ML20031E558
| ML20031E558 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/07/1981 |
| From: | Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8110160112 | |
| Download: ML20031E558 (21) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
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BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 4g Ob Dn.
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275 0.L.
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50-323 0.L.
(Diablo Canyon Nuclear Power
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s Plant, Units 1 and 2)
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JOINT INTERVENORS' SECOND SET OF
" Nm INTERROGATORIES AND REQUEST
/
FOR PRODUCTION OF DOCUMENTS 4,
g TO PACIFIC GAS AND ELECTRIC COMPANY
,o t I.
Interrogatories Please use the same instructions as those given in Joint Intervenors' first set of interrogatories to Pacific Gas and Electric Company ("PGandE" or " Applicant").
Joint Intervenors' contentions 10 and 12 are the contentions submitted in the low power proceeding and ordered by the Commission on September 21, 1981 to be included in the Diablo Canyon full power proceeding.
29.
Explain the present Applicant position on Joint Intervenors' contention 10, regarding pressurizer heater design, and state each and every fact on which that position is based.
30.
Does the current position differ from the position of the Applicant in any prior proceedings?
If so, identify the proceeding (s), explain the prior position, and explain the O}Q[2O y
t
basis for the change in position.
31.
Identify any officers or employees of, or consultants to, the Applicant who dissent from the present Applicant position on Joint Intervenors' contention 10.
Explain the reasons for which any such person dissents.
32.
Identify tie specific sections and page numbers of the FSAR for Diablo Canyon and the NRC Staff's SER and SER Supplements for Diablo Canyon, which are relied upon in formulating the Applicant position on Joint Intervenors' contention 10.
33.
Identify all sections and page numbers of the FSAR, SER, and SER Supplements which contain subject matter pertaining to Joint Intervenors' contention 10.
34.
The Staff has recognized that the " maintenance of natural circulation capability is important to safety (and) depends on the maintenance of pressure control (which) is normally achieved through the use of pressurizer heaters."
NUREG-0578, p. A-2.
(a)
Do you agree?
(b)
Explain why pressurizer heaters s.' their associated controls are not classified as " components important to safety," as discussed in GDC 1/ and the Introduction to Appendix A to CFR Part 50.
35.
Explain in detail whether and in what manner the following design criteria would be met with respect to the pressurizer heater and its associated controls.
a)
GDC 22 (diversity) b)
GDC 2 and 4 (seismic and environmental qualification) - - - - -
c)
GDC 10 (automatic initiation) d)
GDC 3 and 22 (separation and independence) 36.
Specify precisely under what conditions the pressurizer heaters will be relied upon at Diablo to:
(a) regulate and/or control pressure; (b) initiate and/or maintain natural circulation; (c) mitigate the consequences of inadequate core cooling; (d) stabilize the reactor in post-accident conditions; (d) any other functions performed by the pressurizer heaters.
37.
Assuming inoperability of the pressurizer heaters, specify in detail each and every means, system, and/or component available at Diablo Canyon to perform the functions listed in Interrogatory No. 36 under the conditions described in your response to that interrogatory.
State each and every fact upon which you base your contention that such other means, systems, and/or components can adequately perform the functions listed.
38.
Specify precisely each and every way in which the pressurizer heaters and associated controls at Diablo Canyon do not meet the safety-grade design criteria set forth in Appendix A to 10 C.F.R. Part 50, and list each design criteria not complied with.
39.
Describe in detail what changes, if any, have been made in the oesign, contruction, installation, or operation of the pressurizer heaters and associated controls at Diablo Canyon since the TMI-2 accident in March 1979.
With respect to any changes or alterations, specify how, if at all, they are expected or intended to enhance the reliability of the components and/or safe operation of the plant, and state each and every fact upon which your response is based.
40.
Describe in detail what you consider to be the implications, if any, of the experience at TMI-2 in March 1979 with respect to the design, installation, maintenance, and/or operation of the pressurizer heaters and associated controls at Diablo Canyon.
State each fact upon which your response is based.
41.
With respect to the pressurizer heaters and associated controls at Diablo Canyon, specify in detail:
(a) their precise location in Units 1 and 2; (b) the precise specifications to which they were ordered and/or designed and any differences between the design specifications on the one hand and the heaters and associated controls as installed on the other; (c) their manufacturer; (d) the precise location of all seismic-related supports, hangers, snubbers, etc., which are attached to, relate to, or in any way could affect operation of the heaters, associated controls, and/or associated cables, electrical or otherwise; (e) the precise polar position and elevation and coordinate location with respect to tl.e center of the containment at which the cables for the pressurizer heaters cross the annulus in Diablo Canyon, Unit 1.
d 42.
List and describe in detail all analyses and tests conducted by you, your agents, or your consultants with respect to the pressurizer heaters and associated controls.
Specify:
(a) the person or entity conducting the analyses or tests; (b) the purpose (s) of the analyses or tests; (c) the rauge of test conditions or conditions assumed in the analyses; (d) the specifications of the components tested or analyzed; (e) the results of the tests or analyses; (f) any other tests or analyses planned to be conducted prior to full power operation.
43.
State whether you contend that the pressurizer heaters and associated controls at Diablo Canyon should be classified as important to safety and required to meet all applicable safety-grade design criteria, and state each and every fact upon which your response is based.
44.
Describe what modifications would have to be made in the Diablo Canyon pressurizer heaters and associated controls to bring them into compliance with all applicable safety-grade design criteria.
Estimate the minimum time period necessary to make those modifications, and state each and every fact upon which your estimate is based.
45.
Specify precisely (a) which Emergency Operating Procedures for Diablo Canyon include the use of pressurizer heaters and (b) which require that the heaters be switched to the on-site power supplies.
46.
Explain the present Applicant position on Joint Intervenors contention 12, regarding valve design, and state each and every fact on which that position is based.
47.
Does the current position differ from the position of the Applicant in any prior proceedings?
If so, identify the proceeding (s), explain the prior position, and explain the basis for the change in position.
48.
Identify any officers or employees of, or consultants to, the Applicant who dissent from the present Applicant position on Joint Intervenors' contention 12.
Explain the reasons for which any such person dissents.
i 49.
Identify the specific sections and page numbers of the FSAR l
for Diablo Canyon and the NRC Staff's SER and SER Supplements for Diablo Canyon, which are relied upon in forumlating the Applicant position on Joint Intervenors' contention 12.
50.
Identify all sections and page numbers of the FSAR, SER, and SER Supplements which contain subject matter pertaining to Joint Intervenors' contention 12, 51.
Does the Applicant agree that proper operation of PORVs, associated block valves and the instruments and controls for these valves is essential to mitigate the consequences of accidents?
Explain your response fully.
52.
Does the Applicant agree that failures of these valves, instruments and controls can cause or aggravate a LOCA?
Explain your response fully.
-53.
Provide the justification for the failure to classify power operated relief valves (PORVs) and associated block valves,.
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and their respective instruments and controls as " components important to safety," requiring compliance with safety-grade design criteria.
54.
Explain how the motive and control components of the PORVs and their associated block valves and the vital instruments shall be supplied by the on-site emergency power source when offsite power is not available without degrading the capacity, capability and reliability of emergency power in violation of GDC 17.
55.
How ha'fe the devices through which motive and control power components for the PORVs and their associated block valves are connected to emergency buses been qualified in accordance with safety-grade requirements?
56.
With respect to the valves, instruments, and controls cited in contention 12, list each and every General Design Criterion in Appendix A to 10 C.F.R. Part 50 which is not complied with, and describe precisely in what respects those valves, instruments, and controls do not comply.
57.
Describe precisely each and every function of the PORVs at Diablo Canyon, and for each such function, specify in detail the operating conditions in which the PORVs would be relied upon to perform that function.
I 58.
Describe precisely each and every function of the block
]
valves at Diablo Canyon, and for each such function, specify in detail the operating conditions in which the block valves would be relied upon to perform that function. '
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l 59.
Specify precisely which Emergency Operating Procedures for I
Diablo Canyon include the use of (a) PORVs and (b) block valves.
I 60.
Describe in detail what modifications would have to be made in the PORVs, block valves, instruments, and controls referred to in contention 12 to bring them into compliance with all applicable safety-grade design criteria.
Estimate the minimum time period necessary to make thore modifications, and state each and every fact upon which your estimate is based.
61.
Describe in detail the current status of the EPRI valve performance testing program.
In your response. state:
(a) when the relief and safety valve testing will be completed;.
(b) under what conditions (e.g.,
transition flow, full water flow, saturated steam, etc.) have the relief and safety valves been tested to date; (c) whether any of the relief and safety valves tested have failed, suffered galling, or been in any way damaged during the testing, and, if so, describe in detail the l
circumstances of such occurrences; (d) why the relief and sa$lety valve testing program completion date has been delayed and when the program is now scheduled to be completed; (e) whether an EPRI block valve testing program is planned and, if so, when it will be completed; i
_a_
(f) other than the block valve failures discussed at the Diablo Canyon low power test hearing in May 1981, whether any of the block valves tested have failed, suffered galling, or been in any way damaged during the testing, and, if so, describe in detail the circumstances of such occurrences; (g) whether PGandE has submitted to the NRC a correlation or other evidence to substantiate that the salves tested in the EPRI program demonstrate the functionability or the relief and safety valves installed at Diablo Canyon, and, if so, describe that correlation or other evidence in detail; (h) to what extent, if at all, the control circuitry, piping, and supports associated with the Diablo Canyon relief and safety valves have been qualified, and, if so, describe precisely how they have been qualified and the results of any related tests or analyses; (i) when the " correlation" referred to in subpart (g) of this interrogatory will be submitted to the NRC.
62.
On August 19, 1981, an emergency planning exercise for Diablo Canyon was held in San Luis Obispo.
Based on your involvement in that exercise and your knowledge of the involvement of other persons, officials, agencies, or other entities, describe the exercise in detail and include in your response at least the following information:
(a) a detailed description of the exercise scenario employed, including the sir.aulated events, time period l
and locations involved; 1
(b) the number of persons participating in the drill, 2
I including the specific company, agency, or other entity I
represented, if any,-
and the extent and nature of their involvement; (c)
(1) the number of PGandE personnel assumed or deemed to have been evacuated during the course of the exercise; (2) the number of PGandE employees actually evacuated, and (3) when such evacuation was begun'and when completed; (d)
(1) the number of non-PGandE persons (e.g., members of s
the public) assumed or deemed to have been evacuated and/or sheltered during the course of the exercise, (2) the number of such persons actually evacuated and/or sheltered, and'(3) when such evacuation was begun and when completed; (e)
(1) the number of ambulances assumed or deemed to have been utilized during the course of the exercise and (2) the number of ambulances actually utilized; (f)
(1) the number of simulated injured persons assumed or deemed to have been transported to and treated at French Hospital during the course of the exercise and (2) the number of simulated injured persons actually transported 4
and treated at French Hospital; (g)
(1) the number of simulated injured persons assumed or i
deemed to have been transported to and treated at St.
Francis Hospital in San Francisco during the course of 1
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the exercise and (2) the number of simulated injured persons actually transported to and treated at St.
Francis Hospital; (h)
(1) the number of residences and/or households in San Luis Obispo and Santa Barbara Counties assumed or deemed to have been contacted durina the exercise, (2) the number and location of such residence and/or households actually contacted, and (3) the time period required to contact such residences and/or households; (i)
(1) the number of automobiles assumed or deemed to have utilized Highway 101 as an evacuation route during the course of the exercise and (2) the number of automobiles which actually utilized Highway 101 as an evacuation route; (j)
(1) the number of persons or automobiles assumed or deemed to have utilized Highway 1 as an evacuation route during the course of the exercise and (2) the number of persons or automobiles.which actually utilized Highway 1 as an evacuation route; (k)
(1) the number of persons or automobiles assumed or deemed to have utilized Avila Road as an evacuation route during the course of the exercise and (2) the number of persons or automobiles which actually used Avila Road as en evacuation route; (1)
(1) the number of persons assumed or deemed to have been i
notified of a radiological emergency occurring at Diablo Canyon during the course of the exercise, (2) the number.
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I and location of persons actually notified of such j
emergency, and (3) the time period required to complete such notification.
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(1) the number of emergency response personnel (i.e.,
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monitoring, etc.) assumed or deemed to have been 3
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i mobilized and/or dispatched during the course of the i
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exercise and (2) the number of such personnel actually I
mobilized and/or dispatched; i
(n)
(1) the protective actions assumed or deemed to have been taken within the plume exposure pathway EPZ by i
public officials, emergency respcase personnel, and l
members of the public during the course of the exercise I
and (2) the protective actions actually taken by such persons within the area specified; (o)
(1) the protective actions assumed or deemed to have been taken within the ingestion pathway EPZ by public t
officials, emergency response personnel, and members of l,.
the public during the course of the exercise and (2) the l
protective actions actually taken by such persons within the area specified; j
(p)
(1) the number and location of radiological monitoring samplings sssumed or deemed to have been taken during the course of the exercise and (2) the number and location of such samplings actually taken; (q)
(1) the number of persons involved in the exercise and (2) the number of persons reasonably expected to be 4
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involved in an actual radiological emergency at Diablo Canyon; (r)
(1) the number of automobile accidents or collisions, if any, assumed or deemed to have occurred on main evacuation routes during the course of the exercise and (2) the number of such accidents or collisions reasonably expected to occur in the event a full scale evacuation is ordered in response to an actual radiological emergency at Diablo canyon; (s)
(1) the types and quantities of emergency response equipment (e. g., communications equipment, respiratory equipment, protective clothing, monitoring equipment, vehicles, helicopters, signs, placards, medical equipment, etc.) assumed or deemed to be available or to have been used during the course of the accident and (2) the types and quantities of such equipment actually available or used; (t)
(1) the number of media personnel present and inquiries-from the public received during the course of the exercise and the number of such personnel likely to be present and inquiries from the public likely to be received in the event of an actual radiological emergency at Diablo Canyon; (u) the names of all local and state officials, agencies, offices, and/or other entities actually notified as part of the exercise, by telephone or otherwise, regarding the simulated emergency at Diablo Canyon; the (
1 approximate time of each such notification; the precise language of the notification message; the name of the person who notified such cfficials and/or agencies; the i
names of each person who received the notice; and the i
time period required to complete notification of all j
such persons.
63.
Based on your involvement in the August 19, 1981 emergency planning exercise and your knowledge of the involvement of j
other persons, officials, agencies, or other entities in that exercise, provide a detailed chronology of all actions taken by the participants in connection with the exercise, and include in that chronology at least'the following i
information:
(a) the time each action was taken; (b) the name of the person taking the action; (c) the office, agency, or other entity represented by that person; l
j (d) any problems or difficulties encountered by that person j
in taking the action; (e) the location of the action, including, for example, point of origin and point of destination; (f) any equipment (i.e., vehicles, walkie-talkie, radio, protective clothing, etc.) utilized in taking the action; (g) the consequences resulting from the action.
64.
Explain in detail how the exercise included such things as 4
1 (a) simulated casualties; t
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(b) offsite fire department assistance; (c) rescue of personnel; (d) use of protective clothing; (e) deployment of radiological monitoring teams; and (f) public information and notification acti*.*ities.
65.
State how, if at all, the August 19 exercise simulated and/or tested for the complicating effects of a major earthquake on emergency response capability at Diablo Canyon.
66.
State what, if any, critical emergency response equipment (i.e., vehicles, communications systems and lines, monitoring equipment, notification sirens, etc.) were assumed to fail during the course of the August 19 exercise.
67.
State what, if any, evacuation routes (a) for the site and (b) for the plume exposure pathway EPZ were assumed to be fully or partially blocked during the course of the August 19 exercise.
68.
In light of the information and experience gained from the August 19 exercise, what revisions, changes, or alterations, if any, will be made in the following documents prior to full power operation of Diablo Canyon:
(a) the Diablo Canyon on-site emergency plan and emergency procedures; (b) the San Luis Obispo County emergency and evacuation plans; (c) the Sta*e of California emergency plan; (d) the San Luis Obispo County Sheriff's " plan" (Board Exh..-
t 5 at Diablo Low Power Test hearing).
l II.
Request for Production of Documents Please use the same instructions as those given in Joint Intervenors' first request for production of documents to PGandE, except that the date for production shall be on or before November 6, 1981, unless another time is agreed upon.
Each document is relevant to Joint Intervenors' admitted contentions.
The term " document" as used herein is consistent with the definitions set forth at page 2 of Joint Intervenors First Set of Interrogatories and Request for Production of Documents to Pacific Gas and Electric Company, previously filed I
herein.
1.
All documents identified in response to Interrogatory Nos. 29-68 supra.
2.
All documents in the possession, custody or control of PGandE or its officers, employees, agents, or consultants which relate in anyway to the emergency planning exercise held on Aunust 19, 1981 in San Luis Obispo County.
Without limitation of the scope of this request, documents requested include:
(a)
All evaluations, assessments, memoranda, notes,
.fitiques or other documents which assess, or in any way relate to the August 19 exercise.
(b)
All. notes, photographs, memoranda, or other documents which record or relate in any way to., _. _ _.. -. _ _
actions or events which occurred in preparation j
for, during, or as a consequence of the August 19 exercise.
(c)
All documents which assess or in any way relate to whether the scenario for the August 19 exercise was complete and adequate to test the emergency response capabilities of PGandE, the County, and/or the State.
3.
All documents in the possenaion, custody, or control of PGandE or its officers, employees, agents, or consultants which relate in any way to, or were prepared in connection with or response to, the NUREG-0737 item II.D.1 requirement that the licensee submit to the NRC "a correlation or other evidence to substantiate that 3
the valves tested in the EPRI or other generic test program demonstrate the functionability of as-installed primary relief and safety valves." (NUREG-0737, at II.D.1-2.)
4.
All documents in the possession, custody, or control of PGandE or its officers, employees, agents, or consultants which relate in any'way to the reliability, design, and/or classification of (a) the pressurizer heaters and associated controls installed at Diablo Canyon or (b) such components of a design, model, or type similar to those installed at Diablo Canyon.
5.
All documents in the possession, custody, or control of PGandE or its officers, employees, agents, or
_17_
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consultants which relate in any way to the reliability, design, and/or classifjestion of (a) the Diabl7 Canyon relief valves, associated block valves, and the instruments and controls for those valves or (b) such componcets of a design, model, or type similar to those installed at Diablo Canyon.
1 Dated:
October 7, 1981 Respectfully submitted, JOEL R. REYNOLDS, ESQ.
JCHN R. PHILLIPS, ESQ.
Center for Law in the Public Interest 10203 Santa Monica Blvd.
Fifth Floor Los Angeles, CA 90067 DAVID S. FLEISCHAKER, ESQ.
17 35 Eye Street, N.W.
Washington, D.C. 20006 (202) 638-6070
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i By.
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[3/ELR. Q#YNDLDS j
Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESSRVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER 18-w
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION il BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
)
In the Matter of
)
)
1 PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
1
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
I
)
CERTIFICATE OF SERVICE j
j I hereby certify that on this 7th day of October, 1981, I have served copics of the foregoing JOINT INTERVENORS' SECOND SET OF f
INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY, mailing them through the U. S. mails, first class, costage prepaid.
Nunzio Pallodino, Peter A. Bradford, Chairman Commissioner i
U.S. Nuclear Regillatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Victor Gilinsky, John F. Ahearne, Commissioner Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
e Washington, D.C.
20555 Washington, D.C.
20555 Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555
Richard S. Salzman, William Olmstead, Esq.
Chairman Marc R.
Staenberg, Esq.
l
' Atomic Safety & Licensing Edward G. Ketchen, Esq.
Appeal Board Office of the Executive Legal U.S. Nuclear Regulatory Director - BETH 042 Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Dr. W.
Reed Johnson Atomic-Safety & Licensing Nancy Culver Appeal Board 192 Luneta U.S. Nuclear Regulatory San Luis Obispo, CA 93401 Commission Washington, D.C.
20555 Mr. Fredrick Eissler Scenic Shoreline Preservation Dr. John H.
Buck Conference, Inc.
Atomic Safety & Licensing 4623 More Mesa Drive Appeal Board Santa Barbara, CA 93105 U.S. Nuclear Regulatory Commission Sandra A. Silver Washington, D.C.
20555 1760 Alisal Street San Luis Obispo, CA 93401 Admin. Judge John F. Wolf, Chairman Gordon Silver Atomic Safety & Licensing 1760 Alisal Street Board San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission David S. Fleischaker, Esq.
Washington, D.C.
20555 P. O. Box 1178 Oklahoma City, Oklahoma 73101 Glenn O. Bright Atomic Safety & Licensing Bruce Norton, Esq.
Board 3216 N. Third Street U.S. Nuclear Regulatory Suite 202 Commission Phoenix, Arizona 85012 Washington, D.C.
20555 Mr. Yale I.
Jones, Esq.
Dr. Jerry R. Kline 100 Van Ness Avenue Atomic Safety & Licensing 19th Floor Board San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Andrew Baldwin, Esq.
Washington, D.C.
20555 Friends of the Earth 124 Spear Street Docket & Service Branch San Francisco, CA 94105 Office of the Secretary U.S. Nuclear Regulatory Harry M. Willis, Esq.
Commission Seymour and Willis Washington,sD.C. 20555 601 California Street e
Suite 2100 San Francisco, CA 94108 1,
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7 Mrs. Raye Fleming Janice E. Kerr, Esq.
D Lawrence Q. Garcia, Esq.
Shell Beach, CA 93449 J. Calvin Simpson, Esq.
California Public Utilities MHB Technical Associates 1
llamilton Avenue 52 Stat uilding S
e 350 McAllister Street San Jose, CA 95125 San Francisco, CA 94102 ar e urger Malcolm H. Furbush, Esq.
Vice President and General O
x San Luis Obispo, CA 93402 Ph pA Crane, Esq.
Pacific Gas & Electric Company Byran Georgiou, Esq.
- fhe
$nhr is CA 941 enr State Capitol Building Arthur C.
Gehr, Esq.
Sacramento, CA 95814 Snell & Wilmer l
3100 Valley Center Lawrence Coe Lanpher, Esq.
I
. PhoenJ.X, Arizona 85073 Hill, Christopher & Phillips 1900 M Street, N.W.
Washington, D.C.
20036 O
TJ OEL R. 4(EFNOLDS, ESO.
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