ML20098F098
| ML20098F098 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/28/1984 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | |
| References | |
| CON-#484-158 OL, NUDOCS 8410020313 | |
| Download: ML20098F098 (27) | |
Text
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UNITED STATES OF AMERICA M N TED W
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 1 l q
q.,
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COWANY
)
Docket Nos. 50-275 6 L
)
50-323 o L (Diablo Canyon Power Plant
)
Units 1 and 2)
)
)
PACIFIC GAS AND ELECTRIC COWANY'S RESPONSE TO APPEAL BOARD ORDER OF SEPTEMBER 10, 1984 The Appeal Board, by its order of September 10, 1984, has requested the parties to this proceeding to provide the Board with their " views" as to how the Board should proceed with respect to Diablo Canyon Unit 2.
Pacific Gas and Electric Company, for the reasons set forth infra, submits that sufficient evidence exists in the record for the Board to issue its decision as to the adequacy of the design of Unit 2 of the Diablo Canyon Nuclear Power Plant upon the issuance of the Staff's SSER on that subject. The parties to this action have had ample opportunity to raise any issues or contentions regarding Unit 2.
Of the thirty-nine issues litigated in the so called design quality assurance (DQA) hearings of October-November 1983, the vast majority related to both units and three were unique to Unit 2 (Contentions 1(e), 2(d), and 5).E 1.
Of the thirty-nine issues in the DQA hearings, the joint intervenors and Governor both failed to file proposed findings on sixteen issues, including 2(d), and, in addition, the joint intervenors failed to file proposed findings on one issue the Governor abandoned in his proposed findings, leaving twenty-two issues for decision by the Board.
In the matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units I and E) ALAB-763, NRC
, slip op, at 9-10, March 20,1984.
8410020313 840928 PDR ADOCK 05000275 0
PDR 3S03 2410d _
As shown in the following memoranduin of Points and Authorities and the affidavits attached hereto,2_/ the existing record is sufficient to resolve the issues litigated in the DQA hearings as they relate to Unit 2.
EMORANDUM OF POINTS AND AUTHORITIES I
FACTS Structures Diablo Canyon Units 1 and 2 are nearly identical, mirror-image plants.
The Class I structures are either common, essentially identical, or basically the same but with variation enough to require separate analysis.
Those structures that are conr.on are the intake structure and the auxiliary building including the fuel handling building.
All of the conmon structures were reviewed by the IDVP.
The structures that are essentially identical (the same analysis applies to both) are the containment shells, containment concrete interiors, and Class I outdoor storage tanks and buried diesel fuel oil tanks.
The criteria, methodology, and analyses of the identical structures were reviewed by the IDVP. The structures that were basically the sane, but analyzed separately, were the annulus structures and the two halves of the turbine building.
The criteria and methodology for these similar structures were the same for bc;h units, and the IDVP reviewed the criteria, methodology, and analyses for the annulus of Unit I and the Unit I side of the turbine building.
(White affidavit, Attachment 1. )
2.
References in the memorandum of Points and Authorities are either to the record or to the attached affidavits which reference the record.
2410d s
Systems and Components The mechanical, electrical, HVAC, and instrumentation and control systems in Unit 2 are the same as the systems used in Unit 1.
The basic system functions, criteria, design, and nethodologies are identical between units.
(Connell-Vahlstrom affidavit, Attachment 2.) The components are either common to both units or essentially identical for Units 1 and 2.
Anderson et al.,
f f. Tr. D-224, at 28.
Piping and Supports The piping arrangement is essentially the same for both units.
- However, because of the mirror image arrangement of the two units, separate analyses and support designs were perfomed for each unit. These analyses and designs were based on the same criteria, methodology, design process and procedures 'in Unit 2 as were used for Unit 1.
(Shipley affidavit, Attachment 3. )
The IDVP reviewed and found acceptable the criteria, methodology, design i
process and procedures used for piping in Unit 1.
(ITRs 59, 60, and 61 in evidence as Exhibits 149,150, and 18il. )
i Quality Assurance and As-Builts The as-built process for Units 1 and 2 at Diablo Canyon was the same.
(Moore-Cranston affidavit, Attachment 4.) The Quality Assurance program at Diablo Canyon was, for all material purposes, the same for Unit 2 as for Unit 1.
(Jacobson-de Uriarte affidavit, Attachment 5.)
2410d..
6-Internal Technical Program (ITP)
To check the applicability of the Unit 1 IDVP design verification to Unit 2, the Diablo Canyon Project (DCP) established an internal procedure.
( Anderson et al., f f. Tr. D-224, at 29; Moore, Tr. P-385. ) Under that procedure, any Unit 1 finding that was found not applicable to Unit 2 was documented and the basis for this decision provided.
If the finding applied to both Units 1 and 2, a determination was made as to whether the Unit I resolution also applied.
In cases where the Unit 1 resolution applied to the Unit 2 design, procedures were in place to ensure that the resolution was implemented for Unit 2.
If a finding deemed applicable to Unit 2 involved physical modifications to the plant, the appropriate design change document was issued to PGandE's General Construction Department for implementation on Unit 2.
( Anderson et al., ff.
Tr. D-224, at 29-30; Cranston, Tr. D-384-85. )
If the substance of the ITP or IDVP review item was not identical for both units, the DCP evaluated and l
l documented the differences and the applicability to Unit 2.
A determination r
was made as to whether the item required resolution for Unit 2, and the effect i
of the differing resolution of the review item on Unit 2 was evaluated and documented. Before implementing the Unit 2 resolution, the Unit 2 Project
[
Engineeririg group reviewed the resolution to establish or confirm that it was consistent with licensing criteria and that appropriate action was taken to ensure that the Unit 2 requirements were satisfied.
( Anderson et al., ff.
Tr. D-224, at 30; Cranston, Tr. D-384-85. )
l l
2410d..--
Both the ITP and IDVP reviewed and verified plant design.
The two review efforts were independent of each other insofar as they were conducted by different organizations under strict and carefully administered procedures, and because each used its own technical methodology.
Each review effort was in and of itself sufficiently comprehensive to provide reasonable assurance that licensing criteria have been satisfied and that the plant can be operated sa fely. Beyond the ITP's design review efforts, it performed additional functions that were interrelated with the IDVP review.
The ITP provided data, analyses and other information requested by the IDVP and responded to all findings of the IDVP.
The ITP implemented all corrective actions in response to both its own findings and those of the IDVP.
The two programs were further interrelated because the IDVP verified two major aspects of the ITP:
the technical validity of the corrective action process and the ITP's compliance with a quality assurance program meeting 10 CFR 50, Appendix 8.
(Anderson et al., ff. Tr. D-224, at 3-4. )
Unit 2 Schedule Unit 2 is currently undergoing hot functional testing and is expected to be ready for fuel load by mid-December.
(Friend affidavit, Attachment 6. )
2410d --
II ARGUMENT The twenty-two issues decided by this Board in ALAB-763 were comprised of nine basic contentions with, in some cases, subissues.
Those issues were:
1(a )
through (e), five issues dealing with the adequacy of the IDVP; 2(a) through (c), three issues dealing with the adequacy of the ITP; 3(f)(iii), (iv), (v);
(o), (q) and (r), six issues dealing with the adequacy of seismic analyses; 4(i)(1), (1), and (t), three issues dealing with the adequacy of non-seismic system analyses; 5, dealing with Unit 1 and 2 as-builts; 6, dealing with the adequacy of Westinghouse design; 7, dealing with root causes of quality assurance deficiencies; 8, decling with the ITP's quality assurance program and 9, dealing with the component cooling water system (CCWS).
The five issues under contention 1 dealt with the adequacy of the IDVP.
Issue 1(e), directed solely at Unit 2, alleged that the IDVP did not verify the design of Unit 2.
While the IDVP efforts were indeed directed at Unit 1, those efforts, by parity of reasoning, do verify the design of Unit 2.
As set forth supra at 1-2, the IDVP verified the design criteria, methodologies, processes, procedures, and analyses for Unit 1.
The same design criteria, methodologies, processes, and procedures were used for Unit 2 structures, systems, and components.
Therefore, the IDVP did indeed verify the design criteria, methodologies, processes, and procedures for Unit 2.
What they did not do on Unit 2 that they did on Unit 1 was to check, by sampling, final analyses.
2410d
-6
m The joint intervenors and Governor abandoned one of the three issues which was unique to Unit 2 in the DQA hearing, namely contention 2(d).2/ That contention alleged:
2.
The scope of the ITP review of both the seismic and non-seismic aspects of the designs of the safety-related systems, structures and components (SSAC's) was too narrow in the following respects:
(d) The ITP has failed systematically to verify the adequacy of the design of Unit 2.
It is respectfully submitted that the ITP did systematically verify the adequacy of the design of Unit 2.
Even though this Board made no such finding in ALAB-763, there was uncontroverted testimony as to how the systematic verification of the Unit 2 design had been and was continuing to take place.
( Anderson et al., ff. Tr. D-224, at 28-30; Shipley, Tr. D-387-88, 393-94; Anderson, Tr. D-1426; Moore, Tr. D-385, 388; Cranston, Tr. D-384-85. ) That verification is now nearly complete.
The six issues under contention 3 dealt with seismic issues.
Five of the six issues (3(f)(iv), (v), (o), (q), and (r)) dealt with structures which are common to both units.
Those structures are the auxiliary building (3(f)(iv) and (v)), the fuel handling building (3(o)), the buried diesel oil tanks (3(q)), and the intake (3(r)). The sixth issue, 3(f)(fii), dealt with containment tilting. As set forth supra at 2, the containment structures are essentially identical, and the same analysis applies to both units.
3.
See footnote 1, supra, p.1 2410d 4:
The three issues under Contention 4 were concerned with non seismic systems Ar.al :? t.
Specifically, those issues dealt with the auxiliary feedwater (AFW) f pump room (4(i)(1)), jet impingement analyses (4(1)), and 4160 V Das circuit breakers (4(t)). The resolution of these issues was reviewed and approved by the IDVP in ITRs 18, 48, and 24, respectively.
App. Ex.110,140, and 116.
Pursuant to established procedure, these resolutions were applied to Unit 2.
( Anderson et al., ff. Tr. D-224, at 29-30. ) This Board ordered the Licensee to analyze three lines for Unit I which had not been analyzed as part of the ITP jet impingement analyses.
The analyses for Unit I were completed and reported to the NRC on April 9,1984.
The analyses for the same three lines in Unit 2 have also been completed and no modifications were indicated.
(Connell-Yahlstrom affidavit, Attachment 2.)
Contention 5 alleged that the verification program has not verified that Diablo Canyon Units 1 and 2 "as built" conform to the design drawings and analyses.
This Board found, inter alia, that both the IDVP and ITP verified that the plant, as analyzed, is in conformity with the plant, as built, with respect to both its seismic and nonseismic design.
(ALAB-763 at 71-73.)
The as-built document process was verified by the IDVP.
(Id. at 74-75.) The as-built process was, in all material respects, identical for Units 1 and 2.
(Moore-Cranston affidavit, Attachment 4. )
I a
2410d..-
Contention 6 charged that the design of the Westinghouse-supplied safety-related equipment was not verified as having met licensing criteria.
I This contention was not particularized as to unit, and, not surprisingly, none of the evidence received on the subject was particularized as to unit. This Board held that there was no basis to find that the verification effort was flawed by its exclusion of Westinghouse-supplied equipment and that reliance upon the Westinghouse quality assurance program was reasonable.
(ALAB-763 at 77-82. ) Reference to the record makes it clear that the Westinghouse quality assurance program applied equally to Units 1 and 2.
(Kreh et al., f f.
Tr. D-1088, at 1-5. )
In Contention 7 it was claimed that the verification program failed to identify root causes of deficiencies in Pacific Gas and Electric Company's quality assurance program. As with Contentions 6, 8, and 9, this contention was not directed at either Unit 1 or 2, but at the totality of the project.
Again, by parity of reasoning, tha Board's finding that the causes for the failures of the quality assurance program and the evaluation of those errors for generic concerns had been sufficiently addressed by the verification program is equally applicable to Units 1 or 2.
(ALAB-763 at 87.) A review of the record shows that the issue of root causes was not unique to separate units.
(de Uriarte et al., ff. Tr. D-847, at 1 et seq.; Reedy, et al., f f.
Tr. D-1459, at 7-1 et seq.; Knight et al., f f. Tr. D-2906, at 1 et seq. )
2410d.-
,4?
Contention 8 maintained that the ITP failed to timely develop and implement an adequate QA program. This Board found that the ITP's quality assurance program governing the verification program was adequate.
(ALAB-763 at 98. )
The QA program for Units 1 and 2 was, in all material respects, the same.
(Jacobson affidavit, Attachment 5.) All elements of the QA program were applied to the Unit.2 design efforts, and an audit of the Unit 2 internal review of Unit i verification program results found that the program was being effectively implemented.
(de Uriarte et al., ff. Tr. D-847, at 24. )
Contention 9 maintained that there was no adequate assurance that the CCWS's heat removal capacity was not sufficient, even with a technical specification limitation, to comply with GDC-44.
As stated previot. sly, this contention was never thought of as applyin,; to one unit or the other.
The reason for this is i
obvious.
The CCWSs for the two units are essentially identical and the same design criteria, methodology, and procedures apply to both.
(Connell
~ affidavit, Attachment 7. ) The Board's finding that the applicant's technical shecification is sufficient to meet the requirements of GDC-44 is equally
!~
applicable to both Units 1 and'2.
III CONCLUSION tre is more than sufficient eviden e in the record to pemit this Board to conclude that the design of Unit 2 is adequate upon submittal by the Staff of
,. ~i 1
,4
,1 2410d '
its SSER on Unit 2.
The structures, systems, and components of the two units are either common, identical, or similar so that the same design criteria and methodology apply to both.
The IDVP efforts and findings on Unit 1 are directly transferable to Unit 2 and the ITP systematically verified the design of Unit 2 and transferred all lessons learned from Unit 1.
It is respectfully submitted that this Board should, on the record as it now exists, issue its finding that the design of Unit 2 is adequate.
Dated:
September 28, 1984 Respectfully submitted, RGBERT GHLBACH PHILIP A. CRANE, JR.
RICHARD F. LOCKE DAN G. LUBBOCK Pacific Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120 (415) 781-4211 ARTHUR C. GEHR Snell & Wilmer 3100 Valley Center Phoenix, AZ 85073 (602) 257-7288 BRUCE NORTON THOMAS A. SCARDUZIO, JR.
Norton, Burke, Berry & French, P.C.
P.O. Box 105G9 Phoenix, AZ 85064 (602) 955-2446 Attorneys for Pacific Gas and Electric Company S
Dated:
September 28, 1984 By uM lbyt4h Bruce Norton 2410d., _ -
h55[l3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ili
[il't I R1 :7d BEFORE THE ATOMIC SAFETY ANP LICENSING APPEAL BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COW ANY
)
Docket Nos. 50-275
)
50-323 (Diablo Canyon Power Plant
)
Units 1 and 2)
)
I AFFIDAVIT OF E. C. CONNELL, III STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO )
The above being duly sworn, deposes and says:
I, Edward C. Connell, III, am the Mechanical Group Supervisor for the Diablo Canyon Project. My qualifications have been previously submitted before this Board in the 1983 Design Quality Assurance hearings.
- Connell, III, et al., f f. Tr. D-487.
The Unit 2 CCW system is the same as that provided for Unit 1 in all significant respects and is designed to the same criteria es used for the I
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Unit 1 CCW system. FSAR, App. Exc. 5, Section 9.2, Tr. 3456, LPB 79-26, 10 NRC 453, 459 (1979).
Dated:
September 28, 1984 6 bo
[
E. C. CONNELL, III Subscribed and sworn to before me this 28th day of September,1984, i ma'a'aaaaaaaaaaaaaas aaaaa'aaaat C. T. NEAL MADISON i
@ NOTOY PTUC -CALIFOltN Cli f V COUNTY OF SAN FRANCISCO My Commimon tapwes Du. 27,1985 i i.uunnunun.u.un.w.n.un.u.uun.nunu.e CT Ned h&
cynthia Neal-Madison Notary Public in and for the City and County of San Francisco State of California My ccmnission expires December 27, 1985 00MA.
UNITED STATES OF AERIC *.
NUCLEAR REGULATORY COMMISSIDH Occure Uh,k BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOAPD l
E GUI -j m 3,,
In the Matter of
)
~ '-
)
PACIFIC GAS AND ELECTRIC COWANY
)
Docket Nos. 50-275
~
)
50-323 (Diablo. Canyon Power Plant
)
Units 1 and 2).
)
)
AFFIDAVIT OF E. C. CONNELL AND W. VAHLSTROM STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO )
The above being duly sworn, depose and say:
I, Edward C. Connell III, am a Hechanical Group Supervisor for the Diablo
. Canyon Project. My qualifications have been previously. submitted before this Board in the 1983 Design Quality Assurance hearings.
Connell, III, et al.,
ff. Tr. D-487.
I, Wallace Vahlstrom, am the Senior Electrical Engineer for the Diablo Canyon. Project.
1.
The Mechanical, Electrical, Instrumentation and Control (IAC) and HVAC systems in Unit 2 are the same as the systems used on Unit 1.
The basic system functions, criteria, design and methodologies are identical
- between units. Anderson et al., ff. Tr. D-224 at 28-29, 2.
Nearly all of the safety related Mechanical, Instrumentation, HVAC and Electrical equipment in Unit 2 is identical and interchageable with the corresponding equipment in Unit 1.
Anderson et al., ff. Tr. D-224 at 28-29.
The Unit 2 reactor has a slightly higher themal output rating than the Unit i reactor: however, the physical differences between reactors are very minor. App. Ex. 5, Section 1.1, Tr. 3456, LPB-79-26, 0311M
-I-
_.,.. - -.... _ _. _ _ _ _ _., _..._.._ _ - _. _ _ _.. _.. _. _. _ _._.~._._. _.- _
10 NRC 453, 459 (1979). All of the accident analyses that are dependent upon reactor parameters were t,ased on Unit 1 or Unit 2 parameters as appropriate to give the bounding case. App. Ex. 5, Chapter 15 Tr. 3456, LPB-79-26,10 NRC 453, 459 (1979).
3.
The seismic and environmental qualification for equipment was done using the same criteria and methods.
Anderson et al., ff. Tr. D-224 at 29.
4.
In the completion and verification for Unit 2, every issue that was reviewed, aodressed, or verified for Unit 1 was (or is being) also reviewed, addressed, or verified and, thcreby, fully resolved for Unit 2.
Anderson et al., ff. Tr. D-224 at 5-7, 28-30 5.
In response to Contention 4(1), the Board ordered Licensee to analyze three lines of Unit 1 which had not been analyzed as part of the ITP jet impingement analyses.
The analysis for Unit 1 was completed and reported to the HP.C on April 9,1984 (Exhibit A) and the analysis for the same three lines for Unit 2 have been completed.
No modifications are indicated to be necessary.
Dated: Saptember 28, 1984
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E. C. CONNELL, III W. V.WiL5TROM Subscribed and sworn to before me this 28th day C. T. NEAL MADISON l
of September' 1984*
EP.'? "PilC - CALIFORNIA s 1..
"...D CoutJTY OF h.[. h-b/h Ian.ummun$if.S.NnN.NnIubn.fr SAN FRAf4CISc0 Cynthic Neal-Madison Notary Public in and for the l.
City and County of San Francisco State of California l
My commission expires December _ 27, 1985 l
L MfRE C;FIElED
.m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'M i;!!i -l f!175 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD n
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275
)
50-323 (Diablo Canyon Power Plant
)
Units 1 and 2)
)
)
AFFIDAVIT OF H. B. FRIEND STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO )
l The abobc being duly sworn, deposes and says:
I I, Howard B. Friend, am the Project Completion Manager for the Diablo Canyon Project. As such, I am knowledgeable of the schedules for Unit 2.
My qualifications have been previously submitted before this Board as a portion of PGandE's Answer dated liarch 6,1984, in Opposition to Joint Intervenors' Motion to Augment or in the Alternative, to Reopen the Record, i
(1) The Unit 2 schedule for fuel load is November 26, 1984.
Hot functional testing is in progress and is proceeding satisfactorily.
l 0065A.
(2) Overall, testing and plant completion activities are 2-3 weeks behind schedule, which, at this time, makes fuel load likely by mid-December.
Dated:
September 28, 1984 H. B. (
ND Subscribed and sworn to before me this 28th day
,,,,,,,,,,,,,,,,,,,,C.T. NEAL M ADISON,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,!
of September,1984.
N0i?.Y P'J:LIC -CALIFORNIA E CITi A;O COUNTY OF.
SAN FRANCISCO M C.memon Empires Dn. 27,1985 =
...r........................
Cynthia Neal-Madison Notary Public in and for the City and County of San Francisco State of California My comission expires December 27, 1985 l
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0065A
f UNITED STATES OF APERIC A M((
NUCLEAR REGULATORY COMMISSION BEF0PE THE ATOMIC SAFETY AND LICENSING APPFAL BOAFB G; -1 f!] 25 In the Matter of
)
)
PACIFIC GAS AND ELECTRIC C0ffANY
)
Docket Hos. 50-275
)
50-323 (Diablo Canyon Power Plant
)
Units 1 and 2)
)
)
AFFIDAVIT OF M. J. JACOBSON AND T. G. de URIARTE STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO )
The above being duly sworn, depose and say:
I, M. J. Jacobson, am the Project Quality Assurance Engineer for the Diablo Canyon Project. My qualifications have been previously submitted before this Board in the 1983 Design Quality Assurance hearings. de Uriarte et al., ff. Tr. D-847.
I, T. G. de Uriarte, am the Director of Program Management for Pacific Gas & Electric Company's Quality Assarance Department.
My qualifications have been previously submitted before this Board in the 1983 Design Quality Assurance hearings, de Uriarte et al., ff. Tr. D-847.
1.
All elements of the PGandE and DCP QA P.ograms have been equally applied to both Unit 1 and Unit 2 design efforts.
de Uriarte et al., ff.
Tr. D-847 at 24; Moore Tr. n-3165.
2.
Between November 1981 and August 1982, the developing DCP was conducted under the PGandE QA Program. This program, in total, applied to both
. Units 1 and 2.
de Uriarte et al., ff. Tr. D-847 at 9,,24.
Project Engineering was controlled by and implemented procedures contained in the PGandE Engineering Manual. Moore, Tr. D-3161, D-3165 0067A
-1
3.
From August 1982 to the present, all woric was performed under the DCP QA Program. The DCP QA Frogram was developed from the NRC-approve' Rechtel Topical Report, BQ-TOP-1, Rev. 3A. The PGandE Engineering Manual was modified or supplemented where necessary to mesh with the DCP QA Program. de Uriarte et al., ff. Tr. D-847 at 10,13,16.
Engineering procedures in this manual were used to implement the QA Pr igram requirements for both units. Moore, Tr. D-3161, D-2165.
4.
The IDVP, through R. F. Reedy, Inc., performed an in-depth audit of the QA program applied to the Corrective Action Program. App. Ex.133.
5.
The IDVP audits confirmed the timeliness and adequacy of the QA Progran which is applicable to both units.
Reedy et al., f f. Tr. D-1459 at 8 8-7.
In addition, the Staff confirmed that the Corrective and Preventative Action Programs implemented by the ITP was timely and sufficient to assure that licensing criteria have been met Morrill, ff.
Tr. D-2906, at 4-6, Haass, ff. Tr. D-2906, at 3, 4.
Dated: 3eptember 28, 1984 M. S.%
M. J. JACOB 5ON T. G. de URIARTE Subscribed and sworn to before me this 28th day i=========================
C. T. NE*L f.8.ADISON l
of September,1984.
"Y.' ' 'G~ ~ - CAUiORNIA =
u
.DO::TY OF s'.:s rRANCISCo
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.i..............*'""*"'*"***"*~
Cynthia Neal-Madis.on Notary Public in and for the City and County of San Francisco State of California My commission expires December 27, 1985 0067A.. - _ _. - - _ - - - _ - -
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~
UNITED STATES OF AMERIC A NUCLEAR REGULATORY COMMISSION,
_1 m G5 i:
o.,
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
. }*e.
)
~
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC C0ffANY
)
Docket Nos. 50-275
)
50-323 (Diablo Canyon Power Plant
)
Units 1 and 2)
)
)
AFFIDAVIT OF G. H. MOORE AND G. V. CRANSTON STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO
)
The above being duly sworn, depose and say:
I, Gary H. Moore, am the Project Engineer for the Diablo Canyon Project, Unit 1.
My qualifications have been previously submitted before this Board in the 1983 Design Quality Assurance hearings.
Anderson et al., ff. Tr. D-224.
I, Gregory V. Cranston, am the Project Engineer for the Diablo Canyon Project, Unit 2.
My qualifications have been previously submitted before this Board in the 1983 Design Quality Assurance hearings.
Anderson et al., ff. Tr.
D-224.
1.
All completion and modification work performed by the Diablo Canyon l
Project conformed to PGandE's Engineering Manual which provides for engineering review of construction results and revision of design documents to reflect as-built conditions.
Anderson et al., f f. D-224, a t 32.
App. Ex.161.
}
0066A.
2.
The design process specified for Unit 2 was that used for Unit 1.
The primary difference in the written procedure for Unit 1 is that 3.6 OH has added levels of review by the Nuclear Power Operations Department fo
- ny design change in conformance with technical specification requirer.ents.
Procedure 3.6 ON, App. Ex.161.
That review does not affect the quality of the design or the design change.
3.
Procedure 3.7, "As-Built Documents," applies to both Units 1 and 2.
Thi s "as-built" portion of the design process is monitored and audited for compliance with all elements of the PGandE and DCP QA Programs, de Uriarte et al., ff. Tr. D-847, at 24; App. Ex.161 Dated:
September 28, 1984
(*> t Ner, c..
G. H. MOORE M
G. V. GRAH5 TON Subscribed and sworn to before me this 28th day sa=== na me ma..........m..
of September,1984.
C. T. NEAL MADISON i
i !DT
- r.*X - CAUFORNIA !
Ch i A..~ ) COUNTY oF.
SAN FRANCISCO C.T No^ M ~
- =~ 2 2 = t:t;.2..k.""..
Cynthia Neal-Madison Notary Public in and for the City and County of San Francisco State of California My comission expires December 27, 1985 0066A. -.
f g
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIONU, LJ d M, -
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD..q
.i v.- -
7,9
)
In the Matter of
)
)
PACIFIC GAS AND ELCCTRIC C0ffANY )
Docket Nos. 50-275
)
50-323 (Diablo Canyon Power Plant
)
Units 1 and 2)
)
)
AFFLAVIT OF L. E. SHIPLEY STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO )
The above being duly sworn, depose and say:
I, Larry E. Shipley, am currently the Chief Plant Design Engineer for the San Francisco Area Office of the Western Power Division, Bechtel Power Corporation.
I have served as the Piping Consultant for the Diablo Canyon Project prior to my current assignment. My qualifications have been previously submitted before this Board in the 1983 Design Quality Assurance l
l hearings. Anderson et al., ff. Tr. D-224.
The piping arrangement is essentially the same for Diablo Canyon Units 1 f
and 2.
Anderson et al., ff. Tr. D-224 at 28-29.
Minor differences do exist l
in piping arrangement and pipe support design which result primarily from the
" opposite hand" arrangements of Unit i vis-a-vis Unit 2.
These minor differences in piping design are necessary to accommodate equipment which is L
identical to that furnished for Uait 1 (same hand) for use in the opposite L
hand arrangement for Unit 2.
Due to the rigorous analytical nature of piping l
l 2405d _ _. _ _
design, these minor differences still required a complete set of unique analyses, calculations and pipe support designs for Unit 2 (D-387, 393-394).
However, the same criteria, methodology, design pocess and basic procedures which were employed for the Unit I review, verification and modification effort were used for the analyses, calculations and designs for Unit 2 piping. Anderson et al., ff. Tr. D-224 at 30 Dated:
Septenber 28, 1984 s
L. E. IIFL
~
Subscribed and sworn to
""""""""""'""""'t
' """"""""'"' '.""T. 'NEAL MADISON g
before me this 28th day C
i of September,1984*
!'".' * ' .!! - CALIFORNIA =
a t:
COJ:4TY OF g
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- ... :,e AciSCO g
lay Commin.on [xpire DH. 27,1985 g i wannunen.uunn.u.uunu.a.unnuunuu e C T W n~%
Cynthia Neal-Madison Notary Public in and for the City and County of San Francisco l
State of California i
My conriission expires December 27, 1985 l
2405d - -
^-
UNITED STATES OF AMERICA
?"~
NUCLEAR REGULATORY COMMISSION
.;qo _. i [*O f BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
.i
)
,a?g#'..
In the Matter of
)
, Ei m -
)
PACIFIC GAS AND ELECTRIC COMPANY )
Docket Nos. 50-275
)
50-323 (Diablo Canyon Power Plant
)
Units 1 and 2)
)
)
AFFIDAVIT OF W. H. WHITE STATE OF CALIFORNIA
)
)
ss CITY AND COUNTY OF SAN FRANCISCO )
The above being duly sworn, deposes and says:
I, William H. White, am currently the Assistant Project Engineer for the seismic area for the Diablo Canycn Project.
I am also an engineering specialists for the San Franciso area office of the Western Power Division, Bechtel Power Corporation.
My qualifications have been previously submitted before.this Board in the 1983 Design Quality Assurance hearings.
- Anderson, et al., ff. Tr. D-224 1.
Major structural systems in Units 1 and 2 can be grouped as follows:
l (1) Essentially identical structures: Specifically, the containments and Class I outdoor storage tanks and buried diesel fuel oil tanks of l
the two units.
Anderson et al., ff. Tr. D-224, at 28-30.
i (2) Common structures which are the auxiliary building, the fuel handling building and the intake structure.
Anderson et al., ff.
Tr. D-224, at 28-30.
(3) Similar structures which include the annulus structures (inside l
containment) and the turbine building. These steel structures in i
l 0061A --
Unit 2, although similar in geometry to their counterparts in Unit 1, exhibit sone minor variations in configuration.
Anderson et al., ff. D-224, at 28-30.
2.
Since structures mentioned in (1) and (2) above are either essentially identical or common, the criteria, methodology and evaluation which were applicable to these structures in Unit 1, and which were reviewed by the Independent Design Verification Program (IDVP), remained the same for Unit 2.
3.
The similar structures mentioned in (3) above were evaluated separately for Unit 2; however, the evaluation criteria and the methodology, which were reviewed and approved by the IDVP for Unit 1, were also applied to these Unit 2 structures.
4 There is also one Final Safety Analysis Report (FSAR) which is common to both Units 1 and 2.
App. Ex. 5, Sections 3.7 and 3.8, Tr. 3456, LPB-7926,10 NRC, 453, 459 (1979).
Dated:
September 28, 1984 i
/.
W. H. WHITE Subscribed and sworn to before me this 28th day of September,1984.
Qt.. C. T. NEAL MADISON
...it - Gum s.
. COUNTY oF y
... ;.'n:nsco Mr Comm.uien heires Du. 27,1985 g
- uunununneau,unnenau,une d.T~Akal-hadw Cynthia Neal-Madison Notary Public in and for the City and County of San Francisco State of California My commission expires December 27, 1985 2
0061 A.
^
UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION' In the Matter of
)
)
u t..w PACIFIC GAS AND ELECTRIC COMPANY
)
Docket No. 50-275
~
)
Docket No. 50-323
'SII /3 Diablo Canyon Nuclear Power Plant, )
14 si ~l Units-1 and 2
)
)
T:.
.an,
,m s 9RACH 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 CA 93401 US Nuclear Regulatory Commission Washington 1 DC 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission John Phillips, Esq.
Washington DC 20555 Joel Reynolds, Esq.
Eric Havian Judge Jerry R. Kline Center for Law in the Public Interest
- Atomic Safety and Licensing Board 10951 W. Pico Blvd. - Suite 300 US Nuclear Regulatory Commission Los Angeles CA 90064 Washington-DC 20555 David F. Fleischaker, Esq.
l Mrs. Elizabeth Ap'felberg P. O. Box 1178
.c/o Betsy Umhoffer Oklahoma City OK 73101 I
1493 Southwood Sun Luis Obispo CA 93401 Arthur C. Gehr, Esq.
Snell & Wilmer Janice E. Kerr, Esq.
3100 Valley Bank Center Public Utilities Commission Phoenix AZ 85073 i
l State of California l
5246 State Building Bruce Norton, Esq.
~350 McAllister Street Norton, Burke, Berry & French, P.C.
Scn Francisco CA 94102 P. O. Box 10569
' Phoenix AZ 85064 l
Mrs. Raye Fleming 1920 Mattie Road Chairman Shall~ Beach CA 93449 Atomic Safety and Licensing Board Panel Mr.' Frederick Eissler~
US Nuclear Regulatory Commission L
Scznic Shoreline Preservation Washington DC 20555 Conference, Inc.
4623-More Mesa Drive Snnts Barbara CA 93105 l
L
Chairman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel
' Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Washington DC 20555 US Nuclear Regulatory Commission Washington DC 20555 Secretary Judge W. Reed Johnson US ' Nuclear Regulatory Commission Atomic Safety and Licensing Washington DC 20555 Appeal Board US. Nuclear Regulatory Commission Attn:
Docketing and Service Washington DC 20555 Section
- Lawrence J. Chandler, Esq.
Commissioner Nunzio J. Palladino Henry J. McGurren Chairman US Nuclear Regulatory Commission US Nuclear Regulatory Commission Office of Executive Legal Director 1717 H Street NW Washington DC 20555 Washington DC 20555 Mr. Richard B. Hubbard Commissioner Frederick M. Bernthal MHB Technical Associates US Nuclear Regulatory Commission
'1723 Hamilton Avenue Suite K 1717 H Street NW San Jose CA 95125 Washington DC 20555 Mr. Carl Neiberger Commissioner Lando M. Zech, Jr.
Telegram Tribune US Nuclear Regulatory Commission P.
O.
Box 112 1717 H Street NW
-San Luis Obispo CA 93402 Washington DC 20555 Michael J. Strumwasser, Esq.
Commissioner James K. Asselstine Susan L. Durbin, Esq.
US Nuclear Regulatory Commission Peter H. Kaufman, Esq._
1717 H_ Street NW L
A geles A
90bl0 Commissioner Thomas M. Roberts l
US Nuclear Regulatory Commission l
1717 H Street NW Washington DC 20555 L
f l~
l Date:
September 28, 1984
,\\ t OJ-R tv &cs
- Copies' delivered by Courier
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