Text

Board Notification 82-24:forwards W Cooper Re Design Verification Program Manager for Facility.W/O Encl. Related Info Encl
	ML20212L187
Person / Time
Site:	Diablo Canyon
Issue date:	03/15/1982
From:	Eisenhut D; Office of Nuclear Reactor Regulation
To:	Bradford, Gilinsky, Palladino; NRC COMMISSION (OCM)
Shared Package
ML20209B373	List: ML20209B366; ML20209B381; ML20212L166; ML20212L187; ML20212L196; ML20212L211; ML20212L224; ML20212L251; ML20212L286; ML20212M096; ML20212M107; ML20212M115; ML20212M136;
References
	FOIA-86-151, TASK-AS, TASK-BN-82-24 BN--82-24, NUDOCS 8701290357
	Download: ML20212L187 (73)
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{{#Wiki_filter:--__________ UNITED STATES F NUCLEAR REGULATORY COMMISSION { WASHINGTON, D. C. 205SS CiM Docket No.: 50-275 MEMORANDUM FOR: Chairman Palladino Comissioner Gilinsky Comissioner Bradford i Comissioner Ahearne Comissioner Roberts FROM: Darrell~ G. Eisenhut, Director l Division of Licensing l Office of Nuclear Reactor Regulation

SUBJECT:

INFORMATION ITEM - SUBMITTAL BY TELEDYNE ENGINEERING SERVICES (3/8/82) REGARDING THE SEISMIC VERIFICATION PROGRAM - PHASE 1 FOR DIABLO CANYON UNIT 1 (BOARD NOTIFICATION 82-24) In accordance with present NRC procedures regarding Board Notifications, 4 the following enclosed submittal is provided to the Comrission for information: Letter from W. Cooper, Teledyne Engineering Services, to G. A. i Maneatis, PG&E, and H. R. Denton, NRC, dated March 8, 1982, regarding the selection of DCNPP Design Verification Program Manager, with enclosure. This material is relevant to the safety issue on seismic design adequacy of the Diablo Canyon Unit 1, which is currently before the.Comission for consideration. i i ( ) 8701290357 870122 PDR FOIA i 5 HOLMES 86-151 PDR Ei entu, rector Division of Licensing

l Office of Nuclear Reactor Regulation I

Enclosure:

i As stated i cc: ASLB ASLAB SECY i OGC l OPE EDO Service List

Contact:

H. Schi_enling i X49-28123 I

DISTRIBUTION OF BOARD NOTIFICATION SUBMITTAL BY TELEDYNE ENGINEERING SERVICES (3/8/82) Diablo Canyon ACRS Members w/o enc 1'. Atomic Safety and Licensing Mr. Myer Bender . Appeal Board Dr. Max W. Carbon Atomic Safety and Licensing Mr. Jesse C. Ebersole Board Panel Mr. Harold Etherington Docketing and Service Section Dr. William Kerr Mrs. Elizabeth Apfelberg Dr. Harold W. Lewis Andrew Baldwin, Esq. Dr. J. Carson Mark Richard E. Blankenburg Mr. William M. Mathis Mr. Glenn 0. Bright Dr. Dade W. Moeller Herbert H. Brown, Esq. Dr. David Okrent Dr. John H. Buck Dr. Milton S. Plesset Philip A. Crane, Jr., Esq. Mr. Jeremiah J. Ray Mr. Frederick Eissler Dr. Paul G. Shewmon David S. Fleischaker, Esq. Dr. Chester P. Siess Mrs. Raye Fleming Mr. Davis A. Ward Arthur C. Gehr. Esq. Bryon S. Georgiou Mark Gottlieb Mr. Richard B. Hubbard Dr. W. Reed Johnson Janice E. Kerr, Esq. Dr. Jerry Kline Mr. John Marrs Thomas S. Moore Bruce Norton, Esq. Joel R. Reynolds, Esq. Mr. James 0. Schuyler Mr. Gordon Silser Mrs. Sandra A. Silver Paul C. Valentine, Esq. Harry M. Willis John F. Wolf, Esq. .\\ i i I 4 l l

BOARD NOTIFICATION DISTRIBUTION w/o encl: Docket File 50 275 w/enci LPDR ACRS (16) POR NSIC TERA LB#3 Files DEisenhut RPurple SVarga DVassallo RClark JStolz R.Tedesco BJYoungblood ASchwencer FMiraglia JMiller EAdensam DCrutchfie.1d i WRussell Tippolito RVollmer HThompson RMattson SHanauer BSnyder RHartfield, MPA MJollenstein (4) (w/ enc 1), HDenton ECase PPAS MWilliams HSchierling iFM i JLee i bec: WJDircks VStello GCunningham IE(3) 4= l 4 l e

1 1 UNITED STATES OF AMERIC A NUCLEAR REGULATORY COMi!S!!ON 3 i MEETING WITH PACIFIC GA.S AND ELECTRIC CCM?ANY i

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== TO D;SCCSC SEISMIC DESIGN REV!EW, CIAELC CANYCN U5!! 1 5 \\ Nuclear R egulat::y Com.?issien 7 Room P-ile 7920 Norfolk Avenue Bethesda, Zaryland 8 9 Friday, Octete: 9, 1991 10 The seeting convened at 9:05 a.m. 11 NRC ST AFF PRESENT4 12 R. DENTON D. EISENHUT 13 R. VOLLMER B. BUCKLEY 14 W. OLESTEAD J. KNIGHT 15 E. JORDAN B. FAULKENBERRY 16 D. KIRSETT P. K00 17 F. SCHAUER R. TEDESCO 18 S. BOSNAK 19 PRESENT FR0! PACIFIC G AS AND ELECTRIC CC.: 20

3. SHACKILFORD N. NORTON 21 D. BRAND R. BETTINGER 22 J. HOCH H. TRESLER 23 R. CLOUD J. SCHUYLEB

) J. ELOOM 24 J. ROCCA 25 E. ESSEL3AN \\ ALCERSON REPCRitNG COMP AM. INC. g* 400 VIAG1Ni A AVE., S w W ASe4iNGTCN O C 2M24 42371 $54 2345

k. "J [ CU 1 Houover, to coprocisto tho proors: that I will bo 2 describing, I believe it will help to understand sene of the 3 cateocries to which the diagras error does cat belong, and 4 in par'ticular two keys ones are s first, that it does not 5 involve a calculational error, there are no ea t.?.eca tical 6 mistakes nor arith; etic mistakes, no cor; uter code mistakes; 7 and second, it does not involve inco::ect mathematical 8 mod eling. The models were prepared from a mathematical ~ 9 point of view correctly. In fact, these strai;htforward to considerations have been checked, tested and audited over 11 the years and really never have been in question. 12 With these thoughts in mind, I have formulated a 13 progran to search f or additional sources of error in seismic 14 design applied to the safety-related ' systems, which is 15 outlined on the slide. 16 (Slide) 17 The title of the slide is " Independent Assessment '18 of Saf ety-related Design Issues." First it consists of ts three major tasks, and the first task is the opposite hand 20 issue. What we want to do here is find all of that verk 21 which was done but once but applied to both plants by taking 22 advantage of opposite hand design or other symmetry. 23 Our approach is to collect and identify all that 24 work, establish criteria for revie w, which we vill review in 25 detail, which we vill screen through and then go to work, t ALD(ASoN REPOAfiNG COMP ANY. INC. 400 VIRGINIA Abt $ W. W ASHINGTCN. O C 200:4 (:ct) 154 2345 1 1

dr. hdWh I l 't 1 to the sectos and to the regional of ficos that quality 2 assurance in A;;endix E means A through Z but it ex:1udes 3 wha t has happened in this case. 4 To the contrary, I think what has ha;pened here is 5 truly a monumental breakdown of quality assurance, and I 6 think that ought tu be the startin; point for the staff's 7 analy sis. It isn't an issue to be contained or confined te 8 s e r.e subsets it is an issue that goes to th e heart of the 9 quality control and quality assurance that has teen applied to to this facility. Our next question is what will the staff do. We 11 12 w a n t the staff to requitte here. We want the staff not to 13 be an umpire saying whether a ball or a strike has been 14 thrown. We want the staff to be an a'ggressive participant 15 in the review. We look to the staff and we know that the 16 public looks to the staff. We want the sta ff to de an 17 independ ent review that is above question. 18 We don't want to suggest ourselves that the staff is is just relying upon what PGCE has said and the staff is 20 a uditing that. We want the staf f to be an accressive 21 p ar ticip ant. For exanple, we want the staff specifically te 22 add ress the issue of whether an amendment to the TEAR should 23 be issued, and we want the staff to address specifically the 24 question of wha t requiatory action should we take, given our 25 regulatory obliga tions to r egulate. It is not simply, as we notasos atpontiuG counsv. ise. 400 VlaGINIA AVE, $ w., w ASMiNGTcN. O c 20024 (2021 $$4 234$

1 tho likolih. cod of on undotected orror in tho sois:ic l[g 2 analysis or design is greatly reduced." 3 What we find today is that despite perha ps the 4 Sts f f 's best efforts, we had so:e ve ry substartial 5 undetected errors that came up after an operating license 6 was issued. 7 And for that reason, on behalf cf the people that a live around the plant, I would like to urge the Etaff to 9 take a very careful look at the work PG LI is doing, at the to quality assurance program. And I would like to request that _ 11 the Staff recommecd an independent e uilt of the sels=ir 12 res nalysis. 4nderendent 13 ER. DENION: I think we are ca****- 14 a u d it. I assume we are getting an independent audit through 15 the work that Dr. Cloud is doing. That is one reason I 16 v nted the re ve rifi ca tion program 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 veicome any comments you 19 cight have on that plan after we have had a chance to see it 20 f r o m the company. And we vill have our own look at these 21 sa me areas, of course. 22 MR. BBOWN Harold, let te follow up on that. I 23 as not sure if maybe David is sa tisfied. But to the extent 24 that an independent audit ought to be pursued, it r e a ll.y i l 25 ought to be what we would consider inde pend en t, at least to '** ~ ~" i i ALCEH$oN REPCRT.NG CCVP ANY. INC, 400 VIRGIN'A AVE, S W, W ASHINGfoN. O C 2X24 (202) 554 234$ l

121 1the extent to which the governor would be comfortable. !t 2 would 'be an audit that is not being done by PGEE or throurh 3 PGE E's f unding. 4 And I say this not casting any doubts on Er. 5 Cloud 's integrity or his crpability. I stipulate those frc: 6 the beginning. It is just that the natural inclination of 7 People who have studies and audits done by those whc have a been found to have committed an error is not to take 9 necessa rily wi th the same enthusias: an audit the way they 10 would if done by an independent party net being f unded by 11 tha t individual or party t h'a t com:itted the errer. 12 And tha t is about as cently and a s truncated a as I 13 sentence as I could use to try to shoy as much respect ( 14 can to Dr. Cloud, because, as I said, I am not 1n any var 15 challengin; his qualifications or his integrity, and I 16 stipulate those to begin with. 17 But I think a party that does not have either an 18 int eres t or a sourre of funding from the pa rties interested 19 in the q uestion -- 20 E3. DENTON4 I think I understand the point you 21 are making, and we vill certainly take it under advisement. 22 BR. FLEISCHAKER4 I want to make it perfectly 23 cle a r tha t we are not accusing PGCE of dissembling here, and 24 ve are not accusing the Staff either. It is really a 25 question tha t we have got everybody here that shares the ( ALCERsCN REPt ATING COM8 ANY. INC. 4oo vincimA wt s w. w A +NotcN o e :oc:4 :::: ss+:245 1

122 9 1 problem, you have got a plant that was located on an 2 earthquake fault that was belatedly discovered. 3 It seems te me it is in everybody 's interest and 4 PGCE' interest and the Staf f 's interest and certainly in ry 5 clients ' interests.who. live near the plant that we reduce te 6 an absolute minimum the possibility of there bein; an 7 undetected error. And if we are going to do that, I think 8 ve. need a really tough audit on that plant, and that is the and that is the basis fer 9 basis -- an independent audit 10 this reduest. 11 1 think PGCE and the Staff are doing the best th e y 12 c a n. The Staff is overworked. PGCE has an interest in 13 seeing that $2.3 billion project go o,n line. We veuld like 14 to see somebody who has no impression, who has no interest, 15 to come in and audit this plant, to reduce the possibility 16 of human error and undetected error. 17 ER. DENTON: I do not propose to try to decide 18 tha t issue today, Dave. And I think I will pestpone it 19 until things become a little bit clearer about What the 20 program will contain and what it will not. But I will 21 cer tainly con' sider it and get back to you and report on what 4 22 ve are going to do in tha t area. BB. SHACKELTORD: I would like to cooment,'?.r. 23 4 24 Den ton, that I happen to be a director of PGCE, and our 25 board of directors has the sar.o kind of concerns Mr. l i i At:tasca. atacatwG coupany. isc. 4o0 viacim4 avr. s w, w Asmuctos, o e roc:4 tr::: ssorm j r_-.

\\bb ~ 1 Fleischaker has' expressed. We are as interested in havinc a 2 clear and thorough audit of this as anyone. 3 MR. FLIISCHAKEE: And we think Dr. Cloud's audit-4 is an independent audit and would add to th at. The record 5 in this case is very long and very thorough, and the record 6 ve have heard today shows -- 7 MR. DENTON: I think we have done well to Xeep the. 8 adversarial nature of this proceedin; down to the level it 9 has occurred. I think it has been an effective r.eeting for 10 tra nsmittin g information. There is a lot of follow-up we 11 have to do to understand what is behind and underneath the 12 inf orma tion you presented today. 13 We vill keep all parties inf or:ed of subsequent 14 meetings. I envision they will start occurring next week as 15 soon as we can get our people together and get c5t there. 16 We vill, hopefully, hear from you at some later tire what 17 sorts of dates these three requests might be fulfilled, so 18 ve can plan our own workload accordingly. 19 If there are no other com:ents, I propose to close 20 the meeting. EB. BRAND: On behalf of PGCI, I would just like 21 22 to say we believe we had a good meeting and full 23 coemunication with the Staff here today, and we look' forward 24 to our meetings next week. ER. DENTON: Fine. Thank you. 25 ALDER $oN REPORTING COMP ANY,INC. 400 viRGINI A AVE. S W WASHINGioN. o c. 200:4 (202) 554 2345 l

PRESENTAT20N FIGURES

1 JES AR FICURE 1. 2-2 JBHoch VERTICAL ANNULUS CUTAWAY
2
3 FSAR FIGURE 1 2-24 EQUIPME'NT LO' CATION DRAWING AT 140'
4
21' ' HOSCRI FIGURE 4-28 RV5ettinger
5 HOSGRI FIGURE 4-28 JBHoch EQUIPMENT LOCATION A 140'
6 FRAME ORIENTATION " WRONG"
7 FRAME ORIENTATION "RIGHT','
8
9 LIST OF SYSTEMS MRTresler VERTICA'. ANNULUS CUTAWAY
10 ORIGINAL VS. CORRECTED TRAME'IDCATION fil DRAWING AREAS OF AFFECTED SPECTRA AT 116'
12 AREAS OF AFFECTED SPECTRA AT 106' f13 EFFECT OF DIACRAM ERROR ON SYSTEMS f14 PIPING EVALUATION PROCEDURES
15 PIPING SUPPORT EVALUATION PROCEDURES
16 PIPING SUPPORT REVIEW
17
18 MODIFICATION SCHEDULE PIPES NEEDED FUEL LOADINC AND COLD
19

' SYSTEM TESTS SCHEDULE FOR INDEPENDENT ASSESSMENT

20 RCloud

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o T. ( & (ca p N& 7 184 ,b+ p. 1 consider to be Phase I of the reverification program, and 2 than Phase II is the larperrprogram. , Y:*E E J 3 'It turns out that it vill be easier in the overall E,r2..; 4 context to present the entire program first and the work ~ 5 with Bloom and PGCE second. 6 (Slide) 7 Our overall progras today vill be discussed. I 8 vill cover our objective, the scope and the logic of the 9 program. 10 (Slide) t 11 7hereas before ve had three -- We vere going to ~ 12 perf orm review in three areas, we have acv collapsed th a t js

13. vork into one major task, and this is the first major task
-jg 1* sho wn on the chart.

This is a review of the seismic design g y s-i; -C 15 rhain, including the seismic data that goes back and forth ~, Q _ @I.? 16 between PGCE and various subcontractors for its ~- t. E_. 17 a pplicability, and I will discuss each of these in sort 02: Ik. 18 detail as I go through. N I !N" ' The major aspect of the restructuring was that we 1g-h_- I (

59. '

20 f elt we would have a better progras if we included l s'. 4 x-F.h' 5' 2t independent calculations and ihdependent requalificau.v u el e ' r.;;P-22 certain items of equipment. This vill be our second taf or 1:3.-- - ~ 23 task and one of the larger efforts. r. f._, n.~. ' ' 24 Third, to complete the verification of the items ' N *. - - pu-25 for which we have recalculated, we vill go into the f.irld .ew. - gy -. ~

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9 n 187 {-- /y 1 really an overview disgram because I have it illustrated in ,j a m.;, And you can see when we have a specific block for i. 2 detail. h h.%r#4 3 each task that it is" going to 'be quite a complex and lengthy-m e.. e. :. . i. 4 process. t 1.., ~ Basically it is our first task in the 5 8 applicability review to diagran that, select our sample and 7 then go to work on it. 8 (Slide) { [. 9 Ihe second major task is to perform independent to calculations and independent qualification of parts of the 11 plant. This is bssically what we have in mind a t the 12 com ent. It is our intention -- and I will discuss each of h 13 these in more detail as we go through -- to requalify one of i - g 14 the buildings to take a look at ten piping problens, and I r t - 15 wan t to explain the use of the' word "problen." It is not a i. 16 problem but rather this is engineering jargon that divides t

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17 the piping system into a suitable sire that is tractable for ~. ta the computer, so it is really only piping analysis. I I6U'- T.I. 1s ~~ ~~ .. " We are 7oing to take 200 feet of small-bore LY ? [D [- 20 conduit supports, and these nunbers of ites 20 piping, .r..- r 3..c. 21 equipment and electrical panels and cabinets. I want. co ae ,.av :. - " yy.,J. 22 clear on the last ites, the electrical cabin'ets. It v i.11

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h,t 4W.: M.9.-y'. 23 not be our intention -- auch of this equipment is qualified m 6 24 by means of shake table testing. At the moment we do not L.,g.P.- 4 * . g *j g g -- 25 envision a need to retest any equipnent. , N"-V: r wp a j {WN.. . f, i k-4.7 f e n ! Y' L i AL.EASCN AEPcRTINo CCMPANY, INC,

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1E s o 190 . p l E,f- - t approach. Okay. ---,] L. C - 2 - Well, let's proceed then with the discussion of w h555% P - ' ~ 3 those items. -~- p.__ _ i;.- 4 :. (Slide) =:.... ~ 5 In the building qualification we vould propose to 8 do it slightly differently than the equipment. Instead of 7 developing an entirely new model from scratch, we find tha t 8 may or say not be warranted. Our first approach, however, 9 would be to review the sodel that presently exists for the to building tnat we rheese, and then if in our judgment it 11 represen ts a reasonable model f or that particular 12 configuration, than we would scrept the model and check it 13 by means of completely independent calculation of all of the-F 14 input that goes in to the model for that building. t e r i., 15 Then we would compare our results for the input to [ '/ I ~ - 18 those which now exist, and then if there are discrepancies [ ',' l 17 ve would stop and make an assessment. Obviously one I 1 F-l > 5 t.c.f 18 assess =ent that migh t be made, if there were no niste k.c ' .ad (mA I E.'.' 19 it turned out to be ma tters of judgment, night be to L - /. c.$J' l ?. 20 continue with the dynamic analysis and find out the 't l [... 21 consequenca. This is our a pproach on the building.

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?5~ 22 At the zoment we are thinking in terms of y k.,,u. ;. - .c ...? 23 proceeding with the auxilia ry building, and our reasons for R 24 this 'are that -- well, we debated be tween the a uxilia r7 k J -Q' 25 building and the containment building. We felt there hc s i l - s3 r a.m _ -

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me 191 C l '.. 1 been quite a bit of other review and study of the e 2 containment building and we 'sould make a better contribution,e l :sg x. ~ ~ ~ 3 to the saf ety'of ' the plant by reviewing'the work on the 4 auxilia'ry building, which, of course, is quite an important ~ 5 structure. 8 (Slide) 7 Cn our piping reanalysis this is perhaps the oth: 8 most important area in the plant. 'Je have said that we 9 would choose ten piping analyses. In this case ve vill take 10 the lines, independently develop our own models with t 11 completely separate computer progran or prograss, and 12 perf orm the dynamic analysis in a completely independent vay. 13 Only when the results are complete vill be compare 14 our results to those which now exist, and at tha t stage, by 15 means of comparing stresses, frequencies, nodes, et cetera 18 vill we be satisfied. Then further is we vill see the work I 17 done here vill serve to check other items related to the N 18 piping, particularly piping supports and probably v a l.., <..- .4 s. F Ig ' (Slide) ?f.- 20 To"sdeed it up a little bit, the s=all bore ~ ~ - w.:~ 's 21 piping,. of course, is not designed by compu ters it i 2 'd..... : f;;-J,, 2z. designed by hand calculations and spacing tables and T'- 23 cha rts. In this instance it makes sense to choose a certain E.k.- 24 length of pipe,and that is what we have done. 'J e vill go a.v...

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25 throtigh the design process with this pipe and see if our ,r%.. M b- . ;m. jhh '7 ff' i

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'r O i s 992 ( 1 results compare to that which exist. .. M.. e f.v.. 2 (Slide) 4 3 ...,2e have chosen 20_ pipe supperts. We vill

w-T.,y.w 4 independently do the stress analysis on the pipe supports: ... :a I

i 5 using the loads tha t we calculate from the piping analysis. 2 ~ G Ihat Is to say;we vill take supports from our sasple piping, 7 and this way we vill get both a check on the load and on the 8 method of strass calculation. 9 (S lid e ) 10 Similarly for the conduit in the HVAC supports, a f 11 comparable process, which is several items of equipment as-I 12 previously listed. 13 (Slide) [ 14 I don't think the number exsetly adds up to 20, L 15 but we vill independently do this analysis and compare our ff I , RL '16 results to the PGCE vork - Then a t some stage in this [ 17 reanalysis process ve.will begin our field verification. ~ l 18 (Slide) ~ f f. .l. 19 In this. case it vill be our intention to takt-tina s, E87 '20 drawings of the equipment that.We have independently ~ ~ 1_..,., ' S '~ ' 21 tequalified, go do.vn in to the field, inspect each iter-r~. _... r

i.,j:._-4 22 this equipment and take measurements or whatever may be E $$.k

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20u . -{ l.aEr 1 These tanks were sodified at the time of the Hospri ~ i 2 re-evaluation, and their founda tions were strengthened E 'Q{' 3 substantially. So we feel tha t the reverification vill be 1_ 4 satisfactory but it has yet to be done, and this is an 5 instance also of an indirect interf ace because a soil 6 roasultant was involved. 7 (Slide.) 8 In the piping analysis area, we have identified 9 the seismic desi;n chain. We have located tr ans mit t als 10 between PGEE and consultants, and located transsittals of 11 both desi;n and raview of various piping and supports. In 12 the reverification program we vill systematically reverify P 1 13 the work by indepandent calculations, as I had described. r ( ~~ 14 (Slide.) 15 Valves are about the same as the piping. We have 16 identified the valves we vant to study. We've identif;,i 17 the inte rf aces and those pa rties connected with the velve [.: 18 qualification.- And ve vill do independent re-analysi" 3. e 19 the valves. 'L 20 (Slide.) f:- s. ,E ~ 21-On-the electrical raceways,.these are t . 1sy. av.. hi. O ZZ f undamentally the conduit supports and we did review m. ,5. "& 9', 23 sangle of the calculations for the supports, and we did find . 'Y '. ? 24 instances of misapplication of the Hosgri spectrum. To say n.#- e2 6 15 what that is I have to explain the design of the conduir '. W.'[~A'... '. ~.5 q.m,.. ((# ' -e%- '/ -f g.,y. ,rs.' e-2W ALCERSCN AEPCRT'NG CCMP 44Y, INC,* ,h - 400 VIRGIN!A AVE. S.W. WASMNGTCN D.C 20C24 (202) $54 5 . m.

"f s e 208 I hoped that the entire nuclear design 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 vould not affect safety. And I believe tha t 5 that is the situation that we find ourselves in now at the 6 soment. We do not find the basic safety of the plant has 7 been com promised, but we have found instances of r 8 nisapplication of seismic data. Thank you. r 9 MR. DeYOUNG: 7 I ask a question? Why did you 10 hope you wouldn't find large errors that would impose upon = 11 safety? Why did you hope that? I could see why the utility 12 would hope that, but as an independent reviewer, why did you 13 hope tha t? 14 HE. CLOUDS I'm speaking as a professional 15 e ngineer. 16 MR. DeYOUNG: Som etimes if you ho pe for something, 17 you direct your activities toward that hope. It's a stranga -18 sta temen t f or an independen t reviewer. 19

33. VOLLMERt Bob, ;etting back to some of th e 20 errors that you found[ I's curious, vere these f o und because 21 you re-did the calculations or because the design 22 documentation was so good you can go back and find very 23 specifically where the" error occurred?

24

33. Cl0UD:

Our work up to now has been based upon 25 the review of the applicability of the data. We checked the ALOERSCN RE?CATNG CCMP ANY. INC, 400 VIRGINIA AVE., $?N 'N ASHiNGICN. O C. 20024 Con 554 2345

9 21a C S[($ M/ 1 were not changed to indicate that this analysis coE[d be c 2 usad for ' Unit 1 if you so dhose. egy y -49.. eigt. -During the design process of the supports in Unit 4 3 'f 4 2 it was decided to change the anchor design in Unit 2 f:Om 5 what we had in Unit 1, and they changed tha anchor to allow' 6 rotation but anchored it to prevent any translational 7 iovement. When that change was mada it bera.1e necessary to 8 rerun that Unit 2 thernal analysis which was used for Unit 2 9 and Unit 1, to pro perly model the anchor. '"he analysis was 10 rerun and issued, and the previous Unit 2 analysis-was 11 cancelled. 12 Fortunately, the pipe designers recognired that 13 since it was specific to Unit 2 and that it modeled a 14 dif ferent anchor configuration, they should continue to use' 15 the cancelled previous Unit 2 analysis for Unit 1, and th e r-16 did. So the design was proper. 17 ER. DENTON: Do ve have a report from you on 18 this ? All the things you just sen tioned ? 3.. 19

52. CREWS:

We do have an LEE. I think we have 20 the initi&L report. ~ 2 - 21 MR. TREST.ER: I have described it as to Reg.tou 5, y E. 22 res- ?!: 23

53. DENTON:

lat me move bark to an issue that we f g., E'- 24 started on and that's the degree of independence of Dr. n 25 Cloud Tell us who in the organiration he caports to- . - - ~... i y.- .N-i [- ,p / 3 F-g- ALCERSoN PEPCRTING COMPANY,INC. 400 vtRGINIA AVE.,1W, WASNINGTCN, D.C. *0024 (*CD 554-h4

, r e 215 l 1 ER. MANEATIS: I was going to add tha t Dr. Cloud 2 doesn't report to anyone inour organitation. He has been $f::." ~ 5 -= - f 3 retained to do an independent and indepth reverification. ~. 4

58. DENTON:

Who gives his his directions as to 5 scope? e 3R. YANEATIS: As I had earlier indicated, Mr. 7 Brand, our Vice President of Engineering, is directing this a whole investigation and re-analysis progras. And he, with 9 his subordinates has retained his to make this independen: 10 investigation. 11

12. CLOUD:

If I could add something to that, I 12 wocid say the propras that I presented was based on all :r 13 own ideas, and I formulated it myself without any help from 14 the people at PGEE. 15 HR. HANEATIS: And I would further comment that on 16 the basis of his findings that he reported in his interis 17 report, I think Lt is clear that his review is. objective. 18 EE. DENION: Do we get the sams reports he.. w [ ., 4 19 you ? I 8 20

32. MANEATIS:

Iou just got it. And I ha ve

t. o 21 say, Mr. Denton, that some of these things have just been ct 22 disclosed to me,'so you got it almost the same time i d....
.3

'.Q,.%. ~ ' ' 1 l y; ' 23

33. EISENHUT:

When will we be expecting to sea h. 24 tha t short-ters report, Bob Cloud said it's essentially . t y *'. 25 completa. ~

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,r 216 1 ER..HORTON: Dr. Cloud, could you answer that? a= 2 ER. CLOUD: I bell' eve it's -- we vill be turning 4., - 3 it in either this week or next, so you should have it 4 shortly thereaf ter. 5

52. NORTONt I might add we do no t have it.

It's 6 not a question of us. reviewing it. We don't have it, 7 either. It just hasn't been done yet. 8 MR. DENICN Well, since this is a particularly 9 sensitive issue, I was wond ering how you propose to handle j 1q ossents on this draft, or are you scing'to s'ind us the si e'""* c ll 11 report he sends you and add you cover letter to it? Or hov 12_ vill you preserve inde pende nce? 13 MR. NORTON t Well, Like any other satter, I's a 14 little bit concerned about suddenly there b_einLastions 1 15 about, the independence of the review. The NRC has retained I 18 a consultant and the sane question migh t be asked -- v el.t i 1 4 17 gee, how do ve know that review is independent? I mean, i 18 there is no reason to believe this review isn't indepet... t ,d3. DENTON I'm just asking hov independent is 't. 19 = 20 MR,NORTON: Any saqqestions you have -- if :r ou i 2t want-the caport before ve see it, fine. I frankly resent \\. j 22.the implication that Dr. Cloud is not an independent a-1 1 23 reviewer because he is. As Mr. Maneatis just reported to f 24 you, we heard this presentation to you yesterday -- in f act, 3;.5 2r we heard it Sunday for the'first tine. I assure you that'r l la..

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i 217 1 the case and we came back last night, or we came back ~ 2 yesterday, and you heard it this morning. < ~.r A@ 3 Ihe report itself hasn't been prepared. If you 4 vant a copy of it before ve get it, fine, or 5 simultaneously. It is an independent consultant, and, you 6 know, I don 't know how we can show you that more than to 7 give you the reoccts when they are prepared. You certainly 8 are welcome to have an auditor, if you vill, from the NRC 9 accomany Dr. Cloud and his people in their work. "hatever to you want to do. If you want to talk to them directly out of 11 our presence, fine. He is an inde pe nden t_ CAM"?l $ -. 12

33. DENTON:

Well, he senti:ned in his 13 presenta tion a recessendation to the company, for example, 1 14 believe that you include some aspect. 15 ER. NORTON: Yes. 16 3R. DENTON Will your action on those ir recommendations then be in a cover letter to us? What will 18 be the follovup of the report? 19 ME. NORTON: My understanding is that this y_ 20 reco=sendation was made very shortly -- very recent1) 5y!'... 11 should say, and indeed, PGCE is going to adopt the c>u. .[ i ' 22 recommendation b'It it hasn't gotten to the point of beln? s;*;". 23 reduced to writing yet. 1 24 3R. DENTON I just wondered how we would receive

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m e-218 / { 1 MR.,NORION: We vould advise you,.as we agreed at 2 the last meeting we would do'. We vill keep you advised. So. ...m. " g.,,. ,i. ' 3 f ar you have pretty well been with'us during this 4 procedure. You were out there during the week of the 12th. 5 I believe it was the 12th o r the lu th o r th e 16 th, in th at 6 timeframe. And we intend to keep you fully advised. 7 MR. EISENHUT: As you go through this there are 8 bound to be a number of recommendations that cose out, and ~ _9 think you were treating Harold's question too a.arrov'.y. Aie % .s ind_epend_eit' 10 rou, at some point, going to say here's the 11 study of these 38 recommenda tions and here's wha t ?GCE is o r 12 is not going to do about th a t? 13 ER. 53HION: Absolutely. I think a procedure can 14 and should be worked out to do that. I guess the problem is- ~ 15 You can 't report some' minutiae'that really has no 16 significance or bearing to everybody, and I guess the i 17 question is where do you draw the line. And maybe vo cau i-18 provide you with a weekly status report or a ten-day t L 19 report. K. 1 20 ER. DEUTON: Why don't we cover that this 7 21 afternoon? I think some periodic report would be very 4 22.useful because we have trouble scheduling our work like you ?; 23 a us t, as nav information de velops. 24 Let s'e raise a couple of other issues. You A. 7.0 25 rep'orted something concerning a safety injection in you r- !C ' ?^7 ~ ~ ..y. :*. / .g. ALCERSCN REPCAT NG COMPU4Y INC. (. 400 VIRGINTA AVE. S.W. WA$NINGTCN. O C. 200:4(202) $54 u

236 (-- 1 service contracts during this period of interest, four of 2 which you described. The other eight would be looked at rm? jf.; 3 under the seismic reverification progris. And in addition, 4 then, you wearing your QA hat will look a t all twelve? 5 ER. HAYEOND: Yes. 6 ER. DENTON: For evidence of controls? 7 3H. RAYMOND: Yes. 8

53. DENTON:

During that period. 9 ER. RA!MOND: Yes. to J3. DE TOUNG : Again going back tc independent 11 review, you have two major programs underwa ys one, the 12 verifica tion program with D r. Cloud, someone free outside, 13 completely independent; the other thing is the CA check frc: 14 within the conpany. Did you consider going outside to get 15 an independent chack of that? 16 2H. NORTON: No. The nature of quality assurance 17 progran and audit is such that we believe very strongly that 18 ICE and, f or that =a tter, NRR can easily ve rif y our autt ~ 19 It is the vary nature of the paper trail, the audit is goi'eg 20 to be done and, of course, create its own paper trail. o 21 ve believe the NRC can easily satisf y itself of the e, , =. zz or depth of the audit and the accuracy simply by jfl., gg'spotchecking without a great deal of inpu't on ?.he NRC's 24 p a r t. r: 25 MH. DE TOUNG: Dr. Cloud said he had spent ahnu" a r ~~ ' Y* * ~ A4.0ER$CN REPCRT'.NG CCMPANY. INC. 400 V!AG NIA AVE, S.W. WASHINGTCN, D.C. 20C24 (202) 5541M J Q .~..

237 ( 1 thousand man-hours to date. How many san-hours ha ve you ~-" 2 spent on your part of it? "7I 5. 3 MR. BAYMOND4 .The question was how many san-hours 4 have ve expended on the information we have identified to 5 date; right? 6

12. DE YOUNGt Yes.

7

53. RAYMOND:

Let se do sose sental arithmetic 8 real quick. Approximately 250 to 300 san-hours. 9 $2. DENTDN: Do you report to any or;anication? 10 MR. RATMOND The vice president of nuclear power 11 generation. 12 T3. DENTON: Is thic independent then of -he 13 organitational units th'at you are auditing? s_ 14 ER. RAYEONDs Yes. 15 MR. DENTON: You say different person than just 16 head of tha engineering staff? 17

52. RAYMOND:

Yes, he is. Don Brand is vice 15 18 president of the angineering department. Mr. Schuyler t.s 19 the vice president of nuclear power generation. Two n.- 7 20 differen t distinct people. 27 3R. DENTON: I would like to touch on just a few 41.*

y zt other cleanup issues here.

I do not want to put Dr. 31oon . t. 23 on the spot. But I will anyway, since he is quite capable 'ipl: 24 of answering any questions in his field. ??2 25 I wondar, do you have any comments you woulf. .th 5',A' - ~7 T. - - A.e*h -rM / q 'M ~2 [-j ALCERSCN REPCRTING CCMPANY. INC.

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400 VIRGANIA AVE. S.W. WASHINGTCN. O.C. 20024 (202) 554 2345

4 241 C 1 statement that I think will be = ore helpful. -c h g'* N 2 The cantral issue) though, was raised by Dick n d' 3 DeYoung's comment, and Darrell Eisenhut pursued it, 4 concernin: the independence of the audit. The Governor has v' 5 asked that there be an independent audit. 6 Yesterday a very interesting L.A. Times edito rial 7 nade this point another way. It said, "Is anyone likely to a believe the people who nissed the mistakes in the first 9 place, if they say that th ere vere no others? 7e doubt it. 10 Governor Brown 's proposal =akes sense, and the sooner the 11 outside help is sought, the sooner the questions can be 12 answerad. 13 "Dr. Cloud is not an independent auditor in this 14 case because ?GCE uses the word ' independent.' A cow is not 15 a horse. Dr. Cloud is' not independent. He was selected by 16 PGCE without the input and the consultations of the othcr 17 parties. We certainly did not play a part in it. 18 _"I think it is unlikely to think the public.xei. 19 conceivably believe conclusions reached by ?GCE 's own 2.' 20 selected investigator when we have not played a part J r. ) 21 Dr. Cloud stated,that he had a predisposition th a_t h e 'nau =.: 22 hoped that the basic safety of the plant would not be 23 compromised, and he found that to be realiced.' 24 "In addition to that, there is no var that his 3 ,n N'F 25 study or that of any other truly independen t group can i.- 2,6. - _3

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g 242 ( }(WN$ the e-W 1 credibility with the public unless there is some forn of an j ) -2 oversight committee made up'of representativ~es of .t - hav'e a stak'e'in the proceeding." 3 different parties that ~ 4 The second point is I think the institution of '5 integrity and credibility of the agency is really at stake 0 here, because despite the vell-meaningness of everybody 7 here, it really was a very embarrassing fact to realize that 8 the plant was licensed and then these errors, which should 9 have been caught systematically and r:ctinely, vere found, 10 as the NRC spokesman put it casually, by a young engineer. 11 I think the only way the NEC can r ansara-a 'c 12 institutional credibility in this case is if the NRC sets in 13_ motion a truly indeeendent studv eursuant to th e proposals 14 set forth with the Governor 's lettst. 15 So I would like at t'his point Dick Rubbard to 16 address some of his tachnical observations. 17 ER. HU3 BARD: I know everybody is tired and hunory 18 and totentially very irritabla, so I will try to go t h. o r,. 19 this ve ry quickly. First o f all, my impression is that

20. Criteria 1 through 7 of the 18 criteria have repeatedly no t 21 been met at Diable.

We find that the progran was late ceiny zt established; by that, it was not established until the 23 1977-78 time period. 24 Based on my experience at General Electric, that 3-25 prior to 1970 -- prior to ' 1976, I would hav e said by '7? to

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o 2n9 C 1 HB, DENTCN We are sorry to keep you waiting. 'J e 2 will be ready here in a sombnt. .T h:' ~ 3 ~ I understand you have' requested an opportunity to 4 make some additional ecmsents before we begin. EE. 33sTONt Tes, we do. Are you ready to proceed 5 6 at this tise ? 7 KE. DENTON: Yes. 8 F. 3. NOETON: There a:e a couple o f areas I would s like to cove r. Sasically they relate to questions of the to independence of the reverification of the progran. 11 First of all, ve disagree emphatically with the 12 f actual representation in arguments made by Governor Brow:*s 13 representatives. However, we don't believe this is the 14 foruz to get into a debate about those re prese n ta tions, but 15 v e did v a'n t you to k'now that we don't aq ee simply by.ss 71: q 18 nothing. 17 Getting to the reverification progran, I ha ve not 18 gathered -- in f act, Governor Brown's counsel even 19 stipulated to the qualifications of Dr. Cloud, and I hg v s 2

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20 gathered anyone challanges the ability of Cloud and . ~. -. 21 Associates to do the job. Indeed, that is why PGCE.seuaued Dr. Cloud, was because of his qualifi:s tions and abili. ties 47g.. 21 if 23 to do the job. The job is under var. I think Dr. Cloud l l 2. f 9/." 24 said this morning they spent approximately 1000 san hours to m:- 2E.. 25 date. I assume again from the nature of the questions that

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g e 250 1 the prog ras is basically acceptable, although I' gathered c 2 from the questions asked thi's morning the NEC sar well have 7.'. ,2 3 additional input. They may well expand it here or there. I 4 think that was the sense of the questions ther were asked ..N. g, 5 this morning. 6 The problem doess 't appear to be th e program 7 itself or the ability of Cloud and Associates to do the 8 program. The problem aplet t to be people saying, well, it 9 can 't be ladependant if the utility hires the consultant to 10 do the independent verification because they hired him. = 11 That is not a general philosophy with which we vould agree. 12'It is standard, traditional practice'in any work of this 13 kind, whether it be nuclear or otherwise, that utilities and i 14 indeed government agencies hire consultants to come in and 15 tack 1.e problems that ther really can't tackle for one reason te or another. It is no different in this situation. 17 But obviously peopla are questioning whether or 18 not this is independent. So our problem lies, we thin..,

1g how do you assure that it is an independent evaluation, 20 Someone during the lunch hour said, well, you should pen tea y 2t him as wearing a black hat We could sar that, but nobody

.?- 22 is going to believe it br simp 1T saying it. 23 What we have decided to do, keeping in mind that 24 time is of the essence here, the 1000 man hours that have 25 heen put in so far, and the hundreds of man hours that t svo .r. e' ALCERSoN REPORTING CCMPANY. INC. a 400 vtAGINtA AVE. S.W. WASHINGTCN, D.C. 20024 (M23 554C - l.g

251 --( g.- 1.been put in on Q A-QC have not indicatad any significant -e 2 saf ety problems where we fe91 there is anY dinger,' or if rme 3 there was any, that these erro,es have gone undetected. So - - ~ $~ci II 4 time is certainly of the essence to us in terms of gettinc f.g 5 that facility in operation as it has been nov for the past 6 sany months. 7 The 'JRC has apparently brought 3rockhaven aboard 8 about the same ti:e we brought Cloud and Associa te s aboa rd, 9 again as an independent check to assist the NRC in its the.RC expand N 10 svalua tion. We would request that 11 Brookhaven's scope of work as -- I think the best phrasa I 12 can use is 'a process sonitor, to sonitor the process of -he la reverification program, to have peopla or a person or 14 however they feel they can best do the job, in Cloud 's 15 offices to see what is happening there, to have a person or 16 people, however they think they can best do the job, to W vo that it ts 17 PGCE and Cloud's people -- to verify the process, 18 indeed indapendanc. We can say it is independent until g 19 are blue in the f ace, but if somebody isn't going to N'..- 2a us, saying it isn't going to change it. i F 2t But we feel that Brookhaven, who is at le se y_.p-22 several parties removed from us, can verify the independence L ztof that vetifigation program, and do it easily. We c'. 24 certainly can't have two organizations doing the hfr 25 reverification program at the same time. They'd never get u:s. ~ p.. h~ . p%- ,L e' E. 4.6 ALrERSCN REPCRTTNG CCW*NY,INC. i -- 400 V1AGIN1A AW S.W. WASNNGTON, D.C. 20C26 (202) $3440

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252 1 it done. ~ 2 3R. DENTON: We don't have to address that problem, - -. I"^ ..I'm'sure, though, the Commission would 3 this af ternoon. ^ since the proposal 4 appreciate any views you have on that I to the Commission, and if you vculd like to respond, 5 vent topic. 6 as sure they would appreciate your views on that We tra coing to restrict oge comments this 7 8 af ternoon to what I think you should be doing in the progras. 9 MR. NORTON: All righ t. We thou;ht in li;ht of 10 the questions that were asked this morning that the staff 11 should indeed, if the staff has a desire to verify the that we have no objection 12 independenza of this program, outlined. We 13 whatsoever to the kind of program we just an intrusion, if you will, by the staff 14 would welcome such 15 in the p rocess. By' intrusion I don't mean that in a 16 negative way. We feel it might slov it down a little bit. 17 When you get more people involved, it slows the process down ve are 18 a little bit, but while time is of the essence, 19 certainly willing to live with that. t MR. DENTON: I think that issue may well bc ite i 20 at 21 issue of a Comnission meeting on Eonday, and I am sure vu with that time the role of the staff vill be to discuss it '. eir 22 +. ~ j f 23 the Consission. h ER. NORTON: Incidentally, again, the question was i 24 { f.a - tha independence of the QA-CC. Again, we vould j'f. 25 raised about .Y % bT. =). - .ex ? . a:. y ALCE.ASCN REPCRTING COMP ANY,lNC. 4 400 VIAGINIA AVE. $.W. WASNNGTCN. 0.C. 200 4 (202) : w.79 t [

253 we feel the NRC is fully capable, as 1 like to reiterate that 2 it has, to continue to evaluate tha t. Histocical'ly in the ~ ,1 b-3 industry, the 3RC has certainly worn a black hat in that ig - L-4 area. 5

53. DENTON:

Thank you. 6 In the period since we met, Dick De Young and t 7 and our staffs have net to reflect on what we heard this 8 morning and what we have ga thered by direct discussion ever 9 the last three weeks, and we have come to some conclusions to about the scope and extent of your activities that I think of 11 in some respects vould substantially broaden the extent 12 design verification. 13 _ Let ne tal.t about these areas. One area our view is what you are 14 still hasn't chan7sd. on, and I think that embarked on -- you remember last tine we indicated we 15 now 16 thought you should do an independent review and verifica tion - 17 of all the selsnic related activities prior to fuel loading,

r. :

18 and the results of this should be forwarded to us, 19 sodifications that that progran requires should either p o r r. i ' t e d 20 made or it should be justified to us before you be 21 to load fuel. I think our views on that are the sane, and I 22 b think the Cloud approach substantively will be addressing E 23 th'at issue. So I think with regard to the activities 24 U-25 requiring f uel loading you are embarked on a progra.m th a t E. h.. F - t '~ ?. = u. ALCERSCN REPCRTING CoMPAt4YelNC. '.Y' 400 vtf4G;NtA AVE S.W. *ASHINGTCN. O.C. 20024 (202) C'.4 ; ~~ k'I

y .o 254 c r area. satisfias what we think should be done in that 1 2 And what I see y6u doing, just to restate, I see L .p... 3 an independent design reverification being done in all ~ 4 seismic design related areas. That includes the eight 5 service type contractors. So I think in that area what we 6 are stating is not dif f eren t than what we said la st tise. I think where ve do differ is wha't else needs to 7 8 be done beyond that. It seems to us that before we can sake 91 determinition about goin g above i percent power, assuming 10 t ha t the seismic design verification progra: had been 11 completed, that the scope of discovery was not any larger, we t h i r. mu 12 and its modifications required had been :ade, 13 need a sisilar independent design verification of all the 1E safety related other service contracts. 15 The other four that you sentioned, you had in our view, vould 16 proposed to do a QA check on those which, 17 only go partvar toward addressing the problem. I think -h' 18 those other four service related contracts should have 19_same sort of in-depth independent design verification. _- g One meaning of the word " independent" fot t-20 ~.* 27 independent of the people who did the original work,. d. 22 whether that was done by your existing contractor, Dr. T? I Cloud, or some other group, it seems to me in order to be 23 =- - - - - -. ~...., _..,,. [ 24 valuable it has got to be_done sor_e or less outside your ~. - &M 25 design organiration. [. [: 3.. .p ALOEASCN REPCRTING COMP 4NY*INC. ~ 400 V1RGINtA AVIE 3.W WASHINGTCN. D.C. M4 (202) m

v i s o 255 1

52. N3RION:

Exct,se m e, Mr. Dento n. Iamkot sure, 2 rou intended to say what I.. thought I heard you say, but I [~ 3 have heard other people sarit':. Dr. Cloud' has not worked

4. for PGCE bef ore on this pro ject.

Someone said he was a 5 consultant before. That is not so. 6

32. DE3 ION:

No, I was trying not to say that he 7 wouldn' t be suitable. I was sayin7 that it didn't have to 8 be Dr.. Cloud but a similar eff ort like that done by his er 9{cmeone dho is independent of the de sign activities related 10 to those four other service type contracts. 11 Secondly, and I think the bigger ef fort, Will be 12 to conduct a similar -- and for the area I ;ust mentioned, 13 these four other service related contracts, I think it 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 information with regard to service 17 contracts that you should do that not only for the eight.vo u 18 have started, but for the other four. 19 Now, I think on the sampling basis you need to i j 20 an independent danien verification of.PGCE's own inter,al 21 design activities which ve-were no t able to establit.i. .le S e 22 sorning that thera were internal organirational situaticor .t ~. 23 or procedures that somehow precluded some of this 24 informality to get into your own internal process. So I M. 25 would think you need an effort comparable to what we have q

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g 0 256 basis for PGCE's own h,.1 heard to seismic, but on a sampling I 2 internal design review effort. r~ d =.. f And I would think'for starte'es, if you were to 3 4 spend the same amount of design verification effort on .F 5 PGCE's own design activities that you are spending on the provide a f air degree of a seismic, you would help to 7 confidence that you either errors if they existed or 8 demonstrated that they were not there. So that would be the I think we vou,ld like for you to io before i 9 second activity 10 going above 5 percent. The third activity ve think you should und erta ke 11 12 would be an independent desitn veM '*cm-ion ecce a rti.- on -, 1h the sampling basis of the service related contractor sock-i 14 thst was developed af ter the 1978 tizef came when you 15 supposedly did have good CA in effect. So I think where ve differ from where ve were at 18 17 the last meeting is that in the last meeting we had focused w-r2c 18 on the independent design verification onlyJn.th.o You have proposed this morning a 9A 19 related activities. I as not able to see a ~ 20 check on other activities. .i 21 distinguishing characteristic today that wo uld excim r P' looking into these other areas. That's why I would semple

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22 .7 I would have someone M the company's own design activities. 23 '78, and I vould i 24 sample the activities of contractors af ter crier if 25 then do a complete check of these other four services ~

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~ ~ 258 l ~ R independent sampling of the oth,er 1 you did sufficient 2 activities ve,have described during fuel load and low power.T F-to bed questions that sight 3 testing activities to put design verification throughout. 4 otherwise arise about And I would propose to communicate more formally 5 6 with the company af ter this meeting 'for specific details on But I 7 what these words sean, our tisef rases and so forth. 8 vanted to get the approach laid out nov so we could discuss 9 it if necessary.

13. NORION:

May we assume that the type of 10 verification. program as outlined by Dr. Cloud this torning 11 12 as the way the varificatica pcogr$s proceeds is acceptable that we use that same type of 13 in these other areas, to do is get two sonths down 14 progras ? '4h at we don't want what we had in 15 the' road and sa7 that progran really isn't 16 sind for this. Is the type of verification progras you have L 17 I 18 advised the same? s

58. DE IOUNGs Yes.

w 13 MB. 30BTON a Thank you.- 20 HR. DENTO!I:- I thought the type of progras seems a 21 You sentioned you had put

2. -

logical approach to the activity. ~t 22 23 258 man hours into checking Q A.- '4e had put far sore than low number for you to quote

24. t h a t.

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~.: 262 C- ~ 1 'fR. JORDANS I think you could clarif.y that by 2 saying those reports vou$d not substitute f or your technica-1 f# ~ 3 -- i.i. 4 '58 NORIOMs We also have-5255(d) for Unit 2. 5 These wo uld be in addition to that. s ER. DENIGN: We tried to write this down in plain 7 language as opposad to regulatory language. 8 (Generai laughter.) i 9

53. DENION4 And we vill pass these around for 10 people interested.

4 11 It might be well if you spend a moment to take a 12 look at it. 13 ER. NORTON : Excuse me. Earlier I said that Dr. 14 Cloud had not been a consultant before. What I meant was 15 not during any of the timef rame th a t all this was going _ on. 18 He was involved in a seismic systes in_ter_ action _crocr=s tt.a : 17 vas done for the ACRS, and since somebody pointed ou rit en I ^ If 18 said ha was not a consultant bef ore, what I was thinkin-of 3. 19 was during this timeframe we are talking about, '76, "/7, 20 ' 78, and I believa late '79 when the seismic system l 21-int eraction program was going on '.!,.i 22 ER.-DENTON: I appreciate the clarification. ee I que,ssAst to_g.eitetate,..mI. Jiav.of indepeadence 23 s d.6 g: 24 would mean as a minimum Jou are not reviewing the work with -2 ~- 1 25 which you vera associated. 3 .-h, - q. ~. ~. ALCEA$oN AEPoRTING CCMPANY,INC, '7.- 400 VIAGINIA AVE. S.W. WAS)4tNGTCN. O.C. 20074 f 7fm NN

f,7 gy. t s_g;.g. 1,.-f.. D : ;.;. .. -. 1. _ 4 263

33. NORTONs sure.

~ j t 2 5R. BROWNS I_have got a couple of questions. IfT -w.. 3 vant the racord to be clear, the Governor of California said: + 4 that an independant audit would be one not done by a party 5 selected exclusively and unilaterallr by PGCE. Now, Dr. 6 Cloud would not be what the Governor considers to be an 7 independent audit, so I would like the record to be clear. 8 Are you permitting Dr. Cloud to do the audit which 9 PGCI is going to do to verify the quality of this nuclser l l to over plant and the matters relating to the recently 11 disclosed errors? 12

32. DENION:

'4 e would not exclude Dr. Cloud ir.0: 13 performin; part of the required independent design review.

u. -

13. BROW 3 But are you going to permit him to do 15 that now without sdding anyona else?

I want to make sure to that the record is clear here. 17 As I understand it, this is the only audit t.b r ' :s [ 18 going to be done on the outside that will be sanctioticc. by 19 PGCE, by Dr. Cloud, and a report vill come in. Are vot' I 20 stating here that that is accaptable? 21 EH. DENTON s. When coupled with the Commission h,e. ~ 22-resources that are available to verify the adequacy of such l 23 a report. I think we are operating here in a mode in which l 1 l C 24 ve require the Applicant to do what is necessary, and th en m. l {; 25 the Commission, through its staff and consultants, ,9 [ v: '$h - f* l , r. ? O l . y, ALCEASCN REPCRT1NG COMPANY INC. f (z l#' s ew= mne ou s aut tw waewwt1TPM S e dW*g a s *W9g saa.vtaa

4 P 264 1 necessary, vill verify that. (__,, Therefore, to make this clear for' the ** 2 HR. BROWN: a E_I 3 record again, you are now rejecting 7Ae request of the "5" audit as he 4 Governor of Calif ornia for an independent c 5 defines it. Is that corbe'c ?~ O* 6 MR. DENION : Well, I'm not precluding the company 7 a from doing it if they so desire, but I am n ot requiring tha t 9 it be done in the manner which you specify. 3R. 33023. Ihe Governor requested the Chairman O f to the the Commission to respond -- well, the Governor sent 11 12 letter to the Chairman, and 'sha: is important f or us on ne 13 record is your action here, the authoriced action of the 14 Consission. Is the Commission in effect saying that what 15 the Governor has ssked for will not be granted? 5H. DENTON: I'm speaking only fo r the staff. I 16 17 am not requiring that that activity be done. You realice, 18 of course, the Commission is meeting Monday and they coo'4 ivY 19 decide dif f erently, but I am not recommending such an 5: I know today. I am ~ 20 extensive verification based on what k$: 21 asking for substantially expanded design verificatiora over I Ei 22 what was proposed, but not an across-the-board look as the 4 s.- Dd Governor has proposed it. ty.- 23 MR. BROWN: Okay. I understand that. 24 m ? 23 I want to go to one more aspect. J,e,- e c... po. - 9V' r5

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4 n.cascn avonvNa ccep. me. ~ 400 VIAGINIA AVL S.W. WASHINGTON. Q.C. 200 4(202) 5544 145 I:.. YW*

o 255 C 1 The Governor has asked that there be a steering 2 committee, that is, that a representative of the Governor .cz a .,[ 3 play a meaningf ul part in the audit. One of the purposes 3,. 4 was to assure there can be some public confidence in the ? 5 results of this study because outsiders are involved, and 6 that in fact every party to the proceeding had an 7 opportunity to contribute to the steering committee. 8 Ire You today rejecting the idea of the steering 9 committee? 10 3R. DENTON: Your participation can be ':o the 11 fullest, as it has been up to date, with complete access to 12 all' the inf o rma tion that we have access to, but I don't see 13 a need for a forsal steering committee of the type that Io 14 have proposed. 15 ER. BROWN: And is it correct again that you are-l 16 spe,aking for the staff and not the Commission? 17 MR. DENTON: Yes. 18 NR. BBOEN : Is it also correct to conclude that l 19 since you stated there is a meeting next Xondar, you 20 recommend to the Commission tha t-the Commission not grant the request of the Governor for the audit being -- 21 '[. 22 EH. DENTON: I will recommend that the Commission m 23 approve what I have required. 24 Herb, I feel like I am being interrogated here. t 25 You are certainly free to advocate the position of the i% %u '- 3,2 - r T. l ' 5;;. te M.CER$oN RUCRTING CCMPANY,INC. 400 VIAGINIA AVE, S.W, WASHINGTCN. 0.C. 200;;4 (202 534-23M5 g- , 3

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j l b ( '~~ 1. Licensee ~ Activities Prior to Pael Loading Conduct an indekendent daeign review and vertftcation of all safety -~ related activities performed under the PG&E-URS/Blume contract as they relate to the Hosgri reanalysis. This review should address the development, accurancy, transmittal, and use of information both within PG&E and within URS/Blume, as well as the transmittal of infomation between PG&E and URS/Slume as related to the ~ requirements of'NRC Quality Assurance Criteria (10 CFR Part 50, Appendix B). The results of this verification program should be provided for NRC review. (.. The errors that have been identified to date, as relate to performance of activities conducted odner 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. 2 In addition, any modifications that are required as a result of the current and newly identified problems must be completed prior to [{ fuel loading unless specific exceptions are approved by NRC. N-(- .,x e'

~.; lM ~ ~ 0 ~N .9 bj.. 2. Licensee. Activities Prior.to. Exceeding 5% P_cwer Ooeratic'n a) Conduct an indeoendent desf en review and verification of all safety related structures, systems, and components 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 i PG&E and each contractor, as related to the requirements of NRC Quality Assurance Criteria. b) Conduct an independent design sampling review and verification of PG&E internal design activities that have been performed on -Diablo Canyon Unit I that related to the development of the design of safety related structures, systmes, and components. The extent of this review should be that which is necessary l to confinn that the PG&E quality assurance controls described in their QA Manual and associated procedures since 1970, and as p related to the implementation of NRC Quality Assurance Criteria 1 have been fully and effectively implemented, y, ~. g r*m o' e i

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== [* J %*! c).,; Conduct an independent design sampling review and verification

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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 components. 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 PG1E, as they relate to NRC Quality Assurance Criteria Provide the results of this verification program for NRC review. Any modification required as a result of this program shall be completed prior to exceeding 5% power unless speicife exemptions are approved .2 by NRC. H -h V. _^f qO. T.s _*l -i<- {$ ^ T :*~ -h i .ex. g. + 4

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REVIEW OF_ SEISMIC.DitSION CHAIN POR APPLISABE.lTY i

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i FRANK MIRAGLIA 492-7243 11/09/81 PG8E REVERIFICATION PROGRAM PROPOSED BY STAFF (SUBJECT OF 50,54F LETTER) CONTINUED o PG8E TO PROVIDE: DETAILED PROGRAM PLAN FOR C0f1 DUCT OF INDEPENDENT DESIGN REVERIFICATION PROGRAMS DESCRIPTION OF QUALIFICATION OF PERSONNEL AND CONTRACTORS PERFORMING INDEPENDENT DESIGN REVERIFICATION PROGRAMS l i l 8 l 9 L-

3. 4h2 b ]1/09/81 PG8E REVERIFICATION PROGRAM PROPOSED BY STAFF (SUBJECT OF 59.54F 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 Oil FlflAL DESIGN EVALUATED AND REANALYSIS DOCUMENTED IN TECHNICAL REPORT ALL APPLICABLE MODIFICATIONS TO FACILITY DESIGil RESULTING FROM REANALYSIS AND REVERIFICATION EFFORTS BE COMPLETED o PRIOR TO EXCEEIllNG 57. POWER INDEPENDENT AND COMPLETE DESIGN REVIEW AND REVERIFICAT 0F ALL OTHER PRE-JUNE 1978 SERVICE-RELATED C0!! TRACTS INDEPENDENT AND SAMPLillG REVIEW AND REVERIFICATION OF PG8E INTERNAL DESIGN ACTIVITIES IflDEPENDENT AflD. SAMPLING REVIEW AND REVERIFICATION OF POST-1978 SERVICE CONTRACTS j ALL APPLICABLE MODIFICATIONS TO FACILITY DESIGN l RESULTING FROM REANALYSIS AND REVERIFICATI0'l EFFORTS i BE COMPLETED l

w. -g a ' 4 i s *ta 3--/ n#'e, UNITED STATES '~ NUCLEAR REGULATORY COT.*.*.*!SE!CN 3, " g, $ I wasse.cTen. o.c. :esss g, v j 'g ]

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t OFFICE OF THE f.8,gpch ]g,]ggg SECRETARY Docket Nos. 50-275 OL 50-323 CL Byron Georgiou, Esq. Legal Affairs Secre_tary.to .the Governor ~ - :- State Capitol Building Sacramento, CA 95814

Dear Mr. Georgiou:

There are currently pending before the Ccmission petitions filed by Governor Brcwn and the Joint Ir.tervenors in this proceeding for review of the Atomic Safety and Licensing Scarc's decision in ALAS-5ad, 13 NRC 903 '(June 16,1981). On March IS,1982, the Ccmmission declined to grant the petitions for review. 10 CFR 2.736(b)(5). The views of individual Comissioners are enclosed. Spicerely, If gf 'g: M. samuel J. C N k Secretary cf the Cecmission

Enclosure:

Separate views of Chairman Palladino and Commissioners-Gilinsky, Bradford, Ahearne and Roberts cc: Service List x f ) n <A, m n 1c ;.v.acruv g-i ol'.

e *ete g ,I*g UNITED STATES T NUCLEAR REGULATORY CC'.'J. CISION y *f, 5, j g [ W ASHINGT ON, Q,C,20$33 ~ ' L fG q.i n y March l8, l$-32Y2

lS = ' I'* l OFFICE OF THE SECRETARY Jocket Nos. 50-275 OL

'50-323 OL Lawrence Coe Lanpher, Esq. Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W., Suite 800 Washington, D.C. 20036

Dear Mr. Lanpher:

There are currently pending before the Cc. :.iision petitions filed by Governor Brown and the Joint Intervenors in th's proceeding for review of the Atcmic Safety and Licensing Board's decision in ALA5-544, 13 NRC 903 (June 16, 1981). On March 18, 1932, t. s C: mission declined to grant the petitions for review. 10 CFR 2.755(t)(5). The views of individual Corr.issioners are enclosed. / Sir erely, '/ p,,g ~ al.uel J. :hilkh Secretary :f' the co=ission

Enclosure:

Separate views of Chairman Palladino and Cormissioners Gilinsky, Bradford, Ahearne and Roberts cc: Service List

UNITED STATE.; [*{ y {0%c[ga..j.. NUCLEAR REGULATORY COMMISSION wA:sincien. o.c. 2:sss / March 18,1922 .p-...,j,,* pg.q~ orri:E OF THE SECRETARY Docket flos.:50-275.0L 50-323 OL Jcel R. Reynolds, Esq. J:nn R. Phillips, Esq. Center for Law in the Public Interest 1C951 West Pico Boulevard, 3rd Floor Les Angeles, CA 90064

Dear Messrs. Reynolds and Phillips:

There are currently pending before the Commission petitions filed by Governor Brown and the Joint Intervenors in this pr:ceeding for review of the Atomic Safety and Licensing Board's decision in ALAS-644, 12 f1RC 903 (June 16,1981). On March 18, 1982, the Cc mission declined to grant the petitions for review. 10CFR2.786(b)(5). The views of ir.dividual Comissioners are enclosed. Sin)! rely, f A.q ~9 Samue J. Chi Secretaryofg.he Commission

Enclosure:

Separate views of Chairman Palladino and Comissioners Gilinsky, Bradford, Ahearne and Roberts cc: Service List

SEPARATE VIEWS OF CHAIR"AM PALLADING I would extend.the time for the' Commission to review this Appeal Board' decision on Diablo Canyon seisnicity. I would not make a final decision until the Commission knows more about the results of the Diablo Canyon reverification and has concluded the process with respect to its inquiry about Mr. Newmark, the staff's key expert on the seisnic design of the Diablo Canyon plant. I should say that my inclination, at this time, is not tc review ALAB-644 However, I would prefer to have in hand the results of the matters I have mentioned above before ! make a decision on this matter.

i UNITED STATES OF AMERICA NUCLEAR REGULATCRY CCI1:!ISSION CC::MISSIONERS : Nunzio J. Palladino, Chairman Victor Gilinsky Peter A. Bradford Jchn F. Ahearne Thomas M. Roberts ) In the !!atter of ) ) PACIFIC GAS & ELECTRIC COMPANY ) Docket Mos. 50-275 OL ) 50-323 OL (Oiablo Canyon Nuclear Power ) Plant, Units 1 and 2). ) ) ) CPINION OF COMMISSIONERS GILINSRY AND DRIsDFORO ON CC:'J!ISSION FIVIEW OF ALAB-6 4 4 (DIABLO CA;YCN SEISMIC PROCEEDI:;G) The Commission has had in hand since June 16,1985, the Appeal Scard's decision approving the seismic design of the Diablo Canyon nuclear power plant. The Ecard's decision deals with the = cst important issue in this Operating License proceeding in vieu of the discovery of a nearby earthquake fault after plant construction was well underway, and the subsequent need to redo the seismic design. Normally, the Commission allows itself 30 days te de:ide whether to review an Appeal Board decisien. If the Commissi:n dces not act in that time the decision is nc: taken up for review. In this case, the General Counsel provided the C:=missi:n with a twenty-tuo page memorandum en the legal r. aries cf the Scarf's 3 = decision and, at the Commission's request, the Office of Policy 1 Evaluation, af ter a six-week study involving four consultants,- produced an 89-page analysis of the technical aspects of the decision. After receiving these memoranda, the Commission found itself unable te decide whether to take review. Altogether over a period of nine months, the Commission extended the time for deciding whether to take review thirteen times. This week the last extension was allowed to lapse. The issues in the Appeal Board decision need c be distinguished frem these of the ongoing reverification of the Diablo Canyon seismic design which has received so much attention recently. The Appeal Board decision deals with whether the bases of the seismic design, as formulated by the applicant and approved by the NRC staff and Licensing Board, are adequate. The reverification program assumes the correctness of those bases and i 1coks into whether they were properly applied in the detailed design of the plant structures and equipment. The Appeal Board decision deals with the fundamental " response spectrum" at the site--in effect, the frequency and maximum amplitude of the various oscillations of structures attached te the plant's foundation. These maximum oscillations are calculated en the basis of the agreed-upen maximum earthquake, and all safety-related structures and equipmen: must be designed te withstand them. The Appeal Board deals, in pcr icular, with the adequacy of the new seismic design standarf chcsen af ter :..e I e discovery of the nearby Ecsgri fault, which had net been taken into account in the original design of the plant. The case ,cresents a number of novel prcblems, particularly as the assumed earthquake location is very near the plant, and the choices inescapably involve a gcod deal of judgment. The difficulty the Commission found itself in, as the nine months cf indecision betrays, is that the Appeal Board's decision is not a satisfactory one. On some points it can probably be rescued by dtf ferent reasoning, though even that would nct eliminate the need for review because of'the decision's precedential significance. On at least one point, however, the use of the so-called " tau effect" to permit a substantial across-the-board relaxation of the seismic standard applied to the plant, the Board's reasoning is utterly inadequate and is very likely wrong.

ithout Commission review, not only will questiens remain about the ccrrectness of the Diablo Canyon seismic design, but the Board's decision will stand as an unfortunate precedent which will undermine application of the Commission's regulations on seismic design.

Procedural Background The NRC issued the Ctnstructic.- Permits for Diablo Canycn Units 1 and 2 in 1968 and 1970, respectively. These permits were issued en the assumption that the plants cculd be expected to face, at v.c s t, a 6.75 magn :ude earthquake at a distance cf abou 2:

i. a i 4 miles. In 1971, Hoskins and Griffiths published a paper which established the existence of a fault approximately 3 miles eff-shore of the Diablo Canyon site. The existence of the fault--called the Hosgri fault--was confirmed in a 1974 study. As the plant was largely constructed, this forced a reevaluaticn c f the seismic design at an awkward time. After reanalysis, the applicant, the NRC staff and the ACRS concluded that, with certain specified modifications, the plants 4 could withstand the more severe earth movements which must be i r = assumed as a result of the Hoscri fault discoverv. This follcwed 1 1 a determination by the U.S. Geological Survey that the maximum i j Hosgri fault earthquake against which the plant had to be desianed was one of magnitude 7.5. The applicant and NRC staff 4 did not believe this was the right choice, but apparently 1 j convenience dictated its acceptance for the purposes of the proceeding. Much of the difficulty in this case stems, in our tiew, frcm the formal acceptance of this standard, but the less-than-wholehearted application of it.2 i In the course of the Diablo Canyon C eratinc. License prcceeding, I I the Licensing Board conducted evidentiary hearings en the seismic I issues between December 1978 and February 1979. At the close of j this part of the proceeding, the parties stipulated, and the i scard agreed, that it would be conservative, in view of the 1 l existence of the Hosgri fault, to attribute a magnitude of 7.5 :c i 1 1 the Safe Shutdown Earthquake ("SSE")~. The Licensing 3carf i i i . -- 1

_.-m _g_ o o also fixed the maximum vibratory ground motion that an SSE might induce at the plant site and concluded that the seismic t i reanalysis and redesign were adequate to withstand this SSE.' The Join: Intervenors appealed several aspects of this decision to the Atomic Safety and Licensing Appeal Board, and were joined 4 i in their appeal by Governor Brown, participating as an amicus 4 i curiae. On June 16, 1981, the Appeal Board issued its decision t I affirming the Licensing Board's finding that the Diablo Canyon j clants were adequately designed to withstand a 7.5 magnitude l earthquake on the Hosgri fault. Since that date, the case has been before the Commission awaiting its decisien on whether or i not to take review. a i J { Technical Backcround As stated above, after the discovery of the Ecsgri fault and the i t subsequent analysis..by the U.S. Geological Survey, the parties to i the Diablo Canyon proceeding agreed to an earthquake of magnitude 7.5 on a nearby portion of the fault as the fundamental seismic i j event against uhich the plant would be designed. Since the plant was in large part already constructed at this point, the i reanalysis and redesign understandably did not proceed as they iT would have in a plant yet to be built. Every advantage was taken l l cf slack in safety cargins left in the pre-Hesgri analysis, bcth 1 i n developing the response spectrum and in its application. To 1 cite a couple cf exanples: a larger damping value was used in analyzing structures (7 percent instead cf the earlier 5 i l l . - _... ~.

_s_ a percent), which reduced the effect of ground vibrations on the structures. At the same time, credit was taken for the actual -- "as-built" -- strengths of materials (rather than for the minimum required strengths, as is the usual practice) so that larger vibrations became tolerable. These choices were not improper, but they do add significance to further substantial relaxations in the seismic standards for the plant on the basis of the " tau effect". The point is that these further relaxations ccme on top of a redesign that has already shaved safety margins tc the extent permitted in the tegulations. Probably most important along these lines was the choice of the earthquake record used in developing the response spectrum, and the manner in which that record was used. Because no record was available from a station close to a 7.5 earthquake, the applicant used the seismic record,*known as the Paccima Dam record, frc= a recording station near the center of a 6.5 earthquake (the 1971 San Fernando Valley earthquake). This record could plausibly be taken to represent a larger magnitude earthquake, in particular because it included the largest horizontal acceleration recorded up to that time, about 1.2 g. Nevertheless, the Beard's handling of this issue is" unsatisfactory. As the Cc= mission's Office of Policy Evaluation put it: "It is not clear, however, from the Boards' records if the Pacoima Dam record in the frequency range of interest (1-10 R:) represents a deviation frc. that expected for a 6.5 ::

_7_ earthquake. Most of the testimon*, on Pacoima Dam centered on a frequency range of little practical interest (i.e., near 33 H ) regarding excitation of structures important te safety. We fcund no supporting statement on the record which indicated that the Pacoima Der, record substantiall; exceeded that expected for a 6.5 M earthquake in the frequency range of 1-10 Hz. USGS Circulab'i72 7).7) indicated that in the frequency range of 1-10 H:, the Pacoima Dam record closely resembled what one would expect for a 6.5 M earthquake."5 Which brings us to the final point, that on tcp of all this crimming, the Board permitted a further substantial reduction, =cre-or-less across the board, in the respense spectrum. " Tau Effect" The " tau effect",_ defined by Dr. Nathan Neumark, the NRC staff censultant, is used to describe the filtering effect that icrge rigid foundations have on the motion imparted to the building's structure during an earthquake. Newmark's estimate cf the effect was used to justify a reduction in the respense spectrur for each cf the important structures in the reanalysis of Diablo Canycn. Newmark's analysis for the reactor containment reduced the acceleration response spectrum by abcu 20 percent ever the 6 frequencies of interest.

_g_ I. reading of both the Appeal and Licensing Boards' decisions shows an almost total reliance on the cpinions of Newmark te ustify the tau effect. Newmark in turn apparently relied heavily on the work of Yamahara. Yamahara's work dealt largely with an odd-shaped building quite unlike any of the structures at the Diablo Canyon plant and with earthquakes well below the magnitudes considered at the Diablo Canyon site. Neither cf these discrepancies 4are explained in either Board decision. The Licensing Board's justification sounds almost mystical: "There is ample evidence of the excellent performance of large building f:undations in earthquakes. Tau is a manifestation of this."I The Appeal Board responded to criticism of Dr. Neumark by stating: " Simply in light of his repeated references to Dr. Yamahara's work, only a very crabbed reading cf Dr. Newmark's testimony could assume that he did not appreciate tau in all its ramifications."8 What seems less clear is whe her either Scard - had any idea what it was talking about. f Tnat there is some effect of this kind is plausible, even likely; that the effect is as large as claimed by the applicant and staff is merely conjecture. Here is the way the Cennission's Office of Felicy Evaluation describes the situatica: " Based on the record, it appears that a phencmenen e.:.s:s which at times limits the damage te structures in the. ear field during an earthquake. Hesever, we ". ave nc: been ab'e to find an empirical er analytical approach which provides

justification as to why the tau effect should be calculated in one specific manner over another. Analyzed or existing data are so sparse that the actual reason for the cbserved effect may still not have been reccgnized within the engineering community. Except for the judgment of Drs. Blume and Newmark, there is no evidence to demonstrate an ability to predict tau effects over a range of earthquake magnitudes, structural configurations, and site conditions." Tne fact is that the tau effect has not been used in any cther nuclear plant analysis. To our knowledge, it has net been used in the design of any cther large building. Ccmparison of Response Spectra With the changes and adjustments permitted by the Ecard it turns -cut that the post-Hosgri seismic response spectrum does not in all respects represent a more severe seismic standard than the ene used before the discovery of the Hosgri fault. As the j accompanying diagram illustrates, in the frequency range between 5 and 10 hertz (cycles per second), a ranse cf particular interest in the analysis of the containment huilding surrcunding the reactor, the two response spectra are qud te close.10 For part of this range, in fact, the cid spe rucc :h:ws a higher respense. In other words, for that part of the range the

riginal design ccnditions were rcre demanding than the new cnes mpeced after the disecvery of the Hesgri fault.

This neu

.0-e spectrum is the basis of the engineering reanalysis and ultimately determined the extent to which the containment wasto be modified.

Joe surprisingly, in view cf the above, caly minor changes were required in this area.

Precedential Sicnificance ~ ' ' 07he Commission decision not to take review, in effect, places the Ccmmission's stamp of approval on the Appeal Scard's decision. The Board's reasoning on the " tau effect", for example, may be cited in future cases when an applicant er licensee would ctherwise have difficulty in complying with cur regulations. Cr the tau effect could be used to compensate fer deficiencies discovered in the design of completed plants. This would be a significant weakening of past agency practice. Altogether, we cannot escape the impressien that the Ccemission is declining review not because the cpinien is essentially scund, but because it is unsound and the prospcct cf reviewing it is so unsettling.

+ a NOTES 1. We would note that one of the cutside consultants retained by the Commission was also acting as a censultant en seismic issues to the applicant in the Summer case. We would have preferred to disqualify this expert in order to avoid any dCtual or apparent Ccnflict of interest. 2. No hearings were held when the hosgri fault was discovered. The persistence of litigation over these issues to this day suggests that it would have been wise policy, as well as good law, to reopen the construction permit hearing at tha: time. 3. The Commission's regulations, 10 CFR Part 100, Appendix A, define the " Safe Shutdown Earthquake" as being "that earthquake which is based upon an evaluation of the' maximum earthquake potential considering the regicnal and local geology and seismology and specific characteristics of local subsurface. material. It is that earthquake which produces the maximum vibratory ground motion fer which certain structures, systems, and components are designed to remain functional." ~ The specific structures, systems, and components which must remain functional are those which are necessary to assure: " (1) The integrity of the reactor ecclant pressure boundary. (2) The capability to shut down the reacter and maintain it in a safe shutdcwn condition, or (3) The ccpability to prevent or mitigate the consequences of a:cidents which could result in potential off-site exposures comparable te the guideline exposures" of Part 100. 4. In the Matter of Pacific Ccs and Electric Company (Diabic Canyon Nuclear Power Plant (Units 1 and 2)), 10 NRC 453 (1979). 5. Memorandum to the Commissioners from Forrest Remick,

Subject:

Diablo Canyon Design, dated Neverber 12, 1981 with enclosure. 6. ALAB-644, p. 114, footnote 266. 7. In the !!atter of Pacific Gas and Electric Ccmpany (Diablo Canyon Nuclear Power Plant (Units 1 and 2)), 10 NRC 453, 495 (1979). 8. ALAB-644, page 124. 9. Itemorandum to the Commissioners fr:m Terrest Remick, Sub]ect: Diablo Canycn Design, dated Nevember 10, 1951 w th enclosure. _J

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L 4: - -__ 4 OPINION OF COMMISSIONER AHEARNE ON COI.ISSION REVIEW OF ALAB-644 (DIABLO CANYON SEISMIC PROCEEDING) Commissioriers Gilinsky and Bradford are releasing their recently written opinion on Commission review of this case, and describe the Commission as being unable to act on it. In the interest of a more complete picture I am also releasing my opinion, distributed to my fellow Commissioners three months ago. The issue before the Commission was whether to taice review of the Appeal Board decision (ALAB-644). After reviewing the decision, and the staff memoranda referred to by Commissioners Gilinsky and Bradford (the last being the Office of Policy Evaluation memorandum of November 5th), I sent out the following on December 9, 1981: t ..r -,,,, - = - e----.--

I would not take review and I do not believe the record needs 00 be reopened again. However, the reader should understand tnree points about not taking review: (1) Not taking review of ALAS-544 does not in any way make a judgment concerning my posi tion or the Commission's position wi th respect to the latest problems that have arisen ~ a t the Diablo Canycn plant, which led to the recent suspension of the low power license. (2) Not taking review.does not indicate tha; ei ther I or the Commission believe issues regarcing earthcuake estimates and seismic design are unimportant. B, ecause of their significance for Diablo Canyon, the current problems were considered sufficiently important to lead to license suspension. ~ (3) Not ta ki n g review is not synonymous with not examining. To reach the conclusion on whether or not to take review, I di d examine ALAB-644, the filings of all parties c the Commission on ALAB-644, and extensive staff reviews prepared by the Office of General Counsel and the Office of Policy Evaluation. I also reviewed USGS Circular 672 and USGS Open .ile Repor-51-355. And, finally, I reviewed the :iablo Canyon 5ER Supplement No. 5. l . : =* = *;**.T:::..T.. '? M C = * *' - - - ^

l I reached the following conciusions: (1) There is no real question that magnitucs 7.5 is large enough for the SSE for Diablo Canyon. There is some ques tion that it may be too larga. This qu es ti on' i s no t irrelevant, although M7.5 is accepted by the NRC staff, because many Of the other arguments would diminish or disappear if one were to conclude, as did at leas t one Scard-called wi tn e s s, that a lower value earthcuake w:uld be more appropria te. (2) There are several engineari.ng issues adcressed at length here for the first time in an NR iicensing case, making the decision quite importan: because it may establish precedents. (3) There are several important issues relating to earthquake analysis. In my opinion the only remaining significa.n engineering issue is what modification is appropriate in predicting a building's response to earthquakes because the building is a large rigid object. Some eff ect is plausible. The Board used an analogy to waves aff ecting. a large boat differently than a string of small boats. Probably there are two effects involved: (1) When the wavelength of a signal is small with ~ res pect to' the si ze of an c bject which the signal perturbs, the resul ting eff ect is modi fied f rom that when the waveleng:h is ccmparable :: the

a object size. The resulting eff ect is an integration because the body do'es not respend to ea ch individual wave. This is the basic phenomenon which :he Board's analogy addresses. This effect has little significance bere since the important wavelengths (for the 1-10 Hz range) are several huncred to several thousand feet, i.e., ccapa ra bl e te or larger than the plant. (2) When a large object is perturbed by many signals, arriving so that the accelerations vary both in magnitude and frequency, and perhaps in cirection, the perturbing signals are inccherent. The resulting effect upon the building is a smoothing or an averaging of the var'ious accelerations. Thus the 'early references in the literature by Yamahara, Ambraseys, and Scanlan refer to an average acceleration over the width of the foundation (SEp. No. 5, p. C-10). In SER No. 5 Newma rk used the " travel" time across an "eff ective width" for the building by taking the appropriate distance to be the squa.re root of the area. He then averaged the spectrum over this time to deve. lop his tau reduction factor. t The effect is plausible and the records cited from the Hollywood Storage Building show the eff ect exists for the frecuencies of interest. The two important cuestiens are

xht t magni tude is the effect and should tha N?.C allow for it in determining if our regulations are me:. i If the technique is explainable, defensible, and reproducible, then I believe the NRC should allow for it. This technique ap; ears to be sufficiently new and of limited applicability (enly to large buildings with rigid foundations, such as nuclear plants) that it is not widely known. In addition, the data base is very limited. However, all earthquake analysis suffers f rom a limited data base, particularly analyses for very large earthquakes and in the near field (bc h represen.tative of Diablo Canyon). These unfamiliar with seismic analysis may be surprised to see that the model used for the containment building, which contains the reactor and is a cylinder ab:vt 150 feet in diameter and 210 feet high, is a stick. The improved model us es weights distributed along the stick and examines the response of the weighted stick as the base shakes. Dr. Newmark modified the input to this model by using a reduction to incorporate effects of building size at the higher f requencies. The approach is reasonable, ali seismic data in this area is weak, and in the end the decision will be based upon en.gineering judgment. On balance, I-su; port Dr. N ewm a'r k.

The third area, that of earthquake analysis, ha d many is sues, but the possibly trovo7ing one was whether the Pacoima Dam spectrum can be used to model the nea r field of a.. earthquake of ma gnitude 7. 5. The earthquake regis:ered at Pa:cima Dam is estimated to be of magnitude 6.5-6.6. Dr. Newmark and others argued that the recording spot was on a rocky ridge which led to a much stronger signal than would be true of a less unique location. Dr. Newmark found the Pacoima Dam spectrum was well fit by a design spectrum appropriate to 0.75g, even though the measurement had a peak of 1.25g, the highest' horizontal acceleration ever recorded. In SEF No. 5 Dr. Newmark argued that in the near field of an earthquake the peak acceleration is not a reasonable basis t: draw a design spectrum and it is more appropriate to mat:h the overall s'pectrum. Dr. Boore, et al., in US'GS Circular 672 adopted the 1.25g as appropriate to the maximum considered amplitude ( hey were making estimates for the Trans-Alaska Pipe Line, which traverses regions of seismicity up to magnitude 5.5). Tcking 1.25g as the maximum is consistent wi th the concep t of magnitude sa turation. In this particular case, they would be using 1.259 as the maximum appropria:e :: the l arges 7. earthqua ke being co nsi dered. The OSGS reduced the measured spectrum to get an es timate cf the spe : rum for the

a 1 magnitude 6.5g earthcuake tha: triggered :he Fac-ita Car re:ord. They argued that Hewmark and Hall (the :' asic raference f:r establishing response spectra) overes:ima tes the response i a::ve 8 Hz. By removing,the components above 9 h:, the T

a. hors modified the Pacoima Dam record to get

0. 3g as the a;;ropriate maximum horizontal acceleration for a 5.5 ma;nitude earthquake.

They then i n t,grp.c.la tg.be twean 0. 99 for M6.5 t a.d 1.25g for M8.5 to get 1.lg for M7.5. Soore, =1 a l., ref ected the use of the Pacoima Dam spectrum as a.nc:olous i be:ause "[t]he au thors a re no t aware of any inves tiga tior.s cf possible side eff ects that conclusively demons trate an an:molous amplification (grea ter than 25-53 percer t) of recorded motion in the frequency range 1-10 Herz." (Emphasis adced)(P. 7, Circular 672) Finally, Open File Report 81-3 65 by Joyner, et al., propetes a new equation relating maximum horizontal acceleration and ' maximum horizontal velocity to earthquake magnitude and distance to the surface projection of the fault rus ure, c Unfortunately, like all available analyses, this report is based on data outside the near field of large earthquakes. The authors sta te: "The data set contains no recordings a; rock sites with d less than 8 kilometers for earthquakes wi th M grea ter than 6. 0, and caution is i indicated i. applying equa tions, to rock sites. at shorter dis ta nces for ea --hquakas of '.arcer magnitude." (F. 15) Diablo Canyon is a r::k si a wi:n d approxima tely 5.5 kiicmeters and, for desigr p urpc s as, 1 l ,.,..n-,-=

~. c:nsiders an M of 7.5, i.e., exactly the type of site outside the da ta set, for which the authors indica ted cau:icn snould be used. Dr.:e again, this area is one in which data is poor and ex:erts disagree. Dr. Newmark's arguments are based on ma tching the significant portions of the spectrum, and rest his professional judgment. The criticisms of a:cepting on tne Newmark position are also judgments, as shown :y the qualifications in the Boore and Joyner reports. I come down on the side of Dr. Newmark. I agree that seismic design 'is a major issue relating to safe operation of the Diablo Canyon Nuclear Fewer.:lant. Mcwever, I do not believe another full-scale adjudi:atory review will add any additional light to the extensive reviews al ready done. Controversy in Diablo Canyon centers on the validity of judgments made by experts. An extensive record documents a wide range of expert opinion. Sc long as the Commission empowers Boards to sit for us to examine such disputed issues as the seismic design for Diablo Canyon, our dec ision to take review of a Board's decision should be _ based on whether there are any basic policy issues which be addressed or any serious errors. must The basic question we ~have before us is whether an existing. piant redesigned to some extent to withs tand the predicted

.~o eff ects of a large earthquake from a nearby facit is adequately c esi gned. We are not addressing what should be the design criteria for new plants nor are we addressing what l should be t the design criteria for this plant were it seeking a construction permit. The degree of conservatism tha: the Commission imposes must take into consideration a greater level of realistic estimates with regard to modificatiens or acceptance cf an existing plant than for projects n:t yet begun. With the help of the Commission staff., the Commission has examined the seismic issues. Thi s exami..a tion wa s neces s a ry if we were to.make an informed assessmen:. I agree in ~ general with the Appeal Board decision a..d I have not identified any serious errors. Th e r e f o r,e, I do not believe the Commission should take review. s l

~ o / SEPARATE V!C! 0F CO:UISSICt:EF. POSEF.TS I vote against review of ALAB-642 by-the Cetnissicn based or ny evalua-tion of the opinion and of the varices analyses prepared to assist the Ccnmission in its decision by the Office of General Counsel, the Office of Policy Evaluation, and by seismic consultants specially hired by the Commission for this task. All of the groups listed above recoccended that the Commission not review ALAB-644. L'nder 10 CFP, ! 2.786(b), the Commission may not review ALAE-6dd simply because it is intrigued by the technical issues raised or because it thinks its ur.derstanding cf the technical issues is nore sochisticated than the Appeal Ecard's under-standing. Similarly, Comnission review is not to be undertaker sinply to correct the factual record in the proceeding. Rather, Connissier review should be undertaken when the Appeal Board has clearly er-reneously decided factual issues or incorrectly decided important legal or policy issues. I.do not believe this to be the case here. I agree with Comnissioner Ahearne's technical analyses of the issues raised in the opinion. Beyond that, I wish to respond to scme cf the nisleading statenents made in the dissent. First, with regard to the allegation that the length cf tire between issuance cf ALAE-622 and issuance of this Order reveals that the Appeal Ecard's decision is u ns a *.i s f ac to ry. I note that I vcted not te review ALAE-Sad cr ':cvercer 23, 1981, several weeks after receipt of OPE's last analysis cf the ceinion. Second, with regard to 'he acceptability of assuring a cag-nituce 7.5 earthcuake en t e Fcsgri Fault, ! note tra-f.e figure <a s h

- - -. = 2 ~o described as " grossly conservative"1/ during the hearing ard that, on appeal.even the Joint Intervenors agreed that this figure was "ac-ceptably conservative."2/ Third, with regard to the Appeal and Licensing Board's reliance on the expert testinony cf Dr. Nathan Newmark, I note that, at the tine of his 4 death, Dr. Newmark was considered the preeminent authority on seismic engineering and seismology in this country. The technical issues resolved by the Boards in this case were not simply fact cuestions whose answers were within the grasp of educated laynen. Rather, resolution of these issues required the engineering judgn' nt of experts who had vast e i experience not only in the history of earthcuakes and how earthouakes move but also in how an earthquake transmits erergy to a building and 1 how that building, in turn, responds. Dr. Newmark's great depth of experience in every facet of the required analysis is precisely why the Boards properly relied on his testinony. Firally, with regard to the allegation that the Ccanission declined to review ALAB-644 because it believes the decision is unsound and because i to reveal that would be " unsettling," I wish to state that not cnly is that not the basis for the Commission's decisien but that the crocess undertaken to deternine whether to review ALAS-6ad revealed cuite the i cont ra ry. The history of the Diablo Canycr proceeding reveals a -1/ Pacific Gas and Electric Cc. (Diablo Canycn Uuclear Fewer Plant, Units 1 and 2), LBP-79-26, 10 MRC 453, 480 (1979). 1 ?/ Facific Gas and Electric Co. (Diablo Canyon.'iuclear ocwer Piart, Units 1 and 21, ALAS-6a",13 'GC 903, 913 (1981). l

2 willingness to eyenine and reexamine the design basis of this plar.t. Evidentiary hearings on the seismic issues in the Diablo Canyon cperat-irg license preceeding began in Decerber of 1972.1'/ In its decision of September,1979, the Licensing Ecard found that the plant was adecuately designed tn withstand any earthcuake that could reesonably be ex-pected.4/ The Licensing Board found that the Staff's seismic review was the cost extensive ever undertaken and that the Applicant's review was extraordinarily thorough.5/ On October 15, 1979, a large earthquake struck California's Imperial Valley, approximately 250 miles southeast of the Diablo Canyon site. The Appeal Board reopened the record and took evidence itself. At that trial, 17 expert witnesses appeared, includirg two ACRS consultants called by the Appeal Gcard.5/ Subsecuer to the Appeal Board's decision, the Ccanission hired its own seismic consultants. This lengthy indepth checking and rechecking cf the bases of the seismic design hardly reveals fear on the part of the Commission to scrutinize the numbers. 3/ Pacific Gas and Electric Co. (Diablo Canyon tJuclear Power Plant, ~ Units 1 and 2), LEP-79-26, 10 NRC 45?, d'58 (1979). 4/ !d. at 507 5/ Id. 5/ Pacific Gas agd Electric CO. (Diabic Canyon Nuclear ?o.er 713r:, Units I and E!, ALA?-6aa, 13 NRC 903. 912 (1951'.}}

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