ML20210E602

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Comments on Draft Phase II Commission Paper Per 821004 Request.Staged Licensing,Intervenor Comments & Consolidated Staff Position Discussed
ML20210E602
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 10/06/1982
From: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20209C222 List:
References
FOIA-86-151 NUDOCS 8609250051
Download: ML20210E602 (5)
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j NUCLEAR REGULATORY COMMISSION REGION V G

4 1450 MARIA LANE.SulTE 210 WALNUT CREEK, CALIFORNIA 94505 g . . . . . ,@g OCT 0 61982 MEMORANDUM FOR: D. G. Eisenhut, Director, Division of Licensing FROM: R. H. Engelken, Regional Administrator

SUBJECT:

DIABLO CANYON PHASE II COMMISSION PAPER As requested by your note of October 4,1982, we have reviewed the draft of the Diablo Canyon Comission Paper. Our general comments are provided below. Other, more specific coments have been provided in the enclosure.

1. Scope of the Comission Paper The contents of the Paper clearly go beyond the approval of the Phase II Program Plan. It is mcomended that the Purpose section of the Paper be modified to recognize that the staff recommendations affect the Phase I Program (e.g., PG&E/ Westinghouse Interface),

other areas (e.g., Construction QA), and identify those actions which should be completed before fuel load and full power decisions.

2. Coherence of the Paper and Encle:ures It appears that the coherence of the Paper could be substantially improved. As currently presented, the reader must have an intimate knowledge of the substantive issues and the enclosures to be able to understand the topics discussed in the Paper and rationale for staff nicommendations. It is recommended that the following actions be taken to improve the continuity and the comprehensibility of the paper:
a. Concise summary statements, reflecting the staff's current position and/or review status, should be added to the end of each " Discussion" paragraph involving actions and results. The statements should be developed such that they support the staff's overall conclusions and recommendations. Such summary statements should be provided for: Overall Findings to Date (provide a staff position on the significance of the errors and agreement / disagreement with the licensee's "no loss of intended safety function" statement); IDVP Phase I and II Results (Item i 1.b has such a sumary statement, similar statements should '

l be provided for the others); PG&E Actions,and tae IDVP/ITP l

Interface.

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8609250051 860916 PDR FOIA I HOLMES86-151 PDR O

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D. G. Eisenhut b. Additional discussion elements should be added if we intend

, to use additional elements in the Conclusions portion of the Paper (e.g. Figure 3 of the Conclusion mentions "ITP QA Program" and "PG&E/ Westinghouse Interface", these are not addressed in the body of the Paper).

c. The Conclusions should include a clear and concise list of each specific action we feel is needed. These conclusions should logically follow staff position statements (see a. and b.,

above). This list should basically include the information provided in Figure 3 and identify how these actions relate to the Phase I and II IDVP program plan and to license restoration.

d. The information contained in Figures 2 and 3 should be addressed

, in a narrative included in the body of the paper. The figures themselves should be simplified so that they are self explanatory or eliminated.

3. Staged Licensing The subject of staged license restoration has been treated too t

lightly in the Paper. The PG&E proposal would involve revision to, or relief from, tt.6 Diablo Canyon Technical Specifications.

Such action nay well require prior notice and has potential for additional public hearings (as in the Trojan wall issue). It is recommended that we elaborate on the ramifications of, and staff position on, the staged license restoration. An ELD opinion may l be in order on this subject.

4. Intervenor Comments The Paper. should recognize that in developing the staff recomendations consideration was given to the Intervenor's coments (reference Attachment No. 8 to Mr. Dirck's memorandum to the Commission dated September 24,1982).
5. Consolidated Staff Position

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It is mcommended that a statement be included which indicates that the positions identified in the Paper were jointly developed by NRR/RV/IE and ELD who concur in the recommendations.

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~ . . . ~ . .

o D. G. Eisenhut t If you have questions or require further information regarding our convents, please contact our office (Contact: T. W. Bishop FTS 463-3751).

& D.

R. H. Engelken Regional Administrator

Enclosure:

As stated cc: R. DeYoung H. Denton R. Vollmer F. Miraglia

T. Novak J. Kerrigan H. Schierling r-m- -

, --,, - - - - . --- - - --, -c - . - - - - - , - -- -

S REGION V SPECIFIC COMMENTS ON THE DIABLO CANYON PHASE II COMMISSION PAPER AND ENCLOSURES

1. Page 3, paragraph 1.b.: List the topics of each ITR.
2. Page 3, paragraph 1.d.: Add a summary statement indicating that all open inspection issues am being appropriately handled by the IDVP/ITP/and/or the NRC staff.
3. Page 3, paragraph 1.e. : Expand to clarify the DE and DDE concern and identify the staff position.
4. Page 3, paragraph 2.a.: Clarify that the R. F. Reedy results are preliminary and that it may be premature to draw conclusions on the significance of the findings. The Region V letter (enclosure 6) pertains to this item as well as paragraph 2.b.
5. Page 4, paragraph 3.a.: Provide a sumary statement to indicate

, the staff position (e.g. the CAP appears to effectively address the findings to date.)

6. Page 4, paragraph 3.d: Discuss the significance of this PG&E position.
7. Page 4, paragraph 3.e.: Indicate that the program for Construction QA was reviewed and found to be consistent with the Region V recommendations of March 29, 1982 and is satisfactory (reference, R. H. Engelken memo to D. G. Eisehnut dated October 1, 1982).
8. Page 4, paragraph 3.f.: Discuss the purpose of the walkdowns and the staff position.

l l 9. Page 4, paragraph 3.g.: Discuss the staff position and the related relief or revision to Technical Specifications, as well as ramifications.

10. Add discussion of PG&E/ Westinghouse Interface, ITP QA, determination of correct Hosgri Spectra, etc., if these topics are to be included ,

in the conclusions section.

11. Page 4, paragraph 4: Provide a concise narrative discussion of ,

j the IDVP/ITP interface.

12. Page 5, Proposed Phase II Program: Discuss the late introduction of Bechtel and the need to evaluate personnel with regard to independence from Bechtel. (As you are aware, two senior R. F. Reedy managers were former Bechtel managers. We are interviewing the R. F. Reedy staff this week to assess individual independence. An update on this will be provided to NRR by C.0.B. October 8,1982.)

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13. Page 5,

Conclusions:

Reorganize this section to include a listing of each specific action and corresponding time frame (i.e., before fuel load, or prior to exceeding 5% power....) for each item. Indicate whether the action item modifies to Phase I, II, or other.

14. Page 6, Conclusions, paragraph 3: Discuss the relationship of R. F. Reedy managers to Bechtel (see item 12, above).
15. Page 6, Recommendations: Request approval of the specific actions listed in the Conclusions section (see item 13, above).
16. Page 6. Coordination: Revise to reflect NRR/IE/RV/0 ELD development of and concurrence in the recommendations.

i 17. Figure 2: Simplify or delete (see item 11, above)

18. Figure 3: Simplify or delete (see item 13, above).
19. Enclosure 3: Reduce to summary statements. A draf t of the summary statements for enclosure 3 was provided to Region V by Mr. Buckley (NRR) on 10/6/82. This summary is appropriate (with two minor additions, which were provided to Mr. Buckley).
20. Enclosure 4: Discuss IDVP involvements in review of this issue.
21. Enclosure 7: Discuss staff position on this program.
22. Enclosure 9: See item 9, above.
23. Enclosure 10: Address RFR/Bechtel relationship, see item 12.

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