ML20209C318
| ML20209C318 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/15/1983 |
| From: | Haass W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16340C148 | List:
|
| References | |
| FOIA-86-151 NUDOCS 8308040314 | |
| Download: ML20209C318 (6) | |
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UNITED STATES 8
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g Docket No. 50-275 JUL 151983 MEMORANDUM FOR:
George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing, NRR
'FROM:
Walter P. Haass, Deputy Chief Quality Assurance Branch Division of Quality Assurance, Safeguards, and Inspection Programs, IE
SUBJECT:
DIABLO CANYON VERIFICATION PROGRAM - SER SUPPLEMENT In your memorandum dated June 22, 1983, you indicate SSER inputs should be sub-mitted to DL by July 13 but request it as early as possible. A first-cut pre-liminary draft of our SSER input (Chapter 3.0 per the outline) was sent to the PM for the verification effort on July 13. The final draft is enclosed.
You will note that Sections 3.2, 3.3, and 3.4 of the outline have been combined into Section 3.2 of the enclosure. A new Section 3.4 has been included to add-ress the QA program for the Bechtel/PG&E corrective actions under the DCP. The remaining sections in Chapter 3.0 have been renumbered accordingly.
If there are any questions concerning the enclosure to this memorandum, please contact Jack Spraul on x24530.
(G u
alter P. Haass, Deputy Chief Quality Assurance Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
Enclosure:
As stated cc:
E. L. Jordan, IE J. M. Taylor, IE B. K. Grimes, IE H. Schierling, NRR T. Bishop, RV J
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1 3.0 QUALITY ASSURANCE 3.1 Introduction The Comission Order and the NRR Letter both required that the IDVP audit quality assurance (QA) procedures, controls, and practices for the design
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i of DCNPP-1 with special concern for the development, accuracy, transmittal, and use of safety-related information within PG&E, within its contractors' organizations, and between PG&E and its contractors. The construction permit for DCNPP-1 was issued by the NRC (then AEC) in April, 1968; but more specific staff requirements for QA were not incorporated into 10 CFR Part 50 until June of 1970 and applied to DCNPP-1. These more specific requirements for QA are given in Appendix B to 10 CFR 50, " Quality Assur-ance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."
Therefore, significant design efforts were underway for DCNPP-1 prior to the availability of Appendix B.
Responsibility for conduct of the QA audit was assigned to Roger F. Reedy, Inc. (RFR) reporting to Teledyne Engineering Services as the Program Manager. The audit was performed by establishing a checklist of QA re-quirements from' Appendix B and considering NRC staff QA requirements in existence at the time of program review and acceptance.
3.2 Quality Assurance Audits of the Design Process i
The quality assurance audits conducted by RFR compared applicable QA man-uals and procedures against the applicable criteria of Appendix B to 10 CFR 4
'l Part 50. Following review of the QA Manuals and procedures, implementation of the program by each organization was audited. The organizations audited included PG&E, ANCO Engineers, Cygna Energy Services, EDS Nuclear, Garretson-t Elmendorf-Zinov Associates, Harding Lawson Associates, Quadrex, Radiation F
Research Associates, URS/J. A. Blume & Associates, and Wyle Laboratories.
The results of the QA manual and procedure review varied. 'It was found i
that five of the design organizations had no QA manual or, if there was a manual, it was not invoked for the work being reviewed. Two of the design organizations (including PG&E) had manuals which did not appear to reflect all the pertinent requirements of 10 CFR Part 50 Appendix B.
The three remaining design organizations had QA manuals which appeared generally acceptable and were used for the work being reviewed.
The results of the implementation audit also varied in that two of the design organizations did not implement a QA program, five implemented 1
a QA program which did not appear to meet all the pertinent requirements of 10 CFR Part 50 Appendix B, and three implemented a QA program which was acceptable.
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. One purpose of performing the above reviews and audits was to obtain information regarding the need for additional samples for design veri-fication. Where QA programs were missing or found to be less than entirely ~ acceptable, the scope of the IDVP was expanded to verify that the-design was acceptable.
Fifteen E0Is that identified any required additional design verification were. issued as a result of the QA program reviews and implementation audits.
In cases where initial E0Is responded directly to the review or audit findings rather than to the expanded scope of design verifi-cation, the initial E01s were closed by incorporating them into nine 3000 series E01s. The other six E0Is directly addressed a required additional design verification.
Of these fifteen E0Is, one (7002) has been classified as a class A/8 error, five have been closed by being transferred to or combined into files which have been classified as a class A/B error (3006, 3007, and 3008 into 1014; 7004 and 7005 into 8001), and the remainder have been closed by the IDVP on the basis that the program for verification of the design process was formulated and conducted with the assumption that even though significant deficiencies in the QA programs and their' implementation may be identified, it can also verify the acceptability of the design in spite of any reported QA shortcomings.
E01700L resulted from the lack of documented evidence that PG&E had con-l sidered the effects of jet impingement on components inside containment.
The work done by the Diablo Canyon Project in the area of jet impingement inside containment was verified by the IDVP. The IOVP verification effort identified four items of possible concern which are identified in EDI 8065~.
i (This information is to be supplemented per page 4.8.5-2 of the IDVP final
. report. E01 1014 concerning the containment annulus structure also remains open as indicated on page D.3-31 of the IDVP final report. This report must
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.be updated in these areas.) E0I 8001 addressed concerns about the calcu-lation of pressure and temperature outside containment. Diablo Canyon Project reanalyses resulted in new values of pressure and temperature in the affected areas which will be incorporated into the DCNPP-1 design.
i E01 8001 was closed based on the satisfactory resolution of the con-cerns expressed.
3.3 Quality Assurance Audits of Construction Quality assurance audits of the construction process, although not required l
by the Comission Order or the NRR Letter, were added to the IDVp by PG&E to ' assess whether the construction of DCNPP was in accordance with design requirenents and whether shortcomings like those found in design QA would i
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9 be found in construction QA. The civil / structural work on the containment building by Guy F. Atkinson Co. (GFA) and the installation of NSSS piping by Wismer & Becker (W8B) were audited by Stone & Webster Engineering Corp-oration. Experienced auditors, qualified and certified in accordance with ANSI N45.2.23, reviewed each contractor's QA program and procedures and audited the physical construction of selected components of each construc-tor's work and as-constructed documentation. Checklists were developed and used for these audits. Potential findings resulting from tnese audit were reviewed by a Findings Review Committee to determine their significance.
The results of this work were reported in ITR's #36 and #38.
Four E0I's resulted from the review and audit of GFA. Each of these E01's was closed when it was determined it had no apparent real or potential 1
impact on quality.
Twenty-five E01's resulted from the review and audit of W&B. Of these twenty-five E01's, one (9026) has been classified as a finding that required evaluation due to its potential impact on quality, five were closed because they were invalid, and the remaining sixteen were closed when it was determined they had no apparent real or potential impact n6 quality. E0I 9026 concerned the lack of documentati' n to assure the o
liquid penetrant inspection of areas on the reactor coolant piping where lugs had been removed. The areas were subsequently liquid penetrant in-spected and determined to be acceptable. Since the audit verified thG performance of all required inspections except this one, it was considered to be a unique occurrence and E0I 9026 was closed.
Staff review of ITR's #36 and #38 resulted in questions regarding ths rationale for closing out some of the E0Is.
Insufficient information was included to adequately justify the actions taken. The IDVP constuc-tors provided the necessary information in a meeting and 1,n revisions to 3
the reports to resolve our concerns, t
3.4 Audits of Diablo Canyon Project Activities i
The staff reviewed the Diablo Canyon Project (DCP) QA program for tbc cor-t rective actions resulting from the Commission Order and NRR Letter and found it met the pertinent requirements of 10 CFR Part 50 Appendix B.
The DCP QA program consists of the QA programt for Bechtel and PG&E.as applied to the corrective actions. The implementaticn of this QA program was audited, by R. F. Reedy, Inc., as pa'rt of the IDVP, first as it applied to the design corrective action activities and then as it applied to the design office.
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The audit of the design corrective action activities noted twenty-four conditions of incomplete documentation beca.use the audtt was performed during the early stages of implementation. A followup audit some montns later showed that appropriate actions had been taken to correct ithe earlier noted conditions to the satisfaction of the audit team. h E0!s were issued.
The audit of the design office included the examination of calculations used by each engineering discipline. Seismic incuts for qualifft3 tion analyses and discussions with engineers and supervisors were alw included.
No audit findings were identified which fould have eithee a potentia'l or real impact on the design, and thus no E01s were 1ssued.
3.5 Audits of IDVP Activities The Management Plan for the IDVP providad the coarnttm6nt that the activi-ties of the IDVP participants would be conducted in actoroance with the opplicable requirements of 10 CFR Part 50 Appenc'ix B, and the QA programs of the IDVP participants (Teledyne Engineerug Services, R. F. Reedy. Inc.,
Robert L. Cloud and Associates, Inc., and Stepe and Vebster Engineerirs Corp.) were referenced in the plan. FG&E audited each of the participants in the program, and Teledyna Engineering Services also cydited the other participants. NRC Region V audits showed,that the activities of the IDVP participants were being controll6d in accordance with the applicable re-quirements of 10 CFR Part 50 Appendix B by means of appropriate procedures and traistad parsennel.
2.6 Sununary Staff Evaluation buring the IOVP, audits of the est+blis.hment and irripler4ntation of QA pr ograms of several contrectors relative to Apper. dix B were cor. ducted, some at the specific direction cf the staff. The QA audits o.f the seismic derign work showed that some of the work wts perferried with no fcemal.QA l
program in effect. However, further review of the design Mrk indicated that the w rk was nevertheless perfoiced correctly. This is acceptable to tb.e staff.
The QA, audits of construction activities indicated adeouate imphmentation of QA contrbis such that the IDVP coccinced that, in the ar6as revieweh the work performed in conttracting 02PP-}.was satisfactory. No physical j
modifications of DCNPP-1 were required as a result of the construction QA audits. Th,e IDVP found no indication tnat PG3E failed to adequately con-l trol the activities of the c.onstruption contractors. The staff conclodes that the IDVP audit sccpe of tn(s work was ac.ceptable. The constructica QA audits provifie additicnal asscron:e that DCNPP construction is accept-able.
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s The audits of the Diablo Canyon Project activities indicate that corrective action efforts resulting from the Ccamission Order and hRR Letter are being performed by Bechtel utilizing their approved QA program and by _PG&E utilizing the more recently accepted QA program for operations. The latter program in-cludes updated QA controls and is applicable to design ar.d construction (e.g.,
modifications) activities alsc. This program is being effectively implemented.
QA audits of IDVP activities confirmed that the work was being perfonred in accordance with the epplicable requirements of 10 CFR Part fic Appendix B.
The staff concludes that shortecrtings found in earlier QA programs for certain design activities ame being compensated for by the IDVP by v!!ri-fication of the final design, that constructicn was done under acceptable QA controls, and that current corrective actions and the IDVP work itself are being performed in accordance with acceptable QA programs.
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