ML16340C357

Forwards Clarification on Correlation Between Contractor Performed Work & Independent Samples Re Seismic Reverification Program & Criteria for Addl Verification Re Deficiencies in QA Review & Independent Calculations

ML16340C357
Person / Time
Site:	Diablo Canyon
Issue date:	02/27/1982
From:	Cloud R ROBERT L. CLOUD ASSOCIATES, INC.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML16340C358	List: ML16340C357 ML16340C359 ML16340C431 ML16340C432 ML17083A989 ML19264C781 ML19264C782
References
P-105-4, NUDOCS 8203020531
Download: ML16340C357 (24)

Text

REGULATORY

<FORMA'TION DISTRIBUTION S EM (RIDS)

ACCESSION NBR:8203020531 DOC ~ DATE: 82/02/27 NOTARIZED:.,NO DOCKET FACIL:50-275 Diablo Canyon Nuclear 'Power "Planti Unit 1i Pacific Ga 05000275

. 50-3?3 Diablo Canyon Nuclear Power Planti Unit 2i Pacific Ga 05000323 AUTH BYNAME AUTHOR AF F ILIATION, CLOUDiR ~ LE Ro>ert Ls Cloud Associatesi Inc.

RECIP ~ NAME RECIPIENT AFFILIATION DENTONiH ~ Rs Office of Nuclear Reactor Regulationi Director

SUBJECT:

Forwards clarification on correlation between contractor performed work 8 independent samples re seismic

reverification program L criteria for addi verification re deficiencies in QA review 8 independent calculations'ISTRIBUTION CODE: Boois COPIES RECEIVED:,LTR L ENCL L SIZE:LL TITLE: PSAR/FSAR AMDTS and Related Carr espondence NOTES:J Hanchett 1cy PDR Documents'PDR 2cys PDR Documents~

J Hanchett 1cy PDR Documents'PDR 2cys PDR Documents, 05000275 05000323 REC IP IENT ID CODE/NAME ACTION:

A/D LICENSNG LIC BR P3 LA INTERNAL: ELD IE/DEP/EPDB 35 MPA NRR/DE/EQB 13 NRR/DE/HGEB 30 NRR/DE/MTEB 17 NRR/DE/SAB 24 NRR/DHFS/HFE840 NRR/DHFS/OLB 34 NRR/DS I/AEB 26 NRR/DS I/CPB 10 NRR/DSI/ETS8 12 NRR/DS I/PSB 19

/RSB 23 REG F IL 04 EXTERNALS ACRS FEMA REP 0 IV 39 NRC,PDR 0?

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ROBERT L. CLOUD ASSOCIATES, INC.

I25 UNIVERSITYAVENUE BERKELEY, CALIFORNIA94710 (415) 84I 9296 P l05-4 February 27, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Ave.

Bethesda, Maryland 20114

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Dear Mr. Denton,

Two issues raised during the February 3,

1982 meeting with the NRC staff require additional clarification.

Six seismic service-safety related contractors have been identified to date:

EDS Wyle Cygna (EES)

URS/Blume Harding-Lawson Anco In addition to the QA review, the independent calculations, which cut across the seismic design'hain, encompass work performed by each of these contractors.

The enclosed

document, "Seismic Reverification Program-RLCA-Sample Selection" gives a one to one correlation between the con-tractor performed work and the in'dependent samples.

Additional verification is required if deficiencies are found in either the QA review or the independent calcula-tions.

The basis and approach for this'dditional. verif'ica-tion is discussed in'he enclosed document:

"RLCA-General Criteria for Addit'ional.Verification".

In. addition, four examples of additional verification are given.

It is hoped that these two documents will help to clarify the two is'sues raised "at the Februa'ry 3,

1982 meeting.

You s g~t R,

. Clo d RLC Ihcc Enclo sui e EI2030Z0531" 820227

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I ROBERT L.

CLOUD ASSOCIATES, INC.

GENERAL CRITERIA FOR ADDITIONALVERIFICATION 1.0 Introduction The Seismic Verification Program is based upon the following steps:

1.

Performance of Independent Calculations for a sam-ple of buildings, piping and equipment 2.

Review of Quality Assurance programs for adequacy and implementation 3.

Performance of additional verification if deficien-cies are found in the QA review or the Independent Calculations The basis and approach for the third step, additional veri-fication, is discussed in the following paragraphs.

1l

2.0 Additional Verification Resulting from Quality Assurance Reviews Deficiencies in the Quality Assurance program adequacy or imple-mentation of PGGE or service related contractors will be cause for additional technical verification of design work.

This review will cover the technical work done under the deficient QA program.

QA deficiencies are reported as findings or observations.

For present purposes these are defined as:

~Findin a nonconformance with respect to the Quality Assurance Program adequacy or implementation that re-quires corrective action due to potential impact on quality.

Observation:

a noncomformance which does not require corrective action.

This nonconformance does not have an apparent impact on quality.

Additional technical verification of the subject design work will be performed for all Findings as defined above (Observations will not require additional verification).

2.1 Criteria Depending upon the nature of the design work done under inadequate Quality Assurance, one of the following approaches will be taken.

2.1.1 Design Review

~ Technical work of a qualitative nature will verified by review, by means of the following steps,

t

-Define scope of work

-Establish an independent review program

-Perform review to establish whether work is satisfactory based upon state-of-the-art methods applicable to the ori-ginal design work

-Write review report and draw conclusions as to whether work is satisfactory or not 2.1.2 Independent Calculations Technical work of a quantitative nature will be verified by means of independent calculations.

The following steps will be followed,

-Establish scope of work.

-Develop a verification program based upon independent calculation of a suitable sample of the work, based upon state-of-the-art methods applicable to the ori-ginal design work.

-Perform verification program to establish whether work is satisfactory.

-Write verification report 2.1.3 Example An example of this verification that covers both qualitative and quantitative review is given herein as Example 2.1.3-1.

l

3.0 Additional Verification Resulting from Independent Calculation Program The independent calculation program entails four categories of verification:

1. -Field inspection to determine whether the as-installed configuration conforms to the design configuration

2. -Independent calculations to determine the correctness of the design calculations

3. -Verification that applicable seismic design input was employed

4. -In certain cases, design methodology is separately verified Deficiencies identified by any of the above will result in additional verification.

3.1 Deficiencies resulting from field inspection The objective of performing additional verification as a

result of identified deficiencies in the as-built config-urations will be to discover the extent of such deficiencies.

One of the two following methods will be used for such addi-tional verification.

-Repeated field inspections of additional sample con-figurations

-Establish the cause or reason for the discrepancy; then trace down other discrepancies that could possibly

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result from such cause or reason (see Example 3.1.-1).

3.2 Deficiencies resulting from the independent calculation program The objective of performing additional verification as a re-sult of identified calculational deficiencies will be to discover the extent of such deficiencies.

This will be accom-plished by one of the following means.

-Performance of additional independent calculations 4

until the reasons for discrepancies are understood and a clear basis exists for all remaining safety-related discrepancies to be remedied.

-Determination of the cause or reason for the discrepancy; then trace down other discrepancies that result from such cause or reason (see Example 3.2-1).

3.3 Deficiencies resulting from inapplicable seismic input The objective of performing additional verification as a

result of the use of inapplicable seismic input will be to discover the extent and significance of such deficiencies.

This will be accomplished by one of the following means

-Determination of the cause or reason for the discrepancy; then trace down other discrepancies that result from such cause or reason (see Example 3.3-1).

-Performance of additional checking of seismic inputs.

3.4 Deficiencies in design methodology The objective additional verification will be to identify and correct all deficiencies in design that result from faulty methodology.

This will be accomplished by two me-

thods,

-a critique of the methodology in question will be issued

-when the methodology has been improved or justified, the design work will be re-verified relative to the new or revised design methods.

Example 2.1.3-1 Deficiency:

Harding-Lawson QA Report by Reedy contained three Findings (QA Findings

968, 969 and 970)

Additional Verification:

RLCA and Robert McNeillare currently assessing the scope of the Harding-Lawson work.

A program will be developed to verify this by design review, inde-pendent calculations or a combination of the two Example 3.1-1 Deficiency:

An ambiguous design note led to a communication problem between engineering and the field concerning'dditional tubing weight on raceway supports (EOI 910)

Additional Verification:

PGandE has set up a program to examine all raceway supports with attached tubing.

Pre-liminary indications show attached tubing on about 100 of the 20,000 class IE raceway supports

r

Example 3.2-1 Deficiency:

The buckling of the of the tank skirt and sloshing loads on the roof were not evaluated by PGandE for the Boric Acid Tank (EOI 1030).

Additional Verification:

RLCA will verify that other Hosgri tanks are not affected by the above items.

Example 3.3-1 Deficiency.:

Nine of twenty electrical raceway support calcu-lations checked for the Preliminary Report used inappli-cable spectra (EOI 983).

Additional Verification:

PGandE is currently reviewing all the class IE electrical raceway support calculations.

RLCA will select a sample of these re-done supports for inde-pendent calculations to close out EOI 983.

Pr ject anager/Date Approved 2 zzg~

s Seismic Reverification Program Robert L. Cloud, Associates Sample Selection PIPING RLCA Anal sis Number PGandE Anal sis Number PGandE or Contractor A~nal sis

100,

'01 102 103 104

. 105 106 107

~

108

~

109

~

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8-33 8-21 8-24 8-25 8-31 8-3 4-2 4-3 3-5 4A-5 8-34 2-17 EES EES EES PGandE EES EES EES EES EES

'GandE EES PGandE Unknown at present

4

EQUIPMENT Item PGandE or Contractor Anal sis CCW Hx CCW Pump Aux SW Pump Turbine Driven Aux FW Pump Diesel-Engine Starting Air Receiver Tank Diesel-Engine Oil Priming Tank Anco

& PGandE Manufacturer

& PGandE Manufacturer

& PGandE Manufacturer

& PGandE Anco

& PGandE PGandE Boric Acid Tank Main Annunciator Cabinent Hot Shutdown Remote Control Panel HVAC Supply Fan S-31 HVAC Damper 7A

~

Valve FCV-41 Valve FCU-95 7 Groups by Test PGandE Wyle

&, PGandE Manufacturer

& PGandE EDS Nuclear EDS Nuclear EDS Nuclear EDS Nuclear Wyle Auxiliary Building Item Dynamic Analysis PGandE Contractor Anal sis URS J.

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