ML20032E386
| ML20032E386 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/26/1981 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| References | |
| NUDOCS 8111200506 | |
| Download: ML20032E386 (64) | |
Text
"M1D Co:trzpay 9
r
%N DOLMETED d.
A 1
NOVI g 793g, n' UNITED STATES OF AMERICA
,1
81 (ET 29 P4:38 2
o u.a.
LEAR REGULATORY COMMISSION I
Q OFFICE OF SECRETRY 3
g
\\
DOCKETING & SERVICE 8
4 4
BRANCH g
rFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
6 7
In the Matter of
)
8
)
Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY
)
Docket No. 50-323 9
)
Diablo Canyon Nucleer Power Plant
)
(Full Power Proceedings) 10 Units Nos. 1 and 2
)
)
11 12 13 14 APPLICANT PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO JOINT INTERVENORS' 15 SECOND SET OF INTERROGATORIES 16 17 INTERROGATORY NO. 29:
18 Explain the present Applicant position on Joint 19 Intervenors' contention 10, regarding pressurizer heater 20 design, and state each and every fact on which that position 21 1s based.
22 23 ANSWER TO INTERROGATORY NO. 29:
24 It is PGandE's position that the pressurizer 25 heaters and associat'ed controls are not required to be 26 classified as " components important to safety" and therefore D
Q$b 8111200506 811026 PDR ADOCK 05000275 hI l C
PDR d
1 are not. required to meet all safety grade design criteria.
2 However, the pressurizer heater design associated with the 3
capability of obtaining power from the onsite emergency 4
power supply meets GDC 10, 14, 15, 1-7 and 20 of Appendix A 5
to 10CFR50.
Therefore, PGandE believes the method that has 6
been used to connect the pressurizer heaters to the onsite 7
emergency power supply is fully adequate.
8 PGandE's position is based on the fact that the 9
design of the pressurizer heaters meets the NRC regulatory 10 requirements including those arising from post TMI lessons 11 learned, specifically NUREG-0737.
12 13 14 15 INTERROGATORY NO. 30:
16 Does the current position differ from the position 17 of the Applicant in any prior proceedings?
If so, identify 18 the proceeding (s), explain the prior position, and explain 19 the basis for the change in position.
20 21 ANSWER TO INTERROGATORY NO. 30:
22 No.
23 24 25 26 _J
a 1
INTERROGATORY NO. 31:
2 Identify any officers or employees of, or 3
consultants to, the Applicant who' dissent from the present 4
Applicant position on Joint Intervenors' contention 10.
1 5
Explain the reasons for which any such person dissents.
6 7
ANSWER TO INTERROGATORY NO. 31:
8 None.
9 10 t
i 11 1
i 12 INTERROGATORY NO. 32:
13 Identify the specific sections and page numbers of
~
14 the FSAR for Diablo Canyon and the NRC Staff's SER and SER 15 Supplements for Diablo Canyon, which are relied upon in 16 formulating the Applicant position on Joint Intervenors' i
17 contention 10.
18 i
19 ANSWER TO INTERROGATORY NO. 32:
(
i 20 SER Supplement 14,Section II.E.3.1,
" Emergency 21 Power Supply for Pressurizer Heaters," pages 2-19 through 22 2-21.
f 23 24 25 26 4 '
1
a 1
INTERROGATORY NO. 3_3_:
2 Identify all sections and page numbers of the 3
FSAR, SER, and SER Supplements which contain subject matter 4
pertaining to Joint Intervenors' contention 10.
5 6
ANSWER TO INTERROGATORY NO. 33:
7 Applicant objects to this interrogatory.
The 8
FSAR, SER and SER Supplements consist of literally thousands 9
of pages.
Joint Intervenors are more capable than anyone l
10 else of going through those documents and making a 11 Judgmental decision as to whether any section or page 12 contains subject matter pertaining to their own contention.
13 14 15 16 INTERROGATORY NO. 34:
17 The Staff has recognized that the " maintenance of 18 natural circulation capability is important to safety (and) 19 depends on the maintenance of pressure control (which) 20 is normally achieved through the use of pressurizer 21 heaters."
NUREG-0578, p. A-2.
22 (a)
Do you agree?
l 23 (b)
Explain why pressurizer heaters and their associated 24 controls are not classified as " components important to 25 safety," as discussed in GDC 17 and the Introduction to 26 Appendix A to CFR Part 50. )
1 ANSWER TO INTERROGATORY NO. 34:
2 (a)
Yes.
3 (b)
The plant design, including operational prac-4 tice (training, procedures, etc.), provides alternative 5
and reliable methods of maintaining pressure control, 6
and therefore maintaining natural circulation, which 7
use systems and components designed to safety grade re-8 quirements.
Therefore, the pressurizer heaters and 9
associated controls are not classified "important to 10 safety."
11
- Further, there are no NRC regulations or 12 requirements that provide' that the pressurizer heaters 13 and their associated controls ought to be classified 14 "important to safety."
The NRC Staff, on page A-2, there is a need to consider 15 NUREG-0578, states "
16 the upgrading of those pressurizer heaters and 17 associated controls to a
safety grade 18 classification.
The NRC Staff further states, 19 on page A-2 of NUREG-0578, "In the short term, designs 20 should be upgraded to provide the operator with the 21 capability to maintain natural circulation at hot 22 standby through the use of pressurizer heaters when 23 offsite power is not available."
This last statement 24 has become a requirement as identified in item II.E.3.1 25 of NUREG-0737, the document that identified those 26
/// J
1
'Eil-related actions that the NRC Commissioners ' have 2
approved for implementation.
3 Pressurizer heaters and associated controls 4
meet both the requirements of item II.E.3.1 and GDC 17 5
in terms of emergency on-site power supplies for the 6'
pressurizer heaters.
Item II.E.3.1 does not require I
7 the pressurizer heaters or associated controls to be 8
designed to safety grade requirements; in fact item 9
II.E.3.1
- states, "Being non-Class IE loads, the 10 pressurizer heaters must be automatically shed from the 11 emergency power sources.
12 The NRC Staff's characterization of the 13 pressurizer heaters as non-Class IE
- loads, by 14 definition, precludes them from being classed as 15 components "important to safety."
16 17 18 19 INTERROGATORY NO. 35:
20 Explain in detail whether and in what manner the 21 following design criteria would be met with respect to the 22 pressurizer heater and its associated controls.
23 (a)
GDC 22 (diversity) 24 (b)
GDC 2 and 4 (seismic and environmental qualification) 25 (c)
GDC 10 (automatic initiation) 26 (d)
GDC 3 and 22 (separation and independence) w
1 ANSWER TO INTERROGATORY NO. 35:
2 The applicable General Design Criteria (G.D.C.) of 3
Appendix A to 10CFR Part 50, including GDC 2, 3,
4, 10, and 4
22 are met by the design of the pressurizer including its 5
associated components, such as the heaters.
In particular, 6
application of these criteria is made to assure the 7
following:
8 1.
that the pressure boundary of the pressurizer is not 9
jeopardized by penetrations in the pressurizer vessel 10 for the external electrical connections to the heaters 11 that are located inside the pressurizer, and 12 2.
that when the heaters are loaded onto the emergency 13 electrical power buses, the separation and independence 14 of separate trains of this vital distribution system 15 are not violated by the hard wired electrical 16 connection to the heaters.
17 The pressurizer heaters in performing the function 18 of maintaining pressure in the pressurizer are not required 19 to terminate or mitigate an accident including a small break 20 LOCA.
Therefore, the above GDCs do not apply to this 21 specific function.
22 23 1
24 25 26 >
1 INTERROGATORY NO. 36:
2 Specify precisely under what ronditions the 3
pressurizer heaters will be relied upon at Diablo to:
4 (a) regulate and/or control pressure; 5
(b) initiate and/or maintain natural circulation:
6 (c) mitigate the consequences of inadequate core cooling; 7-(d) stabilize the reactor in post-accident conditions; 8
(e) any other functions performed by the pressurizer 9
heaters.
10 11 ANSWER TO INTERROGATORY NO. 36:
12 (a)
The pressurizer heaters are used tc establish 13 and maintain a suturated condition with a steam bubble 14 in the pressurizer.
They assist in maintaining 15 pressurizer pressure at a nominal value and prevent 16 reactor trip as a ?;esult of pressure variations caused 17 by design transients.
During steady state operation, 18 the pressurizer pressure control system normally 19 controls only the proportional heaters to compensate 20 for minor pressure fluctuations.
The proportional 21 heaters will continuously operate at a low level to 22 compensate for the continucus spray rate (approximately 23 1 gpm) and pressurizer heat losses.
24 (b)
Pursuant to a postulated loss of offsite 25 power, the pressurizer heaters can be used to enhance 26 natural circulation conditions by maintaining Reactor >
1 Coolant System (RCS) until offsite power is restored 2
but are not required for this function.
The primary 3
function of the heaters is to assist in maintaining RCS 4
pressure control by compensating for pressurizer heat 5
losses.
6 (c)
Procedures for mitigating the consequences of 7
an event that could result in inadequate core cooling 8
do not require the use of the pressurizer heaters.
9 (d)
Following desion basis accidents in which the 10 safety injection (SI) system is manually or 11 automatically initiated, operation of the 17ssurizer 12 heaters is re-established to restore sa.urated 13 conditions in the pressurizer after safety injection 14 has been terminated and normal charging and letdown has 15 been restored.
Following anticipated events in which 16 reactor trip is manually or automatically initiated, 17 the pressurizer heaters are used to return the RCS to 18 normal operating conditions.
39 20 21 22 INTERROGATORY NO. 37:
23 Assuming inoperability of the pressurizer heaters, 24 specify in detail each and every means, system, and/or 25 component available at Diablo Canyon to perform the 26 functions listed in Interrogatory No. 36 under the
_9_
J
j 4
1 conditions described in your response to that interrogatory.
f 2
State each and every fact upon which you base your i
3 contention that such other means, systems, and/or components 4
can adequately perform the functions listed.
5 6
ANSWER TO IN'1ERROGATORY NO. 37:
i 7
(a)
If the pressurizer heaters are assumer, l.o be 8
lost during normal operation, the normal charging and 9
letdown system would be used to control RCC pressure 10 until the heaters can be restored.
Calculations which a
11 have been performed indicate that seversi hours exist 12 prior to the time at which the heat losses via the 13 pressurizer result in RCS hot leg saturation.
If the e
14 heaters cannot be restored prior to the time of hot leg saturation, continued effective primary to secondary 15 1
16 heat transfer can be ensured by maintaining the steam 17 generator water level at the nominal setpoint either by 18 use of the main feed system or the auxiliary feedwater 19 system.
The option of maintaining RCS pressure at the 20 nominal value by using either the normal charging 21 system (if available) or the safety grade safety 22 injection system is also available.
23 (b)
The method for maintaining natural i
24 circulation conditions without pressurizer heaters is 25 similar to that discussed in 37(a).
The major 26 distinction is that the heat losses via the pressurizer 1 4
-._, _ _ _ _ _, _ _ - _ _ _.. _ _. _. _,. _ _ _ _ _._ _. _ _ _ __ _ __.--._ a
1 are less for the natural circulation case due to the 2
loss of driving head for the pressurizer spray (thus no 3
spray flow will enter the pressurizer) because the 4
Reactor Coolant Pumps (RCPs) are not running.
As a 5
result, a much longer period of time exists prior to 6
obtaining saturatio".1 conditions in the hot leg of the 7
RCS.
As in 37(a), the operator also has the option of 8
maintaining RCS nominal pressure by using the normal 9
charging system or the safety grade safety injection 10 system.
11 (c)
Since the pressurizer heaters are not used in 12 operating procedures for inadequate core cooling, no 13 alternate means are needed to mitigate the consequences 14 of inadequate core cooling.
15 (d)
If the pressarizer heaters are not available 16 following an anticipated operational occurrence or a 17 design basis accident, the operator can use either the 18 normal charging and letdown system or the high head 19 safety injection system to maintain or restore RCS 20 pressure at the nominal value.
Adoption of one of the 21 two pressure control modes in conjunction with 22 maintaining an effective heat sink in the secondary of 23 steam generator via the auxiliary feedwater system will 24 ensure that the system can be stabilized following a 25 postulated accident.
26 i
I
~11-
1 INTERROGATORY NO. 38:
2 Specify precisely each and every way in which the 3
pressurizer heaters and associated controls at Diablo Canyon 4
do not meet the safety-grade design criteria set forth in 5
Appendix A to 10 C. F. R. Part 50, and list each design.
6 criteria not 'omplied with.
7 8
ANSWER TO INTERROGATORY NO. 38:
9 The answer to ir.terrogatory 44 indicates that the 10 pressurizer heaters and associated controls are in 11 compliance with all applicable NRC requirements and.are 12 therefore also in compliance with all applicable safety 13 grade design criteria of Appendix A to 10CFR50, specifically 14 10, 14, 15, 17 and 20 as -noted in item II.E.3.1 of 15 NUREG-0737 and GDC 2,
3, 4,
10 and 22 as listed in the 16 answer to interrogatory 35.
17 18 19 l
20 21 22 23 24 25 26 -
6 1
INTERROGATORY NO. 39:
2
. Describe in detail what changes, if any, have been 3
made in the design, construction, installation, or operation 4
of the pressurizer heaters and associated controls at Diablo 4
5 Canyon since the TMI-2 accident in March 1979.
With respect 6
to any changes or alterations, specify how, if at all, they 7
are expected or intended to enhance the reliability of the 8
components and/or safe operation of the plant, and state 9
each and every fact upon which your response is based.
10 f'
11 ANSWER TO INTERROGATORY NO. 39:
12 As required by NUREG-0660 and 0737, the following 13 changes have been made since March 1979:
14 (A)
Two circuit breakers were added -- one on each ESF bus 15 G and H to provide the capability to supply two heater 16 groups with emergency power.
i 17 (B)
Two transformer switches were added to isolate the l-18 above heater groups from either the offsite or the 19 emergency power source.
I 20 (C)
Necessary interconnecting power and control wiring were j
i I
21 added.
l 22 (D)
Wattmeters were installed indicating the power demand 23 of the heater groups which can be connected to the ESF 24 buses.
25 Operating Procedure OP A-4A:V was written to 26 incorporate design modifications to Pressurizer Heater i
-s
1 Groups No. 1-2 and 1-3, and it provides for transfer of 2
either Pressurizer Heater Group 1-2 or 1-3 from a non-vital 3
source.
This procedure addresses the loading limitation of 4
the diesel generator to assure reliability is not degraded.
5 Specific guidance is given for shedding selected loads, as 6
- required, from the vital bus to maintain the diesel 7
generator within its load capability.
8 These changes provide additional availability and j
)
9 reliability of the power source supplying the pressurizel 10 heaters, which can reduce the number of challenges to the 11 Emergency Core Cooling System by facilitating natural 12 circulation until offsite power is restored.
13 14 15 16 INTERROGATORY NO. 40:
17 Describe in detail what you consider to be the 18 implications, if any, of the experience at TMI-2 in-March 19 1979 with respect to the design, installation, maintenance, 20 and/or operation of the pressurizer heaters and associated 21 controls at Diablo Canyon.
State each fact upon which your 22 response is based.
23
///
24
///
25
///
26 -
4 i
1 ANSWER TO INTERROGATORY NO. 40:
2 PGandE agrees with the NRC Staff that the capabil-3 ity to maintain pressure control in the reactor coolant sys-4 tem is an important safety aspect, and that this capability 5
should be available during anticipated operational occur-6 rences.
To enhance this capability and provide additional 7
availability and reliability to the pressurizer heater 8
system, the capability of providing power to the pressurizer 9
heaters from the on-site emergency bus has been provided at 10 the DCPP.
Reactor operations personnel have been provided 11 training and procedures related to the use of the on-site 12 emergency bus to provide power to the pressurizer heaters.
13 14 INTERROGATORY NO. 41:
15 With respect to the pressurizer heaters and 16 associated controls at Diablo Canyon, specify in detail:
17 (a) their precise location in Units 1 and 2; 18 (b) the precise specifications to which they were ordered 19 and/or designed and any differences between the design 20 speci fications on the one hand and the heaters and 21 associated controls as installed on the other; 22 (c) their manufacturer; 23
///
24
///
25
///
26.
~
-. = _
1 i
j i
1
- (d) the precise location of all seismic-related supports, 2
hangers, snubbers, etc., which are attached to, relate 3
to, or in any way could affect operation of the t
4 heaters, associated controls, and/or associated cables, 5
electrical or otherwise; 6
(e) the precise polar position and elevation and coordinate 7
location with respect to the center of the containment
}
8 at which the cables for the pressurizer heaters cross 4
9 the annulus in Diablo Canyon, Unit 1.
l 10 11 ANSWER TO INTERROGATORY NO. 41:
r 12 (a)
The location of the pressurizer heater Class 13 lE equipment for Unit 1 is as follows:
14 (1) 480 volt vital breakers 52-1G-72 and 15 52-lH-74 are located in the Auxiliary Building, Area H, 4
16 Elevation 115 '-0",
in the 480 Volt Vital Switchgear 17 Rooms 1G and 1H, on the East wall.
18 (2)
The control switches for the 480 volt i
19 vital breakers are located in the Auxiliary Building, 20 Area H, Elevation 140 '-0",
in the control room, on l
21 control console CCl.
22 The location of the pressurizer heater Class 23 lE equipment for Unit 2 are found in locations.
24 comparsble to the Unit 1 equipment.
25
///
4 26
///
4 1
- J
. -.,.., -.,. _, ~ -. -.. - _. - - -. -.. - - --. -
1 (b)
The pressurizer heater Class lE equipment 2
specifications can be found in the following documents:
3 (1)
The specifications for the 480 volt 4
circuit breakers and enclosures can be found on 5
Purchase Order No.'s 4R-40053 and 4R-45511 for Unit 1 6
and Unit 2 respectively.
7 (2)
The Class 1E cable used for connection 8
between the 480 volt vital breaker and bus 9
specifications can be found on Purchase Order No.
10 4R-0703.
11 (3)
The specifications for the vital control 12 switches were purchased as part of the Nuclear Steam 13 Supply System and can be found in specification 8700.
14 (4)
The support structure specifications for 15 the 480 volt vital breakers can be found on PGandE 16 drawing 050053, detail 34.
All equipment was purchased 17 and installed in accordance with specifications.
18 Pressurizer heaters for Units 1 a"d 2 were 19 manufactured in accordance with Westinghouse Equipment 20 Specification 676440, Rev. 4 and Addendum 677231, 21 Rev.
O.
22 (c)
Presssurizer heaters were manufactured by 23 Weigand.
24 (d)
The pressurizer heaters Class lE equipment 25 seismic supports are limited to the 480 volt vital i
1 26 breaker enclosure supports which are located in the i
i 1
Auxiliary Building, Area H, Elevation 115'-0",
in the 2
480 Volt Vital Switchgear 1G, lH, 2G and 2H Rooms.
3 (e)
The pressurizer heater power cables cross the 4
annulus of the containment for Unit' 1 in three basis i
5 groups:
6 (1)
Group 1 runs from penetration 37E via 7
tray EJB from a polar position of 256 and an elevation
}
8 of 120'-6" crossing the annulus and ending at a polar 9
position of 333 and an elevation of 128'-0".
10 (2)
Group 2 runs from penetration 34E via 11 trays EJC, EJCA and EJCB from a polar position of 250 12 and an elevation of 120'-6" crossing the annulus and l
13 ending at - a polar position of 330 and an elevation 14 113'-0".
15 (3)
Group 3 runs from penetration lE via 16 trays DJ, DJA and DJB from a polar position of 200 at 17 an elevation of 120'-6" crossing the annulus and ending--
18 at a polar position of 60* (DJA) and 57* (DJB) and'an I
j 19 elevation of 113'-0".
20 i
21 l
l 22
]
23 l
24
- l 25 1
26
' i._-.,_..._.-,.........-_____.._._._.-_.___...___.___.--___..___.__-~_--._.._
1 INTERROGATORY NO. 42:
2 List and describe in detail all analyses and tests 3
conducted by you, your agents, or your consultants with 4
respect to the pressurizer heaters and associated controls.
5 Specify:
1 6
(a) the person or entity conducting the analyses or tests; 7
(b) the purpose (s) of the_ analyses or tests; 8
(c) the range of test conditions or conditions assumed in 9
the analyses; 10 (d) the specifications of the components tested or 11 analyzed; 12 (e) the results of the tests or analyses; 13 (f) any other tests or analyses planned to be conducted 14 prior to full power operation.
15 16 ANSWER TO INTERROGATORY'NO. 42:
j 17 As required by the Westinghouse specification, the 18 following tests were performed by the supplier on the 19 pressurizer heaters:
20 (1)
Continuity test 21 (2)
High Potential test 1
22 (3)
Radiography - full length examination in 23 two planes ninety (90) degrees apart 24 (4)
Megger Resistance test 25 l
26
' I
1 INTERROGATORY NO. 43:
2 State whether you contend that the pressurizer 3
heaters and associated controls at Diablo Canyon should be 4
classified as important to safety and required to meet all 5
applicable safety-grade design criteria, and state each and 6
every fact upon which your response is based.
7 8
ANSWER TO INTERROGATORY NO. 43:
9 The response to Interrogatory 36 discussed in 10 detail the conditions under which the pressurizer heaters 11 are assumed to operate during normal operation, design 12 transients and following post accident conditions.
13 Furthermore, the response to Interrogatory 37 specified the 14 equipment that is available to the operator to utilize in 15 lieu of using the pressurizer heaters for RCS pressure 16 control.
17 To summarize the above two responses, the 18 pressurizer heaters provide only one of a number of methods 19 for controlling RCS pressure.
The other methods utilize 20 safety grade components.
Therefore, the pressurizer heaters j
21 need not be classified as important to safety.
1, 22 i
23 1
24 25 26
~
1 INTERROGATORY NO. 44:
2 Describe what modifications would have to be made 3
in - the Diablo Canyon pressurizer heaters and associated 4
controls to bring them into compliance with all applicable 5
safety-grade design criteria.
Estimate the minimum time 6
period necessary to make those modifications, and state each 7
and every fact upon which your estimate is based.
8 9
ANSWER TO INTERROGATORY NO. 44:
10 The pressurizer heaters and associated controls 11 are presently in compliance with all applicable existing NRC 12 rules and regulations.
In addition, the design and 13 installation of the pressurizer heaters and associated 14 controls have been reviewed and accepted by the NRC Staff as 15 noted on pages 2-19 through 2-21 of Supplement 14 of the 16 Diablo Canyon SER.
17 Since the pressurizer heaters and associated 18 controls are in compliance with NRC requirements, and are in 19 compliance with safety-grade design criteria of Appendix A 20
-to 10CFR50, 10, 14, 15, 17 and 20, as required by item 21 II.E.3.1 of NUREG-0737, no modifications are required.
22 23 24 25 26 j
i t
i !
~
1 INTERROGATORY NO. 45:
2 Specify precisely. (a) which Emergency Operating 3
Procedures for Diablo Canyon include the use of pressurizer 4
heaters and (b) which require that the heaters be switched 5
to the on-site power supplies.
6 7
ANSWER TO INTERROGATORY NO. 45:
8 (a)
The following DCPP Emergency Operating 9
Procedures include the use of pressurizer ' heaters:
10 EP OP-0, REACTOR TRIP WITH SAFETY INJECTION 11 EP OP-1, LOSS OF COOLANT ACCIDENT 12 EP OP-2, LOSS OF SECONDARY COOLANT 13 EP OP-3A, STEAM GENERATOR TUBE RUPTURE 14 EP OP-4, LOSS OF ELECTRICAL POWER 15 EP OP-8, CONTROL ROOM INACCESSIBILITY 16 EP OP-13, MALFUNCTION OF REACTOR PRESSURE CONTROL 17 SYSTEM 18 EP OP-23, NATURAL CIRCULATION OF REACTOR COOLANT 19 EP OP-44, GASEOUS VOIDS IN THE RCS.
20 (b)
The following DCPP Emergency Operating 21 Procedures direct the operator to transfer a
22 pressurizer heater group to a vital power supply for 23 use, as required, to maintain RCS pressure.
24 EP OP-4, LOSS OF ELECTRICAL POWER 25 EP OP-8, CONTROL ROOM INACCESSIBILITY 26 1
INTERROGATORY NO. 46:
2 Explain the present Applicant position on Joint 3
Intervenors contention 12, regarding valve design, and state 4
each and every fact on which that position is based.
5 6
ANSWER TO INTERROGATORY NO. 46:
7 The Reactor Coolant System at Diablo Canyon Power 8
Plant Unit 1 contains three block valves and three relief 9
valves.
All of the block valves, as well as their 10 instruments and controls, have been classified as components 11 important to safety and have been designed and fabricated to 12 meet all safety-grade design criteria.
In addition, two of 13 the three relief valves and their associated circuitry have 14 been classified as components important to safety and meet 15 all safety-grade design criteria.
The remair.ing relief 16 valve, which does not meet all safety-grade design criteria, 17 was installed to provide 100% local rejection without trip-18 ping the reactar.
It provides no safety related function.
19 The DCPP relief valves, block valves and 20 associated instruments and controls have been designed and 21 fabricated to meet all applicable requirements.
22 Furthermore, there has been a long history of successful 23 operation of relief and block valves representative of DCPP 24 valves under full power operation at other similar plants.
25 Therefore, these valves have been demonstrated to be capable 26 of functioning under required operating conditions.
t I
1 Westinghouse has performed analyses to show that, 2
even if all of the relief valves, block valves and their 3
associated ' controls and instruments had failed during full 4
power _ operation, core uncovery would not occur and public
~
5 health and safety would not be endangered.
6 7
.8 9
INTERROGATORY NO. 47:
10 Does the current position differ from the position 11 of the Applicant in any prior proceedings?
If so, identify 12 the proceeding (s), explain the prior position, and explain 13 the basis for the change in position.
j, 14 15 ANSWER TO INTERROGATORY NO. 47:
- ~
16 No.
I' 17 18 19 20 INTERROGATORY NO. 48:
21 Identify any officers or employees of, or 22 consultants to, the Applicant who dissent from the present 23 Applicant position on Joint Intervenors' contention 12.
24 Explain the reasons for which any such person dissents.
25
///
26
///
=
t 1
ANSWER TO INTERROGATORY NO. 48:
2 None.
{
3 i
4, 5
4 6
INTERROGATORY NO. 49:
7 Identify the specific sections and page numbers of 8
the FSAR for Diablo Canyon and the NRC Staff's SER and SER 9
Supplements for Diablo Canyon, which are relied upon in 10 formulating the Applicant position on Joint. Intervenors' 11 contention 12.
12 13 ANSWER TO INTERROGATORY NO. 49:
14 The following FSAR sections are identified:
15 3.1 Conformance with AEC' General Design Criteria 16 3.2 Classifi nation of Structures, Components and Systems 17 3.6 Criteria for Protection Against Dynamic Effects 18 Associated with a Postulated Rupture of Piping 19 3.9 Mechanical Systems and Components 20 5.2 Integrity of the Reactor Coolant System Boundary 21 15.1 Condition I-Normal Operation and Operational Transients 22 The following section of SER Supplement 15 is 23 identified:
i.
24 Appendix B:
Environmental Qualification of Safety-Related 25 Electrical Equipment 26 i.
! 4
~-- - --~-
1 INTERROGATORY NO. 50:
2 Identify all sections and page numbers of the 3
FSAR, SER, and SER Supplements which contain subject matter 4
pertaining to Joint Intervenors' contention 12.
5 6
ANSWER TO INTERROGATORY NO. 50:
7 Applicant objects to this interrogatory.
See 8
response to Interrogatory number 33.
9 10 11 12 INTERROGATORY NO. 51:
13 Does the Applicant agree that proper operation of 14 PORVs, associated block valves and the instruments and 15 controls for these valves is essential to mitigate the 16 consequences of accidents?
Exp'.ain your response fully.
17 18 ANSWER TO INTERROGATORY NO. 51:
19 The applicant agrees that proper operation of a 20
- PORV, associated block valve and the instruments and 21 controls for the necessary valves is essential to mitigate 22 the consequence of accidents.
23 The accident analyses presented in the DCPP Safety 24 Analysis Report demonstrate that the pressurizer power 25 operated relief valves (PORV) are not required to actuate 26 automatically on a pressure setpoint to nitigate the 1
consequences of the accidents, i.e.,
the licensing criteria 2
are met with or without automatic PORV opening when 3
requested.
- However, postulated transients have been 2
4 analyzed since TMI which require that the operator be 5
capable of manually opening and/or closing the PORV's.
For 6
such postulated transients, the proper. operation of a PORV 7
or block valve is essential.
8 For the case of an inadvertently stuck open PORV, 9
the operator has been trained in the use of an Emergency 10 Procedure describing the operations that must be implemented 11 to take the plant to a safe shutdown condition.
Once the 12 operator closes the associated PORV block valve, the plant 13 can immediately be restored to normal plant conditions.
)
14 15 16 17 INTERROGATORY NO. 52:
18 Does the Applicant agree that failures of these i
19 valves, instruments ar.d controls can cause or aggravate a 20 LOCA?
Explain your response fully.
21 22 ANSWER TO INTERROGATORY NO. 52:
23 The Applicant agrees that it is possible to 24 postulate scenarios in which failures of the PORV's and 25 their instruments and controls can result in a small break 26 LOCA.
An inadvertent opening of a pressurizer PORV result.s 4 em a
er. - -,-.
w~-w e.....-
--.w
,,m
,-,%,.,,---.4
.,4e.
s,,-., -,., - - - -
.v_,-
-.-.----w-
- -. +,, -..
.---w-.w.-
, - - - + -
1 in a breach of the RCS pressure boundary, necessitating the 2
actuation of the Emergency Core Cooling System (ECCS) to 3
mitigate the accident consequences.
Even though the DCPP l
4 design provides the operator with the capability to open 5
and/or close the PORV's with safety grade circuitry, the l
6 ECCS system is designed to mitigate the consequences of a 7
postulated failure of the PORV's to close.
8 9
10 4
11 INTERROGATORY NO. 53:
3 12 Provide the justification for the failure to 13 classify PORVs and associated block valves and their 14 respective instruments and controls as " components important-15 to safety," requiring compliance with safety-grade design 16 criteria.
1 17 18 ANSWER TO INTERROGATORY NO. 53:
19 All block valves (and their instruments and 20 controls) associated with the PORVs are classified as 21 safety-related.
Two of the three PORVs are classified as 22 safety-related although they are not required to be such.
23 Operation of only one PORV is necessary to fulfill the 24 required safety function.
To insure operation of one PORV, is redundant devices at~e provided.
Therefore, the third PORV 26
///
1 need not be classified safety-related.
Additional discus-2
-sions have been provided in response to Interrogatories 46 3
and 51.
4 5
6 7
INTERROGATORY NO. 54:
8 Explain how the motive and control components of 9
the PORVs and their associated block valves and the vital 10 instruments shall be supplied by the on-site emergency power 11 source when offsite power is not available without degrading 12 the capacity, capability and reliability of emergency power 13 in violation of GDC 17.
14 15 ANSWER TO INTERROGATORY NO. 54:
16 Normal plant instrument air supply (motive power) 17 to each redundant valve is provided with a dedicated high 18 pressure nitrogen backup system capable of operating the 19 valves 140 times.
This backup system is classified as 20 safety-related and is not dependent on any external power.
21 Power for control components of the three FORV's 22 is provided from three, _ Class lE, 125 V DC distribution 23 panels.
The distribution panels are redundant to each 24 other.
Power for motive and control for the three 25 associated block valves is provided from three, class lE, 26 480V AC motor control centers, each redundant to each other. L
1 The tot'al electrical design for these valves meets GDC 17.
2 Therefore, the capacity, capability and reliability of the 3
emergency power will not be degraded in the event of loss of 4
offsite power.
5 1
6 l
7 8
INTERROGATORY NO. 55:
9 How have the devices through which motive and i
10 control power components for the PORVs and their associated i
11 block. valves are connnected to emergency buses been i
12 qualified in accordance with safety-grade requirements?
13 14 ANSWER TO INTERROGATORY ~NO.
55:
15 The. devices _through which motive.and control power 16 components for the PORVs and their associated block valves i
i 17 are connected to emergency buses have been qualified in 4
a 18 accordance.with applicable safety-grade requirements as 19 follows:
j 20 control and power wiring subjected to a harsh 21 environment have been environmentally qualified for the 22 environment to which they could be subjected.
23 Circuit breaker panel boards and motor 24 control centers have been seismically qualified.
25 i
26 i
t
1 t
INTERROGATORY NO. 56:
2 With respect to the valves, instruments, and 3
controls cited in contention 12, list each and every General i
4 Design Criterion in Appendix A to 10 C.F.R. Part 50 which is 5
not complied with, and describe precisely in what respects 6
those valves, instruments, and controls do not comply.
7 8
ANSWER TO INTERROGATORY NO. 56:
4 9
With respect to the valves, DCPP complies with 10 4
General Design Criteria 1, 14, 15 and 30.
No other General 11 Design Criterion applies.
i 12 The instruments and controls associated with the 13 PORV's and block valves comply with all applicable safety 14 grade criteria of Appendix A to 10CFR50.
15 4
j 16 17 18 INTERROGATORY NO. 57:
19 Describe precisely each and every function of the 20 PORVs at Diablo Canyon, and for each such function, specify 1
21 in detail the operating conditions in which the PORVs would 22 be relied '2pon to perform that function.
23 4
///
25 fff 26 fff 1
...... m..
1 ANSWER TO INTERROGATORY NO. 57:
i 2
The Diablo Canyon power-operated relief valves 3
have three functions which are not safety-related.
4 1.
prevent reactor trip on high pressure by limiting high 5
pressure transients beyond the capability of the 6
pressurizer sprays.
2 7
2.
minimize the operation of the spring loaded safety 8
valves.
9 3.
vent non-condensible gases from the pressurizer to 10 proper operation of the pressure control system.
11 They have one safety-related function:
12 Provide cold overpressure protection on 13 startup and shutdown to maintain pressure below the
- 14 limits specified in Section 3/4.4.9 of the Technical 15 Specifications.
16 The PORVs would be expected and have been 17 qualified, but are not required, to perform all of the above 18 functions in conditions ranging from normal operation to:
19 1.
the Hosgri Seismic Event; i
20 2.
the loss of coolant accident as described in the FSAR, 1
21 and 22 3.
the main steam line break inside containment.
23 The latter two conditions would not pertain to low l
24 pressure operation.
I 25 26
- ww
- -e 7
4--w-v s-,-
g iw-i.-y y.3
- -.g
,---.m r
---w
i i
1 INTERROGATORY NO. 58:
2 Describe precisely each and every function of the 3
block valves at Diablo Canyon, and for each such function,
~
t 4
specify in detail the operating conditions in which the 5
block valves would be relied upon to perform that function.
6 7
ANSWER TO INTERROGATORY NO. 58:
8 The Diablo Canyon block valves have two functions:
9 1.
isolate leaking PORV until maintenance can be 10 performed, and 11 2.
isolate a stuck open PORV until the plant can be 12 shutdown.
13 Both of these functions are required to occur in a 14 normal operating environment, since operating procedures 15 direct the operator to close these valves and isolate the i
i 16 PORV before significant reactor coolant can escape to the 17 containment.
These valves have been qualified to function 18 in such environment and also during and after the Hosgri 19 Seismic Event.
[
20 21 I
l 22 i
23 INTERROGATORY NO. 59:
24 Specify precisely which Emergency Operating 25 Procedures for Diablo Canyon include the use of (a) PORVs 26 and (b) block valves..
l 1
ANSWER TO INTERROGATORY NO. 59:
2 The following DCPP Dmergency Operating Procedures 3
specify the use of Pressuri2.er FDRV's and/or PORV block 4
valves :
5 EP OP-0, REACTOR TRIP WITH SAFETY INJECTION 6
EP OP-1, LOSS OF COOLANT ACCIDENT 7
EP OP-2, LOSS OF SECONDARY COOLANT 8
EP OP-3A, STEAM GENERATOR TUBE RUPTURE 9
EP OP-4, LOSS OF ELECTRICAL POWER 10 EP OP-5, REACTOR TRIP WITHOUT SAFETY INJECTION 11 EP OP-13, MALFUNCTION OF REACTOR PRESSURE CONTROL 12 SYSTEM 13 EP OP-22, EMERGENCY SHUTDOWN 14 EP OP-38, ANTICIPATED TRANSIENT WITHOUT TRIP 15 16 17 18 INTERROGATORY NO. 60:
19 Describe in detail what modifications would have 20 to be made in the PORVs, block valves, instruments, and 21 controls referred to in contention 12 to bring them into 22 compliance with all applicable safety-grade design criteria.
23 Estimate the minimum period necessary to make those 24 modifications, and state each and every fact upon which your 25 estimate is based.
26
///
1 ANSWER TO INTERROGATORY NO. 60:
2 The necessary power operated relief valves, 3
associated block valves, and the instruments and controls 4
for these valves presently comply with all applicable 5
safety-grade design criteria and therefore no modifications 6
are required.
7 8
9 10 INTERROGATORY NO. 61:
11 Describe in detail the current status of the EPRI 12 valve performance testing program.
In your response, state:
13 (a) when the relief and safety valve testing will be 14
- completed; 15 (b) under what conditions (e.g.,
transition flow, full 16 water flow, saturated steam, etc.) have the relief and 17 safety valves been tested to date; 18 (c) whether any of the relief and safety valves tested have 19 failed, suffered galling, or been in any way damaged 20 during the testing, and, if so, describe in detail the 21 circumstances of such occurrences; 22 (d) why the relief and safety valve testing program 23 completion date has been delayed and when the program 24 is now scheduled to be completed; 25 (e) whether an EPRI block valve testing program is planned 26 and, if so, when it will be completed;
~.
1 (f) other than the block valve failures discussed at the 2
Diablo Canyon low power test hearing in May 1981, 3
whether any of the block valves tested have failed, 4
suffered galling, or been in any way damaged during the 5
- testing, and, if so, describe in detail the 6
circumstances of such occurrencec; 7
(g) whether PGandE has submitted to the NRC a correlation 8
or other evidence to substantiate that the valves 9
tested in the EPRI program demonstrate the 10 functionability of the relief and safety valves 11 installed at Diablo Canyon, and, if so, describe that 12 correlation or other evidence in detail; 13 (h) to what extent, if at all, the control circuitry, 14 piping, and supports associated with the Diablo Canyon 15 relief and safety valves have been qualified, and, if 16 so, describe precisely how they have been qualified and 17 the results of any related tests or analyses; 18 (i) when the " correlation" referred to in subpart (g) of 19 this interrogatory will be submitted to the NRC.
20 21 ANSWER TO INTERROGATORY NO. 61:
22 The Applicant objects to this interrogatory on the 23 basis of relevancy.
The EPRI valve performance testing 24 program is clearly outside the scope of this contention, 25 which concerns the classification of power operated relief 26 valves, block valves and associated circuitry, and _
1 compliance with design criteria.
The EPRI test program was 2
litigated in the low power hearings which resulted in a 3
license being issued.
4 5
6 7
INTERROGATORY NO. 62:
8 On August 19, 1981, an emergency planning exercise 9
for Diablo Canyon was held in San Luis Obispo.
Based on 10 your involvement in that exercise and your knowledge of the 11 involvement of other persons, officials, agencies, or other 12 entities, describe the exer i.se in detail and include in 13 your response at least the following information:
14 (a) a detailed description of the exercise scenario 15 employed, including the simulated events, time period 16 and locations involved:
17 (b) the number of persons participating in the drill.
18 including the specific company, agency, or other entity 19 represented, if any, and the extent and nature of their 20 involvement; 21 (c)
(1) the number of PGandE personnel assumeJ or deemed to 22 have been evacuated during the course of the exercise; 23 (2) the number of PGandE employees actually evacuated, 24 and (3) when such evacuation was begun and when 25 completed; 26
///
1 (d)
(1) the number of non-PGandE persons (e.g., members of 2
the public) assumed or deemed to have bcen evacuated 3
and/or sheltered during the course of the exercise, 4
(2) the number of such persons actually evacuated 5
and/or sheltered, and (3) when such evacuation was 6
hegun and when completed; 7
(e)
(1) the number of ambulances assumed or deemed to have 8
been utilized during the course of the exercise and 9
(2) the number of ambulances actually utilized; 10 (f)
(1) the number of simulated injured persons assumed or 1
'1 deemed to have been transported to and treated at 12 French Hospital during the course of the exercise and 13 (2) the number of simulated injured persons actually 14 transported and treated at French Hospital; j
15 (g)
(1) the number of simulated injured persons assumed or 16 deemed to have been trancported to and treated at 17 St. Francis Hospital in San Francisco during the course J
18 of the exercise and (2) the number of simulated injured 19 persons actually transported to and treated at i
20 St. Francis Hospital.
I 21 (h)
(1) the number of residences and/or households in_ San 22 Luis Obispo and Santa Barbara Counties assumed or i
23 deemed to have been contacted during the exercise, 24 (2) the nunber and location of such residences and/or 25 households actually contacted, and (3) the time period 26 required to contact such residences and/or households;
1 (i)
(1) the number of automobiles assumed or deemed to have-2 utilized Highway 101 as an evacuation route during the 3
course of the exercise and (2) the number of 4
automobiles which actually utilized Highway 101 as an 5
evacuation route; 6
(j)
(1) the number of persons or automobiles assumed or 7
deemed to have utilized Highway 1 as an - evacuation 8
route during the course of the exercise and (2) the 9
number of persons or automobiles which actually 10 utilized Highway 1 as an evacuation route; 11 (k)
(1) the number of persons or automobiles assumed or 12 deemed to have utilized Avila Road as an evacuation 13 route during the course of the exercise and (2) the 14 number of persons or automobiles which actually used 15 Avila Road as an evacuation route; 16 (1)
(1) the number of persons ' assumed or deemed to have 17 been notified of a radiological emergency occurring at 18 Diablo Canyon during the course of the exercise, i
l 19 (2) the number and location of persons actually e
20 notified of such emergency, and (3) the time period 21 required to complete such notification; 22
///
23
///
24
///
25 26 i _. - - _
1 (m)
(1) the number of emergency response personnel (i.e.,
2 law enforcement,
- fire, health,
- park, military, 3
monitoring, etc.) assumed or deemed to have been 4
mobilized and/or dispatched during the course of the 5
exercise and (2 ) the number of such personnel actually 6
mobilized and/or dispatched:
7 (n)
(1) the protective actions assumed or deemed to have 8
been taken within the plume exposure pathway EPZ by 9
public officials, emergency response personnel, and 10 members of the public during the course of the exercise 11 and (2) the protective actions actually taken by such 12 persons within the area specified; 13 (o)
(1) the protective actions assumed or deemed to have 14 been taken within the ingestion pathway EPZ by public 15 officials, emergency response personnel, and members of 16 the public during the course of the exercise and 17 (2) the protective actions actually taken by such 18 persons within the area specified; 19 (p)
(1) the number and locations of radiological monitoring 20 samplings assumed or deemed to have been taken during 21 the course of the exercise and (2) the number and 22 location of such samplings actually taken; 23 (q)
(1) the number of persons involved in the exercise and 24 (2) the number of persens reasonably expected to be 25 involved in an actual radiological emergency at Diablo 26 Ca.nyon; -
j.W*,A L
.d
-e-JJ>
I I
1 (r)
(1; the number of automobile accidents or collisions, 2
if any, assumed or deemed to have occurred on main 3
evacuation routes during the course of the exercise and 4
(2) the number of such accidents or collisions 5
reasonably expected to occur in the event a full scale 6
evacuation-is crdered in response to an actual 7
radiological emergency-at Diablo Canlon; 8
(s)
(1) the types and quantities of-emergency response 9
equipment (e.g., communications equipment, respiratory 10 equipment, protective clothing, monitoring equipment, 11
- vehicles, helicopters,
- signs, placards, ' medical 12 equipment, etc.) assumed'or deemed to-be available or-13 to have been used.during the course of the accident and 14 (2) the types and quantities of such equipment actually 15 available or used; i
16 (t)
(1) the number of media personnel present and inquiries l
17 from the public received during the course of the 18 exercise and the number of such personnel likely to be 19 received in the event of an actual radiological 20 emergency at Diablo Canyon; 21 (u) the names of all local and state officials, agencies,.
t 22 o f fices, and/or other entities actually notified as.
23 part of the exercise, by telephone or otherwise, 24 regarding the simulated emergency at Diablo Canyon; the i
25 approximate time of each such notification; the precise 26 language of the notification message; the name of the
, [
1 person who notified such officials and/or agencies; the 2
names of each person who received the notice; and the 3
time period required to complete notification of all 4
such persons.
5 6
ANSWER TO INTERROGATORY NO. 62:
7 (a)
A detailed description of the exercise 8
scenario utilized on August 19, 1981 has been provided.
9 Reference discovery document sPNG 59753 - Diablo Canyon 10 Power Plant Emergency Preparedness Exercise Scenario.
11 (b)
The following major entities to the best of 12 our knowledge participated in the August 19, Exer;ise:
13 1)
Pacific Gas and Electric Company 14 2)
County of San Luis Obispo and supporting agencies 151 identified in the SLO County Nuclear Power P3 ant 16 Emergency Response Plan including:
17 a)
Chairman, County Board of Supervisors 18 b)
Emergency Services Director 19 c)
County H.]th Agency / County Health Officer 20 d)
Environmental Health Lirector 21 e)
Air Pollution Control District 22 f)
Agricultural Commissioner 23 g)
County Public Information Officer 24 h)
County Social Services 25 i)
Red Cross 26 j)
County Engineer t
1 k)
County Fire Department 2
1)
County General Services 3
m).
County Counsel l
4 n)
County Superintendent of Schools I
5 o)
County Sheriff 6
p)
Area Fire and Rescue Coordinator 7
q)
County Technical Services 1
8 3)
City of Morro Bay 9
4)
State Office of Emergency Services 10 5)
Other State Agencies 11 The number of persons participating in the i
12 exercise representing these various entities varied 13 from several to approximately 200.
The extent and 14 nature of their involvement is defined in the agencies i
15 various emergency plans and standard operating 16 procedures.
These are discoverable documents.
l 17 (c)
(1)
During the course of the exercise, i
18 approximately 250 PGandE personnel were assumed to have 19 evacuated.
20 (2)
During the exercise on August 19, 1981, 21 11 PGandE amployees were actually evacuated.
22 (3)
The evacuation began at 9:05 a.m.
and i
23 was completed by 11:00 a.m.
1 24 (d)
(1)
Approximately 53,000 non-PGandE persons 25 were assumed to have been evacuated and/or sheltered 1
26 during the course of the exercise.
i r - - - - -
1 (2)
The number of persons actually evacuated 2
and/or sneltered during the exercise was 45.
These 3
persons were evacuated from Montada de Oro State Park.
4 (3)
The evacuation began at 10:15 a.m.
The 5
evacuees arrived at Camp Roberts at 10:15 a.m.
They 6
were released at 2:30 p.m. and were returned to Montana 7
de Oro at 4:00 p.m.
8 Note:
Additional evaucation capability was 9
demonstrated when plant security personnel 10 turned away substantial numbers of 11 construction workers reporting for work 12 during the exercise.
13 (e)
(1)
During the course of the exercise, two 14 (2) ambulances were assumed to have been utilized.
15 (2)
One ambulance was actually utilized 16 during the course of the exercise.
17 (f)
(1)
During the course of the exercise, one 18 (1) person was assumed transported to French Hospital.
19 (2)
One simulated injured person was 20 actually transported and treated at French Hospital.
21 (g)
(1)
During the course of the exercise, no 22 simulated injured persons was assumed transported to 23 and treated at St. Francis Hospital.
24 (2)
No simulated injured persons were 25 actually transported to and treated at St. Francis 26 Hospital.
J i
1 1
(h)
(1)
None.
2 (2'
None.
I 3
(3)
Not applicable:
Ref (2) above.
4 (i)
(1)
Approximately 3,100 vehicles were 1
5 assumed to have utilized Highway 101 as an evauation 6
route during the course of the exercise.
e i
7 (2)
Approximately 45 persons (1
Bus) 8 actually utilized Highway 101 as an evacuation route i
9 during the exercise.
10 (j)
(1)
Approximately 1500 vehicles were assumed 11 l
to have utilized Highway 1 as an evacuation route 12 during the course of the exercise.
13 (2)
Approximately 45 persons (1 Bus) 14 actually utilized Highway 1 as an evacuation route 15 during the exercise.
i 16 (k)
(1)
Approximately 1200 vehicles were assumed 17 to have utilized Avila Road as an evacuation route 18 during the course of the exercise.
19 (2)
Approximately 4 vehicles actually used 20 Avila Road as an evacuation route.
21 (1)
(1)
Millions of persons were assumed to have 22 been notifed of a radiological emergency occurring at
)
23 Diablo Canyon during the course of the exercise.
24 (2)
Hundreds of thousands of people 25 throughout the country were actually notified of such 26 an emergency.
a T
1 (3)
Notification was completed over a period 2
- a few hours.
3 f,a )
_(1)
The number of emergency response personnel assumed or deemed to have been mobilized 4
5 and/or dispatched during the course of the exercise is 6
unknown.
7 (2)
The number of such personnel actually 8
mobilized and/or dispatched is unknown.
1 1
9 (n)
(1)
Protective actions assumed or deemed to 10 have been taken within the plume exposure LPZ by public 11 officials, emergency response personnel, and members of 12 the public during the course of the exercise included 13 evacuation, recommendations to administer potassium 14 iodide pills to place livestock on stored feed.
15 (2)
Some evacuation measures were actually 16 demonstrated.
Recommendations were made to administer 17 potassium iodide pills and to place livestock on stored 18 feed.
19 (o)
(1)
Protective actions assumed or deemed to i
20 have been taken within the ingestion pathway EPZ by i
21 public officials, emergency response personnel, and 22 members of the public during the course of the exercise 23 included county announcements restricting reentry into 24 the evacuated area pending completion of ingestion 25 pathway studies.
26
///
i d
1 (2)
No protective actions were actually 2
taken-by such persons within the area specified.
3 (p)
(1)
See answer to Part (2) of this question.
4 (2)- Approximately forty-eight (48) ambient, 5
particulate or deposition radiation samplings were 6
actually taken (i.e.,
instruments
- deployed, 7
calculations made, etc.)
at-various locations as 8
dictated by meteorological conditions and plume 9
dispersal, during the August 19, 1981 exercise.
10 The compressed timeframe required by the 11 exercise resulted in a lesser number of radiation 12 samplings than would result in an actual radiological 13 accident.
l 14 (q)
(1)
Approximately 400-500 persons were j
15 involved in the exercise.
16 (2)
Approximately 400-500 persons can 17 reasonably be expected to be involved in an actual 18 radiological emergency at Diablo Canycn.
19 (r)
(1)
One automobile accident was assumed to 20 have occurred on main evacuation routes during the 21 course of the exercise.
22
///
23
///
24
///
25 26
1 (2)
It is impossible to predict the number 2
of such accidents reasonably expected to occur in the 3
event of a full scale evacuation is ordered in response 4
to an actual radiological emergency at Diablo Canyon.
5 The scope of the evacuation area has not been defined 4
6 e.g.,:
LPZ, 1 Sector or multiple sector evacuations.
7 (s)
(1)
Applicant objects to this question on I
8 the basis that it is (a) impg sible to answer, (b) 9 overly broad, (c) not fully within the knowledge of the 10 answering party anti (d) not designed to lead to 11 admissible evidence.
i 12 (t)
(1)
Approximately 20-30 media personnel were 13 present during the August 19, 1981 exercise.
Inquiries 14 from the public were few in number.
It is impossible 15 to predict the number of such personnel likely to be l
16 present and inquiries from the public likely to be f
17 received in the event of an actual radiological 18 emergency at Diablo Canyon.
Such a response would be 19 dependent upon many variables including the scope, 20
- extent, duration of the accident as well as the 21 significance of other breaking newsworthy events.
i 22 (u)
All major entitled participating in the i
23 August 19, 1981, exercise were contacted following the 24 appropriate emergency plans and standard operating 25 procedures.
Communications logs and in some instances 26 tape recordings of conversations were recorded to. -,., - -
i i
i j
1 document major events.
This material has been 2
submitted for discovery.
I 3
~4 INTERROGATORY NO. 63:
5 Based on your involvement in the August 19, 1981 6
emergency planning exercise arid your knowledge of the 7
involvement of other persons, officials, agencies, or other 8
entities in that exercise, provide a detailed chronology of 9
all actions taken by the participants in connection with the 10
- exercise, and include in that chronology at least the 11 following information:
12 (a) the time each action was taken; 13 (b) the name of the person taking the action; 14 (c) the office, agency, or other entity 2.epresented by that 15 person;
[
16 (d) any problems or difficulties encountered by that person 17 in taking the action; 18 (e) the location of the action, including, for example, y
19 point of origin and point of destination; 20 (f) any equipment (i.e.,
vehicles, walkie-talkie, radio, 21 protective clothing, etc.) utilized in taking the 22 action; 23 (g) the consequences resulting from the action.
24
///
25
///
26
///.
1 ANSWER TO INTERROGATORY NO. 63:
2 A detailed chronology of all actions taken by the 3
participants in connection with the exercise in the level of 4
detail requested is not available.
The following documents 5
have been provided for discovery and to some extent will 6
contain particular information regarding specific emergency 7
response actions in light of the very broad, general content 8
of this request.
9 DOCUMENT NUMBER 10 EPPI-0090023 EPPI-0090062 EPGP-0095193 EP:?I-0090024 EPPI-0090120 EPCO-0095628 11 EPPI-0090032 EPPI-0090142 EPPA-0095705 EPPI-0090062 EPAD-0092221 EPCE-0095764 12 EPPI-0090104 EPPI-0093859 EPCE-0095765 EPPI-0090120 EPPI-0093864 EPCE-0095766 13 EPPI-0090142 EPPI-093865 EFCE-0095767 EPNP-0083334 EPPI-0093866 EPCE-0095836 14 EPED-0086113 EPPI-0094072 EPSH-0096005 EPNP-0088768 EPPI-0094073 EPDC-0096115 15 EPPI-0090023 EPPI-0094074 EPDC-0096112 EPPI-0090024 EPPI-0094075 EPDC-0096128 16 EPPI-0090032 EPPI-0094078 EPDC-0096145 EPPI-0090033 EPPI-0094082 EPDC-0096161 17 EPPI-0090034 EPPI-0094083 EPSO-0096637 EPPI-0090045 EPPI-0094084 EPSO-0096639 18 19 20 21 INTERROGATORY NO. 64:
22 Explain in detail how the exercise included such 23 things as 24 (a) simulated casualties; 25 (b) offsite fire department assistance;
}
26 (c) rescue of personnel; 1
(d) use of protective clothing; 2
(e) deployment of radiological monitoring teams; and 3
(f) public information and notification activities.
4 5
ANSWER TO INTERROGATORY NO. 64:
6 (a)
The exercise scenario provided one simulated 7
casualty, a broken leg, when a worker slipped and fell 8
while exiting the reactor containment building.
Two 9
additional simulated casualties were provided, by the 10 exercise scenario, when the ambulance transporting the 11 broken leg victim was involved in an automobile 12 accident.
All three casualties simulated 13 unconsciousness due to the ambulance accident.
14 (b)
The California Department of Forestry (CDF) 15 participated in a communications capability check 16 during the exercise.
All other offsite fire fighting 17 assistance was simulated during the exercise.
18 (c)
The broken leg victim was carried out of the 19 reactor containment building by a first aid team using 20 a stretcher.
Ambulance accident victims were assisted j
21 by medics from a simulated second ambulance.
22 (d)
The first aid teams that assisted injured, 23 contaminated personnel wore anti-contamination 24 clothing.
Fire fighting teams wore standard fire 25 fighting protective clothing and associated equipment 26 such as respirators.
-i. -
1 (e)
The onsite radiological monitoring team was 2
deployed, in accordance with radiological monitoring 3
procedures, by Technical Support Center personnel.
The 4
three offsite radiological monitoring teams, including 5
the mobile environmental monitoring laboratory, were 6
deployed by Emergency Operations Facility personnel in 7
accordance with their Standard Operating Precedures.
8 (f)
Public information was disseminated through 9
the joint PGandE/ County Public Information Center / Media 10 Center.
Public notification is the responsibility of 11 San Luis Obispo County officials and was simulated 12 through the use of SLO County Emergency Plan 13 implementing procedures.
14 15 16 17 INTERROGATORY NO. 65:
18 State how, if at all, the August 19 exercise 19 simulated and/or tested for the complicating effects of a 20 major earthquake on emergency response capability at Diablo 21 Canyon.
22 23 ANSWER TO INTERROGATORY NO. 65:
24 The August 19, 1981, accident scenario did not 25 incorporate an earthquake incident.
26 -
1 INTERROGATORY NO. 66:
2 State what, if any, critical emergency response 3
equipment.(i.e., vehicles, communications systems and lines, 4
monitoring equipment, notification sirens, etc.) were 5
assumed to fail during the course of the August 19 exercise.
6 1
7 ANSWER TO INTERROGATORY NO. 66:
8 No critical emergency response equipment was 9
assumed to fail during the course of the August 19 exercise.
t j
10 11 12 13 INTERROGATORY NO. 67:
14 State what, if any, evacuation routes 15 (a) for the site and 16 (b) for the plume exposure pathway EPZ 17 were assumed to be fully or partially blocked during the 7
18 course of the August 19 exercise.
19 j
20 ANSWER TO INTERROGATORY NO. 67:
l 21 (a)
None.
{
22 (b)
None.
23 24 25 26 l
l l t
1 INTERROGATORY NO. 68:
2 In light of the information and experience gained 3
from the August 19 exercise, what revisions, changes, or 4
alterations, if any, will be made in the following documents 5
prior to full power operation of Diablo Canyon:
6 (a) the Diablo Canyon on-site emergency plan and emergency 7
procedures; 8
(b) the San Luis Obispo County emergency and evacuation 9
plans; 10 (c) the State of California emergency plan; 11 (d) the San Luis Obispo County Sheriff's " plan" (Board 12 Exh. 5 at Diablo Low Power Test hearing).
13 14 ANSWER TO INTERROGATORY NO. 68:
15 On October 15, 1981, representatives from FEMA, 16 San Luis Obispo County, California State Office of Emergency 17 Services, and NRC Region V met in Sacramento to review FEMA 18 findings and recommendations identified following the 19 August 19 exercise.
A draft open item action list was 20 established on responsibilities assigned for closure.
21 Activities are now in progress to finalize this document, 22 including task completion schedules.
This document will be 23
///
24
///
25 fff 26 1
furnished as a supplement to PGandE's response to the 2
request for production of documents.
3 4
Respectfully submitted, 5
MALCOLM H.
FURBUSH PHILIP A. CRANE, JR.
6 RICHARD F. LOCKE Pacific Gas and Electric Company 7
P.O.
Box 7442 San Francisco, California 94120 8
(415) 781-4211 9
ARTHUR C. GEHR Snell & Wilmer 10 3100 Valley Center Phoenix, Arizona 85073 11 (602) 257-7288 12 BRUCE NORTON
.Norton, Burke, Berry & French, P.C.
13 3216 N. Third Street Suite 300 14 Phoenix, Arizona 85012-2699 (602) 264-0033 15 Attorneys for 16 Pac' Gas and El tr' Company 1
e B
s ude Nor$on 19 L
20 DATED:
October 26, 1981.
21 22 23 24 25 26 JOINT INTERVENORS' SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 46-50, 51, 52, 53, 60, 61 Said answers are true and correct to the best of my knowledge and belief.
G. C. Wu Subscribed and swora to before me this 26th day of October, 1981.
O SE'A': i Theodora C'ooke, hotary Public
~
in and for the City and County of San Francisco, State of California My Comission expires January 28, 1985 l
JOINT INTERVENORS' SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUtiENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 29-38, 40, 42, 43, 44, 56 Said answers are true and correct tc t.he best of my knowledge and belief.
W
((0. Coffer Subscribed and sworn to before me this 26th day of October, 1981.
Thecdora Cooke, Notary Public SEAI.,
in and for the City and County of San Francisco, State of California My Comission expires January 28, 1985
JOINT INTERVENORS' SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 57, 58 Said answers are true and correct to the best of my knowledge and belief.
S.T. % M W J. J. ficCracken Subscribed and sworn to before me this 26th day of October, 1981.
N Thendora Cooke, Notary Public in and for the City and County of San Francisco, State of California My Commission expires January 28, 1985
JOINT INTERVENORS' SECOND SET OF INTE ROGATORIES AND REQUEST FOR PRODUCTION OF DOCUf1ENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 45, 59 Said answers are true and correct to the best of my knowledge and belief.
Yl. [ Fujimoto Subscribed and sworn to before me this 26th day of October, 1981.
Thecaora Cooke, Notary Public SEAL in and for the City and County of San Francisco, State of California My Commission expires January 28, 1985
JOINT INTERVENORS' SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY 1
I have assisted in preparing the answers to Interrogatories 62, 63, 64, 65, 66, 67, 68 Said answers are true and correct to the best of rny knowledge and belief.
D U
A R.
McDevitt Subscribed and sworn to before me this 2 6thday of October, 1981, Theodora Cooke, Notary Public u,
in and for the City and County of San Francisco, State of California My Comission expires January 28, 1985
. = -
4 JOINT INTERVENORS' SECOND SET OF INTERROGATORIES AND REQUEST FOR FRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 62, 63, 64, 65, 66, 67, 68 Said answers are true and correct to the best of my knowledge sad belief.
M Cit 2.
S. M. Skidmore 1
Subscribed and sworn to before me this 26tn day of October, 1981.
SEAL Thcodora Cooke, Notary Public
'-~/
in and for the City and County of San Francisco, State of California My Commission expires January 28, 1985
JOINT INTERVENORS' SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY-I have assisted in preparing the answers to Interrogatories 39, 41, 54, 55 Said answers are true and correct to the best of rny knowledge and belief.
/
bt 5 W
V J. E. Herbst Subscribed and sworn to before me this 26th day 1
of October, 1981.
N i
A b
s Theodora Cooke,~ Notary Public l
in and for the City and County of San Francisco, State of California My Comission expires January 28, 1985 l
l l
l L
~,
UNITED STATES OF AMERICA
- /
NUCLEAR REGULATORY COMMISSION
'g 00CMETED USHRC In the Matter'of
)
)-
11 SCT 29 P438 PACIFIC GAS AND ELECTRIC COMPANY
)
' Docket No. 50-2 75
)
Docket No. 50-3 pr dNG hh[
Diablo Canyon Nuclear Power Plant,
)
CM Units 1 and12
)
(Full Power ProceedMgipCH
)
CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (have) been served today on the following by deposit in the United States mail, properly stamped and addressed:
Judge John F. Wolf Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety and Licensing Board San Luis Obispo, California 93401 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo, California 93401 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission John Phillips, Esq.
Washington, D.
C. 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest Judge Jerry R.
Kline 10203 Santa Monica Drive Atomic Safety and Licensing Board Los Angeles, California 90067 U. S. Nuclear Regulatory Commission Washington, D.
C. 20555 David F.
Fleischaker, Esq.
P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City C/o Nancy. Culver Oklahoma 73101 192 Luneta Drive San Luis Obispo, California 93401 Arthur C. Gehr, Esq.
Snell & Wilmer Janice E. Kerr, Esq.
3100 Valley Bank Center Public Utilities Commission Phoenix, Arizona 85073 of the State of California 5246 State Building Bruce Norton, Esq.
350 McAllister Street Norton, Burke, Berry & French, P.C.
San Francisco, California 94102 3216 N. Third Street Suite 300 Mrs. Raye Fleming Phoenix, Arizona 85012-2699 1920 Mattie Road Shell Beach, California 93449 Chairman Atomic Safety and Licensing Mr. Frederick Eissler Board Panel Scenic Shoreline Preservation U. S. Nuclear Regulatory Commission Conference, Inc.
Washington, D. C. 20555 4623 More Mesa Drive
-Santa Barbara, California 93105
Chnirman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Appeal Board Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Sscretary U. S. Nuclear Regulatory Commission Judge W. Reed Johnson Wachington, D. C. 20555 Atomic Safety and Licensing Appeal Board Attn.:
Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555 William J. Olmstead, Esq.
Bradley W. Jones, Esq.
Judge John H. Buck Office of Executive Legal Director Atomic Safety and Licensing BETH 042 Appeal Board U. S. Nuclear Regulatory Commission U.
S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K Sen Jose, California 95125 Mr. Carl Neiberger Talegram Tribune P. O. Box 112 Srn Luis Obispo, California 93402 H rbert H. Brown, Esq.
LCwrence Coe Lanpher, Esq.
Christopher B. Hanback, Esq.
Hill, Christopher & Phillips 1900 M Street, N.W.
wachington, D.
C. 20036 Byron S. Georgiou, Esq.
Legal Affairs Secretary Govnrnor's Office State Capitol SRcramento, California 95814
~
}
s A
/
)1dLew J
l Philip A. Crane, r.
/
Attorney Pacific G s and Elec ric Company
\\
Dato:
October 26, 1981
[