ML20032D052

Responses to Second Request for Production of Documents

ML20032D052
Person / Time
Site:	Diablo Canyon
Issue date:	11/10/1981
From:	Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	JOINT INTERVENORS - DIABLO CANYON
Shared Package
ML20032D050	List: ML20032D049 ML20032D052
References
ISSUANCES-OL, NUDOCS 8111130332
Download: ML20032D052 (3)

Text

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UNITED STATES OF AllERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter.of

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PACIFIC -GAS AND ELECTRIC COMPANY Docket 1.os. 50-275 0.L.

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50-323 0.L.

(Diablo Canyon Huclear Power Plant,

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Full Power Proceeding Unit IJ9s. 1 and 2)

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NRC STAFF RESPONSE TO JOINT INTERVENORS'-SECOND REQUEST FOR PRODUCTION OF DOCUMENTS The NRC Staff herein responds to Joint Intervenors' Request for Production of Documents, dated October 7,1981.

1.

All documents identified in response to Interrogatory Nos.

29-68 have already either been attached to the NRC Staff Response to Joint Intervenors' Second Set of Interrogatories, been made available to Joint Intervenors, or been made available to members of the public at the NRC Public Document Room,1717 H Street, N.W., Washington, D.C.

2.

The Staff has already provided a copy of IE Inspection Report i

Nos. 50-275/81-21 and 50-323/81-15. Staff has no other documents that are not otherwise avaliable to the parties.

3.

A letter dated June 29, 1981 from Philip A. Crane, PG&E, to Frank J. Miraglia, Jr., NRC, is responsive to this request. The i

document has been provided together with NRC Staff Response to Joint Intervenors' Second Set of Interrogatories.

811113030G2 811110 DR ADOCK 0500027

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4.

See Attachment A.

Additional. documents have already been.

identified or produced in connection with NRC Staff Response to Joint Intervenors Second Set of Interrogatories or are otherwise ava able to Joint Intervenors. One document responsive to this request is not being produced on the ground that it is an intraagency memorandum which would not be available by law to a party other than an agency in litigation with the Commission, pursuant to 10 C.F.R. s2.790(a)(5).

This document is a memorandum, dated October 13, 1981, from Thomas E.

Hurley, Director, Division of Safety Technology, NRR, through Edson G.

Case, Deputy Director, NRR, for Harold R. Denton, D; ector, Office of Nuclear Reactor Regulation, on the subject of " Safety Classification Terminology -- Proposed Standard Definitions." This document contains recommendations of the NRR Staff on the subject matter to Mr. Denton concerning proposed courses of action. As a recommendation, rather than final agency action, it is deliberative it: nature and is precisely the sort of Commission document which the language of 10 C.F.R. 92.790(a)(5) and the case law on protection of intraagency deliberative documents is designed to protect.

See, Environmental Protection Agency v. Mink, 410 U.S. 73 (1973).

Segregable factual information in the memorandum has been provided, as attached.

(AttachmentB). The subject memorandum has five enclosures:

(1) a memorandum provided as Attachment A; (2) testimony excerpts provided with Attachment B; (3) a draft memorandum concerning standard definitions, which, as a draft, is outside the scope of HRC documents subject to discovery pursuant to 10 C.F.R. 92.790(a); (4) a proposed definition of terms; and (5) a graphic, both of which are

-3 inseparable from the deliberative portion of. the memorandun withheld, and are not provided on the same grounds.

With respect to part (b) of this request, by failing to define the scope.cf the request other than to documents "which relate in any way to the reliability, design, and/or classf #ication of...

(b) such components of a design, nodel, or type _sjnilar Oc nose installed at Diablo Canyon" (emphasis added), Joint Intervenors' request is overly broad and indefinite. As a result. this request is objectionable as failing to provide reasonable particularity.

5.

See Reponse 4.

With respect to part (b) of this request, the request is overly broad, in that it could arguably include all papers of any sort generated in connection with the EPRI. testing program, amounting to roughly thousands of pages. The use of the tem "similar", moreover, renders the request too indefinite to proyue a reasonable response. Without more specificity and narrowing of scope, this portion of the request is objectionable as failing to provide reasonable particularity.

Respectfully submitted, Q

b-George Jo ison Counsel for NRC Staff Dated at Bethesda, Maryland this 10th day of November,1981

ATTACHMENT A

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DCT 3 01980 MEMORANDUM FOR: All DSI Personnel

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FROM:

Denwood F. Ross, Jr., Director, Division of Systems -

Integration, NRR

SUBJECT:

SAFETY TERMINOLOGY SED'IN TMI-1 RESTART HEARING TESTIMONY One' contention by intervenors in the TMI-1 Restart Hearing would require that all non-safety components that could cause or aggravate an acciderit, or that -

could be called upon to mitigate the consequences of an accident, should be made safety-grade.

Specific examples focused on by the intervenors in this regard, include the PORV and block valves, pressurizer' heaters, and reactor poolant pumps, in view of the roles played by those components in the TMI-2 accident sequence and recovery process.

In addressing this issue, it was negessary to focus on the definition, application, and commo.n usage.of the tenninologies employed by the staff in this regard.

The attached testimony establishes the definition for two of the most frequently used tems of this kind, i.e., "important to safety" and " safety-grade."

It should be noted that another frequently used term, i.e., " safety 'related,"

is not treated in the attached testimony.

Office of Standards Development has

~ prepared a Commission Paper that is intended to resolve the definition of that term.

The thrust of the OSD effort is to establish that the tems " safety-related" and "important to safety," as they are defined and used in the regu-lations, are synonymous (at least in the context of application of the quality assurance criteria of Appendix B to 10 CFR Part 50). At this point, however, the definition of the term " safety-related" is not yet fully resolved; and, because the OSD effort involves a proposed change to the language of Appendix

. B, the Conmission will have the final word in that regard.

To the extent that definitions for commonly-used safety terminologies have been established (as in the attached-testimony), our goal should be consistency in i

their usage and application in all of our activities. More to the point, in

-m 2 the context of immediate concern. I expect all DSI personnel involved in the r

TMI-1 Restart Hearing to give particular emphasis to consistent usage and application of the terms "important to safety" and " safety-grade" in accordance with the definitions established in the attached testimony.

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-(A Denwood'F Ross,Jr.,Dirlictor )'

Otyision of Systems Integration Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

See next page

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. OCT 3 01980 c'c: 'h. R. Denton, DIR, NRR R. B.' Minogue, DIR, 050

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V. Stello, DIR, IE

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H. SKipar, DIR ELD All NRR Division Directors H. Silver, DOL S. Richardson, OSD J. M. Cutchin, IV, ELD T. F. Dorian, ELD 1

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. ENCLOSURE 2 t

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MEMORANDUM FOR: y.p.s..

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- %-SS#4-N'F:- _ Harold R. Denton. Director.~ / ;M

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Office of Nucle ation C m. 4_.m.

gy, 1NRU Edson G. Case. Deputy Director NRR ",'

FROM:

Thomas E. Murley, Director Di, vision of Safety Technology, NRR

SUBJECT:

SAFETY CLASSIFICATI]N TERMIMOLOGY--PROPOSED STA!!DARD DEFINITIO!!S a --

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• attached is excerpted from testfrony developed by the DSI staff

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in connection with the litigation of Contention #14 in the THI-l Restart.

. Hearing.

That testimohy set forth. definitions for two safety classification terms (i.e.. "finportant t'o' safety""aiuf "siThty; grade")~used frequently in ;.

the conduct of'the ~ agency's! safety ~regula.tfon. activities. These definitions -

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were endorsed explicitly by the Director. DSI (s' e Enclosure 2); and you will,

e recall that this testimony was dfREssed specifically with you and Ed case at..

a meeting just prior to the argiiaen't'of' ton'thntion 14 in the hearing last-December.

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Original signed by:

Thomas E.1!urley Thomas E. Murley Director Division of Safety Technology Enclosures (5)

As stated

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D. Ross. RES R. Hinogue. RES Y. Stello, Jr.. IE H. Shapar. ELD. _

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t Excerpts from Staff Testimony On Contention UCS #14 in the THI-1 Restart Hearing

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Q.4 b' hat is the purpose of your testimony?

A.

The purpose of my testimony is to respond to UCS Contention #14, which states:

"The accident demonstrated that there are systems and components presently classified as non-safety-related which can have an' adverse effect on the integrity of the core because they can directly or. indirectly affect temperature, pressure, flow and/or reactivity.

This issue is discussed at length in Section 3.4, " System Design Requirements," of NUREG-0578, the TMI-2 Lessons Learned Task Force ','rg. c (Short Tem)., The foilowing quete from page 18 of the report di s,.cibes the problem:

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'Th. e is another perspective on this question provided by the TMI-2 accident. 'At TMI-2, operational problems with the condensate -purification syster:t led.to.a. loss of feedwater and initiated the sequence of.e' vents' that eventually resulted in damage to the. core.

Several nonsafety systems were used at.

various times in the mitigation of the accident in ways not considered.in the safety analysis; for example, long-term maintenance of core flow and cooling with the steam generators and the reactor ccolant pumps.

Tne present classification system does not adequately recogni::e either of these kinds of effects that nonsafety system can have on the safety of the pl ant.

Thus, requirements for nonsafety systems may be needed to reduce the frequency of occur ence of events that initiate or adversely affect transients a.M accidents, and other require,

cents may be needed to improve the current capability for use of nonsafety systems during transient or accident situations.

In its work in this area, the Task Force will include a more realistic assessment of the interaction between cperaters and

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syst ems. '

The Staff proposes to study the problem further. This is not a. sufficient answer.

All systems and ccraponents which can either cause or aggravate an accident er can be called upon to mitigate an accident must be identified and classified as ccraponents important to safety and required to meet all safety-grade design criteria."

The Board limited the scope of this contention to the core cooling system.

(First Special Prehearing Conference Order, December 18,1979).

ENCLOSURE 1

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Q.5 How is the term "... conponents important to safety..." defined in the Commission's regulations?

A.

The term "... structures, systems, and components important to safety.i."

is defined in the introductory paragraph to the General Design Criteria (Appendix A.to 10 CFR Part 50) as those "... structures, systems, and components that provide reasonable assurance that t'he facility can be operated without undue risk to the health and safety of the public."

From this context, it is clear that the expression "... important to safety..." is meant to apply generally to all structures, systems, and component's addressed in the General Design Criteria (GDC).'~ Th'e

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2 tenr. is used consistently in that sense throughout the -GOC, and in ~

other part's of the re351sif ons is'well'(e.gi,2seedicussidn+beldw).?

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Q.6 Is the term "... safety-grade..." defined ia-the regulations?

A.

That tenn is not defined explicitly in the regulations.

The term is widely-used, however, in the context of the safety review process. The meaning of the term, as most commonly used by the staff in that context, is-inferred from the language of the regulations, as follows:

(a) General Design Criterion 1 introduces the notion of different cuality levels for plant features with differing s'afety roles and varying degrees of importance to safety.

Specifically, GDC-1 requires application of "... quality standards commensurate with the importance of the safety function to be performed..." for structures, systems, and components important to safety.

(b) Appendix A to 10 CFR Part 100 implements the concept established in GDC-1 (i.e., gradations in quality levels corresponding to relative safety importance) by identifying explicitly a select ENCLOSURE-1

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sub-class of structures, sy. stems, and components (out of the broad class "important to safety") that. are required for the performance of specific, critical safety functions (e.g., safe shutdown, accident

- preventien and consequence mitigation, etc.).,Specifically, Sec. III.c of Appendix A to 10 CFR Part 100 defines the Safe Shutdown Earthquake (the most severe seismic event analyzed for a n0 clear power plant),

and requires that "... certain structures systems, and components (important to safe.ty)..." be desi.gned to remain functional for that event.

Those "certain" plant features, and the critical sarety.,

functions they must perfonn, are further identified in Sec. III.c as:

"... those necessary to assure:

. (1) The integrity of the reactor coolant pressure boundary, (2) The capability to shut doEn the reactor and maintain it in a safe shutdown condition, or (3) The capability to prevent or mitigate the censequences of accidents which could result in potential offsite exposures

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comparable to the guideline exposures of this part."

Very high quality standards must, of course, be applied to plant features required for such purposes, in order to assure their availability when called upon and very higli reliability in service.

• Such considerations are the origin of the terb ' safety-grade"; and the staff applies that term only to the structures, systems and components recuired to perform the specific critical safety functions ider 'fied above.

(Frequently, the term " safety-grade, systems or components" is shortened to " safety systems or components." These two terms are used interchangeably in the following testimony).

ENCLOSURE 1

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Q.7 Would you summarize from the preceding, the relationship between the terms "important to safety" and " safety-grade"?,

A.. (1) The term "important to safety" applies generally to the broad class "

• of structures, systems, and components addressed in the General Design Criteria.

(2) " Safety-grade" structures, systems and component: are a sub-class

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of all those "important to safety."

(3) All structures, systems, and components encompassed by the term "important to safety" (including the " safety-grade." sub-class) are l

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necessary to meet the broad safety gaal articulated in Appendix A to 10 CFR Part 50 of the regulations (i.e., provide reasonable assura,nce that a facility can be operated without undue risk to the health and safety of the public).

(4) Only " safety-grade" structures, systems and components are recuired

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for the critical accident prevention, safe shutdown, and accident consecuence mitigation safety functions identified in Sec. III.c of Appendix A to 10 CFR Part 100.

0.8 Has the staff identifieo those structures, systems and components which must be safety-grade?

A.-

Yes. They are listed in detail in Regulatory Guide 1.29.

The specific purpose of Reg. Guide 1.29 was to identify all structures, systems and components of nuclear power plants that should be designed to withstand the effects of the Safe Shutdown Earthquake (designated Seismic Category I).

Because of the manner in which the term safety-grade was derived in the preceding discussion, however, the list of Seismic Category I plant features identified in Reg. Guide 1.29 should also be the listing of all " safety-grade" structures, systems, and components in a plant.

ENCLOSURE 1

Q.9 Is the term "... core cooling ' system..." defined in the regulations?

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To my knowledge, that' term is not' defined explicitly in the' regulations.

'Fran the context in which it is applied in the specification of this ~

contention, however, the ~ staff co~ siders that term-to encompass those n

primary, secondary, and auxiliary systems used to remove heat fran the core an.' transfer it to the heat ' sink, both in normal operatio'n and under o

accident conditions.

Q.10 Referring now to the first sen'tenc'e of the contention,.

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~ U "a) Can non-safety systems and c' mponents directly or indirectly affe~ct o

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'* e temperature, p~ressure ' flow and/or reactivity, and (b) Can non-safety. systems and components, therefore, have an adverse effec't on th6 integriti of thec' ore?

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('a) The staff stipulates that nbn-safety systims and components can 4

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directly or indirectly affect core reactivity and primary coolant temperature, pressure and flow.

It follows, therefore, that (at least in general) failure or off ~ normal operation of non-safety systems and components can cause or aggravate an accident, but-(b) That does not establish that failure or off-normal operation of non-safety systems and components alone can have an adverse effect on the integrity of the core, as strongly implied by the wording of

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the contention.

(In the TMI-2 accident sequence, failure of non-safety cgaponents, coupled with. improper coeration of installed safety systems, led to core damage.)

ENCLOSURE 1 v

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(.11 Do you have any clarifying or.'implifying comments regarding the second -

paragraph of the contention, i.e., the quote excerpted from NUREG-05787 A.

'The staff acknowledges that non-safety systems and components were used in the mitigation of the TMI-2 accident; but it is-importan,t to note and emphasize, in the discussion of this contention, that resort was made to use of non-safety systems and components in the accident miti-s gation role, only after improper operatior of installed safety systems had resulted in severe cors damage and other outside-design-basis. :

conditions (e.g., voiding in'the primary cooloat and hydrogen generatinn, y

which maf have blocked _ natural' circulation, thus c. aating the need'for forced cooling).

Q.12 Referring nos Eo the last sentence of the contention, what is the staff's

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position regarding the sta'tement that "All sy$tems and components

>Aich can either cause or aggravate an accident or can be called on to mitigate an accident must be identified and classified as components important to safety and required to meet all safety-grade design criteria"?

A.

We believe that, in the sense that the term "important to safety" is defined and used consistently in the regulations (see response to Q.5 above),

such systems and components would already be regarded (i.e., classified) as important to safety. But, as further established in the responses to Q.6 and Q.7 above, all components important to safety need not 'be

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safety-grade.

Only components recuired for the specific critical safety functions delineated explicitly in the response to Q.6 above need to meet safety-grade design criteria.

e ENCLOSURE 1

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.Q.13 More sp'ecifically, if a given non-safety system or component is known' to havel5ntributed to an accident, or is known to have been relied upon to-recover from an accident (as was the case at TMI-2), how does the'sta'ff.

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decide whether-or-noti the safety classification of the system ~or component ;

should be changed and whether-or-not that, system or component should.be i

made safety-grade?

A.. The test applied by the staff,- in deciding whether a given non-safety s.istem or component should be upgraded to safety-grade, is not-just whether it could

'cause or aggravate or be called upon to mitigate an accident. The final detennination (regarding whether-or-not to upgrade) is based upon consideration -

2 of the following question's '(decision criteria), which derive' directly from the definitions and discussions developed iiithe responses to Q.5 through Q.10:

(a) will the failure or off-normal operation of the non-safety system or component in cuestion, in and of itself, degrade the capability of installed. safety systems such that those safety systems cannot-mitigate accident cansequences and assure adequate safety,*

'(b) will the effects of failure or off-ncrmal operation of the non-safety, system'or component in questien alone exceed the capability of installed

• safety systems to mitigate accident consequences.and assure adequate safety, if installed safety systems are operated properly so that full I

credit can be taken for their functioning to design capability throughout i

the accider.t sequence,*

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• Assuming single failure in the installed safety systems in accordance with

.the Single Failure Criterion.

ENCLOSURE 1

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(c) is,a non-safety system or component-that may be called upon actually _

reautred to mitigate accident consequences and assure adequate safety,.

if installed safety systems are operated properly so that full credit

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can be taken for their functioning to design capability throughout the accident sequence.*

If the staff determines, either by carefui analysis or actual experience, that the answer to any of these questions, in all of its aspects, is yes, then:

(i) the system or component in question would be upgraded to safety-grade, or

.(11) the design of the facility and/or the capability of the installed safety systems would be improved such that the answer is no to all three questions.

In some instances (as has been the case for some of the aon-safety components 7.._

which were involved in the TMI-2 accident sequence and recovery process),

even though none of the decision criteria above that would require upgrading are met, the staff may decide as a prudent measure to require upgrading of the system or component in question, but not to full safety-grade. This might be done, for exam

, in order to improvt Se availability and 4

reliability of the component in question, and thereby provide. increased safety j

mar?tns or greater flexibility for dealing with potential fut"-e accident

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situations (either within the current desiga. basis or like TF -2, and irrespective of how such conditions might come about).

• Assuming single failure in the installed safety, systems in accordance with the Single: Failure Criterion.

ENCLOSURE 1

UNITED STATES OF A!! ERICA NUCLEAR REGULATORY C0KilSSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the !!atter of

)

PACIFIC-GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.

)

50-323 0.L.

(Diablo Canyon Nuclear Power Plant,

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FULL PG!ER PROCEEDING Units Nos. 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " RESP (NSE TO JOINT INTERVEN0RS' THIRD SET OF INTERROGATORIES" and "NRC STAFF RESPONSE TO JOINT INTERVENORS' SECOND REQUEST FOR PRODUCTION OF DOCUMENTS" dated November 10, 1981 in the above-captioned proceeding have been served on the following by deposit in the United States mail, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system this 10th day of November,1981:

John F. Wolf, Chairman Mrs. Raye Fleming Administrative Judge 1920 Mattie Road Atomic Safety and Licensing Board Shell Beach, California 93449 U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Mr. Frederick Eissler Scenic Shoreline Preservation

• Mr. Glenn 0. Bright, Administrative Conference, Inc.

Judge 4623 More Mesa Drive Atomic Safety and Licensing Board Santa Barbara, California 93105 U.S. Nuclear Regulatory Comission Washington, D.C.

20555

• Dr. Jerry Kline, Administrative Judge Mr. Gordon Silver Atomic Safety and Licensing Board Mrs. Sandra A. Silver U.S. Nuclear Regulatory Commission 1760 Alisal, Street i

Washington, D.C.

20555 San Ints Obispo, California 92401 Philip A. Crane, Jr., Esq.

Pacific Gas and Electric Company Richard *. Hubbard 77 Beale Street, Room 3127 MHB Techt.ical Associates San Francisco, California 94106 1723 Hamilton Avenue - Suite K San Jose, California 95125 Mrs. Elizabeth Apfelberg l

1415 Cozadero Andrew Baldwin, Esq.

San Luis Obispo, California 93401 124 Spear Street

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San Francisco, California 94105 l

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s Paul C.

alentine, Esq.

Bruce Norten. Esq.

321 Lytton Avenue 3216 North 3rd Street Palo Alto, California 94302 Suite 300 Phoenix, Arizona 85012 Harry M. Willis kvfdS F

cluker, Esq.

aio Street, Suite 2100 San Francisco, California 94108 mlb etty, Oklahcru 73101 John R. Phillips, Esq.

Simon Klevansky, Esq.

Byron S. Georgiou Ma garet Blodgett, Esq.

Legal Affairs Secretary Marion P. Johnston, Esq.

Governor's Office Joel Reynolds, Esq.

State Capitol Ceriter for Law in the Public Sacramento, California 95814 Interest 10203 Santa Monica Boulevard Herber t H. Brown Los Angeles, California 90067 hill, CHRISTOPHER & PHILLIPS. P. C.

1900 M Street, N.W.

Arthur C, Gehr. Esq.

Washington, D.C.

20036 i

Snell & Wilmer 3103 hiley Center Richard E. Blankenburg, Co-publisher Phoanix, Arizona 85073 Wayne A. Soroyan, News Reporter South County Publishing Company Janice E. Kerr, Esq.

P. O. Box 460 Lawrence Q. Garcia, Esq.

Arroyo Grande, California 93420 350 McAllister Street San Francisco, California 94102

• Atomic Safety and Licensing Board Panel Mr. James 0. Schuyler U.S. Nuclear Regulatory Commission Nuclear Projects Engineer Washington, D.C.

20555 Pacific Gas fa Electric Company 77 Beale Street

• Atomic Safety and Licensing Appeal San Francisco, California 94106 Panel U.S. Nuclear Regulatory Connission John Marrs Washington, D.C.

20555 Managing Editor San Luis Obispo County

• Secretary Telegram-Tribune U.S. Nuclear Regulatory Commission 1321 Johnson Avenue ATTN: Chief, Docketing & Service Br.

P. O. Box 112 Washington, D.C.

20555 San Luis Obispo, California 93406 Mark Gottlieb California Energy Ccrrission 15-18 1111 liove Avenue

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Sacramnto, California 95825 George E Johnson Counsel for tac Staff i

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