ML20211B710

Advises That Author Obtained Listed Info Which May Be of Use in Developing Seismic Reverification Program for Diablo Canyon.Related Info Encl

ML20211B710
Person / Time
Site:	Diablo Canyon, 05000000, Shoreham
Issue date:	10/28/1981
From:	NRC
To:	NRC
Shared Package
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References
FOIA-86-151 NUDOCS 8610200423
Download: ML20211B710 (37)

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8610200423 860930 MES86 151 PDR

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CONTENTION Sa, b, & c QUALITY ASSURANCE / QUALITY CONTROL 1.

STATEMENT OF CONTENTION Sa.

Intervenors contend that the Applicant and Regulatory Staff have not adequately demonstrated that the quality assurance program for the design and installation of struc-tures,. systems, and components for the Shoreham nuclear station was conducted in a timely manner in compliance with the pertinent portions of 10 CFR Part 50, Appendix B, Cri-i teria 1 through 18 and with 10 CFR Part 50, Appendix A, l

Criterion 1 with regard to:

i.

Equipment qualification and the resulting qualification records.

ii.

Organizational independence of inspection i

and construction supervision.

l iii.

Applicant's qualitt program not implemented o-until after a large portion..of plant struc.

~

l tures, systems, and components are designed i

and installed.

iv.

Control of clean rooms anci other special environmental conditions.

l Training, qualification, and assessing of v.

welders anc welding procedures.

vi.

Internal audit frequency and reporting of

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results to management.

vii.

Traceabili~ty of welding records to welders.

viii.

Documentation of test results.

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ix.

Calibration and accuracy of measuring and. test equipment.

Qualificacion and training of NDT personnel.

x.

xi.

Acceptance of incoming equip ~ ment including suitable status indication, such as tags or labels.

I xii.

Release of uninspected equipment for installation.

i xiii.

Indentification,: segregation, review, and release I

of nonconforming items.

5.-1 o

xiv.

Records of nonconforming items.

xv.

Test records.

xvi.

Chronological records of detection and resolution of all safety-related problems detected during construction.

xvii.

Revision control of design documents.

xviii.

Selection, evaluation, and source inspection for suppliers.

r

. xix.

Technical adequacy of procurement documents.

Control of changes to procurements documents.

xx.

Mh b.

Intervenors contend that the Regulatory Staff's Inspec-tion and Enforcement (I&E) Program has not adequately verified g sli "

that the Applicant's quality assurance program for Shoreham l

has been implemented in accordance with the requirements of 10 CFR Part 50.'34(a), paragraph 7 and the pertinent portions of 10 CFR.Part 50, Appendix B, ' Criteria 1 through 18.in that:

I 1.

The I&E Program has identified only the symptoms of the Shoreham quality deficiencies, and has not required Applicant to initiate corrective' action to resolve the root causes.

ii.

The I&E's reliance on the Applicant for primary inspections at Shoreham with NRC officials ~ serving as auditors has recently. proven to be inadequate in timely identifying quality deficiencies at other nuclear. facilities.

(e.g., Browns Ferry, North Anna, Davis Besse, and Racho Seco.)

iii.

The I&E Program has no objective and quantitative measurement of the Shoreham quality program effec-tiveness.

l

.Sc.

Intervenors further contend that the quality asurance program description for operation of the Shoreham plant, as provided in the FSAR, does not comply with 10 CFR Part 50.34-(b)(611), and with the pertinent portions of 10 CFR Part 50, Appendix B, Criteria 1 through 18 with regard to:

'i.

Failure to address, 'as a minimum, each of the cri-teria in Appendix B in sufficient detail to enable an independent reviewer to determine whether and how all the requirements of the Appendix will b6 satisfied.

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Failing to adequately describe the extent t6 which the operations phase quality assurance program will follow the guidance in WASH-1284, WASH-1283, and WASH-1309.

iii Failing to adequately identify, report, and N

analyze all equipment failures discovered during operation and maintenance.

Failing to ensure that replacement materials and parts are equivalent to the original equipment, that replacements are installed in accordance with adequate pg ess procedures, and that the repaired or rewe a structure, system, or com-4 ponent is adequately inspected and tested.

2.

CONTENTION CHRONOLOGY t

i This contention,.along with all other currently. active County contentions, was originally described in County's 16, 1977.

All Amended Petition to Intervene, dated September-parts of this contention with the exception Sc('ii) were ruled l

l as acceptable for discovery at the ' October 11, 1977 Prehearing Conference.

The continued acceptability of all such parts was confirmed in the-Board's order of January 27, 1978 and in addition, Part Sc(ii) was included as acceptable for discovery

. subject to the condition that the County would. be required to

, file a precise specific contention for Sc(ii) at the close of

, discovery.

3.

BASIS FOR CONTENTION i

The basis for this contention is jos stated in the Amended Petition To Interview dated' September 16, 1977, and as further elaborated upon in the County's-Response to Applicant's Second Interrogatories dated January 31, 1978, pages 8 through 14 In order to present a complete status of the contention in this report, the following discussion includes extracts from 5-3

'e the preceding two documents along with relevant new infer-mation.

i Appendix B, Quality Assurance Criteria For Nuclear

~

Power Plants and Fuel Reprocessing Plants," to 10 CFR Part i

50 requires, in.part, that "every applicant for an opera-tive. license is required by the provisions of Part 50.34 to include in its Final Safety' Analysis Report (FSAR) a de-l l

scription of the quality assurance program for operations.

The 18 criteria of Appendix B set forth the quality assurance requirements which " apply to all activities affecting the safety-related functions of those structures, systems, and I

I

~

components."

In addition, General Design Criterion'.1, l

" Quality Standards.and Records," of Appendix A to 10 CFR -Part 50 describe quality assurance requirements.-

The latest regulatory requirements are, in addition, de-fined by the Staff in the following Regulatory Guides and documents:

a.

Regulatory Guide 1.28, March 1978 (ANSI N45.2-1977) b.

Regulatory Guide 1.30, August 1972 (ANSI'N45.2.4-1972) c.

Regulatory Guide 1.37, March 1973 (NASI N45.2.1-1973) d.

Regulatory Guide 1.38, May 1977 (ANSI N45.2.2-1972)

.e.

Regulatory Guide 1.39, September 1977 (ANSI N45.2.3-1973) f.

Regulatory Guide 1.58, August 1973 (ANSI N45.2.6-1973) g.

Regulatory Guide 1.64, June 1976 (ANSI N45.2.11-1974)

.i h.

Regulatory Guide 1.74, February 1974 (ANSI N45.2.10-1973) l 5-4

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i.

Regulatory Guide 1.88, October 1976 (ANSI N45.2.9-1974) j.

Regulatory Guide 1.97, April 1976.(ANSI' N45.2.5-1974) k.

Regulatory Guide 1.116, May 1977 (ANSI N45.2.8-1975) 1.

Regulatory. Guide 1.123, July 1977 (ANSI N45.2.13-1975)

I m.' ANSI N45.2.12-1977 The Applicant's description of quality assurance measures are summarized in Section 17 of the FSAR.

3a.

Implementation of Quality Program During Construction As stated in County's Amended Petition to Intervene, Page 6, 10CFR 50 Appendix A, Criterion 1 applies to al1 twenty of. the issues (i through xx) listed in Contention 5 (a).

The pur-

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pose of discovery, of course is -to Feview the QA records for design, manufacture, and construction in order to further particularize the precise details of'the issues and in-adequacies identified in the contention.* County's Request

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No. 1 for the Production of Documents dated December 23, 1977 requested that the Applicant produce documents for the County to assist in the determination requested in this question.

• Applicant's January 17, 1978 response to this request indi-

'cated that-four listed Lilco documents would be made avail-

,able for County's review during normal business-hours at Lilco's corporate headquarters.

County's consultants con-ductedaninitialreviewofthfsedocumentsonJanuary 30, 1978.

Applicant's response for the production of other documents for County's.use was a refusal to produce claiming they contained confidential commercial information and also claiming the requests were too broad in scope.

Later the Applicant did 5-5 1

l -- _

agree to provide the County with an index of the requested quality records.

In drder to review the detailed records (such as radiographs)a proprietary agreement will be re-quired to permit County and County's consultants access to the QA records.

Such an independent audit of QA records should be conducted by the County.

In addition, the County shoul'd review the NRC I & E reports related to Shoreham, as well as the I & E. reports describing the QA inspections at the (1) (2) maj or vendors to Lilco (such 'as G.E.).

Examples of recent I & E reports documenting Lilco's failure to implement the required QA measures for weld rod control and equipment storage are included as Attachments A and B of this report.

It is also possible at this time to identify the specific criteria of' 10 CFR 50 Appendix B' which do apply to the twenty issues identified in Contention 5 (a).

Ihespecific.

i criteria are as follows:

Contention 5 (a) Issue Appendix B Criterion

~

i III, XI, XVII i

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iii

- II

. 4 iv XIII

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v II, IX, IVII l

vi

- XVIII vii VIII, IX i

viii V, XI, XIV, IVII l

ix XII x.

XVI, XI, XIV, XVII f"

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--better document its inspection findings.

.The. Commission is aware of the need for improvements and has made some changes, one of which is the assignment of resident inspectgry to selected I

reactors under construction." tJ1 To evaluate the manner in which NRC inspectors did their work, GAO reviewed inspection reports at all five NRC regional offices and selected individual report items for detailed review.

During visits to 6 of the 7 powerplant construction

. sites, GAO reviewed 45 of the NRC inspection report items to determine if they could retrace the steps of the NRC in-spectors, identify and review the documents the Staff re-viewed, and interview the s'ite personnel the Staff contacted.

~

In some cases GAO could not determine which records the NRC inspector -had reviewed because.that information was not shown in the reports.

In other cases, GAO found errors in the reports which made it. difficult for them to follow the work performed by NRC.

In addition, GAO identified instances where NRC inspectors overlooked or did not report certain weaknesses which GAO believe they should.have found and re-ported.

~

' Based upon the GAO findings and NRC's responses, GAO con-cluded that 31'of the 45 inspection report items, about 69 per-cent, were deficient in some manner.,GAO noted, however, that some of these items are ibsignificant and others re-flect their judgment as opposed to NRC's.

Also, while GAO did not attempt to determihe the safety significance of these 5-8

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Other studies conducted by and for the' Staff have identified deficiencies in the conduct of.the I&E program.

In particular, questions need to be answered about the Staff policy of relying on builders for primary inspec-tions with NRC officials serving as only auditors.

Because of the history of past I&E failures and the many proposed changes to I&E practices, the NRC should clearly describe in the SER the extent of the proposed I&E program for Shoreham.

Since a key factor in assessing the potential risk of a nuclear plant is the assumption of a disciplined, thorough quality assurance program.

Any inadequacies in the Shoreham operating licensing review of the quality program may allow deficiencies in the program implementation which will pose a significant hazard to the public health and safety.

3c, QA Program for Operat' ions NRC document WASH-1309, " Guidance on Quality Assurance Requirements During the Construction Ehase'of Nuclear Power i

i i

Plants," WASH-1283, " Guidance on Quality Assurance Requirements i

, During Design and Procurement Phase of Nu'elear Power Plants,"

l

.,and WASH-1284, " Guidance in Quality Assurance Requirements During the Operations Phase'of Nuclear Power Plants" contain

~

ANSI quality assurance standards which describe requirements for implementing various portions of the quality assurance program.

A number of the stand'ards contained in WASH-1309, WASH-1283, and WASH-1284, were in draf t form.

Thus, in a e

6 5-10

number of instances, the provision of the WASH documents applicable to Shoreham have'been superceded by the issued ANSI standards and the accompanying Regulatory Guides.

The Staff procedures for reviewing compliance to WASH-1309,

~

WASH-l283, and WASH-1284 are summarized as follows in Standard Format and Contents of Safety Analysis Reports for Nuclear Power Plants (PB-245-724, Revision 2, October 1975):

"Where a portion of the QA program to be implemented will follow the guidance provided by a regulatory guide, WASH-1283,. WASH-1309, or WASH-1284, the program desc~ rip-tion may consist of a statement that the guidance will be followed for that.cortion of the QA program.

When these documents are used in describing the" QA program, the applicant should indicate how the guidance documents will be aoolied to portions of the QA program and s,hould l

delineate the organizational element responsible for implementing various provisions of the. respective guidance i

documents within each major organization in the project, including that of the applicant, the architect-engineer, the nuclear steam system supplier, the constructor, the 1

construction manager (if other than the constructor).."

(Emphasis added)

The Applicant in the FSAR, ' Appendix 3B, indicates the in-tent to conform to some of the NRC Regulatory Guides which address quality assurance.

The Applicant's agreement to im-

' plement the current Regulatory Guides is clearly not evident from the FSAR.

Furthermore, on page 17-2 of the Standard l

. Format and Content of SARS (PB-245 724) the NRC states that "where a portion of the QA Program to,be implemented will follow the guidance provided by' a regulatory guide.....the -

Applicant should indicate how the guidance document will be applied to portions of the QA program."~

(Emphasis added)

,The Applicant's brief and general description of the Shoreham 5-11 l

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QA program in the FSAR does not describe how the relevant regulatory guides on QA will be implemented.

The' procedures which describe how the Shoreham QA program is to be accomplished may be described in the Quality Assurance Manual and its implementing procedures rather than in the

~

FSAR.

For power plant ouners with little or no previous nuclear power plant experience, such as Lilco, it is im-perative that the how of the.QA program be clearly defined and described in the PSAR, as required by 10 CFR, Part 50.34, which states that "the description of the quality assurance program.....shall include a discussion of how the applicable requirements of Appendix B will be s.atisfied."

(Emphasis added)

Similar statements concerning the necessity to describe how the program will be implemented are included.in the Section 17.1 of the Standard Review Plan, (NUREG-75)0S7). and page

'7-1 of the' Standard Format and Content of Safety Analysis.

1 Report for Nuclear Power Plants (PB-245-724).

Clearly, a cursory recapitulation of the 18 ' criteria of Appendix B in

. the FSAR does not meet the requirements of 10 CFR, Part 50.34.

4.

REF5RENCES

~

1.

NRC I&E Reports for Shoreham. Vendor Inspection Vendor Inspection Program 2.

RC I&E Reports (General Elec'tric design and/or manufacturing plants particularly).

3.

EMD-78-80, "The Nuclear Regulatory Commission Needs to Agressively Monitor and Independently Evaluate Nuclear Power Plant Construction," GAO, September 7,1978..

5-12

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Examples include:

(a)

NUREG-0321, A stu'dy o~f the Ncclear Regulatory Commission Quality Assurance Program, August

1977, U..

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(b)

NUREG-0397, Revised Inspection' Program for Nuclear Power Plants, March 1978, U. S. NRC (c)

NUREG-0425, NRC Inspection Alternatives, February 1978

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U. S. NRC.

~~ '

(d)

GAO ' Report EMD077-30, ' Allegations 'of Poor Con-struction Practices on the North Anna Power-

~

plants, June 2, 1977.

(e)

Browns Ferry Nuclear Plant Fire, Hearings before the Joint Committee on Atomic Energy, September 16, 1975.

(f)

NRC Press Release 76-122, Independent Assessment o'f

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NRC Quality Assurance Activities Planned, May 25, 1976.

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5.'. SUlOIARY AMD CONCLUSIONS The FSAR and the cited reports critiquing the NRC I6E program pr6 vide an inadequate basis for the County to con-clude that the quality assurance program 6f the Applicant and the NRC to be provided for the safety related stru'etures, systems, and components of the Shoreham Nuclear Power Stations, provides a reasonable assurance of safety.

For all the fore-going reasons, the County should request the Applicant to amend tl.e FSAR to reflect the recommended analyses, review, and documentation of the quality assurance program as de-i scribed in this report.

Any resulting modifications to

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Category 1 structures, systems, and components sh6uld be defined prior to the issuance of an. operating license for i

Shoreham.

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I.

THE' COURSE OF NEGOTIATIONS i

Suffolk County (County) filed a petition to intervene in this proceeding on March 17, 1977, raising numerous contentions.

For the next two years, the County and Long Island Lighting Company (LILCO) dealt with one another in..a formal, adversarial fashion.

There resulted much written and o,ral argument, many Board rul,ings, and the generation of far more heat than light.

Early in 1979, the County and Company, encouraged by the NRC Staff, decided to try an in. formal approach, in the hope that it would prove less sterile than prior exchanges.

This hope has borne fruit.

Thousands of man-hours have been devoted to the new.

approach by the parties' representatives and consultants.

The NRC Staff has actively participated in the. process, while the New York State Energy Office has monitored it.

The parties have met 18 times in plenary sessions:

Meeting Dates Meeting Places March 30, 1979 Bethesda, Md.

April 20, 1979 Shoreham, N.Y.

May 2, 1979 Boston, Mass.

June 5, 1979 Shoreham, N.Y.

, November 2, 1979 Shoreham, N.Y.

December 11-12, 1979 Boston, Mass.

June 17, 1980 Shoreham, N.Y.

l July 29-30, 1980 Boston, Mass.

August 29, 1980 Bethesda, Md.

October 9, 1980 Boston, Mass.

November 13, 1980 Shoreham, N.Y.

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January 21, 1981 Shoreham, N.Y.

February 24, 1981 Bethesda, Md.

April 9, 1981 Shoreham, N.Y.

May 14l 1981 Boston, Mass.

May 28, 1981 Shoreham, N.Y.

July 9, 1981 Shoreham, N.Y.

September 9, 1981 Mineola, N.Y.

Between meetings, there has been significant communication among the parties by phone and mail, and there have' occurred a-number of smaller working sessions involving consultants who were dealing in detail with pending technical issues.

As indicated, a huge amount of time has been devoted to this process of information exchange, explanation and negotiation --

man-hours of a magnitude akin to those required for lengthy hearings.

Five stipulations among the County, Company and NRC Staff have resulted so far from this process, dated June 5, 1979, November 2, 1979, dune 10, 1980, October 9, 1980, and

' January 21, 1981.

Each of these agreements has been accepted i

by the Atomic and Safety Licensing Board.

See ASLB Orders of i

June 28, 1979, January.7, 1980, June 26, 1980, October 27, 1980, and February 17, 1981.

The process has hinged on the following factors:

(1) Good faith efforts by the County to state l

clearly and concretely its concerns; (2).Similar efforts by LILCO and/or the NRC Staff to respond directly and fully to these concerns orally and via documents -- and to respond I

without regard to whether the concerns have been previously recognized as " contentions" in the licensing proceeding:

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(3) A willingness by the County to. agree that its concerns have been resolved when, in fact, LILCO and/or the NRC Staff have provided answers satisfactory to the County; and (4) A, willingness by LILCO to take certain steps not compelled by law in order to resolve other County concerns.

II.

RESOLUTION OF CERTAIN COUNTY CONTENTIONS

~

After more than four years of intense participation in this proceeding, the County believes that the majority of its concerns have now been satisfactorily resolved either through information and explanations provided by the Applicant and NRC Staff, or by LILCO's' commitments to ta'ke -voluntarily' certain

~

steps regarding Shoreham. - A significant step is the Company's agree, ment to have a County representative on LILCO's. Nuclear Review Board.

Only~by such membership will the County be assured of continuing access to significant information regarding the plant and continuing opportunity to influence I

developments concerning it.

Part III below details the res,olution of most of the Count'y's concerns.

Accordingly, the Coun,ty agrees to pursue no further in this procee. ding its i

previously raised contentions, except as specified in Part V below.

III.

LILCO AGREEMENT TO TAKE CERTAIN STEPS 9

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independently to the~ County; LILCO will also provide to,the County the data from the NRC required high-range radiation, temperature and pressure monitors in the containment building and high-range

. radiation monitors in the containment building vent.

i E.

~ Physical Inspection and QA/QC Review LILCO will hire an independent consultant to perform a non-NRC, third-party physical inspection and review of the

~

quality assurance / quality control program for Shoreham.

The i

. review will consider aspects of both construction and

~

operational QA/QC. The following guidelines will prevail:

1.

Selection of Independent Consultant The County has approved-as. acceptable bidders for the independent QA/QC work in question the experiencedt consultants listed in County counsel's September 11, 1981 letter to Company counsel.

None of these consultants is an employee of Stone & Webste'r, General Electric, or any other contractor having direct responsibility for the Shoreham QA/QC progr'am'." Th'e low evaluated bidder from among these consultants will do the vor,k, and that bidder will be chosen in compliance with the bidding procedures required by the

- Public Service Commission and LILCO.

Time constraints j

may necessitate the more rapid selection of a County-approved consultant to do the work described in paragraph E.2.(e) below.

If so, that consultant will be one of the certified NDT Level III experts also listed in County counsel's September 11, 1981 letter to Company counsel.

j

,2., Scope of Review The assessment of the Shoreham QA/QC program will include:

(a) a review of on-site QA/QC records for, and a physical inspection of, one electrical system (reactor protection system, ESAR figure 7.2.1-1) and one mechanical system, including its l

f structural support, chosen by the consultant from among the following three systems, core spray l

(FSAR figure 7.3.1-4), high pressure coolant injection (FSAR figure 7.3.1-1) and residual heat removal (FSAR figure 7.3.1-7 ),

covering:

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1-16-(i) the des ~ignation of safety-related items to determine 'whether the systems' structures and components have been properly classified, y

(ii) the LILCO and S&W QA/QC programs for design and construction of the systems to identify those safety-related structures and components-not designed or constructed in accordance with 10 CFR, Part 50, Appendix B, and assess the

-safety. significance of any deviation,

~

, (.i.ii ) training and qualification records of construction and inspection personnel, (iv) records concerning the identification and control'of installed material, parts and components,

' ' lv) records.concerning the control of special processes, (vi) disposition of non-conformances,

~

~ (vii) corrective action measures and timely close-outs, (viii) audit follow-ups and timely close-outs, (ix) equipment qualification records, (x) drawing change control procedures including field changes, (xi) comparison of "as-built" drawings to actual plant configuration, (xii) receiving inspection and test results, i

(xiii) material certifications, (xiv) concrete strength where applicable, (xv) visual inspection of the systems including

welds, (xvi) cable identification and separation, (xvii) verification of the torque of bolts, e

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17 (xviii) control panel functional test results,

'xix) non-destructive test records,

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(xx) the program for control of materials, parts and components for non-safety grade portions of the systems, and (xxi) a determination of the adequacy of the L:LCO and Stone & Webster QA/QC programs and their implementation based on all the above; (b) a comparison of the LILCO operational QA/QC program to current NRC Regulatory Guides specifically related to QA/QC activities; (c) a review of LILCO's operational QA/QC program, including:

(i) the qualification of the Shoreham QA/QC staff, (ii) the availabilit'y: of QC personnel on off-

shifts, (iii) the availability of "as-built" drawings, (iv) 1the selection of replacement materials and parts for safety-related items, the applicability of the.QA/QC program to (v) replacement electrical and instrumentation components, modules and equipment, (vi) ~ the handling and installation of replacement parts and materials for safety-related items, and (vii) the program for procurement of non-safety related replacement materials and parts; and

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a documentation rev$ tw of the ~ reactor pressure (d) vessel inspest--A r'ictices and results during the fabrication; and vessel's desar.2 arc.

(e) a review and surveillance of_ LILCO's 1981 pre-service inspection (PSI) ultrasonic examinatien (including checks on instrument calibration) of the Shoreham reactor pressure vessel beltline welds and pressure v'essel to including nozzle welds to ASME code' requirements, verificaton of earlier PSI ultrasonic data on r

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selected beltline welds and pressur,e vessel to nozzle welds to review the adequacy of the earlier

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1 PSI physical inspection program; any deficiencies discovered will be subject to additional physical inspection and review until the pressure vessel can be verified as adequate and satisfactory relative to ASME code requirements; (f) the cost of this QA/QC assessment is expected to be between $50,000 and $150,000.

3.

Review

' This QA/QC^ report and its recommendations will be reviewed by the Company's Nuclear Review Board, nmong others, and will be provided to the County on a timely basis.

If the recommendations include the need to conduct further inspection and testing of the sample or other systems, the work will be conducted in

~

accordance with MIL-STD-105D (" Sampling Procedures and Tables for Inspection by Attributes").

4.

Schedule The Company has begun the process of initiating the physical inspection described above, which will be pursued concurrently with negotiations regarding stipulation and settlement between the Company and County.

The physical inspection and QA/QC review wit 1 q

be completed prior.to fuel load, and any appropriate action in response to it will be taken as soon as feasible thereafter.

F.

Security Planning LILCO will give the County's consultant on security matters access to the entire Shoreham security plan.

Such access will be governed by the protective order and non-disclosure agreements already in effect-for security issues in the Shoreham operating license proceeding.

The plan will be I

~

made avai'lable immediately upon execution by the County and Company of this sixth Stipulation.

If, after review of the entire plan, there remain concerns about its adequacy that e

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n to n-y Status cf NRR Efforts Regarding PG&E Seismic Re-Analysis of the Diablo Canyon Unit 1 Containment Annulus Area On October 9,1981, PG&E met with the NRC staff in Bethesda.. Maryland to discuss the discovery of errors in the analysis of the seismic design of equipment and gomponents in the annulus area of the Diablo Canyon Unit I containment. A transcript of that meeting was made and distributed (Board Notification 81-29, dated October 16, 1981).

At the conclusion of this meeting, Mr. H. Denton, Direc' tor' of NRR indicated

~

that the following info'mation would be required to be submitted by PG&E' r

for staff review (Tr. pgs.102 through 111):

o A technical' report which sumarizes the errors ' detected, PG&E actions, de'scription of PG&E's reanalysis effort and the technical bases on which modifications to the facility were determined to be needed or not.

o A description of PG&E's reverification program plan of the seismic design of all safety-related eqaipment.

'o An interim report on the results of a verification of the transfer and utilization of information and data between URS/Blume and PG&E used in the seismic design of Diablo Canyon since the Hosgri Fault reanalysis of 1977.

n During the period of October 14 through 16, 1981, representatives of the j

NRC staff and their consultants met with PG&E staff in San Francisco, California. At the conclusion of that meeting the staff requested additional information (including weight and* weight distribution for use in constructing an analytical model' of the annulus region) from PG&E and described the c'ontent of audit packages that the staff would expect'to review'upori completion of PG&E's reanalysis effort. ThestaffreduiredPG&Etoprovide a schedule for the submittal of their technical report on the reabalysis~"

effort; the completion of audit packages and the verification program plan and. interim results. A meeting summary of the October 14-16 meetings with PG&E was prepared on October 19, 1981 and distributed (Board Notification 81-33, dated October 23,1981).

On October 16, 1981 PG&E transmitted a draft outline of the proposed reverification program to Region V.

On Tuesday,' October 20, NRR transmitted comments on this draft outline to 01&E Region V via a conference call.'

These comments indicated that substantial restructuring of the program would be required in order to be found acceptable by the NRR staff.

On Wednesday, October 21, NRR called PG&E to inquire as to when a letter from PG&E providing schedules would be provided. PG&E indicated that that.let,ter was being prepared and would be sent on Thursday or. Friday.

PG&E also indicated that in developin'g the weight and weight distribution data per the staff's request, potential discrepancies with data originally-used in design exist and was looking into this matter. NRR advised PG&E to promptly notify OI&E Region V if discrepancies other than those formally reported to date were determined to exist.

NRR also inquired as to O

h 1

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'whether a meeting in San Francisco, early the week of 0ctober 26 was

~

warranted.

PG&E. indicated they would advise.

On Thursday October 22,1981, -J. Schuyler, PG&E informed NRR that PG&E could not conclusively confirm that weight distributions used in the original analysis represented the !'as-built" configuration for Unit 1.

As a result PG&E intended to re-run the analytical model for the containment annulus wi-th-newly verified weights-and weight distributions to generate vertical response spectra for comparison with those used initially.and in the reanalysis effort toidate. Since this effort would take a few days rPG&E would not be able to provide the requested schedules to the staff. In addition, Mr..Schuyler indicati;d that a second draft of the reverification program outline would not be avr.ilable until October 26. Mr. Schuyler suggested that any meetings between PG&E and staff be deferred until late in the week of October 26. Mr. Schuyler was advised to promptly notify OI&E Region V and to sent a letter-to NRR by c.o.b. October 23, 1981 l

summarizing the status of PG&E's reanalysis effort.

On October 23, 1981, NRR staff discussed with OI&E HQ's and Region V, via conference call, tentative plans for a meeting with PG&E in San Francisco on Thursday, October 29, 1981.

The attached letter dated October 23, 1981 was received from PG&E.

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FRANK MIRAGLIA 492-7243 i

11/09/81 i

NOVEMBER 9, 1981

' COMMISSION. BRIEFING ON DIABLO CANYON t

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FRANK MIRAGLIA 492-7243 11/09/81 BRIEFING OUTLINE O

BACKGROUND o

ERRORS DETECTED TO DATE o

PG8E PROPOSED REVERIFICATION PROGRAM o

TENTATIyESTAFFCONCLUSIONS 0

PG&E'S REVERIFICATION PROGRAM PROPOSED BY STAFF o

5 AFF ACTIONS o

SCHEDULE l

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o FRANyMjRAGLIA 1$/0981 o

BACKGROUND SEISMIC DESIGN ERRORS DETECTED IN SEPTEMBER FUEL LOADING 0F PLANT DEFERRED HQ'S MEETING WITH PG&E ON OCTOBER 9 INITIAL STAFF REQUIREMENTS TECHNICAL REPORT ON REANALYSIS AND MODIFICATION REVERIFICATION OF SEISMIC DESIGN OF ALL

' SAFETY-RELATED SYSTEMS PRIORITY REVERIFICATION OF SEISMIC DESIGN INVOLVING URS/BLUME PRELIMINARY TECHNICAL AUDIT OCTOBER 14-16

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REGION V INSPECTION ACTIVITIES OCTOBER 14-23 HQ'S MEETING WITH PG&E ON NOVEMBER 3 d

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FRANK MIRAGLIA.

492-7423 11/09/81

=-

0 ERRORS DETECTED TO DATE INAPPROPRIATE APPLICATION OF CONTAINMENT ANNULUS " DIAGRAM" INCORRECT DISTRIBUTION WITHIN PG8E OF CORRECT SEISMIC RESPONSE SPECTRA INCORRECT WEIGHT AND WEIGHT DISTRIBUTIONS FOR EQUIPMENT, COMPONENTS AND PIPING IN CONTAINMENT ANNULUS.

ERRORS, UNRELATED TO ABOVE, DETECTED DURING RE-ANALYSIS EFFORT ERRORS, DETECTED DURING REVERIFICATION EFFORT l

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-RANyM{RAGLIA

$$09f81 PG&E'S REVERIFICATION PROGRAM o

COMPLETE REVERIFICATION OF SEISMIC DESIGN OF I

SAFETY RELATED STRUCTURES, SYSTEMS AND COMPONENTS BY AN INDEPENDENT CONSULTANT RETAINED BY PG&E DRAFT PROGRAM OUTLINE PROVIDED TO ALL 4

PARTIES (BN-81-38) i EFFORT INCL.UDES REVIEW 0F ALL URS/Bl.UME PG&E INTERFACES ON A PRIORITY BASIS o

INTERNAL QA/QC REVIEW BY PG&E OF ALL PRE-1978 SERVICE CONTRACTS RELATED TO SEISMIC DESIGN OF SAFETY-RELATED STRUCTURES, SYST MS AND COMPONENTS i

REVERIFICATION TO BE DONE IN AEEAS FOUND t

TO BE DEFICIENT 1

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FRANy{RAGLIA il598$

TENTATIVE STAFF CONCLUSIONS o

LACK OF RIG 0R AND FORMALITY IN DESIGN CONTROL:

- THE PG8E QA SYSTEM DID NOT APPEAR TO HAVE ESTABLISHED A FORMAL INTERFACE WITH AND QA CONTROLS ON URS/BLUME THE PG&E QA SYSTEM DID NOT APPEAR TO ADE9UATELY CONTROL &

DISTRIBUTE DESIGN INFORMATION THE PG&E 0A SYSTEM DID N0i APPEAR TO HAVE ESTABLISHED A FORMAL INTERFACE AND QA CONTROLS ON OTHER SERVICE CONTRACTORS.

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09 81 PG8E REVERIFICATION PROGRAM PROPOSED BY STAFF (SUBJECT OF 50.54F LETTER) o PRIOR TO FUEL LOAD AND OPERATION UP TO 5% POWER INDEPENDENT AND COMPLETE REVERIFICATION OF ALL SAFETY-RELATED ACTIVITIES PERFORMED BY URS/BLUME IMPACT OF ALL ERRORS DETECTED ON FINAL DESIGN EVALUATED AND REANALYSIS DOCUMENTED IN TECHNICAL REPORT ALL APPLICABLE MODIFICATIONS TO FACILITY DESIGN RESULTING FROM REANALYSIS AND REVERIFICATION EFFORTS BE COPPLETED o

PRIOR TO EXCEEDING 5% POWER INDEPENDENTANDCOMPLETEDESIGNREVIEWANDREVERIFICATION OF ALL OTHER PRE-JUNE 1978 SERVICE-RELATED C0flTRACTS IflDEPENDENT AND SAMPLlllG REVIEW AND REVER!FICATION OF PG&E INTERNAL DESIGN ACTIVITIES IflDEPENDENT AND SAMPLING REVIEW AND REVERIFICATION l

OF POST-1978 SERVICE CONTRACTS ALL APPLI. CABLE MODIFICATIONS TO FACILITY DESIGN RESULTING FROM REANALYSIS AfiD REVERIFICAT!0il EFFORTS BE COMPLETED i

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FRANK MIRAGLIA

$$/09hf PG8E REVERIFICATION PROGRAM PROPOSED BY STAFF (SUBJECT OF 50.54F LETTER) CONTINUED o

PG&E TO PROVIDE:

DETAILED PROGRAM PLAN FOR CONDUCT OF INDEPENDENT DESIGN REVERIFICATION PROGRAMS DESCRIPTION OF QUALIFICATION OF PERSONNEL AND CONTRACTORS PERFORMING INDEPENDENT DESIGN REVERIFICATION PROGRAPS l

FRANK MIRAGLIA 1$ 69f$f.

o STAFF ACTIONS ISSUE 50.54F LETTER REQUIRING REVERIFICATION PROGRAM BY PG&E MONITOR PG&E'S REVERIFICATION EFFORTS (BI-WEEKLY REPORTS FROM PG&E)

REVIEW PG&E'S REVERIFICATION PROGRAM PLAN REVIEW QUALIFICATIONS OF PERSONNEL / CONTRACTORS CONDUCTING REVERIFICATION PROGRAMS REVIEW'AND AUDIT PG&E'S REVERIFICATION REPORTS PERFORM TECHNICAL REVIEW 0F PG&E RE-ANALYSIS PERFORM SITE INSPECTIONS TO VERIFY MODIFICATIONS e

FRANK HIRAGLIA 492-7423

.11/09/81 SCHEDULE TECHNICAL REPORT REVERIFICATION OF URS/BLUME - PG&E' INTERFACES REVERIFICATION OF PROGRAM PLAN (RESTRUCTURED PER STAFF REQUIREMENTS).

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REVERIFICATION REPORTS PRE-1978 SERVICE CONTRACTS INTERNAL PGRE DESIGN REVIEW POST-1978 SERVICE CONTRACTS e,

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DIABLO CANYON UNIT 1 DESIGN VERIFICATION PROGRAM MILESTONES 8 ELEMENTS LOW POWER LICENSE ISSUED SEPT, 22, 1981 MIRROR IMAGE PROBLEM LATE SEPT.

COMMISSION ORDER (PHASE I)

NOV. 19, 1981 NRR LETTER (PHASE II)

NOV. 19, 1981 BNL EFFORT LATE 1981 IDVP PHASE I PROGRAM APPROVAL MARCH 1982 INDEPENDENCE IDVP ORGANIZATIONS INITIAL SAMPLE DIABLO CANYON PROJECT (DCP)

APRIL 1982 PG&E/BECHTEL ORGANIZATION INTERNALTECHNICAL PROGRAM (ITP)

PHASE I PROGRAM EXPANSION MAY 1982 CORRECTIVE ACTION PROGRAM BNL REPORT AUG 198?

1

w IDVP PHASE II PROGRAM APPROVAL DEC, 8, 1982 INDEPENDENCE IDVP ORGANIZATIONS INITIAL SAMPLE ADDITIONAL VERIFICATION 3-STEP LICENSING PROCESS APPROVAL DEC 8, 1982 CONSTRUCTION DA VERIFICATION SEPT. 1982 DCP FINAL REPORT PHASE I SEPT,.1982 TO OCT, 1983 DCP FINAL REPORT PHASE II JUNE 1983 IDVP FINAL REPORT MAY 1983 TO OCT, 1983 ASLAB HEARINGS ON CONSTRUCTION QA JULY 1983 t-SER SUPPLEMENT 18 AUG, 1983-SER SUPPLEMENT 19 OCT, 1983 ASLAB HEARINGS ON DESIGN QA NOV. 1983 2

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O CURRENT STATUS UNIT 1 1.

LOW POWER LICENSE ISSUED SEPT, 1981 SUSPENDED NOV. 1981 2.

AUTHORIZED FOR:

MODE 6 - (RE) FUELING MODE 5 - COLD SHUTDOWN FUEL LOADED COLD SYSTEM TESTING ONGOING

-3.

ASLAB FULL POWER HEARINGS CONSTRUCTION 0A - DENIED DESIGN QA

- COMPLETED DECISION EXPECTED EARLY 1984 4.

LICENSEE SCHEDULE MODE 4 - HOT SHUTDOWN DEC. 30 MODE 3 - HOT STAND BY MODE 2 - STARTUP JAN, 16 MODE 1 - POWER OPERATION FEB, 16 FULL POWER MAY 15 3

IDVP REVIEW AND EVALUATION WITH RESPECT TO CRITERIA AND COMMITTMENTS-IN FSAR AND OTHER DOCUMENTS ISSUANCE OF ERROR OR OPEN ITEM FILE (E01)

RESOLUTION OF CONCERN (INDEPENDENCE DURING PRE CONCLUSIONARY EFFORT)

CRITERIA FOR ERROR

• ABOUT 330 E01 FILES OPENED, 30 IDENTIFIED AS ERRORS SCOPE 0F PROGRAM

• INTERIM TECHNICAL REPORTS BASIS AND FREQUENCY 4

SCOPE OF IDVP PHASE I:

INITIAL SAMPLE:

AUXILIARY BUILDING 3 PIPING SYSTEMS IN CONTAINMENT-1 FINAL PROGRAM:

SAMPLE OF ALL ACTIVITIES PERFORMED UNDER DCP ENTIRE SEISMIC REVIEW QUALITY ASSURANCE REVIEW f

5 l

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PHASE II:

INITIAL SAMPLE:

AUX. FEEDWATER SYSTEM CRVPS 4160 V ELECTRICAL SYSTEM ADDITIONAL VERIFICATION REDUNDANCY OF POWER SUPPLIES IN UNIT 1/ UNIT 2 SHAPED SYSTEMS SELECTION OF SYSTEM DESIGN PRESSURE AND TEMPERATURE ENVIRONMENTAL CONSEQUENCES OF BREAKS OUTSIDE CONTAINMENT CRICUIT SEPARATION AND SINGLE FAILURE JET IMPIGEMENT EFFECTS FROM BREAKS INSIDE CONTAINMENT QUALITY ASSURANCE REVIEW CONSTRUCTION QA REVIEW 6

l

ERROR CLASSIFICATION ERROR CLASS A -

DESIGN CRITERIA OR OPERATING LIMITS ARE EXCEEDED; PHYSICAL MODIFICATION OR CHANGE IN OPERATING PROCEDURE IS REQUIRED, ERROR CLASS B -

DESIGN CRITERIA OR OPERATING LIMITS EXCEEDED; RESOLUTION POSSIBLE BY MEANS OF MORE REALISTIC CALCULATIONS OR RETESTING, ERROR CLASS C -

INCORRECT ENGINEERING OR INSTALLATION OCCURRED;-

DESIGN CRITERIA OR OPERATING LIMITS ARE NOT EXCEEDED: PHYSICAL MODIFICATION IS NOT REQUIRED.

ERROR CLASS D -

SAFETY-RELATED EQUIPMENT IS NOT AFFECTED; PHYSICAL MODIFICATION IS NOT REQUIRFD (THIS CLASSIFICATION-WAS NOT USED FOR ANY EDI),

i QA FINDING -

NONCONFORMANCE IN 0A WITH SIGNIFICANT OR POTENTIAL IMPACT ON QUALITY l

QA OBSERVATION - NONCONFORMANCE IN DA WITH NO APPARENT IMPACT ON QUALITY i

)

7

O PGgE EFFORT PHASE I:

INITIALLY RESPONSIVE TO IDVP EFFORTS EARLY 1982 EXPANSION OF COMPLETE SEISMIC PEVIEW 0F ALL SAFETY-RELATED STRUCTURES, SYTEMS AND COMPONENTS AND REANALYSIS AS NECESSARY RESULTS INCLUDE STIFFENING 0F CONTAINMENT STEEL ANNULUS, ADDITIONAL PIPE SUPPORTS, BRACING AND CONNECTINS IN FUEL HANDLING BUILDING AND TURBINE BUILDING PHASE II:

EFFORT WAS REACTIVE TO IDVP EFFORTS P0TENTIAL GENERIC CONCERNS REVIEWED FOR ALL STRUCTURES, SYSTEM, COMPONENTS 8

BNL EFFORT CONTAINMENT ANNULUS STRUCTURE VERTICAL ANALYSIS CONTAINMENT ANNULUS STRUCTURE H0RIZONTAL ANALYSIS BURIED DIESEL OIL TANK ANALYSIS PIPING SYSTEM ANALYSIS CONTAINMENT SPRAY LINE OTHER REVIEW EFFORT (SEISMIC) 6 F

9

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e H6 ALLEGATIONS 1)

1 DIABLO CANYON UNIT 2 SCHEDULE MILESTONES SCHEDULED MILESTONE START DATE INTEGRATED LEAK RATE TEST MARCH 16, 1984 HOT FUNCTIONAL ~ TESTS APRIL 6, 1984

. FUEL LOAD AUGUST 31, 1984 INITIAL CRITICALITY NOVEMBER 1, 1984 POWER ASCENSION DECEMBER 1, 198h COMMERCIAL OPERATION FEBRUARY 15, 1985 I

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ElFMENTS OF 50.54(F) LETTER TO DIABLO CANYON 1.

45-DAYS BEFORE FUEL LOAD PROVIDE:

o FOR ALL SEISMIC SERVICE-RELATED CONTRACTS (PRE-JUNE 1978)

RESULTS OF REVIEW 0F QA PROCEDURES & PRACTICES RE ALL SAFETY-RELATED INFORMATION INTERFACES RESULTS OF SUITABLE N0. OF SAMPLE CALCULATIONS TECHNICAL REPORT RE CAUSE AND IMPACT OF ERRORS

• PG&E'S CONCLUSIONS OF EFFECTIVENESS OF DESIGN VERIFI-CATION PROGRAM

• SCHEDULE FOR COMPLETING MODIFICATIONS

• 2.

45-DAYS BEFORE OPERATION ~AB0VE 5% PROVIDE:

o FOR ALL NON-SEISMIC SERVICE-RELATED CONTRACTS (PRE-JUNE 1978)

RESULTS OF REVIEW 0F QA PROCEDURES & PRACTICES RE ALL SAFETY-RELATED INFO. INTERFACES SUITABLE NO. OF SAMPLE CALCULATIONS ASTERISK ITEMS IN 1 AB0VE o

FOR PG&E INTERNAL DESIGN ACTIVITIES (1970-PRESENT)

RESULTS OF REVIEW 0F QA PROCEDURES & PRACTICES BASED ON SUITABLE SAMPLE OF ACTIVITIES RESULTS OF SUITABLE N0. OF SAMPLE CALCULATIONS ASTERISK ITEMS IN 1 AB0VE o

FOR ALL SERVICE-RELATED CONTRACTS (POST-JANUARY 1978)

RESULTS OF REVIEW 0F QA PROCEDURES & PRACTICES BASED ON SUITABLE SAMPLE OF ACTIVITIES RESULTS OF SUITABLE N0. OF SAMPLE CALCULATIONS ASTERISK ITEPS IN 1 AB0VE 3.

30-DAYS FROM DATE OF LETTER PROVIDE:

o QUALIFICATIONS.0F COMPANIES TO CONDUCT REVIEWS 4.

20-DAYS AFTER NRC APPROVAL 0F REVIEWERS PROVIDE:

o PROGRAM PLAN FOR THE DESIGN VERIFICATIONS 5,.

PROVIDE STATUS REPORTS (TWICE A MONTH)

/

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VIOLATIONS CONSIDERED I.

VIOLATION OF QUALITY ASSURANCE REQUIREMENTS 10 CFR PART 50, APPENDIX 3 QA PROGRAF 1 FAILED TO EFFECTIVELY EXERCISE CONTROL OVER THE REVIEW AND APPROVAL OF INFORMATION PROVIDED BY PG8E TO AND FROM URS/BLUME.

QA PROGRAM FAILED TO IDENTIFY ERROR UNTIL AFTER LICENSING UNIT 1.

II.

VIOLATION OF GENERAL DESIGN CRITERION 10 CFR PART 50, APPENDIX A CRITERION 2 STRUCTURES, SYSTEMS, AND COMPONENTS IMPORTANT TO SAFETY SHALL BE DESIGNED TO WITHSTAND THE EFFECTS 0F NATURAL PHENOMENA SUCil AS EARTHQUAKES...,

III.

MATERIAL FALSE STATEMENT PG8E REPRESENTED TO NRC STAFF THAT SEISMIC DESIGN BASIS FOR DIABLO CANY0t' UNIT I WOULD BE BASED UPON UNIT I CONTAINMENT DESIGN CONFIGURATION.

FALSE IN THAT SEISMIC SPECTRA APPLIED WAS BASED, IN PART, UPON UNIT 2, CONFIGURATION.

i MATERIAL IN THAT NRC STAFF RELIED UP3N THIS REPRESENTATION IN ISSUANCE OF OPERATING LICENSE.

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POSSIBLE CIVIL PENALTIES FOR FAULTY QA A.

MARCH 8, 1977

- ERR 0NEOUS DRAWING TO URS/BLUME FROM PG&E B.

AUGUST 3, 1977 ERR 0NEOUS SPECTRA TO PG8E FROM URS BLUME C.

NOVEMBER 3, 1977 END OF THREE MONTH PERIOD AFTER RECEIPT OF ERR 0NE0US SPECTRA AND WHEN INTENSIVE USE AND SCRUTINY SHOULD HAVE BEEN EXPECTED D.

SEPTEMBER 21, 1981 -

DETECTION OF ERRORS TIME PERIODS POSSIBLE PENALTIES A TO B 148 DAYS

$5,000/ DAY

$125,000*

=

B TO C 3 MONTHS

$5,000/ DAY

$ 75,000*

=

C TO D 47 MONTHS

$5,000/ DAY

$235,000**

=

LIMITED BY LA!I TO $25,000/ MONTH ASSUMING EQUIVALENT OF ONE DAY PER MONTH KHEN AUDITS, REVIEWS, CHECKS, ETC., SHOULD HAVE UNC0VERED ERRORS.

740,000 455,000 7,000,000 l

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