ML20211C008
| ML20211C008 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Diablo Canyon |
| Issue date: | 09/09/1982 |
| From: | Georgiou B CALIFORNIA, STATE OF |
| To: | |
| Shared Package | |
| ML20209B155 | List:
|
| References | |
| FOIA-86-151 NUDOCS 8610210248 | |
| Download: ML20211C008 (32) | |
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Statement of Byron S. Georgiou Legal Af f airs Secretary to the Governor 4
Concerning Saf ety Implica tions of Deficiencies Disclosed at the Diablo Canyon Nuclear Power Plant September 9, 1982
' We welcome this opportunity to meet again with the NRC Staf f for the purpose of addressing the safety implications of the design and construction deficiencies disclosed at the Diablo Canyon plant-and the ac tivitics underway to correct these deficiencies.
Several significant events have. occurred since our. meeting in San Francisco last February.
These. indicate a f ar wider spectrum of problems at Diablo Canyon than was suspected during the early months following the NRC's suspension of PG&E's low power license.
First, the blunt conclusion of the Reedy Report released last March documented that for the technical areas studied, PG&E had no quality assurance program.
Second, the NRC Region V Staf f recommended last March that 'the Diablo Canyon design verification program be expan ded to include an assessment of quality assurance for certain construction activities as well. 8610210248 860930 PDR FOIA HOLMESB6-151 PDR
Third, last June, the Brookhaven National Laboratory reportal several deficiencies in the Diablo Canyon design process that could have generic ~ implications for the plant.
For these rea' sons we are 'here today to review basic questions about the safety of the Diablo Canyon plant and to encourage the Staff to move aggressively in seeking the answers to these questions both f rom those perf orming the verificat' on program and, even more i
importantly through the Staff 's own technical resources, including the Brookhaven National Laboratory.
In addition to the technical recommendations that will be made by Mr. Eubbard and Dr. Rosette, I ask that Staff take action concie tent '. ith the following points.
(1)
PG&E has established an unrealistic schedule for cenpleting the verification program and for seeking a Commission decision un whether its suspended license should be issued.
Since PG&E's license was lifted 10 months ago, the range of flaws at Diablo Canyon has widened while the number of flaws has increased.
Given the multiplicity of errors and the large numbers of unanswered questions, PG& E's proposed November 30 completion date is patently unreasonable and should be discarded by the NRC as an artificially derived scheduling tool.
PG&E's own preferred schedule for the
" independent" verification program should have no influence whatsoever on those performing that program.
Indeed, no decision should be i
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entertained by the NRC on whether to issue fuel loading and low power -licenses unless all safety questions '- including those raised by the Reedy and Brookhaven repor ts - --have been fttlly and completely resolved.
(2)
The Staff should perform an evaluation to determine whether the scope and content of the original verification program established by the Commission last November 19 is adequate
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now in light of the drastically changed scope, number, a nd severity of flaws discovered at Diablo Canyon.
We must recall J
that when the Commission acted in November, there were 14 known errors.
Now the flaws exceed ~200, with clear implications of generic significance for the plant.
If anything, PG&E should develop a program to search out every important ' safety error in the plant, rather than promoting an artificial schedule for premature NRC approval of an operating license for the plant.
(3)
The Staf f should reject outright any PG&E ef fort to obtai a fuel loading license before both Phase I and Phase II of 'the verification program are completed.
In light of the many flaws
. disclosed to date in Phase I, there is every reason to expect that Pha se II also will reveal errors, some of which may have further generic saf ety implications.
For these reasons, we continue to believe tha t the dichotomy between Phase I and Phase II is I
ar tif icial and therefore unsound.
It follows that it also would g
,,s.
r compromise saf ety to fragment Phase I itself so as to rush PG&E's date for a fuel loading license.
I wish especially to
' hig hlig ht that we believe it to be inappropriate for Teledyne - -
which has been cast in the sensitive and critical role of
~
" independent auditor" -- to be formulating its work schedu.le to serve PG& E's unreasonable f uel load schedule.
Such appears to be the case from the dialogue at the Staff's September 1 meeting with PG&E Teledyne should te sensitive to the process through which 'it was selected as " independent" auditor.
It should perceive' its role -- and act its role -- as working f or the public interest alone, no t PG& E 4.
The Staff should evaluate whether the format and procedure of t2 verification program are valid to provide a-basis for public confid-ence in that program and in the credibility of its findings and reports.
In ' p ar ticular, since last November when the format and procedure v.ere established, PG&E has retained Bechtel to serve as project manager and to play a. major role in the. current procesr.
There are relationships established now between PG&E and Bechtel, and between the PG&E/Bechtel team 'and the verification program reviewers, which should be identified and eva,1uated by the staff in light of the purpose and intent of the Commission's Movember 19 Order.
For example, on September 1, PG&E announced' that it would study certain construction activities and that Tcledyne had agreed to perform the work.
This apparent unila teral _____- _-__
a modifica tion - of the approved verification program, ' determined
, in an agreement between the " independent" auditor ard PG&E, was effected without' involvement of the Staff, the Governor, or the joint intervenors, as should be the case.
(5) The prolif eration of cryptically-written reports by the verification program reviewers has made it impossible for
.the Staf f or any other party to understand the findings of such reviewers or the causes and.' implications of those findings.
The verification program has beccme so encumbered with non-substantive papeiwork that it is dif ficult-to discern whether the fundamental question of whether Diablo Canyon is saf e is actually being addressed.
The Staff should take action to correct the current non-substantive repor ting system.
In this regard we commend the Staff for its pursuit at the September 1 meeting of staig htf orward~ and comprehensive answers f rom PG& E to some of the basic questions of saf ety which so deeply af f ect the public.
In conclu sion, we consider it of utmost importance tha t the root cause or causes of the prolif era ting flaws at Diablo Canyon be clearly identified and their ef f ects and implications on saf ety be thoroughly evaluated by the NRC Staff itself.
The Commission's order explicitly required the identification of such roo t causes.
The plain f act is that today there is even more reason to question the saf ety of the plant than there was when PG&E's license was suspended last November.
Not only have scores of additional errors been uncovered, but new uncertainties about PG&E's design and construction programs have arisen.
The NRC staff should.(Asure that the full significance of these uncertainties is not overlooked as a result of' either cursory analysis or PG&E's desire to rush ma tters forward to a-premature decision on whether to license-the plant...
r J
V
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PRESENTATION OF RICHARD B. HUEBARD TECHNICAL CONSULTAllT TO GOVERNOR EDMUND G. BR01'N, JR.
CONCERNING DIABLO CANYON REVERIFICATION PROGRAM 10 PICS TO EE ADDRESSED.
o SIGNIFICANT EREAKDOWNS IN PG&E'S MANAGEMENT CONTROL SYSTEI'.S FOR DESIGN AND SITE ACTIVITIES FOR E0TH SEISMIC AND NON-SEISMIC SAFETY FEATURES HAVE BEEN DISCLOSED SINCE PG&E'S LICENSE WAS SUSPENDED.
e TIlE PROPOSED TELEDY!lE PHASE II REVERIFICATION PROGRAM FAILS TO PROPERLY ADDRESS NUMEROUS DESIGN AND CONSTRUCTION ACTIVITIES IMPORTANT TO SAFETY AT DIABLO CANYOil, e
THE PROPOSED PGSE/EECHTEL INTERNAL CORRECTIVE ACTION PROGRAil IS ARTIFICIALLY CONSTRAINED TO MEET A PREDETERMINED COMPLETION DATE.
e THE SAMPLING PROGRAM RELIES ON SUBJECTIVE CRITERIA INSTEAD OF PROVEN AND RELIAELE STATISTICAL TECHNIQUES.
- 1. -
- FINDING - SIGNIFICANT BREAKDOWNS IN IW1AGEMENT CONTROL SYSTEMS FOR DESIGN / SITE _afI HIIIES_ EOR _IOTH SEISNIC AUR NON-SEISMIC SAFEH_EEAIURES_liAYE_EEEN DISCLOSEIL11EE THE LICENSE WAS SUSPENDER e
14 DISCREPANCIES HAVE GROWN TO OVER 200 SEISMIC-RELATED DISCREPANCIES WIDESPRESD BUILDING - AUXILI ARY, FUEL HANDLING, TURBINE CUPPORTS - PIPE, CAELE TRAYS, EQUIPMENT 79-I.4 AS-EUILT REVIEV' INSUFF IC IENT -
Orp i-dp Ad' EQUIPMENT MODELED INCORRECTLY SPECTRA IMPROPERLY USED AND CONTROLLED NON-SEI SMIC DISCREPANCIES ALSO DISCLOSED PIPING THERMAL ANALYSIS CIRCUIT PREAKER MISAPPLIED CONTROL ROOM POWER SUPPLY c
ILF. -REEDY Fil03_PGSE QUALITY ASSURANCE _J)EFICIENT INADEQUATE IN POLICY, PROCEDURES, IMPLEMENTATION GENERAL VlEAKNESS IN INTERNAL / EXT INTERFACE & DOC CONTROL DESIGN VERIFICATION NOT FORMALIZED / INCONSISTENTLY IMPLEMENTED e
Ea011A'lEN REEORT IDEtLI1EIES_ POTENTIAL GENERIC PROELEIE MODEL - PLANT CONFIGURATION /AS-BUILT DIMENSIONS NOT USED' MODEL PARAMETERS - MASSES INCORRECT SPECTRA - SMOOTHING TECHNICUES NOT CONSERVATIVE o
REG 103_LLETTER RECOMMENDS EXPANDED SCOPE COMPLETE PHASE 11 ACTIVITIES PRIOR TO FUEL LOADING ACCESS QA PROGRAMS OF ON-SITE CONSTRUCTION CONTRACTORS
- BEC0f3ERDAT10N - REVISE _AUll EXPAND _EliaSE I/ PHASE _ll REY _ER I F I C AT I ON P R OGEenS_IQ_ADDBESL ISSUES IDENTJElER
-2
.i
- FINDING -
THE PROEaSED_IELEDE E PHASE I.lJEYERIFICATI0t{
EB0ERAM FAILS TO PROPERLY ADDRESS NUMER01!S RESLGN/ CONSTRUCTION ACTIVITIES If1PORTANT TO SAEEll L'ESTINGHOUSE SHOULD BE INC1EED IN PROGEAD INED IN ORIGINAL PURCHASE ORDER SEISMIC CRITERI A NOT DgF,ESTINGHOUSE EXCHANGE YEARS OF INFORMAL PG&E/h LACK OF DESIGN SPECIFICATION g-.L ( SQ1*
FUEL SPACER GRID OVERSTRESS PHASE I/ PHASE II DICHOTOMY IS ARTIFICIAL JUNE 1978 DATE NOT SIGNIFIChNT PHASE I/II DESIGN ACTIVITIES
'NTERRELATED WHERE QA/QC LACKING REVERIFY l00%
OF SAFETY ACTIVITIES DETERMINE ROOT CAUSE OF ERRORS 6
ADD CONSTRUCTION CAJEVIEh' TO PROERA3 CIVIL, MECHANICAL, AND ELECTRICAL ACTIVITIES ADD REVIEU OF E0111EMENT "IMPORTANT T0_SAEEI1" ASSESS GDC-I COMMITMENT
- Lla REQU1BE_MaSBlG1100S DATA REEDRTING_BY TES LP_GRE J ;y h'EEKLY LOOKAHEAD REPORT COMPLETE REPORTING-ELut1E INTERNAL REVIEW /PG8E INTERNAL MEETINGS / SITE INSPECTIONS OPEN TO PARTIES SIMULTANEOUS REPORTING
- RECKI1EEATION -
COMP 1EIE_EXPASDED PliaEE_JI PROGEatl 1
- FINDING -
THF PROPOSED PG8E/BECHTEL INTERNAL CORRECTIVE ACTION 1R& GRAM IS ARTIFICIALLY CONSTRAINED TO HEET A PRFDETERMINED COMPLETION DATE.
SLOPE OF SEISMIC REVIEW IS INCOT LEIE HORIZONTAL SPECTRA EXCLUDED NSSS VENDORS NOT ADDRESSED USE OF DE/DDE ANALYSES UNCLEAR ALL SAFETY EQUIPMENT NOT REVIEWED i
PROPOSED TIMING 0F FUEL LOAD INCONSISTENT WITH WORK REMAINING QUALITY OF DESIGN AND CONSTRUCTION MUST BE DEMONSTRATED PRIOR TO FUEL LOAD MODIFICATIONS PROPOSED AFTER FUEL LOAD (E.G. FUEL HDLING BLDG)
INADEQUATE TIME FOR NRC/IDVP REVIEW OF PG8E/BECHTEL WOR K e REPORTING JNTERNAL REPORTS NOT DOCKETED K00T CAUSES OF DEFICIENCIES NOT IDENTIFIED
- REConMENDATION
_CDELETE DESIGN REVIEL PHYSICAL INSPECTIOR AND PLANT MODIFICATIONS PRIOR TO FUEL LOAD
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- FillDitlG -
THE SAi1PLING PR06RAf1 BELIES ON SUBJECTIVE CBITERIA RATHER THAN PROVEN STATISTICAL TECHNIQUES e
JUDGMENT-SAf1PLING WILL BE UTILIZED _IR llAELO REVIEWS BEC HTEL/PG&E NRC TELEDYNE PROGRAM a
JHEQSSIBLE TO INFER ANYTHING ABOUT A PO?U1ATION FROL1 A " JUDGMENT" 0R " CONVENIENCE" SAMPLE JUDGMENT SAMPLING LAdKS REPEATABILITY e
ECE_PIARCE CRITERIA flUST BE ESTAELISHED PRIOR TQ SAMPLING 99 PERCENT CONFIDENCE OF LESS THAN I PERCENT ERRORS c
SIAU.STICAL TECHNIQUES PROVEN UTILIZED FOR FINANCIAL AUD1TS
' STATISTICAL METHODS SHOWN TO C0f1PLEMENT JUDGMENTS
- RECOMi-]fl!EalLOR -
ELAMlED USE OF_AVAILABLE STATISTICAL TECHNIQUES CAN PRODUCE DATA FROM 'WHIC11 VALID EXTRAPOLATION IS POSSIELE' July 30, 1982 (Corrscted)
MEMORANDUM FOR:
Counsel to Governor Brown FROM:
MHB Technical Associates
SUBJECT:
Comments on Proposed Phase II Program Management Plan Diablo Canyon Design Verification Program The proposed Program Management Plan for Phase II of the Diablo Canyon Verification Program was submitted to the NRC by Teledyne Engineering Services ("TES") in a June 18, 1982
' letter to Harold R.
Denton.
The Phase II program is intended to develop the additional information Mr. Denton requested in his November 19, 1981 letter to Malcolm H. Furbush of PG&E.
Thus, the Phase II program as originally defined by the NRC Staff at the time that the Diablo Canyon license was suspended, addresses non-seismic service related contracts performed prior to June 1, 1978, PG&E internal design activities, and all service related contracts post-January, 1978.
On July 8, 1982 Mr. Denton l
provided TES's proposed Phase II Program Management Plan to l
l Governor Brown for written comments.
Pursuant to that request, set forth herein are general comments applicable to the TES proposal and specific comments related to particular ' sections of the proposal.
I.
GENERAL COMMENT
S CONCERNING.SIGNIFICANT NEN INFOR':ATION DISCLOSED SINCE N'OVEMBER 19, 1981 At least 14 separate errors in design and construction were identified at Diablo Cany in in the seven weeks between authoriza-
tion of the fuel loading and low power testing license on September 2l1, 1981 and suspension of the license on November 19, 1981.
In response to these errors, the NRC ordered that a two-phase design verification program be initiated.
Since suspension of the license, more than 186 additional design and construction deficiencies.have been disclosed in the bi-weekly status reports submitted by PG&E and TES.
These design and construction deficiencies involve almost all subjects and items reviewed to date.
The multiplicity of deficiencies establishes clearly that PG&E and its major contractors failed to implement properly a large number of the 18 mandatory quality assurance criteria required by Appendix B to 10 C.F.R. Part 50 of the regulations and committed to by PG&E in the Diablo Canyon operating license application.
Insights into "why" the widespread design and construction breakdowns occurred were provided by the QA/QC program reviews and audit conducted by R.
F. Reedy Incorporated ( "Ree dy " ) of PG4E and its principal seismic safety related design service contractors who performed work prior to June 1, 1978.
- Indeed, in a report first issued in March 1982 as part of the Phase I verification program, Reedy stated the following three conclusions concerning the PG&E quality assurance program:
(a)
The PGLE Quality Assurance Program for design work was not adequate in areas of policy, procedures and implementation.
The Quality Assurance organization had insufficient program responsibility.
(b)
A general weakness existed in internal and external interface and document controls.
This questions whether appropriate design information
_3_
was being exchanged and utilized by design groups and consultants.
One concern is if,the latest Hosgri seismic data was inputted for design analysis.
(c)
The design verification program was not formalized and was inconsistently implemented and documented.
This included major gaps in.
design overviews of the design approach to mechanical and other equipment.
Thus, the Reedy report indicates that the 200 design and construction deficiencies identified to date may have had as a significant root cause the failure of PG&E to implement the required and committed to QA/0C program.
l Additional significant disclosures are found in the recently released report by the Brookhaven National Laboratory ("BNL Report").
BNL, at the request of the NRC' Staff, conducted an independent revicu and development of the vertical floor seismic response spectra for the Diablo Canyon containment annulus structure.
The developed response spectra were then utilized by BNL for evaluations of two selected piping systems.
In a July 1, 1982, letter to.Dr. William Cooper.of TES, Mr. Denton noted the following seven aspects of the design process utilized i
l by PG&E and its principal seismic subcontractor, URS/ Blume, and l
l summarized by URS/ Blume in its May, 1979 report for the contain-
[
ment structure, which as a result of the BNL Report require further exploration and assessment as to their generic implica-tions for the Diablo Canyon design process:
1.
The distributed masses of the steel members l
comprising the annulus structure apparently were not included in the mathematical model used in the original seismic analysis.
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2.
The mathematical model used in the original analysis apparently considered the joints between the beams and columns to be rigid, whereas the Brookhaven interpretation of the drawing indicates these joints are more appropriately considered flexible (shear carrying only).
3.
Statements on page 11 of the URS/ Blume May 1979 report "Diablo Canyon Nuclear Plant Unit 1 Containment Structure, Dynamic Seismic Analysis.
for 7.5 M Hosgri Earthquake," May 1979, concerning the structural connections may not be consistent with the mathematical model used in the original analysis.
4.
The response spectrum smoothing techniques employed in the original analysis appeared inconsistent with the FSAR commitments.
5.
Design dimensions were apparently used instead of the as-built dimensions in the two piping problems sampled.
6.
The. 5D bends in the piping analysis were apparently modelled as long radius bends, This has the effect of softening the model and reducing the natural frequencies.
7.
The piping support forces computed by the BNL model are much larger than those computed by the PG&E model.
As a result of the prece' ding breakdowns in the PG&E/ Blume design process, BNL recommended that "given the magn.itude of'the support force increases a reevaluation of all (pipe), support designs would seem warranted."
In addition, BNL concluded that its results differed from the results obtained using PG&E's recently developed "New Hosgri -
5 Mass Spectra."
Indeed, in response to a question from David Fleischaker during the July 27, 1982 meeting among PG&E, TES, BNL and the NRC, the BNL personnel confirmed tne following two BNL conclusions were with regard to PG&E's "New Hosgri - 5 Mass Spectra:"
(a)
BNL support force values obtained using BNL models and PG&E supplied spectra do not match.
The differences are probably due to the differ-ences in modelling.
(BNL Report, p. 11).
(b)
Support forces calculated using BNL piping models and BNL 3-D Model B envelope or independent spectra substantially exceed PG&E calculated values.
The major cause for this is that Model B spectra greatly exceed the spectra used by PG&E.
(BNL Report, p. 12 ).
Thus, even the current PG&E seismic reanalysis in important aspects was not in accord with~the BNL analysis and thus may provide an inadequate level of safety.
The foregoing new information -- the numerous design and construction deficiencies disclosed since November 19, 1981, the-breakdowns in the PG&E and URS/ Blume design process disclosed in the BNL-Report, and implications of the findings and conclusions of the Reedy report -- require that the reverification 4
program be alte'ed in a.significant manner in recognition of the r
facts that:
(a)
The Phase I/ Phase II dichotomy in the reverification program as originally contemplated by the NRC is nc
- r technically justified.
Thus, the Phase I/ Phase II dichotomy should be promptly abandoned.
(b)
The PG&E seismic design process breakdowns were not limited to the period prior to June 1,1978.
Rather, the break-downs were evident in the URS/ Blume 1979 report and continue to some degree even today in the current New Hosgri - 5 Mass Spectra.
Further, the seismic-design process breakdowns appear generic, l
l thus requiring a complete remodeling and reevaluation of seismic safety features.
l
4 (c)
The conclusions of the Reedy QA/QC audit raise serious questions as to the adequacy of the PG&E QA/QC program in other than design activities.
Thus, the reverification program must
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' encompass all PG&E QA/QC activities, including site activities.-
The reverification program should verify, to the maximum extent possible with non-destructive examination, the proper construction and installation of Diablo Canyon safety features in the as-built configuration.
(d)' The multiplicity of mistakes disclosed to date indicate-that the reverification program should be broadened to address all items "important to safety," rather than be artificially limited to only " safety related" items.
(See the definitions for the preceding as set forth in Mr. Denton's November 20, 1981 Memorandum which is included herein as Attachment A.)
- Clearly, the General Design Criteria ( "G DC ")
set forth in Appendix A to 10 C.F.R. Part 50 and in particular the quality assurance measures of-GDC 1, require verification for all activities and items important to the safety of Diablo Canyon.
II.
SPECIFIC COMMENTS 2
1.
(Section 2.1)
The Diablo Canyon reverification program should be re-
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structured and expanded as summarized in the preceding " General Com.aen ts. "
The TES proposal, contrary to the preceding, appears generally to ignore the significance of the 200 design and con-struction deficiencies identified to date.
- /
It' is understood that NPC Pegion V recently recommnded to NPC-NRR that site activities be evaluated as part of the Diablo Canyon rewrification program.
-7 2.
(Section 2.2)
The resources to be devoted by TES, Reedy, Stone & Webster Engineering Corporation ("SWEC"), and Robert L. Cloud Associates
("RLCA") to the reverification. program, and the proposed schedule for the program, are not described by TES.
Clearly, the anti-cipated resource allocation and time span for completing the verification program provides an-indi~ation of the depth and extent of the intended verification activities.
3.
(Section 2.2)
The TES proposal ~ fails to describe how, and to what extent, the work TES performed for PG&E in response to I&E Bulletin 79-02 will be evaluated during the. verification program.
4.
(Section 2.4)
The SWEC scope should be clarified to assure representative examplea from ca~ch design service contractor.
Further, contrary to the TES proposal, the design efforts for representative sample of' mechanical, electrical, seismic, and structural safety features per' formed by the nuclear steam supply system vendor (Westinghouse) should be included in the verification program.
if other equip'ent vendors performed significant In addition, m
design efforts for important safety features, then those organiza-tions should also be identified and their design control and design verification process be evaluated.
The SWEC verification review when combined with the RLCA efforts, should be sufficient to assure that the design process results in a design in conformance with the Diablo Canyon license application and NRC regulations.
8-5.
(Section 2.6)
The Reedy. acceptance criteria for QA/QC programs and their implementation, should be based on the requirements set forth in Appendix B to 10 C.F.R. Part 50 and GDC 1 of Appendix A to 10 C.F.R. Part 50.
The NRC's regulatory guide, and associated ANSI standards, should be utilized as criteria for design and site activities consistent with PG&E's commitments in the licensing application and consistent with the timing of the issuance of Regulatory Guides and ANSI standards.
Contrary to the limited Design Control Practices Evaluation methods proposed by TES in Section 5.7 of Appendix D to the Management Plan, any such design. control evaluation performed by Reedy should, as a minimen, be evaluated using the requirements set forth in Sec-tdons 2 to 11 of ANSI Standard N45.2.11-1974 (enclosed herein as Attachment B).
6.
(Section 3.1)
The engineering program plan ' set forth in Appendix D of TES's Management Plan should be consolidated to increase the clarity of the TES proposal by eliminating the need for the numerous cross-references between the two documents.
Such a consolidation would also increase the scrutability of the Management Plan.
7.
(Section 3.2.1)
As set forth herein, and in the " General Comments," the
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design chain for structures, systems and components "important to safety" should be developed and considered in the verification
program.
The preceding comment applies throughout the various aspects of the.TES proposah and in the interest of brevity will not be repeated.
8.
(Section 3.2.2)
The QA review and audit by Reedy should be sufficient in
~
depth and. extent to identify, insofar as practical,-the under-lying root cause of any design or construction deficiencies disclosed by the TES, SWEC, and RL'CA assessments.
- Further, contrary to the TES proposal, in the absence of an acceptable QA program or its implementation, all safety activities conducted by the deficient organization should be reevaluated.
9.
(Section 3.2.3)
The basis for the acceptance criteria set forth by TES in Appendix D should-be explicitly stated.
10.
(Sections 3.2.4 and 3.2.5)
An integral element of TES's design verification proposal is sampling of structures, systems and components to determine that they are in fact designed in accordance with applicable requirements.
However, TES's' proposed program does not adequately describe the statistical basis for the criteria to be used for the selection of a suitable number and type of samples to be reviead under the program or for the selection of additional verifications.
i In short, TES has proposed to use sampling extensively without providing adequate guidelines or criteria for evaluation of.that
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sampling.
Thus, contrary to the TES proposal, including Appendix C thereto, the proposal should be altered as follows:
.(a)
Define the confidence level which the auditors desire to achieve for each sampling effort and provide the' basis for selection of that confidence level.
(b)
Provide the statistical basis'for the relative size of sample utilized in each case.
If a statistical basis is not being utilized', then the judgmental or other criteria should be specified precisely.
(c)
For each. sample selected, demonstrate factually that the sample is representative of.the total population of the item being sampled.
(d)
Define precisely the acceptance criteria for each sampling effort, together with the factual basis for those criteria.
This is essential if any meaningful review is to take place.
(e)
Specify precisely the criteria to be used for expanding a sample based on the results of the initial sample.
(f)
Identify the person who will conduct the Phase I program review.
In addition, TES should specify in detail the scope of work proposed for the satistician.
11.
(Section 4.6)'
In order to provide an opportunity for planning and participation in the TES program, TES should provide a weekly look-ahead report to all parties (PG&E, NRC, Joint Intervenors, Governor Brown) in the Diablo Canyon licensing proceeding,
listing all planned meetings.and site visits proposed by TES, RLCA, SWEC and Reedy with PG&E and subcontractors for the sub-sequent week.. All such meetings and visits should be opened to all parties to audit.
12.
(Section 6.0)
Contrary to the TES proposal, program reports should be l
submitted to all parties simultaneously, rather than to only PG&E and the NRC as suggested by TES.
The preceding comment applies to all of the procedures noted in Section 7.0 of the TES proposal as well.
Further, in the interest of scrutability, all program reports should provide a sufficient level of detail to the parties to describe' unambiguously the matter under consideration.
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