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.MEMDRANDUM FOR:
Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
DIABLO CANYON j
Since it has been the subject of some discussion, I recently asked my i
staff to examine the records of the recent Diablo Canyon meetings to determine the staff's posture with respect to the independence question.-
While the attached memorandum, with transcript records, speak to this question, it appears to me that the staff did not " require" independence until the November 3,1981 meeting.
I s
Darre 1 G. Eisenhu, Director i
Division of Licensing
Enclosure:
As Stated i
cc: w/ enclosure t
W. Dircks E. Case
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R. Tedesco /
R.* Vollmer-R. DeYoung i
R. Engelken i
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UNITED STATES f-p, NUCLEAR REGULATORY COMMISSION g
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UAN 12 982 1
MEMORANDUM FOR:
Darrell-G. Eisenhut, Director-Division of Licensing FROM:
Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
SUBJECT:
" INDEPENDENT REVIEW" BY PG&E CONTRACTORS (RECORD SEARCH)
As you requested in your note of January 4,1982, we have searched the subject in the transcripts of the PG&E meetings of October 9 and November 3,1981, and in the transparencies for the Comission briefing on November 9,1981 (closed meeting. Attachment 1 is a sumary of the
. staff's discussions during those meetings on the subject of " independent review" (requirements, scope and definitions). Attachment 2 is a copy of the pages and transparencies cited in the summary.
The subject of " independent review" was discussed frequently during those meetings but to a lesser degree or not with respect to its definition.
We have the appropriate transcript pages available at your request.
E ck..% s.-
s.
Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
. Enclosures :
As stated f
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.AffACHMENT 1 Sununary of Record Search for " Independent Review"'- Requirements, Scope and Definition
- 1.
PG&E Meeting 10/9/81 Staff did not specifically request an indepen' dent review. Based on presen-tation in meeting by R. Cloud of his plan for an " independent review" the staff assumed that the review would be independent (page 120)
~ ';,
"Indeper. dent review" was not defined or characterized by PG&E or by staff; H. Brown requested that for the review to be independent it should not,
be funded by PG&E (pages 120,121) 2.
PG&E Meeting 11/3/81
'C Staff inquires and raises que.stions on " independent review" (pages 208,
-214, 216, 236, 237)
Staff characterizes independent review as " sensitive issues" and to mean
" independent of people who did the original review, as a minimum, and to be done outside the PG&E design organization" (pages 216, 254, 255, 262)
Staff expands scope of independent review of seismic related activities to include design verification of all safety related other service contracts (pages 253, 254 and 3 pages of typed specifics provided to PG&E at end of meeting) 3.
Commission briefing 11/9/81 Staff requires independent and complete reverification and identifies scope of such review (2 transparencies) l l
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ATTACHMENT 2
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Transcript Pages (PG&E Meetings on October 9 and November 3.1981) and Transparencies (Comission Briefing on November 9,1981) on Subject of 4
" Independent Review" t
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COE3!SS!0N EEETING WITH PACIFIC CAS AND ELECTBIC CCMPANY 4
TO DISCUSS SEISP.IC DESIGN REVIE7, DIAELC CANYCN UNIT 1 5
6 Nuclear Regulate:y Cor.cissien 7
Foem P-ile 7920 Noric1h Av'enue 8
Bethesda, Maryland 9
Friday, October 9, 1991 _
10 The meeting convened at 9:05 a.m.
11 NRC STAF? PRESENT:
12 H.
DENTON D.
EISENHUT 13 E. VOLLMIR
- 3. BUCXLEY 14 W.
OLMSTEAD J. KNIGHT 15 E. JORDAN B. FAULKENBERRY 16 D. KIRSETT P. KUD 17 F. SCHAUER R. TEDESCO 18
- 9. BOSNAK 19 PEESENT F30E PACIFIC GAS AND ELECTRIC Co.:
20
- 3. SHACKELFORD N. NORTON 21 D. BRAND R. LETTINGER 22 J.
HOCH H. TRESLER 23 R. CLOUD J. SCHUTLEE D
24 J. BLOOM J. ROCCA 25 E.
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1 tho likolihood of an undetected orror in tho peis:ic 2 analysis or, derign is greatly reduced."
3 What we find today is that despite perhaps the 4 5taff 's best eff=rts, we had some very substantial 5 undetected errors that came up after an operating license 6was issued.
7 And for that reason, on behalf cf the peo;1e that s live areund the plant, I would like te urge the Etaff to 9 tak ela~~very ca ref ul look at the work FG T.I i s d oing, at the 10 quality assuraace program.
And I would like to request,that 11 the Staff recomaeed an independent audit of the seismic 12 rea nalysis.
13 ER. DENTON:
I think we are getting an independent 14 audit.
I assume we are getting an independent audit through 15 the work that Dr. Cloud is doin_g.
That is one reason I 16 vanted the reverification ;rogram plan submitted, so we can 17 look at it in advance to see if we think it is really 18 a de qua te.
And I,would certainly welcome any comments you ismight have on that plan after we have had a chance to see it 20 from the company.
And we vill have our own look at these 21 sa me a re as, of course.
22
'HR. EBOWN Harold, let me follow up on that.
I 23 a n not sura if anybe David is satisfied.
But te the extent 24.t h a t an independent audit ought to be pursued, it really 25 ought to be what we would consider'independ ent, at least to ALDERSON REPORTING COMPANY. INO.
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1 the extent to whirh the governor would be comfortatie.
It 2 would be an audit that is not being done by PGEE or throu;h 3 PGE E's f undin;.
4 And I say this not casting any doubts on Dr.
5 Cloud 's inte grity or his capability.
I stipulate those fr:m J
6 the beginning.
It is just'that the natural inclination of 7 people who have studies and audits done by those whc have 8 been found to have come.itted an error is not to take 9 necessarily wi th the same enthusias: an audit the vay they 10 would if done by an independent party not being f unded by 11 that individual or party that com:itted the errer.
12 And that is about as gently and a s trunca ted a 13 sentence as I could use to try to show as much respect as I I
14 can to Dr. Cloud, because, as I said, I am not-in any way 15 challencin; his qualifications er his integrity, and I 16 stipulate those to begin with.
17 But I think a party that does not have either an 18 interest or a sourre of funding f rom the pa rties interested 19 in the question --
20 ER. DENTON:
I think I understand the point you 21 are making, and we will certainly take. it under advisement.
22
.BR. FLE!SCHA KER:
I want to' make it perfectly 23 cle a r th a t we are not accusing PGCE of dissembling here, and 24 we are not accusing the Staff either.
It is really a 25 question that we have got everybody.here that shares the i (
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UNITED STATIS OF AMERICA NUCLIAR RIGULATORY COMMISSION 2
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DIABLO CANTON SEIS!!C RE7IEW 4
5 Room P-116 8
Phillips Building 7950 Norfolk Avenue 7'
Bethesda, 3a ryland 8
Tuesdar, Novemb'er 3, 1981 9 PRESENT:
10 E. JORDAN R..DENTON 11 D. EISENHUT B. BUCXLEY 12 H. YOLLMER R. DE YOUNG 13 J. CREWS R. FAULKENBERRY 14 J. XNIGHT F. MIRA0LIA 15 On behalf of the NRC 18 R. HUBBARD H. BROWN 17 On behalf of Intervenors i
18 G. MANEATIS
- 3. NORTON 19 D. 3 RAND W. BAY!OND 20
- 2. GANGLOFF R. CLOUD 21
- 7. GHIO R. 3ETTINGER 22
- 3. TRESLER J. BLUME 23 On behalf of PGCE
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a/s/n 1 hoped that the entire nuclear desica process with its 2 margins and its requirements would be enough that any of the 3 errors that one would expect to find in a review of a lot of 4 calculations would not affect safety.
And I bel'ieve tha t 5 that is the situat' ion that we find ourselves in now at the e soment.
We do not find the basic safety of the plant has 7'been compracised, but we have found instances of a misapplication of seismic data.
Thank you.
9 ER. DeYOUNG:
Nar I ask a question?
Why did you_
to hope you wouldn't find large errors that would l'apose upon 11 saf ety ?
Whr did you hope that?
I could see why the utility 12 would hope that, but as an independent reviewer, why did you 13 hope that? _
14
- 32. Cl0UD I*n speaking as a ;cof essional 15 engineer j
16
- 33. CeICUNGa Sometimes if You ho pe for something,
17 Tou direct your activities toward that hope.
It's a strange I
18 statement for an independent reviewer.
19
- 33. VOLLMERs Bob, getting back to some of the 20 errors that you found, I's curious, were these found because
- 21. you re-did the calculations or because the design 22 documentation was so good you can go ba'ck and f[nd very
' 23 specifically where the error occurred?
-24
- 13. Cl0UD:
Our work up to now has been based upon 25 the review of the applicability of thet data.
We checked the 0
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1 were not changed to indicate that this analysis could be 2 usad for Unit 1 if you so chose.
3 During the design process of the supports in Unit 4 2 'it was decided to change the anchor design in Unit 2 from 5 what we had in Unit 1,
and they changad the anchor to allov' 6 cotation but anchored it to prevent any translational 7 aovement.
When that chan;e was mada it became necessary to 8 cerun that Unit 2 thermal analysis which was used for Unit 2 9 and Unit 1, to properly model the anchor.
Th'e analysis was
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to rerun and issued, an'd the previous Unit 2 analysis was 11 cancelled.
12 Fortunately, the pipe designers recognized that 13 since it was specific to Unit 2 and that it modeled a 14 dif f eren t anchor configuration, t':ey should continue to u'se 15 the cancelled previous Unit 2 analysis for Unit 1,
and ther 18 did.
So tne desi;n was proper.
' rom ycu on 17
- 53. DENTON:
Do ve have a report f
18 this ?
All the things you just me n tioned ?
g 19 f.3. CHE2S:
We do have an 1I2.
I think we have
. 20 the initidi report.
l 21 3R. THES1E2:
I hava described"it as to Region 5, 22 res.
23 3R. DENTON:
let se move back.to.an issue that ve
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24 sta rted on and tha t's the degree of independence of Dr.
25 Cloud.
Tell us who in the ocpui stian he caports to.
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ER. MANIATIS:
I was going to add tha t Dr. Cloud 2 doesn't report to anyone in our organization.
He has been 3 retained to do an independent and indepth reverification.
4
- 38. DENION :
Who gives his his directions as to 5 scope?
6'
- 33. ZANEATIS:
As I had earlier indicated, Mr.
7 Brand, our Vice President of Engineering, is directing this t
a whole investigation and re-analysis program.
And he, with 9 his subordinates has retained his to make this independent to investigation.
11 5R'. C100D:
If I could add something to that, I 12 would say the pro;rss that I presented was based on all mr 13 own ideas, and I formulated it myself without any help from 14 the people at PGEI.
15 ER. MANEATIS:
And I would further consent that on 16 th e basis of his findings that he reported in his interis if repoct, I think it is clear that his review is objective.
18 ER. DENION:
Do we get the sas4 reports he gives 19 you ?
20
- 23. HANEATI5:
Iou just' got it.
And I have to 21 say, Nr. Denton, that sone of these things have just'been 22 disclosed to me, so you got it almost the same time I did.
23
- 13. EISENHUT:
When vill we be expecting to see 24 tha t short-ters repo rt, Bob Cloud said it's essentially 25 complete.
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1 ER. NORTON:
Dr. Cloud, could you answer that?
2 3R. CLOUD:
I believe it's -- we vill be turning 3 it in either this week or next, so you should have it 4 shortly thereaf ter.
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5 5R. NORTON:
I might add we do not have it.
It's i
6 not a question of us reviewing it.
We don't have it, 2
7'either.
It just hasn' t been done yet.
.8 3R. DENTON:
Well, since this is a particularly 9 sensitive issue, I was wondering how you propose to handle 10 =caments on this draft, or are you going to send us the same 11 report he sends you and add you cover letter to it?
Cr hov 12 vill you preserve independence?
i 13 XR. N3RIONs Well, Like any other matter, I's a 14 little bit concerned about suddenly there b eing questions 15 ahout the independence of the reviev.
The NRC has. retained 18 a consultaar and the sane question migh t be asked -- vell 17 gee, how do we know that review is independent?
'I mean, 18 there is no reason to believe this review isn't independent.
19
_3R. DENTON:
I*a just asking how independent is it._
20 3R. NORT0F:
Any succestions you have -- if you
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21.vant-the ca port bafore ve see it, fine.
I frankly resent i
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-1 22 the inplication that Dr. Cloud is not an independent f;
m reviewer because he is..
As Mr. Haneatis jcs: reported to L
24 you, ve heard this presenta tion to you yesterday -- in f act, t
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' 25 ve heard i: Sunday for the'first time.
I assure you that's I
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N 1 service con t:2 cts during this period of interest, four of 2 which you described.
The othoc eight would be looked at 3 under the seismic reverification pecq:am.
And in addition, 4 then, you wearing your QA hat will look at all twelve?
5
~3R. RAYROND:
Yes.
6 5R. DENTON:
For evidence of controls?
y 3R. RAYMOND:
Yes.
8
- 52. DENTON:
During that period.
9 ER. RAIMOND:
Yes.
10
- 32. DE YOUNG:
Again coinc b=ck te i n'd a e a a d a a t 11_ ceview, you have two major programs underways one, the 3
12 verifica tion progras with Dr. Cloud, someone from outsido. _
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13 completely independent; the other thing is the QA check feca 14 within the conpany.
Did you consider going outside to get 15 an independent chack of that?
16 ER. NORTON:
No.
The nature of quality assurance 17 progras and audit is sucn that we believe very strongly that 18 ICE and, for that =a tter, NRR can easily ve:if y our audit.
1g It is the ve:y nature of the paper trail, the audit is going I
20 to be doce and, of course, create its own paper trail.
And 21 ve believe the NRC can easily satisf y itself of the extent 22 or depth of the audit and the accuracy simply by 23 spotchecking without a great deal of input on the NRC's 24 p a r t -
25 3R. DE YOGNG:
Dr. Cloud said he had spent about a AL:EPSCN REPCAUNG COMPANY. lNC.
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How many man-hours have you 2 spent on your part of it?
3
- 32. 3AYMCN34 The question was how many man-hours 4 have we expended on the inforsation we have identified to
. 5 date; right?
6
- 13. DE YOUNG:
Yes.
7
- 33. RA!!OND:
Let ne do some mental arithmetic 8 real quick.
Approximately 250 to 300 man-hours.
9
- 13. DENTON:
Do you report to any organization?
10 MR. HA!MOND:
The vice president of nuclear power 11 generation.
12
- 33. DENTON:
Is this independent'then of the 13 organizational units that you are auditing?
14 3R. EAY50ND:
Yes.
15 XH. DENTON:
You say different person than just 16 head of the engineering staff?
17
- 32. RAIZOND:
Yes, he is.. Don Brand is vice l
18 president of the engineering departsent.
Mr. Schuyler is 19 the vice president of nuclear power generation.
Two 20 dif feren t distinct people, f
21
- 33. DENTON:
I would like to touch on just a few 1
l 22 other cleanup issues here.
I do not want to put Dr. 31oos 23 :n the spot.
But I will anyvar, since he is quite capable 24 of ansvering any questions in his field.
25 I vonder, 13 You have an7 c5mnents you would like i
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1 like to reiterate that we feel the N3C is fully capable, as 2 it has, to continue to evaluate th a t.
Historically in the 3 industry, the 53C has certainly vorn a black hat in that 4 area.
5
- 33. DENTON:_ Thank you.
6 In the period since ve met, Dick De Young and I 7 and our staffs have set to reflect on what we heard this 8 morning and what we have ga thered by direct discussion ove.r 9 the' last three weeks, and we have come to some conclusions 10 about the scope and extent of your activities that I think 11 in some respects would substantially broaden the extent of 12 design verification.
13 Let se talk about these areas. 'One area our view r
14 s till h a sn ' t chan7ed.on, and I think that is wha t you are 15 now e= barked on -- you resember last time ve indicated we 16 thought you should do an independent review and verifica tion 17 of all the seismic related activities prior to fuel loading, 18 and the results of this should be forwarded to us, and any 19 aodifications that that prograa requires should either be 20 sade or it should be justified to us before you be permitted i
21 to' load fuel.
l 22 I think our views on that ar'e the same, and I l
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- 23 think the Cloud approach substantively vill be addressing
.24 that issue.
So I think with regard to the activities 25 requiring f uel loading you are embarked on a progras that i
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uhlst 1 satisfies what we think should be done in that area.
2 And what I see you doing, just to restate, I see 3 an independent design reverification being done in all 4 seismic design related areas.
Ihat includes the eight 5 service type contractors.
So I thin'k in that area what we 6 are statin; is not dif f eren t than what we said la st tim e.
7 I think where ve-do differ is ~vhat else needs to 8 be done beyond that.
It seems to us that before ve can make 9 a d'etermination about going above 5 percent power, assuning to that the seismic design verification progras had been 11 completed, that the scope of discovery was not ant larger, 12 and its sodifications required had been made, we think you 13 need a similar independent design verification o f all the 14 saf ety related other service contracts.
15 The other four that you sentioned, you had 16 proposed to do a Q A check on those which, in our viev, vould 17 only go partvar toward addressing the probles.
I think 18 those other four service related contracts should have the 19 same sort of in-depth independent desi7n verification.
20 One seaning of the word " independent" for se is 21 independent of the people who did the original work, and 22_ vhe the r tha t was done by your existing contractor, Dr.
23 Cloud, or some other group, it seems to se in order to be 24 valuable it has got to be done sore or less outside your 25 design o rganica:isn.
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- 33. 53ar0N:
Excuse me, Er. Denton.
I am not sure 2 you intended to say what I thought I heard you say, but I 3 have hea rd other people say it.
Dr. Cloud has not verked 4 for PGEI before on this project.
Soanone said he was a 5 consultant
- bef ore.
That is not so.
I 6
- 32. DE3 ION:
No, I was trying not to say that he 7 wouldn' t be suitable.
I was saying that it didn 't have to k
8 be Dr. Cloud but a similar effort like that done by him or 9 soseone she is independent of the design activities related
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to to those four other service type contracts.
,a 11 Secondly, and I think the bigger effort, will be 3
12 to cond u ct a similar -- and for the area I just mentioned, 13 these four other service related con tracts, I think it f
14 should be to the same depth that is being done on the first 15 eight.
I think there has been sufficient doubt about the 16 formality of the inforsatica with regard to service 17 cont:2 cts that you should da that not only for the eight you 18 have started, but for the other four.
19 Now, I think on the saspling ba sis you need to do 20 an independent design verification of SGCE's own internal 21 design activities which we were no t able to establish this 22 2cening that thera were internal organt:stional situs: ions 23 or procedures that somehow precluded sose of this 24 informalit7 to get into your own internal p rocess.
So I 25 would think you need an effor: comparable to what we have A& LESCN 4tpCAr%G 00 washy. NC.
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- 33. JCEDAN:
I think you could clarif y that by
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- 53. NORIOMs We also have 5255(d) for Unit 2.
5 These would be in addition to that.
6' da. DENICNt We tried to write this down in plain 7 language as opposed to requistory language.
8 (General laughter.)
9
- 23. DENION:
And we vill pass these around for 10 people interested.
11 It might be well if you spend a soment to take a 12 look at it.
. 13 HR. NORTCN. Excuse me.
Earlier I said that Dr.
/
14 Cloud ha'd not been a consultant before.
What I meant was 15 not during any of the timeframe that all this was going on.
16 He was involved in a seismic system interaction program that 17 was done for the AC35, and since somebody pointed out when I 18-said he was not s consultant before, what I was thinking of 19 was during this timeframe ve are talking about, '76,
'77, 20 ' 78, and I believe late '79 when th e seismic system l
21 in t'er actio n propras was poing on.
22 ER. DENTON:
I appreciate the cla rifica tion.
23 I guess just to reiterate, =y view of independence
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- 24 vould mean as a minimus_you are not revieving the work with 25 which you vers associated.
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Licensee ?,ctivittes Prior _ to Fuel Loadtne Conduct an independent [ design review and verification of all safety related activities performed under the PG&E-URS/Blume contract as they relate to th'e Hosgri reanalysis. This review should address
.~ Z J the development, accurancy, transmittal, and use of information h
both within PG&E and within URS/Blume, as well as the transmittal
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of information between PG&E and URS/Blume as related to the s
requirements of NRC Quality Assurance Criteria (10 CFR Part 50, Appendix B). The results of this verification program should be provided for NRC review.
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The errors t' hat have been identified to date, as relate to performance of activities conducted udner this contract, should be addressed as regards to basic cause and impact upon final design. Also, any new errors or deficiencies identified should be appropriately addressed in the review and subsequent report.
In addition, any modifications that are required as.a result of the current and newly identified problems must be completed prior to a
sfuel loadilig. unless specific exceptions are approved by' NRC.
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Licensee Activities Prior.to Exceeding Sy P_ower Ooeration a)
Conduct an independent design review and verification of all safety related structures, systems, and ccmponents that received design input information or data developed by PG&E service-related contractors prior to June 1,1978. This review should address all ' activities involved in the development, accuracy transmittal, and use of safety-related information, both within'the PG&E organization and within each contractor's organization, as well as the transmittal of information between PG&E and each contractor, as related to the requirements of NRC Quality Assurance Criteria.
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Conduct an indecendent design sampling review and verificatio_n of PGaE' internal design activities that have been performed on Diablo Canyon Unit 1 that related to the development of the design of safety related structures, systmes, and ccmponents.
I The extent of this review should be that which is necessary i
to confinn that the PG&E quality assurance controls described in their QA Manual and associated procedures since"1970, and as I
related to the implementation of NRC Quality Assurance Criteria l
have been fully and effectively fr:@lemented.
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Md durIk tt /1/ tr uccfry c)
Conduct an [ independent design sampling review and verification of all PG&E service related contractor work that was developed subsequent to January 1,1978 and that has, been or will be used as input into the design of safety related structures, systems, and'ccmponents. The extent of this. review should be that which is necessary to confirm that the contractor and PG&E quality assurance controls and procedures that were in effect during this time period were fully and effectively implemented. The review'should address all interface activities associated with the work, both internal to the contractor and within PG&E, as l'
they relate to NRC Quality Assurance Criteria J
g Provide the results of this verification program for NRC review. Any
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modification required as a result of this program shall be completed I
prior to exceeding 55 power unless speicife exemptions are approved t{
by NRC.
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r FRANK MIRAGLIA 4-492-7243 3
_11/09/81 NOVEMBER 9,19Ei1
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COMMISSION BRIEFING ON
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49 J1/09/81 PG&E REVERIFICATION PROGRAM PROPOSED BY STAFF (SUBJECT OF 50.514F LETTER) o PRIOR TO FUEL LOAD AND OPERATION UP TO 5% POWER INDEPENDENT AND COMPLETE REVERIFICATION OF AlI _
SAFETY-RELATED ACTIVITIES PERFORMFD BY URS/RIItME
. 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 COMPLETED
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i o PRIOR TO EXCEEDING 5% POWER
-INDEPENDENT AND COMPLETE DESIGN REVIEW AND REVERIFICATION OF ALL OTHER PRE-JUNE 1978 SERVICE-RELATED CONTRACTS INDEPENDENT AND SAMPLING REVIEW AND REVERIFICATION OF
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PG&E INTERNAL DESIGN ACTIVITIES INDEPENDENTANDSAMPLINGREVI$WANDREVERIFICATION
-0F POST-1978 SERVICE CONTRACTS _
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' ALL APPLICABLE MODIFICATIONS TO FACILITY DESIGN
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RESULTING FROM REAN'ALYSIS AND REVERIFICATION EFFORTS.
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BE COMPLETED
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