ML16341B542

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Forwards Request for Addl Info Re Items 260.11 Through 260.16 Delineated in 810122 QA Program.Review of Table 3.2-4, Classification of Structure,Sys & Components for Diablo Canyon, Identified Deficiencies in Item 260.17
ML16341B542
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 03/06/1981
From: Tedesco R
Office of Nuclear Reactor Regulation
To: Furbush M
PACIFIC GAS & ELECTRIC CO.
References
NUDOCS 8103120817
Download: ML16341B542 (24)


Text

Docket Nos.:

50-275/323 n,

Nr. Halcolm H. Furbush Vice President - General Counsel Pacific Gas

& Electric Company P. 0.

Box 7442 San Francisco, California 94106

Dear Ib. Fur bush:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - DIABLO CANYON UNITS 1

8I 2 Me have completed our review of the information provided on your quality assurance program during lllhe operations phase of Diablo Canyon as delineated in your letter of January,'22, 1981.

Ife find that your submittal does not satisfy all our concerns.

and the enclosed items 260. 11 through 260.16 are forwarded for your response.

In addition, we have completed our review of Table 3.2-4, "Classification of Structures, Systems and Components for Diablo Canyon," which identifies items subject to your operational quality assurance program of the FSAR for Diablo Canyon Units 1 5 2.

Under a revised procedure that involves the review of this list by other NRR technical

branches, we have identified certain deficiencies which are noted in item 260.17 of the enclosure.

Enclosure item 260.17c reflects the requirements of NUREG-0737, UClaIkficationsof TIII Action Plan Requirements,"

(November, 1981).

It is requested that you provide the requested information expeditiously in order that we can complete our review in a timely manner.

Sincerely, Original Signe" bl Robeyt I, Tedesoe 8 1 03ggo'5l7..

Enclosure:

Request for Additional Information Robert L. Tedesco, Assistant Director for Licensing Division of Licensing cc:

See next page.

DISTRIBUTION:

See next page.

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Docket Nos.:

50-275/323 Mr. Malcolm H.

Furbush Vice President - General Counsel Pacific Gas 8 Electric Company P. 0.

Box 7442 San Francisco, California 94106

Dear Mr. Furbush:

SUBJECT'EQUEST FOR ADDITIONAL INFORMATION - DIABLO CANYON UNITS 1

& 2 We have completed our review of the information provided on your quality assurance program during the operations phase of Diablo Canyon as delineated in your letter of January 22, 1981.

We find that your submittal does not satisfy all our concerns, and the enclosed items 260.11 through 260.16 are forwarded for your response.

In addition, we have completed our review of Table 3.2-4, "Classification of Structures, Systems and Components for Diablo Canyon," which identifies items subject to your operational quality assurance program of the FSAR for Diablo Canyon Units 1

8 2.

Under a revised procedure that involves the review of this list by other NRR technical

branches, we have identified certain deficiencies which are noted in item 260.17 of the enclosure.

Enclosure item 260.17c reflects the requirements of NUREG-0737, "Clarification of TMI Action Plan Requirements,"

(November, 1981).

It is requested that you provide the requested information expeditiously in order that we can complete our review in a timely manner.

Sincerely, Qp~ c~~

Enclosure:

Request for Additional Information Robert L. Tedesco, Assi stant Director for Licensing Division of Licensing cc:

See next page.

1 l

Hr. Malcolm H, Furbush Vice President - General Counsel Pacific Gas 4 Electric Company P.O.

Box 7442 San Francisco, California 94106 MN 6

1981 CC:

Philip A. Crane, Jr.,

Esq.

Pacific Gas 8 Electric Company P.O.

Box 7442 San Francisco, California 94106 Janice E. Kerr, Esq.

California Public Utilities Commission 350 McAllister Street San Francisco, California 94102 Nr. Frederick Eissler, President Scenic Shoreline Preservation Conference, Inc.

4623 Nore Mesa Drive Santa Barbara, California 93105 Ms. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, California 93401 Nr. Gordon A. Silver Ns.

Sandra A* Silver 1760 Alisal Street San Luis Obispo, California 93401 Harry N. Willis, Esq.

Seymour 8 Willis 601 California Street, Suite 2100 San Francisco, California 94108 Nr. Richard Hubbard NHB Technical Associates Suite K

1723 Hamilton Avenue San Jose, California 95125 Nr. John Narrs, Managinq Editor San Luis Obispo County Telegram-Tribune 1321 Johnson'venue P. 0.

Box 112 San Luis Obispo, California 93406

~J f

Nr. Malcolm H. Furbus'h cc:

Resident Inspector/Diablo Canyon NPS c/o U. S. Nuclear Regulatory Commission P. 0.

Box 396 Arroyo Grande, California 93420 Elizabeth S.

Bowers, Esq.,

Chairman Atomic Safety 8 Licensing Board U. S. Nuclear Re'gulatory Commission Washington, D. C.

20555 Nr. Glenn 0. Bright Atomic Safety 8 Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Richard S.

Salzman, Esq.,

Chairman Atomic Safety 8 Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. M. Reed Johnson Atomic Safety 5 Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. John H. Buck Atomic Safety 8 Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Ms.

Raye Fleming 1920 Hattie Road Shell Beach, California 93440 John R. Phillips, Esq.

Simon Klevansky, Esq.

t1araaret

Blodgett, Esq.

Marion P. Johnston, Esq.

Joel

Reynolds, Esq.

Center for Law in the Public Interest 10203 Santa Monica Boulevard Los Angeles, California 90067

1

Hr. Malcolm H. Furbush MAR g egg cc:

Paul C. Valentine, Esq.

321 Lytton Avenue Palo Alto, California 94302 Nr. Byron S. Georgiov Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814 t1r. John Harrs Hanaging Editor San Luis Obispo County Telegram - Tribune Jo nson venue P. 0.

Box 112 San Luis Obispo, California 93406

.Herbert H. Brown, Esq.

Hill, Christopher

& Phillips, P.C.

1900 M Street, N.M.

Washington, O.C.

20036 t1r. Richard E. Blankenburg, Co-Publisher t1r. Mayne A. Soroyan, Hews Reporter South County Publishing Company P. 0.

Box 460 Arroyo Grande, California 93420

Mr. Malcolm H. Furbush CC:

Mr. James

0. Schuyler Nuclear Projects Engineer Pacific Gas

& Electric Company P.O.

Box 7442 San Francisco, California 94106 Bruce Norton, Esq.

Suite 202 3216 North 3rd Street

Phoenix, Arizona 85012 Mr.

W. C. Gangloff Westinghouse Electric Corporation P. 0.

Box 355 Pittsburgh, Pennsylvania 15230 Michael R. Klein, Esq.

Wilmer, Cutler 8 Pickering 1666 K Street, N.

W.

Washington, D. C.

20006 David F. Fleischaker, Esq.

Suite 709 1735 Eye Street, N.

W.

Washington, D.'.

20006 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Coneission Washington, D.C.

20555 Mr. Thomas S.

Moore Atomic Safety and Licensing Appeal Board U. S..Nuclear Regulatory Commission Washington, D.C.

20555 Marjorie Nordlinger, Esq.

Office of the General Counsel U. S. Nuclear Regulatory Commisssion Washington, D.C.

20555

6 REQUEST FOR ADDITIONAL INFORMATION AND STAFF POSITION Diablo Can on Units 1

& 2 260. 0 QUALITY ASSURANCE BRANCH 260.11 260.12 260.13 260.14 260.15 260.16 The August 1973 version of Regulatory Guide 1.58 was referenced in our item 260.1(i) and, therefore, in your response to this letter.

Revision 1

of Regulatory Guide 1.58 was issued in September 1980.

Therefore, revise the commitment from Revision 0 to Revision 1 of this Regulatory Guide or provide an alternative for our evaluation.

You will note that the new regulatory positions of this guide are applicable to operating plants and plants under construction.

The response to 260.4 did not respond to 260.4h, "Quality Control under the

flanager, Nuclear Projects."

Therefore, describe the responsibilities of the quality control organization under the Manager, Nuclear Projects as they impact on the QA program for Diablo Canyon during the operations phase.

Also indicate the number of supervisory and technical personnel in this quality control organization.

Also update the response to item 260.4f.

Clarify that the "audits by the Quality Assurance Department to determine the overall effectiveness of the quality assurance program" (per Section 17.2.18 of the FSAR) include audits at least annually of each PG&E quality control organization as listed in item 260.4.

The response to 260.8 indicates that the Materials Department, the Engineer-ing Services Department, and the Plant Staff can place purchase orders and contracts with suppliers.

Normally, such actions are under a procurement organization only.

Describe the controls which the PG&E Materials Manager has over purchase orders and contracts placed by the Engineering Services Department and those placed by the Plant Staff.

The second paragraph of'ection 17.2.4 at the bottom of page 17.2-18 of the Diablo Canyon FSAR indicates that approved suppliers must be reviewed and approved by the Quality Assurance Department only "if a quality assurance program is required."

It.is the staff's position that each supplier of safety-related items or services must be reviewed and approved by the Quality Assurance Department.

Commit to comply with this position or pro-vide justification for not doing so for our evaluation.

The response to 260.10 indicates that quality control requirements are included in procedures and policies on performance qualification tests for welders.

Verify that the quality control requirements are administrated by a PG&E quality control organization or provide an alternative for our evaluation.

Section 17.1.2.2 of the standard format (Regulatory Guide 1.70) requires the identification of safety-related structures,

systems, and components (9-list) controlled by the gA program.

You are requested to supplement and clarify the Diablo Canyon g-list in Table 3.2-4 of the FSAR in accord-ance with the following:

a.

The following items do not appear on the g-list (FSAR Table 3.2-4).

Add the appropriate items to the g-list and provide a commitment that the remaining items are subject to the pertinent require-ments of the FSAR operational quality assurance program or jus-tify not doing so.

1.

Safety-related masonry walls (see IE Bulletin No. 80-11).

2.

Breakwaters.

3.

Leak detection system (see FSAR Section 3.5)

~

4.

Missile barriers which protect safety-related items.

5.

Onsite power system (Class lE).

a)

Electrical penetrations of containment - Non-vital including primary and backup fault current protective devices.

b)

Raceway fire stops and seals.

c)

Emergency light battery packs.

6.

Radiation monitoring (fixed and portable).

7.

Radioactivity monitoring (fixed and portable).

8.

Radioactivity sampling (air, surfaces, liquids).

9.

Radioactive contamination measurement and analysis.

10.

Personnel monitoring internal (e.g., whole body counter) and external (e.g.,

TLD system).

ll.

Instrument storage, calibration, and maintenance.

12.

Decontamination (facilities, personnel, and equipment).

13.

Respiratory protection, including testing.

14.

Contamination control.

15.

Radiation shielding.

16.

Meteorological data collection programs.

17.

Expendable and consumable items necessary for the functional performance of safety-related structures,

systems, and compo-nents (i.e., weld rod, fuel oil, boric acid, snubber oil, etc.).

18.

Measuring and test equipment used for safety-related struc-

tures, systems, and components.

19.

Ground slope east of building complex.

20.

Firewater storage reservoir ponds.

21.

Hydrogen recombiner, including piping and valves.

22.

Containment pressure indication system.

23.

Containment water level indication systems.

24.

Containment hydrogen indication system.

25.

Valve operators for safety-related valves.

26.

Motors for safety-related pumps.

o b.

The following items from the g-list (FSAR Table 3.2-4) need expansion and/or clarification as noted.

Revise the list as indicated or jus-tify not doing so.

Portions of the turbine generator building (sheet

4) which enclose the emergency diesel-generator units and ancillary systems as well as other safety-related components should be under the controls of the operational gA program.

2.

3.

4.

New fuel storage racks (sheet

3) should be under the con-trols of the operational gA program.

Intake structure and conduit (sheet

5) should be under the controls of the operational gA program.

Containment structure

sump, sump screen, and vortex sup-pression should be under the controls of the operational gA program.

5.

6.

7.

8.

Reactor cavity sump pump (sheet

18) should be under the con-trols of the operational gA program.

Clarify that the primary system PORV, safety valves, and PORV block valves and their actuators are included under "Reactor Coolant Systems Valves," (sheet 25).

Clarify that the main steamline safety valves and steamline PORVs and their actuators are included under "Valves for the Above (Main Steam Piping-SG to MSIV) Portion of System" (sheet 23).

Identify the safety-related instrumentation and control sys-tems to the same scope and level of detail as provided in Chapter 7 of the FSAR.

9.

The 250V DC Motor Control Center SD 121 (sheet

36) should be under the controls of the operational gA program.

10.

Circulating water conduits (sheet

5) should be under the controls of the operational gA program.

0

c.

Enclosure 2 of NUREG-0737, "Clarification of THI Action Plan Require-ments" (November 1980) identified numerous items that are safety-related and appropriate for OL application and therefore should be on the g-list.

These items are listed below.

Add the appropriate items to the g-list and provide a commitment that the remaining items are subject to the pertinent requirements of the FSAR operational quality assurance program or justify not doing so.

NUREG-0737 (Enclosure 2)

Clarification Item 1)

Plant-safety-parameter display consol e.

2)

Reactor coolant system vents.

3)

Plant shielding.

4)

Post accident sampl ing capabilities.

5)

Valve position indication.

6)

Auxiliary feedwater system.

7)

Auxiliary feedwater system initiation and flow.

I 8)

Emergency power for pressurizer heaters.

9)

Dedicated hydrogen penetrations.

10)

Containment isolation dependability.

11)

Accident monitoring instrumentation.

12)

Instrumentation for detection of inadequate core-cooling.

13)

Power supplies for pressurizer relief valves, block valves, and level indicators.

14)

Automatic PORV isolation.

15)

Automatic trip of reactor coolant pumps.

16)

PID controller.

17)

Anticipatory reactor trip on turbine trip.

18)

Power on pump seals.

19)

Emergency plans.

20)

Emergency support facilities.

21)

Inplant I2 radiation monitoring.

22)

Control-room habitability.

I.D.2 II.B.1 II.B.2 II.B.3 II.D.3 II.E.1.1 II.E.1.2 II.E.3.1 II.E.4.1 II.E.4.2 II.F.1 II.F.2 II.G.1 II.K.3(1)

II.K.3(5)

II.K.3(9)

II.K. 3 (1 2)

II.K.3(25)

III.A.1.1/III.A.2 III.A.l. 2 III.D.3.3 III.D.3.4

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