ML20209B360

From kanterella
Jump to navigation Jump to search
Forwards Summary of Revised Review Plan for Design Verification Program.Meeting W/Identified Personnel to Discuss Activities Underway Recommended
ML20209B360
Person / Time
Site: 05000000, Diablo Canyon
Issue date: 04/28/1982
From: Miraglia F
Office of Nuclear Reactor Regulation
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20209B094 List: ... further results
References
NUDOCS 8205050193
Download: ML20209B360 (5)
v • d • e


Text

--

.,6-M

o UNITED STATES l'

  • _, o 7 ',,W NUCLEAR REGULATORY COMMIS'SION

{-

,l,

,I WASHINGTON, D. C. 70555 '

i,,- %,/

APR 2 81982 MEMORANDUM POR: Darrell G. Eisenhut, Director, Division of Licensing, NRR THRU:

Robert L. Tedesco, Assistant Director for Licensing,{DL FROM:

, Frank J. Miraglia, Chief. Licensing Branch No.

3.. DL

SUBJECT:

REVIEW PLAN FOR DIABLO CANYON UNIT 1 DESIGN VERIFICATION PROGRAM The staff has reviewed the Teledyne (TES) plan for the Diablo Canyon Independent Design Verification Program (IDVP) - Phase I and the PG&E plan for its Technical Program. With some minor changes both plans have been found acceptable and a letter to PG&E has been prepared. Since the activities under both programs have already been ongoing since last fall and in some cases are nearing completion (e.g., QA review by R. F. Reedy under the IDVP and annulus review by PG&E under the TP) it is important that the staff promptly perform the detailed review of these activities.

On February 25, 1982 we issued for comment a proposed detailed review plan for the entire Diablo Canyon 1 Design Verification Program (DVP).

The emphasis on certain aspects of the original program has changed and we have redefined those staff activities that must be completed in the near future. Attached is a summary of the activities, including proposed assignments for conducting the review.

Before proceeding with fine tuning and developing a computer tracking system, we would like to discuss them with you.

We also'recomend a meeting with the staff identified in the attached chart to discuss the activities currently in progress.

FrankJ.Midhglia, nief Licensing Branch No. 3 Division of Licensing rlf-

./poWD,p

$q t

x 7

..y.

7,,, '.4 ! '

Diablo Canyon Unit 1 Design Verification Program Near Term Staff Action Items 1.

Decision on TES Plan for IDVP Phase I (1) Sta'ff review. complete, input to PM (2) Memo to Denton with proposed letter

~

to PG&E and TES (3) Letter to PG&E and TES.

2.

Decision on PG1E Plan for Technical Program (TP)

(1) Staff review complete, input to PM (2) Memo to Denton with proposed Itr.

to PG&E and TES (3) Letter to PG&E and.TES 3.

Scope of Phase I (1) Staff meeting on (a)

Reedy QA audit reports (b)

Results of QA meeting on 4/1/82 (c)

Implication of QA findings on Scope of Phase I (d) Staff recomendation for scope of Phase I (see Region V memo of 3/29/82; for example, identify elements of Phase II to be done prior to fuel loading, accelerate Phase II program review and approval (2)

Prepare memo to Denton with staff recommendation (3) ' Prepare letter to PG&E on revised scope of Phase I

3 L.

,Q.5 2-4.

Staff Assignments-i (1) Approval of assignment of individuals to Diablo Canyon design verification effort (see attached chart forproposed, structure)

(2) Assignmentsofindividualsto specific activities in the IDVP and the TP (3) Define' specific activities to be followed by Region V (4)

Identify Region V activities that need support from NRR and IE (5)

Develop schedules -

5.

Review of IDVP and TP Activities o Determine current status of IDVP and TP activities based on latest semi-monthly reports o Determine current status of 1

errors and open items 'on basis of listings provided.by Cloud.

TES and PG&E in their semi-monthly reports and evaluate-proposed resolutions o Meeting with PG&E and TES, if 4

necessary, to identify status of activities Review expansion of s' ample o

size initiated by TES or PG&E o Review QA audits completed by Reedy and prepare evEluation o In depth review of IDVP and TP activities performed by PG&E TES and others at their offices o Inspection of design modifications at the site

+

D

., _.., - + -

~~h=*-

.i *. <

6.

QA Program proposed for Tes plan o Determine acceptability of QA activities proposed in TES plan o Request and obtain, as necessary, copy of Qk manuals for conduct of IDVP by TES, Cloud, Reedy, PG8E.

o Review QA manuals o Request information from Region IV based on'its inspection of TES QA program o Prepare written findings on review of QA manual and on audit of QA implementation 5

s e

O I

3 1

i

,, _, __ _ _.i' 1 7

~ ~2 ~ 7 ~ '

., ' l ~'

.~

T~

]

,;-s. :~-

. ~

NRC Review of Diablo Canyon Unit 1 Independent Design Verification Program es,,

4p' IDVP Policy 4

Review Group D. Eisenhut R. Vollmer J. Crews Tech. Direction Project Management R. Vollmer D. Eisenhut or or J. Knight R. Tedesco Project Branch LB#3 PG&E F. Miraglia Teledyne H. Schierling et.al.

NRR I E, OELD Region V R. Bosnak - Mechanical J. Fair

  • L. Chandler T. Bishop F. Schauer - Structural B. Jones P. Kuo -

EHL, "

W. Haass -

QA G. Bagchi - EQ M. Messier - Financial K. Herring *- Seismic Brookhaven

  • Will provide support to Region V

[**,

o UNITED STATES 3

a NUCLEAR REGULATORY CUMMISSION

[,

3

,I REGION V 0,

g 1450 MARIA LANE. SUITE 210

,e WALNUT CREEK, CALIFORNI A 94596 MAY 11 1992 MEMORANDUM FOR:

F. J. Miraglia, Chief, Licensing Branch No. 3. DL FROM:

J. L. Crews, Director, Division of Resident, Reactor Projects and Engin' ering Programs e

SUBJECT:

REGION V INSPECTION OF ACTIONS RELATED TO THE DIABLO CANYON REVERIFICATION PROGRAM The enclosed memorandum provides a description of Region V inspection activities related to the Diablo Canyon Reverification Program.

The results of this inspection effort may ultimately be reflected in a Safety Evaluation Report issued by your office. Accordingly, it is requested that you complete the following actions regarding this effort:

1. Coordinate with NRR Division of Engineering and Division of Licensing and IE to determine if the inspection program, as described, is compatible with their planned actions.
2. Identify, as appropriate, additional areas where R' gion V e

inspection effort is requested (regarding the Diablo Canyon Reverification Program).

3. Identify any specific items, within 'the planned inspection scope, for which you, NRR:DL, NRR:DE, or IE request special emphasis.

It is requested that your response 'to the actions identified above be provided to this office by May 25, 1982.

Please contact T. W. Bishop (FTS 463-3751) if you have any questions regarding this request.

I

/

i: //

dL C tor i

ividionofResident, Reactor Projects and Engineering Programs

Enclosure:

RV memo T. W. Bishop to J. L. Crews,

dated May 10, 1982 I

cc:

D. G. Eisenhut, NRR, DL if R. H. Engelken, RV Qk

('{(

m E. L. Jordan, IE I1 D R. H. Vollmer, NRR, DE 3 R g

um 7

./.

/.d-A M kme4 1..

J'..

% ~,94 atc

',,(

Q UNITED STATES p 3 f(jj" g -

NUCLEAR REGULATORY COMMISSION 7, < *. 6 2

yy.~ f.r/g WASHINGTON. O. C. 20555 N *' *#

~

February 1, 1982 CHAIRMAN f

d The Honorable John D. Dingell, Chairman

$cawe LeNer b k.'0 Hinger C =sittee on Energy and Comerce United States House of Representatives.

Washington, D.C.

20515

Dear Mr. Chairinan:

We share the concerns expressed in your November 13, 1981 letter regarding the implicat6n of the recent seismic design errors detected at the Diablo Canyon nuclear power plant.

The implication of.these errors has been and will be thoughtfully considered by the Cc.:nission.

~

The timing of the detection of these errors, so soon after authorization for icw-power oper'ation, was indeed unfortunate and. it is quite understandable that the Congress' and the public's perception of our licensing process has been adversely affected.. Had this information been known to us on or prior to September 22, 1981, I am sure that the facility license would not have been issued until the questions raised by these disclosures had been resolved.

Because of these design errors, on Nov' ember 19,1981 we suspended.

Pactric Gas and,iectric Company's (.pGiE) license pending satisfactory c

Completion or tn,e rollcwing:

1.

The c:nduc of an independent design raview program c[ all safety-related activities performed price to June 1,1978 under all seismic-related' service contracts used in the desien of safety-related struc ures, systems and c m;0nents."

2.

A technical re;0r: that fully assesses the basic cause of ali design err:rs identified by this ;r: gram, -he significance f :he errors found and -heir impa:: on facility design.

3.

?GiE's c nclusicns of the effectiveness of the design verifica:icn program in assuring the adecuacy of facility design.

4 A. schedule for compisting any

dificati:ns to the facility that are required as a result of the design verification pr.cgram.

In addi:icn, ne C:.Thission ordered ?GiE. o pr: vide..dcr !GC review and a p; r:v,ai :

A :e;:-i;;':n sr.d cis: ssi:m.:f re ::r;;ra:e qualifica:icns cf -he

:1 3 :- :: :tr'es :ra: G i w:ulc pr:;;se :: carry cut the 3' M 0opl g f.

g 3

O, f(

/,..

z independent design verification program, including information that demonstrates the independence of these companies.

2.

A detailed program plan for conducting the design verification' o

program.

In recognition of'the need to assure the credibility ~6f the design

' verification program, NRC will decide on the acceptability of the compan'ie's' proposed by PG&E to conduct this program after providing the Governor of California and Joint Intervenors in the pending operating licensing proceeding 15 days for coment.

Also, the NRC will decide on the acceptability of the plan proposed by PGLE to conduct the program, after providing the Governor of California and the Joint Intervenors in the,pending operating license proceeding 15 days for coment.

Prior to authorization to proceed with fuel loading, the NRC must be satisfied with the results of the seismic design verification program and with any plant modification resulting from that program that may be necessary prior to fuel loading.

The NRC may impose additional requirements prior to. fuel loading necessary to protect health and safety based upon.its. review of the-program or any of the information.

provided by PG&E.

This may include some or all of the requirements specified in the letter to PG&E dated November 19,,1981.

Responses to each of the four questions in your letter are enclosed.

A decision to perr.it PG&E to proceed with fuel. loading will not be made until all the actions contained in the Comission's November 19, 1981 Order are fully satisfied.

Sincerely,

=

q/

b)<

Nur.:io J. Pallacino cc:

Rep. Carlos M :rhead

Enclosures:

y'Q'j

1. C:n.ission Order, dated 11/19/81
2. L:r fr:m Office of Nuclear Reactor Re;ula:icn, NRC co F35E dated 11/19/51 d 42 %j
3. Resp:r.ses to Questier.s O.N(tv:cN o *

,.,,,,y

/

AC,fM.rt, 3_..

Please provide the criteria to be used in assuring that the prop'osed audit wil.1'be '

Question 2:

" independent."

The competence of the individuals or companies is the.most important. factor in the Resoonse_:

Also, th,e companies selection of an auditor.

or individuals may not have had any direct previous involvement with the activities at Diablo Canyon that they,will be reviewing.

In addition, the following factors wil'1 be considered in evaluating-the question of i n d e p e nde r.ce :

Whether the individuals.or companies involved had been previously hired by 1)

PGAE to do similar seismic design work.

invo5ved had been Whether any individual previously employed by PG&E (and the 2) nature of the employment).

Whether the' individual owns or controls significant amounts of PG&E stock.

3)

Whether members of the present household of individuals involved are emp. layed' by 4)

PG&E. -

Whether any relatives are employed by 5)

PG&E in a management capacity.

)

In addition to the above considerations,'the following procedural guidelines will be used to assure independenee:

An auditable. record will" be. provided of all comments en draft or final reports, 1) of such any changes made as a resultcommen issue changes; or the consultant will (without pri r only a final report licensee comment).

NRC will a'ssume and exercise the respon-sibility for serving the report on.all 2) parties.

9 0

SI n'i llrSil!,\\il IA\\

i

(,y:j k

( ' i i
, '. 6 n u, m

[3 icT n

l iuoum (3,.c w%:mLTir6H Com:ss:Cu

. g

{1 % kvb C

v. a~.c ga

~

iYb E cl N 4 1

~

P h

x o s.S S

~.

  • te.*._r-d 2 y

j t

MEETING WITR PACIFIC GAS AND ELECTRIC COMPANT TO DISCUSS SEISMIC DESIGN REVIEW, DIABLO CANYON tmIT 1

?

.sr g*

m

(,1 m. Marcir 25, 19.82 PAGZS: 1 thru 177

.r.

Bethesda, Marylar.d.

1 v~

[

i 1

e-

_LLDERSON PIPORTD'G

(..-

~

1 2 A n., s.w. w>< '.5-- -.n. C.

Ico24 4 c c vt.

2 1

['

Oel.eph:~.c : (202} 554-2345 i

l v

l i

l

u."

i 1

MF.. MIPAGLIA:

Ona item that cana up was an crorcssM 2

of clear indication of what the staff requirerents are for the can#1MteSbSielif's AI think the s'taff would be 3

4 ' receptive c,o each of the progran plans describing the proceduri i

5 and process that you proposed to use relative to these conflic-e l

n j

6l of interest statements and the criteria which you would use to 5,

7 have an individual fill them out, the kind of records that yes

%'j 8, would propose to caintain and igplement that requirement and i Jy9 the procedures are explicit' enough and acceptable to the staf2

^

z_

10 We understand that you have a process an'd that you have criter z

by which you are going to' implement that process.

j 11 3

f.12 P.R. COOPER:

Tha't one givEs 'ce a lot of difficulty.

=

E 13 Individual coccanies choose to handle that by different techni

~=

l 14 That has to be demonstrated to date in this program, and I thi c

these techniques together, but it's

=

,2 15 it's possible we might get f_.

j 16 administrative type of coc=ission requirement, and until I has vs l

d 17 ' more guidance in -- than I have seen put forward at this ti=e.

E 18 noticing that there are differences in the way we handle the

~

l 19 thing, our response to what we understand to be the requests.

-_n difficulty responding to that at least in thc 20 p would have great 21 kind of time frames we are t'alking about for the plan. submitta S

22,

I would rather -- perhaps we could eventually incluc i

23 it as one of the things that I have called proj ect procedures i

24 l program procedures, but I certainly wouldn't want to cc= nit t-3

~

25 ;j this for next week, and I cight have trouEle even after that.

I C.

I 4

ALDERSON REPORTING COMPANY. INC.

i

%~Q

.m_

.. m x _.,.. m u y g 3...,, g. g.,.. g g.,,,,,

m.-

.-g v e'. *,,, u.

s t,o1

.g,..

f.

/

.L.

s. -

163' c

'l I just -- mayb'e ~ some who have been involved in this issue longer

,2 than I have a thought on it.

~e 3'

' Bob?

- MR. CLOUD:

Yeah.

Having enjoyed the benefits of

'l" l

4 5, participating. in this program for some period ~ of time, my first.

p j

6 question is would you want such procedures to be addressed to all N

M',

7, individuals that might be involved?

j 8l

'M MR. MIPAGLIA:

i think what we are saying is that we d

=;

9' would,1 eave it to you--to--proposeth.hdada.-by_-wh%h-you wog_

=

10 f ns&i;what-fndivi-duals"you-woufd1TdEEtih"-=cpcsa '-Mt_crggg

=.

g 11-anci-irrdIEate'thatuy6u-.wiQq~cag=es.-to.igLtament-tnis-:t, i

3 l

.*j. 12

- 2*fdmfaarprograr4Hd that y:cIEGLIlT6aIiirtTfn_._ _...,.,

hem

-some--kind' o-f

.E y

13 dirYt crve:iPl

=

i j:

14

>9.

CLOUD:

I wouldn' t have any obj ection to that e

2 15, except that I would proo. ose that such procedufes should be

]

16 confined to the management offices involved with the program.

G 6

17 '

Just as a matter of practice.

Don't misunderstand me.

I don't

\\

a

.=.

l y 18 ' have the. -- you know -- the son-in-law of any of the PG&E people l

E r

19 on my staff.

I am j us t saying as a =atter of practice that it'sl M

1 I

20 1 going too far that each ' professional not own stock in PG&E,. for l

21 exa:ple.

It's sort of -- to quote an eminent mecher of the NPC 221 staff, it would be contra y to the A=erican way.

[

L.

23.I MR. C00?I?.: - Let ce cite an exacole.

I showed a i

t i

24 Figure 1 and 2 today.

I had scribbled those out, and I went to 1

25; Ren '4:ay and I said, '4:ay, you got secebody -- Ron, can ycu get l

i i

4 A i n r = m.w = = = n o - i v e.e m... c v. i u e L:

Y

-I l som3 body thoc can letter these j

j 2

, in this report?

}I He said yeah, and one of our co-op studen 3

, it; and about i

ten minutes after they were riven to ce, the (

4 engineer in the program care in and s' id I'c.g.cing to cite -

a l

g 51 6 l before he did it,for not having these gu I'

8

}

]

1 and I said, Gee whiz, don't I even have t.

I llcoget R

}

7 that guy to fill out the thing?

I got.in this bind i

5 i

..TT j

R 8

had Ron~do it five minutes age,.

i d

d 9

z.

He said, Okay.

G 10 I'll give you two days.

I said, e

~

, He will have gone back to school in two days.

E g.11

- - - (Laughter)

'W'-

y 12 MR.. COOPER.:.

This' is how ridi~cEilous it-is really 5

j 13

=

I. getting as we are trying to do this thing threugh what we arc 14 i cocmitted to today, and guidance -- Eezi broadrpiiidanqe-irm

_t'

.R 15 MR. HOCH:

E Can I ask ?ou a question?

I don't knc j

16 _if-I reviewed all these things.

Hive you found any of your s

y 17 employees who have a conflict yet?

'~

18 MR. COOPERi, No.

}

19 MF. CLdUD:

No, n

20 MIcNeh6'We*4e-wigLgg.come 31pMTh 21 somethirgTthat-4-tWhIII.*

k 22l MR. COOPER:

Excuse ce.

The answer would have bec 8

23 ' yes only -we -knew better than to ask him to fill out the form 24 l because he worked on Diablo Canyon.

Now -

g 25,4

~.

j RR. DENISON:

The answer is yes in one instance.

1 a

ALDERSON REPORTING COMPANY. INC.

s

,, '- 9 EE lg,3,'M j [1e

' b.' '* " Ud - * ** ' ' ' _

-~ _ - ;..-....

q;.y,,,

g i20 9

..i

n 16'5 a

~

t

.)

I t

1 father owns sixty-three shares of s tock.

~

i~

-2'.

FF. BF.0WN:

I don'c think anyone is satisfied'with the, 3, ultimate resolution of.-- the go'vernor, the joint intervenors.--

g 1-4 ' we all would have liked it differently, but I think the staff better be cautious in not 'getting into a position and backing g

5 g

j 6

down just because somebody suggests that it might not be "

C 7 j convenient.

The bottom line was t'dat there were pretty l thoroughly understood guidelines.

W j

8 Nobody liked exactly what d

d 9, they were because they came out of different s tuff, but I think j

i 10 t

it would be proven and we would insist from a literal reading of. i E

~

j 11 l what the cotsission-did; th_me hmme-p~aop tewccQg it

'i 12 ' conftter_of-interesc;rtdefttrethby-thee,n # es ton sent to the z

~--

..~--.n,..

. +.

S 13 w6r M P3f thd~cli2fra'as M ~~Pifon't recall the subsequent

=

E 14 l extensive conversation that went on, and this ended in two days b

i si 15 - of incenvenience.

That is something thEt we have to live with l

I 5

l i

j 16 or we will enp up quibbling over something that we should have

-A 17 long behind us.

2 s

18 MR. VOLLFE.P.:

6.

I think those guidelines were fairly '

I t

[

19 clear.

I don't thi.1k they caused the probler.

I think the t

n 20 proble: being posed was one share of PG&E or a hundred~ shares is i

21 a conflict of interes t or things of that nature.

Is that right? l 22,

I hope that there is no question in anybody's mind that people I,

23 who are part of th'is prograc sho.uldano.t-ce;-reviagng-worjnthat 24 they.-vere;.a-carcyc.e,q:.be. fore, and: that..has.Jeen ma.2.-.em.m ar all along.

d cle y

m%.

. p..

4 i

i l

25, I hcpe that is not the proble-

e b

.y.

s.

s

1. I MR. FRIEND:

Doorn't sc;m to hava onything to do K 2 Istock ownership whatsoever.

3 MR. VOLLMER:

No, but that %7 s another :r.atter that l

4 lbroucht up in a nur3er o f cther meetings to' vhich yo u weren't a pa e

5 MR. FRIIND:

But the whole dialogue has been about

~

e j

6 owning stock and financial interests, and you just enunciated l

R 2

7

'seme different rules.

'I;t3 ink 7 thaj:fs - o rgb ab ly ~w~ny.9itrs"

~

.4 8

8 imoor. tant"~tF.iE~s-bu do give. us.,some cuidance...

m-.-

M.ayb e.b.o. th-o f

.~

____.,s-~.,_..-

3:i 9

app [_Maybe only one.

N 5

10 MR. MIRAGLIA:

Both;co f-themy do. apply"a sMtc.isg.:,

3 G

11 c.u.,rrentlyNritten __ _-We-will-do3that.

e 3

ti 12 3

MR. CLOUD:

I.would say that the issue of persons

i g

13 reviewing wrk that they have participated in is a non-issue.

=:

14 ene ever does that. ' What I'm suggesting -,and -perhaps we ar b

15 going overboard when we require that every person involved in a

j 16 project not own stoch, not have a relative in PG&E, et cetero

d p

17 mean half the people in the Bay area worked for PG&E at cne 5 Ei E

18 or have relatives th' t worked for them or whatever.

a

  • =

t 19 :

MR. SOCE:

As an alternative to -- I'm a little un 5

I n

20 If we didn't take advantage of what you stated or the program 21 people didn 't take advantage of what you stated with respect 22 l putting a procedure together and scating what the procedure v 23 in the 'n ear term at least, is it acceptable to just centinue P4 d the policy of having everycne do what they've been doing?

T I

25 j is, sign th"e statement and so forth?

I' Il l

ALDERSON REPORTING COMPANY, INC.

.-. ~.

T -.

=....

s 3

.e t.

8 yg a

't V

1 MR. MIRAGLIA:- Yes.

s 2

MR. HOCH:

.Because in the short term that may be the 3.

mos expedient way to-handle it.

~

~

e 4

MR. MIRAGLIA:

Yes.

s-5- ;

MR. COOPER:

a

'If we can agree on that, I.will tryfto. '"

6-put together a program procedure as defined in our program plan.Y e

4

-n It's the.implemen.ta.t.io. n of. t..he criteria.

7 u

t,

-I am concerned about, 4.

t i

8 l

3 and I will try to put together,,such, but I. won!tdimplement it 1

i h

9 l prior to sending it in for your comments because it is in p

p i

i h

E 10 E

I response to a direct procedural issue that -you folks have raisede. ;

j '1,! Ordinarily I would plan to imp,lem.ent.a_ procedure.an.d. send it to li e

n i

12 you-for information.

?

5 13 MR. CLOUD:

I think we could right now with' complete 5

14 l and full assurance know that no engineers 'wil1~ be involved in a

t 15.

reviewing work tihat they have done.

i 16 MR. COOPER:

That is true.

3 y 'j7 MR. CLOUD:

So -

and I would suggest that sooner or i

j gg later people will' have to accept the fact that most of the f_19 people doi.g this are honest men.

20 MR. MIRAGLIA:

There was scme comments raised by the L

21 parties, and I think we said with respect to undecketed reports

, i 22 ' that j

we are still -- there is still a question that the staff 23 had on February 3rd and that PG&E is attempting to deal with.

j l'

Again, I gur_ss the apprceriate plan is to address that matter to l

24

{

25 l. scme degree as well.

6 d

.,f

--- -~~

- ' ~ ~

L

eauwfuuuuto 7::: ' 1<

- NUCLEAR REGULATORY CO'MMISSION -

hhh,h.3 A j f-.

-I

,,,n

' REGION V :

1..

14so MARIA.ANs.suira 210 p

.V, WALNUT CREEK.,CALIFcRNIA 94S96 j

- M4Y 1 I 1982

' MEMORANDUM FOR:

F. J. Miraglia, Chief, Licensing Branch No. 3. ' DL -

-~

FROM:--

-J. L. Crews, Director, Division of Resident, Reactor Projects and Engineering Progr'amsz

~

SUBJECT:

REGION V INSPECTION OF ACTIONS RELATED TO' THE DIABLO CANYON REVERIFICATION PROGRAM The enclosed memorandum provides a description of Region V inspection activities related to the Diablo Canyon Reverification Program.

The results of this inspection effort may ultimately be reflected in a Safety Evaluation Report issued by your office. ' Accordingly, it is requested that you complete the following actions regarding this effort:

1. Coordinate with NRR Division of. Engineering and Division of Licensing and 'IE to determine if the inspection program, as described, is compatible with their planned actions.
2. Identify, as appropriate, additional areas where Region V.

inspection effort is requested (regarding the Diablo Canyon Reverification Program).

3. Identify any specific items, within the planned inspection scope, for which you, NRR:DL, NRR:DE, or. IE request special emphasis.

It is requested that your respolise to the actionsridentified above

~

be provided to this office by May 25, 1982.

Please contact T. W. Bishop (FTS463-3751) if you 'have any questions regarding this request.

{

- b e

(, u/

I. L Crjews, Director ivi ion of Resident, Reactor Projects and Engineering Programs

Enclosure:

RV memo T. W. Bishop to J. L. Crews, dated May 1.0, 1982 r

cc:

D. G. Eisenhut, NRR, DL l

R. H. Engelken, RV E. L. Jordan,'IE-R. H. Vollmer, NRR, DE 4106lig5547 L--

A

. = - -

7_

.,7_

.c

weWSAU m

.W

e ",

ez

. fluCLEAR RECULATORY COMMISSION

~

' 5. ".:.

-I REGION V a.

  • w y%/

7 1450 MARIA LANE,SulTE 210

,e, W*ALNUT CREEK, CALIFORNIA 94596 -

MAY 101982 7;

MEMORANDUM FOR:

J. L. Crews, Director, Division of Resident, React'or-Projects and Engineering Programs FROM:

T. W. Bishop, Chief, Reactor Construction Projects Branch

SUBJECT:

REGION V INSPECTION OF ACTIONS RELATED TO THE DIABLO CANYON REVERIFICATION PROGRAM In anticipation of a request to support the office of Nuclear Reactor Regulation in the Safety Evaluation Report (SER) for the Diablo Canyon Reverification Program, it is suggested that we clarify our areas of input.

Our input should naflect, among other things, the results of our inspections.

Accordingly, it is intended that, within Region V, the scope and responsibilities for inspection /SER input will be as identified below.

It-is expected that Headquarters support (IE/NRR) will be provided for this inspection effort.

1.

Implementation of Independence Requirements for Technical Reviewers Selective examination of individual technical reviewers

" independence statements"; selective examination of employment resumes to confinn " independence statements"; selective interviews with technical reviewers to confirm " independence statements" and assess the reviewer's freedom to fully explore concerns.

This process shall be performed for each organization involved in the independent reverification (Teledyne, Stone & Webster, R. L. Cloud Associates, and R. F. Reedy, Inc.)

Lead Responsibility:

J. H. Eckhardt 2.

Examination of Implementing Procedures for Controlling Work Activities Verification that appropriately approved procedures have been developed to control work activities; selective examination ~

cf procedures to assure compliance with approved program plans, SAR/ Tech Spec requirements, NRC Order, NRR letter of Nov. 19, 1981, and pertinent QA requirements.

Mr(:

f u ~ u r, L r,n L G

~ ' ~ ~ '

/-

1~

~ ] f4

.. ~,,.. _..

f.

, f *.fl '

'i m

p

.. f J. H, Eckhardt

2:--

r[*,.

^

This vrocess should _ be performed-for each organization involv

~

actio'ns.(Teledyne, Stone & Webster, R. L o

/

R. F. Reedy, Inc., and the. integrated PG&E/Bechtel organ c-Lead l Responsibility
iP.'J.Morrillj, D'

3.

Examination'of Implementation of Procedures for Activity and-4 Program Control Verification that' independent reverification activitie' 'and followup / technical program actions are performed in accordance s

with controlling requirements (approved program plans and procedures, SAR/ Tech Specs, and QK documents).

Examination is to be achieved by: auditing to determine if personnel are knowledgeable of program requirements; and auditing

}.

implementation of. controlling requirements.

This process should be performed for each organization -

(Teledyne, Stone & Webster, R. L. Cloud Associates, R. -F.

I Reedy,, Inc., and the integrated PG&E/Bechtel organization).

L'ead Responsibility:

J. H. Eckhardt 4.

. Assist NRR Reviewers in Examination of Technical Adequacy of On-going Work Activities i

Verification of technical adequacy of independent r[ verification L

selective sampl.ing of individual work items. activities Examination should : assess such things as depth, scope, and thoroughness i

of a review activity; appropriateness of engi i

and adequacy of corrective / followup measures.neering assumptions; During this examination the inspectors shall be alert for, and identify, 4

any obs_erved areas where undue pressure is applied to technical personnel.

This process should be performed for each organization (Teledyne, Stone & Webster, R. L. Cloud Associates, R. F.

Reedy, Inc., and the integrated PG&E/Bechtel organization).

Lead Re3ponsibility: NRR (Regional contact:

P. J. Morrill) l' 5.

Examination of Plant Modifications f.'

Verification that plant modifications i

accordance with approved design docume. are accomplished in nts and in accordance with established quality requirements.

Examination shall i

invol.ve a large percentage of field modifications and shall

!L include physica~l inspection of the nodification and. examination of quality related mcords.

Sample selection shall include some of the specific work items examined under paragraph 4, above.

t Lead Responsibility:

J. F. Burdoin V

~

^

~

s

-e, g

J. L. Crews -

Many of the above inspection activities have been in progress for some time and are documented in Region V inspection reports and NRR/IE trip reports.

This form of documentation will be continued, with a sumation to' be provided in the Region V SER submittal.

~

i I.%!! 5.h T. W. Bishop, Chief Reactor Construction Projects Branch cc:

J. F. Burdoin J. H. Eckhardt J. R. Fair, IE K. S. Herring, NRR P.'J. Morrill H. E. Schierling, NRR D. M. Sternberg T. Young G

go

=

es 9

4 eee.

e e===e.eemmasam &

  • e N
  • e em euw w=w-M-
  • e een e

-+-oc%

% w wm..

7 gpg 9 4 g tic W k PE10RN:Otm FOR:

Richard F. Yo11rer. Director Division of Engineering THRU:

Daniel P. Muller, Assistant Director for Enviroc xntal Technology FPOM:

Faurice Pessier, Senior Antitrust Econoreist Antitrust and Econonic Analysis F. ranch SUPJECT:

CRITEP.IA TOR FIMA!;CTAL It.TEPENDEFCE OF P.EVERIFNATIO" TWC The ~ purpose of this x=o is to cl.arify the criteria used to detemine the financial independence of the seism.ic design reverification teams proposed by applicants. At the Parch 25 PC3E r.eeting. Staff indicated that it wuld provide the criteria (both technical and financial) hy which a contractor would be appreved (see pp.162-67). If the criteria for financial independence is stated, we and the applicants should be

-in a better ocsition to judge the' acceptability Uf the prooosed contracto9 Under the Diablo Canyon criteria the following factors are being considerG to judge independence:

1.

No direct previous involvment with the activities at Diable Canycn which are being reviewed; 2.

Ho previcus seist$fe design vork for.E.J.E; 3.

ne previous ecployment with PG8E;

  • 4 Fo ownership or control of PET.E stock;
5. ' ro relatives enployed by PC3E.

i l-In addition, contractors have been asked to reveal:

6.

Their total revenues; 7.

The percer.tage of their total revenues accounted for by electric utility accrunts; and E.

The percentage of their total revenues accounted for by the licenses.

e e

(

$ff' m

ame-

,,,m

    • M.&**'AMW'

p.

+

v AEpS has tbeen involved in judging inde;iendance under all of*these'criter1A B'

1, exceptfcrfactors_(1)and(2). Currently we lack set licits for the above factors. ' For exarple, there are no tieie linits set for previous

~ ~ ~

t e= ploys:ent; no licit on the arount of stock which can be owned or controlled if any; how cany relatives can be ecployed by the licensee, if any; for how =any years this data applies, and Wether it applies to individual reviewers, as well as to canagerient.

s.

Peccreendation

~

1.

Neither 1'ndivihal merd>ers of the contractor's panagement, individually or collectively, nor the corporation shnuld own or control five percent or nore of the licensee's stock; 2.

The licensee should not account for nore than five percent i

of the contractor's revenees in each of the past three years; and 3.

Individuals assi:;ned to the Project hean should not:

a.

own or centrol any of.the licensee's stock; b.

have worked for the licensee within the past, twelve 1

nonths; and c.

have any nenbers of his househcid currently e-: ployed by the licensee.

In order to detemine the approcriate criteria it is necessary to recognize the different roles the centractor's management and the individual reviewers of the Project Team hold.

If the technical review plan of the cor. tractor (and subcontractors) are approved as being " independent" of che licensee, then it would seen proper to apply the above criteria to t

management differently than to the individuals on the Project Tea:s. For exar,ple, if the Project Tean reports simultaneously to the EC, the licensee, and to its panagenent, the staff can be fairly assured that there will be a ninimum of influence felt on the Project Tean as a i

result of either 'canagement or-the corporation holding the licensee's s teck.

The satse lack of influence between management and the Project' l

Team can be as Ltried regarding previous enplopent by managenent and/or ecployment of the management's household members.

Thus, for individual sembers of corporate canagement it is recor.r: ended that they need only affim that individually or collectively they do not own or control five percent or core of the licensee's stock, the sane rec,uireocnt of the Securities and Exchange Cece.ission. This sane five percent criteria would apply to the corporation.

In tl~ iest the contracter has been asked to supoly its total revenues and the percentage of these revenues accounted for by electric utility accounts. While total revenues may present an idea that the contractor is financially stable, and therefore will remain independent. I believe a better ceasure of independence is the contractor's ability to retain sufficient and qualified technical personnel.

If the Profect Tean is acceptable, we can presune that the contractor will find a way to cocpensate them.

e e

86 e

eo e w an*e m" ee es =* *

=

  • m.

.e-u-ow.eso...-

, +.

--n-.r, v,y

,_r,-m,.

v,,

.m.,.,._._..,

.._..,,_w,,emmn.

-._ey,_m-.m

.v.

m.,

m

,,m.m.-y.,-,,m.w,-~c,-_w..

J w;.

3-The staf f has also been concerned that the contractor should not be heavily indebted to the electric utility sector for their business.

On the other hand, we have insisted on experience.

In view of the fact that the electric utility industry is the nost, capital intensive irdustry in this country it is highly unlikely that a qualified corpany will not derive a substantial portion of its business frem this sector.

L For the purpose of' assuring financial independence it should be sur-ficient that the licensee not account for core than five percent.of the

~

contractor's total revenues in each of the past three years.

The criteria for ' individuals of the Project Tean follow the Diablo Canyon guidelines except a limitation has been set on previous ceployeent (twelve nonths) and the ownership of stock (none). These linits are arbitrary, but they should not impose an endue burden on. the centractor. -

In cases'where subcontractors are employed indiYidUSIs shoold be classi-fied by their function as.either r.ahagement or Froject Tean ucchers, and then the' appropriate criteria should be applied.

P.anrice Messier

~

Senior Antitrust Econcaist-' ~

Antitrust and Economics Analysis Branch Civision of Engineering Office of Nuclear K,cact.or Regulation DISTRIBUTION:

AEAB Rerding

~

AEAB FILE DMuller MMessier Reading NRR:AEAB DE MHessier:na DHuller 4/

/82 4/

/82 y

,y

-,._y

,,._,,7___

_,___m_m.

f..."fG7. ;E

_ _ w ~eem wasw.no s. o. c. 2ctss

.e.g.:,j[f May 4. 1932 j

u

+

o.

~

%, '.V mo.o.

j, I I t

e M%4tLAr ?)

MEO RAiDUM FOR:

Caniel R. Muller, Assistant ' Director Environmental Technology, DE FROM:

Richard H. Vollmer, Director, DE.

~

SUBJECT:

CRITERIA FOR FItiA!!CIAL IfiDEPE!iDEliCE.0F REVERIFICATIO!i-TEAMS I have revitwed Mr. Messier's memorandum of April 14, 1982-on this subjec.t and find the criteria recon. ended ther'ein to be too restrictive.

I think as a basis for our independence criteria we should use those items specified in the Comission's letter to Congress.

In that, the primary factors were cited as the competence of the auditor to do the job and that the company or individuals involved in the audit not have previous involvement with the activity under review.

In additicrt, the Co.v.T.ission cited criteria similar to those you had indicated;.

namely, previous involvement with the company or project, ownership or control of stock, and employment by the ccmpany under review.

Further, the discussion of separating responsibilities between manage'-

ment and the project team might be very difficult to determine and enforce because the organizational aspects would likely be different from auditor to auditor.

With the above considerations, would it not be appropriate to quantify the thoughts expressed in the Commission's criteria to make* the.T. more useful to the staff on a specific job?

In terms of stock ownership, I would suggest some reasonable level but not zero fs a criteria basis.

You may recall that in the past we only had to cite stock ownership in excess of $7500 and criteria like that would seem reasonable.for this process as well.

/A L Richard H. Volicer, Director

~

Division of Engineering g

cc:

T. Sullivan a

J. Knight M. Messier

.e e...'

-.__m

.n--

e.-

' - ~~~

Mdit'dDDThild DYb1D f

t 920 $f C0hO tvt %Ut I..u g

  • Adaaw wuSA;m.SEFS C2254 417. t>>3350 **s I? e 22a.7130 April 5, 1982 5511-18 h t, C O :.

Mr. G. A. Maneatis, Senior Vice-President, Facilities Development Pacific Gas and Electric Co.

77 Beale Street CONTROLLED DOCUMcNT San' Francisco, California 94106 ca o

j Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation 9

~.d'.>

g U. S. Nuclear Reagulatory Comission f

b Washington, D. C.

20555

,{-} g i[=

8

[1 O*' f Mr. R. H. Engelken, Regional Administrator

{

Office of Inspection and Enforcement Region V

=

U. S. Nuclear Regulatory Comission 4

1450 Maria Lane, Suite 210 Mi9 Walnut Creek, California 94596

Subject:

Independent Design Verification Program:

Potential or Ap-parent Conflicts of Interest of Individuals

Reference:

Docket No. 50-275, Diablo Canyon Unit 1 License No. OPR-76 Gentlemen:

During the meeting of March 25,1982 (transcript, page 167, lines f-12)', I committed to submitting a Program Procedure draft on this subject for NRC and PG&E approval.

That draft is enclosed, and would be included as AppEidix G of the IOVP Program Plan when fully approved.

We believe the enclosed draft is re-sponsive to the directions and needs of this program; but recognize that it is a procedure imposed by others and we will modify it in accordance with your coments.

Very truly yours, TELEDYNE ENGINEERING SER7 ICES

$f24 30?;

William E. Cooper Project Manager

/

l WEC/1h Enclosure H. Schierling (NRC R. R. Fray (PG&E) )

cc:

. -L. C-loud (RLCA R. F. Reedy (RFR)).

p e..

0

.INEERS AND METALLURGISTS P

y).

L,,

a~

L.RGWERiNGSEPMOES '

~ :

s '.

w.

n MARCH 29, 1982 DRAFT OF 0 liPP-IDVP-PP-0D5' POTENTIAL OR APPARENT CO.'iFLICTS OF INTEREST OF INDIVIDJALS

'I 1.0 POLICY

~

In order to assure the independence of the Independent Design Verifi-cation Program (IDVP), it is essential that responsible individuals assigned to the verification program be free of potential or apparent conflicts of " interest.

This consideration includes previous work on the Diablo Canyon Nuclear Power Plant, financial interest in PG&E, and employ-ment of relatives by PG&E.

2.0 APPLICABILITY This Program Procedure applies to the following types of persons do _

are assigned to the IDVP:

All exempt employees, as defined by the Fair Labor Stand,ards Act, a.

who are participating in an engineering function.

b.

All

" Contract Engineers," consultants, or subcontrac tor em-playees.

3.0 PROCEDURE Each of the organizations participating in the IDVP (TES, RLCA, a.

RFR and SWEC)' shall prepare a " Statement Regarding Potential or '

Apparent Conflicts of Interest." Similar to, but no less inclu-sive than, that of Appendix A to this Program Procedure.

d b.

The term "immediate family" as used on the form includes, as a minimum, the employees spouse and the parents, siblings and children of the, individual and his or her, spouse.

yT.

,,,f.f.*

- ens!NEERiidSEPMCES,

s.

~ *

,{'

.c.

Each individual to whom this Program Procedure applies shall~be t-asked to complete a " Statement" and file the completed form with the Personnel. Relations Manager, or similar appropriate. ind.ivi-dual.as determined by the participating organization.-

v i-

'd.

The completed form shall be retained by' the Personnel Relations Manager, or ' equivalent, and shall be auditable by authorized NRC and PG&E. personnel.

e.

The Personnel R' elations Manager, or equivalent, shall review the completed forms and shall notify the organization's Project Manager if a question arises as to the use of a particular indi -

vidual on the IDVP.

f.

If the Project Manager is in doubt, he or she will address a

- letter to the NRC (Denton) and PG&E (Maneatis). outlining the.

facts, without identification of the individual, and request con-currence that the individual be assigned to the IDVP.

^

g.

Each semimonthly report shall include the, following sta ement:

"As required by DCNPP-IDVP'PP-005, individud1s assigned by this organization to the IDVP have completed an acceptable Statement Regarding Potential or Apparent Conflicts of Interest."

6 e

e i

i l

i p

  • +.. - -..

_. - - - - _ ~. _. _ _ _ _ _ _ ~ _ _, _ _ _ _. _ _ _. _. _ _., _ _ _ _ _ _ _. _ _, -, _ -

r j q'.: /.

ENGINEERING SERVibE w uu-m

    • ~..

s:

p APPENDIX A STATEMENT REGARDING POTENTIAL OR APFARENT CONFLICTS OF INTEREST 9

To: Teledyne Engineering Services e

Whereas, the undersigned employee (" Employee") understands that he or she is being considered "as a participant to provide services to Pacific Gas &

Electric Company with respect to the Design Reverification Program for the Diablo Canyon Nuclear Power Plant - Unit I; and Whereas, Employee understands that it is necessary that proposed partici-pants be screened for any potential or apparent conflicts of interest with respect to this assignment; Therefore, for ' the above stated purposes Employee makes the following representations to Teledyne Engineering Services:

1.

Employee has not engaged in any work or business involved with or related to the engineering or design of the Diablo Canyon Nuclear Power Plant-2.

Neither Employee, nor any mem.bers of his or her imediate family, own any beneficial interest in the Pacific' Gas &

Electric Company, including but not limited to comon er preferred stock, bonds or other securities issued on behalf of the Pacific Gas & Electric Company;,and-3.

None of the members of Employee's immediate family are employed by Pacific Gas & Electric Company.

This statement is based upon the Employee's best information and belief and any exception's to the representations contained herein have been described on the reverse sioe of this document.

Dated:

Signature:

Print N.ame e.ee-e e

e

+>

Retrieved from "https://kanterella.com/w/index.php?title=ML20209B360&oldid=4029911"