ML20080M591

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Addl Contentions on Design QA
ML20080M591
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 09/29/1983
From: Kaufman P, Reynolds J
CALIFORNIA, STATE OF, CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20080M582 List:
References
ISSUANCES-OL, NUDOCS 8310040212
Download: ML20080M591 (4)


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UNITED STATES OF AMERICA J RC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOW OCT -3 Pl2 50 CFFICE 0F SECRETAF -

00CKETING & SERV!U.

) BRANCH In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL

) 50-323 OL (Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

GOVERNOR DEUKMEJIAN AND JOINT INTERVENORS' ADDITIONAL CONTENTIONS ON DESIGN QUALITY ASSURANCE Pursuant to the Atomic Safety and Licensing Appeal Board's September 7, 1983 order, Governor Deukmejian and the Joint Intervenors hereby submit the following additional contentions on design quality assurance arising out of materials which have been released after the last opportunity to tender contentions:

3. (o) The ITP has not demonstrated and the IDVP has not verified, that the DCP modeling of the seismic response cf the fuel handling building is proper, in that the DCP has not adequately justified the use of the translational and torsional response of the' auxiliary building as input to the fuel handling building nor has it demonstrated the validity of the dynamic degrees of freedom selected. (ITR 57.)

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8310040212 830929 PDR ADOCK 05000275 O PDR

(p)- The ITP'has not demonstrated, and the IDVP has not verified, that the DCP seismic model of the slabs in the auxiliary building is proper, in relation to the use of vertical and rotational springs to model the columns, and the motions used as input at the ends of the springs not connected to the slabs. In addition, in the study of the diaphragms, the ITP has not adequately accounted for the inplane flexibility of these slabs, and has not adequately demonstrated that stresses are within allowable limits at all elevations. (ITR 55.)

(q) The ITP has not demonstrated and the IDVP has not verified, that the soils analysis for the buried diesel fuel oil tanks is proper in that the values of,the exponent shown in figure 14 of ITR 68 have not been demonstrated to be appropriate and the variation of shear velocity with depth is not properly justified.

(ITR 68.)

(r) The ITP has not demonstrated and the IDVP has not verified that the soils analysis for the auxiliary saltwater piping and circulating water intake conduits is proper in that the selection of the modulus versus strain curve utilized is not justified. (ITR 68.)

(s) The ITP has not demonstrated and the IDVP has not verified that the seismic analysis of the turbine 2.

building is proper in that bolt bearing capacities were taken from an inappropriate source. (ITR 56.)

(t) The ITP has not demonstrated and the IDVP has not verified that the seismic analysis of the turbine building is proper in that the use of four different models for the vertical analysis has not been justified. -'

(ITR 56.)

9. Contrary to General Design Criteria 44 (GDC-44) of Appendix A to 10 C.F.R. Part 50, PG&E has failed to provide adequate assurance of component cooling water system (CCWS) heat removal safety function capacity in that the maximum ocean water temperative of 64* F. is not conservative because it-has already been exceeded in 1983. Furthermore a technical specification limitation which permits plant operation at reduced power levels in lieu of enlarging the capacity of the CCWS does not provide an equivalent level of

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safety as compliance with the requirements of GDC-44 (SSER 16 (Aug. 1983 ) and September 1983 ocean water temperature readings).

DATED: SEPTEMBER 29, 1983.

Respectfully submitted, JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy,A9 ne n "al By '

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' ' 'P ER H. KAUFMAN Attorneys fo Governor George Deukmejian 3580 Wilshire Boulevard Los Angeles, California 90010 Telephone: (213) 736-2102 JOEL R. REYNOLDS, Esq.

JOHN R. PHILLIPS , Esq.

ERIC HAVIAN, Esq.

Center for Law in the Public Interest 10951 West Pico Boulevard Los Angeles, California 90064 Telephone: (213) 470-3000 i DAVID S. FLEISCHAKER, Esq.

P. O. Box 1178

[ Oklahoma City, Oklahoma 731 1 By '

As}R _ k _j '

(/ / JOEL RgyNOLDS pf Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER

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