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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20212B1681999-09-13013 September 1999 Forwards Insp Repts 50-275/99-12 & 50-323/99-12 on 990711- 08-21.Four Violations Being Treated as Noncited Violations ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210H6181999-07-27027 July 1999 Forwards Insp Repts 50-275/99-07 & 50-323/99-07 on 990503- 0714.Apparent Violations Being Considered for Escalated Enforcement Action ML18107A7011999-06-25025 June 1999 Requests Rev of NRC Records to Reflect Change of PG&E Address ML20205J3381999-04-0808 April 1999 Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision Expired. Commission Declined Any Review & Became Final Agency Action on 990406.With Certificate of Svc.Served on 990409 DCL-99-038, Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f)1999-03-31031 March 1999 Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f) DCL-99-033, Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl1999-03-12012 March 1999 Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl DCL-99-010, Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld1999-01-26026 January 1999 Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld ML20202A9831999-01-18018 January 1999 Informs That Modesto Irrigation District No Longer Seeking Addl Interconnection with Pacific Gas & Electric Co at Pittsburg,Ca & Matters First Addressed in 980429 Comments in Opposition to Restructuring of Util Have Now Become Moot IR 05000275/19980121999-01-13013 January 1999 Informs That Insp Repts 50-275/98-12 & 50-323/98-12 Have Been Canceled DCL-98-163, Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld1998-11-24024 November 1998 Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld ML20195G5161998-11-16016 November 1998 Forwards Insp Repts 50-275/98-16 & 50-323/98-16 on 980913- 1024.No Violations Noted ML20155F7951998-11-0303 November 1998 Second Partial Response to FOIA Request for Documents. Records Subj to Request Encl & Identified in App C DCL-98-123, Submits Listed Address Changes for NRC Service Lists for Listed Individuals1998-09-0909 September 1998 Submits Listed Address Changes for NRC Service Lists for Listed Individuals DCL-98-108, Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year..1998-08-0707 August 1998 Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year.. ML20236T2931998-07-24024 July 1998 Forwards Order Prohibiting Involvement in NRC Licensed Activities for 5 Yrs.Order Being Issued Due to Falsification of Info on Application to Obtain Unescorted Access to PG&E Plant ML20236T3431998-07-22022 July 1998 Forwards Insp Repts 50-275/98-11 & 50-323/98-11 on 980526-28.Apparent Violations Identified & Being Considered for Escalated Enforcement Action ML20236J2251998-07-0101 July 1998 Ltr Contract,Task Order 232 Entitled, Review of Callaway, Comanche,Diablo Canyon & Wolf Creek Applications for Conversion to Improved TS Based on Standard TS, Under Contract NRC-03-95-026 ML20236G0691998-06-19019 June 1998 Forwards Endorsement 123 to Neila Policy NF-228,Endorsement 145 to Neila Policy NF-113,Endorsement 124 to Neila Policy NF-228 & Endorsement 89 to Maelu Policy MF-103 IR 05000275/19980051998-04-17017 April 1998 Forwards Insp Repts 50-275/98-05 & 50-323/98-05 on 980202-06 & 23-27 & 0302-18.No Violations Noted.Insp Focused on Resolution of Previous NRC Insp Findings & Included Review of Issues Identified During Architect/Engineering Insp Rept ML20203G0371998-02-25025 February 1998 Forwards Revised Copy of NRC Form 398, Personal Qualification Statement - Licensee, (10/97) Encl 1,which Has Been Revised to Reflect Current Operator Licensing Policy DCL-98-014, Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld1998-02-10010 February 1998 Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld ML20199H6691998-02-0202 February 1998 Ack Receipt of ,Transmitting Rev 18,change 11, to Plant Physical Security Plan,Submitted Under Provisions of 10CFR50.54(p).Role of Video Capture Audible Alarm Sys Needs to Be Addressed in Security Plan,Per 980123 Telcon DCL-97-187, Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld1997-11-19019 November 1997 Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld IR 05000275/19970181997-10-31031 October 1997 Forwards Insp Repts 50-275/97-18 & 50-323/97-18 on 971006- 10.Insp Verified That Liquid & Gaseous Radioactive Waste Effluent Mgt Program Was Properly Implemented.No Violations Noted DCL-97-156, Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld1997-09-16016 September 1997 Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld ML20210H4671997-08-0202 August 1997 Requests That NRC Suspend Investigation & Review of Issues Raised by Modesto Irrigation District & Transmission Agency of Northern CA Re Contention That PG&E Had Violated Nuclear License Conditions Known as Stanislaus Commitments ML20137N1591997-03-31031 March 1997 Informs That Licensee Facility Scheduled to Administer NRC GFE on 970409.Sonalsts,Inc Authorized Under Contract to Support NRC Administration of GFE Activities ML16343A4801997-02-25025 February 1997 Forwards non-proprietary WCAP-14796 & Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methodology. Proprietary Rept Withheld,Per 10CFR2.90 ML20134H6271997-02-10010 February 1997 Fifth Partial Response to FOIA Request for Documents.Records in App I Encl & Available in Pdr.App J Records Withheld in Part (Ref FOIA Exemption 5) & App K Records Completely Withheld (Ref FOIA Exemption 5) ML20134K3421997-02-0606 February 1997 Conveys Results & Conclusions of Operational Safeguards Response Evaluation Conducted by NRR at Plant,Units 1 & 2, on 960909-12.W/o Encl ML16342D5291997-01-31031 January 1997 Transmits WCAPs Supporting NRCs Review of License Amend Request 96-10,rev of TSs to Support Extended Fuel Cycles to 24 months.WCAP-11082,rev 5,WCAP-11594,rev 2 & WCAP-14646,rev 1 Withheld ML16342D5331997-01-24024 January 1997 Requests Proprietary Version of WCAP-14646,rev 1, Instrumentation Calibration & Drift Evaluation for Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1997 Be Withheld from Public Disclosure Per 10CFR2.790 ML16342D5311997-01-24024 January 1997 Requests That WCAP-11594,rev 2, W Improved Thermal Design Procedure Instrument Uncertainty Methodology,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation Be Withheld from Public Disclosure,Per 10CFR2.790 ML16342D5321997-01-24024 January 1997 Requests WCAP-11082,rev 5, Westinghouse Setpoint Methodology for Protection Sys,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1996 Be Withheld from Public Disclosure Per 10CFR2.790 ML20136C3521997-01-11011 January 1997 Discusses Japan Oil Spill & Np Intake & Possibilities of Such Event Occurring at SONGS or Dcnpp ML20133F8961997-01-0909 January 1997 Responds to NRC Ltr of 961206 Received on 961210 Which Requested Further Info Re Utils Violations of Conditions of Its Nuclear Licenses Designated to Promote & Protect Competition in Bulk Power Market in Northern & Central CA ML20133F8721997-01-0909 January 1997 Acks & Responds to NRC Ltr of 961206 Received by Undersigned on 961210 Requesting Further Info to Document Tancs Assertion,Per Filing on 960429 That Util Has Violated Terms & Conditions of Nuclear Power Project Licenses ML16342D5521996-12-18018 December 1996 Requests That Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methology, Be Withheld (Ref 10CFR2.790(b)(4)) ML20129J4001996-10-18018 October 1996 Forwards Order Approving Corporate Restructuring by Establishment of Holding Company & Safety Evaluation NSD-NRC-96-4846, Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl1996-10-16016 October 1996 Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl ML20129G6121996-09-24024 September 1996 Second Partial Response to FOIA Request for Documents. Forwards Documents Listed in App C,E,F & G.Documents Available in Pdr.App E,F & G Documents Partially Withheld Ref FOIA Exemptions 4 & 6.App D Record Listed as Copyright DCL-96-170, Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld1996-08-14014 August 1996 Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld DCL-96-141, Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld1996-07-31031 July 1996 Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld ML20116B8411996-07-22022 July 1996 Forwards Revisions to SR 95-03,SR 95-04 & SR 95-05 Re EDG 1-2 Valid Failures ML20117E6171996-05-24024 May 1996 Forwards Public Version of Rev 11 to EPIP EP R-7, Off-Site Transportation Accidents DCL-96-102, Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld1996-05-0606 May 1996 Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld DCL-96-096, Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 151996-04-16016 April 1996 Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 15 DCL-96-054, Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld1996-02-28028 February 1996 Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld 1999-09-13
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18107A7011999-06-25025 June 1999 Requests Rev of NRC Records to Reflect Change of PG&E Address DCL-99-038, Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f)1999-03-31031 March 1999 Forwards Decommissioning Funding Repts for Diablo Canyon Power Plant,Units 1 & 2 & Humboldt Bay Power Plant,Unit 3, Per Requirements of 10CFR50.75(f) DCL-99-033, Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl1999-03-12012 March 1999 Forwards Change 16 to Rev 18 of Diablo Canyon Power Plant Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Safeguards Effectiveness of Plan.Without Encl DCL-99-010, Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld1999-01-26026 January 1999 Forwards Change 15 to Rev 18 of Dcnpp Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan.Encl Withheld ML20202A9831999-01-18018 January 1999 Informs That Modesto Irrigation District No Longer Seeking Addl Interconnection with Pacific Gas & Electric Co at Pittsburg,Ca & Matters First Addressed in 980429 Comments in Opposition to Restructuring of Util Have Now Become Moot DCL-98-163, Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld1998-11-24024 November 1998 Forwards Change 14 to Rev 18 of Physical Security Plan. Changes Do Not Decrease Safeguards Effectiveness of Plan & Submitted Pursuant to 10CFR50.54(p).Encl Withheld DCL-98-123, Submits Listed Address Changes for NRC Service Lists for Listed Individuals1998-09-0909 September 1998 Submits Listed Address Changes for NRC Service Lists for Listed Individuals DCL-98-108, Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year..1998-08-0707 August 1998 Submits 90-day Response to NRC GL 98-01, Yr 2000 Readiness of Computer Sys at Nuclear Power Plants. Util Has Pursued & Continuing to Pursue Year 2000 Readiness Program Similar to That Outlined in Nei/Nusmg 97-07, Nuclear Util Year.. ML20236G0691998-06-19019 June 1998 Forwards Endorsement 123 to Neila Policy NF-228,Endorsement 145 to Neila Policy NF-113,Endorsement 124 to Neila Policy NF-228 & Endorsement 89 to Maelu Policy MF-103 DCL-98-014, Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld1998-02-10010 February 1998 Forwards Change 12 to Rev 18 to Physical Security Plan,Per 10CFR50.54(p).Plan Withheld DCL-97-187, Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld1997-11-19019 November 1997 Forwards Change 11,rev 18 to Physical Security Plan.Encl 1 Describes Proposed Revs to Physical Security Plan.Plan Withheld DCL-97-156, Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld1997-09-16016 September 1997 Provides Change 10 to Rev 18 of Physcial Security Plan & Change 2 to Rev 3 of Safeguards Contingency Plan.Plans Withheld ML20210H4671997-08-0202 August 1997 Requests That NRC Suspend Investigation & Review of Issues Raised by Modesto Irrigation District & Transmission Agency of Northern CA Re Contention That PG&E Had Violated Nuclear License Conditions Known as Stanislaus Commitments ML16343A4801997-02-25025 February 1997 Forwards non-proprietary WCAP-14796 & Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methodology. Proprietary Rept Withheld,Per 10CFR2.90 ML16342D5291997-01-31031 January 1997 Transmits WCAPs Supporting NRCs Review of License Amend Request 96-10,rev of TSs to Support Extended Fuel Cycles to 24 months.WCAP-11082,rev 5,WCAP-11594,rev 2 & WCAP-14646,rev 1 Withheld ML16342D5321997-01-24024 January 1997 Requests WCAP-11082,rev 5, Westinghouse Setpoint Methodology for Protection Sys,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1996 Be Withheld from Public Disclosure Per 10CFR2.790 ML16342D5331997-01-24024 January 1997 Requests Proprietary Version of WCAP-14646,rev 1, Instrumentation Calibration & Drift Evaluation for Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation, Jan 1997 Be Withheld from Public Disclosure Per 10CFR2.790 ML16342D5311997-01-24024 January 1997 Requests That WCAP-11594,rev 2, W Improved Thermal Design Procedure Instrument Uncertainty Methodology,Diablo Canyon Units 1 & 2,24 Month Fuel Cycle Evaluation Be Withheld from Public Disclosure,Per 10CFR2.790 ML20136C3521997-01-11011 January 1997 Discusses Japan Oil Spill & Np Intake & Possibilities of Such Event Occurring at SONGS or Dcnpp ML20133F8961997-01-0909 January 1997 Responds to NRC Ltr of 961206 Received on 961210 Which Requested Further Info Re Utils Violations of Conditions of Its Nuclear Licenses Designated to Promote & Protect Competition in Bulk Power Market in Northern & Central CA ML20133F8721997-01-0909 January 1997 Acks & Responds to NRC Ltr of 961206 Received by Undersigned on 961210 Requesting Further Info to Document Tancs Assertion,Per Filing on 960429 That Util Has Violated Terms & Conditions of Nuclear Power Project Licenses ML16342D5521996-12-18018 December 1996 Requests That Proprietary WCAP-14795, Nrc/Util Meeting on Model 51 SG Tube Integrity & ARC Methology, Be Withheld (Ref 10CFR2.790(b)(4)) NSD-NRC-96-4846, Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl1996-10-16016 October 1996 Transmits Proprietary & non-proprietary Versions of Preliminary Rept, Incomplete Rcca Insertion. W Authorization ltr,AW-96-1021 & Affidavit Requesting Info Be Withheld from Public Disclosure Encl DCL-96-170, Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld1996-08-14014 August 1996 Forwards Change 1 to Rev 4 of Training & Qualification Plan, Per 10CFR50.54(p).Plan Withheld DCL-96-141, Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld1996-07-31031 July 1996 Submits Change 9 to Rev 18 of Physical Security Plan.Plan Withheld ML20116B8411996-07-22022 July 1996 Forwards Revisions to SR 95-03,SR 95-04 & SR 95-05 Re EDG 1-2 Valid Failures ML20117E6171996-05-24024 May 1996 Forwards Public Version of Rev 11 to EPIP EP R-7, Off-Site Transportation Accidents DCL-96-102, Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld1996-05-0606 May 1996 Submits Change 8 to Rev 18 of Physical Security Plan,Per 10CFR50.54(p).Encl Withheld DCL-96-096, Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 151996-04-16016 April 1996 Forwards Public Version of Rev 3 to Diablo Canyon Power Plant Units 1 & 2 Emergency Plan, Change 15 DCL-96-054, Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld1996-02-28028 February 1996 Forwards Change 7 to Rev 18 of Physical Security Plan & Change 1 to Rev 3 of Safeguards Contingency Plan.Encl Withheld ML20100L4631996-02-23023 February 1996 Forwards Response to NRC Enforcement Action 95-279 Re Violations Noted in Insp Repts 50-275/95-17 & 50-323/95-17 on 951021-1208.Corrective Actions:Directive Was Issued to Plan 2R7 W/Six Day Work Schedule DCL-96-036, Forwards Public Version of Rev 18 to EPIP EP EF-1, Activation & Operation of Technical Support Ctr1996-02-20020 February 1996 Forwards Public Version of Rev 18 to EPIP EP EF-1, Activation & Operation of Technical Support Ctr ML20097E9341996-01-25025 January 1996 Forwards Public Version of EPIP Update for Diablo Canyon Power Plant,Units 1 & 2 DCL-95-272, Supports Comments Submitted by NEI Re Licensee Qualification for Performing Safety Analyses,With Listed Exception.Nrc Should Allow Traning Requirement to Be Met by on-job Training1995-12-11011 December 1995 Supports Comments Submitted by NEI Re Licensee Qualification for Performing Safety Analyses,With Listed Exception.Nrc Should Allow Traning Requirement to Be Met by on-job Training DCL-95-264, Forwards Change 6 to Rev 18 to Physical Security Plan.Encl Withheld (Ref 10CFR73.55(d)(5))1995-12-0606 December 1995 Forwards Change 6 to Rev 18 to Physical Security Plan.Encl Withheld (Ref 10CFR73.55(d)(5)) ML20094M6001995-11-21021 November 1995 Forwards Final Rept of Investigation & Analysis of Event 29257 Re Substandard Fastner Processed & Sold by Cardinal Industrial Products,Lp,So That Customers Can Evaluate Situation in Light of 10CFR21.21(a)(1)(ii) & (b)(1) DCL-95-204, Forwards Proposed Changes to Physical Security Plan.Encl Withheld1995-09-19019 September 1995 Forwards Proposed Changes to Physical Security Plan.Encl Withheld DCL-95-199, Requests Exemption to 10CFR73.55 & Provides Draft Changes to Plant Physical Security Plan1995-09-14014 September 1995 Requests Exemption to 10CFR73.55 & Provides Draft Changes to Plant Physical Security Plan ML20087A0471995-07-28028 July 1995 Forwards Security Safeguards Info in Form of Change to Proposed Draft Plant Security Program.Encl Withheld DCL-95-153, Forwards Public Files Version of Revised Corporate Emergency Response Plan Implementing Procedures,Including Rev 14 to 1.1,Rev 8 to 1.2,Rev 11 to 2.1,Rev 5 to 3.1,Rev 12 to 3.2,Rev 6 to 3.5,Rev 14 to 4.3.W/950807 Release Memo1995-07-27027 July 1995 Forwards Public Files Version of Revised Corporate Emergency Response Plan Implementing Procedures,Including Rev 14 to 1.1,Rev 8 to 1.2,Rev 11 to 2.1,Rev 5 to 3.1,Rev 12 to 3.2,Rev 6 to 3.5,Rev 14 to 4.3.W/950807 Release Memo DCL-95-134, Forwards Rev 4 of Diablo Canyon Security Force Training & Qualification Plan.Encl Withheld Per 10CFR2.790(d)1995-07-0505 July 1995 Forwards Rev 4 of Diablo Canyon Security Force Training & Qualification Plan.Encl Withheld Per 10CFR2.790(d) ML20086H5461995-06-29029 June 1995 Forwards Final Exercise Rept for 931020,full Participation Plume Exposure & Ingestion Pathway Exercise of Offsite Radiological Emergency Response plans,site-specific to Plant.No Deficiencies Noted DCL-95-046, Submits Summary Description of Proposed Vehicle Control Measures Per 10CFR73.55.Encl Withheld1995-02-28028 February 1995 Submits Summary Description of Proposed Vehicle Control Measures Per 10CFR73.55.Encl Withheld DCL-95-039, Forwards Public Version of Revised Epips,Including EPIP Table of Contents,Rev 18 to EP G-2,rev 3 to EP OR-3,rev 17 to EP EF-1 & Rev 3 to EP EF-9.W/950306 Release Memo1995-02-23023 February 1995 Forwards Public Version of Revised Epips,Including EPIP Table of Contents,Rev 18 to EP G-2,rev 3 to EP OR-3,rev 17 to EP EF-1 & Rev 3 to EP EF-9.W/950306 Release Memo ML18101A5671995-02-17017 February 1995 Informs of Improper Presentation of Jet Expansion Model in Bechtel Technical rept,BN-TOP-2,Rev 2 Design for Pipe Break Effects Issued May 1974.NRC May Need to Consider Evaluating Consequences of Potential Misapplication of Expansion Model ML18101A5681995-02-17017 February 1995 Requests NRC to Clarify Whether Plant Should Declare ESF Portion of Ssps Inoperable & Enter TS 3.0.3 LCO Under Circumstances as Ref in in 95-10.Subj in Re Postulated Slb W/Potential to Render One Train of Ssps Inoperable ML18101A5741995-02-17017 February 1995 Requests Clarification of Whether Plant Should Declare ESF Portion of Ssps Inoperable & Enter TS 3.0.3 Limiting Conditions for Operation Under Circumstances Described in Info Notice 95-10 DCL-95-033, Forwards Public Version of Rev 3,Change 14 to Corporate Emergency Response Plan (Cerp) & Cerp Implementing Procedures1995-02-13013 February 1995 Forwards Public Version of Rev 3,Change 14 to Corporate Emergency Response Plan (Cerp) & Cerp Implementing Procedures DCL-95-013, Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-11,rev 7A to EP RB-15:F,rev 4A to EP RB-15:G,rev 15A to EP EF-2 & Rev 14D to EP G-4.W/950208 Release Memo1995-01-24024 January 1995 Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-11,rev 7A to EP RB-15:F,rev 4A to EP RB-15:G,rev 15A to EP EF-2 & Rev 14D to EP G-4.W/950208 Release Memo DCL-94-258, Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-8,Rev 4B to EP RB-10,Rev 5 to EP RB-12,on-spot Change to Rev 9 to EP RB-15:C,Rev 16A to EP EF-1 & Rev 3B to EP EF-3B1994-11-21021 November 1994 Forwards Public Version of Revised Epips,Including Rev 11A to EP RB-8,Rev 4B to EP RB-10,Rev 5 to EP RB-12,on-spot Change to Rev 9 to EP RB-15:C,Rev 16A to EP EF-1 & Rev 3B to EP EF-3B 1999-06-25
[Table view] Category:PUBLIC ENTITY/CITIZEN/ORGANIZATION/MEDIA TO NRC
MONTHYEARML20236U6921987-11-20020 November 1987 Telex from San Luis Obispo California Mothers for Peace Re Facilities ML20236C1201987-10-20020 October 1987 Forwards Request for Stay Filed by Sierra Club in Proceeding Re NRC Issuance of Amends 8 & 6 to Licenses DPR-80 & DPR-82,respectively.Requests Commission Act on Request by 871026 ML20235K7941987-10-0202 October 1987 Informs of Change of Address for Receiving All Matls Related to Facility.New Address Listed.Served on 871002 ML20235F2561987-09-24024 September 1987 Forwards Request for Stay & Notice of Appeal of Licensing Board 870911 Initial Decision,Authorizing License Amends & 870902 Order of Board Denying Sierra Club Motion to Admit Contention & Request for Preparation of Eis.W/O Encl ML20238B7731987-08-0707 August 1987 FOIA Request for Records Explaining Status of Listed LERs Omitted from List,Previously Received from Nrc,Of LERs Filed by Commercial Nuclear Power Plant Licensees for Operating Year 1986 ML20237G9911987-07-28028 July 1987 Comments Supporting Onsite Storage & Reracking Until Federal Repository for Storage of All Spent Fuel Built.Support of Util & Facility Operations Discussed ML20236K7881987-07-0202 July 1987 Appeals Denial of FOIA Request for Interview Tapes Re SER of Operation of Plant ML20235G8501987-06-15015 June 1987 Appeals Denial of FOIA Request for Documents Re Plant Listed in App E.W/O App ML20215B1431987-02-25025 February 1987 FOIA Request for Listed Documents Re Mgt of Facility QA & QC Personnel ML20213A3971986-11-30030 November 1986 Summarizes ACRS Subcommittee on Extreme External Phenomena 861120 Meeting Re Facility long-term Seismic Program.Studies Necessary & Conducted in Excellent Manner ML20214P8771986-09-16016 September 1986 Submits Addl Corrections to 860822 Preliminary Conference Transcript.Requests That Response Remain Open Until 860919 in Order That Items Be Accurately Researched & Corrected. W/Certificate of Svc ML20212L1781986-08-18018 August 1986 Forwards Rept on Efforts to Resolve Sierra Club Contention (I)(A) ML20207H7661986-06-25025 June 1986 Supports San Luis Obispo Mothers for Peace & Sierra Club Request for Stay of Issuance of Amends 8 & 6 to Licenses DPR-80 & DPR-82,respectively.Problems Associated W/No Significant Hazards Determination Noted ML20214T6541986-05-28028 May 1986 Appeals Denial of FOIA Request for Ofc of Inspector & Auditor Rept & Related Documents Re Allegations That NRC Responded Improperly to Allegations of Whistleblowers at Plant.Response Requested within 20 Working Days ML20214T7651986-03-0404 March 1986 FOIA Request for Documents Re Ofc of Inspector & Auditor Investigation & Audit of Charges That NRC Improperly Responded to Allegations of Whistleblowers at Plant ML20210G9101986-01-27027 January 1986 Undated FOIA Request for Transcript of Closed Commission 811119 Meeting to Discuss Suspension of Diablo Canyon Unit 1 Low Power OL ML20141N3161986-01-14014 January 1986 FOIA Request for R Jackson to R Vollmer Re Diablo Canyon Hearing Reopening & San Onofre Review Status ML20138Q8561985-11-20020 November 1985 FOIA Request for Documents Re Ofc of Inspector & Auditor Investigation Into Charges That NRC Responded Improperly to Allegations by Whistleblowers at Facility ML20133G9571985-08-20020 August 1985 FOIA Request for Documents Re Ofc of Inspector & Auditor Charges That NRC Responded Improperly to Allegations of Possible QA & Safety Violations by Whistleblowers at Plant ML20198M9631985-06-17017 June 1985 Forwards Allegations of Safety Violations of Nuclear Regulatory Law or Westinghouse QA Requirements.Investigation Requested.Related Info Encl ML20133H5871985-05-0808 May 1985 FOIA Request for Documents Re Plant,Including All Contacts Between DOE Task Force on Commercial Nuclear Power,White House Cabinet Council Working Group & NRC Concerning OL ML20128Q6531985-05-0808 May 1985 FOIA Request for Three Categories of Documents Re Facilities ML20128P8031985-04-0808 April 1985 FOIA Request for Access to or Records Re Potential Environ Impact Associated W/Fuel Loading &/Or Low Power Testing at Diablo Canyon & AEOD Sept 1980 Rept on Browns Ferry Interim Equipment to Detect Water in Discharge ML20126J0361985-03-26026 March 1985 Ack Receipt of 850325 Telegram Re Followup Interview of Clients for Pending Allegations.Finalization of Interview Schedules Requested.Second Witness Name Should Be Deleted If Telegram Publicly Available ML20127F1741985-02-0101 February 1985 FOIA Request for All Records & Info Re Vendor Insp Branch 840229 Rept 99900840/83-01 at Cardinal Industrial Products Corp That Mention Diablo Canyon ML20107K7771984-11-28028 November 1984 Appeals Denial of FOIA Request for All Transcripts from Commission June,Jul & Aug 1984 Meetings Re Issuance of Full Power License for Facility ML20215L7951984-11-15015 November 1984 Forwards Amended Mcdermott & O'Neill Petition Re Plant,Per 10CFR2.206.Exhibits 7-18,consisting of Affidavits from 12 Witnesses,Being Filed W/Nrc to Avoid Compromising Ongoing Ofc of Investigations Investigation.W/O Encl ML20133Q2971984-11-0505 November 1984 Appeals Denial of FOIA Request for Transcripts of Commission Meetings Held During June,Jul & Aug 1984 Re Effects of Earthquakes at facility,SECY-84-70 & SECY-84-291 & Commission Final Order CLI-84-12 ML20107C4631984-11-0101 November 1984 Forwards Mc Thompson,Tm Devine & Lockert Affidavits Representing Portion of Results from 841009-30 Investigative Trip.Commission Has Adopted Adversary Position W/Respect to Public Since 840817 Stay ML20107H7671984-10-19019 October 1984 FOIA Request for Documents Re Commission Meetings Held During June,Jul & Aug 1984 on Complicating Effects of Earthquakes on Emergency Preparedness ML20107H0161984-10-15015 October 1984 FOIA Request for Documents Re Facility,Including Transcripts of Meetings Concerning Issuance of Unit 1 Full Power OL ML20107F9121984-10-0909 October 1984 FOIA Request for Transcripts of Closed Commission Meetings Held During June,Jul & Aug 1984 Re Complicating Effects of earthquakes,SECY-84-70,SECY-84-291 & Drafts of Final Order CLI-84-12 & Related Documents ML20107J4551984-10-0404 October 1984 FOIA Request for Documents on Jul 1984 SER Re Operation of Facilities ML20107J8011984-09-13013 September 1984 FOIA Request for Documents Re 840612 Congressional Briefing on Facility ML20129A3601984-09-13013 September 1984 FOIA Request for Documents Generated in Connection W/Sser 22 (NUREG-0675) Re Operation of Facilities Which Provided Further Findings on Whistleblower Charges ML20117B7041984-09-13013 September 1984 FOIA Request for Documents Re Sser 26 (NUREG-0675) Concerning Operation of Diablo Canyon Plant ML20107K5221984-09-13013 September 1984 FOIA Request for Documents Re Ofc of Inspector & Auditor Rept by R Smith on Allegations of Staff Misconduct at Facility ML20213F0181984-09-0404 September 1984 Alleges That NRC Handling of Allegations Has Shifted Burden of Proof to Allegers & Posed Threat to Anonymity.Nrc Posturing Also Alleged.Recommendations for Improved Handling & Relationship Between NRC & Whistleblowers Given ML20096H4441984-09-0101 September 1984 Suggests That Yin Be Assigned as Technical Liaison to Work W/R Meeks on Investigation.Team Could Help Regain Respect & Perform Definitive Exhaustive Investigation No One Could Challenge ML20117M9621984-08-0101 August 1984 FOIA Request for Probabilistic Seismic Safety Assessment of Diablo Canyon Nuclear Power Plant & Amend 52 to FSAR ML20093N8071984-07-31031 July 1984 Forwards Suppl Supporting T O'Neill 840727 Petition Under 10CFR2.206 on Behalf of J Mcdermott & T O'Neill.Also Expands Original Request for Retraining ML20093K0901984-07-29029 July 1984 Forwards Attachment 1 to T O'Neill 840727 Petition,Omitted from Original Submittal Due to Administrative Error. Affidavits in Support of Petition Will Be Executed on 840730 ML20093K1821984-07-27027 July 1984 Submits Petition to Defer Any Further Licensing Decisions Until Effects Neutralized from Onsite Harassment & Retaliation That Have Intensified Since 840413 Low Power Testing Decision ML20090H7461984-07-25025 July 1984 Withdraws Allegations Against NRC Staff as Summarized in Rept of Interview W/Ofc of Inspector & Auditor Atty R Smith. Methodology for Investiation Obviously Designed to Predetermine Results ML20093G5751984-07-23023 July 1984 Clarifies & Suppls 840716 Petition by Requesting Public Participation in 840726 Plant Tour,Nrc Public Rept on Postponement of Util Compliance & Naemark Comments on NSC Audit ML20093E5021984-07-16016 July 1984 Petitions Commission to Take Six Listed Minimum Steps Legally Necessary to Assure Public Safety Before Issuance of Ol.Petition Submitted,Per 10CFR2.206 ML20090A8451984-07-11011 July 1984 Forwards Affidavit of T Devine Notifying of Resignation of I Yin from Review Team Overseeing Plant Readiness for Commercial Operation,As Suppl to 840503 Petition Under 10CFR2.206 ML20092N1441984-06-29029 June 1984 Extends Time Limit for Relief within 840503 Petition Filed Per 10CFR2.206 Until Date When Commission Schedules Licensing Vote on Commercial Operations.Deadline Extended Due to Large Vol of New Evidence ML20092G7121984-06-21021 June 1984 Forwards Summary of 17 Addl Witness Statements Gathered in Support of 840503 10CFR2.206 Petition to Defer Further Licensing Decisions Until Completion of Listed Tasks ML20140C6471984-06-15015 June 1984 Extends Deadline for Commission Response to Mothers for Peace 840503 Petition Per 10CFR2.206 Until 840629 1987-09-24
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GEOFFREY COWAN ADMINISTRATIVE OFFICER MARSHA M. KWALWASSER viSmNG rELLO.S LAWRENCE A. GOLOSERG October 24 I 1983 JOCElvN O. L AftMIN CvNTMI A D. 90B elNS ET M A N p. SCHULMAN BY FEDERAL EXPRESS
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Nunzio Palladino, Chairman Victor Gilinsky, Commissioner Thomas Roberts, Commissioner James Asselstine, Commissioner Frederick Bernthal, Commissioner United States Nuclear Regulatory Commission Washington, D.C. 20555 Re: In the Matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Nos. 50-2750L, 50-3R30L
Dear Chairman Palladino and Members of the Commission:
This letter is submitted on behalf of the Joint Inter-venors to the above-entitled proceeding in anticipation of the October 28, 1983 briefing scheduled by the Commission. It supplements their letter dated September 1, 1983 commenting on the Independent Design Verification Program ("IDVP") Final Report and the NRC Staff Supplemental Safety Evaluation Report
("SSER") No. 18 pertaining to reissuance of the suspended license for fuel loading and low power operation of Pacific Gas and Electric Company's ("PGandE") Diablo Canyon Nuclear Power Plant ("Diablo Canyon") , Unit 1.
The Joint Intervenors continue to believe that Commission consideration of relicensing of Diablo Canyon is premature.
Licensing hearings regarding the adequacy of Diablo Canyon's r310260236 831024 PDR ADOCK 05000275 O PDR eoano or inusicts JAwCS N. ADLES PMrLLf8 S SERRY ELiZABE TH u hoe 0Wr'Z JuDe CettumG pef gt % a vgMromTM $'twAmt L yOALL
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Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 2 design -- and, specifically, whether the verification program provides requisite assurance of such adequacy -- are scheduled to commence on October 31st. Those hearings, and the conclusions of the Appeal Board based on the evidence adduced, bear directly on the Commission's contemplated decision on relicensing. That being so, we find dismaying irideed the f act that the Commission has scheduled for October 28th a briefing to consider lifting the suspension, apparently in anticipation of a Commission vote on the matter without regard to the l
hearings which its own Appeal Board has concluded are legally required.
l Given the complexity of the disputed issues surrounding l the verification effort, and considering PGandE's checkered history in this lengthy and heavily contested proceeding, the l
Joint Intervenors believe that the adjudicatory hearing scheduled to commence in one week is the proper forum in which to develop a reliable and accurate hearing record as the basis for a licensing decision. It is, moreover, the forum in which Congress, in enacting S 189 (a) of the Atomic Energy Act, 42 U.S.C. S 2239 (a) , intended such critical disputed matters to be resolved. Particularly under the circumstances of this case, a premature decision by the Commission to relicense Diablo Canyon in disregard of the October 31st hearings would be not only unlawful but senseless.
Further, the critical issue of Diablo Canyon construction has not been addressed. The discovery within the past month and a half of a previously undisclosed and highly critical
Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 3 independent audit of PGandE's principal piping contractor conducted in 1977 has provided compelling new evidence of quality assurance deficiencies in construction activities at Diablo Canyon. Repeatedly, PGandE has assured the Commission and its Staff of its confidence in the actual construction of the plant -- the physical hardware as distinguished from the design. Even though construction and design activities were governed by the same quality assurance program under identical PGandE management, PGandE has dismissed as totally unjustified any suggestion by the Joint Intervenors or the Governor that the kinds of deficiencies now conceded by all parties to have characterized PGandE's design practices at Diablo Canyon apply to its construction practices as well.1/ The recently disclosed audit by Nuclear Services Corporation (now Quadrex) contradicts those assurances by documenting a major breakdown in the quality assurance / quality control program of one of PGandE's principal construction contractors since 1971, a breakdown l
found by the auditor to have occurred throughout the period I when Diablo Canyon was constructed (1971-1977) in a program that PGandE has proudly cited as a model of quality assurance l compliance.2 /
i 1/ The Commission should also be aware of the numerous quality assurance problems experienced in connection with recent construction activity at Diablo Canyon by the Howard P.
Foley Company, PGandE's other major construction contractor.
For example, widespread welding nonconformances have been found in the Fuel Handling Building for Units 1 and 2 (14% and 11%
rework rates, respectively), the Hot Shop (18% rework rate) ,
and the Unit 1 Containment Building (7.8% rework rate). See Letter, Schuyler (PGandE) to Martin (NRC) (August 23, 1983).
2/ See CQA Transcript, at 605 (July 21,1983) (testimony of PGandE's Diablo Canyon site quality assurance supervisor).
\ .
1 Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 4 This report has also revived concerns about PGandE's lack of candor with the NRC and the public. Despite the significance of the deficiencies found by the auditor and the fact that quality assurance has consistently been an issue of controversy before the licensing boards in this proceeding, PGandE failed to disclose the audit's existence to the NRC or its hearing boards considering the issue. Instead, it unilaterally discounted the audit based on its own disagreement with the findings and limited corrective action instituted in 1978. Apparently on that basis, it thereafter opposed any attempt to reopen the issue of quality assurance and, in fact, sponsored sworn affidavits and testimony directly contrary to the audit's conclusions. The Joint Intervenors believe that such conduct by a major public utility is inexcusable and, therefore, they applied last week to this Commission for revocation of the Diablo Canyon low power license (DPR-76) or, in the alternative, for continuation of the suspension, pending a full investigation of the matter and its implications.2/
Finally, PGandE has recently informed the NRC Staff of its intention to continue with modifications to Diablo Canyon structures, systems, and components, even after fuel loading.
By letter dated September 10, 1983, PGandE's John Hoch (for J.O. Schuyler) informed Darrell Eisenhut that the modifications listed in a five-page attachment would not be completed prior 2/ Joint Intervenors' Motion for Revocation of Facility Operating License or, in the Alternative, for Continuation of Suspension (October 20, 1983).
Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 5 to fuel load. Along with continuing modifications to the annulus steel in the Unit 1 containment building, PGandE proposes the addition, modification, replacement and calibration of new and existing equipment. Approximately 22 systems are subject to such modification, including a substantial but unspecified number of modifications to the systems inside containment. The Joint Intervenors submit that such a proposal is fundamentally inconsistent with the legal requirement that a facility be substantially constructed in accord with the Commission's regulations before a license is issued. 10 C.F.R. S 50.57.S/ Moreover, given the history of this proceeding, a decision to ignore that requirement leaves the Commission and the public vulnerable to further disclosures of errors after the fact analogous to those leading to the l
initial license suspension in November 1981.
In addition to the foregoing matters of concern as well as those discussed in the September 1, 1983 letter, the Joint Intervenors and Governor Deukmejian have raised a number of specific issues with regard to the scope and implementation of the verification program that are outlined in the contentions submitted to and accepted by the Appeal Board in the reopened design proceeding. Without reiterating here each of those A!See Letter, Reynolds to Commission, at 18-23 (September 1, 1983).
k Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 6 contentions or the testimony already filed in support of them,E/ the following are illustrative:
(1) The IDVP conclusions regarding design conformance of Diablo Canyon to the license application criteria are unjustified because based on extrapolations from samples selected through engineering judgment rather than through rigorous statistical techniques. While the NRC Order and Staff letter dated November 19, 1981 require that criteria be developed for evaluating activities of the design process, the vague and subjective standards actually applied by the IDVP undermine the objectivity and reliability of its conclusions. Because the IDVP fniled to adopt a sound statistical basis for selection of the samples, its attempt to extrapolate to structures, systems, and components that were not sampled is invalid.
E! The contentions of the Joint Intervenors and Governor Deukmejian are attached hereto as Exhibit 1. In addition, the testimony of Richard B. Hubbard, quality assurance consultant to Governor Deukmejian, is attached hereto as Exhibit 2 as an example of the detailed concerns that both the Joint Intervenors and the Governor continue to have with regard to the verification program. Other witnesses testifying on behalf of the Governor include Dr. Jose Roesset, Professor of Civil Engineering at the University of Texas at Austin, and Dr.
George Apostolakis, Professor of Engineering and Applied Science at the University of California, Los Angeles.
Witnesses testifying on behalf of the Joint Intervenors include Dr. Francisco Samaniego, Professor of Statistics and Assistant Vice Chancellor for Academic Affairs at the University of California, Davis, and Dr. Peter Kempthorne, Assistant Professor of Statistics at Harvard University.
k Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 7 Hence, the assurance provided by the IDVP is limited to only those structures, systems and components actually verified. Indeed, even the statistician retained by PGandE has conceded that the probabilities of a Class A or B etior5/ in the unsampled portions of the nonseismic design are "quite high, 90 percent or something."2/ Such a high probability of error is inconsistent with the IDVP's finding of reasonable assurance that Diablo Canyon is properly designed.E/
(2) The verification program has failed to verify that Diablo Canyon, Units 1 and 2 "as-built" conform to the design drawings and analyses. Various reviewers of PGandE's design control practices for its pre-November 1981 design activities found numerous examples where the as-built Diablo Canyon plant failed to conform to the design documents.EI However, the IDVP's recent review of 5! A " Class A or B error" is defined by the IDVP to include those errors for which design criteria or operating limits of safety related equipment were exceeded. IDVP Final Report, at Appendix F.
2/ Deposition of Stanley Kaplan, at 135-36 (September 26, 1983).
E/ See generally, Testimony of Kempthorne and Samaniego; Testimony of Apostolakis.
E/ See, e.g., NRC Bulletin 79-14 Review for Diablo Canyon; Brookhaven National Laboratory, " Independent Seismic Evaluation of the Diablo Canyon Unit 1 Containment Annulus Structure and Selected Piping Systems" (July 1982); Institute of Nuclear Power Operations, Report (February 12, 1983).
Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 8 a sample of design documents resulting from the Diablo Canyon Project's ("DCP") post-November 1981 corrective action program identified a number of instances where the as-built plant differed from the design documents.
Although EOIs were issued for some af these (1120, 1121, 1123, 1124, 1133, 1135, 1137), a large number of such discrepancies were (for reasons not explained by the IDVP) never made the subject of an EOI. Examples of these undocumented configuration control discrepancies in design documents involved differences in pipe weight, piping geometry, support modeling, valve modeling, support locations, and miscellaneous other design discrepancies.
According to Richard Hubbard, Quality Assurance / Quality Control consultant to Governor Deukmejian:
The IDVP's reviews to date of a sample of the product (the design documents) result-ing from the quality assurance / quality control process of the DCP's corrective action measures demonstrate to me that con-figuration control deficiencies continue to exist at Diablo Canyon. Such configuration differences between the as-built plant and the design documents are, in my judgment, contrary criteria dix B:
to the [ requirements of Appen 1S/
3, 6, 10, 11, and 16.]
AS/ Hubbard Testimony, at 17-18.
L Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 9 (3) The verification program failed to verify that the design of safety related equipment supplied to PGandE by Westinghouse meet licensing criteria. Although Westinghouse was the responsible design organization for over 70% of the Diablo Canyon safety-related systems, neither the IDVP nor the ITP conducted a systematic verification of the design of Westinghouse-supplied NSSS equipment or design services. Instead, the IDVP conducted only a limited review of the Westinghouse-PGandE design interface. Even in this limited review, however, errors were disclosed in 30% of the Westinghouse samples examined by the IDVP. On this basis, BNL questioned whether the sample was adequate to verify the Westinghouse qualification spectra. Therefore, because the IDVP samples of other design service contractors cannot be extended to provide meaningful conclusions as to the adequacy of the NSSS equipment or the Westinghouse design services, a thorough review of the Westinghouse design work is necessary.11!
(4) The verification program failed to identify the root causes for the failures in the PGandE design quality assurance program or to determine if such failures raise generic concerns. Although the IDVP provided a general statement regarding basic cause for the errors identified, in no case did the IDVP or the ITP correlate the basic causes cited to the identified errors as is required by 11/ Id. at 20-24.
Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 10 Criterion 16 of Appendix B to 10 C.F.R. Part 50.12/ As a result, the basic quality assurance failures leading to the individual errors were not determined and, further, potential generic concerns were either not raised or were only partially addressed.
(5) PGandE has failed to establish and implement a quality assurance program for its corrective action work adequate to ensure that all Appendix B requirements are satisfied and that the Diablo Canyon facility will meet licensing criteria. Even in the IDVP's limited review of the corrective actions instituted since November 1981, a substantial number of errors that should have been prevented by an adequate PGandE quality assurance program have been found by the IDVP. Some of these errors have been documented by an EOI; others have not. In any case, according to Mr. Hubbard, these errors lead to the following conclusions:
The results of the IDVP design product verification, as well as its design process audits, demonstrate that the ITP failed to satisfactorily execute a design quality assurance program for the design modifications developed since November 1, 1981. The results further indicate that, contrary to the requirements of Criteria 1 and 2 of Appendix B, the DCP failed to establish and execute a design quality assurance program. Further, contrary to 12/ For examples of specific EOIs for which the basic cause was not determined, see Hubbard Testimony, at 28-38.
k Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 11 Criterion 3, the DCP's design control measures failed to assure that the Diablo Canyon design criteria were correctly translated into design documents. Indeed, the errors and potential errors . . .
demonstrate that the DCP QA program failed to adequately implement the required audits and corrective action measures contrary to Criteria 18 and 16 of Appendix B. . . .
Given the demonstrated number and nature of the errors disclosed in the IDVP's review of a sample of the Corrective Action Program, in my judgment it is reasonable to conclude that further critical errors (Class A or B) exist in the design of the plant which can only be uncovered by a rigorous and thorough verification program.
Further, the cumulative impact of the major errors (Class C) when coupled with the critical errors indicate the necessity for further verification of the post-November 1, 1981 design activites.
(6) The verification program has failed to verify fully the adequacy of the seismic redesign. Although the attached contention sets forth a list of detailed concerns, Dr. Jose Roesset has identified four principal issues that require further verification:
l
--The effect of possible uplift of the mat of the containment building on vertical accelerations and the design of the equipment.
--The ability of the walls of the auxiliary building at elevation 100 feet to carry the increased forces that might result from considering a fixed base at elevations 85 feet and 100 feet, neglecting
Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 12 the soil structure interaction effects (considering the springs at elevation 100 feet to be rigid).
--the adequacy of the rotational springs used to model the columns in the vertical analysis of the slabs of the auxiliary building in relation to the size of the finite elements.
--The adequacy of the soils work performed by HLA in relation to the deter-mination of rock and soil properties, vari-ationofthesepropertieswithdepthggp their variation with level of strain.--
Each of the matters described briefly above relates directly to issues being considered by this Commission at the October 28th briefing: whether Diablo Canyon has been designed consistent with the Commission's regulations and PGandE's licensing commitments. The appropriate forum in which to
- resolve those issues is the hearing on design scheduled to commence on October 31st. Neither the public interest in safety nor the Commission's interest in avoiding further l
" surprises" would be served by a premature decision to l
reinstate the license based on an inadequate record.
12! Testimony of Jose Roesset, at 25-26.
Members of the U.S. Nuclear Regulatory Commission October 24, 1983 Page 13 Common sense, fairness, and applicable law dictate that the Commission stay its hand pending completion of the scheduled hearings and resolution of the matters discussed above. For all these reasons, the Joint Intervenors oppose reissuance of the suspended license at this time.
Very truly yours, JOEL R. REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
ERIC HAVIAN, ESQ.
Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESO.
P. O. Box 1178 Oklahoma City, OK 73101 By %
DEL R]$0LDS Attorneys for Joint Inter-venors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER JR:cc cc: Diablo Canyon Service List
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