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JUN 171933 MEMORANDUM FOR:
Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel FROM:
James M.. Taylor, Director Division of Quality Assurance.
Safeguards, and Inspection Programs, IE
SUBJECT:
DIABLO CANYON CONSTRUCTION QA -
RESPONSE TO SPECIFIC ISSUES As requested by G. W. Knighton's memorandum dated May 23, 1983 and as modified in the telecon of May 25, 1983 involving NRR, IE and RV, the fol. lowing is IE's response to specific issues 1 and 3 regarding the motion by joint intervenors to reopen the Diablo Canyon hearing record on construction, quality assurance.
1.
" Safety related" vs. "important to safety" (limited scope of COA)
The Commission's Order Suspending License, CLI-81-30, issued on November 19, 1983 to Pacific Gas and Electric Company (PG&E) for Diablo Canyon, Unit 1, requires the conduct of an indep,endent design verification program and the completion of a technical recovery program. These actions are directed toward all safety related activities performed in the design process for safety related structures, systems and components (emphasis added). While the commission's Order used the phrase "important to safety," it used the phrase in its broad context and Attachment 1 to the Order narrowed the scope of the required program to safety related activities and plant items.
During the course of implementing the Order, the program was expanded to address the construction process also. Consistent with the Commission's Order, the focus of the construction process addition to the program is also on safety related activities and plant items.
In light of the above, the Cor. mission's Order is not concerned with PG&E's commitment to GDC 1 of Appendix A to 10 CFR 50 nor with PG&E's implementation of its requirements.
It is rather concerned with PG&E's commitment to Appendix B to 10 CFR 50 and the adequacy of PG&E's implementation of its Appendix B Quality Assur-ance Program. Appendix B is directed solely to " safety related" activities and plant items.
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GDC 1, on the other han'd, establishes a broader requirement to apply an ap-propriate quality assurance program to structures, systems and components "important to safety." The quality assurance requirements would be applied to activities performed on such plant items in a graded manner in accordance with the items' importance to safety. As noted in H. R. Denton's memorandum to the staff dated November 20,1981 (copy enclosed), the terms " safety related" and "important to safety" have been used inconsistently and inter-changeably. This usage problem has manifested itself on several recent license applications with the result that the need for a resolution of the requirements to satisfy GDC 1 has been identified. Therefore, it is the staff's intent to re-review PG&E's commitment to GDC 1 (pages 3.1-4/5 of the FSAR) and to require implementation of the resolution as appropriate, but outside the context of the present Commission Order.
3.
Adecuacy of Programmatic QA The programmatic quality assurance controls for the Diablo Canyon project evolved in several stages during the course of design and construction.
The acceptability of the initial quality assurance controls to be applied to the construction of the Diablo Canyon units relative to Appendix B requirements was determined in the context of the PSAR review at the CP stage.
NRC RV has reported that PG&E upgraded its QA program for Diablo Canyon several times in the mid-1970. time frame to incorporate more re-cently developed QA controls.
At the inception of the IDVP, PG&E indicated that the QA program for operations (which also includes QA controls for design and construction activities) would be utilized to control and verify these activities. With the recent retention of Bechtel as the construction completion manager, the programmatic QA controls were further modified to -
include the Bechtel program as described in their QA topical report. The staff has reviewed the revised QA program and,_ by letter to PG&E dated January 26, 1983, advised that the program was acceptable.
Shculd you require additional information regarding the above, please contact W. Haass on x29677.
, f T.,
a irector iv sic of Quality Assurance, Saf guards, and Inspection Programs Office of Inspection and Enforcement
Enclosure:
See Page 3
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Lawrence J. Chandler I 7 633
Enclosure:
Memorandum to Staff Personnel from H. R. Denton, dated 11/20/81, cc:
H. R. Denton, NRR R. J. Mattson, NRR R. H. Vollmer, NRR D. G. Eisenhut, NRR G. W. Knighton, NRR l
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UNITED STATES 8'
NUCLEAR REGULATORY COMMISSION q
g jg WASHINGTON. D. C. 20555 NOV 2 01981 i
MEMORANDUM TO: Darrell G. Eisenhut, Director, Division of Licensing, NRR Stephen H."Hanauer, Director, Division of Safety Technology, NRR Richard H. Vollmer, Director, Division of Engineering, NRR Roger J. Mattson, Di':ector, Division of Systems Integration, NRR Joel Kramer, Acting Director, Division of Human Factors, WRR Bernard J. Snyder, Program Director, TMI Program Office, NRR Paul S. Check, Progran: Director, CRBR Program Office, NRR Hugh L. Thompson, Director, Planning and Program Analysis Staff, NRR FRGi:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
STANDARD DEFINITIONS FOR COMMONLY-USED SAFETY CLASSIFICATION TERMS In accordance with a recent recommendation made to me by NRR Division Directors (ref: Memo dated 10/13/81, Murley to Denton, same subject)
I have endorsed.and prescribed for use by all NRR personnel standard definitions for three safety classification terms most commonly used in the conduct of NRR's safety review and licensing activities. A copy of my letter to all NRR personnel implementing this decision is enclosed.
As a means of better assuring the implementation of my decision and action, please instruct your principal staff to pay particular attention to this matter in their review of all official correspondence and documents during the next few months.
Y n
Harold R.-Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated cc:
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NOV 2 01981 MD40RANDUM FOR: All NRR Personnel FROM:
Harold R. Denton, Director.
Office of Nuclear Reactor Regulation i
SUBJECT:
STANDARD DEFINITIONS FOR COMMONLY-USED SAFETY CLASSIFICATION HMS Litigation of one of the principal issues in the TMI-1 Restart Hearing brought to light the fact that there is not complete consistency among all elements of the NRR staff in the application of safety classification terms used frequently in the conduct of NRR's safety review and licensing activities. More specifi-
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cally, it appears that terms "important to safety," " safety grade," and " safety-related" have been used at times interchangeably, or in ways not completely consistent with the definitions and usage of such terms in the regulations, and which do not fully reflect the intent of the regulations or current licensing practice.
Efforts have been underway for some months now to develop guidance for the-consister.t usage of these terms. These efforts have included:
(a) review of a large number of Reg Guides and SRP's, in conjunction with parts of the regula-tions upon which they are based, for consistency in the application of safety classification teminology. (2) extensive discussions among cognizant NRR, RES (Stds. Devel.) and ELD representatives regarding proper interpretation and application,of such terms, including consideration of alternative " standard" definitions and (3) consultation with the cognizant ACRS Subcommittee regarding these matters, and consideratio.n by the full ACRS as well.
As a result of these efforts, I am endorsing and prescribing for use by all NRR
- personnel the standard definitions set forth in the enclosure to this'1etter. -
It should be noted that jft connection with long-term efforts to develop means for ranking reactor plant systems with respect to d.egree of importance to safety, and in connection with related efforts to develop a graded Q.A. approach in reactor licensing, the general question of safety classifications and safety classification
.. terminologies will be reexamined; and this could result in changes to the defini-tions set forth in the enclosure or perhaps in development of a completely new scheme in this regard.
For the time being, however, the definitions in the en-closure should be considered " standard" and should be applied consistently by all i
NRR personnel in all aspects of our safety review and licensing activities and l
should be appropriately reflected in our regulatory guidance documents.
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DEFili!TI0ti 0F TEPJiS Imoortant to Safety Definition - From 10 CFR 50. Appendix A (deneral Design Criteria) - see first e
paragraph of " Introduction."
"Those structures, systems, and components that provide reascoable assurance that the facility can be operated without undue risk to the health and safety of the public'."
w Encompasses the broad class of plant features, cevered (not necessarily s
explicitly) in the General Design Criteria, that centribute in import 6nt way to safe operation ag protection of the ptblic in a1], phases and aspects of facility operation-(i.e., normal pperat' ion and transient control as well as accident mitigation).
e Incin', Safety-Grade (or Safety-Related) as a subset.
Sa fety-Rela ted Definition - From 10 CFR 100. Appendix A - see sections III.(c). VI.a.(1), and e
VI.b.(3).
Those structure, systems, or components designed to remain functional for the SSE'(also termed ' safety features') necessary te aarure recuired safety functions, i.e. : '
(1) the integrity of the reactor coolant p essure toendary; (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3).the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures' comparable to the guideline exposur.es of this part.
Subset of "Important to Safety" e
e Regulatory Guide 1.29 pnsvidesan D:R-oeneric, function-oriented listing of
" safety-related" structures, systems, and components needed to provide or perform
- required safety functions. Additional infonnation (e.g., NSSS type, BOP design A-E, etc.) is needed to generate the com'plete listing of safety-related SSC's for any specific facility.
Note: Th.e term " safety-related" also appears in 10 CFR 50, Appendix B (Q.A. Program Requirements); however, in that context it is framed in somewhat.different language than its definition in 10 CFR 100, Appendix A.
That difference in language between the two appendices has contributed to, confusion and misunderstanding regarding the exact meaning of " safety-related" and its relationship to "important to safety" and " safety-grade." A revision to the language of Appendix B has been proposed'to clarify this situation and remove any ambiquity in the meaning of these terms.
Enclosure
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2 Sa fety-Gra de e Term not used explicitly in regulations but widely used/ applied by staff and industry in safety review process, o Equivalent to " Safety-Related," i.e., both terms apply to the. same subset of the broad class "Important. to. Safety.."
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