ML20050M816

Answer Opposing Governor Brown Motion for Deferral of ASLB Decision Pending Evaluation of Util Design Errors Involving Block & Relief Valves & Pressurizer Heaters.Certificate of Svc Encl

ML20050M816
Person / Time
Site:	Diablo Canyon
Issue date:	04/07/1982
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	NRC COMMISSION (OCM)
References
NUDOCS 8204140322
Download: ML20050M816 (5)

Text

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4 e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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In the Matter of )

PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275

) Docket No. 50-323 (Diablo Canyon Nuclear Power )

Plant, Unit Nos. 1 and 2) ) (Full-Power Proceedin 03 0) b O PACIFIC GAS AND ELECTRIC COMPANY'S s ?

OPPOSITION TO MOTION OF GOVERNOR EDMOND G. BROWN g jR.

,h[yp 7j FOR THE DEFERRAL OF BOARD DECISION PENDING - y gy.' ,p, EVALUATION OF PGandE DESIGN ERRORS INVOLVINGd

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BLOCK AND RELIEF VALVES AND PRESSURIZER HEATERS \ f'e .

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Governor Brown has requested a deferral of a Bod (>d/- ,)'

Decision regarding PGandE's application for a full-power operating license citing PGandE's Board Notification of February 24, 1982, which indicated that the seismic response spectra at the elevation where the power operated relief valves (PORV) and their associated block valves are located may not have been conservative.

Preliminarily we note that in oral testimony presented at the hearings as well as the written prepared testimony, it was asserted by PGandE and the NRC staff witnesses that neither the pressurizer heaters nor the PORVs and their associated block valves were required to be classified as safety grade. However, we did state that all block valves and all but one of the three PORVs have been qualified to meet safety grade requirements.

With respect to questions raised concerning the appropriateness of the seismic analyses for these components, the only portion of the pressurizer heaters that is required to withstand the postulated Hosgri event is the heater penetration 1)So3 g

on the pressurizer. Admittedly, this penetration must be safety jg DOhko!$80hh5 PDR

grade to maintain the pressure boundary. However, the design of the heater penetration was considered as part of the analysis of the pressurizer and its associated piping. The information furnished in the February 24, 1982, Board Notification and upon which this Motion is based does not relate to the spectra developed below the 140' level but only the appropriate spectra above this level. Hence, the Motion fails to present any information affect-ing the seismic qualification of these components. With respect to the seismic qualification of the PORVs and their associated block valves, the only requirement is that they be qualified to withstand the Hosgri event in order to maintain the pressurizer pressure boundary. Revised spectral inputs appropriate to the elevation at which the PORVs and associated block valves are located are currently being generated and will be utilized in a reanalysis of the valves. Based on this reanalysis, the valve piping and associated supports will be modified, if and as necessary, to maintain their safety grade qualification as testified at the Full-Power Hearings.

Since the qualification of the valves will be maintained and further that the pressurizer heater qualifications are not at issue, there is no compelling reason, based upon the February 24, 1982, Board Notification, for this Board to defer its decision on

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those issues relating to block and relief valves and pressurizer heaters presented at the January Full-Power Hearings. Accordingly, PGandE urges that the Motion be denied.

Respectfully submitted, MALCOLM H. FURBUSH PHILIP A. CRANE, JR.

RICHARD F. LOCKE Pacific Gas and Electric Company P. O. Box 7442 San Francisco, CA 94120 (415) 781-4211 ARTHUR C. GEHR Snell & Wilmer 3100 Valley Bank Center Phoenix, AZ 85073 (602) 257-7288 BRUCE NORTON Norton, Burke, Berry & French, P.C.

3216 N. Third Street, Suite 300 Phoenix, AZ 85012-2699 (602) 264-0033 Attorneys for Pacific Gas and Electric Company Dated: April 7, 1982 By' ~

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275

) Docket No. 50-323 Diablo Canyon Nuclear Power Plant, ) (Full Power License Proceeding)

Units 1 and 2 )

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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 10951 W. Pico Boulevard - Suite 300 Atomic Safety and Licensing Board Los Angeles, California 90064 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. Rayo 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 l

ta Chairman 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 Secretary U. S. Nuclear Regulatory Commission Judge W. Reed Johnson Washington, 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 San Jose, California 95125 Mr. Carl Neiberger Telegram Tribune P. O. Box 112 Snn Luis Obispo, California 93402 Herbert H. Brown, Esq.

Lnwrence Coe Lanpher, Esq.

Christopher B. Hanback, Esq.

Kirkpatr,ick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.

Wschington, D. C. 20036 Byron S. Georgiou, Esq.

Legal Affairs Secretary Governor's Office State Capitol l Sncramento, California 95814 I

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c Crkne,Jr.

Attorney Pacific Gas and Electric Company

' Date s April 7, 1982