ML20081B196
| ML20081B196 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/24/1983 |
| From: | JOINT INTERVENORS - DIABLO CANYON |
| To: | |
| Shared Package | |
| ML20081B195 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8310270361 | |
| Download: ML20081B196 (7) | |
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NUCLEAR REGULATORY COMMISSION U 1RC BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
'83 00T 26 P3:29 In the Matter of
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Docket Nos. 50~-2tl$ dIL'.
PACIFIC GAS AND ELECTRIC COMPANY
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50-323 0.L.
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(Diablo Canyon Nuclear Project,
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Units 1 and 2)
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ISSUES TO BE CONTESTED BY GOVERNOR DEUKMEJIAN AND JOINT INTERVENORS October 24, 1983 1.
The scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures and components (SS&C's) was too narrow in the following aspects:
(a)
The IDVP did not verify samples from each design activity (seismic and non-seismic).
(b)
In the design activities the IDVP did review, it did not verify samples from each of the design groups in the design chain performing the design activity.
(c)
The IDVP did not have statistically valid samples from which to draw conclusions.
(d)
The IDVP failed to verify independently the analyses but merely checked data of inputs to models used by PG&E.
(e)
The IDVP failed to verify the design of Unit 2.
2.
The scope of the ITP review of both the seismic and l
non-seismic aspects of the designs of the safety-related systems, structures and components (SS&C's) was too narrow in the following aspects:
(a)
The ITP did not verify samples from each design activity (seismic and non-seismic).
(b)
In the design activities the ITP did review, it did not verify samples from each of the design groups in the design chain performing the design activity.
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8310270361 831024 PDR ADOCK 05000375 G
O (c)
The ITP did not have statistically valid samplcs from which to draw conclusions.
(d)
The ITP has failed systematically to verify the adequacy of the design of Unit 2.
3.
In various situations listed below, the ITP used improper engineering standards to determine whether design activities met license criteria.
In some of these situations, the IDVP either used or approved the use of such improper standards or did not verify them at all.
j (f)
The ITP's modeling of the soil properties for the j
containment and auxiliary buildings was improper in that:
(i) in the soil structure interaction analysis of containment for the DE and the DDE, use of boundary motion inputs to the model were improperly used; (ii) the soil structure interaction analysis for 1
containment for the DE and the DDE uses a 7 percent damping value for rock, which is unconservative, especially for the DE; (iii) the dynamic analyses of the containment for all earthquakes omit any analysis of uplifting of the foundation mat; (iv) the modeling of the soil springs for the auxiliary building does not specify soil properties; (v) in the modeling of the soil springs for the auxiliary building, the motion inputs to the lower ends of the springs does not account for all soil structure interaction phenomena that could be expected.
(o)
The ITP has not demonstrated, and the IDVP has not verified, that the DCP modeling of the seismic response of 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.
l (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 2.
inplane flexibility of these slabs, and has not adequately demonstrated that stresses are within allowable limits at all elevations.
(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.
(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.
(s)
The ITP has not demonstrated and the IDVP has not
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verified that the seismic analysis of the turbine building is proper in that bolt bearing capacities were taken from an inappropriate source.
(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.
4.
The 1DVP accepted deviations from the licensing criteria without providing adequate engineering justification in
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-the following respects:
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a.
Contrary to the requirements of FSAR Section 17.1 I
regarding compliance of the as-built installation with the design documents, the IDVP review of the AFWS disclosed that the as-built installation failed to meet the design drawings in that (i) a steam trap on the turbine-driven AFW pump steam supply line is not provided and (ii) there are discrepancies in the arrangement of the long-term cooling water supply line.
b.
Contrary to FSAR Section 8.3.3, the electrical design does not fully comply with the commitments regarding separation and color coding.
c.
Contrary to the single failure criterion of Appendix A to 10 C.F.R. Part 50, a single failure may cause loss of redundant power divisions because redundant electric power division trains are l
electrically interconnected through two circuit breakers and a single power transfer switch.
3.
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d.
Contrary to GDC 57 of Appendix A, valve operators for the isolation valves which provide the steam supply to the turbine-driven auxiliary feed pump from two of the main steam generators have not been classified and procured as safety-related components.
The single failure of an auxiliary relay would e.
prevent automatic closure of the redundant steam generator blowdown isolation valves on automatic initiation of the AFWS contrary to a Westinghouse interface requirement and FSAR Figure 7.2-1.
f.
Contrary to NUREG 0588 regarding environmental qualifications, flow transmitter FT-78 and flow control valve FCV-95 are located in a harsh
' environment but were not listed as such in the PG&E Environmental Qualification Report dated September 1981, and are not yet environmentally qualified.
g.
Contrary to the requirements of NUREG 0588 regarding environmental qualifications, portions of the CRVPS were omitted from PG&E's Environmental Qualification Report.
h.
Contrary to PG&E's September 14 and December 28, 1978, licensing commitments, CRVPS equipment identified in the FSAR as necessary to maintain control room habitability during safe shutdown has not been evaluated regarding the effects of a moderate energy pipe break.
i.
The fire protection for the motor driven AFW pump room is not consistent with the PG&E licensing commitment for fire zone separation as stated in its November 13, 1978, Supplemental Information for Fire Protection Review ("SIFPR") in that:
1) there is a large grated ventilation opening in the ceiling of the room; j
2) a fire damper has gaps when it is closed.
j.
The fire protection for the AFW pump room is not consistent with the PG&E licensing commitment for cable separation as stated in its SIFPR of November 13, 1978, in that:
1) the pumps for the motor driven AFW pumps and the control circuitry for a flow control valve necessary for operation of the turbine driven AFW pump are located in a single fire zone; 4.
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2) cables for some APW circuits are not routed in accord with descriptions in the SIFPR and four AFW circuits PG&E committed to identify and review in the SIFPR were not included in that document.
k.
Contrary to the licensing commitment set forth in its SIFPR of November 13, 1978, each of the three 4160 volt cable spreading rooms has a ventilation opening leading up to the 4160' volt switchgear rooms.
l 1.
Contrary to "FSAR Section 3.6, possible jet i
impingement loads have not been considered in the design and qualification of safety-related piping and equipment inside containment.
m.
Contrary to QA program commitments in FSAR Section 17.1, documented evidence is inadequate to demonstrate that rupture restraints outside and inside containment have been properly designed and installed to provide protection against rupture in high pressure piping, n.
For the containment exterior shell review the ITP review used the AISC Code rather than Section III of the ASME Code contrary to the commitment in Table 3.2-4 of the FSAR.
o.
Contrary to the requirements of NUPEG-0588 regarding environmental qualifications, safety-related cables and cable splices which could be subject to a harsh environment during a high-energy line break are not identified in the PG&E Environmental Qualification Report.
p.
The NSC pipe break analysis, which is Appendix A to FSAR Section 3.6, did not include all likely sources of water in the calculation of flooding l
levels.
q.
Contrary to PG&E's December 28, 1979, licensing i
commitment letter to the NRC, modifications to protect two Auxiliary Feedwater valves from the effects of moderate energy line breaks were not implemented.
C ntrary to the licensing commitment to maintain r.
o minimum system redundancy as stated in FSAR Section 3.6A (NSC evaluation of pipe break outside containment), four components were identified for 5.
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r which high energy line cracks could cause temperatures in excess of the specification temperatures of the components.
t s.
Contrary to the licensing commitment to maintain sinimum system redundancy as stated in FSAR Section 3.6A (NSC evaluation of pipe break outside containment), a conduit was identified whose failure due to a high energy line crack could eliminate redundant Auxiliary Feedwater system flow.
l t.
Contrary to the FSAR Section 8.3 commitment to provide switchgear buses with adequate short circuit interrupting capability, the calculated duties for circuit breakers on 4160 V buses F, G, and H were above the nameplate ratings for those buses.
u.
Contrary to single failure criteria stated in FSAR Section 3.1.1, reviews of the Auxiliary Feedwater and Control Room Ventilation and Pressurization systems identified circuit separation and single failure deficiencies.
Similar deficiencies were identified in additional verification reviews, j
which included other safety-related systems.
5.
The verification program has not verified that Diablo Canyon Units 1 and 2 "as built" conform to the design drawings and analyses.
6.
The verification program failed to verify that the design of safety-related equipment supplied to PG&E by Westinghouse met licensing criteria, 7.
The verification program failed to identify the root causes for the failures in the PG&E design quality assurance program and failed to determine if such failures raise generic concerns.
1 8.
The ITP failed to develop and implement in a timely manner a design quality assurance program in accordance with 10 C.F.R. Part 50, Appendix B to assure the quality of the recent design modifications to the Diablo Canyon facility and the IDVP failed to ensure that the corrective and preventative action programs implemented by the ITP are sufficient to assure that the Diablo Canyon facilities will meet licensing criteria.
9.
Contrary to General Design Criteria 44 (GDC-44) of Appendiz A to 10 C.F.R. Part 50, PG&E has failed to provide adequate assurance of component cooling water system (CCWS) heat 6.
removal safety function capacity in that the maximum ocean water temperative of 64 degrees 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 safety as compliance with the requirements of GDC-44 (SSER 16 (Aug.1983) and September 1983 ocean water temperature readings).
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