ML20210U513
| ML20210U513 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/30/1986 |
| From: | Grimsley D NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Holmes G MHB TECHNICAL ASSOCIATES |
| Shared Package | |
| ML20210U520 | List:
|
| References | |
| FOIA-86-197, RTR-NUREG-0588, RTR-NUREG-588 SECY-85-156, NUDOCS 8610100042 | |
| Download: ML20210U513 (4) | |
Text
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UNITED STATES n neo
[a
]o NUCLEAR REGULATORY COMMISSION
[
g W ASHINGTON. D. C. 20555 5
SEP 30 1986 Mr. Gregory A.
Holmes Associate Consultant MHB Technical Associates 1723 Hamilton Avenue, Suite K IN RESPONSE REFER San Joce, CA 95125 TO FOIA-86-197
Dear Mr. Holmes:
This is in regard to your request, pursuant to the Freedom of Information Act, to which the NRC assigned the above number.
_X__
This is a partial response to your request.
We will notify you upon.completiors of search for and review of any additional recor's' subject to your request.
d The staff has cumpleted the search for and review of records subject to your request, and thie is the final Iesponse to your request.
The NRC has no records subject to your request.
Records subject to your request are available for public inspection and copying at the NRC Public Document Room (PDR), 1717 H Street, NW, Washington, DC 20555, as noted Y
on the enclosure (s).
The PDR accession number if identified beside each record description.
_X_
Records subject to your request are being made available for public inspection and copying at the NRC Public Document Room (PDR), 1717 H Street, NW, Washington, DC 20555, in the PDR file folder under the above number and your name.
These records are listed on the enclosure (s).
We are enclosing a riotice that provides information about charges and procedures for obtaining records from the PDR.
Sincerely,
[
g
-c+w Donnie H. Grimsley, Director Division of Rules and Records Office of Administration
/
Enclosure (c):
As stated
/
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8610100042 860930 PDR FOIA HOLMt.S86-197 PDR
l Re:
86-197 Appendix F i
1.
1/84 Response to Udall Questions 1 through 10 (12 pages) 2.
1/11/84 Testimony of Palladino before the Subcomittee on Energy and
-(draft) the Enviror. ment (24 pages) 3.
1/13/84 Note to J. Knight and T. Bishop, relationship between allegations and matters before the Appeal Board (7 pages) 4.
1/18/84 Testimony of Palladino before the Subcomittee on Engery and (final the Environment, 1/24/84 (14 pages) coments) 5.
1/20/84 Memo for Chairman Palladino, Comiss'ioner Gilinsky, Comissioner Roberts, Comissioner Asselstine, and Comissioner Bernthal, Final. Testimony for Udall Hearing on Diablo Canyon (11 pages) 6.
1/24/84 Testimony of Michael J. Strumwasser, licensing process of Diablo Canyon (25 pages)
Memo for George W. Knighton, Meeting (with Pacific Gas and 7,
1/27/84 Electric Company, scheduled 1/31/84 20 pages) 8.
1/31/84 Note to T. Novak, ACRS Briefing on.Diablo Canyon. February 10, 1984,(1 page) 9.
Undated Piping Information (13 pages)
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- 10. 2/2/84 Scheduling Notes; Coments by Parties on Diablo Canyon Criticality and Low Power Operation (2 pages)
- 11. 2/10/84 Coments by G. A. Maneatis, and Status on Diablo Canyon (6pages)
- 12. 2/10/84 Prepared Testimony of Thomas Devine (18 pages)
- 13. 3/30/84 Memo for George Knighton, Meeting with Pacific Gas & Electric Company on Diablo Canyon, scheduled 4/2/84 (3 pages) 14, 4/9/84 Note to Richard DeYoung, Comission order regarding consideration of earthquakes and emergency planning (18 pages)
- 15. 5/7/84 Memo for H. Denton, April 12, 1984, GAP request on Diablo Canyon (2pages) 1
Re: F01A-86-197
- 16. 5/8/84 Memo for H. Denton, May 3, 1984 2.206 Petition from GAP: Diablo Canyon (3 pages)
- 17. 5/17/84 Memo for T. Bishop, et al., SSER on IDVP (16 pages)
- 18. 5/25/84 Note to Harold Denton, ACRS Meeting on Diablo Canyon Seismic Plan (3 pages)
- 19. 6/12/84 Memo for G. Knighton, Proposed Letter to Applicant on Cultural Resources - Diablo Canyon (3 pages)
- 20. 6/21/84 Note to D. Eisenhut and J. Martin, Diablo Canyon Allegations (2 pages)
- 21. 7/5/84 Letter from PG&E, (ALAB-775) material #307 (5 pages)
- 22. 7/16/84 Note to. James Knight, Use of A307 Bolts (1 page)
- 23. 7/31/84 Commission Memo, Diablo Canyon Unit l'- Information for Full Power Briefing (5 pages)
- 24. Undated Slides 1 Commission Briefing PG&E Diablo Canyon Full Power License (27 pages)
- 25. 8/14/84 Note to Harold Denton, Commission Decision on Consideration of Earthquakes in the Context of Emergency Planning and Memorandum and Order Authorizing Issuance of Full Power Operating License (22 pages)
- 26. 8/31/84 Note to H. Schierling, Issues to be resolved before appeal board (8 pages) 4
- 27. 9/10/84 Meeting Notice for 9/13/84 meeting (2 pages)
- 28. 9/27/84 Memo for H. Schierling, Transfer of Allegation Resolution Responsibility (1 page)
- 29. 10/31/84 Memo R. Vollmer, Diablo Canyon Unit 1 - Allegations (5 pages)
- 30. 1/3/85 Note, Telecon with PG&E Reference Diablo Canyon Units 1 and 2 Technical Specifications (2 pages)
- 31. 1/28/85 Note - Diablo Canyon Allegations (by H. Schierling) (5 pages)
- 32. 1/29/85 Handwritten note from H. Schierling to H. Denton, et al., advising of 3/31/85 fuel loading date for Unit 2 (1 page) 2 i
Re:
- 33. 4/12/85 Meeting Notice; Diablo Canyon w/ PG&E (2 pages)
- 34. 4/17/85 Note to J. Knight, L. Chandler, et al., April 19, 1985 Meeting with PG&E Diablo Canyon.2 (4 pages)
- 35. 4/18/85 J. D. Shiffer Comments - Unit 2 Operational Readiness, Before the NRC on April 19,1985 (20 pages)
- 36. 4/19/85 H.B. Friend's Coments before.the NRC staff (13 pages)
- 37. 4/19/85 Proposed Agenda - NRC/PG&E Meeting in Bethesda, Unit 2 Low Power License including several slides stapled in 4 separate packages (37 pages) 19, 1985 meeting (handwritten)
Listing)of Attendees for the April
- 38. 4/19/85 (1 page
- 39. 6/10/85
' Note to Hans Schierlirig,.Coments on Diablo Canyon Sholly-Packages (61 pages)
- 40. 10/24/85 Han'dwritten note by H. Schierling, Unit 2 schedule (1 page)
- 41. 2/26/86 Memo for Diablo Canyon Allegation File; ARB Meeting Minutes, August 2,1985(2pages)
- 42. 3/3/86 Memo for Dennis F. Kirsch, Diablo Canyon Allegations (2 pages)
- 43. 3/4/86 Memo; Sumary sheet for allegation numbers 1230 and 1231 for Diablo Canyon, Units 1 and 2 (33 pages)
- 44. Undated (6) Vu-Graphs, Backup Slides - Diablo Canyon Unit 2 (7 pages)
- 45. 3/5/86 Memo for B.-Youngblood, A. Schwencer, et al., Salem ATWS reviews (2 pages)
- 46. 3/6/86 Memo; Diablo Canyon, Units 1 and 2 Combined Technical Specifications Changes (TAC 59655 and 59656) (6 pages)
- 47. 3/14/86 Memo for Steven A. Varga, Diablo Canyon Allegation No. 676 (2 pages)
- 48. 3/14/[86] Affidavit - State of California, before the NRC (2 pages)
- 49. 5/3/85 Adjudicatory Issue for the Comission, Litigation Report 1985 -
11 (4 pages)
- 50. 7/10/85 Statement of Edward J. Markey, Chairman (5 pages)
- 51. 10/24/85 Letter to The Honorable Nunzio Palladino, Events surrounding an automatic shutdown of the Diablo Canyon nuclear plant on May 18, 1985 (12 pages) 3
M
- Q TECHNICAL ASSOClATES
\\niW%d U~G w TECHNICAL CONSUL TANTS ON ENERGY & THE ENVIRONMENT Date G Bodenbaugh 1723 Hamriton Avenue-Surte K
-Richard B Hubbard San Jaso California %125 Gregoryf' Minor Phone HOB) 266-2M March 4,
1986 Mr. Donnie 11. Grimsley, Director Division of Rules and Records Office of Administration U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
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'r RE: FOIA REQUEST RtLA-st.-n7.=
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Dear Mr. Grimsley:
Pursuant to the Freedom of Infor'mation Act,. please 'make
^
availa'ble at the Commi'ss' ion 's Washing ton, D.C.,
P0blic Document Room single copies of records in the following categories:
A.
From the Chron Files of Mr. Hans Schierling from January 1, 1984, to the present, all records concerning in any way the Diablo Canyon Nuclear Power Plant, Units 1 and/or 2.
B.
From the Reading Files of Mr. Hans Schierling~
from January 1, 1984, to the present, all records concerning in any way the Diablo Canyon Nuclear Power Plant, Units 1 and/or 2.
Please provide partial responses as batches of documents become available.
If you have any questions concerning -this request, please contact me at the telephone number given above. Your prompt attention to this request will be appreciated' Very T uly Yours
/
Gr 9 A.
Holmes Associate Consultant 0
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TESTIMONY 0F NUNZIO J. PALLADINO CHAIRMAN U
S. NUCLEAR REGULATORY COMMISSION BEFORE THE SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT COMMITTEE ON INTERIOR AND INSULAR AFFAIRS UNITED STATES HOUSE OF REPRESENTATIVES ON DIABLO CANYON LICENSING CONCERNS JANUARY 24, 1984
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TESTIMONY OF NUNZIO J. PALLADIN0 CHAIRMAN U. S. NUCLEAR REGULATORY COMMISSION i
BEFORE THE SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT COMMITTEE ON INTERIOR AND INSULAR AFFAIRS UNITED STATES HOUSE OF REPRESENTATIVES ON DIABLO CANYON LICENSING CONCERNS JANUARY 24, 1984 T
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9 MR CHAIRMAN AND MEMBERS OF THE SUBCOMMITTEE, WE AGAIN APPRECIATE THE OPPORTUNITY TO DISCUSS WITH YOU THE ISSUES AND CONCERNS,
REGARDING THE STATUS OF THE LICENSING PROCESS FOR THE DIABLO CANYON NUCLEAR POWER PLANT.
WE LAST DISCUSSED THESE MATTERS WITH YOU NEARLY A YEAR AGO ON MARCH 8, 1983.
MR. CHAIRMAN, IN YOUR LETTER TO ME OF DECEMBER 20 0F LAST YEAR YOU IDENTIFIED AS YOUP PARTICULAR CONCERN "THE STATUS OF THE LICENSING PROCESS AND THE RESULTS OF THE NRC'S REVIEW OF THE DIABLO CANYON DESIGN AND CONSTRUCTION."
FIRST, I WILL DISCUSS THE STATUS OF THE DESIGN VERIFICATION EFFORT; SECONDLY, THE ONGOING HEARING PROCESS WITH RESPECT TO THE FULL POWER LICENSE; AND THIRDLY, THE MATTER OF l
ALLEGATIONS THAT HAVE BEEN RAISED.
DESIGN VERIFICATION PROGRAM THE DESIGN VERIFICATION PROGRAM FOR DIABLO CANYON UNIT 1 HAS ESSENTIALLY BEEN COMPLETED.
THE PROGRAM WAS THE RESULT OF THE
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e PALLADIN0 TESTIMONY.
NRC ORDER IN NOVEMBER OF 1981 WHICH SUSPENDED THE LOW POWEP LICENSE FOR UNIT 1.
IT INCLUDED THE VERIFICATION OF THE SEISMIC DESIGN, REFERRED TO AS PHASE I, AND THE NON-SEISMIC DESIGN, REFERRED TO AS PHASE II.
IT CONSISTED OF TWO COMPLEMEN-TARY EFFORTS:
THE INDEPENDENT DESIGN VERIFICATION EFFORT, CALLED IDVP, WHICH WAS PERFORMED UNDER THE DIRECTION OF AN INDEPENDENT CONTRACTOR (TELEDYNE ENGINEERING SERVICES), AND THE INTERNAL TECHNICAL PROGRAM, CALLED THE ITP, WHICH WAS PERFORMED BY PACIFIC GAS AND ELECTRIC COMPANY WITH THE ASSISTANCE OF THE BECHTEL CORPORATION UNDER THE DIABLO CANYON PROJECT, THE PG&E EFFORT, THAT IS THE ITP, INCLUDED A VERIFICATION OF THE SEISMIC DESIGN OF ALL SAFETY-RELATED STRUCTURES, SYSTEMS, AND COMPON-ENTS; RESOLUTION OF CONCERNS IDENTIFIED BY THE IDVP; AND MODIFICATIONS TO THE PLANT AS NECESSARY.
THE IDVP EFFORT CONSISTED OF A SEISMIC DESIGN VERIFICATION IN SELECTED AREAS AND A NON-SEISMIC DESIGN VERIFICATION OF THREE MAJOR SAFETY-RELATED SYSTEMS.
THE IDVP ALSO
PALLADIN0 TESTIMONY -
PERFORMED AN AUDIT OF QUALITY ASSURANCE PROGRAMS AND THEIR IMPLEMENTATION.
SEMI-MONTHLY REPORTS ON THE STATUS OF BOTH THE IDVP AND PG&E PROGRAM WERE ISSUED, PARTICULARLY FOCUSING ON THE IDENTIFICATION OF NEW CONCERNS.
IN ADDITION, THE IDVP ISSUED IN EXCESS OF 60 INTERIM TECHNICAL REPORTS, CALLED ITRS.
THE REPORTS WERE ISSUED WHEN THE VERIFICATION OF A PARTICULAR ASPECT HAD BEEN SUFFICIENTLY COMPLETED TO ALLOW THE IDVP TO REACH A CONCLUSION.
THE IDVP ISSUED A FINAL REPORT ON ITS EFFORTS IN MAY 1983 WHICH INCLUDED AN EVALUATION OF ALL ERRORS AND THE BASIC CAUSE FOR THESE ERRORS.
PG8E ISSUED SEPARATE FINAL REPORTS FOR PHASE I IN SEPTEMBER 1982 AND PHASE II IN JUNE 1983.
ALL REPORTS WERE AMENDED THROUGH OCTOBER 1983, AND DISTRIBUTED TO ALL PARTIES.
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PALLADING TESTIMONY THE IDVP CONDUCTED ITS VERIFICATION ON THE BASIS OF INFORMATION THAT HAD BEEN PROVIDED BY PG8E.
THE INFORMATION WAS EVALUATED WITH RESPECT TO LICENSING CRITERIA AND COMMITMENTS IN THE FINAL SAFETY ANALYSIS REPORT AND IN OTHER LICENSING DOCUMENTS FOR DIABLO CANYON.
IN EXCESS OF 300 CONCERNS WERE IDENTIFIED BY THE IDVP.
BASED ON FURTHER INFORMATION PROVIDED BY PGRE, LESS THAN EIGHT PERCENT OF THESE CONCERNS WERE CLASSIFIED AS ERRORS.
AN ERROR DESIGNATION MEANS THAT A DESIGN CRITERION WAS NOT MET OR AN OPERATING LIMIT WOULD HAVE BEEN EXCEEDED.
THE RESOLUTION OF AN ERROR REQUIRED A PHYSICAL MODIFICATION, A CHANGE IN OPERATING PROCEDURE, MORE REALISTIC CALCULATIONS, OR RETESTING.
THE DESIGN VERIFICATION EFFORT BY THE IDVP AND PG8E RESULTED IN EXTENSIVEMODIFICATIONS[0THEPLANT.
WHILE SOME OF THOSE CHANGES WEPF. DUE TO THE CONCERNS IDENTIFIED BY THE IDVP, THE MAJORITY WERE THE RESULT OF PGRE'S INTERNAL SEISMIC DESIGN VERIFI-CATION OF ALL SAFETY-RELATED STRUCTURES, SYSTEMS, AND COMPONENTS.
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PALLADIN0 TESTIMONY '
WHENEVER THERE WAS A QUESTION REGARDING THE NEED FOR A MODIFI-CATION, THE PLANT WAS UPGRADED TO ENSURE THE DESIGN BASES F0 THE PLANT WERE MET.
SUCH MODIFICATIONS WERE OFTEN MADE IN LIEU OF 1
1 FURTHER ANALYSES AND EVALUATIONS.
EVEN THOUGH, ANOTHER ANALYSIS OR EVALUATION MIGHT HAVE PROVEN THE MODIFICATIONS UNNECESSARY.
IN MID-1983 THE DESIGN VERIFICATION EFFORTS WERE SUFFICIENTLY COMPLETED FOR OUR STAFF TO EVALUATE THE PROGRAM AND ITS FINDINGS.
THE STAFF'S EVALUATION WAS ISSUED ON AUGUST 5, 1983 AS SUPPLEMENT 18 TO THE SAFETY EVALUATION REPORT.
FURTHER STAFF EVALUATIONS AND RESOLUTION OF CONCERNS IDENTIFIED IN THE REPORT WERE SUBSEQUENTLY ISSUED ON OCTOBER 14 AND ON DECEMBER 23, 1983 AS SUPPLEMENTS 19 AND 20.
i THE NRC STAFF CONCLUDED IN SUPPLEMENT 18:
(1) THAT THE IDVP HAD MET THE REQUIREMENTS AND OBJECTIVES OF THE DESIGN VERIFICATION EFFORT, (2) THAT THE DESIGN VERIFIC/ TION EFFORTS BY THE IDVP AND PG8E HAD
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PALLADIN0 TESTIONY IDENTIFIED ALL SIGNIFICANT DESIGN DEFICIENCIES, AND (3) THAT APPROPRIATE CORRECTIVE ACTIONS HAD BEEN AND WILL BE TAKEN TO ENSURE THAT THE DESIGN OF DIABLO CANYON UNIT 1 CONFORMS TO THE LICENSING CRITERIA.
LICENSING AND HEARING PROCESS THE PREVIOUSLY DISCUSSED LICENSING REVIEW ACTIVITY FOLLOWED A THREE-STEP LICENSING PROCESS. THAT PROCESS WAS PROPOS5D BY PGaE AND APPROVED BY THE COMMISSION IN DECEMBER 1982.
IN THIS PROCESS THE i
REINSTATEMENT OF THE LOW POWER LICENSE AND ISSUANCE OF THE FULL i
POWER LICENSE WERE TO BE ACCOMPLISHED IN THE FOLLOWING STEPS:
STEP 1:
A DECISION REGARDING THE LOADING OF FUEL INTO THE f
i REACTOR VESSEL AND PERFORMANCE OF COLD SYSTEM TESTING.
(THE REACTOR IS IN THE SUBCRITICAL CONDITION, AND THEREFORE NO FISSION PRODUCTS ARE GENERATED).
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PALLADIN0 TESTIMONY STEP 2:
A DECISION REGARDING CRITICALITY AND OPERATION AT A POWER LEVEL UP TO 5 PERCENT.
1 STEP 3:
A DECISION REGARDING THE ISSUANCE OF THE FULL POWER LICENSE.
AT AN OPEN MEETING ON OCTOBER 28, 1983 THE COMMISSION CONSIDERED THE MATTERS RELATED TO THE REINSTATEMENT OF THE LOW POWER LICENSE.
J PRESENTATIONS WERE MADE BY OUR STAFF, PG8E, AND THE JOINT INTER-VENORS.
ON NOVEMBER 8 THE COMMISSION AUTHORIZED PG8E TO COMMENCE THE ACTIVITIES UNDER STEP 1.
PG8E STARTED THE FUEL LOAD OPERATIONS ON NOVEMBER 15 FOLLOWING THE DENIAL BY THE U. S. COURT OF APPEALS OF A STAY REQUESTED BY THE JOINT INTERVENORS.
FUEL LOAD OPERA-TIONS WERE COMPLETED ON NOVEMBER 20 AND THE REACTOR VESSEL HEAD WAS BOLTED DOWN ON NOVEMBER 29. PG8E HAS NOW COMPLETED COLD SYSTEM TESTING.
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PALLADIN0 TESTIMONY.
8-WE HA E CURRENTLY BEFOPE US A REQUEST BY PG8E TO AUTHORIZE TESTING IN THE HOT SHUTDOWN AND HOT STANDBY CONDITION.
SUCH ACTIVITIES ARE VIEWED BY THE STAFF AS AN EXTENSION OF STEP 1 ACTIVITIES SINCE t
THE REACTOR WILL NOT BE PERMITTED TO ACHIEVE CRITICALITY AND FISSION' PRODUCTS WILL NOT BE GENERATED.
SUCH OPERATION WOULD ALLOW FURTHER CHECK-0UT AND TESTING OF SYSTEMS AND COMPONENTS AT EVEVATED TEMPERATURES, INCLUDING A CHECK FOR THERMAL EXPANSION OF PIPING AND EQUIPMENT.
PG&E HAS INFORMED US THAT DIABLO CANYON UNIT 1 IS NOW READY FOR SUCH TESTING ACTIVITIES.
WE HAVE ALSO BEFORE US A REQUEST BY PG&E TO IMPLEMENT STEP 2 0F THIS PROCESS, THAT IS, TO PERMIT CRITICALITY AND LOW POWER OPERATION.
REGARDING THE HEARING PROCESS, THE ATOMIC SAFETY AND LICENSING APPEAL BOARD CONDUCTED A HEARING ON THE REOPENED ISSUE OF DESIGN QUALITY ASSURANCE IN NOVEMBER OF LAST YEAR IN AVILA BEACH, CALIFORNIA.
AT THE HEARING, EVIDENCE ON A NUMBER OF DESIGN-RELATED t
PALLADING TESTIMONY
-9' ISSUES WAS PRESENTED BY OUR STAFF, FG8E, GOVERNOR DEUKMEJIAN AND JOINT INTERVENORS.
ALL PARTIES HAVE FILED PROPOSED FINDINGS WITH THE APPEAL BOARD AND A DECISION IS EXPECTED IN THE NEAR FUTURE.
STATUS OF ALLEGATIONS FINALLY, I NOW WILL DISCUSS THE MATTER OF ALLEGATIONS THAT HAVE BEEN RAISED REGARDING THE DIABLO CANYON PLANT.
AS OF THE END OF 1983, APPROXIMATELY 100 SEPARATE CONCERNS HAD BEEN IDENTIFIED.
THE ALLEGATIONS WERE RECEIVED FROM A VARIETY OF SOURCES, INCLUDING PRIVATE CITIZENS, FORMER AND CURRENT WORKERS AT THE PLANT AND AT THE PGRE OFFICES, NEWS MEDIA, INTERVENORS, AND CONGRESSIONAL OFFICES.
IN SOME CASES, THE SOURCE HAS REMAINED COMPLETELY t
ANONYMOUS; IN OTHERS IT IS KNOWN TO THE NRC WITH ANONYMITY AS REQUESTED BY THE ALLEGER; HOWEVER, IN MOST CASES THE SOURCE HAS BEEN PUBLICLY IDENTIFIED.
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PALLADIN0 TESTIMONY 10 -
WE HAVE INITIATED A CONCERTED EFFORT TO ENSURE THAT THE ALLEGA-TIONS ARE EXAMINED AND EVALUATED IN A TIME FRAME CONSISTENT WITH THE LICENSING DECISIONS ON DIABLO CANYON.
IN LIGHT OF THE NUMEROUS ALLEGATIONS, OUR STAFF ESTABLISHED AN ALLEGATION MANAGEMENT PROGRAM FOR DIABLO CANYON TO COORDINATE BETTER THE ACTIONS BY THE VARIOUS NRC OFFICES.
THE PROGRAM WILL PROVIDE A CLEARER UNDERSTANDING OF EACH ALLEGATION, A DETAI, LED TECHNICAL REVIEW OF THE APPROPRIATE AREA 0F THE ALLEGATION, AND ON-SITE INSPECTIONS AND DISCUSSICNS WITH THE ALLEGER AS NECESSARY.
A STATUS OF THESE EFFORTS AS OF LATE DECEMBER WAS ISSUED AS SAFETY EVALUATION REPORT SUPPLEMENT 21.
I WOULD NOTE THAT A SECOND PART OF THE DOCUMENT WAS ISSUED WITH A LIMITED DISTRIBUTION IN ORDER TO i
PROTECT THE ANONYMITY OF SOME ALLEGERS AND TO ASSURE THAT NRC ONGOING EFFORTS IN ENFORCEMENT AND INVESTIGATION AREAS WOULD NOT l
BE IMPEDED.
WHILE WE CAN STATE THAT THE MAJORITY OF THE ALLEGATIONS HAVE BEEN O
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PALLADIN0 TESTIMONY '
EXAMINED IN SUFFICIENT DETAIL TO ALLOW US TO CONCLUDE THAT THEY DO NOT PRESENT A SIGNIFICANT SAFETY ISSUE OR REQUIRE FIXES OR REPRESENT A SUBSTANTIAL BREAKDOWN OF MANAGEMENT OR QUALITY CONTROL SYSTEMS.
WE NOTE HOWEVER, THAT THESE ARE THE ALLEGATIONS THAT WERE MOST AMENABLE TO RESOLUTION.
HANY OF THE REMAINING ALLEGATIONS HAVE BEEN PARTIALLY EXAMINED,
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IHBV SNVOLVE MORE COMPLEX AND DIFFICULT ISSUES, AS WELL AS NEW i
ALLEGATIONS WE CONTINUE TO RECEIVE.
WE HAVE SO FAR NOT DETERMINED WHETHER ANY SIGNIFICANT SAFETY ISSUE OR SUBSTANTIAL BREAKDOWN OF MANAGEMENT OR QUALITY CONTROL SYSTEMS WILL EMERGE FROM THE CONTINUING EVALUATION OF THE ALLEGATIONS.
THESE ALLEGATIONS INVOLVE SUCH ISSUES AS SMALL BORE PIPING, ANCHOR BOLT INSTALLATION, CONSTRUCTION RECORDS CONTROL, INSPECTOR QUALIFICA-TIONS AND HARASSMENT OF PERSONNEL.
CUR STAFF WILL COMPLETE ITS EXAMINATION OF MOST OF THESE ALLEGATIONS AND DRAW A CONCLUSION IN THE NEXT FEW WEEKS.
o PALLADIN0 TESTIMONY.
BASED ON THE ALLEGATIONS ALREADY REVIEWED THE STAFF IDENTIFIED SOME ACTIONS THAT WE BELIEVE SHOULD BE COMPLETED PRIOR TO A DECISION REGARDING AUTHORIZING CRITICALITY, AND SEVERAL OTHERS HAVE BEEN IDENTIFIED FOR COMPLETION PRIOR TO AUTHORIZING OPERATION ABOVE 5 PERCENT POWER.
THERE MAY BE ADDITIONAL ACTIONS IDENTIFIED AS THE STAFF COMPLETES ITS EXAMINATION.
IN CLOSING, I WANT TO ASSURE YOU THAT, WHILE PG&E IS EXPECTED TO BE READY TO PROCEED IN OPERATION TO CRITICALITY SHORTLY, WE WILL NOT AUTHORIZE ANY SUCH ACTIVITY UNTIL WE ARE SATISFIED THAT THERE IS REASONABLE ASSURANCE THAT THE HEALTH AND SAFETY OF THE PUBLIC IS ADEQUATELY PROTECTED.
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pVESTION 1.
WHAT IS THE NRC TIMETABLE FOR COMPLETION OF THE REVIEWS AT DIABLO CANYON?
ANSWER.
THE PLANT,.HAS COMPLETED MODE 6 AND 5 ACTIVITIES AND WILL BE READY FOR MODE 4 AND 3 ACTIVITIES DURING THE WEEK OF JANUARY 23, 1984.
ASSUMING NRC APPROVAL FOR MODE 4 AND 3 DURING THE WEEK OF JANUARY 23, 1984, THE PLANT IS EXPECTED TO BE READY TO PROCEED TO INITIAL CRITICALITY DURING THE WEEK OF FEBRUARY 13, 1984, THE STAFF S REVIEW EFFORT REGARDING ALLEGATIONS IS CONTINUING AND STATUS REPORTS WILL BE PROVIDED TO THE COMMISSION PRIbR TO DECISIONS.
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DOES THE COMMISSIOf INTEND TO MAKE A DECIS10t.
ON LOW-POWER OPERATION PRIOR TO THE APPEAL BOARD DECISION ON DESIGN QUALITY ASSURANCE?
DECIDED THE COMMISSION HAS NOT At SWER:
WHETHER TO AWAIT THE APPEAL BOARD DECISION ON DESIGN QUALITY ASSURANCE BEFORE DETERMINING WHETHER TO AUTHORIZE CRITICALITY AND LOW-POWER TESTING.
IN NOVEMBER 1983, WHEN THE COMMISSION VOTED TO AUTHORIZE FUEL LOADING AND CERTAIN PRECRITICAL TESTS AT DIABLO CANYON, COMMISSIONER ASSELSTINE INDICATED THAT HE WOULD NOT BE PREPARED T.0 CONSIDER AUTH, RIZING CRITICALITY AND 0
LOW-POWER TES. TING UNTIL THE APPEAL BOARD DECISION IS ISSUED.
THE COMMISSION DID NOT l
DECIDE THIS ISSUE AT THAT TIME, STATING ONLY l
THAT WE "MAY WELL CHOOSE TO AWAIT" THE APPEAL BOARD DECISION BEFORE PROCEEDING.
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i QUESTION 3.
CAN YOU IDENTIFY SOME OF THE MODIFICATIONS TO THE PLANT NECESSARY TO ALLOW THE PLAflT TO GO TO LOW POWER OPERATION?
TO FULL POWER OPERATIOH?
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- ANSWER, i
ALL MODIFICATIONS NECESSARY TO RESOLVE CONCERNS REGARDING STRUCTURES, SYSTEMS AND COMPONENTS NECESSARY TO BRING THE PLANT BE ' COMPLETED PRIOR TO TO SAFE SHUTDOWN WILL BE QLQUIRED TO AUTHORIZATION TO OPERATE TOW POWER.
EXAMPLES OF THESE WOULD I
BE MODIFICATIONS TO STRUCTURAL STEEL SUPPORTS, PIPE HANGER 1
SUPPORTS, HEATING VENTILATION AND AIR CONDITION SUPPORTS, AND l
I RACEWAY SUPPORTS, MOST OF THESE MODIFICATIONS ARE N0!>! COMPLETE AND ALL MODIFICATIONS INSIDE CONTAINMENT ARE REQUIRED TO BE l
COMPLETED PRIOR TO INITIAL CRITICALITY.
t HE O Y ITEMS REQUIRED PRIOR TO AUTH0 lZATION FOR FULL POWER I
OPERATION INVOLVE DDITIONAL INFORMATION AND EVALUATION IN REGARD TO THE TURBINE BUILDING, CONTA: MENT ANNULU'i STRUCTURE, LARGE BORE PIPING AND JET IMPINGEMENT i0 ADS ON PIPING INSIDE l
l; CONTAINMENT.
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6 OUESTION 4.
AT THE TIME OF OUR LAST HEARING (MARCH'8, 1983)
THE PROJECTED DATE FOR LOW POWER OPERATION WAS JULY 1983.
CAN YOU TELL ME THE REASONS FOR THE DELAYS IN THE SCHEDULES?
ANSWER.
THE DELAY IN PG&E SCHEDULE, FROM JULY 1983 TO FEBRUARY 1984, TO GO CRITICAL AND CONDUCT LOW POEER OPERATION WAS LARGELY THE RESULT OF THE EXPANSION OF THE PG8E'S EVALUATION / MODIFICATION EFFORT.
THIS EXPANSION WAS DUE TO EXTENSIVE REVISIONS IN FLOOR 4
. RESPONSE SPECTR)M FOR THE CONTAINMENT ANNULUS STEEL STRUCTURE.
THEREVISIONSWERECAUSEDBYTHESTIFFENINGOFTHATSTRUdTUREAND REQUIRED ADDITIONAL ANALYSES., DESIGN AND MODIFICATION.
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KILL THE COMMIS3:M: CONSIDER THE EFFECT OF A MAJOR EAF.THQUAKE ON THE EMERGEMCY RESPONSE PLAN AT DIABLO?
ANSWER:
IN 1981, DURING ITS REVIEW OF THE LICENSING PROCEEDING FOR SAN ONOFRE, ANOTHER PLANT S'ITUATED IN CALIFORNIA, THE COMMISSION DETERMINED THAT REVIEW OF THE EFFECTS OF A MAJOR EARTHQUAKE ON EMERGENCY RESPONSE PLANS WAS MORE APPROPRIATELY UNDERTAKEN ON A GENERIC, RATHER THAN CASE-BY-CASE, BASIS.
SUCH GENERIC CONSIDERATION HAS NOT YET BEEN FORMALLY INITIATED.
PG&E HAS FACTORED CONSIDERATION OF EARTHQUAKES INTO THEIR EMERGENCY RESPONSE PLAN AT DIABLO CANYON AND
-THE NRC STAFF HAS REVIEWED AND APPROVED THAT PLAN.
HOWEVER, THE ISSUE WAS EXCLUDED FROM THE HEARING ON THE BASES OF THE COMMISSION'S DECISION IN SAN ONOFRE.
i THE COMMISSION IS PRESENTLY CONSIDERING HOW TO PROCEED WITH THIS ISSUE IN THE CONTEXT OF THE DIABLO CANYON FULL-POWER LICENSE PROCEEDING.
I MIGHT ADD THAT ACCORDING TO COMMISSION REGULATIONS, OFFSITE EMERGENCY RESPONSE PLANS ARE NOT NECESSARY AT THE FUEL-LOADING AND LOW-POWER TESTING STAGE BECAUSE
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OF THE EXTREMELY LOU RISI' 0F Af? ACCIDEl!T 7:./.T f
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COULD CAUSE AN OFFSITE RELEASE OF RADIATICt;.
THIS LOW RISK STEMS FROM THE EXTREMELY SPALL RADI0 ACTIVE FISSION PRODUCT I!!VENTORY, THE LONGER TIME PERIOD IN WHICH TO IDENTIFY AND RESPOND TO PROBLEMS, AND THE REDUCED DEMAhD I
ON THE REACTOR AND THE REACTOR SAFETY SYSTEMS INHERENT IN LOW-POWER OPERATIONS.
IN SUM PG&E AND THE NRC STAFF HAVE CONSIDERED THE POTENTIAL EFFECT OF AN EARTHQUAKE ON EMERGEliCY PLANNING.
THE COMMISSI N IS COGNIZANT OF THE ISSUE AND HAS NOT YE,T DETERMINED HOW ULTIMATELY TO REVIEW IT.
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QUESTION 6.
YOUR TESTIMONY (PAGE 3) INDICATES THAT PGaE ISSUED SEPARATE FINAL REPORTS FOR PHASE I IN SEPTEMBER 1982 AND PHASE 11 IN JUNE 1983.
THESE REPORTS WERE AMENDED IN OCTOBER 1983.
WHAT WERE THE REASONS FOR AND NATURE OF THE AMENDMENTS?
ANSWER.
PGaE BEGAN TO ISSUE ITS FINAL REPORT FOR ITS PHASE I ACTIVITIES (THAT IS, SEISMIC DESIGN) IN SEPTEMBER 1982 ON THOSE EFFORTS THAT WERE COMPLETED AT THAT TIME., AS FURTHER EFFORTS WERE COMPLETED BY PGaE THIS FINAL REPORT WAS UPDATED."
MAKING THE " FINAL REPORT" A "LIVING DOCUMENT."
IN ADDITION, THE REPORT WAS AMENDED TO REFLECT REVISIONS IN ANALYSES RESULTING FROM ONGOING INTERACTIONS WITH THE.IDVP AND WITH THE NRC.
THE REPORT WAS A DOCUMENT THAT REFLECTED THE STATUS OF THE PG8E EFFORT.
THE PG8E PHASE II (NONSEISMIC EFFORT) REPORT WAS ISSUED IN JUNE 1983.
A SINGLE UPDATE WAS MADE IN OCTOBER 1983.
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O QUESTION 7.
ALSO ON PAGE 3, YOU INDICATE THAT THE "IDVP CONDUCTED ITS VERIFICATION ON THE BASIS OF INFORMATI0k! PROVIDED BY PE8E.
IS IT LOGICAL FOR THE IDVP TO HAVE BEGUN ITS REVIEW ON THE BASIS OF INFORMATION SUPPLIED TO THE IDVP BY PGaE RATHEPJ THAN DETERMINING WHAT INFORMATION IT SHOULD HAVE?
ANSWER.
AFTER THE IDVP SELECTED A STRUCTURE, SYSTEM OR COMPONENT FOR ITS INDEPENDENT DESIGN VERIFICATION IT REQUESTED PGaE TO PROVIDE
. SPECIFIC AND DETAILED INFORMATION ON SELECTED ASPECTS.. THIS INFORMATION WAS PROVIDED IN THE FORM OF DETAILED DESIGN AND CALCULATIONAL PACKAGES.
THE IDVP REQUESTED ANY FURTHER INFORMATION FOR ITS EVA1.UATION WHEN NECESSARY.
THIS INFORMATION FORMED THE BASIS FOR THE IDVP EVALUATIONS.
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QUESTION 8.
To DATE, HOW MANY ALLEGATIONS HAS THE NRC RECEIVED CONCERNING DIABLO CANYON?
IS THIS A GREATER OR LESSER NUMBER AT OTHER PLANTS?
WHAT CONCLUSIONS CONCERNING THE QA PROGRAM CAN THE NRC DRAW FROM SUCH A LARGE NUMBER OF ALLEGATIONS?
ANSWER.
AS OF NOW WE HAVE OVER 150 ALLEGATIONS ON DIABLO CANYON. MANY OF THESE WERE RECEIVED IN JANUARY, AND AT THE TIME OF THE ISSUANCE OF SSER 21 WE HAD APPROXIMATELY 100 ALLEGATIONS.
IT IS HARD TO COMPARE THIS NUMBER OF ALLEGATIONS WITH THE NUMBER AT OTHER PLANTS BECAUSE OF THE VARIATIONS IN THE WAY ALLEGATIONS ARE FORMED.
FOR EXAMPLE, AT THE MIDLAND AND COMANCHE PEAK
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FACILITIES, WE HAVE BETWEEN 30 AND 50 ALLEGATIONS, AND AT THE ZIMMER FACILITY WE HAVE IN EXCESS OF 1,200 ALLEGATIONS.
ONE CANNOT DRAW A CONCLUSION REGARDING THE EFFECTIVENESS OF THE QA PROGRAM AT A FACILITY FROM THE NUMBER OF ALLEGATIONS THAT WERE RECEIVED.
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ARE THERE SUFFICIE!!T EXPERIEt4CED CPERATORS FO?
DIABLO? -
ANSWER.
THE STAFF AND THE COMMISSION ARE CONCERNED ABOUT THE AMOUNT OF COMMERCIAL OPERATING EXPERIENCE ON A COMPARABLE REACTOR OF THE DIABLO CANYON OPERATING STAFF, AND ARE CONSIDERING WHAT ADDITIONAL STEPS PG8E SHOULD BE REQUIRED TO TAKE TO ALLEVIATE OUR CONCERNS.
AMONG THE ALTERNATIVES UNDER CONSIDERATION IS TO REQUIRE A MORE DELIBERATE AND PHASED APPROACH TO FULL POWER OPERATION OF THE REACTOR, 4
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- JESTION 10, WHAT IS THE TAU EFFECT?
- ANSWER, IHE " TAU EFFECT" IS A PHRASE WHICH WAS EMPLOYED BY DR. N, NEWMARK,
i TO SYMBOLIZE A PHENOMENON BY WHICH THE EARTHQUAKE MOTION OF HIGHER FREQUENCIES WERE REDUCED IN LARGE STRUCTURES, IT IS GENERALLY RECOGNIZED THAT GROUND MOTIONS AT ANY INSTANT OF TIME VARY BOTH IN THE DIRECTION CONSIDERED AND IN THE TRANSVERSE DIRECTION.
ALTHOUGH DR, NEWMARK USED THIS TERM TO REPRESENT THE TIME NEEDED FOR A SEISMIC WAVE PROPAGATING HORIZONTALLY TO CROSS THE EFFECTIVE WIDTH OF A BUILDING, IT APPARENTLY ENCOMPASSES SEVERAL DIFFERENT AND TECHNICALLY COMPLEX PHYSICAL PHENO.MENA.
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i NOTES ON " TAU" BOTH THE LICENSING BOARD AND THE APPEAL BOARD GAVE THE QUESTION OF THE "TA0 EFFECT" THOROUGH AND EXTENSIVE CONSID-ERATION.
BOTH BOARDS RENDERED FORMAL DECISIONS APPROVING THE USE OF THE " TAU EFFECT" IN THE SEISMIC DESIGN CRITERIA FOR DIABLO CANYON.
THE COMMISSION ITSELF GAVE EXTENSIVE CONSIDERATION TO THE MATTER AND DETERMINED THAT FORMAL COMMISSION REVIEW WAS NOT NECESSARY.
AS A SEPARATE MATTER, THE NRC'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS, THE
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ACRS, REVIEWED THE SEISMIC DESIGN CRITERIA UTILIZED AT DIABLO CANYON, AND FOUND AN ACCEPTABLE LEVEL OF SAFETY.
AS FOR THE USE OF " TAU," THE ACRS DECIDED ONLY THAT ITS USE WAS EXTRAORDINARY, THAT IT DEPENDED UPGN THE EXPERIENCE A'ND ENGINEERING JUDGMENT OF A RECOGNIZED EXPERT IN THE FIELD AND COULD NOT BE SPECIFICALLY DUPLICATED, AND THAT IT MERITED REVISITING IN THE N' EAR FUTURE.
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(;lll TESTfMONY OF NUNZIO J. PALLADIN0 CHAIRMAN U. S. NUCLEAR REGULATORY COMMISSION BEFORE THE SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT '
COMMITTEE ON INTERIOR AND INSULAR AFFAIRS UNITED STATES HOUSE OF REPRESENTATIVES ON DIABLO CANYON LICENSING CONCERNS JANUARY 24, 1984 i
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2 MR, CHAIRMAN AND MEMBERS OF THE SUBCOMMITTEE, WE AGAIN APPRECIATE THE OPPORTUNITY TO DISCUSS WITH YOU THE ISSUES AND CONCERNS RELATED TO THE DESIGN, CONSTRUCTION AND OPERATION OF UNITS 1 AND 2 0F THE DIABLO CANYON NUCLEAR POWER PLANT, WE LAST DISCUSSED 4
THESE MATTERS WITH YOU NEARLY A YEAR AGO ON MARCH 8, 1983.
MR, CHAIRMAN, IN YOUR LETTER TO ME OF DECEMBER 20 0F LAST YEAR YOU IDENTIFIED AS YOUR PARTICULAR CONCERN "THE STATUS OF THE LICENSING PROCESS AND THE RESULTS OF THE NRC'S REVIEW OF THE DIABLO CANYON DESIGN AND CONSTRUCTION."
WE WILL ADDRESS YOUR i
CONCERN IN TERMS OF THREE SEPARATE BUT RELATED ELEMENTS.
FIRST, THE HISTORY AND STATUS OF THE SUSPENDED LOW POWER LICENSE FOR UNIT 1, THE ASSOCIATED DESIGN VERIFICATION EFFORT AND ITS APPLICATION TO UNIT 2; SECONDLY, THE ONGOING HEARING PROCESS WITH RESPECT TO THE FULL POWER LICENSES FOR UNIT 1 AND UNIT 2; AND THIRDLY, THE MATTER OF ALLEGATIONS AND CONCERNS THAT HAVE BEEN RAISED REGARDING THE DIABLO CANYON PLANT, a
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PALLADING TESTIMONY -
FOR PURPOSES OF BACKGROUND I WOULD LIKE TO BRIEFLY SUMMARIZE THE EVENTS DURING THE LAST TWO YEARS REGARDING THE REINSTATEMENT OF THE UNIT 1 LOW POWER LICENSE.
THE NRC ISSUED ON SEPTEMBER 22, 1981 OPERATING LICENSE WHICH AUTHORIZED PACIFIC GAS & ELECTRIC COMPANY TO LOAD FUEL IN DIABLO CANYON UNIT 1, GO CRITICAL AND PERFORM LOW POWER TESTING AT POWER LEVELS UP TO 5 PERCENT OF RATED FULL POWER.
SHORTLY THERAFTER THE LICENSEE INFORMED THE NRC OF WHAT HAS BECOME KNOWN AS THE MIRROR IMAGE OR DIAGRAM ERROR.
ON NOVEMBER 19, 1981 WE ISSUED AN ORDER SUSPENDING THE AUTHORIZA-TION TO LOAD FUEL AND REQUIRING PG8E TO UNDERTAKE, BY AN INDEPENDENT ORGANIZATION, A DESIGN VERIFICATION PROGRAM FOR SEISMIC, SERVICE-RELATED DESIGN ACTIVITIES.
IN ADDITION, THE NRC 1 - _. ;. _
PALLADIN0 TESTIMONY STAFF, REQUIRED THAT SUCH AN EFFORT ALSO BE PERFORMED FOR
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NON-SEISMIC, SERVICE-RELATED DESIGN ACTIVITIES.
THE FIRST EFFORT, WHICH BECAME KNOWN AS PHASE I, WAS TO BE COMPLETED PRIOR TO REINSTATEMENT OF THE SUSPENDED AUTHORIZATION TO LOAD FUEL.
SATISFACTORY COMPLETION OF THE SECOND EFFORT, WHICH BECAME KNOWN AS PHASE 11 WAS A REQUISITE FOR A FULL POWER LICENSE DECISION.
BOTH EFFORTS WERE TO BE CONDUCTED BY SELECTING A SAMPLE OF SAFETY-RELATED STRUCTURES, SYSTEMS AND COMPONENTS FOR VERIFICATION.
.i THIS DESIGN VERIFICATION EFFORT WAS INITIATED IN LATE 1981, THE PROGRAM CONSISTED OF TWO COMPLIMENTARY EFFORTS, NAMELY, THE INDEPENDENT DESIGN VERIFICATION PROGRAM (IDVP) UNDER THE DIRECTION OF TELEDYNE ENGINEERING SERVICES AS THE IDVP MANAGER AND A SEPARATE VERIFICATION EFFORT UNDER THE INTERNAL TECHNICAL
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PALLADIN0 TESTIMONY.
PROGRAM (ITP) CONDUCTED BY PGRE' DIABLO CANYON PROJECT (DCP)
ORGANIZATION WHICH INCLUDED EXTENSIVE PROFESSIONAL AND MANAGEMENT l
PARTICIPATION BY THE BECHTEL CORPORA-TION.
IN APPROXIMATELY MID-1982 THE IDVP'HAD IDENTIFIED A NUMBER OF CONCERNS OF SUCH A NATURE THAT THE DIABLO CANYON PROJECT DECIDED IT WOULD BE MORE EFFECTIVE TO INITIATE A A PG8E INTERNAL VERIFICATION EFFORT THAT WOULD ENCOMPASS THE SEISMIC DESIGN OF ALL SAFETY-RELATED STRUCTURES, SYSTEMS, AND COMPONENTS.
THIS EXPANSION FROM A SAMPLING PROCESS BY THE IDVP TO A COMPLETE REVIEW AND ANALYSIS, BY PG8E INCLUDING MODIFICATIONS AS I
NECESSARY, WAS THEN FOLLOWED BY A SAMPLE VERIFICATION OF THE COMPLETED EFFORT BY THE IDVP.
FOR THE NON-SEISMIC DESIGN VERIFICATION EFFORT, THE IDVP SELECTED AS A SAMPLE THREE MAJOR l
l SAFETY-RELATED SYSTEMS WHICH COVERED ALL ENGINEERING DISCIPLINES.
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PALLADIN0 TESTIMONY 5-IN SEPTEMBER 1982 THE VERIFICATION EFFORT WAS EXPANDED BY PG8E BY i
INCLUDING A QUALITY ASSUPANCE AUD!T OF CERTAIN CONSTRUCTION ACTIVITIES, IN DECEMBER 1982 PG8E PROPOSED A THREE-STEP LICENSING PROCESS FOR DIABLO CANYON UNIT 1 WHICH WAS APPROVED BY THE COMMISSION, IN THIS THREE-STEP PROCESS THE REINSTATEMENT OF THE LOW POWER LICENSE WAS TO BE ACCOMPLISHED IN TWO STEPS:
STEP 1 TO AUTHORIZE THE LOADING OF FUEL INTO THE REACTOR VESSEL AND TO PERFORM COLD SYSTEM TESTING, THAT IS THE REACTOR IS IN THE SUBCRITICAL CONDITION AND THEREFC9E NO FISSION PRODUCT IS GENERATED, t
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STEP 2 TO AUTHORIZE CRITICALITY AND OPERATION AT A POWER LEVEL UP TO 5 PERCENT, THAT IS COMPLETE REINSTATEMENT OF THE SUSPENDED LOW POWER LICENSE.
THE FULL POWER LICENSE DECISION WOULD BE STEP 3 AFTER COMPLETION OF THE PHASE II ACTIVITIES I.E.,
AND MEETING ALL OTHER PERTINENT l
REQUIREMENTS LICENSING.
THROUGHOUT THE DESIGN VERIFICATION EFFORT THE IDVP AND PG8E 4
REPORTED TO THE NRC IN SEMI-MONTHLY REPORTS ON THE STATUS OF THEIR ACTIVITIES, IN PARTICULAR ON THE IDENTIFICATION OF NEW CONCERNS.
IN ADDITION, THE IDVP ISSUED IN EXCESS OF 60 INTERIM TECHNICAL REPORTS (ITRS) AND CERTAIN OTHER REPORTS ON QA 4
AUDITS ISSUED PRIOR TO APRIL 1982.
WHENEVER THE VERIFICA-t TION OF A PARTICULAR DESIGN ASPECT OR PROGRAM EVALUATION HAD
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PALLADIN0 TESTIMONY 7-BEEN SUFFICIENTLY COMPLETED TO ALLOW THE IDVP TO REACH A F
CONCLUSION AN ITR WAS ISSUED ON THAT ASPECT.
THE NEED FOR.
THESE ITRS AROSE BECAUSE OF OUR SPECIFIC REQUIREMENT FOR INDEPENDENCE BETWEEN THE IDVP AND PG8E PRIOR TO ANY j
CONCLUSIONS BY THE IDVP.
THE IDVP ISSUED A FINAL REPORT FOR THE DESIGN VERIFICATION EFFORT FOR WHICH INCLUDED AN EVALUATION OF ALL DESIGN ERRORS WHICH I WILL DISCUSS SHORTLY, AND THE BASIC CAUSE FOR THESE ERRORS.
THE REPORT WAS ISSUED AND AMENDED FROM MAY 1983 TO OCTOBER 1983.
PG8E PROVIDED FINAL REPORTS FOR ITS ACTIVITIES UNDER PHASE I AND i
PHASE II WHICH WERE ISSUED AND AMENDED FROM SEPTEMBER 1982 TO i
OCTOBER 1983.
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PALLADINO TESTIMONY '
ALTHOUGH THE DESIGN VERIFICATION EFFORTS WERE STILL ONGOING, THE NRC DETERMINED IN MID 1983 THAT THE PROGRAMS, BOTH THE IDVP AND THE ITP, WERE SUFFICIENTLY COMPLETE FOR THE STAFF TO PREPARE A SAFETY EVALUATION OF THE DESIGN VERIFICA-TION PROGRAM AND ITS FIN' DINGS.
THE. STAFF EVALUATION WAS ISSUED ON AUGUST 5, 1983'AS A SUPPLEMENT TO THE STAFF'S SAFETY EVALUATION REPORT.
FURTHER STAFF EVALUATION AND RESOLUTION OF CONCERNS IDENTIFIED IN THIS REPORT SUBSEQUENTLY ISSUED ON OCTOBER 14, 1983 AND ON DECEMBER 23, 1983 AS ADDITIONAL SUPPLEMENTS.
BEFORE PRESENTING THE STAFF'S CONCLUSIONS FROM AN SAFETY EVALUATION I WILL BRIEFLY DISCUSS THE DESIGN VERIFICATION PROGRAM i
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METHODOLOGY EMPLOYED.
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THE IDVP CONDUCTED ITS INITIAL DESIGN VERIFICATION ON THE BASIS OF INFORMATION ON A PARTICULAR STRUCTURE, SYSTEM, OR COMPONENT 1
THAT HAD BEEN PROVIDED BY THE LICENSEE.
INFORMATION WAS I
EVALUATED WITH RESPECT TO THE LICENSING CRITERIA AND COMMITMENTS AS THEY ARE STATED IN THE FINAL SAFETY ANALYSIS REPORT AND IN ANY j
OTHER LICENSING DOCUMENTS FOR DIABLO CANYON.
THIS VERIFICATION EFFORT WAS PERFORMED BY THE IDVP ON THE BASIS OF INFORMATION PROVIDED BY PG8E BUT WITHOUT ANY INTERACTION WITH PG8E.
i DURING THIS INITIAL VERIFICATION, THE IDVP RAISED MANY QUESTIONS AND CONCERNS.
FOR EACH AN ERROR OR OPEN ITEM, CALLED E0lS, FILE WAS ESTABLISHED, MAINTAINED AND REPORTED IN SEMI-MONTHLY REPORTS.
s THESE E0lS FALL INTO THREE BROAD CATEGORIES.
SOME E0lS WERE THE RESULT OF INSUFFICIENT INFORMATION OR OF A MISUNDERSTANDING BY l
THE IDVP.
THEY WERE RESOLVED ON THE BASIS OF ADDITIONAL O
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PALLADIN0 TESTIMONY ~
a INFORMATION PROVIDED BY THE LICENSEE, OTHERS WERE COMBINED WITH ONE OF THE TWO NEXT CATEGORIES.
THE SECOND TYPE ARE IDENTIFIED AS AN " ERROR".
THIS MEANS THAT A DESIGN CRITERION OR AN OPERATING LIMIT OF A SAFETY-RELATED STRUCTURE, SYSTEM OR COMPONENT IS EXCEEDED.
THE RESOLUTION REQUIRED A PHYSICAL MODIFICATION OR CHANGE IN OPERATING" PROCEDURE RESOLUTION OR WAS POSSIBLE BY MEANS OF MORE REALISTIC CALCULATIONS OR RETESTING.
THESE ERRORS THEMSELVES VARY GREATLY IN SIGNIFICANCE, SOME ADDRESSING ONLY A SINGLE DEFICIENCY, OTHERS ENCOMPASSING A NUMBER OF CONCERNS RELATED TO A STRUCTURE, SUCH AS THE ERROR WHICH PERTAINS TO THE ENTIRE SEISMIC VERIFICATION EFFORT OF THE CONTAINMENT.
THE THIRD TYPE OF ERRORS INCLUDES "0BSERVATIONS",
IN WHICH INCORRECT ENGINEERING OR INSTALLATION OF SAFETY RELATED O
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PALLADINO TESTIMONY 11 -
F EQUIPMENT WAS FOUND BUT WITHOUT EXCEEDING LICENSING CRITERIA OR 1-OPERATING LIMITS.
CORRECTIVE ACTION WAS TAKEN BY PG&E REGARDING I
THE SECOND AND THIRD TYPE.
DURING THE COURSE OF THE IDVP, THAT IS THROUGH DECEMBER 1983, A TOTAL OF 329 E01 FILES HAD BEEN OPENED, INCLUDING THOSE THAT RESULTED FROM THE QA AUDITS. A RESOLUTION FOR ALL OF THESE HAS BEEN ACHIEVED, APPROXIMATELY 50 PERCENT FALL INTO THE FIRST I
TYPE; 7 PERCENT WERE CLASSIFIED AS ERRORS, AND 44 PERCENT WERE OBSERVATIONS.
i THE STAFF IDENTIFIED IN ITS SAFETY EVALUATION REPORT A NUMBER OF CONCERNS THAT REQUIRED FURTHER ANALYSIS MODIFICATION OR DOCUMENT-ATION BY THE IDVP OR PG8E NOTWITHSTANDING THESE ITEMS OF INCOMPLETNESS, THE STAFF CONCLUDED THAT THE IDVP HAD MET THE I
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PALLADIN0 TESTIMONY PROGRAMMATIC REQUIREMENTS AND OBJECTIVES OF THE DESIGN VERIFICA-TION EFFORT AS DIRECTED BY OUR ORDER AND THE NRC STAFF LETTER OF NOVEMBER 19, 1981.
THE STAFF CONCLUDED THAT THE DESIGN VERIFICATION EFFORTS BY THE IDVP AND PG8E IDENTIFIED ALL SIGN-IFICANT DESIGN DEFICIENCIES AND THAT APPROPRIATE CORRECTIVE ACTIONS HAD BEEN AND WILL BE TAKEN TO ENSURE THAT THE DESIGN OF DIABLO CANYON UNIT 1 CONFORMS TO THE LICENSING CRITERIA.
THE IDVP AND THE PG8E ADDRESSED IN THEIR FINAL REPORTS THE QUESTION OF A BASIC CAUSE FOR THE DESIGN DEFICIENCIES THAT HAD BEEN IDENTIFIED.
AMONG OTHER FACTORS THEY IDENTIFIED THE l
PROLONGED DESIGN AND CONSTRUCTION PHASE FOR THE DIABLO CANYON PLANT, INCLUDING A COMPLETE REDESIGN AS A RESULT OF REVISES i
SEISMIC DESIGN REQUIREMENTS NORMALLY REFERED TO AS THE HOSGRI i
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PALLADINO TESTIMONY 13 -
a EVENT, THE TRANSFER OF LARGE AMOUNT OF INFORMATION ACROSS DESIGN INTERFACES WITHIN PG8E AND BETWEEN PG8E AND ITS CONTRACTORS, AND THE DOCUMENTATION AND INTERPRETATION OF DESIGN REQUIREMENTS.
THE STAFF CONCLUDED THAT, MORE FUNDAMENTALLY, THE MAJORITY OF THE DEFICIENCIES CAN BE ATTRIBUTED TO THE FAILURE OF PGRE MANAGEMENT TO RECOGNIZE, AT THE TIME OF THE HOSGRI REEVALUATION, THE SIGNIFICANCE OF THE REVISED SEISMIC DESIGN REQUIREMENTS AND THE ATTENDANT NEED TO IMPLEMENT A RIGOROUS AND WELL CONTROLLED DESIGN EFFORT.
ASIDE FROM THE CONCLUSIONS AND RECOMMENDATIONS PRESENTED BY OUR OWN STAFF IN ITS SUPPLEMENTS TO THE SAFETY EVALUATION REPORT AND IN MEETINGS, WE HAVE DISCUSSED ALL MATTERS RELATED TO THE REINSTATEMENT OF THE LOW POWER LICENSE WITH PGRE AND WITH THE
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i JOINT INTERVENORS AND GOVERN 0k DUKMEJIAN OF CALIFORNIA WHO ARE PARTIES TO THE DIABLO CANYON LICENSING PROCEEDING.
ON NOVEMBER 8, 1983 WE AUTHORIZED PG8E TO COMMENCE WITH THE ACTIVITIES UNDER STEP 1 AS I DISCUSSED EARLIER, THAT IS, FUEL LOADING AND PRECRITICALITY TESTING.
I WOULD NOTE HERE THAT OUR ORDER SPECIFICALLY REFERS TO OPERATIONAL MODES 6 AND 5 WHICH ARE, RESPECTIVELY, (RE)-FUELING AND COLD SYSTEM TESTING, THAT IS THE AVERAGE REACTOR COOLANT TEMPERATURE IS BELOW 200*F.
THE LICENSEE
. STARTED THE FUEL LOAD OPERATIONS ON NOVEMBER 15, 1983 FOLLOWING THE DENIAL BY THE U. S. COURT OF APPEALS ON THAT DATE FOR A REQUEST FOR A STAY BY THE JOINT INTERVENORS.
FUEL LOAD OPERATIONS WERE COMPLETED ON NOVEMBER 21, 1983 THE REACTOR VESSEL HEAD WAS BOLTED DOWN ON NOVEMBER 1983, AND THE LICENSEE HAS 4
8 SINCE BEEN CONDUCTING COLD SYSTEM TESTING IN OPERATIONAL MODE 5.
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WE HAVE CURRENTLY BEFORE US A REQUEST BY THE LICENSEE AND A RECOMMENDATION BY OUR STAFF TO FURTHER AUTHORIZE ACTIVITIES 1
UNDER OPERATIONAL MODE 4 (HOT SHUT-DOWN) AND MODE 3 (HOT STANDBY) t DURING WHICH THE AVERAGE REACTOR COOLANT TEMPERATURE CAN BE INCREASED TO 350*F.
IN BOTH MODES THE REACTOR WILL REMAIN SUBCRITICAL AND NO FISSION PRODUCTS WILL BE GENERATED.
OPERATION IN THESE MODES WOULD ALLOW FURTHER HOT FUNCTIONAL TESTING AND i
CHECK-0UT OF SYSTEM AND COMPONENTS UNDER EVEVATED TEMPERATURES AND WILL INCLUDE A CHECK FOR THERMAL EXPANSION OF PIPING AND EQUIPMENT.
THE LICENSEE HAS INFORMED US THAT DIABLO CANYON UNIT l
1 HAS BEEN READY FOR MODE 4 AND MODE 3 ACTIVITIES SINCE THE 15TH 0F THE MONTH.
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PALLADIN0 TESTIMONY '
WE HAVE ALSO BEFORE US AT THIS TIME A REQUEST BY THE LICENSEE i
AND A RECOMMENDATION BY OUR STAFF TO IMPLEMENT STEP 2 0F THE THREE-STEP LICENSING PROCESS, THAT IS FULL RESTORATION OF THE SUSPENDED LOW POWER LICENSE.
THE LICENSEE INFORMED US THAT UNIT 1 CRITICALITYIS EXPECTED APPROXIMATELY TWO WEEKS AFTER MODE 4 AND 3 OPERATION.
WE HEARD FROM THE OTHER PARTIES ON THIS ISSUE A WEEK AGO ON JANUARY 17, HOWEVER, WE HAVE NOT DECIDED l
ON THE REQUEST AS OF TODAY.
l THE SECOND MAJOR ELEMENT REGARDING THE CURRENT DIABLO CANYON l
LICENSING EFFORT IS THE HEARING PROCESS FOR THE FULL POWER l
l LICENSES FOR UNIT 1 AND UNIT 2. THE ATOMIC SAFETY AND LICENSING APPEAL BOARD CONDUCTED A HEARING ON UNIT 1 AND UNIT 2 ON THE l
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PALLADIN0 TESTIMONY,
c REOPENED ISSUE OF DESIGN QUALITY ASSURANCE FROM IN NOVEMBER OF k
LAST YEAR IN AVILA BEACH, CALIFORNIA NEAR THE DIABLO CANYON SITE.
i AT THE HEARING EVIDENCE WAS PRESENTED BY THE COMMISSION STAFF, PG8E THE GOVERN 0'R AND JOINT INTERVENORS ON A NUMBER OF DESIGN-RELATED ISSUES.
ALL PARTIES HAVE FILED POST-HEARING FINDINGS WITH THE APPEAL BOARD AND A DECISION IS EXPECTED IN THE NEAR FUTURE.
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i APART FROM THE HEARING PROCESS, THE COMMISSION, ON NOVEMBER 8, i
i 1983, ACTED TO PEINSTATE LIMITED AUTHORITY TO ENGAGE IN FUEL LOADING AND COLD SYSTEM TESTING OF DIABLO CANYON UNIT 1.
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DECISION FOLLOWED A PUBLIC MEETING OF THE COMMISSION ON OCTOBER
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z 28, 1983, AT WHICH WE HEARD COMMENTS FROM OUR STAFF, THE IDVP, PG&E AND THE JOINT INTERVENORS.
OUR ACTION WAS BASED ON THE
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FINDINGS OF THE INDEPENDENT DESIGN VERIFICATION PROGRAM, PGRE'S SEPARATE INTERNAL TECHNICAt PROGRAM AND THE COMMISSION STAFF'S FAVORABLE EVALUATION OF EACH WITH RESPECT TO THESE LIMITED ACTIVITIES.
IN TAKING THIS ACTION WE ALSO CONSIDERED THE VIEWS OF THE JOINT INTERVENORS, WHILE GENERALLY OPPdSED TO OUR AUTHORIZATION THE JOINT INTERVENORS FAILED TO DEMONSTRATE THAT THE CONDUCT OF THE ACTIVITIES AUTHORIZED WOULD IN ANY WAY PRESENT A RISK TO THE PUBLIC HEALTH AND SAFETY.
AGAIN, I WOULD EMPHASIZE THAT WE HAVE NOT AUTHORIZED PG8E TO BRING THE REACTOR TO CRITICALITY AND THUS NO RADI0 ACTIVE FISSION PRODUCT INVENTORY HAS BEEN CREATED.
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WITH RESPECT TO ANY SUBSEQUENT AUTHORIZATION OF CRITICALITY AND LOW POWER TESTING, MAY WELL CHOOSE TO AWAIT THE APPEAL BOARD'S DECISION ON THE MATTERS CONSIDERED AT THE HEARING.
l REGARDING THE THIRD ELEMENT IN THE REINSTATEMENT OF THE LOW POWER LICENSE, THE STAFF HAS RECEIVED A NUMBER OF ALLEGATIONS AND CONCERNS.
REGARDING THE DESIGN, CONSTRUCTION AND OPERATION OF THE DIABLO CANYON PLANT. A NUMBER OF THESE HAVE BEEN RESOLVED AND i
REPORTED IN INSPECTION REPORTS, AND SAFETY EVALUATION REPORT 4
SUPPLEMENTS MORE RECENTLY THE STAFF WAS MADE AWARE OF ADDITIONAL ALLEGATIONS BOTH PUBLICLY AND IN CONFIDENCE.
THE ALLEGATIONS TO 4
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DATE CONTAIN APPROXIMATELY 100 INDIVIDUAL CONCERNS TO BE ADDRESSED.
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THE COMMISSION THE STAFF, ON OCTOBER 28, 1983, TO PURSUE ALL i
ALLEGATION AND CONCERNS TO RESOLUTION AND PROVIDE A STATUS REPORT PRIOR TO OUR CONSIDERATION OF AUTHORIZING CRITICALITY AND LOW POWER TESTING.
IN RESPONSE TO OUR DIRECTIVE THE STAFF ORGANIZED A MANAGEMENT PROGRAM TEAM WHICH COORDINATES THE ACTIONS BY THE VARIOUS NRC 0FFICES.
THIS PROGRAM UTILIZED TECHNICAL STAFF REVIEW, ON-SITE INSPEC-TIONS, PUBLIC MEETINGS WHERE POSSIBLE, CLOSED DISCUSSIONS WITH ALLEGERS WHERE ANOMITITY WAS REQUIRED, INTERVIEWS WITH ENGINEERS, WORKERS AND MANAGEMENT STAFF 0F PG8E AND HIS CONTRACTORS WHERE APPRIORIATE.
SAFETY EVALUATION SUPPLEMENT 22 HAS BEEN ISSUED, WHICH PROVIDES THE STATUS OF ALL ALLEGATIONS AND CONCERNS THROUGH DECEMBER 19, 1983.
THE DOCUMENT WAS ISSUED IN TWO PARTS DUE TO 4
THE NEED TO PROTECT THE ANONOMITY OF SOME OF THE ALLEGEPS.
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PALLADIN0 TESTIMONY.
i THE DOCUMENT PROVIDES THE FOLL0 DING CONCLUSIONS:
1' "THE ALLEGATION MANAGEMENT PROGRAM IN PLACE FOR CURRENT AND FUTURE ALLEGATIONS RELATED TO DIABLO CANYON HAS AND SHOULD CONTINUE TO PROVIDE A PROCEDURE FOR ORDERLY AND THOROUGH YET TIMELY EXAMINATION OF EACH CONCERN RAISED.
APPROXIMATELY 75% OF THE ALLEGATIONS CURRENTLY RECEIVED HAVE BEEN EXAMINED TO A POINT WHERE IT IS THE STAFF'S OPINION THAT THERE IS NO SIGNIFICANT SAFETY ISSUE OR SUBSTANTIAL BREAKDOWN OF MANAGEMENT OR QUALITY CONTROL SYSTEMS.
THE REMAINING ALLEGATIONS HAVE BEEN ASSIGNED TO VARIOUS ELEMENTS OF THE NRC STAFF FOR EVALUATION AND MOST HAVE BEEN PARTIALLY EXAMINED.
EXAMINATIONS OF 4
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PALLADIN0 TESTIMONY 22 -
THESE REMAINING ALLEGATIONS IN SUFFICIENT DETAIL TO PERMIT A STAFF' CONCLUSION RELATIVE TO SAFETY SIGNIFICANCE IS EXPECTED TO BE COMPLETED DURING SITE INSPECTIONS WHICH 4
l OCCURRED FROM JANUARY 4, 1984 THROUGH JANUARY 13, 1984.
APPROXIMATELY 15 PROFESSIONAL STAFF WERE ACTIVE IN THESE INSPECTIONS.
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THE STAFF HAS NOT AT THIS TIME, IDENTIFIED ANY ISSUE THAT i
WOULD PRECLUDE AUTHORIZATION FOR OPERATION UP TO AND E
l INCLUDING TESTING AT FIVE PERCENT POWER ON THE BASIS OF THE PUBLIC HEALTH AND SAFETY.
HOWEVER, THERE ARE SEVERAL
, AREAS WHERE OUR EXAMINATION OF ALLEGATIONS HAS LED US TO l
j REQUIRE ADDITIONAL INFORMATION.
PENDING FURTHER EVALUATION i
0F THESE MATTERS, AS A MATTER OF PRUDENCE THE STAFF HAS 1
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PALLID 0N0 TESTIMONY.
IDENTIFIED FOUR ACTIONS THAT WE PRESENTLY BELIEVE SHOULD BE COMPLETED PRIOR TO AUTHORIZING CRITICALITY; FIVE OTHER ACTIONS HAVE BEEN IDENTIFIED FOR COMPLETION PRIOR TO AUTHORIZING OPERATION ABOVE FIVE PERCENT POWER."
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