ML20040A932
| ML20040A932 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/14/1982 |
| From: | Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20040A930 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8201220317 | |
| Download: ML20040A932 (6) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY )
Docket Nos. 50-275 O.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
)
JOINT INTERVENOR'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD Pursuant to 10 C.F.R.
S 2.749 (a), Joint Intervenors hereby specify the material facts as to which there exists a genuine issue to be heard with respect to contentions 10 and 12.
A.
Contention 10 -- Classification of Pressurizer Heaters 1.
At Diablo Canyon Nuclear Power Plant ("Diablo Canyon"), the pressuri?2r heaters and associated controls should be formally classified as " components important to safety" (safety-grade) and be designed, manufactured, and constructed with all the care that must be afforded such components.
2.
The TMI accident demonstrated that maintenance of natural circulation capability is important to safety.
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3.
The pressurizer heater system is the normal and preferred system for this function at Diablo Canyon.
4.
The pressurizer heaters must maintain physical integrity for the reactor coolant pressure boundary to be maintained.
5.
Maintenance of natural circulation at hot standby conditions without the use of pressurizer heaters and associated controls may be difficult to control and is contrary to the normal and emergency plant operating procedures.
6.
The Diablo Canyon emergency operating procedures do not specify an alternative to use of the pressurizer heaters in maintaining pressure control.
7.
To insure operability of the pressurizer heater system for response to accident or transient conditions, it is necessary to classify the system as safety-grade and design and manufacture it accordingly.
8.
The Diablo Canyon pressurizer heater system is not designed to meet all safety-grade design criteria.
9.
The applicability of the Sequoyah Nuclear Power Plant test data to the Diablo Canyon pressurizer heaters system has not been demanutrated, nor do the Emergency Operating Procedures specify hov proper operation could be assured if the pressurizer heaters are lost.
Emergency Procedure OP-23, Natural Circulation of Reactor Coolant, assumes that the pressurizer heaters will be available.
D 10.
The method required to transfer some of the heaters to the onsite emergency power supply has not been cemonstrated to be an acceptable response to item 4 of TMI requirement II.E.3-1, particularly in a confusing post-accident situation.
11.
Upgrading the classification of the pressurizer heater system to a " safety-related" classification was recommended by one of the major NRC groups assembled to review the accident.
12.
Upgrading the safety classification of the pressurizer heatet system would enhance its reliability by 2
minimizing the number of challenges to the system and by the i
l optimization of the operability and controllability of systems used in the mitigation or control of abnormal events.
13.
The pressurizer heater system has not been qualified in accordance with GDC 1, 2, 3, 20, or 22.
B.
Contention 12 -- Valve Classification and Testir:g 1.
The design of Diablo Canyon includes 3 PORV's and 3 associated block valves.
Two of the relief valves are described by PG&E as "important to safety" and the third is not, having been added to provide capability for 100% load rejection without reactor trip.
The three block valves are also described as "important to safety."
2.
PORVs and block valves figured prominently in the TMI-2 accident.
The stuck-open PORV contributed to the accident by producing a small LOCA, and the block valve was C
relied upon to control the small LOCA as part of the accident mitigation.
3.
The DORV's and/or Block Valves perform several i
functions which have safety significance.
These functions are:
a.
Maintain integrity of the primary pressure boundary.
b.
Provide pressure relief for Low Temperature Overpressurization conditions.
c.
Reduce the number of challenges to the safety valves.
d.
Reduce the number of challenges to the ECCS.
e.
Provide a bleed capability during the feed-and-bleed mode of operation to remove decay heat from the Core.
Each of these functions is consistent with the NRC Staff definitions of "important to safety," and the first two functions are also consistent with the Staff-definitions of
" safety-related."
4.
Occuments which the plant operator relies on for guidance in operating the plant during emergency conditions provide no evidence of differentiation between the greater or lesser qualified valves or associated equipment.
l S.
It is possible that the lesser qualified PORV would be the only valve operable at a time when PORV operation is l
called upon by a transient or accident.
Therefore, all PORV's should be classified and qualified as safety-grade.
6.
The added valves at Diablo Canyon increase the f
failure points which could lead to a LOCA, additional common L I; l
r
i mode failure mechanisms, and the possibility of systems interation which co~uld impact other safety-related functions.
7.
Proper safety c assification of the PORV/BV and their controls and instruments should insure proper design and qualification for worst case conditions based on plant-specific evaluations.
8.
However, the qualification of the Diablo Canyon PORV's and Block valves is incomplete.
The BV's have not been fully tested, and there apparently are no plans for further testing.
The full range of conditions, including ATWS, has not been tested and the plant-specific analysis has not been prepared to cover Diablo Canyon's design of PORV/BV's and their components, systems, and structures.
Thus, there can be no assurance that the configuration meets GDC 2 and 14.
- Also, the scheduled completion of the valve tests and the plant-specific analyses have been delayed until July 1, 1982.
9.
Based on the functions and required operations of the PORV's and block valves and according to the NRC definitions of safety terms, the PORV's/BV's and their instruments, controls and structures, should all be classified as " safety-related."
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4 10.
There are insufficient test data and plant-specific analyses to show that Diablo Canyon PORV/BV's and associated equipment and structures have been properly qualified.
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DATED:
January 14, 1982 Respectfully submitted, JOEL R. REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.
P. O. Box 1178 i
Oklahoma City, OK 73101 By pd JOEL R.
$EgNOLDS g
Attorneys for Joint Inter-venors SAN LUIS OBISPO MOTEERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
i ECOLOGY ACTION CLUB SANDRA SILVER l
ELIZABETH APFELBERG JOHN J. FORSTER t
i i
_. _ _. _