nuclear Reactor Regulation
Enclosures:
As stated i
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ENCLOSURE A Elements Which Should be Included in the Design Verification Program of Non-Seismic Service Related Contracts Prior to June,1978 1.
A review of all quality assurance procedures and controls used by each pre-June 1978 non-seismic service contractor and by PG&E with regard to that contract; a comparison of these procedures and controls with l
the related criteria of Appendix B to 10 CFR 50; and an identification 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 j
structures, systems, and components involved. This should include all interfaces where design information was transmitted between PG&E. internal design. groups and each contrsctor.
3.
A review of the implementation of quality 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 7
o transmittal of contractor developed information within PG&E and identification of any deficien:ies or weaknesses in the implementation of quality assurance procedures and controls by each contractor and by PG&E.
4.
OcVelopment of criteria for the conduct of this design verification program shoulo consider the guidelines contained in ANSI N45.2.ll, Section 6.3.1.
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Enclosure A (cont'd).
5.
Development of criteria for selection of a suitable number and type of.
sample calculations related to the design of safety related structures, systems and components 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 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 1
j developed.
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ENCLOSURE B Elements Which Should be Included in the Design Verification Program of PG&E Internal Design Activities 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 PG&E 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 components involved. This should include all interfaces where design information was transmitted between internal PG&E 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 PG8E design groups, and an identification of deficiencies or weaknesses in the implementation' of quality assurance procedures and controls by internal PG&E design groups.
- 4.
Development of criteria for the conduct of this design verification program should consider the guidelines contained in ANSI N45.2.ll, Section 6.3.1.
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Enclosure B (cont'd).
5.
Development of criter.f a 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 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 i
when problems in verification are encountered should also be developed.
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O ENCLOSURE 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 as representative samples of the entire activities carried out; a comparison of the procedures and contrcls used by the contractor and PG&E 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 PC&E 2.
Development of a network for the design chain for the structures, systems or components involved with the sample activities.
This should include all interfaces where design information was transmitted between PG&E i
internal design groups ard each contractor.
3.
A review of the implementation of quality assurance procedures and controls used in the ccaduct of the sample activities by and for:
o PG&E internal design groups eac'h contractor internal design group (s) o o transmittal of information between PG&E 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 I
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/. 0 Enclosure C (cont'd) 2-4.
Development of criteria for the conduct of this design verification program should consider the guidelines contained in ANSI N45.2.11,
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Section 6.3.1.
5.
Development of criteria for selection of a suitable number and type of sample calculations related to the sample activities involved. The purpose of these sample calculations should be to verify the design process, particularly in the areas of any identified contractor or 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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