ML16341A168
| ML16341A168 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/20/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Panetta L HOUSE OF REP. |
| Shared Package | |
| ML16341A169 | List: |
| References | |
| NUDOCS 8408010275 | |
| Download: ML16341A168 (18) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 JUL 20 SN The Honorable Leon Panetta United States House of Representatives
'ashington, D. C.
20515 Dear Congressman Panetta:
As stated in his June 19, 1984 letter to you, Chairman Palladino requested the staff to respond to your concern over a perceived tendency by our staff in connection with the Diablo Canyon Nuclear Power Plant to assume that the margins of safety established by our criteria need not be adhered to for systems which are not pivotal to safety, and that less precise, ad hoc standards of safety can be applied.
The testimony by the staff at ttIe January 24, 1984, hearing relating to margins of safety and adherence to licensing criteria should not be construed to mean that the staff accepts less than the margins of safety required by the Commission's regulations.
The staff's determinations are bolstered by the extensive reviews undertaken by the Independent Design Verification Program conducted under the direction of Teledyne Engineering Services, the licensee's own comprehensive Internal Technical Program and the reviews and audits performed by the NRC staff and its consultant,
'Brookhaven National Laboratory.
These efforts effectively evaluated..virtually. all safety-,related structures, systems and components, from the standpoint of their compliance with seismic design criteria and also covered a significant amount of such items in terms of compliance with other, non-seismic criteria.
Since the latter area was evaluated using a suitable sampling approach, it has been recognized that some deviations from criteria may not have been detected.
This is, nevertheless, considered acceptable for'two reasons.
First the findings resulting from the reviews provide ample assurance that any departure from criteria which may not have been detected because of the sampling approach used, is not likely to have safety significance.
Second, it should be recognized that a departure from a specific criterion does not necessarily equate with a failure to satisfy a
Commission regulation.
The criteria established for any given facility reflect an acceptable (but not necessarily exclusive) approach to satisfying a regulation.
- Hence, a departure from such detailed requirement, if accom-panied by adequate justification, does not'ecessarily entail a failure to comply with the regulation underlying it.
The staff believes,'based on the extensive reviews performed, that, in regard to the matters evaluated, it is unlikely that applicable regulations have not been complied with.
In addition, the testimony makes clear that further assurance is provided by the conservatisms inherent in the design and construction (including materials used) of nuclear power plants, which readily offset small departures from very precise criteria.
Such conservatisms assure that safety margins called-for by Commission regulations are maintained even if some deviations from a criteria were found.
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The Honorable Leon Panetta We trust this letter is responsive to your concern.
Sincerely, tSign0d> Vlilliamj. Dircks William J. Dircks Executive Director for Operations Distribution: W/incoming Docket File 50-275/323 NRC PDR*
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 The Honorable Leon Panetta United States House of Representatives Washington, D. C.
20515 Dear Congressman Panetta:
As stated in his June 19, 1984 letter to you, Chairman Pall dino requested the, staff to 'respond to your concern over a perceived tend cy by our staff in connection with the Diablo Canyon Nuclear Power Plant o assume that the margins of safety+established by our criteria need not adhered to for systems which are no pivotal to safety, and that less
- recise, ad hoc standards of safety ca be applied.
The testimony by the staff at ttte January"24, 1984, heari relating to margins of saf ty and adherence to licensing criteria should ot be construed to mean hat the staff accepts less than the margins of sa ty required by the C mmission's regulations.
- Rather, the testimony made cl r that while ther may be undetected departures from licensing criteria, such d
artures would ot likely have any safety significance.
Further, it shoul e recogniz d that a departure from a specific criterion does not necessarily equa e,with failure to satisfy a Commission regulation.
The criteria establishe for y given facility reflects an acceptable (but not necessarily exclus e
approach to satisfying a regulation.
Hence; a departure from-such -detal'ted r cerement; lf-accompanied-by adequate justification, does not necessarily en ai a failure to comply with the regulation underlying it.
The staff's judgment in this matte is bolster by the extensive reviews under-taken by the Independent D
ign Yerificati Program conducted under the direction of Teledyne Engin ering Services, t licensee's own extensive Internal Technical Program an the reviews and audi performed by the NRC staff and its consultant, Br okhaven National Labora ry.
These efforts effectively evaluated virt lly all safety-related str ctures, systems and components from the stand oint of their compliance with eismic design criteria and also covere a significant amount of such i ms in terms of compliance with other, on-seismic criteria.
The findings resulting from the reviews provide am le assurance that any departure from criteria which may not have been detected is not likely to have safety significance.
In addition, the testimony makes clear that further assurance is provided by the conservatisms inherent in the design and construction (including materials used) of nuclear power plants, which readily offset small departures from very precise criteria.
Such conservatisms assure that safety margins called for by Comission regulations are maintained even if some deviations from a criteria were found.
- V
The Honorable Leon Panetta United States House of Representatives Washington, D. C.
20515 Dear Congressman Panetta:
As stated in his June 19, 1984 letter to you, Chairman Palladino requested the staff to respond to your concern over a perceived tendency by our staff in connection with the Diablo Canyon Nuclear Power Plant to assume that the margins of salty established by our criteria need not be adhered to for systems which are,not pivotal to safety, and that less precise, ad hoc standards of safely. can be applied.
The testimony by the staff at ttte January 24, 1984, h5qring relating to mar ins of safety and adherence to licensing criteria shl) ld not be constru d to mean that the staff accepts less than the margins o
safety require by the Commission's regulations.
- Rather, the testimony ma clear that hile there may be undetected departures from licensing criteria, s ch depart es would not likely have any safety significance.
Further, it ould b
recognized that a departure from a specific criterion does not n cess rily equate with a failure to satisfy a
Conmission regulation.
The cr t ia established for any given facility reflects an acceptable (but no ecessarily exclusive) approach to satisfying a regulation.
- Hence, a depar re from such detailed requirement, if accompanied by adequate justification, d es no necessarily entail a failure to comply with the regulation underlying The staff's judgment in is matter is bolstered by the extensive reviews under-taken by the Inde endent Design rification Program conducted under the direction of Teled ne Engineering Se vices, the licensee s
own extensive Internal Technical Pr gram and the review and audits performed by the NRC staff and its consul ant, Brookhaverl Natio al Laboratory.
These efforts effectively evaluat virtually all safety-elated structures, systems and components from th standpoint of their comp iance with seismic design criteria and also covered a significant amount of such items in terms of compliance with other, non-s ismic criteria.
The finding resulting from the reviews provide ample ass rance that any departure from criteria which may not have been detected is not likely to have safety signi icance.
In addition, the testimony makes clear that furth r assurance is provided by the conservatisms inherent in the design and const uction (including materials used) of nuclear power plants, which readily offse small departures from very precise criteria.
Such conservatisms assure that s fety margins called for by Commission regulations are maintained even if some d viations from a criteria were found.
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The Honorable Leon Panetta United States House of Representatives Washington, D. C.
20515 Dear Congressman Panetta:
As stated in his June 19, 1984 letter to you, Chairman Palladino requested the staff to respond to your concern over a perceived tendency by our staff in conncection with the Diablo Canyon Nuclear Power Plant to assume that the margins of safety established by our criteria need not be adhered to for systems which are not pivotal to safety, and that less precise, ad hoc standards of safety can be applied.
The testimony by the staff at the January 24, 1984 hearing relating to margins of safety and adherence to licensing criteria should not be construed to 'mean that the staff accepts less than the margins of safety required by the Commission's regulations.
- Rather, the testimony made clear that while there may be 'undetected depar ures from licensing criteria, such departures would not likely have any hafety si nificance.
Further, it should be recognized that a departure from a specific c iterion does not necessarily equate with a failure to satisfy a Commissiob r ulation.
The criteria established for any given facility reflect on accepta le (but not necessarily exclusive) approach to satisfy a regulation.
- Hence, a
eparture from such detailed requirement, if accompanied by adequate justifi ti
, does not necessarily entail a failure to comply with the regulation unde lying t.
The staff's judgement in this atter is lstered by the extensive reviews under-taken by the Independent Desi n Verificati n Program conducted under the direction of Teledyne Engineering Serv'ces, the licen e's own extensive Internal Technical Program and the reviews and udits performed the NRC staff and its consultant, Brookhaven National Laborat ry.'hese efforts ffectively evaluated virtually all safety related structures, ystems and componen from the standpoint of their compliance with seismic de ign criteria and also overed a significant amount of such items in terms of co pliance with other, non-eismic criteria.
The findings resulting from the review provide ample assurance hat any departure from criteria which may not have been detected is not likely to ha e safety significance.
In addition, the testimony makes clear that further as rance is provided by the conservatisms inherent in the design and construction
( ncluding materials used) of nuclear power plants, which readily offset small depa tures from very precise criteria.
Such conservatisms assure that safety margins alled for by Commission regulations are maintained even if some deviations from a criteria were found.
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The Honorable Leon Panetta We trust this letter is responsive to your concern.
Sincerely, Cr William J.
Dir4<s Executive Director fo Operations
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JUL o 884 The Honorable Leon Panetta United States House of Representatives llashington, D.C.
20515 Dear Congressman Panetta:
As stated in his June 19, 19S4 letter, to you Chai n Palladino requested the staff to respond to your concern over a percei tendency by out staff in connection with the Diablo Canyon ttuclea Power Plant to assume that the margins of safety established by our cr teria need not be adhered to for systems which are not pivotal to safety, a
that less precise, ad hoc standards of safety can be applied.
The test'ony by the staff at the January 24, 1984 hearing relating to margin of safety and adherence to licensittg criteria should not be construed o mean that the staff accepts less than the margins of safety required by t Commission's regulations.
- Rather, the testimony made clear that while their may be undetected departures from licensing criteria, such departures i<o d not likely have any safety significance.
The staff's judgement in this mat is bolstered by the extensive reviews undertaken by the Independent De gn Verification Program conducted under the direction of Teledyne Engine r ing Services, the licensee's own extensive Internal Technical Program and he reviews and audits performed by the HRC staff and its consultant, ookhaven ttational Laboratory.
These efforts effectively evaluate irtually al't safety related structures, systems and components from e standpoint of their compliance with seismic design criteria and also c e
ed a significant amount of such items in terms of compliance with other, no -s ismic criteria.
The findings resulting from the reviews provide ampl as urance that any departure fran criteria which may not have been det cted is not likely to have safety significance.
In addition, the test'ny akes clear that, further assurance is provided by the conservatisms inher nt in the design
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Such conservatisms assure that safety margins called for by Commission regulations are maintain even if some deviations a<ere found..
Ite trust this letter is responsive to your concern.
Sincerely, William J.
ircks Executivq. irector for Operations
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The Honorable Leon Panetta United States House of Representatives Washington, D. C.
20515
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Dear Congressman Panetta:
As stated in his 'June -19, 1984:, letter 'to you Chairman Py'adino requested the staff to respond to your concer'n over an apparent tendency of our staff to assume that the margins of safety established by our cri'teria need not be adhered to for systems which are not pivotal to safety, and that less precise, ad hoc standards of safety can be applied.
The tes$ ihony by the staff at the January 24, 1984 hearing relating to margins of safety should not be construed to mean that the staff accepts less than the margins of safety required by the Commission's regulations.
The testimony was meynt to relate that insp'ection and review efforts are more heavily focused on/those aspects which have the greatest potential for affecting public heal/i and safety.
It is important to note that in addition po the margin of safety incorporated in Commission regulations there are furtPer margins of safety that result from design and fabrication practices employed for nuclear power plants.'hese additional margins of safety are recognized to ameliorate uncertainty from less than absolute confirmation/that the letter of the regulatory require-,
ments have been met in each case.
Rhereas it is beyond reasonable expectation to assure absolute compliance in ach case, we believe that upon completion of the review and inspection progra carried out by the NRC staff, the safe design and construction of the Diablo anyon Plant will be assured.
We trust this letter is resp nsive to your concern.
II Sincerely, William J. Dircks Executive Director for Operations DL:LB¹3 LB¹3 HSchierl'/yt 6',184 6/
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