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[9 UNITED STATES 4
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June 7, 1982 h
se MEMORANDUM FOR:
Darrell G. Eisenhut, Director Division of Licensing FROM:
Richard H. Vollmer, Director-Division of Engineering
SUBJECT:
DIABLO CANYON DESIGN VERIFICATION PROGRAM -
g REGION V INSPECTION ACTIVITIES In response to your meno of May 17 regarding Diablo Canyon Design Verffication Program and Region V's inspection activities, we agree that the items that have been identified are needed and appropriate.
f Richard H. Vollmer, Director Division of Engineering cc:
R. Tedesco F. Mirogita H. Scl.icrling J. Knight l
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Docket No.:
50-275 h
n MEMORANDUM FOR: Frank J. Miraglia, Chief, Licensing Branch No. 3, DL FROM:
Hans Schierling, Project Manager Design Verification Program, Licensing Branch No. 3, DL
SUBJECT:
DIABLO CANYON INDEPENDENT DESIGN VERIFICATION PRO m INSpre m u 0F TELEDYNE ENGINEERING SERVICES Y 25 4
6 26, 1982)
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NRR staff participated in an audit conducted by R?gion V personnel on May 25 and 26, 1982 of the Diablo Canyon Independent Design Verification Program (IDVP) activities of Teledyne Engineering Services (TES) in Walthman, Massachusetts. Representatives from Pacific Gas.and Electric Company (PG&E) were present as observers. Attachment 1 is a list of NRC participants, the PG&E observers and the TES personnel contacted, including their consultants.
The following is a summary of scme observations and items of discussion.
The technical information available at the TES offices in Waltham for the Error and Open Item (E0I) issues is rather limited.
(E0fs are reported in
. TES semi-monthly reports and are tracked by PG&E in semi-monthly reports).
Each isshe, identified as a " File" by number, has a file package which includes status identification at various stages during the IDVP process through the use of standard formats. The information provided in these forms in many cases is not sufficient to allow an evaluation of the issue or even to under-stand the issue. Upon completion of the review effort, TES issues an "IDVP Completion Report", which also is a standard form. This does not necessarily indicate that further action on the E0I may be required or not. (Similarly, PG&E in its tracking of E0Is identifies some issues as " Closed" which also does not necessarily mean that further action may be required or not). Based on the files reviewed, the staff recommended that additional information ' nd a a
better definition of the E0I :tatus be provided in the semi-monthly report.
The item discussed below demonstrates the deficiencies.
The staff audited the TES docueentation for E01 File 932 and discussed the IDVP review with R. Foti and R. Wray of TES. The issue of File 932 is the restraint for a vertical pipe of the containment spray system in a floor penetration in the auxiliary building.
It was identified by R. L. Cloud Associates (RLCA) during Sample Piping Analysis 100. The PG&E drawing and analysis showed a rigid support in both veritcal and horizontal directions while RLCA field information showed Y
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i a support for dead weight only, i.e. no horizontal pipe restraint in the penetra-tion.and no vertical restraint against pipe ~ uplift. File 932 included the above. mentioned standard foms for status identification, beginning with the
" Error. and Open Item Sheet" issued by RLCA on January 4,1982 to PG&E and to the NRC in RLCA semi-monthly report 5.
The last form was Revision 6, "IDVP Completion-Report" which was included in TES semi-monthly report 13. The information in these foms was. insufficient to gain a clear understanding of the issue, of the particular analysis that had been preformed by RLCA and
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TES and for a technical evaluation by the staff. However, additional information
. contained in File 932 at TES consisted of PG&E and TES calculation and sunnary sheets. 'TES stated that more detailed information is conttined in the RLCA.
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- File 932 in Berkeley, California. The IDVP analy' sis by RLCA of the as-built i restraint showed an overstress in piping; an RLCA analysis with a rigid support assumption resulted in stresses within allo'wable limits. PG&E was advised of the results and subsequently redesigned the support and made the -
appropriate modification.
R. Foti, the TES reviewer for pipe supports, had evaluated the RLCA analysis in Berkeley and Waltham,and concurred with the i
RLCA analysis.
In the case of File 932,TES issued an IDVP Completion Report form (File 932 Rev. 6) stating that File 932 Rev. 5 is a Program Resolution Report which recategorized this item as a Closed Item.
(The PG&E status of i,
IDVP items indicated in semi-monthly report 13 that File 932 was " Closed").
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The staff noted that E0I File 1062 makes reference to File 932 and. appears to be a follow-up of that File. File 1062 was initiated on March 15, 1982 and no further action apparently had been taken so far. -
The staff discussed the status and relationship of both files. The staff stated, and TES agreed, that as part of the IDVP TES would verify any field modifications that had'been made as a result of the IDVP. However, it was not clear if such verification already had been made by TES as one could assume from the. issuance of the completion report and from the " Closed" statement in the PG&E tracking
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system. Furthermore, it was not clear how File 1062 is related to File 932 or ff it is a unique new open item.
4 The IDVP technical review effort is conducted by RLCA in Berkeley, California.
W.--Cooper stated that the RLCA review is independent and can include additional verification without prior approval by TES; additional sampling, however, r
must be approved by TES. Detailed files of material reviewed, independent analysis performed and their results are maintained by RLCA in the form of work packages. TES personnel from Waltham have reviewed and audited (check of assump-tions, calcuations and drawings) the work packages in the RLCA offices. The transmittal of information and documentation between RLCA in California. and TES
'in Massachusetts appears to be more of a problem than initially had been
' expected.
At present, about ten equivalent fulltime professional TES personnel are assigned i.
to the IDVP, primarily in a program management function.
Individuals identified as team leaders in a particular area of expertise are frequently the only team members. More staff is expected to be assigned shortly for additional verifica-tion and sampling and for Phase II of the program.
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F. J. Miraglia 3-4 TES made available to the NRC staff a1 draft report by RLCA on their seismic analysis' of the auxiliary butiding for their familiarization of ongoing work.
W. Cooper (TES).did not object to also making the same informaiton available l'
at the same time to the PG&E observers at their request, although the report-was on " work in ' progress" rather than final. Cooper stated that TES is in a unique position in the IDVP effort in that PG&E as the client cannot receive any pre-conclusionary information on the IDVP while the NRC has access to all information at any time.
In Cooper's opinion PG&E and the NRC, in effect, are both clients of TES in this project.
J. Knight (NRC), after staff caucus, advised TES that the NRC should not be considered as a client. The NRC will investigate and audit at any time any type of-work, be it preliminary or a draft, work in progress or a final product. However, only completed work packages should be made available to PG&E in order not to jeopardize the
- independent status of TES. The PG8E observers acknowledged this position in prin-ciple but noted that any staff findings or conclusions which are based on such preliminary 'information should be appropriately identified as such by the staff in trip reports, inspection reports o'r other documentatton.
W. Cooper stated that in the process of reviewing material and resolving E0Is frequently additional clarification and infomation is needed from PG8E. The staff stated that.such requests'and the pertinent PG&E reponse would be within the intent of the IDVP. - The staff emphasized that no discussion or exchang'e of-3 l
. results or completed work should take place between TES or RLCA and PG&E unless the same information is also provided to the NRC. The staff also stated that
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. any in~ formation exchanges should be well documented, in an auditable form, including telephone calls.
This report presents observations made by the author during the audit, it does not address all activities of th NRC staff. For example, P. Morrill of Region V reviewed in detail the TES procedures for the IDVP; J. Eckhardt of Region V interviewed a number of TES employees assigned to the IDVP regarding
- their independence in the assignment; J. Knight, P. Kuo and H. Polk of NRR looked over~ the RLCA draft report mentioned earlier and discussed with J. Holley and M. Biggs, civil-structural consultants to TES, the appropriate-l
. ness of 'certain assumptions for modeling sructures. The detafis of this audit will be documente'd in a Region V Inspection Report.
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Hans Schierling, Pr ject Manager !
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Design Verification Program Licensing Branch No. 3 Division of Licensing
- cc: See next page n
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01.ABLO CANION f'
Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas & Electric Company P.O. Box 7442 San Francisco, California 94120 cc: Philip A. Crane. Jr., Esq.
Pacific Gas & Electric Company P.O. Box 7442 San Francisco, California 94120 Janice E. Kerr, Esq.-
California Public Utilities Commission 350 M-Allister Street l
San Francisco, California 94102 Mr. Frederick Eissler, President Scenic Shoreline Preservation Conference, Inc.
4623'More Mesa Drive Santa Barbara, California 93105
- Ms. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, California 93401 Mr. Goroon A. Silver Ms'. Sandra A. Silver 1760 Alisal Street San Luis Obispo, California 93401 4
Harry M. Willis, Esq.
Seymour & Willis 631 California Street, Suite 2100 San Francisco, California 94108 Mr. Richard Hubbard MHS Technical Associates Suite K 1723 Hamilton Avenue San Jose, California 95125 Mr. John Marrs, Managing Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P. O. Box 112 San Luis Obispo, California 93406 A
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.s fir. Malcolm H. Furbush.,
cc: :Res.ident Inspector /Diablo Canyon NPS c/o U. S. Nuclear Regulatory Conmission 9 '~
P. O. Box 369 Avila Beach, California 93424 1!s.' Raye Fleming.
1920 Mattie Road
- Shell Beach, Cali.'ornia 93440 Joel' Aeynolos, Esq.
. John R. Phillips, Esq.
Center for Law in the Public Interest
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10951 West Pico Boulevard
- Thiro Floor Los Angeles, California 90064 r
Paul C. Valentine, Esq.-
321 Lytton Avenue Palo Alto, California 94302 Mr. byron S. Georgiov Legal Affairs Secretary Governor's 0f fice State Capitol Sacramento, California 95814 Herbert H. Brown, Esq.
Hill,) Christopher & Phillips, P.C.
1900 h Street, N.W.
Washington, D.C.
20036 f.ir. Dick Blankenburg,' Editor & Co-Publisher South County Puelishing Company P. O. Box 460 Arroyo Grande, Cali fornia. 9342U.
Mr. James 0. Schuyler Vice President - Nuclear Generation Department Pacific Gas & Electric Company
-P.O. Box 7442 San F.rancisco, Cali fornia 94120 i
Bruce horton, Esq.
Suite 202 3216 North 3rd Street i
Pncenix, Arizona 85012 L
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. Mr.' Malcolm H. Furbush.
-MrlW.'C.Gangloff Westinghouse-Electri.c Corporation P.'O. Box 355 Pittsburgh, Pennsylvania 15230 David F. Fleischaker, Esq.
P.,O. Box-1178 Oklahoma City, Oklahoma 73101
' Arthur C. Gehr, Esq.
Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073
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Mr. Owen H. Davis, Director Federal Agency Relations Pacific Gas and Electric Company 1050 17th Street, N.W.
Suite 1180 Washington, D.c.
20036
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ATTACHMENT 1-i e
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LIST OF PARTICIPANTS TES AUDIT MAY 25 AND 26, 1982 4
NRC TES' P. Morrill W. Cooper J. Eckhardt R. Wray J. Knight G. May
~ H. Schierling C. Sprangers P. Kuo J. Malonson
- H.: Polk l
J. Cantalupo L. Noriega PG&E (Observers)
R. Foti R. Ciatto B.-Lew
-R. Fray TES Consultants M. Holley J. Biggs 4
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