ML20210E486
| ML20210E486 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/16/1981 |
| From: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Fair J, Miraglia F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20209C222 | List: |
| References | |
| FOIA-86-151 NUDOCS 8609250019 | |
| Download: ML20210E486 (3) | |
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UNITED STATES
$4 15 NUCLEAR REGULATORY COMMISSION e
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1450 MARIA LANE. SUITE 260
,e, WALNUT CREEK, CAUFORMA 94596 December 16, 1981 MEMORANDUM FOR:
ank Miraglia, NRR John Fair, IE:HQ FROM:
B. H. Faulkenberry, Chief, Reactor Construction Projects Branch, RV
SUBJECT:
REGION V COPNENTS ON PG&E'S DESIGN VERIFICATION PROGRAM PLAN AND QUALIFICATIONS OF COMPANIES PROPOSED TO CONDUCT INDEPENDENT REVIEWS Attached.are the Region V coments on the design verificaton program plan for seismic work prior to June 1978 that was submitted to the NRC in a letter from Malcolm Furbush dated December 4, 1981.
Region V intends to reserve commenting on the qualifications of companies proposed to conduct independent reviews until after we complete our current investigation regarding PG&E's reviewing and comenting on the October 1981 Cloud draft report.
&i LuAY N B. H. Faulkenberry, (aier Reactor Construction w ojects Branch
Attachment:
As stated cc:
R. H. Engelken J. L. Crews P. J. Morrill R. L. Tedesco (NRR) l l
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r REGION V COMMENTS - DESIGN VERIFICATION PROGRAM PLAN FOR SEISMIC WORK PRIOR TO. JUNE 1978 1.
Page 2, Section 1.1 - The program scope should include all seismic safety related service contract activities performed prior to June 1,1978, regardless of when the contract was signed by PG&E. The words "in effect" may be interpreted differently.
2.
Page 4, Section 2.2.2 - The network must include internal PG&E interfaces in the same detail as contractor /PG&E interfaces.
It is not clearly stated that the same detailed analysis applies to internal PG&E groups.
It is suggested that the second sentence be changed to include PG&E internal design groups as well as contractors.
3.
Page 5, Section 3.1, First Paragraph, Last Sentence - This sentence should be changed to read:
"These documents shall include applicable revisions in safety related seismic design activities performed in the period prior to June 1978." It is not clear what the words "For the Equipment" is intended to include.
4.
Page 5, Section 3.2, First Sentence - Should define the specific Appendix B criteria under which Section 3.1.1 documents will be reviewed against.
i Should include at least criteria I, II, III, IV, V, VI, VII, XVII, and XVIII.
5.
Page 6, Section 3.2.1 - This section seems to include discussion related to implementation of Appendix B requirements. Section 3 should restrict its discussion to programmatic aspects of Appendix B and implementation aspects of Appendix B should be included in Section 4.
6.
Pages 6-9, Section 3.2.1 through Section 3.2.3 - Only 10 CFR Part 50,
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Appendex B Criteria III and VI are discussed. These sections should be expanded to address Criteria I, II, IV, V, VII, XVII, and XVIII.
7.
Page 10, Section 4.1 - Explain in this section that the evaluations performed will address at least Appendix B criteria I, II, III, IV, V, VI, VII, XVII, and XVIII.
i 8.
Page 10, Section 4.2.a) - This item should be changed to read:
" Applicable PG8E internal design groups including those that interfaced with.the seismic contractor. "
9.
Pages 10-11, Section 4.2 - This section should be expanded to adequately define the extent or degree of sample checks or independent calculations that will be performed, in each area of each contractor's work where Appendix B controls were r.ot implemented, to verify that the work performed was accurate and acceptable.
I The sample checks and independent calculations performed under this section of the plan should be done on a contractor by contractor basis, to l
justify the acceptability of each area of each contractor's work that was i
determined to have had inadequate implementation of Appendix B controls, and i
should be separate and in addition to the sample checks and independent calculations to be performed under Section 5 of the plan.
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10.
Page 11, Section 4.2.d) - Should be changed to read:
"And transmittal
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and use of contractor developed information within PG&E."
11.
Pages 12-21, Section 5.0 - This discussion should explain that these independent sample calculations are above and beyond those that will be performed in Section 4.2, as addressed in Region V's above comment number 9.
These calculations will cut across individual contractor boundaries and provide an additional layer of verification of the adequacy and accuracy of design.
Also, more definition should be provided to justify the adequacy of the number and types of independent calculations that will be performed under this section of the plan, e.g., level of confidence in sampling plan. selected, etc.
12.
Somewhere in the program plan, definitions should be provided for:
(1) Significant deficiency or error, and (2) Insignificant Deficiency or error.
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i UNITED STATES
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NUCLEAR REOULATORY COMMISSION
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2 1460 MasisA LA8sE. SUITE 240
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wausur casso cauroama 845u January 15, 1982 MEMORANDUM FOR:
R. H. Engelk'en, Regional Adninistrator
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J. L. Crews, Chief, Division of Resident, Reactor Projects, and E'ngineering Inspection FROM:
P. J. Morrill, Reactor Inspector, Region V K. S. Herring, Systemctic Evaluation Program Branch, Division of Licensing, NRR J. R. Fair, Reactor Engineering Branch, IE
SUBJECT:
PRELIMINARY ASSESSMENT OF R. L. CLOUD AND PG&E REVERIFICATION PROGRAM Based on recent inspection efforts of the R. L. Cloud /PG&E Reverification Program, it appears, in our opinion, that there are serious concerns requiring prompt NRC Management / Staff evaluation and direction. Without staff evaluation of the proposal submitted by PG&E on December 4,1981, and direction and clarification to PG&E/ Cloud as to what is acceptable or not accepte.ble, Cloud and PG&E will continue on their present " Program" with its various potential problems; while the inspection staff will be delayed in its effort by a lack of sufficient definition as to what constitutes a program acceptable to NRC.
Messrs. K. Herring and J. Fair of Headquarters have worked during the period of January 13-15, 1982, to develop the following potential problem with ongoing work by R. L. Cloud Associates.
1.
Issues Identified by Cloud's Preliminary Seismic Reverification Program are not Necessarily Being Pursued by Cloud's Current Work.(e.g.).
- Westinghouse adequacy to correctly use Blune's Seismic Response (incorrect use of Tau Filtered Vertical Spectra in at least two instances).
- Adequacy of Control Room equipment qualification based only on a review of document transmittal dates, not the documents themselves.
2.
The Scope of the Work Being Done in Accordance with the December 4,1981 Proposed Seismic Reverification Program Appears to be Less than that Required by the NRC's Order of November 19, 1981 (e.g.).
- There is no provision in Cloud's work to verify PG&E's structural element evaluations given input from Blune.
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- Cloud has excluded Westinghouse and General Electric from further examination "...because their work was perfonned in support of the sale and licensing of the NSSS and associated products.
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2.
R. H. Engelken January 15, 1982 3.
The Criteria for Identification, Significance Determination, Reporting
" Deviations" and Follow-up of Errors and Omissions Discovered have not been Established or defined (e.g.)
- The auxiliary building seismic responses documented in the Hosgri report were not up-dated upon the receipt of the final Blume report to PG&E in October 1979. The NRC was not informed when PG&E became aware of this deficiency in November 1981.
- The intake structure seismic responses documented in the Hosgri report appear to have similar problems which have not been reported previously to the NRC although PG&E and Cloud personnel are evaluating the problem.
- Further deficiencies in this area are discussed in Item 5, below.
4.
The Level of Reverification and Additional Sampling Appear Inadequate. (e.g.)
- The independent reverification of the auxiliary building structure is being done hy one individual with hand calculations of the building masses and stiffnesses. No independent computer run or examination of Blume's work is expected unless the masses or stiffness developed hy PG&E are found to be greater than 10 to 15 percent
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in errer.per the December 4,1981 PG&E submittal. Review indicates a problem in this area in the Blume QA/QC program.
- The seismic model for a fan cooler was found by Cloud to be in error. The error turned out to be conservative (in this case),
consequently, no additional sampling appears to be scheduled for such cases.
5.
The Acceptance Criteria and Nethodology of the Reverification Program are not Adequately Defined. (e.g.).
- The methodology used for evaluation of structures (auxiliary building),
piping and equipment (in most cases) is the same as that reportedly used hy PG&E or its contractors.
State of the art improvements are 9enerally not being used.
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- On January 4,1982, Cloud personnel documented " Criteria and Methodology for Independent Calculations" and " Criteria for Indepen-4 dent Evaluation" hy an internal memo. This material has not been incorporated into the December 4,1981 program plan. Both sets of criteria do not define in much detail the criteria for reanalysis, the acceptance and rejection criteria, and the criteria to be used for considering sample expansion. Discussions with Cloud's employees indicated that confusion and a lack of defined goals exist in these areas.
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R. H. Engelken J,anuary 15, 1982 These problems point out the need to promptly:
Accept or Reject Cloud Determine the Adequacy of the Reverification Program
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Develop Necessary Guidance (Scope, Criteria, Reporting, Methodology, etc.)
A convenient form to resolve these concerns is a meeting with PG&E and their contractors such as that previously scheduled for January 19,1981, and subsequently postponed. We propose that a meeting of appropriate NRC Staff be held as soon as possible to discuss further the concerns described above, to be followed up by a meeting with the licensee as previously planned.
P.
. Morrill Reactor ~ Inspector, Region.V s
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K. S. Herring
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Systematic Evaluation Program Branch Division of Licensing, NRR J. R. Fair Reactor Engineering Branch, IE
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