ML20044D378
| ML20044D378 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/07/1993 |
| From: | Warner C PACIFIC GAS & ELECTRIC CO. |
| To: | Bechhoefer C, Kline J, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13959 OLA-2, NUDOCS 9305190064 | |
| Download: ML20044D378 (4) | |
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Pacific Gas and Electric Company 77 Bea'e Street Chnsta;mer Wamet Sanhanos:o CA Chef CounsehtWyrg 415/973-6 9 5 dssec Tele:crer 415573-9271 Teie:oper 415/973 5520 i
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May 7, 1993 i
By Federal Expres_s i
i Charles Bechhoefer, Chairman Administrative Judge i
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Board i
East West / West Towers Building 4350 East West Highway, Room E-413 Bethesda, MD 20814
{
Jerry R. Kline, Administrative Judge Atomic Safety and Licensing Board i
U.S. Nuclear Regulatory Board i
East West / West Tower Building
}
4350 East West Highway, Room E-427 Bethesda, MD 20814 I
Frederick J. Shon, Administrative Judge I
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East West / West Towers Building 4350 East West Highway, Room E-430 Bethesda, MD 20814 Re:
Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Docket Nos. 50-275-OLA, - E i
50-323-OLA, (Construction Period Recaoture
'2-
\\
Dear Administrative Judges:
l t
Attached are copies of.the original affidavits of Usama A.
l Farradj and John A. Lee, facsimile copies of which.were
{
, attached to " Pacific Gas and Electric Company's Initial Response to Questions for Parties," filed concurrently today i
in this proceeding.
The original affidavits have been filed i
l f
i 9305190064 930507 PDR ADDCK 05000275 0
PDR 3
i
4 Charles Bechhoefer, Chairman Jerry R. Kline, Administrative Judge Frederick J. Shon, Administrative Judge May 7, 1993 Page No. 2 with the Office of the Secretary, and copies of the originals provided to the service list.
Sincerely,
/ f*(
A'A CHRISTOPHER J. WARNER Counsel for Pacific Gas and Electric Company 2
CJW:jkh Attachment cc w/att:
Service List l
P E
1 i
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
[
t AFFIDAVIT I,
Usama A.
Farradj, being duly sworn, hereby state as follows:
l 1.
I am employed under contract to Pacific Gas and Electric Company as the Group Leader for Fire Protection within the Nuclear Mechanical Engineering Group in the Nuclear Engineering Services Department of the Nuclear Power Generation Business Unit.
In this position, I am responsible for the maintenance and upgrade of the Fire Protection Program and fire protection systems at the Diablo Canyon Nuclear Power Plant (DCPP).
My engineering experience and educational background qualify me as a fire protection engineer in accordance with NRC Branch Technical Position CMEB 9.5-1 for the purpose of acceptance of DCPP plant design changes with respect to fire protection design requirements.
2.
I am a
registered Professional
- Engineer, Mechanical Engineering under the laws of the State of California.
3.
I have been asked to address question number 2 in the April 16,
- 1993, Atomic Safety and Licensing Board
" Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between the NRC Staf f's evaluation of Thermo-Lag as combustible in NRC Information Notice 92-82, dated December 15, 1992, and PG&E's evaluation of Thermo-Lag as noncombustible under Underwriter Laboratories standards in its September 28, 1992, response to l
Supplement 1 of NRC Bulletin 92-01.
4.
I have provided the information which forms the basis for the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility."
i i
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5.
The information contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Therco-Lag Combustibility" is true and correct to the best of my knowledge and belief.
W :-
Usama A.
Farradj STATE OF CALIFORNIA l
CITY AND COUNTY OF SAN FRANCISCO Sworn and subscribed to before me this 6
- day of May, 1993 I
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA I
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
AFFIDAVIT I, John A.
Lee, being duly sworn, hereby state as follows:
1.
I am employed under contract to Pacific Gas and Electric Company as a
Fire Protection engineer in the Nuclear Engineering Services Department of the Nuclear Power i
Generation Business Unit.
My nuclear fire protection experience includes managing the fire protection program of an l
operating utility, participating in NRC Appendix R audits, functioning as the fire protection consultant on utility audits, and leading projects which concentrate on assessing and upgrading nuclear fire protection programs.
My technical expertise is in the area of fire endurance of passive fire protection features, and I have been a consultant to the Electric Power Research Institute regarding issues concerning Thermo-Lag fire barrier material.
2.
I am a registered fire protection engineer and registered civil engineer under the laws of the State of California.
3.
I have been asked to address question number 2 in the April 16,
- 1993, Atomic Safety and Licensing Board " Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between the NRC Staff's evaluation of Thermo-Lag as combustible in NRC Inf ormation Notice 92-82, dated December 15, 1992, and PG&E's evaluation of Thermo-Lag as noncombustible under Underwriter Laboratories standards in its September 28, 1992, response to Supplement 1 of NRC Bulletin 92-1.
4.
I have provided the information which forms the basis for the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility."
5.
The information contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag r
~ $T5C 9
e Combustibility" is true and correct to the best of my knowledge and belief.
. /7 John A. Lee STATE OF CALIFORNIA p --
omOAL SEE CITY AND COUNTY OF SAN FRANCISCO SAUNDRA V. JAOGON
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Sworn and subscribed to before
'I san krc :=, 0cc,tr i
l_ _ - VV Commeser. h :.es Ju. 10.1994; me this 7th day of May, 1993 W
4 Notary Public
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My(/commisgfon ekpires:
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PACIFIC GAS AND ELECTRIC COMPANY RESPONSE TO ATOMIC SAFETY AND LICENSING BOARD QUESTION REGARDING THERMO-LAG COMBUSTIBILITY In its April 16, 1993, order entitled " Memorandum (Questions for Parties)," the Nuclear Regulatory Commission Atomic Safety and Licensing Board asked the parties to address the following question at a prehearing conference, now scheduled for May 11-12, 1993:
"2.
With respect to the second late-filed contention, what rationale, if any, explains the apparent inconsistency between the Staff's evaluation of Thermo-Lag as being
' combustible' (NRC Information Notice 92-82, dated December 15, 1992, submitted as Attachment 2 to MFP's second late-filed contention),
based on NIST
- tests, and the Applicant's designation of Thermo-Lag material as being ' noncombustible' under Underwriter Laboratories standards in its submission of i
its interim compensatory measures on September 28, 1992 (Enclosure, Attachment 1,
at 2) (approved by the Staff by letter dated October 27, 1992)?"
PG&E has reviewed the Thermo-Lag combustibility test results contained in NRC Information Notice (IN) 92-82 in light of: (1) the i
i NRC's definition of a
noncombustible material under Branch Technical Position (BTP) CMEB 9.5-1, Section B.4 and Generic Letter 86-10; (2) PG&E's previous qualification of Thermo-Lag for use as a noncombustible radiant energy shield in DCPP Units 1 and 2 i
containments based on tests performed by Underwriters Laboratories in accordance with ASTM E-84; and (3) an engineering assessment by t
PG&E of the specific application of Thermo-Lag in containment, to i
determine whether or not the Thermo-Lag, "in the form in which it is used and under the conditions anticipated" (BTP CMEB 9.5-1, Section B.4), could become a combustible material in such a way as to negate its effectiveness as a radiant energy sL2 eld and result in fire damage to safe shutdown equipment.
r
a Based on this review, including the engineering assessment of the specific application of Thermo-Lag for radiant energy shields within containment, PG&E concluded that Thermo-Lag meets the NRC i
definition of noncombustible material (BTP CMEB 9.5-1, Section B.4) in its specific application, and continues to provide an acceptable level of protection against the anticipated fire hazard within containment. Therefore, there is no inconsistency between IN 92-82 and PG&E's response to Supplement 1 to Bulletin 92-01, and there is no current safety concern relating to PG&E's use of Thermo-Lag as o
a noncombustible radiant energy shield in DCPP containment.
This conclusion is based on:
(1)
The NRC's definition of noncombustible material is provided in BTP CMEB 9.5-1, Section B.4 and reiterated in GL 86-10 as follows:
"a.
A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.
b.
Material having a structural base of noncombustible material, as defined in a.,
above, with a surfacing not over 1/8-inch thick that has a flame spread rating not higher than 50 when measured using ASTM E-84 Test
' Surf ace Burning Characteristics of Building Materials. '"
In performing the testing described in IN 92-82, NIST employed the definition of noncombustible provided by the Uniform Building Code (UBC).
That definition is similar to the above NRC definition.
Part b) of the UBC definition applies to flame spread, and part b) of the NRC definition is the same.
Part a) of the UBC definition, which addresses base material burning characteristics, prescribes that the material must conform to ASTM E-136, while the NRC l
definition addresses base material burning characteristics under anticipated conditions.
Thus, the difference between the two definitions is that the NRC definition expressly allows consideration of plant unique applications, whereas the UBC definition may not.
The basis for PG&E's plant specific application is summarized below under items (2) and (3).
(2) PG&E previously has qualified Thermo-Lag for use as a radiant energy shield based on reliance on Underwriters Laboratories (UL) testing in accordance with ASTM E-84.
The UL tests demonstrated that Thermo-Lag has a flame spread of 5, well within the BTP CMEB 9.5-1, Section B.4 flame spread requirement of 50 or less.
This very low flame spread of the base material (Thermo-Lag does not utilize a surface material) indicates that the j
naterial does not exhibit a propensity to burn. Thus, parts a) and b) of BTP CMEB 9.5-1, Section B.4 were satisfied and the material was considered noncombustible.
The NRC has not prescribed a specific test as a determinant of material igniting, burning, or supporting combustion (Part a.
of l
i BTP CMEB 9.5-1, Section B.4) similar to ASTM E-136 as used by NIST in the tests reported by IN 92-82, either in Appendix R regulations or implementing guidance.
Therefore, the ASTM E-136 test results reported IN 92-82 do not invalidate or contradict PG&E's application of the previous UL test results under ASTM E-84 used to j
qualify the Thermo-Lag.
ASTM E-136 tests the material in a more severe environment than necessary for PG&E's specific application as a radiant energy shield.
In addition, as an information notice, i
1 IN 92-82 by definition does not impose new requirements on licensees to retest or requalify Thermo-Lag.
1 (3) PG&E's engineering assessment of the fire hazards in the vicinity of the Thermo-Leg radiant energy shields in containment indicates that the Thermo-Lag is not expected to be subject to the extreme temperatures or the presence of large heat fluxes similar to the conditions under which the NIST tested Thermo-Lag as i
reported in IN 92-82.
Therefore, in its specific application by PG&E, Thermo-Lag is a noncombustible material as defined by the NRC in BTP CMEB 9.5-1, Section B.4.
For these reasons, the NIST combustibility test results reported in IN 92-82 are not inconsistent with PG&E's conclusion that its Thermo-Lag radiant energy shields are noncombustible and will perform the required function as a radiant energy shield protecting safe shutdown equipment from a fire in containment.
I However, this overall combustibility issue has been mooted by PG&E's decision earlier this year to voluntarily replace the Thermo-Lag in DCPP Units 1 and 2 containments with 3M material.
The Unit 2 replacement was completed during the recent Unit 2 fifth refueling outage, and the Unit I replacement is scheduled for completion during the upcoming Unit 1 sixth refueling outage, scheduled for Spring of 1994.
(See PG&E Letter No. DCL-93-109, April 30, 1993).
PG&E understands, based on communications from the Nuclear Management and Resources Council (NUMARC), that the NRC staff plans to issue a supplement to Generic Letter 92-08 in the summer of 1993
~
l that may include more specific information relative to the generic Thermo-Lag combustibility issue.
In the meantime, PG&E continues to monitor NUMARC's Thermo-Lag evaluation program, including NUMARC's evaluation of any further testing needs related to the combustibility issue.
If the NRC provides new or revised generic j
l guidance to licensees on the applicable standards for determining combustibility of Thermo-Lag in accordance with BTP CME 9 9.5-1, PG&E will evaluate and, if necessary, upgrade its current Appendix R fire protection program in light of that guidance.
1 l
i l
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r i
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t
. Pacific Gas and Electric Company 77 Beale Street. Room 1451 GregoryM Rueger l
PO Box 770030 Senior Vce Presdent and San Francisco.CA 94177 General Mar.ager i
415/973 45B4 Nxlear Power Generahon i
Fax 415/973-2313 j
April 30, 1993 l
PG&E Letter No. DCL-93-109 y
U.S. Nuclear Regulatory Commission
'N k
ATTN: Document Control-Desk k'N Washington, D.C.
20555 j
l ', [
l Re:
Docket No. 50-275, OL-DPR-80 i
Docket No. 50-323, OL-DPR-82 i
Diablo Canyon Units 1 and 2 Information Relating to Response to Supplement I of Bulletin 92-01 Gentlemen:
PG&E submitted PG&E Letter No. DCL-92-208 (HBL-92-060), dated September 28, 1992, in response to Supplement 1 of Bulletin 92-01, " failure of Thermo-Lag 330 Fire Barrier System to Perform its Specified Fire Endurance function," dated August 28, 1992.
In DCL-92-208, PG&E noted i
the fire areas at Diablo Canyon Power Plant Units I and 2 where Thermo-Lag was used as a 1 or 3-hour fire barrier.
l l
Also in DCL-92-208, PGSE included a discussion of the Thermo-Lag used for radiant energy heat shields in the Units 1 and 2 containments. DCL-92-208 noted that these radiant energy heat shields are outside the s
scope of Bulletin 92-01 and, therefore, do not require interim compensatory measures..This is to inform you that, subsequent to DCL-l 92-208, PGLE has elected to replace the Thermo-Lag used in these heat shields.
Accordingly, Thermo-Lag heat shield material in Unit 2 containment was I
replaced with 3M material during the recent Unit 2 fifth refueling i
outage. The Unit I containment Thermo-Lag heat shield material.is scheduled for replacement with 3M material during the upcoming Unit I sixth refueling outage, scheduled to begin in the Spring of 1994.
Sincerely, f%
^
Gregory M. Rueger i
cc:
Ann P. Hodgdon John B. Martin Mary H. Miller I
Sheri R. Peterson i
CPUC Diablo Distribution 6094S/85K/ALN/2242 i
f
[
^I
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA l
Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Power
)
Recapture)
Plant, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " PACIFIC GAS & ELECTRIC COMPANY'S LETTER DATED MAY 7,
1993 AND ATTACHMENTS THERETO" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk
(*),
by Federal Express overnight delivery, this 7th day of May, 1993.
Charles Bechhoefer, Chairman
- Frederick J.
Shon*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West / West Towers Building East West / West Tower Building 4350 East West Highway, Room E-413 4350 East West Highway, Room E-430 Bethesda, MD 20814 Bethesda, MD 20814 Jerry R. Kline*
Office of Commission Appellate Administrative Judge Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, DC 20555 East West / West Towers Building 4350 East West Highway, Room E-427 Bethesda, MD 20814 Office of the Secretary Ann P. Hodgdon, Esq.*
U.S.
Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission Attn:
Docketing and Service 1 White Flint North
)
Section 11555 Rockville Pike (original + two copies)
Rockville, MD 20852 l
Adjudicatory File Peter Arth, Jr.
Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G. Fairchild U.S.
Nuclear Regulatory Commission California Public Utilities Washington, DC 20555 Commission 505 Van Ness Avenue San Francisco, CA 94102
Nancy Culver, President Truman Burns Board of Directors California Public Utilities San Luis Obispo Mothers for Peace Commission f
P.O.
Box 164 505 Van Ness, Rn. 4103 Pismo Beach, CA 93448 San Francisco, CA 94102 Robert R. Wellington, Esq.
Joseph B. Knotts, Jr., Esq.
Diablo Canyon Independent Safety David A. Repka, Esq.
Committee Winston & Strawn
(
857 Cass Street, Suite D 1400 L Street, N.W.
Monterey, CA 93940 Washington, DC 20005-3502 Robert Kinosian Jill ZamEk*
California Public Utilities 1123 Flora Road Commission Arroyo Grande, CA 93420 l
505 Van Ness, Rm. 4102 San Francisco, CA 94102 Mr. Gregory Minor
- MHB Technical Associates i
1723 Hamilton Ave., Suite K San Jose, CA 95125 i
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Christopher J.0 Warner i
Counsel for Pacific Gas and Electric Company r
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P r
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e 1
i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
P1snt, Units 1 and 2)
)
)
AFFIDAVIT I, Usama A.
Farradj, being duly sworn, hereby state as follows:
1.
I am employed under contract to Pacific Gas and Electric Company as the Group Leader for Fire Protection within the Nuclear Mechanical Engineering Group in the Nuclear Engineering Se.rvices Department of the Nuclear Power Generation Business Unit.
In this position, I am responsible i
for the maintenance and upgrade of the Fire Protection Program and fire protection systems at the Diablo Canyon Nuclear Power Plant (DCPP).
My engineering experience and educational background qualify me as a fire protection engineer in accordance with NRC Branch Technical Position CMEB 9.5-1 for the purpose of acceptance of DCPP plant design changes with I
respect to fire protection design requirements.
2.
I an a
registered Professional
- Engineer, Mechanical Engineering under the laws of the State of California.
3.
I have been asked to address question number 2 in the April 16,
- 1993, Atomic Safety and Licensing Board " Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between the NRC Staff's evaluation of Thermo-Lag as combustible in NRC Information Notice 92-82, dated December 15, 1992, and PG&E's evaluation of Thermo-Lag as noncombustible under Underwriter Laboratories standards in its September 28, 1992, response to Supplement 1 of NRC Bulletin 92-01.
4.
I have provided the information which forms the basis for the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility."
f *
. =.,
i 5.
The information contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Therno-Lag i
Combustibility" is true and correct to the best of my l
knowledge and belief.
Usama A. Farradj l
l STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO 1
i Sworn and subscribed to before ne this 6
- day of May, 1993 i
/
Notary Publi*d
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UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f
i In the Matter of:
)
[
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
AFFIDAVIT I,
John A. Lee, being duly sworn, hereby state as follows:
i 1.
I an employed under contract to Pacific Cas and Electric Company as a
Fire Protection engineer in the Nuclear Engineering Services Department -of the Nuclear Power Generation Business Unit.
My nuclear fire protection I
experience includes managing the fire protection program of an operating utility, participating in NRC Appendix R audits, functioning as the fire protection consultant on utility audits, and leading projects which concentrate on assessing and upgrading nuclear fire protection programs.
My technical expertise is in the area of fire endurance of passive fire protection features, and I have been a consultant to the Electric Power Research Institute regarding issues concerning Thermo-Lag fire barrier material.
i 2.
I am a registered fire protection engineer and registered civil engineer under the laws of the State of California.
l i
3.
I have been asked to address question number 2 in the April 16,
- 1993, Atomic Safety and Licensing Board " Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between the NRC Staff's evaluation of Thermo-Lag as combustible in NRC j
Information Notice 92-82, dated December 15, 1992, and PG&E's evaluation of Thermo-Lag as noncombustible under Underwriter r
Laboratories standards in its September 28, 1992, response to Supplement 1 of NRC Bulletin 92-1.
i 4.*
I have provided the information which forms the basis for the
[
attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility."
f 5.
The information contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag c
o
Combustibility" is true and correct to the best of my knowledge and belief.
I Yn W: S
~~ John A. Lee i
STATE OF CALIFORNIA S- ^ --- - ~' ~ k y s_,
CITY AND COUNTY OF SAN FRANCISCO ll SAUNDRA V. JAQ3ON j
l N0iAW PUCUC - TWTORNA Sworn and subscribed to before ll San Ff xrs Cww ne this 7th day of May, 1993 J,
14 Comsca Ecas.!n.10.1M4 3
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PACIFIC GAS AND ELECTRIC COMPANY i
RESPONSE TO ATOMIC SAFETY AND LICENSING BOARD QUESTION REGARDING THERMO-LAG COMBUSTIBILITY In its April 16, 1993, order entitled " Memorandum (Questions b
i for Parties)," the Nuclear Regulatory Commission Atomic Safety and Licensing Board asked the parties to address the following question 4
at a prehearing conference, now scheduled for May 11-12, 1993:
l t
"2.
With respect to the second late-filed contention, t
what rationale, if any, explains the apparent inconsistency between the Staff's evaluation of Thermo-Lag as being
' combustible' (NRC Information Notice 92-82, dated December l
15, 1992, submitted as Attachment 2 to MFP's second late-filed l
contention),
based on NIST
- tests, and the Applicant's designation of Thermo-Lag material as being ' noncombustible' under Underwriter Laboratories standards in its submission of f
i its interim compensatory measures on September 28, 1992
{
(Enclosure, Attachment 1,
at 2) (approved by the Staff by letter dated October 27, 1992)?"
PG&E has reviewed the Thermo-Lag combustibility test results j
contained in NRC Information Notice (IN) 92-82 in light of: (1) the NRC's definition of a
noncombustible materia 2 ader Branch l
t Technical Position (BTP) CMEB 9.5-1, Section B.4 and Generic Letter l
86-10; (2) PG&E's previous qualification of Thermo-Lag for use as a noncombustible radiant energy shield in DCPP Units 1 and 2 containments based on tests performed by Underwriters Laboratories j
i in accordance with ASTM E-84; and (3) an engineering assessment by a
PG&E of the specific application of Thermo-Lag in containment, to j
determine whether or not the Thermo-Lag, "in the form in which it is used and under the conditions anticipated" (BTP CMEB 9.5-1, i
Section B.4), could become a combustible material in such a way as l
to negate its effectiveness as a radiant energy shield and result l
in fire damage to safe shutdown equipment.
I
t t
Based on this review, including the engineering assessment of j
the specific application of Thermo-Lag for radiant energy shields t
I within containment, PG&E concluded that Thermo-Lag meets the NRC definition of noncombustible material (BTP CMEB 9.5-1, Section B.4)
[
in its specific application, and continues to provide an acceptable t
level of protection against the anticipated fire hazard within 3
i containment. Therefore, there is no inconsistency between IN 92-82 and PG&E's response to Supplement 1 to Bulletin 92-01, and there is no current safety concern relating to PG&E's use of Thermo-Lag as i
a noncombustible radiant energy shield in DCPP containment.
This i
conclusion is based on:
i (1)
The NRC's definition of noncombustible material is provided in BTP CMEB 9.5-1, Section B.4 and reiterated in GL 86-10 as follows:
"a.
A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when i
subjected to fire or heat.
b.
Material having a structural base of noncombustible i
material, as defined in a.,
above, with a surfacing not over 1/8-inch thick that has a flame spread rating not l
higher than 50 when measured using ASTM E-84 Test
' Surf ace Burning Characteristics of Building Materials.
6 In performing the testing described in IN 92-82, NIST employed the j
definition of noncombustible provided by the Uniform Building Code (UBC).
That definition is similar to the above NRC definition.
Part b) of the UBC definition applies to flame spread, and part b) of the NRC definition is the same.
Part a) of the UBC definition, which addresses base material burning characteristics, prescribes h
that the material must conform to ASTM E-136, while the NRC i !
f
i i
I r
i definition addresses base material burning characteristics under l
t anticipated conditions.
Thus, the difference between the two f
definitions is that th NRC definition expressly allows consideration of plant unique applications, whereas the UBC i
definition may not.
The basis for PG&E's plant specific l
application is summarized below under items (2) and (3).
(
(2) PG&E previously has qualified Thermo-Lag for use as a l
radiant energy shield based on reliance on Underwriters l
Laboratories (UL) testing in accordance with ASTM E-84.
The UL tests demonstrated that Thermo-Lag has a flame spread of 5, well j
within the BTP CMEB 9.5-1, Section B.4 flame spread requirement of 50 or less.
This very low flame spread of the base material I
i (Thermo-Lag does not utilize a surf ace material) indicates that the t
materi31 does not exhibit a propensity to burn.
Thus, parts a) and 1
b) of BTP CMEB 9.5-1, Section B.4 were satisfied and the material was considered noncombustible.
l The NRC has not prescribed a specific test as a determinant of material igniting, burning, or supporting combustion (Part a.
of BTP CMEB 9.5-1, Section B.4) similar to ASTM E-136 as used by HIST in the tests reported by IN 92-82, either in Appendix R regulations f
l or implementing guidance.
Therefore, the ASTM E-136 test results l
reported IN 92-82 do not invalidate or contradict PG&E's application of the previous UL test results under ASTM E-84 used to
[
i qualify the Thermo-Lag.
ASTM E-136 tests the material in a more j
severe environment than necessary for PG&E's specific application t
as a radiant energy shield.
In n$dition, as an information notice, f
I i !
i h
I IN 92-82 by definition does not impose new requirements on licei. sees to retest or requalify Thermo-Lag.
l (3) PG&E's engineering assessment of the fire hazards in the vicinity of the Thermo-Lag radiant energy shields in containment j
indicates that the Thermo-Lag is not expected to be subject to the extreme temperatures or the presence of large heat fluxes similar l
to the conditions under which the NIST tested Thermo-Lag as reported in IN 92-82.
Therefore, in its specific application by PG&E, Thermo-Lag is a noncombustible material as defined by the NRC in BTP CMEB 9.5-1, Section B.4.
t For these reasons, the NIST combustibility test results j
reported in IN 92-82 are not inconsistent with PG&E's conclusion l
(
that its Thermo-Lag radiant energy shields are noncombustible and f
will perform the required function as a radiant energy shield protecting safe shutdown equipment from a fire in containment.
i However, this overall combustibility issue has been mooted by t
i PG&E's decision earlier this year to voluntarily replace the i
J Thermo-Lag in DCPP Units 1 and 2 containments with 3M material.
I The Unit 2 replacement was completed during the recent Unit 2 fifth j
l refueling outage, and the Unit 1 replacement is scheduled for j
completion during the upcoming Unit 1 sixth refueling outage, scheduled for Spring of 1994.
(See PG&E Letter No. DCL-93-109, f
April 30, 1993).
PG&E understands, based on communications from the Nuclear i
Hanagement and Resources Council (NUMARC), that the NRC staff plans to issue a supplement to Generic Letter 92-08 in the summer of 1993
\\
l 1 !
i
V that may include more specific information relative to the generic Thermo-Lag combustibility issue.
In the meantime, PG&E continues to monitor NUMARC's Thermo-Lag evaluation program, including NUMARC's evaluation of any further testing needs related to the combustibility issue.
If the NRC provides new or revised generic guidance to licensees on the applicable standards for determining combustibility of Thermo-Lag in accordance with BTP CMEB 9.5-1, PG&E will evaluate and, if ne.cessary, upgrade its current Appendix t
R fire protection program in light of that guidance.
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l Pacific Gas and Doctric Company 77 Beale Street. Room 1451 GregoryM RueDer
'l P0 Bei 770000 Senior Vee Presdent and
~!
San Francsto, CA 94177 General Manager
-t 415/973 4664 Nuclear Power Generanon l
Fax 415/973 2313 i
1 t
April 30, 1993 PGLE Lettcr No. DCL-93-109
'l U.S. Nuclear Regulatory Commission i
ATTN: Document Control Desk t
Washington, D.C.
20555 l
=
N Re:
Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Information Relating to Response to Supplement 1 of Bulletin 92-01 Gentlemen:
PG&E submitted PGLE Letter No. DCL-92-208 (HBL-92-060), dated September 28, 1992, in response to Supplement 1 of Bulletin 92-01, " Failure of f
Thermo-Lag 330 Fire Barrier System to Perform its Specified fire Endurance function," dated August 28 -1392.
In DCL-92-208, PG&E noted the fire areas at Diablo Canyon Power Plant Units 1 and 2 where Thermo-Lag was used as a 1 or 3-hour fire barriers j
Also in DCL-92-208, PG&E included a discussion of the Thermo-Lag used for radiant energy heat shields in the Units 1 and.2 containments. DCL-92-208 noted that these radiant energy heat shields are outside the scope of Bulletin 92-01 and, therefore, do not require interim compensatory measures. This is to inform you that, subsequent to DCL-92-208, PG&E has elected to replace the Thermo-Lag used in these heat '
shields.
Accordingly, Thermo-Lag heat shield material in Unit 2 containment was replaced with 3M material during the recent Unit 2'fifth refueling outage. The Unit I containment Thermo-Lag heat shield material is 1
scheduled for replacement with 3M material during the upcoming Unit I sixth refueling outage, scheduled to begin in the Spring of 1994.
Sincerely, i
n i
/
Mm Gregory M. Rueger cc:
Ann P. Hodgdon John B. Martin Mary H. Miller Sheri R. Peterson CPUC 2
Diablo Distribution 6094S/85K/ALN/2242
l i
UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA i
)
(Construction Period j
(Diablo Canyon Power
)
Recapture) t Plant, Units 1 and 2)
)
)
i CERTIFICATE OF SERVICE I hereby certify that copies of " PACIFIC GAS & ELECTRIC COMPANY'S LETTER DATED MAY 7,
1993 AND ATTACHMENTS THERETO" in the _ above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk
(*), by Federal Express overnight delivery, this 7th day of May, 1993.
Charles Bechhoefer, Chairman
- Frederick J.
Shon*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West / West Towers Building East West / West Tower Building 4350 East West Highway, Roon E-413 4350 East West Highway, Room E-430 Bethesda, MD 20814 Bethesda, MD 20814 Jerry R. Kline*
Office of Commission Appellate Administrative Judge Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, DC 20555 East West / West Towers Building 4350 East West Highway, Room E-427 Bethesda, MD 20814 i
Office of the Secretary Ann P. Hodgdon, Esq.*
U.S.
Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission Attn:
Docketing and Service 1 White Flint North 7
Section 11555 Rockville Pike l
(original + two copies)
Rockville, MD 20852 Adjudicatory File Peter Arth, Jr.
Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G.
Fairchild U.S.
Nuclear Regulatory Commission California Public Utilities Washington, DC 20555 Commission 505 Van Ness Avenue San Frr.ncisco, CA 94102 i
i I
Nancy Culver, President Truman Burns Board of Directors California Public Utilities San Luis Obispo Mothers for Peace Commission P.O.
Box 164 505 Van Ness, Rm. 4103 Pismo Beach, CA 93448 San Francisco, CA 94102 Robert R. Wellington, Esq.
Joseph B. Knotts, Jr.,
Esq.
Diablo Canyon Independent Safety David A.
Repka, Esq.
Committee Winston & Strawn i
857 Cass Street, Suite D 1400 L Street, N.W.
Monterey, CA 93940 Washington, DC 20005-3502 Robert Kinosian Jill ZamEk*
a California Public Utilities 1123 Flora Road Commission Arroyo Grande, CA 93420 505 Van Ness, Rm. 4102 San Francisco, CA 94102 Mr. Gregory Minor
- MHB Technical Associates 1723 Hamilton Ave., Suite K San Jose, CA 95125
[A61
/
Christophei-J. (Harner Counsel for Pacific Gas and Electric Company i
i i
n e
Y 1
t i
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of:
)
)
Docket Nos. 50-275-OLA l
Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period
[
(Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
}
}
AFFIDAVIT I, Usama A.
Farradj, being duly sworn, hereby state as follows:
1.
I am employed under contract to Pacific Gas and Electric Company as the Group Leader for Fire Protection within the Nuclear Mechanical Engineering Group in the Nuclear Engineering Services Department of the Nuclear Power Generation Business Unit.
In this position, I am responsible for the maintenance and upgrade of the Fire Protection Program i
and fire protection systems at the Diablo Canyon Nuclear Power-Plant (DCPP).
My engineering experience and educational I
background qualify me as a fire protection engineer in accordance with NRC Branch Technical Position CMEB 9.5-1 for the purpose of acceptance.of DCPP plant design changes with i
respect to fire protection design requirements.
i 2.
I am a
registered Professional
- Engineer, Mechanical Engineering under the laws of the State of California.
i 3.
I have been asked to address question number 2 in the April i
16,
- 1993, Atomic Safety and Licensing Board " Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between i
the NRC Staff's evaluation of Thermo-Lag as combustible in NRC Information Notice 92-82, dated December 15, 1992, and PG&E's evaluation of Thermo-Lag as noncombustible under Underwriter i
Laboratories standards in its September 28, 1992, response to Supplement 1 of IGC Bulletin 92-01.
I i
4.
I have provided the information which forms the basis for the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility."
5.
The information contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility" is true and correct to the best of my i
knowledge and belief, t
Usama A.
Farradj STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO Sworn and subscribed to before me this 6
- day of May, 1993 Notary Publfd ful ? lff$
Mycopissionexpires funnunninununuunumunnunuumm i p,..,.,
IAILDRED J. WILLlHA5 i
ihn NOTARY PUBUC - CAtlFERNK E E(yp ciTr & ccant w sAs rsAscisco i
- 1 Com%30cn INpiret Agg. I, II9) h
$19888EllB8BB5838598149888B83318B588Bitt&gannaranaammag h i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
AFFIDAVIT I, John A.
Lee, being duly sworn, hereby state as follows:
1.
I am employed under contract to Pacific Gas and Electric Company as a
Fire Protection engineer in the Nuclear Engineering Services Department of the Nuclear Power Generation Business Unit.
My nuclear fire protection experience includes managing the fire protection program of an operating utility, participating in NRC Appendix R audits, functioning as the fire protection consultant on utility audits, and leading projects which concentrate on assessing and upgrading nuclear fire protection programs.
My technical expertise is in the area of fire endurance of passive fire protection features, and I have been a consultant to the Electric Power Research Institute regarding issues concerning Thermo-Lag fire barrier material.
2.
I am a registered fire protection engineer and registered civil engineer under the laws of the State of California.
3.
I have been asked to address question number 2 in the April 16,
- 1993, Atomic Safety and Licensing Board " Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between the NRC Staff's evaluation of Thermo-Lag as combustible in NRC Information Notice 92-82, dated December 15, 1992, and PG&E's evaluation of Thermo-Lag as noncombustible under Underwriter Laboratories standards in its September 28, 1992, response to Supplement 1 of NRC Bulletin 92-1.
4.*
I have provided the information which forms the basis for the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag Combustibility."
5.
The infomation contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Thermo-Lag
,f
("
b of{
I Combustibility" is true and correct to the best of my knowledge and belief.
1 U /7 !
' John A. Lee STATE OF CALIFORNIA
- - =-- =-'-----" ^ -= "
b3ON CITY AND COUNTY OF SAN FRANCISCO W NDR l
NrJiAM PUCZ - UL'FORW, Sworn and subscribed to before l
San Ferc ;;;, Canty 1.
My Com:nescr. Ec:res Jai 10.1994 me this 7th day of May, 1993 l-
_ ~ - :_ ::
W Notary Public
(/
m 10 (T 9 V Mygcommissjon ekpires:
9 i
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I PACIFIC GAS AND ELECTRIC COMPANY t'
RESPONSE TO ATOMIC SAFETY AND LICENSING BOARD QUESTION REGARDING THERMO-LAG COMBUSTIBILITY In its April 16, 1993, order entitled " Memorandum (Questions j
for Parties)," the Nuclear Regulatory Commission Atomic Safety and Licensing Board asked the parties to address the following question at a prehearing conference, now scheduled for May 11-12, 1993:
"2.
With respect to the second late-filed contention, what rationale, if any, explains the apparent inconsistency between the Staff's evaluation of Thermo-Lag as being
' combustible' (NRC Information Notice 92-82, dated December f
15, 1992, submitted as Attachment 2 to MFP's second late-filed contention),
based on NIST
- tests, and the Applicant's designation of Thermo-Lag material as being ' noncombustible' i
under Underwriter Laboratories standards in its submission of its interim compensatory measures on September 28, 1992 (Enclosure, Attachment 1,
at 2)(approved by the Staff by letter dated October 27, 1992)?"
PG&E has reviewed the Thermo-Lag combustibility test results i
contained in NRC Information Notice (IN) 92-82 in light of: (1) the NRC's definition of a
noncombustible material under Branch Technical Position (BTP) CMEB 9.5-1, Section B.4 and Generic Letter 86-10; (2) PG&E's previous qualification of Thermo-Lag for use as a noncombustible radiant energy shield in DCPP Units 1 and 2 containments based on tests performed by Underwriters Laboratories in accordance with ASTM E-84; and (3) an engineering assessment by l
PG&E of the specific application of Thermo-Lag in containment, to i
l determine whether or not the Thermo-Lag, "in the form in which it is,used and under the conditions anticipated" (BTP CMED 9.5-1, Section B.4), could become a combustible material in such a way as to negate its effectiveness as a radiant energy shield and result in fire damage to safe shutdown equipment.
..y
1 Based on this review, including the engineering assessment of the specific application of Thermo-Lag for radiant energy shields l
within containment, PG&E concluded that Thermo-Lag meets the NRC definition of noncombustible material (BTP CMEB 9.5-1, Section B.4) in its specific application, and continues to provide an acceptable level of protection against the anticipated fire hazard within containment. Theref ore, there is no inconsistency between IN 92-82 and PG&E's response to Supplement 1 to Bulletin 92-01, and there is no current safety concern relating to PG&E's use of Thermo-Lag as a noncombustible radiant energy shield in DCPP containment.
This l
conclusion is based on:
(1)
The NRC's definition of noncombustible material is provided in BTP CMEB 9.5-1, Section B.4 and reiterated in GL 86-10 as follows:
r "a.
A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.
b.
Material having a structural base of noncombustible material, as defined in a.,
above, with a surfacing not over 1/8-inch thick that has a flame spread rating not higher than 50 when measured using ASTM E-84 Test
' Surf ace Burning Characteristics of Building Materials. '"
1 In performing the testing described in IN 92-82, NIST employed the definition of noncombustible provided by the Uniform Building Code l
(UBC).
That definition is similar to the above NRC definition.
Part b) of the UBC definition applies to flame spread, and part b) of the NRC definition is the same.
Part a) of the UBC definition, which addresses base material burning characteristics, prescribes t
that the material must conform to ASTM E-136, while the NRC
- r
l t
definition addresses base material burning characteristics under j
anticipated conditions.
Thus, the difference between the two j
i definitions is that the NRC definition expressly allows j
t consideration of plant unique applications, whereas the UBC definition may not.
The basis for PG&E's plant specific j
application is summarized below under items (2) and (3).
(2) PG&E previously has qualified Thermo-Lag for use as a radiant energy shield based on reliance on Underwriters Laboratories (UL) testing in accordance with ASTM E-84.
The UL j
tests demonstrated that Thermo-Lag has a flame spread of 5, well f
within the BTP CMEB 9.5-1, Section B.4 flame spread requirement of 50 or less.
This very low flame spread of the base material I
(Thermo-Lag does not utilize a surf ace material) indicates that the material does not exhibit a propensity to burn.
Thus, parts a) and l
b) of BTP CMEB 9.5-1, Section B.4 were satisfied and the material was considered noncombustible.
The NRC has not prescribed a specific test as a determinant of material igniting, burning, or supporting combustion (Part a.
of BTP CMEB 9.5-1, Section B.4) similar to ASTM E-136 as used by NIST l
in the tests reported by IN 92-82, either in Appendix R regulations or implementing guidance.
Therefore, the ASTM E-136 test results reported IN 92-82 do not invalidate or contradict PG&E's application of the previous UL test results under ASTM E-84 used to qualify the Thermo-Lag.
ASTM E-136 tests the' material in a more severe environment than necessary for PG&E's specific application l
as a r.'diant energy shield.
In addition, as an information notice, I
i s
l
IN 92-82 by definition does not impose new requirements on i
1 4
licensees to retest or requalify Thermo-Lag.
j (3) PG&E's engineering assessment of the fire hazards in the i
i vicinity of the Thermo-Lag radiant energy shields in containment indicates that the Thermo-Lag is not expected to be subject to the extreme temperatures or the presence of large heat fluxes similar j
to the conditions under which the NIST tested Thermo-Lag as I
reported in IN 92-82.
Therefore, in its specific application by c
PG&E, Thermo-Lag is a noncombustible material as defined by the NRC l
in BTP CMEB 9.5-1, Section B.4.
i For these reasons, the NIST combustibility test results 3
reported in IN 92-82 are not inconsistent with PG&E's conclusion l
i that its Thermo-Lag radiant energy shields are noncombustible and will perform the required function as a radiant energy shield protecting safe shutdown equipment from a fire in containment.
~
However, this overall combustibility issue has been mooted by PG&E's decision earlier this year to voluntarily replace the Thermo-Lag in DCPP Units 1 and 2 containments with 3M material.
i The Unit 2 replacement was completed during the recent Unit 2 fifth refueling outage, and the Unit i replacement is scheduled for completion during the upcoming Unit 1 sixth refueling outage, scheduled for Spring of 1994. (See PG&E Letter No. DCL-93-109, April 30, 1993).
PG&E understands, based on communications from the Nuclear Management and Resources Council (NUMARC), that the NRC staf f plans to issue a supplement to Generic Letter 92-08 in the summer of 1993 i
t I
i i
h that may include more specific information relative to the generic r
i Thermo-Lag combustibility issue.
In the meantime, PG&E continues i
to monitor NUMARC's Thermo-Lag evaluation program, including i
NUMARC's evaluation of any further testing needs related to the j
combustibility issue.
If the NRC provides new or revised generic guidance to licensees on the applicable standards for determining combustibility of Thermo-Lag in accordance with BTP CMEB 9.5-1, l
t PG&E will evaluate and, if necessary, upgrade its current Appendix j
I R fire protection program in light of that guidance.
I l
l l
I I
i i
r l
l I
f i
S i
I i
h i,
2
Pacific Gas and Electric Gompany 77 Beate Street, Room 1451 GregoryM Reger PD. Box 770330 Senior %ce Presioent and SanFranosco CA94177 General Manager 415/973-4684 Nuclear Power Generation Fax 415/973 2313 April 30, 1993 PG&E Letter No. DCL-93-109 U.S. Nuclear Regulatory Commission y/ gr ATIN: Document Control Desk t
b, Washington, D.C.
20555
'!I
=
'N Re:
Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Information Relating to Response to Supplement 1 of Bulletin 92-01 Gentlemen:
PG&E submitted PG&E Letter No. DCL-92-208 (HBL-92-060), dated September 28, 1992, in response to Supplement 1 of Bulletin 92-01, "f ailure of Thermo-Lag 330 Fire Barrier System to Perform its Specified fire Endurance Function," dated August 28, 1992.
In DCL-92-208, PG&E noted the fire areas at Diablo Canyon Power Plant Units I and 2 where Thermo-Lag was used as a 1 or 3-hour fire barrier.
Also in DCL-92-208, PGLE included a discussion of the Thermo-Lag used fo. radiant energy heat shields in the Units 1 and 2 containments. DCL-92-208 noted that these radiant energy heat shields are outside the scope of Bulletin 92-01 and, therefore, do not require interim compensatory measures. This is to inform you that, subsequent to DCL-92-208, PG&E has elected to replace the Thermo-Lag used in these heat shields.
Accordingly, Thermo-Lag heat shield material in Unit 2 containment was replaced with 3M material during the recent Unit 2 fifth refueling outage. The Unit I containment Thermo-Lag heat shield material is scheduled for replacement with 3M material during the upcoming Unit I sixth refueling outage, scheduled to begin in the Spring of 1994.
Sincerely, b
/f{ mv
^
Gregory M. Rueger
' cc:
Ann P. Hodgdon John B. Martin Mary H. Miller Sheri R. Peterson CPUC Diablo Distribution 6094S/85K/ALN/2242
~ _ _ _
e9 l
i
.e i
UNITED STATES OF AMERICA
- 3hkC NUCLEAR REGULATORY COMMISSION j
BEFORE THE ATOMIC SAFETY AND LICENSING BOAg6 W,'l 12 A9 Z9 i
,u i,, r '
In the Matter of:
)
,9 m a i. jn !.i
)
Docket Nos. 50-275WOLA" i
Pacific Gas and Electric Company
)
50-323-OLA
-l
)
(Construction Period (Diablo Canyon Power
)
Recapture) l Plant, Units 1 and 2)
)
)
.i
- l CERTIFICATE OF SERVICE
{
I hereby certify that copies of " PACIFIC GAS & ELECTRIC - COMPANY ' S
[
LETTER DATED MAY 7,
1993 AND ATTACHMENTS THERETO" in the above-
)
captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk
(*), by Federal Express overnight delivery, this 7th day of May, 1993.
Charles Bechhoefer, Chairman
- Frederick J.
Shon*
i
' Administrative Judge Administrative' Judge Atomic Safety and Licensing Board Atomic Safety and' Licensing' Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West / West Towers Building East West / West Tower Building 4350 East West Highway, Room E-413 4350 East West Highway, Room E-430 Bethesda, MD 20814 Bethesda, MD 20814 Jerry R. Kline*
Office of Commission Appellate Administrative Judge Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission _ Washington, DC 20555 East West / West Towers Building 4350 East West Highway, Room E-427 Bethesda, MD 20814 Office of the Secretary Ann P. Hodgdon, Esq.*
f U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission l
Attn:
Docketing and Service 1 White Flint North' j
Section 11555 Rockville Pike j
(original + two copies)
Rockville, MD 20852 l
l Adjudicatory File Peter Arth, Jr.
Atomic Safety and Licensing Edward W. O'Neill j
Board Panel Peter G.-Fairchild U.S. Nuclear Regulatory Commission California _Public' Utilities l
Washington, DC 20555 Commission j
505 Van Ness Avenue j
San Francisco, CA 94102 i
-l
+
4 a
Nancy Culver, President Truman Burns t
Board of Directors California Public Utilities San Luis Obispo Mothers for Peace Commission P.O.
Box 164 505 Van Ness, Rn. 4103 Pismo Beach, CA 93448 San Francisco, CA 94102 i
Robert R. Wellington, Esq.
Joseph B.
Knotts, Jr.,
Esq.
Diablo Canyon Independent Safety David A. Repka, Esq.
Committee Winston & Strawn 857 Cass Street, Suite D 1400 L Street, N.W.
Monterey, CA 93940 Washington, DC 20005-3502 Robert Kinosian Jill ZamEk*
California Public Utilities 1123 Flora Road Commission Arroyo Grande, CA 93420 505 Van Ness, Rm. 4102 San Francisco, CA 94102 Mr. Gregory Minor
- MHB Technical Associates 1723 Hamilton Ave., Suite K San Jose, CA 95125 W/161
/
Christopher J. (Marner Counsel for Pacific Gas and Electric Company i
I I