ML20209C472
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g, Document Control 50-275/323 MEMORANDUM FOR:
Thomas M. Novak, Assistant DirectorPRC System for Licensing LB#3 Reading Division of Licensing JLee THRU:
George W. Knighton, Chief Attorney, OELD Licensing Branch No. 3 Division of Licensing D
FROM:
Hans Schierling, Project Manager Licensing Branch No. 3 1
Division of Licensing
SUBJECT:
LIABLO CANYON INTERROGATORIES l
Attached is the staff response to the first set of interrogatories from the Governor sf California regarding the Diablo Canyon hearing. This response was crecared b.v the technical staff and management and myself since September 13, 1983.
Because of the tight schedule we were not able to provide you with a draft.
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Hans Schierling, Project Manager '
Licensing Branch No. 3 Division of Licensing n\\
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50-275, 50-}23 l
1 MEMORANDUM FOR:
G. Kntghton, Chief, Hr.irtor Licensing Hr.snrh W.
- . NKH H. Scherling, Diablo C.inyon Pro. rect M.in.i ge r. NRF FROM:
P. J. Morrill, Heactor inspectus. HV
SUBJECT:
DIABLO CANYON. READINESS FOR OPERATION MEETIV.
MINUTES, SEPTEMBER 7, 1981 The purpose of this meno is to forward our meeting minutes of the :.uh.ier t meeting. We recoannend that these minutes be incorporated with your observations and be issued to the licensee and public document rooms to document the issues raised and the licensee's committments.
Shs..s id y.iu have-questions or cocuments please. contact at FTS 403-3740.
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P. J. Morrill Reactor Inspector Enc.losure:
As stated
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i ec w/ enclosure:
J. Martin, RV T. Bishop, RV D. Kirsch, RV R. Scarano, RV J. Crews, RV P. Morrill, RV M. Mendonca, RV
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1 NEETING MINUTES Diablo C.inyon Readiness for Operatson September 7n,1983 j
A aceting to discuss operational readiness of the Diablo Canyon Unit I nortea plant was held on September 7,1983, at the Licensee's Public Information 1
Center.
Those present included representatives of the NRC, the 1trensee, the Governor of the State of California, and the Inte rveno rs.
The principle attendees are listed below.
J NRC:
H. R. Denton, Director, Of fice of Nucle.
Re. Lui Regulation D. Ge Eisenhut, Director, Division of Licensing, Nuclear Reactor Regul. tion J. P. Knight, Assistant Director for Components and Structures Division of Engineering H. E. Schierling, Project Manager, NRR J. B. Martin, Regional Administrator, Region V T. W. Bishop, Director, Division of Resident, Reactor Projects and Engineering Programs M. M. Nendoaca, Senior Restdent Inspector, Diablo Canyon P. J. Norrill, Reactor Inspector, Region V Licensee:
G. Naneatis, Executive Vice President, Facilities Development H. Friend, Project Completion Manager J. Schuyler, Vice President, Nuclear Power Generation e
J. Shif fer, Manager, Nuclear Plant Operations R. Thornberry, Plant Manager J. Roch, Project Manager
- 5. Lew, Licensing Manager State of California:
R. B. Hubbard, NHB Technical Assoetates, Consultant to tfe Governor Intervenors:
S. A. Silver, Mothers for Peace De September 6,1983, the NRC personnel listed above visited the site to observe first hand the operational readiness of the facility.
Based upon l
PG&E's presentations and the facility tour, the NRC staff raised the following issues of concern for licensee consideratton and action.
A.
Control Room Readiness for Operation:
The NRC staff observed that (1) i the shif t supervisor was in an of fice which is adjacent to the control room but does not have a good view of the control room, (2) operations personnel and their. shift asstanments were not identified either by name tags or by a status board, (3) the control room was occupied by a number of personnel who were not actively working and whose purpose war not l
clear, and (4) the licensee's shift turnover requires uncompenseatret overtime.
The staff also stressed that any cnnfusion regarding sno was in charge of the factlity or its-c.peration would he t ot.s i l y un.ir c ept.sh l e and that the PGAE management hou!J consul with another, recentlv
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5 licensed utility to discuss the problems of starting up one nuclear gelant while the adjacent plant was being constructed.
Licensee p.rsonnel acknowledged the NRC's commsents. They stated that they would consult with the other utility and would consider how to enhance cont rol room conditions.
B.
Operational Emperience: The staff questioned the licensee's personnel regarding operational experience and the augmentation of the operators with Westinghouse personnel. The staff pointed out that this was PG&Es first large reactor plant and that well planned, deliberate, and controlled actions were essential to a safe and tr6uble free start-up test program. The licensee's personnel concurred and stated that supptimentary personnel frcs Westinghouse wuld be used to ausmeni, their staff during the start-up testing.
C.
Overall Facility control and Management: The staff stated that given the i
large construction and engineering presence on site it may be difficult for the licensee's operations staff to retain control of the faciltty and to manage the various activities occuring on-site.
The staff also observed that the licensee's ambitious schedule was similiar to that recently attempted by another California utility and which appeared to the staff to be a precursor to major items of noncompliance.
In the case of the other utility, the schedule was changed to delay the start-up of a second unit until the first unit's start-up was complete to ensure adequate management attention.
The staff stressed tuat PG&E should consult with management of the other utility to better define and understand the problems encountered and corrective actions required.
The PGEE personnel acknowledged the NRCa comments.
They stated that they would contact the other utility and were currently revaluating the,
" schedule for Diablo Canyon Unit 2.
,.v D.
Need for On-site Engineering: The NRC staff described the 'necesstty for adequate on-site engineering support of the plant operating ::tsff and the improvement in plant safety to be realized by a well staffed and qualified engineering support group.
Licensee representative explained that, with the exception of asjor modifications, engineering would be-l controlled and conducted by PG&E Nuclear Plant Operations, the same group responsible for the safe operation of the facility.
1 E.
Public Address System: The NRC staff questioned the PG&E personnel as to how personnel in the plant would be informed of plant casulties and the statua-of the plant announcing system, which PGGE personnel had committed to evaluate at the last SALP meeting. The NRC personnel observed that, aside from the plaat operators who have two way radios, the only way to
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communicate with personnel'in the plant was with the bell system (similiar to those used in department stores) or by the use of emergency siress.
PG&E personnel acknowledged that this ites did not have high priority and that they would speed up their evaluation and implementation of a plant communication system.
NRC tepresentatives stated that this should be complete prior to initial criticality.
F.
Hot Functional Testing:
The NRC staff observed that the licensee's letter of August 10, 1983, did not contain a commitment to complete an additional hot functional test program prior to fuel loading.
In 1ight
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of the estessive modifications made to the facility in safety-related areas, the large number of construction personnel on site, malicious mischief observed on-site, threats of sabotage, and the de-activitation of the security system', the staff questioned the decision by PG&E to not condus'. a hot functional test prior to fuel load.
Licensee personnel stated that the surveillance tests, piping system stress walkdowns, and securit/ inspections described in their letter of August 10, 1983 letter.
would provide assurance that the plant was fully operational prior to fuel load.
G.
Post Core Load Construction Activities: The NRC staff questioned PG&E personnel as to what construction activities would take place during and
- ft;; =0;= leading.
pC&E normannel stated that ennst ruct ion activity in the control room would be completed prior to fuel loading.
During following discussions the staff questioned the extent of work to be completed on the done service crane in the containment.
PG&E personnel stated that the crane work area would be boxed in to praelude f alling debris, would not be directly over the reactor (which was protected by the missle shield), and the work would not be done during fuel loading.
When questioned, PG&E personnel stated that the heaviest structural members to be added would likely be steel plates weighing approximately 200 pounds.
H.
Systeen Interaction Program:
The NRC staff questioned the status of the Systems Interaction Program.
Licensee representatives stated that the study had been given a lower priority, but that the study for Unit I wonld be completed six months after initial operation of Unit I and that Region V would be informed when the study was complete.
I.
Emergency Response yacilities: The NRC staff stated that emergency facilities and their readiness should be closely followed by the licensee.
At the conclusion of the NRC/ licensee discussions representatives of the p
Governor and the Intervenors were offered the oppertunity to present their views. !!r. R. Rubbard, representing the Governor raised the following issues.
J.
It was not clear how the operability of systems which had been modified would be verified.
The licensee was placing a great deal of reliance upon surveillance testing which was not the purpose of the surveillance tests.
During tours of the facility some calibration stickers over one year old were observed (impting that calibrations may be out of date).
E.
The PGEE approach has been to complete various activities in parallel, which saves time but may result in a questionable product unless integrated control of engineering, construction, and operations was utilized.
Because of this pars 11e1 approach and possible lack of integrated control, the PGEE approach is questionable.
L.
It was not clear when PG&E would be finished, or what the statu. of the project was since there was no presentation of how many items were left to be modified, the rate of closure of open issues and modifications was unspecified, and many s tems had been consolidated by PME.
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Diablo Canyon is PGE's first large PWR.
The PGE organization has a lack of operating experience in this area and may not be c.unpetent to operate the facility.
Ms. S. Silver, of the Mothers for Peace supported Mr. Hubbard's issues and raised the following issues of her own.
N.
It does not seem appropriate for PGE to complete the Seismic Interaction Study and perform modifications while the plant is operating. and afterwards tell the NRC and the public the results.
(Mr. Denton of the NRC staff explained that the previous NRC silence did not indscate
- cepts:c: :=d tht th staff wculd have te ev lusse this sii.uai.iuu. )
O.
Many items had been placed on the "back-burner" (such as the plant sanouncing system and the Seismic Interaction Study) and will not get done. These items deserve the concern of all involved.
P.
The emergency sirens are not seismically qualified.
Plant security s'ould have been retained.
The sabotage event related to h
Q.
the souges in the reactor coolant system, the bomb threats, and the presence of over 7000 personnel at the site are causes for concern.
R.
Personnel with allegations are reluctant to come forward since their candor endangers their jobs, places them irt the hot seat, and, even if some of their allegations are true, results in their public ridicule.
(Mr. Dentos of the NRC staff' acknowledged the problem and stated that the U.S. Labor Department was now involved to eliminate the job threat problem.)
~S.
Leading the fuel before construction is complete is an ites of concern.
la addition, holding hearings on the safety of the facility after fuel loading is inappropriate.
If the facility is to operate at all, then it must be as safe as possible at all times.
At the conclusion of the meeting, Mr. Denton thanked Mr. Maneatis, the PGE staff, Mr. Hubbard, representing the State, and Ms. Silver, representing the Mothers for Peace for their comments.
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SEP 2 E 1533 Mi.-::.RA' CUM FOR:
Darrell G. Eisenhut, Dire:: -
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James M. Taylor, Director Division of Quality Assurance.
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5afeguarcs, and Inspection Programs, IE SUEJECT:
OA DRAFT REPORTS Ir. ras::nse :: your mencrandu dated Se::e :er 22, 1952,~we nave c:= pie:e :ne working papers-for three OA Case Studies.
Tne studies for which working papers are considered complete are.for the Marbie Mili, Yogtle., and Diablo Canyon projects.
Tne studies are conaleted it. tne sense that no further revisions are plannec, and the studies in this curren fer es well as c:ner relevan: infermation will be used as in:u: in devel::in:
a-cer.::stte reecr: Ic Cer.gress on :ne case s:::y a::ivities.
Ir :nis rega'r:,'
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- ne w:rking papers shcule no longer be ::nsioere: " craft' working papers.
Enciesed are c ies of the conoleted werkin; cacers fer the three.:roje::s.
Fiease note tha: :ne Case C working pacer is cate: Se;temmer 19, 1953, an:
is a case s:uay team revision of the earlier craf-dated July 19,.1953, which
.you transmitted in a boarc notification dated September 2,1922.
Enciesed also are copies cf tnree letters cated August 2,19S3 transmitting the w rking papers to the respective licensees.
Tne workinc papers for Cases A and E are icentical to the working papers transmitted in the August 2 letters.
Tne only difference is the cover statement by the team leader that the workin;
- 1pe r: are n: icnger ::nsicered draf.
C: pies of each of these three case stuoy working papers are being placed in tne Public Document Room.
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'ca_. T.. Teylor, Di rector Di dision[pf Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement tnciesures:
See Page 2 ar
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cEP : 5 1555 Garrell G. Eisenhut 1
Enclosures:
1.
Letter Ic Public Serv. ice Indiana, catec S/2/83 Letter'to Georgia Power Cc.aany, datec S/2/83 c.
3.
Letter to Pacific Gas and Electric, dated 8/2/83 Case stucy A Workina Paper f*
5.
Case Stucy B uorking pahe -
6.
Case Stucy C' Working Paper, datec 9/19/83 4
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QUALITY ASSURANCE CASE STUDY WORKING PAPER CASE C REISED DRA.rT WORKING PAPER - DATED SEPTEMBER 19, 1983 A:: acne: is a copy of the above document.
It is a. revision of Case Study C Draft Werkir.; Papers dated July 19, 1983.
This revision was prepared by an NRC contractor tre re# E::s input anc cerer.:s en the earlier draft by members of the Case 5:v:y C Team. which is comprised of NRC and contractor staff members.
This cc:. e : nas
- been su jected to the NRC staff review process, an: it coes not refie:: licensee com:,ents on the July 19 draft.
No further revision of this n:rkir; ; aper is planneo, and this document should no longer ce considered a draft. This d::ument, alone with other relevant information will be used as in:::
- a :.sciidated re:Or: en the case studies, which will be subje::ec ::
tne fuli NRC staff review process.
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^UALITY ASSURANCELCASE STUDY WORKING PAoER CASE C.
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WASHINGTON, D. C.
20014 Sectemaer 19, 1983 0'\\
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s SEP 2 91983 MEMORANDUM FOR:
Thpmas M. Novak, Assistant Director
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for Licensing Division of Licensing FROM:
James P. Knight, Assistant Director r
components & Structures Engineering Division of Engineering
SUBJECT:
DIESEL GENERATOR INTAKE / EXHAUST SEISMIC DESIGN BOARD NOTIFICATION NO. 83-03 Plant Name:
Diablo Canyon Unit 1 Docket No.:
50-275 Licensing Stage:
Post OL Review Responsible Licensing Branch:
Licensing Branch #3 Project Manager:
H. Schierling Review Status:
Complete i.
In response to a staff inquiry on an allegation concerning seismic design of emergency diesel generator intake and exhaust system, the licensee -
Pacific Gas and Electric Company (PG&E) provided additional information i
contained in a letter dated September 9, 1983 from J. O. Schulyer to-i D. G. Eisenhut.
The staff in Equipment Qualification Branch, DE:C&SE has reviewed the additional information and in addition obtained further I
clarification through telephone conference on September 20, 1983.
The purpose of this memorandum is to provide you with the staff assessment of the seismic capability of the emergency diesel generator intake and exhaust system at Diablo Canyon Unit 1.
The diesel generator inlet and exhaust piping is classified as Design Class II, the intake air filter and air silencer are classified as Design Class I,' and the engine exhaust silencer is classified as Design Class i
II.
The criteria for Design Class I and II are defined in Section 3.2.1 of the FSAR.
Design Class II components are considered important to i
reactor operation, but not essential for safe shutdown and isolation of l
the reactor.
However, the diesel generator intake and exhaust system including filters and silencers have been qualified to the original Hosgri Spectra and current Hosgri Spectra where appropriate.
Qualifi-cation models inc'auded explicit representation of exhaust silencer, piping and pipe supports.
As a result of the Hosgri spectra qualifi-cation it has been determined that stresses in critical sections are within allowable values defined in ANSI B31.1-1967 standard.
The Hosgri spectrum qualification has also identified the need for modification
Contact:
G. Bagchi X28251 f
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Thomas M. Novak of piping supports as well as mounting braces of one exhaust silencer.
Based on the above discussion the staff concludes that any loss of
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efficiency in the operation of the diesel generators due to a large earthquake such as the postulated Hosgri event is not likely, provided that modifications to braces and piping supports are properly installed.
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&,, - s James P.
nignt, Assistant Director Components & Structures Engineering Division of Engineering cc:
V. S. Noonan G. Knighton A. Vietti A. Lee l
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