ML20032C212
| ML20032C212 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/02/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-OL, NUDOCS 8111090482 | |
| Download: ML20032C212 (30) | |
Text
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00LKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 11 IDf -4 P4 :47 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRElARY DOCKETtHG & SERVICE BRANCH In the Matter o f
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PACIFIC GAS AND ELECTRIC COMPANY )
Docket Nos. 50-275 C.L.
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50-32 3 0.L (Diablo Canyon Nuclear Power
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e$}rn\\ Rf]fg Plant, Units Nos. 1 and 2)
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(Low Power Pro g) 9 atC0Vtp RESPONSE OF GOVERNOR EDMUND G. BROWN, JR, p}
" NOVO 619g7, h TO SECOND SET OF INTERROGATORIES
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OF NRC STAFF A
f On October 14, 1981, the NRC. Staff propounded interrog-atories to Governor Brown.
We hereby respond to those discovery reques ts.
Interrogatory 1 Name each piece of equipment associated with Diablo Canyon's pressurizer heaters that Governor Brown believes should be required to meet all applicable safety-grade design criteria, including but not limited to diversity (GDC 22),
seismic and envirc nmental qualification (GDC 2 and 4),
automatic initiation (GDC 20), separation and independence (GDC 3 and 22), quality assurance (GDC 1), adequate, reliable on-site power supplies (GDC 17) and the single failure criteria, b503 sn
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Response 1 All components of the pressurizer heater system, including supports and interconnecting wiring snould be required.to meet 1
the applicable safety-grade design criteria.
PG6E has responded that only that equipment associated with the capa-bility of obtaining power from the on-site emergency power supply needs to meet GDC 10, 14, 15, 17 and 20 of )ppendix A to 10CFR50.1/
This is further defined in PGSE's Answer to Interrogatory No. 41 as the 4 80 volt vital breakers.52-1G-72 5 -lH-74, control switches, :7d cable between the vital bus and the breakers. /
This implies then that all of the rest of the pressurizer heater syste'm has not been designed to meet the safety-grade design criteria lis ted above.
The remainder o f the sys tem, the re fo re, consists of the heaters themselves and their associated controls, along with interconnecting wiring and supports.
See PGGE January 26, 1981 submittal to NRC on Full Power License Requirements and associated Figures II.E.3.1-1 5 -2 for diagrams showing the components contained within the pressurizer heater system.5/
1/. Applicant Pacific Gas 4 Electric Cumpany's Answers to Joint Intervenor's Second Set of Interrogatories, page 1 5 2.
2/ Ibid 1/, pages 16 6 17.
T/ Philip A. Crane to Frank J. Miraglia", January 20, 1981, pages II.E-10 through 19.
Interro gatory 2 What is the basis for Governor Brown's belief that the equipment identified in the answer to Interrogatory #1 should be required to. meet all applicable safety-grade criteria?
Response 2 See Response A.8 to NRC Staff's. Request for Admissions.
In te rro ga tory 3 For each piece of equipment identified in the answer to Interrogatory #1, identify a) the design criteria Governor Brown believes it should be required to meet; and b) the applicable NRC regulation (s) or other statutory provision (s) which Governor Brown believes requires the equipment to meet the criteria identified in his response to 3(a).
Response 3 See Response 4 below.
Interrogatory 4 Identify the NRC regulation (s) or other statutory provision (s)
. hich G,vernor Brown believes requires PGSE to have Diablo w
Canyon's pressurizer heaters and associated controls meet all applicable safety-grade design criteria, including but not limited to diversity (GDC 22), seismic and environmental qualification (GDC 2 and 4), automatic initiation (GDC 20),
separation and independence (GDC 3 and 22), quality assurance (GDC 1), adequate reliable on-site power supplies (GDC 17) and the single failure criterion.
Response 4 10CFR50. 55a (a) (1) requires that s tructures, sys tems,
and components shall be designed, fabricated, erected, constructed, tes ted, and inspected to quality standards commensurate with the importance o f the safety function to be performed.
There can be no disagreement that all systems at Diablo Canyon must meet the applicable safety-grade design criteria.
There may be some disagreement on what is applicable.
If that is the thrust of this interrog-atory, see Response 9 for a discussion on Diablo Canyon's failure to comply with applicable criteria.
For specific reference to applicable codes, s tandards, etc., the NRC Standard Review Plan identifies the acceptance criteria for safety related instrumentation and control equipment. 1/
The pressurizer heaters and controls should be evaluated in accordance with these criteria.
A copy of this Table is attached.
Interrogatory 5 Specifically state why Governor Brown believes the equipment associated with Diablo Canyon's pressurizer heaters should be classified as " components important to safety."
i 1/ NUREG 75/087, Sec. tion 7, Table 7-1..,,._.__..
Response 5 See Response A.8 to NRC Staff's Request for Admissions.
Interrogatory 6 Contention 10 alleges that the heater groups should be required to meet certain GDC's identified in the contention.
How does Governor Brown believe the applicant's proposal to connect two out of four of the heater groups to Diablo Canyon's present on-site emergency power supplies fails to provide an equivalent or acceptable level of protection to the level of protection which would be provided if the identified GDC's were met?
Response 6 The proposed arrangement addresses only the reliability of power supply to the pressurizer heaters.
The heaters and associated equipment, ins trume n ta tion, controls, and supports are s till subject to failure's introduced through incomplete attention and compliance with the referenced safety-grade criteria.
Interrogatory 7 Under NRC regulatiou(s), what general design criteria does Governor Brown believe must be met by PGSE in order to connect two out of four of the heater groups to the present on-site emergency power supplies?
Response 7 All of 'the applicable design criteria mus t be met.
See SRP Table 7.1 attached hereto for specific GDC references. _
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Interro gato ry 8 Specify how Governor 2caan believes PGSE has failed to comply with.the NRC regulation (s) identified in the answei to Interrogatory #4 and with the general design criteria identified in the answer to Interrogatory #7.
Response 8 See Responses 4 and 9 Interrogatory 9 Specify how Governor Brown believes the pressurizer heaters and' associated controls at Dicblo Canyon fail to 4
, comply kith ('GDC 20) " automatic initiation"; (GDC 17),
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" reliable on-site power supplies"; (GDC 22), " protection system independence"; (GDC 2), "seismi.c and environmental qualification"; (GDC 4), " seismic and environmental qualifi-cation"; (GDC 3) " fire protection"; and (GDC 1) " quality standards and records" in 10 C.F.R. 6 50, Appendix A.
Response _9 Contention 10 does not s tate that the pressurizer heaters and associated controls fail to comply with specific details in the General Design Criteria but rather that this equipment i
has not been classified as safety-grade and, therefore, has not been required to meet the s afe ty-grade design criteria lis ted.
There is obviously no way to evaluate that compliance since PGSE has not submitted any detailed information on how these l,
l components do or do not meet the specific criteria.
This Interrogatory is therefore premature until sufficient detailed i;'
_information is available to evaluate compliance.
However, it is likely that non-compliances exist for the followi.ig reasons:
a.
GDC 20 requires, among other things, that the protection system shall be. designed "to initiate the operation of systems important to s afety. "
Standard Review Plan Table 7-1 extends the applicability of GDC 20 to all instrumentation and control functions important to safety. 1/
PG6E's January. 26, 1981 response to Full Power i
F License Requirements describes the manual procedure necessary for transferring the pressurizer heater power supply onto the ESF buses.
This requires the dispatch of an operater.3to a location three floors down in the Auxiliary Building and verbal confirmatlun that such action has been taken. 2,/
This complex procedure does not meet the automatic initiation requirements of GDC 20.
b.
None of the pressurizer heater system, other than the breakers, switches and portion of the bus connection cables identified in Response 1, have been qualified in accordance with GDC 2 (seismic and environmental 11/ NUREG 75/087, Section 7, Table 7-1.
J/ Philip A. Crane to Frank J. Miraglia, January 26, 1981, page II E-14. I
4 qualification)- GDC 22 (protection system independence,
" separation") on GDC 3 (fire protection.
c.
Since these components have not been classified as-important to safety, the requirement of GDC 1 (Quality standards and records) do not appear to have been applie d.
Interrogatory 10 1
State specifical? y the reasons why Governor Brown believes that PG6E's proposal to connect two out of four of the heater groups to Diablo Canyon's present on-site emergency power supplies fails to protect the public health and safety and give the reasons why Governor Brown believes that: the equipment associated with Diablo Canyon's pressurizer heaters fails to i
protect the public health and safety.
Response 10 The proposed system does not provide adequate assurance that the mitigating systems will be available and that the plant operators will be able to respond to the needs for mainte nance of natural circulation capability.
The failure to assure this capability imposes. undue risk to public health and s afety.
Interrogatory 11 What additional information does Governor Brown believe should be provided by PGSE to insure that the equipment i -.
associated with Diablo Canyon's pressurizer heaters is adequate to protect the public health and safety and that the proposal to connect two out of four of the heater groups. to Diablo Canyon's present on-site emergency power supplies is adequate to protect the public health and safety?-
Response 11 Demonstrate that the heaters and associated controls h'.ve been classified as " components important to s afety" and that they meet the.jplicable safety grade design criteria.
Interrogatory 12 Specify the NRC regulation (s), safety-grade criteria, NUREG(s), Standard Review Plans, Regulatory Guide (s) or statutory provision (s) Governor Brown believes the pressurizer power-operated relief valves (PORVs), safety valves and block valves at Diablo Canyon are required to meet.
Response 12 Diablo Canyon Safety Valves - are classified as safety-grade and subj ected to the requirements of Design Class I,
Code, Class I as described in FSAR Tables 3.2-1, 3.2-2, 3.2-3, 4
and 3.2-4.
Similarly, they were identified in the Hosgri Amendment to the FSAR as having been seismically tested
-(See -Hosgri Seismic evaluation, VOL. III, Table 7-7 " Seismic Qualification Minimum Required Active Valves for Hot Shutdown and/or Cold Shutdown.")
The PORV's and Block Valves are not specifically identified in the FSAR Section 3.2 tables but
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they are included in the Hosgri Seismic Evaluation (Vol. III Table 7.8, " Summary - Seismic Qualification Valves Required for Normal Shutdown and/or Cold Shutdown.")
There. are few other details of the classification and qualification of these three types of valves.
However, proper operation of power operated relief valves, associated block valves and the instruments and controls for these valves is essential to mitigate the consequences of accidents.
In addition, their failure can cause or aggravate a LOCA.
The re fo re, these valves must also be classified as safety grade components and required to meet all safety-grade design criteria.
There is insufficient information to know if the existing valves and their associated equipment meet the necessary requirements to insure reliable performance of their safety function under worst case accident conditions.
Similarly, the associated control and ins truments for f
these valves mus t comply with applica' ole codes, s tandards,
etc.
The NRC Standard Review Plan (NUREG 75/087 Section 7, Table 7-1) identifies the acceptance criteria for safety-related instrumentation and control equipment which should be applied to these components.
A copy of this table is attached.
Until details are provided on how the valves and components meet the above safety and acceptance criteria, there can be no assurance of their adequacy to perfenn properly in all off-normal and accident conditions..
- Interrogatory 13 State specifically the reasons why Governor Brown believes that PG6E has not met the requirements, criteria and guidance stated in the answer to Interrogatcry 12.
Response 13 See Response 12.
Interrogatory 14 Give detailed reasons why Governor Brown believes that Diablo Canyon's PORVs, safety valves and block valves must be classified as components important to s afe ty.
Response 14 1
In addition to the discussion in Response 12, there-are conditions where the block valves and PORVs may individually or collectively cons titut ' a potential break in the reactor coolant pressure boundary.
Failure to operate correctly, in either oper.ing or closing, may cause or aggrevate a small LOCA.
The valves can also play an important role in mitigating the effects of an ATWS accident.
They may also serve as a mechanism for control and/or mitigation of accident conditions when called upon to operate in the bleed and feed mode (in conjunction with Safety Injection).
Components which have this large an impact on pressure boundary integrity, accidents, and safety should be classed as safety-grade..
L Interrogatory 15 Explain every scenario and the probability of occurrence in which Governor Brown believes failure of Diable Canyon's PORVs,. safety vsives and block valves could cause or aggravate-a LOCA or operational transient.
Response 15 See discussion in Response.to Admissions B.1, B.2, B.3, B.7, B.10, B.17 and Interrogatories 12 and 14.
Interro gatory 16 State specifically the reasons why Governor Brown believes that ~the operation of Diablo Canyon's PORVs, safety valves, and block valves are deficient to protect the public health and safety.
Response 16 Under normal circumstance and assuming proper operation of equipment, there may be no concern regarding these valves.
The deficiency in question in contention 12 is the classification i
and qualification of the valves and their associated controls j
and ins trumentation, without which there can be no assurance.
that the public health and safety will be protected in off-normal and accident conditions.
Interrogatory 17 What additional information does Governor Brown believe should be provided by PG6E to insure that operation of Diablo f :
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Response 17 See Response 12.
Interrogatory 18 Name each instrument and control Governor' Brown believes is associated with Diablo Canyon's PORVs and associated block valves.
Response 18 The devices of interest are those used to energize, 4
control or monitor the operation of the PORV and block valves, as set forth on FSAR Figure 3.2-07 (sheet 2 of 4) and Figure 7.3-21 (sheet 1 of 2).
Interrogatory 19 Why does Governor Brown believe the instrument (s) and control (s) identified in the answer to Interrogatory 18 should be classified as safety-graded design criteria?
Response 19 Proper and reliable operation of safety-grade valve
- cannot be. insured unless their associated control and ins tru-mentation is also qualified, designed, ins talled and tes ted according to the applicable safety and acceptance criteria.
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i Interrogatory 20 For each instrument and control identified in the answer to Interrogatory 18, identify the design criteria-Governor Brown believes it-should be required to meet.
Response 20 See Response 12.
Interrogatory 21 Specify how Governor Brown believes the pressurizer PORVs, and safety valves at Diablo Canyon fail to meet (GDC 1),
" quality s tandards and records"; (GDC 14), " reactor coolant pressure boundary"; (GDC 15), " reactor coolant system design";
and (GDC 30), " quality of reactor coolant pressere boundary" in 10 C.F.R. 50, Appendix A.
Response 21 Contention 12 does not s tate that the PORV and block valves and associated controls and ins trumentation fail to comply with specific details in the General Design Criteria but rather that this equipment has not been classified as s afe ty-grade and therefore has not been required to meet the s afe ty grade ' design criteria lis ted.
Until PGSE submits detailed information on how the components do or do not meet the specific criteria, the evaluation suggested' by the interrogatory is no t possible.
This interrogatory is therefore, premature until suf ficient detail is available on which to evaluate compliance.
However, since some valves and components I
are clearly not clas sed as safety-grade, there is a high likelihood that deficiencies would be discovered.
Unless and until che valves' and their associated controls and ins *rumentation are classified as safety-grade and details provided on their compliance wi th the GDC and other acceptance criteria, there is no assurange that the valves will actually meet the subject criteria.
At this. time there is insuf ficient detailed information availab;e to complete the assessment.
4 Interrogatory 22 Specify how Governor Brown believes Diablo Canyon's pressurizer PORVs and pressurizer safety valves fail to meet Standard Review Plan (SRP) 3.9.2, " Dynamic Tes ting and Analyses of Systems,
Components, and Equipment"; (SRP) 3.9. 3., "ASME Code Class 1, 2 and 3 Components, Component Supports, and Core Support Structures"; Regulatory Guide 1.48 " Design limits and loading combinations for seismic Category 1 fluid systems components";
and Regulatory Guide 1.68 " pre-operational and Initial Startup Tes t Programs for Water Cooled Powe r Reactors."
Response 22 See Response 21.
Interrogatory 23 Why does Governor Brown believe the safety-classification as shown in the FSAR. for pressurizer PORV block valves at -Diablo Canyon is not adequate to protect the health and safety of the public?,.. -,
Response 23 Refer to Responses to Admissions B.1, B.2, B.3, B.7, B.10, B.17 and Interrogatories 12 and 14.
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Interrogatory 24 What additional information does Governor Brown believe should be provided by PGSE to insure that the pressurizer PORV block valves at Diablo Canyon are adequate to protect the health and safety of the public?
Response 24 See Response 21.
Interrogatory 25 What does Governor Brown believe that designating block valves as safety-related equipment is not adequate to protect the health and safety of the public?
Response 25 The meaning of this sentence is uncertain (e.g. should there be a colon after believe or should "What" be "Why"?).
Assuming the ques tion sho tid s tart with "Why",
the answer is the same as stated earlier.
See, fo r ins tance, Response 21.
Interrogatory 26 What are the reasons why Governor Brown believes that block valves should be designated as safety-grade equipment?
Response-26 This interrogatory has been answered in earlier responses to Admissions and Interrogatories.
See, for ins tance, Response 23. l L
Interrogato ry 27 Explain in detail how Governor Brown believes the o s pressurizer power-operated relief valves, safety valves and PORV block valves should be tested and qualified for correct and reliable operation over the range of accident conditions which the Diablo Canyon plant may experience.
Response 27 This interrogatory has been answered earlier but the main issue is that the full range of environmental conditions be
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covered including where necessary, accidents which are not now considered design basis accidents.
It is also essential that the results be directly applicable to the Diablo Canyon Site and its as-built configuration.
Interrogatory 28 For each of the statements in NRC Staff's Request for Admissions by Governor Edmund G. Brown (October 14, 1980) which i
Governor Brown does not admit, identify the witnes s (es) which l
Governor Brown will present on that issue.
Response 28 l
In a previous filing (dated October 16, 1981) on the Diablo l
Canyon Docket, witnesses have been identified and their qualifications provided.
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Interrogatory 29 l
For each of the statements in NRC Staff's Request for i
Admissions by Governor Edmund G. Brown (October 14, 1980) i l
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which Governor Brown does not admit, explain the basis for Governor Brown's position on that statement including any documents relied upon.
Resconse 29 Fcr each Admission Statement not admitted by the Governor, i
the specific concern has been addressed in the Respanse to the Admission Statement.
Interrogatory 30 What is the basis for Joint Intervenors' belief that,.if-classified as " components important to safety," the pressurizer heaters and valves identified in admitted Contentions 10 and 12 from the low power proceeding must meet the GDCs and other requirements lis ted in those contentions.
Response 30 The Governor is not aware of the Joint Intervenors' belief on this specific point.
Interrogatory 31 State any rule (s), regulation (s) or other s tatute(s) which require equipment or systems designated as " components important to safety" to mee t the GDCs and other requirements listed in l
Contentions 10 and 12 from the low power proceeding.
Response 31 See Response 4.
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Document Requests 1.
Provide all cocuments identified in Governor Brown's answers to Interrogatories 1 through 31 which are not already in the possession of the U. S. Nuclear Regulatory Commission.
2.
Provide all documents within the possession or control of Governor Brown which relate - to the pressurizer. heaters for the Diablo Canyon Nuclear Facility, which are not already in the possession of the U. S. Nuclear Regulatory Commission.
Response to Document Requests All documents referredi to in; the above cresponses -are on the Diablo Canyon docket or are in the public domain or are attached hereto.
Thus, no additional documents are provided.
Respectfully' submitted,
- Byron S. Georgiou Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814'
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Herbert H. Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C.
20036-Attorneys for Governor Edmund G.
Brown, Jr., of the State of California Dated:
November 2, 1981 i
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ATTACHMENT 1 NU REG.75/087
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2 ib STANDARD REVIEW PLAN OFFICE OF NUCLEAR REACTOR REGULATION
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ACCEPTANCE CRITERIA FOR INSTRIMENTATION AND CONTROLS Tabla 7-1 contains the acceptance criteria for the SRP sections of Chapter 7.
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acceptance criteria include the applicable General Design Criteria. IEEE standards, Regulatory Guides, and Branch Technical Positions (BTP) of the Instrumentation and Control Systems Branch (ICSB). The applicability of these criteria to specific sections of Chapter 7 is indicated by an X in the matrix listing of criteria and SAR sections. The BTP listed in Table 7-1 are contained in Appendix 7-A to the Chapter 7 SRP section.
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CRITERIA TITLE APPLICAL1LITY RIMARKS 7.1 7.2 7.3 7.4 7.5 7.6 7.7 1.
10 CFR Part 50 a.
10 LFR 550.34 Contents of Application:
Technical Information X
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10 CFR 550.55a Codes and Standards
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GDC 22 Protection System Independence X
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GDC 24 Separation of Protection and Control Systems X
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8 0
1 3
4 6
0 4
5 6
7 E
2 2
2 2
3 3
3 3
3 4
4 4
4 4
5 5
5 5
5 T
I C
C C
C C
C C
C C
C C
C C
C C
C C
C C
R D
D D
D D
D D
D D
D D
D D
D D
D D
D D
C G
'G G
G C
G G
G G
G G
G G
G G
G G
G G
a b
c d
e f
9 h
i q
r s
t u
v w
x y
z a
b c
d e
f 9
h i
y"yo>
e' l
ll 1
r
e E,
TABLE 7-1 (CONTINUED)
I CRITE P.l A TITLE APPLICABILITY REMARKS-7.1 7.2 7.3 7.4 - 7. 5 7.6 7.7 3.
Institute of Electrical and Electronics Engineers (IEEE)
Standards:
r.
IEEE std. 279 Criteria for Protection Systems See 10 CFR 550.55a(h)
(ANSI ii42.7) for Nuclear Power Generating and Reg. Guide 1.62.
Stations X
X X
X X
X X
b.
IEEE Std 303 Criteria for Class IE Electric See Reg. Guide 1.32.
Systems for duelear Power Generating Stations X
X X
X c.
IEEE Std 317 Electric Penetration Assemblies See Reg. Guide 1.63.
in Containment Structures for SRP Section 3.11.
Nudear Power Generating Stations X'
X X
X X
X X
d.
IEEE Std. 336 Installation, Inspection and See Reg. Guide 1.30.
Testing Requirements for Instru-mentation and Electric Equipment During the Construction of 7,u Nucit ar Power Generating Stations X
X X
X X
X
.X A?
e.
IEEE Std 338 Criteria for the Periodic Testing See Reg. ruide 1.118.
of Nuclear Power Generating Station Protection Systems X
X X
X X
f.
IEEE Std 344 Guide for Seismic Qualification See Reg. Guide 1.100 (ANSI N41.7) of Class 1 Electrical Equipment SRP Section 3.10.
for Nuclear Power Generating Stations X
X X
X X
X g.
IEEE Std 379 Guide for the Application of the See Reg. Guide 1.53.
Single failure Criterion to Nuclear Power Generating Station Protection Systems X
X X
X X
X X
h.
IEEE Std 384 Criteria for Separation of Class See Reg. Guide 1.75.
IE Equipment and Circuits X
X X
X X
X X
?
?
6
TABLE 7-1 (C0r1TINUED)
CRITERIA TITLE APPLICABILITY REMARKS 7.1 7.2 7.3 7."
7.5 7.6 7.7 f
4.
Regulatory Guides (RG) i a.
RG 1.6 Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution X
X X
X Systems b.
RG1.7 Contrul of Combustible Gas Concentrations in Containnent following a Loss-of-Coolant Accident X
X X
c.
RG l.11 Instrunent Lines Penetrating Primary Reat. tor Containnent X
X X
X X
X d.
hG 1.22 Periodic Testing of Protection System Actuation Functions X
X X
X X
X l
e.
RG 1.29 Seismic Design Classification X
X X
X X
X SRP Section 3.10 g
f.
RG 1.30 Quality Assurance Requirements for the Installad on, inspec-y L
tion, and Testing of Instrumenta-tion and Electric Equipnent -
X X
X X
X X
X g
9 RG 1.32 Use of IEEE Std 308" Criteria for Class IE Electric Systems for Nuclear Power Generating Stations" X
X X
X Use in conjunctiun with h.
RG 1.47 Bypassed,and Inoperable Status Indicatio.i for Nuclear Power X
X X
X X
X Position 3. RG 1.17.
Plant Safety Systems i.
RG 1.53 Application of the Single-failure Criterion to Nuclear Power Plant Protection Systems X
X X
X X
X J.
RG 1.62 Nanual Initiation of Protection Actions X
X X
X X
4 s.
e
1 TABLE 7-1 (CONilidjED)
CRITERIA TITLE APPLICABILITY REMARKS M
7.2 7.3 7.4 7.5 7.6 7.7 k.
RG 1.63 Electric Penetration Assemblies in Containment Structures for Water-Cooled Nuclear Power Plant X
X X
X X
X X
1.
RG 1.68 Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors X
X X
X X
X X
m.
RG 1.70 Standard Fonnat and Content of Safety Analysis Reports for Nuclear Power Plants, Rev. 2 X
X X
X X
X X
n.
RG 1.75 Physical Independence of Electric' Systuns X
X X
X o.
RG 1.78 Assumptions for Evaluating the
. Habitability of a Nuclear Power Plant Control Roan During a s
Postulated liazardous Chemical d
e Release X
X cn 4
p.
RG 1.89 Qualification of Class IE Equip-y ment for Nuclear Power Plants X
X X
X X
X SRP Section 3.11, i
b q.
RG 1.96 Design of Main Steam Isolation valve Leakage Control Systuns for Boiling Water Reactor Nuclear Power Plants X
X r.
RG 1.12 Instrumentation for Earthquakes X
X s.
RG 1.45 Reactor Coolant Pressure Boundary Leakage Detection Systens X
.I t.
RG 1.67 Installation of Overpressure Protection Devices X
X i
u.
RG 1.80 Pre-operational Testing of Instrument Air X
X X
X.
SRP Section 9.
' ~
.y M
t 5
T ABLE 7-1 (CONTINUED)
CRI1ERIA TITLE APPLICABIL11Y KEHARKS 7.1 7.2 7.3 7.4 7.5 7.6' 7.7 y
v.
RG 1.95 Protection of Nuclear Power Plant Control Room Operators Against Accidental Chlorine Releases X
X l
w.
RG 1.97 Instrumentation for Light llater Cooled Nuclear Power Plants to Assess Plant Conditions During and following an Accident X
X SRP Section 3.10.
x.
RG 1.100 Seismic Qualification of Electrical Equipnent fo,-
Nuclear Power Plants X
X X
X X
X y.
RG 1.105 Instrument Spans and Setpoints X
X X
X X
X z.
RG 1.118 Periodic Testing of Electric Power and Protection Systems X
X X
X X
X SRP Section 3.10.
H aa.
RG 1.120 Fire Protection Guidelines for Nuclear Power Plants X
X X
X X
X X
h 5.
Branch Technical Positions (BIP)ICSB BTP ICSB 1 Bactfitting of the Protection and D0R Responsibility.
a.
Emergency Power Systems of Nuclear Reactors X
X X
X X
b.
BTP ICSB 3 Isolation of Low Pressure Systems from the High Pressure Reactor Coolant Systun X
X X
c.
BTP ICSB 4 (PSB)
Requirements on Motor-Operated Valves in the ECCS Accumulator l
X X
X Lines d.
BTP ICSB 5 Scram Breaker Test Requirements -
Technical Specifications X
X e.
BTP ICSB 9 Definition and Use of " Channel-Calibration" - Technical X
X X
X X
Specifica tions 4
. m
\\
-s TABLE 7-1 (CONTINUED)
CRITERIA TITLE APPLICABILITY REHARKS 7.1 7.2 7.3 7.4u7.5 7.6 7.7 f.
BTP ICSB 10 Electrical and Mechanical Equipment. Seismic Qualification Program X
X X
X X
Replaced by Reg. Guide 1.100 g.
BIP ICSB 12 Protection System Trip Point Changes for Operation with Reactor Coolant Pumps Out of i
Service X
X X
h.
BTP ICSB 13 Design Criteria for Auxiliary Feedwater Systems X
X 1.
BTP IC58 14 Spurious Withdrawals of Single
)'
Control Rods in Pressurized Water Reactors X
X X
j.
BTP ICSB 15 (PSB)
Reactor Coolant Pump Breaker Qualification X
X ro k.
BTP ICSB 16 Control Element Assembly (CEA)
' Interlocks in Combustion Engineering Reactors X
X 3[
1.
BTP ICSB 18 (PSB)
Application of the Single Failure Criterion to Manually-i Controlled Electrically-Operated Valves X
X X
X m.
BTP ICSB 19 Acceptability of Design Criteria for Hydrogen Mixing and Drywell Vacuum Relief Systems X
X X
n.
BTP ICSB 20 Design of Instrumentation and i
Controls Provided to Accomplish Changeover f rom injection to Recirculation Mode X
X X
X l
a.
BTP (CSB 21 Guidance for Application of Reg.
Guide 1.47 X
X X
X X
X p.
.BTP ICSB 22 Guidance for Application of Req.
Guide.122 X
X X
X X
X
??
4 4
s-TABLE 7-1 (CONT]NUFD) g CRITERIA TITLE APPLICABILITY REMARKS,.
7.1 7.2 7.3 7.4 7.5 7.6 7.7 5
q.
BTP ICSB 23 Qualification of Safety-Related Replaced by R'eg. Guide 1.97.
Display Instrumentation for Post-Accident Condition Monitor-ing and Safe Shutdown I
X r.
BTP ICSB 24 Testing of Reactor Trip Systua Replaced by Reg. Guide 1.118.
and Engineered Safety Feature Actuation Systen Sensor Response Times X
X X
X X
s.
BIP ICSB 25 Guidance for the Interpretation of General Design Criterion 37 for Testing the Operability of the Emergency Core Cooling System as a Whole X
X X
t.
BTP ICSB 26 Requirunents for Reactor Protec-1%n Systen Anticipatory Trips X
X M
u.
BTP ICSB 27 Design Criteria for Thermal.
Replaced by Reg. Guide 1.106 Overload Protection for Motors
{
of Motor. Operated Valves X
X X
X h
.h
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY)
Docket No. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
P lan t, Unit Nos. 1 and 2)
)
AFFIDAVIT OF DALE G.
BRIDENBAUGH, RICHARD B. HUBBARD, AND GREGORY C. MINOR FOR GOVERNOR EDMUND G. BROWN, JR.
DALE G.
BRIDENBAUGH, RICHARD B. HUBBARD, AND GREGORY C.
MINOR, being duly sworn, do say under oath that I, the undersigned have assis ted in preparing and reviewing responses of Governor E dmun d G. B rown, J r.
to NRC Staf f's Second Set of Interrogatories -
Nos. 1-31.
Said answers are true and correct to the bes t of my knowledge and belief.
S $----
Dale G. - Bridenbaugh '
thws Rich ard B. Hubb ard October 30, 1981
/
4W Gre goryd C./ Mino r Subscribed and sworn to before me this M day of[fid/ror, 1981.
""'" '"'"5 f""N4 OFFICIAL SEAL g
,ygg h
g -
CARLO F. CARALLI Q
y Th{-p Notary Pubuc Caafornia _g S,gp3l,0H c Pr NOTARY PUBLIC
,u
/ j/
th cemmissien exp res Oct. 5.1754 My commission expires.
/d[&,/[7 Leo-oe-oeo M
..