ML20210B218
Text
r 8p m,#'o, UNITED STATES A
fi NUCLEAR REGULATORY COMMISSION
'7 E
WASHINGTON, D. C. 20555 SEP /
1982 gw.....f MEMORANDUM FOR:
Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
DIABLO CANYON - SEISMIC VERIFICATION PROGRAM Over the past few weeks we have had a number of meetings and discussions in i
order to better define our position regarding the Seismic Verification Program. Since we are scheduled to brief the Commission on Sept. 22 (briefing package is due Sept 15) and to meet with the intervenors on Sept. 9, I have attempted to sumarize the status as I understand it, and to offer a proposal, at this time which should be useful in upcoming discussions.
I.
ORIGINAL PLAN A.
Phase I Order (before reinstating FL and LP) required:
1.
The results of an Independent Design Verification Program (IDVP) for all seismic service-related (SSR) contracts prior to 6/78.
2.
A technical report of the basic cause of the errors, their significance, and their impact on facility design.
3.
PGE's conclusion on effectiveness of IDVP, and 4.
A schedule for modifications; including a basis for any deferred beyond a fuel load decision.
B.
Phase II Letter (before 5% power decision) required:
1.
IDVP for non-seismic service-related contracts (NSSR) prior to 6/78.
2.
IDVP for PGE internal QA, and 3.
IDVP for all service related contracts post-1/78.
C.
For both A and B, work must be done by a " qualified, independent" contractor and a program plan must be submitted for our approval.
COMMENTS:
For Ph.
I., Contractor and Plan have been approved.
l For Ph. II., Proposed contractors and plan was submitted b
t
/
June 18,1982. Although the NRC has yet to comment.
8609180003 e60708 i
i
., v Comments for PH. II., (Continued) on or approve Phase II, much work is well under-way on it and much of Phase II program is projected to be complete in Oct. - Nov.,1982.
On Sept.1 Teledyne stated that over the past few months, the total IDVP' program was expending over 70 man-months / month - with roughly half on Phase I and half on Phase II.
II.
PGE SEISMIC INTERNAL TECHNICAL PROGRAM (ITP)
At our August 6 meeting, PGE discussed in some detail their on-going ITP. That program is meant to re-evaluate all safety-related structures, systems, and components from a seismic standpoint. It was noted that if the re-verification of a building's response was unchanged, then the systens and components in that building need not be re-evaluated.
Similarly, it was noted that some components and systens may be re-evaluated as groups.
Bechtel now has over 500 technical professionals working on the ITP.
They have developed a system whereby the results of the ITP are provided to the IDVP..They will provide information both for where things checked out as well as where modifications are required. The IDVP is developing a about a week) proposed approach for reviewing such information. (Duein As a result of the ITP, a number of errors have been found and modifi-cations have already been made to the D.C. facility. PGE agreed on Sept,1 to develop a listing of such errors and mods and provide them to us shortly. This is needed since the number of errors to date don't clearly " add-up".
i III.
PHASE II PROGRAM PLAN / CONTRACTORS Following the receipt of the proposed Phase II Program Plan it was sent to Region V, IE, DOE and DSI/NRR, and the Intervenors including Gov.
Brown's representatives, for review and comments. I have received comments from everyone except the Division of Engineering. Principal comments received are summarized:
(A set of all comments is being provided l
separately).
PRINCIPAL COMMENTS:
l l
1.
Require the IDVP - NSSR contract effort in Phase I rather than i
Phase II - or at least a significant fraction in Phase I.
l
f 2.
Require Construction QA verification in Phase II.
3.
Require post-78 efforts for all service-related contracts be moved from Phase II to Phase I, or again, a significant fraction.
4.
Post-modification physical as built inspection should be done.
5.
Program should expand to everything "important to safety", not
'just safety-related items.
6.
Three-dimensional modeling must be utilized.
7.
NRC should retain BNL as its independent monitor for all activities.
IV.
PGE POSITION / STATUS A.
Basic Approach:
1.
Want to complete all review / analysis required by Phase I and enough of Phase II work (to have high confidence that no other significant errors exists in Phase II activities) before any decision regarding fuel load.
2.
Prior to a FL decision, complete those modifications flowing from joint Phase I/ Phase II review above, that are needed from a safety standpoint for FL.
Defer modifications until after FL for structures, systems, and components not needed for FL.
B.
Construction QA PGE proposed to include in the IDVP, a construction QA review for a couple of major contractors. PGE believes that it is not needed, that there is no data to suggest it's needed, but proposes it to completely resolve the debate on this issue.
C.
NSSR PGE believes that there is no data to suggest that the problems with SSR contracts exptend to NSSR contracts. They propose, however, that sufficient work re: the NSSRs should be completed prior to a FL decision to have high assurance in their assertion.
i D.
Pre 1978 vs. Post 1978 PGE acknowledges that there is probably no step-wise distinction between pre-78 and post-78 activities. Rather, they stated that overall QA improvements were gradually increasing throughout the 1970's. This distinction will largely be lost in their work since their ITP covers both pre-78 and post-78 work and since they will also perform considerable Phase II work on NSSR (pre and post 78) prior to a FL decision,
f o..
E.
PGE/ Internal QA The Phase II letter required an IDVP for the PGE Intemal QA efforts. Both PGE and Teledyne stated that this effort is going forth expeditiously, and will be completed in the same time frame as Phase I work. Teledyne projects that this will be completed in October 1982.
F.
Modifications to Date 1.
PGE stated that most modifications to date flow from their ITP and not the IDVP.
2.
Almost all modifications are rather insignificant.
3.
All modifications to date are to restore margins.or to meet design criteria.
4.
PGE believes that nothing has been found to date which would not have remained operable following an earthquake.
G.
IDVP/ITP Interface Entire results of PGE ITP will be submitted to TES. TES stated that they are developing a refinement to the Phase I IDVP whereby they would sample-review portions of the ITP to ensure that it was satisfactorily accomplished. TES believes that this can be done under the presently approved Phase I Program Plan.
H.
As Built Walkdowns PGE indicated that they will have a final, after-modification, walk down program.
Its scope and extent are unclear at this time.
I.
Reedy Report PGE stated their belief that the report gives erroneous results and implications; it applies a 1982 interpretation to 1970's work; and that Reedy acknowledges that the strict use of App. B is inappropriate.
J.
BNL Report PGE stated that the BNL report reconfirmed their previous findings; that BNL uses State-of-the-Art techniques but used old data as inputs.
l l
f 1
. 7 V.
PROPOSES STAFF POSITION
['
A.
Do not approve Phase II as submitted in June or approve as modified.
~'
B.
Before a decision re: FL require:
1.
Completion of Phase I Order Items (I. A.1.2.3, and 4 above).
2.
Status report of all Phase II activities (including Construction QA).
3.
Completion of all modifications needed to support FL activities and justification of deferrals per I.A 4.
Y NOTES:
- a. ~ We should stop making much distinction between NSSR and SSR contracts; and between pre-78 and post-78.
b.
We should ensure that Phase II is completed as ernaditinneys hc as possible to facilitate a well founded decision for FL.
c.
The NRC should act promptly to reach a decision regarding the contractors proposed for Phase II.
i 1
NACA Q.
f kOyf 7 ub
(
[.
C.
Before a decision regarding exceeding 5% power,- require:
1.
Completion of all Phase II evaluations.
2.
Schedule (and bases) for completion of all remaining modifications flowing from Phase I or Phase II.
D.
Administrative 1y move to fomalize A-B-C above:
1.
Decide whether Order needs to be modified.
2.
Require, PGE (ITP) to maintain an overall error tracking system similar to that in IDVP in order to be able to have one concise listing of all errors found (and modifications required).
3.
Decide on the extent of our reliance on Teledyne as the
" principal reviewer."
4.
Decide on the extent of the staff's review of Teledyne's work.
s 4..
5.
Decide whether, or not, to rely in a large portion on BNL to do the staff's review as proposed by the joint intervenors.
NOTE:
,e The information contained herein is not meant to be a final' position, but rather should be viewed as a vehicle to promote discussion regarding our position on the Phase II proposals, and should prove helpful in upcoming discussions with the Intervenors and NRC Region V representatives.
/.h{,
((
['(lG U Darre G. Eisenhut, Director Division of Licensing cc:
R. Engelken, Region V R. DeYoung, IE R. Vollmer, DE/NRR R. Mattson, DSI/NRR F. Miraglia, DL/NRR T. Novak, DL/NRR.
H. Schierling, DL/NRR.
J. Kerrigan, DL/NRR E. Christenbury, ELD J. Scinto, ELD L. Chandler, ELD
.