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NOV 121982 MEMORANDUM FOR: Thomas Rehm Assistant for Operations, EDO FROM:
Edwin G. Triner, Director Division of Budget and Analysis Office of Resource Management
SUBJECT:
-BACKGROUND INFORMATION ON THE STATE OF CALIFORNIA FOR CHAIRMAN PALLADINO Attached is the background information you requested for Chairman Palladino's trip to California.
The information was primarily obtained from the NRN and the NMSS Licensing
~
Project Managers, the Office of the' Executive Legal Director, the Office of the General Counsel, the Atomic Safety Licensing Board, the Atomic
. Safety Appeal Board, and the ' Office of Inspection and Enforcement, Region V l-If you have any questions, pleast contact me.
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Edwin G. Triner, Director Division of Budget and Analysis p p pp(gg/4
-Office of Resource Man.gement S ?'
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Attachment:
.As stated
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B. Liaw g/c' /84 S. Miner, ORB-4:NRR (Rancho Seco)(MS-416)
G. Zech l
D.' Droggitis j
W. Paulson, ORB-5:NRR(SONGS 1) (MS-314)
S. Showman H. Rood, LB-3:NRR (SONGS 2-3) (MS-128)
B. Buckley, LB-3:NRR (Diablo Canyon)(MS-128) bec.
chierling, LB-3:NRR (DC:DVP) (MS-128) 0.5hackleton, Investigations, Region"V V. Rooney, ORB-2:NRR(Humboldt Bay) (MS-416) f-J. Hanchett, PA: Region V B. Kratzke, FCAF:NMSS (MS-396-SS)
N. Ketzlach, FCUF:NMSS (MS-396-SS) 110* NL$U oo
/ :MA P. Erickson, (VBWR; EVESR) SSPB:NR{l(MS-340) g, n. %., pyfg R. Fish, IE: Region V 3\\
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, UNITED STATES NUCLEAR REGULATORY COMMISSION h
WASHINGTON, D. C. 20555
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NOV 12 m 4
MEMORANDUM FOR:
Thomas Rehm Assistant for Operations, EDO FROM:
Edwin G. Triner, Director Division of Budget and Analysis Office of Resource Management
SUBJECT:
BACKGROUND INFORMATION ON THE STATE OF CALIFORNIA FOR CHAIRMAN PALLADINO Attached is the background information you requested for Chairman Palladino's trip to California.
The information was primarily obtained from the NRR and the NMSS Licensing Project Managers, the Office of the Executive Legal Director, the Office of the General Counsel, the Atomic Sa'fety Licensing Board, the Atomic Safety Appeal Board, and the Office of Inspection and Enforcement, Region V.
If you have any questions, please contact me.
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E Triner, Director Division of Budget and Analysis Office of Resource Management
Attachment:
As stated l
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L B. Liaw G. Zech D. Droggitis S. Showman
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.DIASLO CANYON UNITS NOS. 1 AND 2 W :ation:
12 mi WSW of San Luis Obispo, CA Utility:
Pacific Gas & Electric (PG&E)
Licensed:
Unit No. 1 Low Power (9/22/81)
(Suspended 11/19/81)
Unit No. 2 Under Construction Power Level:
1084 MWe; 3338 MWt Type:
Pressurized Water Reactor _ (PWR)
NSSS:
Westinghouse AE/ Constructor:
Pacific Gas & Electric Licensing Project Manager:
Bart Buckley (49-28379)
NRR Project Manager - Design 4
i Verification Program:
Hans Schierling (49-27238)
Resident Inspector:
John Carlson (805-595-2353)
. Diablo Canyon Unit No.1 - Suspension of Low Power License; Design Verification
' Program A license.for Fuel Loading and Low Power Testing was issued to Pacific Gas and Electric (PG&E) on September 22, 1981; however, fuel has not been placed in the reactor vessel as a result of discovery of seismic design deficiencies in certain systems.
4 An error-in seismic design of equipment installation and piping in containment was detected by PG&E and reported to NRC late September 1981.
~
Serious weaknesses identified in the fall 1981 in PG&E Design and Quality Assurance Programs raised further doubt concerning the adequacy of the plant to c
withstand earthquake motion.
Details follow:
l On November 19, 1981, NRC issued an order suspending the low power license and iss'ued requirements for a Design Verification Program to be completed prior to restoration of the license for fuel loading and low power testing.
(Referred to as Phase 1 of the Diabl'o Canyon Design Verification Program.)
i L
I On November 19, 1981,- the NRC informed PG&E of additional Design Verification Program requirements that must be met prior to the issuance of a full power p
-license for. Diablo Canyon, Unit No.1.
(The activities related to that part of l
.the program dealing with the full power license (FPL) are referred to as Phase II.)
Between November 1981 and March 1982, PG&E reassessed effort, defined scope and
-hired contractors.
Numerous PG&E/NRC discussions and meetings were held.
On March 19, 1982, NRC approved Teledyne Engineering Service (Waltham, MA) as indeoendent contractor to conduct an Independent Design Verification Program (IDVP).
(Other participants in the Independent Verification Program are 6
11/10/82 L
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Diablo Canyon Unit No.1~ - Suscension of Low-Power Licensing Design Verification Program (Continued)
R. L. Cloud, Associates, and R. F. Reedy, Inc., who had performed evaluations of associated Diablo Canyon design and quality assurance matters prior to the staff approval ~ of Teledyne.)
On March 22, 1982, PG&E contracted with Bechtel Power Corporation to act as the
- PG&E project completion manager for Diablo Canyon to fulfill all requirements for reinstating the low power license for Unit 1 and for meeting all full power license requirements for both units.
On June 19, 1982, PG&E submitted a Quality Assurance Program for the Diablo Canyon project, which describes the manner in which PG&E/Bechtel integrated project organization will fulfill the QA functions.
The NRC reviewed and approved the program on August 2,1982 contingent upon some additional infor-mation to be included.
Teledyne Engineering Services, Inc. submitted the first 12 of approximately 30 Interim Technical Reports on completed aspects and on programmatic issues of the IDVP.
The NRC has completed its review of the first five reports, the review of the remainder is underway.
-In a meeting on August 6,1952, PG&E advised the NRC that they had expanded their own internal technical program to include a complete review and neces-sary seismic analysis of all safety related buildings.
This resulted from the numerous design deficiencies that had been identified during the program thus f
far.
The staff provided the Commission with a status report on the IDVP by memo dated September 24, 1982.
~ SECY-82-414 dated October 13, 1982, presented to the Commissioil the staff proposal regarding an expanded Phase I scope for activities to be completed prior to reinstatement of the suspended license and regarding a redefined scope for Phase II of the program.
The staff briefed the Commission on these matters in a meeting October 20, 1982.
The. Commission requested comment on the staff proposal from the licensee and other parties to the proceeding.
A Commission meeting is scheduled with these parties November 10, 1982.
Full Power License On August 13, 1982, an initial decision was made by the Atomic Safety Licensing
- Board authorizing the issuance of a full power license for Unit 1 subject to the
- completion of certain conditions ~related to emergency planning.
The Federal Emergency Management Agency must approve the California State Emergency Plan before full power authorization is approved, and as noted before, the design j
deficiency issue must be resolved.
Diablo Canyon Unit No. 2 is under construction and is approximately 98 percent complete.
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Diablo Canyon Units Nos.1 and 2 - Emergency Preoaredness An on-site emergency preparedness appraisal was conducted,by the NRC at Diablo Canyon in December 1981.
Five significant deficiencies were identified; however, two of these related to facilities and equipment that were being or to 4
be installed.
Licensee correspondence and Regional inspection have assured satisfactory corrective actions.
The ap
' be considered for improving the program.praisal identified ten items that should The NRC' observed the August 1981 emergency planning exercise, which-included participation by off-site agencies, showed a possible problem with the timely full activation of the Emergency Operation Facility (EOF).
The December appraisal showed that action had been taken to provide activation of the EOF on a timely basis.
The prompt public notification system (essentially sirens installed to give warning to the public within the ten-mile circle of the plant) has been installed and tested.
Testing was performed in August 1982 to comply with the San Luis Obispo County restriction. for testing only during these months (August-Septemb'er).
An on-site emergency-planning exercise was conducted by the NRC at Diablo Canyon
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on October 20, 1982.
No significant deficiencies were identified during the exercise.
.On October 16, 1982, an unusual event was declared by the licensee.due to forest and brush fire on land surrounding the plant.
The reactor experienced a loss of
- off-site power. for several hours.. An emergency diesel generator in each of Unit 1 and 2 were brought on line to carry safety-related loads.
There were no injuries, fatalities or structures damaged as a result of the fire.
The fire
- came to the plant boundary' and smoke detectors inside the plant alarmed due to smoke concentrations.
The control room ventilation system automatically switched to closed circuit operation mode during the event. About 1800 acres of grassland and forest were burned.
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION j' '
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NOV 171982 Docket No.:
50-275 APPLICANT: Pacific Gas' & Electric Company (FG&E)
FACILITY:
Diabl'o Canyon, Unit 1 SUBJECJ:
MEETING
SUMMARY
On October 25, 1982 Harold Polk (SEB), Bart Buckley (OL) and our BNL consultants Drs. Bezler, Philippacopulos, anc Miller visited Diablo Canyon site. The purpose of the visit was to become'familar with the details of structures, piping and cable trays in the plant that are to be evaluated by BNL in the near future.
Moreover, a walkdown of the previously analysed annulus structure and piping systems was conducted.to confirm or modify, as appropriate, the previous model assumptions. The areas toured included the Unit 1 containment, the Auxiliary Building, the turbine Building and the Fuel Handling Building and the intake structure.
Dr. P. T. Kuo (SEB) and the above mentioned NRC and BNL personnel visited
.the PG&E/Bechtel Project Team office on October 26 to determine dramngs and data that a're necessary to carry out the horizontal seismic evaluation of the annulus region, the seismic analysis of the buried diesel oil tank and to select candidate problems and data for additional piping confirmatory analysis. A list of drawings and other data that we will require is being developed for formal transmittal to PG&E.
A list of attendees at this meeting is attached.
Mr. Howard Friend, Project Completion Manager, inquired as to the purpose of the on-going BNLs independent analysis and how would it would be used, if at all, in the licensing decision making process.
He expressed the view that an' independent review by the NRC staff and/or BNL would be a more appropriate approach rather than the BNL independent analysis efforts. He inquired as to when the BNL results would be available and raised the question if the current.PG&E/Bechtel estimated schedule for fuel' loading would be impacted by the schedule associated with BNL's on-going analysis efforts. Moreover, Mr. Friend asked what quality control measures were being implemented at BNL and what quality assurance requirements were delineated in the NRC contract with BNL. The NRC staff informed Mr. Friend that the purpose of this trip was to obtain additional technical information to permit the staff and our
.-consultant. to confirm previous analyses and to pursue additional analyses in the above cited areas. We told Mr. Friend that we would relay his concerns
'to NRC upper management.
With respect to scheduled completion date for the new analyses to be performed by BNL, we informed M'. Friend that we would r
be in'a much better position to address that matter once our information gathering meeting was complete and the information that we would formally request was received by the staff and its consultants.
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/ R. L. Cloud & Associates was visited on Wednesday and Thursday (October 27-28, 1982) to audit ITR-6 "Diablo Canyon Unit 1 Independent Design Verification Program, Auxiliary Building" and ITR-7 "Diablo Canyon Unit 1 Independent Design Verification Program Raceway supports" a list of attendees at this meeting is attached.
During this visit pertinent calculations, drawings and computer output in support of the documents were reviewed.
During these meetings we discussed questions related to their reported work with: S. Harris and E. Denison of RCLA.. The discussions were focused on the following items:
%.x 1.
The methods and assumptions made in modeling the Auxiliary Building.
2.
How were calculations for soil springs made.
3.
Verification of soil / rock properties.
4.
Methods used to evaluate Electrical Raceway Supports.
With respect-to item 1, we raised concerns regarding the methodology used in developing moment of inertia and the in-plane rigidity of the Auxiliary Building concrete slabs (floors). With regard to item 2, we questioned the methodology used in developing soil springs to account for the embeddment effects.
On item 3 we discussed the verification of the soil / rock properties used by RLCA in
- calcu-lating the-Auxiliary Building' soil springs. RLCA. indicated that the soil / rock properties were not independently verified.
We also expressed concern regarding the use of non-linear analysis to qualify the electrical raceway supports.
- v. :., (.. u B. C. Buckley, Project Manager Licensing Branch No. 3 Division of Licensing
.cc: See next page G
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Diablo Canyon y
Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas & Electric Company l
P. O. Box 7442 San Francisco, California 94120 cc: Philip A. Crane, Jr., Esq.
Resident Inspector /Diablo Canyon NPS Pacific Gas & Electric Company c/o 0. S.. Nuclear Regulatory Commission P. O. Box 7442 P. O. Box 369 San Francisco, California 94120 Avila Beach, California 93424 Janice E. Kerr,' Esq.
Ms. Raye Fleming Cdlifornia Public Utilities Commission 1920 Mattie Road
- '350 McAllister Street Shell Beach, California 93440 San Francisco, California 94102 Joel Reynolds, Esq.
Mr. Frederick Eissler, President John R. Phillips, Esq.
Scenic Shoreline Preservation Center for Law in the Public Interest Conference, Inc.
10951 West Pico Boulevard 4623 More Mesa Drive Third Ficor Santa Barbara, California 93105 Los Angeles, California 90064 Ms. Elizabeth Apfelberg Paul C.~ Valentine, Esq.
1415 Coradero 321 Lytton Avenue San Luis Obispo, CA 93401 Palo Alto, California 94302 Mr. Gordon A. Silver Mr. ' Byron S. Georgiou Ms. Sandra A. Silver
/
Legal Affairs Secretary 1760 Alisal Street Governor's Office San.Luis Obispo, CA 93401 State Capitol Sacramento, California 95814 Harry M. Willis, Esq.
Seymour & Willis.
Herbert H. Brown, Esq.
601 California Street, Suite 2100 Hill, Christopher & Phillips, P.C.
San Fran-isco, CA 94108 1900 M Street, N.W.
1 Washington, D. C.
20036 Mr. Richard Hubbard.
MHB Technical Associates Mr. Dick Blankenburg Suite K Editor & Co-Publisher 1725 Hamilton Avenue ~
South County Publishing Company San Jose, CA 96125 P. O. Box 460 Arroyo Grande, California 93420 Mr. John Marrs, Managing Editor San Luis Obispo County Telegram Tribune Mr. James 0. Schuyler 1311 Johnson Avenue Vice President - Nuclear Generation P. 0. Box 112 Department San Luis Obispo, CA 93406 Pacific Gas & Electric Company P. O. Box 7442 San Francisco, California 94120 i
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Mr. Malcolm H. Furbush '!
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Bruce Norton, Esq.
Suite 202 3216 North 3rd Street Phoenix, Arizona 85012 Mr. W. C. Gangloff Westinghouse Electric Corporation P. O. Box 355 Pittsburg, Pennsylvania 15230
. David F. Fleischaker, Esq.
P.0.jBox1178
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Oklahoma City, Oklahoma 73101 Arthur C. Gehr, Esq.
Snell & Wilmer 31C0 Valley Center Phoenix, Arizona 85073 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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Regional Administrator - Region V U.S. Nuclear Regulatory Cecmission 1450 Maria Lane Suite'210 Walnut Creek, California 94596 9
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gif 1 ri 9 32 MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
IDVP P0TENTIAL CONFLICT OF INTEREST In early October Region V identified a potential conflict of interest (COI) for two R. F. Reedy Inc. (RFR) associates (Enclosure 1).
W. Cooper of Teledyne addressed the issue in a letter of October 14, 1982 (Enclosure 2). On October 27, 1982 Mr. Reedy and Region V advised us of a similar COI for a third RFR associate.
The potential COI arises from (1) the previous employment of the three employees with Bechtel_-San Francisco and (2) the previous involvement of one individual with the Bechtel 0A Topical Report which is the. basis for the QA program ~of the integrated PG&E/Bechtel Diablo Canyon Project Organization.
W have discussed with Region V (P'. Morrill) the.information obtained during personal ~ interviews with the two individuals referred to in.
The information will be included in a Region V inspection report. We requested additional information from RFR for all three individuals which was provided October 28, 1982, including their profes-cional resumes and the IDVP " Statement Regarding Potential or Apparent Conflict of Interest" (the information is considered proprietary).
The information indicates the following for all three individuals:
1.
They are well qualified to perform the QA audit functicns within the IDVP.
2.
They left Bechtel and began their employment with RFR prior to the initiation of the design verification effort in November 1981.
3.
They left the Bechtel organization for better opportunities.
4.
They were not aware, at the time of leaving Bechtel, of any forth-
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coming PG&E/Bechtel integrated Diablo Canyon project organization.
5.
Their first assignment at RFR was not related to Diablo Canyon or
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to PG&E.
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Harold R. Denton 6.
They had no previous involvement with PG8E or Diablo Canyon (not at Bechtel or during any other employment).
7.
They were not previously employed by PG&E.
8.
No members of their families are associated with PG&E or with Bechtel in any form of employment.
9.
Two individuals have no financial interests in either PG&E or Bechte1.
The third individual owns jointly with his wife fewer than 100 shares of PG&E comon stock (approximate total value of 2,600 dollars).
10.
One individual participated.from 1972 to 1974 in the development of the Bechtel QA Topical Report, Rev. O, which since has been revised and forms the basis for the Diablo Canyon Project QA program.
The other two individuals had no such involvement.
11.
None of the individuals will be reviewing any work on the Diablo Canyon Project of which he was the originator.
On the basis of our review of the information as described above we conclude the following:
1.
The three individuals meet the IOVP procedure and guidelines for independence which was approved by NRR letter of September 8,1982 (Enclosure 3).
2.
The individuals meet the intent of the NRC criteria as set forth in the letter from Chairman Palladino to Congressmen Dingell and Ottinger (Enclosure 4).
The ownership of 100 shares of PG&E common stock by one of the individuals does not constitute, in our opinion, a conflict of interest and does not influence his integrity.
Similarly, the involvement of one individual in the development of the Bechtel QA topical report between 1972 and 1974, in our opinion, does not constitute a conflict of interest because of the long time lapse and because of the peripheral relationship between the past and current activities.
3.
We also considered how the previous Bechtel employment of the three
. individuals would be evaluated in similar circumstances for former federal employees under the regulations of 10 CFR 0735-26. A two year time lapse is required before 'a former federal employee can represent a new employer before the NRC in matters dealing with his previous employment.
We do not find that the three former Bechtel employees were engaged during their last two years of Bechtel employment in any matters associated or related to their current QA audit work with RFR.
- l 1(
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- Harold.R. Denton We conclude that there exists no dir'ect or potential conflict of interest
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for these individuals with respect to their previous employment by Bechtel.
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. We recommend that Teledyne Engineering Services as the IDVP Project Manager be informed of our conclusion through the attached letter.
M'N
" Elk Darrell G. Eisenhut, Director Division of Licensing
Enclosure:
As stated cc:
R. Engelken R. Vollmer 9
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