ML16340D192
| ML16340D192 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/17/1983 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML16340D191 | List: |
| References | |
| NUDOCS 8303030391 | |
| Download: ML16340D192 (14) | |
Text
UMITEDSTATES ENCLOSURE 1
lwUA2AR REGULATORY CO/i'iVilSSION~
'iVASHINGTQN,D. C. 20555 CHAlnMAN
. february 17, 1983 The Honorable Morris K. Udall, Chairman Committee on Interior and Insular Affairs United States House of Representatives
'Washington, D.C.
20515
Dear Mr. Chairman:
I am responding to your letter of January 11, 1983 in which you refer to concerns of individuals living in the area near the Diablo Canyon Nuclear Power Station.
Your letter raises five specific concerns regarding the requirements which must be satisfied prior to authorization to load fuel.
Each of these concerns is addressed in the enclosure.
Let me assure you that under no condition will we authorize the. Diablo Canyon facility to begin operation until we have reasonable assurance that the public health and safety is adequately protected.
Miore specif-ically we will require a high level of confidence that no significant design or construction deficiencies affecting safety at any authorized level of operation exist at the facility before reaching a decision to authorize that level of operation.
. I hope this letter and its enclosure provide information responsive to your concerns.
Sincerely, Nunzio
. P/ll adino
Enclosure:
As stated cc:
Manuel Lujan 830303039l 830223 pDR *oocK ooooo2'7o PDR
~ ~
I
~ ~
Enclosure
Response
to Five Concerns i3 The first concern is that "the Commission has approved a licensing schedule that would permit fuel loading prior to completion by PGGE of its review of the plant's seismic design and prior to implementation of all necessary corrective measures
. that might result from this review. "
On March 4, 1982 the Co",.~iission approved a program plan for Phase I of.the Independent Desi on Verification Program
( IDVP).
The Phase I activities (described below in our response to the third concern) must be completed prior to reinstatement of the low power license.
On December 8,
1982, the Commission approved a plan according to which a decision regarding the low power license reinstatement will take place in two steps.
,A third step will be the decision regarding issuance of the full power license.
Before any decision to permit PGBE to load fuel, all. activities prescribed in Step 1
- must, be completed, and before any decision to permit low power operation (less than 5$,), all activities prescribed in Step 2 must be completed.
Steps 1, 2, and 3 are listed in the Enclosure of the PGBE submittal of December 2,
1982 (copy attached).
While PG8E has proposed specific dates for both steps (March 31, 1983 and May 15, 1983, respectively),
we do not consider these daies-controlling and will reach decisions only after all necessary review and evaluation 'has been completed.
All modifications to safety-related structures,
- systems, and components required for any particular mode of operation of the facility must be completed prior to a decision regarding that mode.
\\
The second concern is that "no provision has been made for considering analyses of the. seismic design now being prepared by Brookhaven National Laboratory" (BNL).
The results of the seismic design analyse's that have been ongoing at BNL since late 1981 will be fully taken into consideration" in the NRC evaluation and determination regarding the seismic design adequacy of Diablo Canyon Unit 1.
The first, BHL effort involved the containment annulus structure and selected associated piping systems and was documented in a report.
We have requested the IDYP to review this report, consider the results in its own design verification efforts, and provide us with its conclusions.
The HRC staff is evaluating the BHL report in parallel and will have the additional benefit of the independent view provided by the IDVP.
rj i d 1 982 the NRC reques ted conti nued parti cipat i on by BHL to undertake a horizontal seismic analysis of the containment annulus structure, seismic and stress analyses of a buried tank, and additional analyses of piping systems.
The purpose of the BHL analyses is to provide the NRC with additional insight as to the character of results obtainable by use of current state-of-the-art analytical techniques without regard to methods or procedures previous'ly approved in the licensing process for Diablo Canyon.
These analyses are therefore not intended as a substitute for the design and evaluation efforts now underway nor are they a substitute for the analytical effort being performed by the IDYP.
Our experience has
- been, however, that such analyses often provide insights to assist in our review.
The
'BHL analyses will be sufficiently completed and taken into consideration prior to any decision regarding restoration of the license.
I
~ ~
The third concern is that "fuel loading will be allowed before completion of an adequate review of non-seismic safety-related plant elements."
The Commission Order of November 19, 1981 (copy attached),
which suspended the low power license, sets forth the requirements that must be completed prior to reinstatement of the license.
These requirements relate to seismic analyses and design activities performed prior to June 1978 by PGSE and its contractors (i,e., service-related activities) and to the implementation of the quality assurance program for those efforts.
The activities associated with the Com~ission Order have become known as Phase I of the'independent design verification effort and, as discussed
- above, will be completed in two steps.
In addition, the t<RC Office of t/uclear Reactor Regulation required PGE~E in a letter, also -dated tlovember 19, 1981, to initiate an independent design verification effort of safety-related structures, systems and components with respect to seismic analyses and design activities performed after 1978 and with respect to non-seismic analyses and design efforts performed by PGEE and its contractors.
These efforts have become known as Phase II of the design verification program.
By the Commission's approval of the program plan on December 8,
- 1982, the utility is required to submit a statu's report on all Phase II activities prior to any decision regarding restoration of the license.
Such work must be. sufficiently complete to ensure that all major deficiencies were detected.
The design verification efforts for Phase I and Phase II are well underway.
The activities that we require now to be completed prior to a fuel load decision exceed those originally specified in our Order.
Me have expanded the pi ogram to include the following additional IDVP activities:
(1) audit of the implementation of the Diablo Canyon Project quality assurance program (2) audit of a sample of quality assurance program implementation of construction activities, (3) review of the PGKE/Vestinghouse design interface, and (4) verification of the appropriate Hosgri and non-Hosgri spectra...
As explained
- above, at the time of authorization for fuel loading all efforts required for reinstatement of the license will be completed except for modifications to those structures, systems and components that are not required for Step 1, in order to protect the public health and safety.
In addition, the Phase II activities (i. e., non-seismic, safety-related analysis and design) of PGGE and the IDYP will have proceeded to an extent that will allow us to reach a conclusion with respect to any additional desi gn verification that might be required.
At this time the IDYP has completed its review of those structures, systems and components that comprise the initial sample to be verified under Phase II.
Prior to fuel
- loading, PGKE and the IDVP will both submit to the tlRC a report on the status of their respective Phase II activities.
- Again, we will require a high degree of assurance, at the time of a decision regarding fuel loading, that any further design verification efforts in the seismic and non-s'eismic area will not reveal any major deficiency in Diablo Canyon Unit l.
,P
~ 4
'I The fourth concern's that "fuel loading will be permitted before results are received from tho'ngoing audit of the quality assurance program and the implementation of corrective actions, if any, which might be called for as a result of this program."
As stated above in response to the first and third concern, an audit of the quality'assurance (QA) program's and their implementation by PGGE and its contractors is required as part of the Phase I
and Phase II activities.
These audits have been completed by the IDVP; interim technical reports have been issued and are, currently undergoirg HRC review.
In addition, the design verification effort has been expanded to include an audit of QA activities regarding the construction of Diablo Canyon Unit 1.
This activity is ongoing and a status report will be provided to the HRC as part of the Step 1 requirements.
Other audits of QA programs and their implementation include an IDYP QA audit of ongoing PG5E activities, a
PGBE internal QA audit of its contractors, and a
PG8E QA audit of its own ongoing activities'.
In addition, the HRC Region Y Office has routinely inspected ongoing design verification activities, including the implementation of appropriate QA programs.
Host of the above QA audits will be completed prior to fuel loading and reports will be provided to the HRC.
We will require that all necessary corrective actions.be implemented before fuel load authorization.
The fifth concern. is that, "fuel loading will b'e permitted prior to an adequate HRC review of the various seismic and non-seismic safety-related
- audits, analyses and corrective actions undertaken since late 1981."
The HRC Order of Hovember 19, 1981, clearly sets forth the requi rements that must be met and procedures that are to be followed for the authorization of fuel loading.
In Section 5 of Attachment 1, the Order states:
~
"Prior to authorization to proceed with fuel loading the HRC shall be satisfied with the results of the seismic design verification program referred to in paragraph 1,
and with any plant modification resulting from that program that may be necessary prior to fuel loading.
The HRC may impose additional requirements prior to fuel loading necessary to protect health and safety based upon its review of the program or any of the information provided by PGSE pursuant to paragraph 4.
This may include some or all of the requirements specifi'ed in the letter to
- PGEE, dated November 19, 1981,"
Our approval of the two-step process for a decision regarding reinstatement of the license does not permit any deviation from these requirements.
As stated earlier, the approval is limited to the concept of two steps for decisions regarding reinstatement of the license, but is in no way restricted to the target schedule proposed by PG5E.
At this time, PGBE and the IDVP are providing us with much information in the form of semi-monthly
- reports, interim technical
- reports, and sections of their final reports
I I
'4
~
~
0 on the various facets of the design verification efforts in Phase I and Phase II.
Although we intend to give substantial weight in our decision to the findings, conclusions, and recommendations of Teledyne Engineering Sevices as the manager of the IDYP, under no condition wil1 we consider the IOYP to take the place of the necessary and adequate NRC review.
Me will not be restricted in our own review efforts by the specific schedule proposed but will take the time necessary to assure ourselves and the public that there are no deficiencies that would prevent safety-related structures, systems and components from performing their intended safety functions.
I
~
4
< 1 K' l~D S."MIZ -"
FOR FU=L L lhG, LOh'OR CQ. LETIOH OF ACTIYITIFS REQUIP=D POtt":R T"SilhG, Al& FULL P&'"
0"-EPATI(H 12/02/82 ACT I Y ITY SCi.Z)ULED KB~I=T IC8 Dgr.
sKKs.wt Sten I
IIennlsee n
s fn" Res,o. c, lon of,he Lov Pover License I.
Project Reports submltsteedr A.
Final Report for Phase I
B.
Stc,us Repo
. for Phase II C,
Supplement for As-bullts '2/15/83 02/15/83 03/15/83 2.
IDYP reports subnl,ted:
A.
Status Report fc" Phase I
B.
Stafus Repa& for Phase I I C.
Status R~ort for ITP QA Program D.
Status Report fo" Construction QA E.
Sfc,us Report fo" Hon Hosgrl spectra F.
Final Report for PM,B% Interface G.
Final Repo& for Hosgrl spec+a H.
Suppierrfent for As<<built verification 3.
hRC De"Islon fo" Restoration of the Lov Power License 03/Ol/83 03/01/83 03/Ol/83 03/OI/83 03/Ol/83 03/OI/83 03/OI/83 03/15/83 03/31/83 (See Note I)
(See Hate 2)
For fuel Iced Items (bhdes 5 1 6)
(Re Hote 3)
Step I I Require.-.en s fo-Inl Icl Crltlcall ey and Lov Power Testing I.
P.-oject Reports subml, ted:
A.
Flncl Phase I Repor, supplement B.
Svpplef-ant sor As-bul lts 2.
IDYP reports submitted:
A.
Final Repa& fo-Phase I
B.
Status, Repa& fo" Phase I I C.
Svpplenent fo-As-bul lt verlflcailon HRC De Islon for Inltlcl Crltlcallty cnd Lov Power Testing 04/Ol/83 04/30/83 04/15/83 04/15/83 04/30/83 05/15/83 For lov po~er Items (Hodes 2,3,4,5 L 6)
(See Note 4)
St-;en I I I neqel."enents fnr Iss-=s-"e of a Full Power License I.
Project Repo&s submitted A.
Pha e
I I Repa&
B.
Supple."sent fa" As-bvl lt 2.
IDYP repo..s submits ted:
A.
Final Report for Phase II
~
B.
Final Repo& for Construcflon QA D.
Final Repa s for Hon-Hos'gri specfra E.
Supplement for As-bvllt Yerlflcctlon 05/15/83 06/I5/83 05/Ol/83 05/OI/83:
05/Ol/83 05/01/83 05/15/83 Fa" full pc er Items (Pres IW) 3.
hRC Declslon fo-Issucnce of a Ful I Power License 05/30/83
1 4
llOTE S HOTE '
IDYP repor.s nay be star,ed approxlnately nld Decaaber, 1982, vlth further project Input ln nld January and February.
It ls antlclpa ed
.hat ihe repor.s can be conpleted vlthln tvo veeks of receipt of the last project Input.
The IDYP Is In continual contact vl h the project,hroughout this period.
NOTE 2
Phase I I status report
<<I I I address,hat Phase I I actIYliles are sufflclently complete to provide reasonable assurance that no najor def lclencles renaln undetected.
HOTE 3 -
Items to be conpleted after'fuel loading:
HOTE 4
o CIYII structural f lnal conf Irnatory load revlev (supported loads).
Pr Impar Ily hnnulus and Class I plaiforns.
o Fuel handling build lng nodlflcat lons (Unit I only).
o Turbine bulldlng nodlflcatlon design and construction.
Items to be conpleted after RCS heatup and lov pover testing:
o Turbine bulldlng modlf lcatlon design and construction.
hlote This attachment was enclosed in the PGKE submittal of December 2,
1S82.
It lists the activities of Phase I, Phase II and other efforts that must be completed at the two steps for rei nstatement, of the low power license and at the issuance of a full power license.
0 I
E 0