ML20210U838
| ML20210U838 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/31/1984 |
| From: | Chandler L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Schierling H NRC |
| Shared Package | |
| ML20210U520 | List:
|
| References | |
| FOIA-86-197 NUDOCS 8610100220 | |
| Download: ML20210U838 (8) | |
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August 31, 1984 g*
Note to: Hans Schierling
SUBJECT:
DIABLO CANYON UNIT 2 - ISSUES TO BE RESOLVED BEFORE APPEAL BOARD Attached is the list of issues admitted by the Appeal Board in the reopened hearing cn design quality assurance which we discussed in early June and earlier this week in terms of their applicability to Unit 2.
Issues 1.(e),
2.(d), 5, and 8 have either explicit or unquestionable relevance to Unit 2 and will require consideration by the Appeal Board independent of the evi-dence presented at the hearing in October / November 1983.
Issues 3.(f)(i),
(ii), (iii) and 7 will require consideration to the extent that Unit 2 may involve concerns distinct from those on Unit 1.
The other issues appear not to be specific to either Unit but are, rather, applicable to structures, systems or components comon to both and will require new evidence only to the extent necessary to develop the position that what was said before ade-quately addresses the matter.
If the foregoing sorting of the issues is incorrect in your view, please let me know.
At this time, the schedule for preparing the Staff's evaluation of the fore-going issues for presentation to the Appeal Board and the form in which it will be needed (e.g. SER, affidavit or written testimony) is unknown.
I have discussed with you my suggestion that, in order to support PG&E's projected fuel load date in November 1984, the most expeditious approach would be for the utility to file a motion for sumary disposition to which we and the other parties would respond. Under the Comission's regulations, 10 C.F.R. 9 2.749, a reply to such motion is due within 20 days after the motion is filed (plus appropriate mailing time). While I have no way of l
estimating how long it might take the Appeal Board to rule on a motion of this kind, I would guess that it would take about one month.
If the motion i
l were granted in its entirety, there woud be no need for a further eviden-tiary hearing; if denied in whole or in part, a hearing on those issues on l-
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which summary disposition is not granted will be necessary. Of course in that event, some period prior to the hearing would be provided for discovery and preparation of testimony. Accordingly, at this time, the schedule is in PGSE's hands; at the earliest our evaluation of the issues would be due about 20 days af ter PG&E acted if it elects to file a motion for summary disposi-tiun. Since, in order to meet a November fuel load date such motion would have to be filed in early September, it is possible that we will have to respond as early as about the third week of September; drafts, of course, would be required sooner.
If PG&E does not file a motion but rather requests to go to a hearing, the Staff's evaluation would be needed approximately two weeks before such hearing comences. Given the likely and necessary prercq-uisite procedures (such as discovery), I would speculate that if PG&E makes a r
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h request in early September to go to a hearing, such hearing would not likely begin until mid-November at best. To assure that the Staff's efforts will not be on the critical path, I would I would urge that the Staff start devel-oping its evaluation with the shorter timeframe in mind.
Please keep nt advised of progress and of any problems encountered.
a rence J.
andler Special Litigation Counsel
Enclosure:
As stated cc w/ enclosure:
D. Eisenhut R. Vollmer J. Knight G. Knighton C. Grimes
'b' f
107 APPENDIX A Issues At Hearing in Accordance With Orders of August 26 and October 7, 1983 (unpublished)-
1.
The scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures and components (SS&C's) was too narrow in the following respects:
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(a)
The IDVP did not verify samples from each i
design activity (seismic and non-seismic).
(b)
In the design activities the IDVP did review, it did not verify samples from each of the design groups in the design chain performing the design activity.
(c)
The IDVP did not have statistically valid samples from which to draw conclusions.
(d)
The IDVP failed to verify independently the analyses but merely checked data of inputs to models used by PG&E.
(e)
The IDVP failed to verify the design of Unit 2.
2.
The scope of the ITP review of both the seismic and non-seismic aspects of the designs of the safety-related systems, structures and components (SS&C's) 7 was too narrow in the following respects:
y.
(a)
The ITP did not verify samples from each design activity (seismic and non-seismic).
(b)
In the design activities the ITP did review, it did not verify samples from each of tha design groups in the design chain performing the design activity.
(c)
The ITP did not have statistically valid samples from which to draw conclusions.
(d)
The ITP has failed systematically to verify the adequacy of the design of Unit 2.
3.
In various situations listed below the ITP used improper engineering standards to determine whether design activities met license criteria.
In some of these situations, the IDVP either used or approved the use of such improper standards or did not verify them at all.
k 108 (f)
The ITP's modeling of the soil properties for the containment and auxiliary buildings was improper in,
3 that:
(i) in the soil structure interaction analysis of containment for the DE [ Design Earthquake] and the DDE [ Double Design. Earthquake], use of boundary motion inputs to the model were improperly used; (ii) the soil structure interaction analysis for containment for the DE and the DDE uses a 7 percent damping value for rock, which is unconservative, especially for the DE; (iii) the dynamic analyses of the containment for all earthquakes omit any analysis of uplifting of the foundation mat; (iv) the modeling of the soil springs for the auxiliary building does not specify soil properties; (v) in the modeling of the soil springs for the auxiliary building, the motion inputs to the lower ends of the springs does not account for all-soil struct6re interaction phenomena that could be expected.
(o)
The ITP has not demonstrated, and the IDVP has not verified, that the DCP modeling of the seismic response of the fuel handling building is proper, in that the DCP has not adequately justified the use of the translational and torsional response of the auxiliary building as input to the fuel handling building nor has it demonstrated the validity of the dynamic degrees of freedom i-selected.
(p)
The ITP has not demonstrated, and the IDVP has not verified, that the DCP seismic model of the slabs in the auxiliary building is proper, in relation to the use of vertical and rotational springs to model the columns, and the motions used as input at the ends of the springs not connected to the slabs.
In addition, in the study of the diaphragms, the ITP has not adequately accounted for the inplane flexibility *of these slabs, and has not adequately demonstrated that stresses are within allowable limits at all elevations.
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109 (q)
The ITP has not demonstrated and the IDVP has not verified, that the soils analysis for the buried diesel fuel oil tanks is proper in that the values of the exponent shown in figure 14 of ITR 68 have not.been demonstrated to be appropriate and the variation of shear velocity with depth is not properly justified.
(r)
The ITP has not demonstrated and the IDVP has not verified that the soils analysis for the auxiliary saltwater piping and circulating water intake conduits is proper in that the selection of the mo.dulus versus strain curve utilized is not justified.
(s)
The ITP has not demonstrated and the IDVP has not verified that the seismic analysis of the turbine building is proper in that bolt bearing capacities were taken from an inappropriate source.
(t)
The ITP has not demonstrated and the IDVP has not verified that the seismic analysis of the turbine building is proper in that the use of four different models for the vertical analysis has not been justified.
4.
The IDVP accepted deviations from the licensing criteria without providing adequate engineering justification in the following respects:
a.
Contrary to the requirements of FSAR Section 17.1 regarding compliance of the as-built installation with the design documents, the IDVP review of the AFWS disclosed that the as-built installation failed to meet the design drawings in that (i) a steam trap on the. turbine-driven AFW pump steam supply line is not provided and (ii) there are discrepancies in the arrangement of the long-term cooling water supply line.
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b.
Contrary to FSAR Section 8.3.3, the electrical design does not fully comply with the commitments regarding separation and colcr coding.
h.
Contrary to PG&E's September 14 and December 28, 1978 licensing commitments, CRVPS equipment identified in the FSAR as necessary to maintain control room habitability during safe shutdown has not been evaluated regarding the effects of a moderate energy pipe break.
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V 110 i.
The fire protection for the motor driven AFW pump room is not consistent with the PG&E licensing commitment for fire zone separation as stated in its November 13, 1978 Supplemental Information for Fire Protection Review (" SIFPR" ) in that:
1) there is a large grated ventilation
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opening in the ceiling of the room; 2) a fire damper has gaps when it is closed.
j.
The fire protection for the AFW pump room is not consistent with the PG&E licensing commitment for cable separation as stated in its SIFPR of November 13, 1978 in that:
1) the pumps for the motor driven AFW pumps and the control circuitry for a flow control valve necessary for operation of the turbine driven AFW pump are located in a single fire zone; 2) cables for some AFW circuits are not routed in accord with descriptions in the SIFPR and four AFW circuits PG&E committed to identify and review in the SIFPR were not included in that
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document.
l k.
Contrary to the licensing commitment set forth in its SIFPR of November 13, 1978, each of the three 4160 volt cable spreading rooms has a ventilation opening leading up to the 4160 volt switchgear rooms.
1.
Contrary to FSAR Section 3.6, possible jet impingement loads have not been considered in the design and qualification of safety-related piping and equipment inside containment.
q.
Contrary to PG&E's December 28, 1979 licensing commitment letter to the NRC, modifications to protect two Auxiliary Feedwater valves from the effects of moderate energy line breaks were not implemented.
111 4
r.
Contrary to the licensing commitment to maintain minimum system redundancy as stated in FSAR Section 3.6A (NSC evaluation of pipe break outside containment), four components were identified for which high energy line cracks could cause temperatures in excess of the specification temperatures of the components.
s.
Contrary to the licensing commitment to maintain minimum system redundancy as stated in FSAR, Section 3.6A (NSC evaluation of pipe break outside containment), a conduit was identified whose failure due to a high energy line crack could eliminate redundant Auxiliary Feedwater system flow.
i t.
Contrary to the FSAR Section 8.3 commitment to provide switchgear buses with adequate short circuit interrupting capability, the calculated duties for circuit breakers on 4160 V buses F, G, and H were.above the nameplate ratings for those buses.
u.
Contrary to single failure criteris stated in FSAR Section 3.1.1, reviews of the Auxiliary Feedwater and Control Room Ventilation and Pressurization systems identified circuit separation and single failure deficiencies.
Similar deficiencies were identified in additional verification reviews, which l
included other safety-related systems.
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5.
The verification program has not verified that Diablo Canyon Units 1 and 2 "as built" conform to the design i
i not-drawings and analyses.
l 6.
The verification program failed to verify that the design of safety-related equipment supplied to PG&E by Westinghouse met licensing criteria.
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7.
The verification program failed to identify the root causes for the failures in the PG&E design quality assurance program and failed to determine if such failures raise generic concerns.
8.
The ITP failed to develop and implement in a j
timely manner a design quality assurance program in
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accordance with 10 CFR Part 50, Appendix B to assure the quality of the recent design modifications to the Diablo Canyon facility and the IDVP failed to ensure that the corrective and preventative action programs implemented by
6 112 the ITP are sufficient to assure that the Diablo Canyon facilities will meet licensing criteria.
9.
Contrary to General Design Criterion 44 (GDC-44) of Appendix A to 10 CFR Part 50, PG&E has failed to provide adequate assurance of component cooling water system (CCW3) heat removal safety function capacity in that the maximum ocean water temperative of 64*F. is not conservative because it has already been exceeded in 1983.
Furthermore a technical specification limitation which permits plant operation at reduced power levels in lieu of enlarging the capacity of the CCWS does not provide an equivalent level of safety as compliance with the requirements of GDC-44 (SSER, 16 (Aug. 1983) and September 1983 ocean water temperature readings).
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'JNITED STATES
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i NUCLEAR REGULATORY COMMISSION
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1450 MARIA LANE, SUITE 210
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WALNUT CREEK, CALIFORNI A 94596 SEP 2 71984 MEMORANDUM FOR:
H. E. Schierling, Project Manager, Licensing Division T. W. Bishop, Director, Division of Reactor Safety and FROM:
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Projects, Region V
SUBJECT:
TRANSFER OF ALLEGATION RESOLUTION RESPONSIBILITY The Diablo Canyon Allegation Review panel meeting of' September 10, 1984, entered the following allegations into the Diablo Canyon Allegation File (DCAF) with resolution responsibility to NRR.
1422 1429 1452 1423 1430 1453 1424 1431 1454 1425 1432 1461 1426 1433 1466 1427 1434 1469 1428 1451 1472 Attached is a printout from the DCAF containing all cpen allegations with NRR closecut responsibility, including the allegations listed above. Please provide any input you may have regarding the allegations so that we may update and keep current the DCAF.
If you require any further information or would like to supply update information, please contact Thomas Crowley at FTS 463-3789, in the Region V office. Thank you for your cooperation.
h-t u)& W s.
k M bh T. W. Bishop, Director y *. r m...._,o.._.,....-,,-.,.,.
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Docket No.: 50-323 J
MEMORANDUM FOR: George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing FROM:
Hans Schierling, Project Manager Licensing Branch No. 3 Division of Licensing
SUBJECT:
DIABLO CANYON UNIT 2 - MEETING WITH PG&E DATE & TIME:
Thursday, September 13, 1984 10:00 am LOCATION:
Room P-118 Phillips Building j
Bethesda, Maryland PURPOSE:
Discussion of Unit 2 matters and schedule (see enclosed list)
Note 1: The meeting will continue on September 14, 1984 if necessary.
PARTICIPANTS:
NRC T Bishop, T.
vak, J. Knig
, G. Knighton, U Bosnak,-
L. Chandler, Schierling, Grimes, P. T. Kuo M. Hartzman, L. Crocker, F.b nderson, R. Heishma /, H A
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E PG&E J. Hoch, et al.
] (%5 k.,.'~ ( k v CM Hans Schierling, Project Manager i
Licensing Branch No. 3
Enclosure:
As stated cc: See next page 1
Items for Discussion NRC/PG&E Meeting September 13, 1984 1.
Application of Unit 1 IDVP/ITP for Unit 2 2.
Allegations 3.
Piping and support analyses and modifications 4.-
Unit 2 quality assurance program (construction and operation) 5.
Tecnnical Specifications 6.
Unit 2 Readiness 7.
Construction / Modifications Status and Schedule 8.
Licensing Schedule 9.
Other matters to be identified by NRC and PG&E F
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