ML20209B270
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FEB 121982 MEMORANDUM FOR:
Richard H. Vollmer, Director Division of Engineering THRU:
gt idiam V. Johnston, Assistant Director for Materials &
ualifications Engineering, Division of Engineering FROM:
Walter P. Haass, Chief, Quality Assurance Branch, Division o'f Engineering
SUBJECT:
ACCEPTABILITY OF CLOUD VERIFICATION PROGRAM TO SATISFY COMMISSION ORDER ON DIABLO CANYON
References:
1.
Letter, M. H. Furbush to H. R. Denton dated December 4,1981 transmitting Enclosures 1 & 2
- 2. : " Qualifications of Companies Proposed to Conduct Independent Reviews"
- 3. : " Design yerification Program -
Seismic Service Related Contracts Prior to June 1978" 4.
Transcript of Meeting with PG&E to Discuss Seismic Design Review, Diablo Canyon Unit I dated February 3,1982 5.
Size and Technical Qualifications of Review Team (Received February 12,1982) l In discussions on February 9,1982 regarding the seismic design verification program conducted by Dr. Cloud for Diablo Canyon Unit 1, you requested an l
assessment by QAB of the acceptability of the scope of the verification pro-gram relative to the Commission Order (CLI-81-30) - designated Phase I by PG&E.
Based on the referenced documents, the following conclusions can be drawn:
1.
The scope of the review of the establishment of quality assurance progrannatic controls for the :onduct of seismic design by service-related contractors and PG&E is acceptable.
R. F. Reedy, Inc. (RFR) has described an evaluation program that encompasses the pertinent criteria of Appendix B to 10 CFR Part 50. For design verification aspects, the criteria for acceptance will consider the guidelines con-tained in ANSI N45.2.11, Section 6.3.1.
For other quality assurance aspects, it is assumed, though not explicitly stated, that the quality assurance controls committed to at the PSAR stage of review and revised during subsequent upgrades will be utilized to detennine compliance.
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F-Richard H.. Vollmer FEB 1 2 1982 2.
The scope of review of the implementation of the quality assurance pro-gram by PG&E and service-related contractors for seismic design is acceptable. The RFR program provides for full auditing of pertinent documents generated and utilized by the involved organizations to. deter-mine compliance with program requirements.
3.
RFR has provided the professional resumes of its complete staff of per-
-sonnel involved in this effort. This information indicates that the assigned personnel are well qualified to perform thb proposed quality assurance audit.
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h alter P. Haass, Chief Quality Assurance Branch Division of Engineering e
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FEB 161982 MEMORANDUM FOR: Carlyle Michelson, Director Office for Analysis and Evaluation of Operational Data FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
PROPOSED AANORMAL OCCURRENCE - SEISMIC DESIGN ERRORS AT DIABLO CANYON NUCLEAR POWER PLANT This is in response to your February 5,1982 memorandum on the subject matter.
The writeup enclosed in your memorandum appears to be factually correct.
However, it may require updating to reflect the current status of the Region V investigation which is briefly mentioned on pages 5 and 6.
Enclosed is an annotated copy of the writeup which contains some additional coments for your consideration.
l Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated 9
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For:
The C'ommissioners From:
William J. Dircks Executive ~ nirector for Operations
Subject:
ABNORMAL OCCURRENCE RECOMMENDATION - SEISMIC DESIGN ERRORS
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l.T DIABLO CANYON NUCLEAR POWER PLANT
Purpose:
Approval of an abnormal occurrence determination.
Discussion:
Enclosed is a draft Federal Register notice in regard to the seismic design errors at the Diablo Canyon Nuclear Power Plant with the subsequent suspension of the fuel load and low-power operating license of Unit 1 on November 19, 1981.
This item is proposed for reporting based on one of the general criteria of the Abnormal Occurrence Policy Statement; i.e., major deficiencies in design, construction, use of, or management controls fer licensed facilities or material can be considered an abnormal occurrence.
s' CONTACT:
J. Crooks /P. Bobe 492 4425/492 4425
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Recommendation:
That the Commission:
1.
Approve the subject proposed abnormal occurrence together with its associated Federal Register Notice and 2.
Note.that following approval, the Office of Congressional Affairs will notify the appropriate Congressional Committees of the intent to publish the Federal Register Notice.
Scheduling:
While no specific circumstances require Commission Action by a particular date, it is desirable to disseminate abnormal occurrence information to the public as soon as possible.
It is expected that Commission action within two weeks of receipt of this draft proposal would permit-publication in the Federal Register about 10 days later.
William J. Dircks Executive Directer for Operations
Enclosure:
Draft Federal Register Notice e
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NUCLEAR REGULATORY COMMISSION ABNORMAL OCCURRENCE
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SEISMIC DESIGN ERRORS AT DIABLO CANYON NUCLEAR POWER PLANT Section 208 of the Energy Reorganization Act of 1974, as amended, requires the NRC to disseminate information on abnormal occurrences (i.e., unscheduled incidents or events which the Commission determines are significant from the standpoint of public health and safety).
The following incident was determined to be an abnormal occurrence using the criteria published in the Federal Register on February 24,1977(42FR10950). One of the general criteria notes that major deficiencies in design, construction, use of, or management controls for licensed facilities or material can be considered an abnormal occurrence.
The following description of the incident also contains the remedial actions taken to date.
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Date and PEce - On September k 1981 and September 30, 1981, Pacific Gas and Electric (PGAE) submitted letters to the NRC stating that certain drawings (" diagrams") used in the seismic design in the Diablo Canyon Unit 1 containment annulus area were in error. The " diagrams" used were applicable to Diablo Canyon Unit 2, but were identified for use in the Unit 1 seismic design.
Subsequent investigation into this issue revealed additional design errors.
This resulted in suspension of the Diablo on November 19,1981 Canyon Unit 1 fuel Icad and low-power operating license (Unit 2 was g
still under construction and Fad not yet received an operating license).
Diablo Canyon Units 1 and 2 utilize pressuri:ed water reactors and are located in San Luis Obis::o County, blifornia.
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Nature and Probable Consecuences - On September 21, 1981, an engineer employed by PG&E in the hanger design group, was performing work for Diablo Canyon Unit 2 in response to NRC IE Bulletin NO. 79-14 (" Seismic Analysis for As-Built Safety-Related Piping Systems").
This work
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involved the use of " diagrams" of the containment building annulus area.
The engineer became suspicious that the supposed Unit 2 " diagrams" did not accurately represent Unit 2 structural configuration.
On September 21-22, 1981, he continued to investigate this apparent dis-crepancy and brought it to the attention of his immediate supervisor.
On September 24, the responsible Senior Civil Engineer had been informed of the apparent discrepancy.
On September 25, second level PG&E management were notified and they in turn contacted their seismic design contractor, URS/ John A. Blume and Associates (URS/Blume).
URS/Blume confirmed that the wrong " diagrams" had been used. On September 26, PG&E management continued to evaluate the problem.
On September 27, the Plant Superintendent notified the NRC Senior Resident Inspector that a problem did indeed exist.
O NRC investigation into the situation disclosed the following:
(1) The " diagrams" were developed at PG/,E and apparently given to URS/Slume on March 8,.1977 for their use in the development of vertical seismic response spectra for the Unit 1 and Unit 2 containment building annulus areas.
(2) URS/Blume, when given the " diagrams," knew the "diagrar:s" were applicable to Unit 2.
However, they werf net aware that the Unit 1 and Unit 2 con-tainment annul;s areas are mirror images.
Therefore, during the
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[7590-01] v development of the associated seismic response spectra, URS/Blume assumed that both Unit 1 and Unit 2 containment buildings were of the same configuration.
(3)
FG&E., upon receipt of the seismic response spectra in May 1977 and July 1977, developed by URS/Blume, assumed the spectra and associated contai' ament annulus frame orientation " diagrams" were for the Unit I centainment since it was identified as such by URS/Blume.
In actuality, the containment annulus frame orientation " diagrams" represented the Unit 2 containment.
PG&E, in turn, performed subsequent design calculations for Unit 2 and, thus in turn, erroneously used Unit 1 containment annulus frame orientation
" diagrams" for the development of Unit 2 design requirements.
Upon confirmation that wrong " diagrams" were used in th d velop ent e
'u,i.t'urted, w M-weletals af
't4*f.uipmeft of Unit 1 gn gquireme.nts.]G.&E.re: :b::d t': S:';r p' : :-t:
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,using the appropriate containment annulus frame orientation " diagrams'l aad r estmolyees
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d:::m'n:d that, as a result of the error, modifications were required to
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b a nurker/r ehors,m be made on i Unit 1 pipe supports. These modifications involved such o:
actions as adding snubbers, changing the snubber size, adding braces, M onuhses.*
.m.c'dic mm're replacing structural members, and stiffening base plates.
bemods ht" drany.4 Subsecuent investigations by the NRC, and design reviews by PG&E and their consultant have identified a significant number of additional design concerns.
These include:
failure to use the latest revision of the vertical response spectra in design.of conduit and cable tray supports; incorrect n ight distribution used'io determine the containment annulus vertical seismic response s;ectral curves; erreneous spectra used to
[7590-01]
complete safety injection piping problem; and two small. bore piping snubbers required by seismic analyses were not designed or installed..
The design reviews are continuing at this time.
Cause or'Causes - The problem related to the use of the wrong " diagrams" appears to have been caused by the informal manner in which certain
. data were developed by PG&E and transmitted to URS/Blume and the lack of independent review of these data within PG&E prior to submittal to URS/Blume.
Identification of the additional design errors indicates a more general failing' in the licensee's design quality controls for service type contractors.
Actions Taken to Prevent Recurrence Licensee - At the end of September 1981, the licensee verbally requested the services of a consultant, R. L. Cloud Associates, Inc. (R. L. Cloud) to conduct a seismic design review to determine if other errors had been made in the seismic design of Diablo Canyon Unit 1.
This request was subsequently formalized by the licensee with the issuance of a contract to R. L. Cloud.
(HustEG o863,Issw.f)
NRC - In October 1981, the NRC conducted a special inspection,at the PG&E URS/Blume offices in San Francisco, California to evaluate the quality assurance programs and othhr management control systems in effect at PG&E and at URS/Blume during the period from 1970 to present; the extent to which these quality assurance programs and management control' systems were in;:lemented as they relate to the development, transmittal, and use of safety-related design informatich; and, how the identified seismic problems involving the Diablo Canyon containment building annulus areas e
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[7590-013 5-were caused and subsequently discovered.
The results of this special inspection indicated, among other things, that required quality controls were not imposed upon PGSE's safety-related, service type contractors until late 1977 or early 1978; and, many of the work activities perforued by PG&E with regard to the URS/Blume contract were performed in an informal manner.
On November 19, 1981, an order was issued by the Commission which suspended License No. OPR-76.
DPR-76 had been issued on September 22, 1981, and had authorized fuel loading and the conduct of tests at up to five percent of rated power at Diablo Canyon Unit 1.
This order, in conjunction with a letter from the NRC Office of Nuclear Reactor Regulation, defined what would be required from PG&E prior to start of fuel loading and prior to power operation above five percent power at Diablo Canyon Unit 1.
These requirements included the completion of an independent design verification program for seismic related service contracts.
In conjunction with this the licensee was directed to submit a detailed program plan for conducting the design verification and to supply infonnation that demonstrates the independence of the companies proposed to conduct the independent verficaticn.
The licensee has submitted a program plan and information regarding the independence, of the contractor (R. L. Cloud) selected by the licensee.
Prior to an NRC decision on the acceptability of the program plan and the designated independent contractor an additional issue arose. This issue involves the licensee's review and comment on draft editions of the
' independent consultant's report prior to the submittal of the report to the NRC, and statements made by,1[censee representatives to the NRC wnich led the NRC to believe that the licensee had not seen drafts of De issue :as the subjecb eb**c:r NRC investigation. Findin s w ;_- : ;',
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of H116 Inw.sbigation *cyc conbuirnd % NogEG$ 0%2,.DsoUeslands, $
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Future reports on M fi.....,; er O.
' ;;:*4 7*' =, acceptability of the program.plare and the independent contractor will be made, as appropriate, in. the Ouarterly Report to Congress on Abnormal Occurrences (NUREG-0090 Series).
Dated at Washington, D.C. this day of 1982.
Samuel J. Chilk Secretary of the Commission S
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W TELEDYNE l
ENGINEERING SERVICE 130 St CCt.0 mENUE w<MAM MA554CMUSE*TS C2254 (617) 890-3355 TA s (710,328 75~,8 February 18, 1982 5511-7 CONTROLLED DOC!JMEliT Mr. G. A. Maneatis Senior Vice-President, Facilities Development Pacific Gas and Electric Co.
77 Beale Street San Francisco, California 94106
Subject:
Statements Regarding Potential or Apparent Conflicts of Interest
Reference:
EP-1-007, DCNPP Design Reverification Program
Dear Mr. Maneatis:
In accordance with the referenced procedure, Page 6, each of nine employees of Teledyne Engineering Services (TES) presently considered for assignment to this project has filed with the TES Personnel Relations Manager a signed statement regarding potential or apparent conflicts of interest, Figure 2.
As required, each employee has stated that:
(1) He or she has not been involved with or related to the engineering or design of DCNPP except for work related to I&E Bulletin 79-02 which is not part of this reevaluation effort.
(2) No member of his or her immediate family owns any beneficial interest nor is employed by PG&E.
This information will be updated as appropriate.
Very truly yours, TELEDYNE ENGINEERING SERVICES h
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William E. Cooper Project Manager WEC/lh cc:
F. C. Bailey (TES)
D. F. Landers (TES)
C. K. Combs (TES)
R. R. Fray (PG&E) a' i
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