ML20214T725

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Summary Rept for Regional Evaluation of Diablo Canyon Unit 2
ML20214T725
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 11/30/1984
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20213E738 List:
References
FOIA-86-197 NUDOCS 8706100394
Download: ML20214T725 (48)


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SUMMARY

REPORT

~i FOR REGIONAL EVALUATION d

J DIABLO CANYON, UNIT 2 I'

DOCKET NO. 50-323 i

i PREPARED BY U. S. NUCLEAR REGULATORY CG!9 FISSION i

REGION V 1

30 NOVEMBER 1984 l'

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SUMMARY

REPORT FOR REGIONAL EVALUATION i

OF DIABLO CANYON UNIT 2, DOCKET NUMBER 50-323 5

TABLE OF CONTENTS PAGE(S)

ITEM 1

Introduction and Summary

.1 - 2

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2 History of Diablo Canyon Power Plant Unit 2 3-4 3

Quality Assurance Organization 5 - 16 4

Nuclear Regulatory Commission Inspection Activities 17 - 19 5

Generic Correspondence 20 - 32 6

Enforcement History 33 7

Quality Assurance Audit Statistics - Stop Work 34 - 38 Orders - and Outside Agency Audits 8

Construction Deficiency Reports (50.55(e) - Part 39 - 43 21 Notifications 9

Construction Status 44 - 45 10 Preoperational Test Status 46 - 48 4

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INTRODUCTION AND

SUMMARY

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Introduction and Purpose This construction status and operational-readiness summary report has been

' i prepared to provide information to the Directors of the Office of Inspection -

and Enforcement (OIE) and Nuclear Reactor Regulation (NRR) of the findings and results of the Regional office's evaluation of Diablo Canyon Unit 2 readiness for operation. This report is being prepared concomitant with a SALP evaluation which covered the period January 1,1983 through June 30, 1984 and was conducted October 17, 1984.

Plant Summary Data Docket Number: 50-323 Construction Permit: DPR-76; December 9, 1970 Applicant: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Plant Location: San Luis Obispo, California 7 miles South of Los Osos/ Bay Wood Park IE Region: V

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i' Architect Engineer: Pacific Gas and Electric Company i

Nuclear Steam Supply System Vendor: Westinghouse Constructor: Pacific Gas and Electric Company Reactor type: PWR Design Electrical Rating:

1106 MWE

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Corporate

Contact:

J. Shiffer, Vice President j

Nuclear Power Operations (415-781-4211)

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Site

Contact:

R. Thornberry, Plant Superintendent (805-595-7351) i NRC Project Manager:

H. Schierling (FTS 492-700)

IE Resident Inspector:

M. Mendonca (805-595-2354)

Local Public Document Room: Cal Poly State University 1

1 Documents anc Maps Department San Luis Obispo, California 93401 (Diablo Canyon N" clear Power Plant) 1 7

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Item 2 HISTORY OF DIABLO CANYON POWER PLANT, UNIT 2 7

i Planning for Unit 2 of the Diablo Canyon Power Plant (Diablo Canyon, or DCPP) began in the mid-1960s. On February 16, 1968, PGandE applied to the CPUC for-certificate of Public Convenience and necessity for Uniit 2 (Application No. 50028), and following hearings, the CPUC granted the requested i

certification for Unit 2 on March 25, 1969 (Decision No. 75471).

PGandE filed an application for a construction permit with the Atomic Energy Commission (AEC) (now the Nuclear Regulatory Commission (NRC)) for Unit 2 on June 28, 1968. After meetings with the Advisory Committee on Reactor Safeguards (ACRS) and hearings before the Atomic Safety and Licensing Board (ASLB), the AEC issued a construction permit for Unit 2 on December 9,1970.

Construction began shortly after issuance of the construction permit and continued through September 28, 1973, when PGandE submitted the operating license application for both Units 1 and 2.

Included in the FSAR was a description of an offshore fault mapped by two Shell Oil Company geologists, Hoskins and Griffiths (Hosgri). The USGS, acting as a consultant for the NRC, determined that the potential ground motion from the Hosgri fault should be applied to the design of the Diablo Canyon Plant. Early in June 1977, PGandE filed a report with the NRC containing PGandE seismic evaluation of the NRC postulated Hosgri earthquake for the Diablo Canyon units.

Seismic safety hearings before the ASLB resulted in a Partial Initial Decision on September 27, 1979.

This decision found that seismic modifications to the plant would enable Diablo Canyon to withstand an earthquake of 7.5 magnitude along the Hosgri Fault. A Partial Initial Decision by the ASLB would normally have resulted in the issuing of an operating license, however, the NRC was delaying the licensing of all new plants at the timt of the ASLB decision pending resolution of issues which resulted from the Three Mile Island accident of March 28, 1978.

During this period of delay additional hearings on Diablo Canyon were held before the Atomic Safety Licensing Appeals Board (ASLAB) in October and November of 1980. Those hearings reviewed the adequacy of the Diablo Canyon Security Plan and heard new seismic evidence based on data from the October 1979 Imperial Valley Earthquake. The ASLAB found in their decision of September 9,1981, that the security plan conformed with all applicable provisions of the Atomic Energy Act of 1954 and the NRC's security regulations.

In a further decision dated June 16, 1981, ASLAB affirmed the seismic adequacy of Diablo Canyon.

On July 14, 1980, PGuadE filed an application for a fuel load and low power test license for Unit 1 and Unit 2.

Following the NRC Staff issuance of their Safety Evaluation Reports on TMI Safety requirements, ASLAB hearings on fuel load and low power testing were held during May 1981. The ASLB found in a l

Partial Initial Decision dated July 17, 1981 that Diablo Canyon was ready for j

fuel load and low power testing.

In Augtst 1981 the NRC Staff briefed the NRC 1

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1 Commissioners on unconnected issues such'a's. shift staffing. Also in August a j

satisfactory Emergency Planning Exercise was conducted.

At this point in time all issues necessary'to permit issuance of a low power.

j license for both Units 1 and 2 were resolved.except' for completion of l

construction and a final IE inspection and recommendation of issuance of the license. On September 22, 1981, the Low Power License for Unit I was issued i

by the NRC. Construction completion for Unit'2 was scheduled eight months l

after Unit 1.

On November 19, 1981, the NRC issued an Order (CLI-81-30) suspending PGandE's authority to load fuel and to operate and test the Diablo Canyon facility at power levels of up to 5% of rated power (low power testing). The order required the establishment of an Independent Design Verification Program (IDVP) to verify the adequacy of the design process.

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a During the design verification review, Unit 2 review was separated from Unit I for the first time since the filing of the operating licLGee applic.f. ion.

In addition to normal design activities, Unit 2 personnel established a program known as the Internal Review Program (IRP) to address the Unit I findings (such as those identified by the IDVP). An additional program to address Unit I allegations to determine their applicability to Unit 2 was also established.

The Unit 2 norma

'gn process, the IRP, and the Allegation Review Program r

are bein ewed by Nuclear Reactor Regulation (NRR) for adequacy. NRC

dio activities are ongoing in the areas of piping, civil / structural, allegations and the IRP, which further verifies design adequacy of Unit 2.

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Following completion of the NRR review, completion of construction, and h#

demonstration of operational readiness, Unit 2 will be ready for receipt of its -perating license. The following schedule for Unit 2 major milestones has been established by the licensee:

Milestone Scheduled Date Hot Functional Testing December 20, 1984 Security System Implementation January 15, 1985 Plant Operator Licensing January 21, 1985 Fuel Load February 15, 1985 Initial Criticality April 1985 4

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QUALITY ASSURANCE ORGANIZATION i

On April 17, 1969, the proposed " Quality Assurance Criteria for Nuclear Power Plants" was published for comment in the Federal Register. These criteria i

were formally adopted and issued as Appendix B to 10 CFR 50, effective

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t June 27, 1970, over 2 years after the CP for Diablo Canyon Unit I had been issued.

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The PGandE quality program during the time period before Appendix B Sqnsisted of engineering and construction practices which included analyses, levhws, inspections, and tests common to the utility and construction industries.

QA requirements for Diablo Canyon were first addressed in Appendix G to the Unit 2 Preliminary Safety Analysis Report (PSAR) which was submitted to the NRC in June 1968. PGandE revised the Unit 2 PSAR iniJuly 1969, to include the 18 Criteria of Appendix B as part of the quality program.

In anticipation of the requirements of Appendix B, PGandE organized the Quality Engineering (QE) Section within the Engineering Department in November 1969, and assigned it responsibilities in connection with the construction of nuclear power plants. The Company issued a QA manual for Design and Construction (often called the " Red Book") in January 1970, utilizing the proposed 18 criteria of 10 CFR 50, Appendix B.

By the time the manual was issued, the proposed Appendix B criteria had been issued unchanged as a regulation.

With the issuance of ANSI N45.2 in 1971, the concept of independence of the QA organization was further clarified.

In response, PGandE' management established a separate Quality Assurance Department, formerly the QE section.

Instead of reporting to the Vice President of Engineering, the QA Department began reporting to the Senior Vice President (Engineering, Construction, Planning and Research) (see Attachment 1).

In August 1972, the QA Program policy was revised to reflect the new independent reporting relationship.

The new department was responsible for the development and issuance of corporate policies, procedures and revisions thereto, just as QE had been.

The scope of the audit program for the QA Department was broadened over that of QE to provide a means for evaluating the quality priigram's effectiveness in all departments and for reporting findings to executive management.

PGandE submitted to the NRC on January 30, 1975, Amendmenti 25 to its OL Application which revised FSAR Chapter 17.2, " Quality Assurance Program For Plant Operation." Amendment 25 stated PGandE's commitment to follow the guidance contained in the " Rainbow Books" where appropriate.

On September 26, 1975, PGandE issued the " Quality Assurance Manual for Operating Nuclear Power Plants" (commonly referred to as the " White Book")

which was issued in anticipation of fuel loading for Unit 1.

The White Book described the quality program being implemented at the Humbaldt Bay Power Plant 5

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.*I Unit 3, and the quality program which was to be' implemented at Diablo Canyon.

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Units 1 and 2 when the responsibility for the systems in place was transferred

. to the PGandE Operations Department. However, the " Red Book" remained in effect 4

j as the QA manual for design and construction activities.

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Beginning in 1977, each department responsible for nuclear activities F

established a QC group to perform monitoring activities of the department's j

quality-related functions. QC groups were formed within the Engineering, q.

Planning and Research, Materials, and Operations Departments. -General

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Construction's QC group had been functioning onsite at Diablo Canyon since 1969. The quality program became a combined effort of the QA Department and

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the-QC groups working collectively to monitor the implementation of the quality program. The QA Department was responsible for performing an overview 2

l function of the combined effort and for reporting to executive levels of 1

management on program effectiveness. The QC groups were responsible for the

<r day-to-day functioning of the quality program within their respective departments.and the reporting on the status of the quality program to their i

management.

i The QC groups issued procedures which described the requirements that each department had to comply with. These procedures were contained in the following manuals:

Materials Department Manual, issued April 20, 1976 1

Engineering Department Manual, issued May 5, 1977, lI Operations Plant Manual, QC Procedures, issued June 10, 1977 1

Planning and Research Manual, issued April 23, 1980 General Construction Manual, issued May 8, 1980

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l' The establishment of the QC groups and the issuance of QC procedures was followed by major revisions to the corporate QA manuals to describe the responsibilities of the QC groups and to delete procedures 'and/or requirements d

which had been superseded by QC procedures. The revisions to the corporate QA 4

manuals encompassing these aspects of the program spanned the time period from March 1977 through September 1978.

In January 1976, senior management anticipated that with the nuclear units becoming part of the generating system, a concerted effort would be needed to l

identify and manage the large volume of nuclear records.that were being j

developed and the retention of which is required by law..A records management (RM) section was established in 1977 in the QA Department because QA already i

had access to all of PGandE's NRC-required records and had established l

interfaces with all involved departments.

In April 1980, the QA Department began reporting to the Vice President of the i

newly established Nuclear Power Generation Department. This change in reporting occurred in anticipation of management's expectation that Unit 1 would begin operating.

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l On January 22, 1981, PGandE committed to several Reg. Guides and ANSI Standards. These Reg. Guides and Standards are in a table contained in the 1983 revision of Chapter 17 to the Diablo Canyon FSAR (See Attachment 2).

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y revision was submitted to NRC December 2, 1983, and was approved December 20, Q#)'

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1983.

R On February 9, 1981, the Quality Assurance Manual for Nuclear Power Plants was kD

  • l issued, superseding both the " Red Book" and the " White Book".

t In September 1983, the QA Department was reorganized into five basic sections (See Attachment 3). Due to the reorganization and the extent of the FSAR commitments, on June 30, 1984 there were 100 people working directly for i

the QA Department.

(For the number of QA personnel in prior years, See

'.) The reorganization made it possible to give proper attention to the various t. asks the department now had with more employees in supervisory positions. Prior to this reorganization, the QA department consisted of two basic sections, auditing and program development.

During the preparation of the December 1983 revision to FSAR Chapter 17, PGandE management decided to move the QA Department back to its independent position of reporting to an executive level of management.

In December 1983, the QA Department began reporting to the Executive Vice President, Facilities and Electric Resources Development (See Attachment 5).

Another major development in the post-1981, time period was the retention of the Bechtel Power Corporation as the Project Completion Manager. The basic QA Program for this effort was accepted by PGandE based on the NRC's endorsement on June 12, 1981, of Bechtel's Topical Report BQ-TOP-1.

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The formation of the integrated PGandE/Bechtel project team in April 1982, required modifications to the QA program to take into account the new project organization and differences in implementation of the work.

It was the conclusion of both PGandE and Bechtel management that it would be best to adopt the previously approved Bechtel Topical QA program for future design work to be performed by the integrated Project Team. This conclusion was based on the following:

The integrated Project Team was under the direction of a Project Completion Manager who was a Bechtel employee reporting to a PGandE Executive Vice President. The Project Team consisted of PGandE and Bechtel management employees interspersed throughout the integrated organization at various levels of supervision.

The Bechtel Topical QA Program had been accepted generically by the NRC. The program was primarily designed for use in project team matrix organizations typical of other Bechtel projects and similar to that being developed for the integrated PGandE/Bechtel Project Team.

Based on the circumstances under which the integrated Project was formed, it was believed the Bechtel program would be more readily accepted by the NRC, the IDVP, and all other parties involved. With past implementation of the PGandE QA program under question, it would provide additional credibility to use a different, more proven, program.

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Throughout this decision making process, the in place PGandE QA Program was i

adequate and remained in effect, governing procurement and constru.ction m ;.

. activities as well as.PGandE QA auditing and overview of the integrated l'j,

' project's design actiivitiesa '

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, i 1,2 The process"of: conforming.the/PGandE Engineering Manual (EM) to the Bechtel QA Program'and' implementing the revised manual had a positive benefit in that

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. :O Y, evaluated and' certain additional features and c'o'ntrols of the Bechtel QA Program could be

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if appropriate, retained by PGandE for any future 3

engineering evaluation or modification work on the plant during commercial operation.

PGandE's QA Department reviewed and approved the Bechtel QA Program including the revised EM. PGandE's QA Department has reviewed and audited the.

j P implementation'of the project QA Program since its effective date on Ah3ust 20, 1982. Attachment 6 shows the Diablo Canyon Project Unit 2 1

organization and the< relationship of Quality Assurance.

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ATTACHMENT 1

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Vice Freeldent ytce Freeldent

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5tetton Construction Director

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Civil Engineer

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Engineer Spec II f cnt leeis l Fteid Engte.

FCAE ORCANIZATION FtML llE51CH ANil CONSTRUCTinN

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ATTACHMENT 2

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(1983FSARRev.)

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TABLE 17.2 (5heet I of 3)

CUnamer tscutAfeef ameENTS Age PCeedt CeBellitIEIITS

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PRETAININC 70 t QUALITT ASSpaJuect PsocaAM J

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i The Smelity Aseerence Feuerem deerribed le the Quality Aseersece Itsemel for I

Itacleer Feuer Fleets coglies with the regelresente set deem to the Code of Federal tegelettoes. la eddittee, it complies eith the regolater) deceasete end ledestry steederde listed below. Changes to thle list are set mede withmet the review and concorrence of the quality Aseerence Itenager.

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(8.g.) 28 6/F2 Aust MS.I 1978 Quality Aseersece Fregree Requiremente for Weclear Feuer Fleete 3.3F 3/F3 AstSI MS.I.I 1973 Oselity Assurance Regettements for Cleestes Fluid systone end Aseecleted Ceepeneste of Water-Cooled Declear Poser Fleete l.33 5/FF Astsi M5.2.2 1972 Quality Assureece Regelreesets for Fockeglas, i

Shipplag. Receiving. Statese, sed Rendlims of Iteme for Water-Cooled peclear Feuer

1 Fleete i) 1.39 9/FF ANSI M 3.3.3 1973 seeeeheeples togstrousets for water-Cooled Meclear Power Fleste t

i 1.30 S/72 ANSI M5.2.4 1972 Quality Assureece Regeltamente for the I

Imetallettee. Imerecties, and Testing of leetrumentattee end Electric Egelreent j

1 1.94 4/f6 Amst M5.2.5 1974 Quelley Aeoersece Requireesete for I

Instelletten. Imerecties, and Testles i

of Structural Concrete end Strweteral Steel During the Cemetructlee Phase of pecteer Power riente I

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ATTACHMENT 2 (1983 FSAR Rev.)

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TABLE 17.2 (Sheet 2 of 3)

Consumf ascouvent angelsenewes Ase rceedt comentwswrs d'

tsaTAlstuc TO TWE QUALITY ASSWEAleCE P90 CRAM J

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3.53 g/se Amst B45.2.6 1970 9eellficettee of IIseleer Fener Fleet 4[

Imeyeccles. Esseleetles. and Teeting Aust M5.2.6 applies to Sedivlemete Peroommet condwetles 1-f, f ^ QC Seepectione, eseeleetlese. and toets. ANSI mig.8 opplies to pereommel cemenceing g.

leapectione med teste of items or activiales for stich they are reopenetble (e.s.. pleet serveillance test mainteneece teste, etc).

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l.lle 3/72 Amst MS.I.8 1975 9eeller.Ase=reece Begetromente for feetellettee. leepecties, and Teeting of I

Mecheetcel Egelpeset med Byetene l

i l.te 30 /26 AIIBt le45.2.9 1974 Cetteettee, storese and Neletenance of I

secteer Fener Fleet Geellty Aeourance tacept we will eeeply with the too-heer t

accorde vetleg of Sectice S.4 of Afl)J,M S.2.9 issued Jely 13. 1979.

i I.74 2/74 Alesl 345.2.lt 1973 Seelity Assuraece Teres and Deflottlene

'i 1.64 6/76 Amst 1843.2.11 1974 queller Assersees Segelramente for the Deelge of leeclear Power Fleece 1.144 I/79 Amst 545.2.11 1977 Aedities of Geelity Aseerence Fregree for le clear Power riante

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ATTACHMENT 2 (1983 FSAR Rev.)

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Ceaststr escutA1ceT BBquiteserts Aalt FCaedt (Egetf7Mesrts PtaTalWIWC TO TWE QUALITY A55URA80CB P90 craft

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.1 Casesete/teservettene t!j l.123 F/FF Anet 545.2.13 1976

$selity Assureece Regetramente for ig Centrol of Frecereuset of Itene and Services for touclear Power Pleste I

1.144 8/08 AIIst 1845.2.33 1970 Quellficetlee of $sellty Assurance

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Fregree Aedit Peteeeeel for leoclear Feuer tiente t

-l 1.33 2/F0 Aligt 310.7 1976

$selity Asserence Fregree Begelremente (operetten) 9/FS Aset ult.l 1971 1.0 Peroommet Selectise and Trafalog 2/F9 AIISI/ AIRE 3.8 1979 Ferseemet selectise and Trelates within three yeere of commerciel operettee f-4.15 12/77 I

Quelley Assurance for Radlelegical ii lesetteries Fragrome (morael eyerettene) -

Effloset Stresse med the Enestemment BTF

    • e AFCSS 9.S-1 1/F6 Omidollees for Fire Protectice for Itecteer Power Fleets I

l.16 2/76 Quality Creep Cleestftcettoes and standerde l

for Water. Stese, and Bedleectlee Weste teelse med cemetracties of siebte Campee Power Fleet started Je 1965 med meet of Casteleleg Ceepenente of stuclear rever Please the work caemet comply with the specific regelsesente of Begulatory Calde 1.26 February 1976 The lesset of the Reg.

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Calde hee been followed as eheme by j

cooperleg the seg. Celde with Tables 1.t-2 and 3.F-3 le tiev FSAR.

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ATTACHMENT 4 j g SAS 16:58 NEDNESDAY, JULY 183 T9 (~~Tkf ~ PACIFIC OAS AND ELECTRIC COMPANY ll ACTIVE EMPLOYEES 1973-1984(' APRIL) ~ ll l DIVISIONsGENERAL OFFICE DEPARIMENT EXEC VP FACILITIES QUALITY ASSURANCE l F, n.. ;.... ", -~197 3 ~1974 1975 1976 1977 1978 1979 1980 1981 1982 '. 983 sI*1984 (DEC) (DEC) (DEC) (DEC) (DEC) (DEC) (DEC) (DEC) (DEC) (DEC DEC ~~lAPR) i 'l MGT./ PROF. LEVELS 7 A UP 1 1 1 1 4 3 4 5 5 5 '5 ' 13 MOT / PROF. LEVELS 5 & 6 9 13 14 16 11 13 14 10 9 12 14 15 -l HGT / PROF LEVELS 1-4 2 2 3 2 3 9 i .=_____..___________...__________________________________________.__5._.___4'_. I' MGT./ PROF. SUBTOTAL 10 14 15 17 17 18 21 17 17 22 23 37 ', lj ADV. CLERICAL 1 1 1 1 3 6 6 5 8 7 8 6 1t ElllRY CLERICAL 1 1 2 2 3 3 3 5 6 7 10~ 18 ______________===__ CLERICAL SUBTOTAL 2 2 3 3 , 6 9 9 10 14 18 16 ..____.___..._____________________...._____...._______14 TOTAL 12 16 18 20 23 27 30 27 31 36 41 53 w.

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.,i AVERAGE ANilUAL CHANGE IN TOTAL EMPLOYEES 1973 TO 1983 IS: 13.07x N #O NOTE: COUNTS FOR YEARS 1973 THROUGH 1983 HAVE BEEN ADJUSTED FOR CHANGES IN THE ORGANIZATION. ALL COUNTS REPRESENT AS CLOSELY AS POSSIBLE THE ORGANIZATIDHAL STRUCTURE AS OF APRIL 1984. ~ ~ ~ ~ ~ - ~ - ~ PER$0N!IE L INFORMATION AND TECHNICAL SERVICES RitRAY(X4005) !i h )

  • Tliis cliart only shows l'G.inilE employees anal ilous not incluilo consultants wa s-k i ng, f o r t iie 1) epa r t men t in 198'l anil 19H4.

] NO

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.~ n!. t- .. ~. s. e h ,e-o ~ ' Item 4 Nuclear Regulatory Commission . Inspection Activities (a) Construction' Inspections (MC-2512) Construction is essentially complete and the construction inspection program is complete with the exception of several modules (listed below) which were left_open to allow examination of the Lawrence Livermore National Laboratory contractor inspections. 1) 50090 Safety Related Pipe Support and Restraint Systems 51054 Electrical-Observation of Work t! 55063 Safety Related Structures - Observation of. Work 'l 55064 Safety Related Structures - Observation of Work-These inspections will continue at a decreasing pace through January j ', 1985. Final contractor reports are expected in March 1985, although this might slip a month if the licensee still is completing substantial safety related work. e'[ Construction items which current requ e follow-u ude; plant

j rupture restraints, structural ad miscel an steel work in the containment, examinatio of PG report cracking in PPP rupture

.q !t restraints, examinatio of pipe hangers nd vacuum breakers in ( l Unit 2 ASW system, fire door upgradin penetration seals an ng, t

j repair of polar crane mal oist ing, installation o ube ane

,1 blocking devices in steam generators, and completion o the RVLIS.

1 Closeout of these items will require about 2 manweeks f effort.

j; (b) Operations Inspections, Preoperational Testing (MC-2513) i The inspection program for preoperational testing has been completed j' with the exception of hot functional test (HTT) observations and results l review which are currently being completed. Licensee personnel have scheduled completion of the HFT by December 1, 1984 although they are currently two to three weeks behind schedule. The modules remain open l. to evaluate the HFT and its results are listed below. '1 l 70312 Preoperational Test Witnessing 4 70314 Witness Hot Functional Tests 5 70320 Evaluation of Test Results i 70322 Evaluation of ESF Test Results ii The licensee's radiation protection program is identical for Unit.I and 2 and therefore, should only require implementation in the Unit 2 areas of l-the plant coincident with establishing operability of hardware and ~ procedure implementation to allow Unit 2 fuel load. At this tir. Sixteen preoperational tests, NUREG 0737/TMI items, and calibration /acc6ptance i of Twenty-two radiation monitors require completion. The following modules have been left open to allow tracking these items. i 17 I .~u. ,_ =*:,r,m = r i::~ T ~ ~ ~ ~ T"7.~ T*~::" ,. L. -.,-. :: T. -,

c. ~.... - - .~. 83320 Radiation Protection - Preoperational Inspection 84330 Radioactive Waste System - Preoperational Liquid and Solid Waste 84331 RadioactiveWasteSystem-Preoperat[on Gas Waste System ., 3 3 9 !/ 'h I b' h, , The licensee's operations staff app 6h adequate to operate and manage r; Unit 2, however, approximately twenty operators must be qualified for a i " hot" license for Unit 2 prior to fuel load. The Operator Licensing L' ? Branch has the lead for this effort and no modules remain open related - Ll O to staffing of Unit 2. N i Regarding TMI action plan item (NUREG 0737), There are twenty-four fuel { load and twelve full power items requiring completion by the licensee and 1 inspection by the staff. These items appear to be minor in nature (such i as calibration, approval'of procedures, etc.) and do not appear to be an impediment to licensing. Close out for fuel load items is scheduled for January 1985 and for full power items for April 1985. The last security inspection of Unit I was completed June 29, 1984. The licensee intends to inplenient the security program for Unit I by December 22, 1984 to support a fuel loading date of January 28, 1985. The Region V office has scheduled a security inspection for Unit 2 during January 7-11, 1985. Since emergency preparedness is done on a site wide basis, the e emergency preparedness program for Unit 2 was addressed during the preoperational inspection for Unit 1. The routine inspections and observations of emergency preparedness exercises conducted since the Unit 1 operational license was. issued have shown the program to be acceptable. (c) Operations Inspections, Power Ascension Tests (MC 2514) The programatic aspects of the power ascension test program for Unit 2 [ are essentially the same as those for Unit I and have been reviewed and approved by the staff. The modules remaining open involve the observations of tests, the review of results and evaluation by.the staff. N (d) Allegations and Investigations La' Allegations have been managed by the responsible Operations Branch and Section Chiefs which the Technical Support Branch doing most of the evaluation, investigation, and documentation. As of 0 tober 26, 1984 four hundred and seventy-eight allegations were open. orty-six were assigned to Region V, one-hundred-thirty-nine to 01, one-hundred and forty-three to PG&E, and one hundred and fifty to to NRR. The allegations being handled by Region V are divided between the in-office staff and the Diablo Canyon Residents. Since these ton ere examined originally for applicability to Unit 1, review to determhe applicability to Unit 2 must be completed. It s anticipated that thi's review will be documented in an SSER prepare'd by NRC and Region V personnel. 18 . ~.

.=.s

..-- ~. -.. - -.~..-, -. (~.; 1 I o t l l-OI currently has fifteen investigation cases in progress dealing with j Diablo Canyon Unit 2. Most of these cases relate to employee discrimination or intimidation and therefore do not appear to relate to the readiness for operation of Unit 2. On the other hand four cases l (5-84-022,027,028, and 029) relate to QA/QC of PG&E or its' . j contractors and might have some future impact. However, at this time there is no apparent impact on Unit 2 as a consequence of these i allegations. 1 I +' . O I 9 e I a l 19 ...._.._7 .-...._,. ~.,... - -.. _ _ _ _

.. ~.. _ Item 5 l Grnaric Corraepondence 'i Applicable to Diablo Canyon Unit 2 Since 1981 f j' GENERIC

RESPONSE

RESPONSE r LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS I' .'l l. ~ 81-01 Qualification of inspection, 07/14/81 Closed Units 1 and 2. PGandE responded that compliance with examination, testing and Regulatory Guide 1.58, Rev. 1, and Regulatory Guide 1.146, 1; audit personnel with, noted exceptions will be fully implemented by the date that Unit 1 is issued a full power operating license. 9 Compliance confirmed in Chapter 17 on the updated FSAR submitted September.21, 1984. 81-02 Analysis, conclusions, and NA Response is not required. NRC intends to develop additional recommendations concerning criteria for the requirements for operator licensing, and is operator licensing soliciting review and comments. Response to this request is voluntary. 'I d 81-04 Emergency procedures and 03/09/82 Closed Units 1 and 2. PGandE responded that Emergency Operating j training for station Procedures have been developed based on WOG .j blackout events guidelines. Required training has been incorporated g into operator requalification program. i: 'j 81-05 Information regarding the NA Response is not required, this Generic Letter provides l the program for environmental information in response to requests from licensees. It qualification (EQ) of safety-provides clarification of the EQ requirements of the related electrical equipment electrical equipment specified, j 81-06 Periodic updating of FSARs NA Response is not required until 2 years after issuance of i Unit 2 operating license, d a d 81-07 Control of heavy loads NA Response is not required. This Generic Letter corrects a l a text error in an earlier NRC transmittal and forwards 5 y missing pages. The original request to provide information on heavy loads was in a letter from the NRC dated 12/22/80 (not a generic letter). Response for Unit 2 on the control 4' of heavy loads was provided by PCandE submittal of 07/29/83, and supplemental response is scheduled to.be submitted mid-November. 81-10 Post-TMI Requirements for the 04/08/81 Closed ' Units 1 and 2. Information on EOF and staffing levels

~

Emergency Operations Facility - was contained in two PGandE letters both dated 1/13/81. NUREC-0737 Ill.A.I.2 PGandE is in compliance for Units 1 and 2 for required staffing levels. PGand E letter of 4/18/81 provides jl i 1 additional information. J d ki i

l Item 5 G n ric Corr *pondenca Applicable to Diablo Canyon Unit 2 Since 1981 [ 4 CENERIC

RESPONSE

RESPONSE t i LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS i NA Response is not required. Provided to PWR licenees and I 81-11 Second letter on BWR feedwater nozzle and control rod drive applicants for information only. return linenozzle cracking q 81-15 Environmental qualification of NA Response is not required. NRC transmits Policy Statement Class IE electrical equipment in response to concerns from certain equipment vendors and clarification of staff's clarifies NRC's position that summary type information alone handling of proprietary is not adequate to establish qualification. information. l 81-16 Steam generator overfill NA Response is not required. NRC transmit report and request i j that applicable information be factored into operator training and requalification programs. See generic j letter 81-28. i l81-17 Functional Criteria for ERF's NA Response is not required. Transmittal letter for NUREC-0696. p (NUREC-0696) P 81-21 Natural circulation cooldown - 12/07/81 Closed Units 1 and 2. PCandE letter summarizes review and provides vessel voiding assurance to alleviate concerns of reactor vessel voiding, f noting that Diablo Canyon operating procedures will be { revised, tests performed, and training implemented as [ outlined. Complete; see PCandE letter August 2, 1983, and September 26, 1984 (DCL-84-314). ! 81-22 Engineering evaluation report NA Response is not required. Transmittal for information and of H. B. Robinson reactor training purposes. i coolant system leak, 1/29/84 81-23 INPO plant-specific evaluation NA Response is not required. NRC requests that any such' reports reports be submitted through normal docketing channels. Cancelled by Generic Letter 81-23A. 81-23A INPO evaluation reports - NA Response is not required. NRC cancels Generic Letter 81-23. NRC request in Generic Letter l 81-23 is cancelled 4

i Item 5 1 Crneric Correvpondrnca Applicable to Diablo Canyon Unit 2 Since 1981 i, ll CENERIC

RESPONSE

RESPONSE j. LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS j i 81-25 Change in implementing schedule NA Response is not required. NRC transmits schedule of {' for submission and evaluation NUREG-0737 changing the implementation schedule to require t of upgraded emergency plans upgrade emergency plans from prior to " fuel load" to prior to " full power" authorization. i 4 5 j 81-27 Private and proprietary 06/11/81 Closed Units 1 and 2. In accordance with NRC request, PCandE jj material in emergency plans identified information that should be deleted by NRC from i previously transmitted PCandE submits prior to distribution l-to various Public Document Rooms, r 81-26 Steam generator overfill - NA Response is not required. See 81-16 (same subject). IOM [ lj additional criteria for Kaefer to Shiffer reports that requested training was [ li operator training and conducted for cold license candidates and was incorporated qualification in Requalification Training Program, and states no formal written response to NRC is required. 81-29 Request for schedule for 10/01/81 Closed Units 1 and 2. PCandE provided schedule of simulator simulator examinations, examinations through 1981 and all of 1982 for operator [ g N 1981 and 1982 licensing. t i I 81-36 Revised schedule for completion NA Response is not required. NRC transmits a revised schedule in of TM1 action plan Item II.D.1, response to a request for schedule relief for completing that i* relief and safety valve testing portion of NUREG Item II.D.1 related to PWR (EPRI) testing program. I 81-38 Storage of low level radioactive NA Response is not required. NRC guidance is provided on the wastes at power reactor sites variety of plans which are underway and how they should be + reviewed and approved. 81-39 NRC volume reduction policy NA Response is not required. NRC forwards the Federal Register statement Notice for information and use. 81-40 Qualifications of reactor NA Responca ir not required. NRC invites public comments on operators - license examinations license exaaination -iteria, j 82-01 New facility applications survey 03/11/82 Closed Units 1 and 2. PCandE responded that no new facilities or modificntions to facilities are anticipated. Therefore, no applications or requests of the type described in 82-01 would be submitted oy ruandE through 12/31/84.

_.~._m _.m_.__m Iten 5 Gantric Correspondance ~ t I 6 Applicable to Diablo Canyon Unit 2 Since 1981 1 ' l. 4 ' GENERIC

RESPONSE

RESPONSE 3 Q LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS i 4 82-02 Nuclear power plant staff NA Response is not required. NRC transmits the Policy Statement working hours - factors on factors causing fatigue of operating personnel at nuclear causing fatigue reactors. When R.G. 1.33 and NUREG-0737 are revised to reflect the policy NRC will contact each licensee by separate letter. s 1. i, 82-04 Use of INPO SEE-IN program NA Response is not required. NRC describes the Significant { j Event Evaluation and Information Network (SEE-IN) program j and encourages participation. H i 3 82-06 Transmittal of NUREG-0909 NA Response is not required. NUREG-0909 will be made part of [ N relative to Ginna Tube rupture the plant training program under NUREG-0737, TMI TAP 1.C.5.- d' l~ 82-09 NRC Staff positions concerning NA Response is not required.. Transmittal of NRC Staff positions environmental qualification of which will be used in the review of licensing submittals. 4 safety-related equipment y;;'d (Ref RG 1.89/NUREG-0588) w i' t q NA Response is not required. NRC transmits NUREG-0916 and notes O i: 82-11 Transmittal of NUREG-0916 I restart of Ginna Nuclear Plant that generic aspects are being developed as a result of lessons learned from the Ginna event, j d 82-12 Nuclear power plant staff 10/01/82 Closed Units 1 and 2. PGandE administrative procedures address-the f- ]L' working hours (ref: Generic revised working hours guidelines in Generic Letter 82-12. I a 5 y 82-13 Reactor operator and senior NA Response is not required. NRC transmittal, for information. lt reactor operator exams of the results of a meeting to discuss changes to j' examinations. l. NA Response is not required. NRC clarifies the number of 82-14 Submittal of documents to NRC 'i document copies to be submitted to the NRC. i I 82-18 Reactor operator and senior NA Response is not. required. Provides information and schedule g-U reactor operator requalification for NRC-administered requalification examinations. p i' I< L p i I t

_ = _ - - _ -. - - ~ l . t Item 5 Grneric Corraspondance Applicable to Diablo Canyon Unit 2 Since 1981 1 . CENERIC

RESPONSE

RESPONSE j. j LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS [ 82-19 Submittal of copies of NA Response is not required. PCandE follows the procedures documents to NRC outlined in making submittals to the NRC. NA Response is not required. NRC transmittal of NUREG 0906 for 82-20 Guidance for implementing standard review plan rule public comment. 82-21 Technical specifications for NA Response is not required. NRC guidance is provided for m I fire protection audits information. 82-22 Congressional request for 11/24/81 Closed Units 1 and 2. PGandE responded to NRC questions, stating l information concerning steam that PGandE has not accumulated any operating experience at i j.t generator tube integrity Diablo Canyon Units 1 and 2 and, therefore cannot provide q meaningful answers. [ -l l 82-26 Inadequate core cooling 04/27/83 Open Units 1 and 2. PGandE letters dated 4/27/83 and 8/19/83 L. i instrumentation system 08/19/83 provide all the information necessary for the NRC Staff g to complete their review, and state that the systems final j connections, testing, and calibration will be performed 1 during low power testing, and environmental qualification of the systems will be completed by 3/31/85. PCandE letter of 4 6/25/84 provides evidence of EQ documentation. NA Response is not required. NRC reminder to file subject 82-30 Filings relating to 10 CFR 50 production and utilization documents with the Director of the NRC. U 82-33 Requirements for emergency 04/18/83 Open Units I and 2. PGandE submittals provide schedule response capability - 09/19/83 information for completion of the requirements in [ Supplement I to NUREG-0737 04/30/84 Supplement'l to NUREG-0737. PGandE's submittal of 4/30/84 schedules Unit 2 SPDS, EOF, and TSC to be operable / ~, functional prior to Unit 2 criticality. In addition, f' the Control Room Design Review Summary Report is i scheduled 12/31/84, and completion of training of operators on E0Ps and SPDS, as well as implementation of i-l the Emergency Operating Procedures, are scheduled 3/28/85. [ f P 82-36 Meeting to discuss recent NA Response is not required. NRC meeting notice. developments for operating b licensing examinations [~ l [ L i I

. __. _ _, m _-_. .,,y.. . -.-,_ _ ~._ a-L~- ^q ' * ,/ ,C Item 5 Generic Correspond: nce Applicable to Diablo Canyon Unit 2 Since 1981 -t 4 1 GENERIC

RESPONSE

RESPONSE i LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS i I k 82-39 Problems with the submittals NA Response is not required. NRC provides procedures to be 1 g of 10 CFR 73.21 safeguards followed for all future transmittals to the NRC involving information g safeguards information. ] 83-01 Operator licensing examination 02/28/83 Closed Units 1 and 2. PGandE letter provides present estimate of j site visit anticipated requests for rite visits. ] 4 83-04 Regional workshops - NUREG-0737, NA Response is not required. NRC provides information on dates Supplement 1, requirements for and locations of regional workshops. emergency response capability ] 83-06 Certificates and revised NA Response is not required. NRC states new format of k* format for reactor operator and Certificates will be suitable for framing. O senior reactor operator licenses .l 83-07 Nuclear waste policy act of 1982 02/18/83 NA PGandE responded in letters dated 02/18/83 and 03/04/83 that 03/04/83 the Company is actively and in good faith negotiating with the DOE for required contract. A letter from DPHodel, the i U Secretary of Energy, dated 03/24/83 certified that PGandE [ is in good faith negotiating with DOE. 83-10e Resolution of TMI Action 05/31/83 Open Units 1 and 2. PGandE letters provide plans and schedules Item 11.K.3.5 - automatic trip 01/19/84 for resolution of TMI Action Item II.K.3.5. PGandE has of reactor coolant pumps reviewed the WOG report, " Justification of Manual RCP Trip i h for Small Break LOCA Events," and found the generic / d information presented justifies the manual RCP trip for Units 1 and 2 when RCP trip setpoints consistent with WOG i j " Emergency Response Guidelines," Rev. 1, are in use. [ PGandE's schedule for including the RCP setpoint trip in the t j Emergency Operating Procedures is March 28, 1985. 30, 1984. ) (One year N af ter receipt of WOG Guidelines - PGandE letter April 83-12 . Issuance of NRC form 398 NA Response is not required. NRC letter provides the form to be personal qualifications submitted by all applicants for operator and senior operator statement - licensee and senior operator licenses under 10 CFR 55. 83-13 Clarification of surveillance NA Response.is not required. NRC transmi'ts revised testing requirements for HEPA filters requirements to be used in proposed. Technical Specifications l and charcoal absorber units in when they are submitted. These changes will be incorporated ] standard technical specifications inthenextrevisjonoftheSJS.

~...-.-..-_-_.-~_.s- .y i i. j s V Iten 5 Centric Correepondsnee ij Applicable to Diablo Canyon Unit 2 Since 1981 1: i e GENERIC

RESPONSE

RESPONSE l. SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS u'j LuTTER v NA Response is not required. NRc provides clarification of the (* ' 83-14 Definition of " key maintenance 1 personnel" (Clarification of term " key personnel" as used in the NUREC 0737 revision ] Ceneric Letter 82-12) transmitted with Generic Letter 82-12. PCandE procedures are in agreement with this definition. (See also Generic Letter ]g 82-12). d 1 83-15 Implementation of Regulatory NA Response is not required. NRC recommends that all licensees If M-Guide 1.150 modify their technical specifications, if appropriate. PCandE i ] 10M, dated 8/18/83, from NPO to Licensing, states that no modifications are required. Qij 83-16 Transmittal of NUREC-0977 NA Response is not required. PCandE Procedure NPAR C-14, 'a relative to ATWS events at Supplement 1 " Dissemination of Operating Experience," has d) Salen 1 (includes 83-16A) been accepted as satisfying TMI Item I.C.5 in IE-IR 50-323, 81-10. b 83-17 Requalification exams for NA Response is not required. NRC highlights the need for h renewal of reactor operator ensuring that the validity of 10 CFR Part 55 certifications, i g and senior reactor operator and integrity and honesty of the requalification program, are adequately addressed in' facility procedures. NRC will review these procedures as a part of their audits of the licensed 1:.; reactor operator and senior reactor operator requalification Ii programs. 1 t NA Response is not required. Amendment No. 91 to Duane Arno'Id jf ~ Integrated scheduling for y' 83-20 J' Implementation of plant Energy Center operating license is provided to licensees' j. modifications .for information and possible use. i f83-21 Clarification of access control NA Response is not required. NRC letter provides clarification l" procedures for law enforcement of procedures. I visits J j[ I.' i: 83-22 Safety evaluation of " Emergency NA Response is not required. Transmittal of NRC's safety i: Response Guidelines" evaluation of WOC " Emergency Response Guidelines," and {' guidance for implementation. NA Response is not required. Transmittal of NRC's safety 83-23 Safety evaluation of " Emergency 5 Procedure Guidelines" evaluation of Combustion Engineering " Emergency Procedure ,i Guidelines," and guidelines for implementation. j - t

_m_._ Item 5 Generic Correspondence Applicable to Diablo Canyon Unit 2 Since 1981 ~ 4 GENERIC

RESPONSE

RESPONSE LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS l 83-26 Clarification of surveillance NA Response is not required. NRC transmits the revised i requirements for diesel fuel Surveillance Requirements that are to be used when proposed impurity level tests Technical specifications are submitted. 83-27 Clarification of surveillance NA Response is not required. NRC provides clarification of intervals in standard technical surveillance intervals. 83-28 Required actions based on 11/07/83 Open Units 1 and 2. PGandE letter provides the current status generic implications of and the schedules for completion of Generic Letter 83-28 i Salem ATWS events action items for Units 1 and 2. Submittals are scheduled i into 1986. 83-30 Deletion of Standard Technical NA Response is not required. PGandE issued DCL-84-127, Technical Specification dated 3/30/84, to submit LAR 84-07 requesting deletion of i j Surveillance Requirement the sorveillance requirement as required by Generic Letter 4.b.1.1.2.d.6 for Diesel 83-30. Unit 2 proposed Technical Specification submitted Generator Testing in PGandE letter DCL-84-309, dated 9/21/84, does not include

u the diesel generator surveillance requirement.

.a 83-33 NRC positions on certain NA Response is not required. NRC positions are transmitted for requirements of 10 CFR 50, information and use as appropriate. No written response Appendix R is required. 83-35 Clarification of TMI action NA Response is not required. NRC provides clarification of plan item II.K.3.31 analyses which can satisfy the requirements of NUREG-0737, [ Item II.K.3.31. 83-38 NUREG-0965 - NRC Inventory of NA Response is not required. Transmittal of NRC Dam Safety Dams Program for information. L 83-43 Reporting requirements of NA Response is not required. Draft Technical? Specifications 10 CFR 50, Sec. 50.72 and 50.73, for Unit 2 already contain the request'ed change. (New LER I and Standard Technical Rule). Specifications I i 83-44 Availability of NUREG-1021, NA Response is not required. NRC announcement of publication " Operator Licensing Examiner of the subject standards. Standards" i

~. _ _ - ... -.... _ -.-. ~ n. Itu 5 ~ 1 Ctntric Correspondance 2 't Applicable to Diablo Canyon Unit 2 Since 1981 ~ 4 ' '; GENERIC

RESPONSE

j' 'ii ! LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS .i Ii If84-01 NRC use of the terms "important 02/03/84 Closed Units I and 2. PGandE confirmed their intention to participate i[ .t to safety" and " safety related" through a Steering Committee which will represent PCandE on b (( this subject. 'l

) 83-02 Notice of meeting regarding NA Response is not required.' NRC saeeting notice.

NA Response is not required. NRC announcement of publication 84-03 Availability of NUREC-0933, "A prioritization of Generic of NUREG-0933. Safety Issues". ll

r p-84-04 Safety evaluation of topical NA Response is not required. Response would be only required if

{' 'I reports dealing with elimin-PCandE wished to take exemptions on asymmetric blowdown loa.is. jl ation of postulated pipe breaks Since PCandE's analyses have been accepted in SSER 7 and 8 H j-l in PWR primary main loops there is not reason to request these exemptions. ll 'I 2 S4-05 Change to NUREG-1021, NA Response is not required. NRC transmits a copy of a change E j " Operator Licensing Examiner to NUREG-1021 for information and use in keeping copies of, [ Standards" NUREC-1021 current. }l 84-08 Interim procedures for NRC NA Response is not required. NRC transmits interim procedures management of plant-specific for information. backfitting NA Response is not required. NRC provides instruction for l 84-10 Administration of operating tests prior to initial obtaining an exemption.to 10 CFR 55.25(b), and clarifies criticality (10 CFR 55.25) when an request is needed. No action is. required for Diablo Canyon Unit 2. L p'j 84-12 Compliance with 10 CFR, Part 61, 8/29/84 Closed . Units.1 and 2. PCandE's PCP update was submitted in the and implementation of the semiannual report (DCL-84-296, dated 8/29/84) to insure radiological effluent technical compliance with 10 CFR.61. The PCP applies to both Units I l i specifications (RETS) and and 2. PCandE's Unit I full power Technical Specifications j. attendant process control include the RETS, which satisfies the latest 10 CFR 61, 1a program (PCP) and the Unit 2 proposed. Technical Specifications includes ii the same RETS.. ,;t l'

i 84-13 Technical specification for NA Response is not required. NRC transmits a revision to the t

snubbers model specification, Rev. I of Surveillance Requirements for Snubbers. ,U n

Item 5 Grutric Correspond!nca ~ Applicable to Diablo Canyon Unit 2 Since 1981 ~ GENERIC

RESPONSE

RESPONSE l_ LETTER SUBJECT PROVIDED STATUS DESCRIPTION OF ACTIONS i 84-15 Propose staff actions to improve NA Response is not required for Unit 2. PGandE letter DCL-84-318, i' and maintain diesel generator dated 10/02/84 submitted the information requested in 84-15 reliability for Unit I to the NRC. Generic Letter 84-15 states applicants for operating licenses and holders of construction permits are ] not required to respond. i' 84-16 Adequacy of on-shift operating NA Response is not required. This NRC transmittal contains no experience for near term reporting requirement and is for information only, operating license applicants 84-17 Annual meeting to discuss NA Response is not required. NRC meeting notice. recent developments regarding operator training, qualifi-cations, and examinations 84-29 Availability of Supplement I to NA Response is not required. NRC announcement of publication of NUREC-0933 "A Prioritization Supplement I to NUREG-0933. No reply is required. h[$ of Generic Safaty Issues" 1 FEMA Interim Findings on State NA Response is not required. NRC transmits the interim finding of California Nuclear Pcwer Plant report for review, and recommends continued coordination Emergency Response Plan (NRC with offsite governmental authorities to effect the improvements letter dated August 16, 1984) identified by FEMA. i 1 i 84-20 Scheduling guidance for licensee NA Response is not required at this time. PCandE is not planning submittals of reloads that to submit reload analyses for at least two years, and a PCandE involve unreviewed safety Licensing task is identified and will be tracked to re-review questions Generic Letter 84-20 in January 1937. I

-..~.- -_--_.- _ e - Item 5 Cantric Correspondence Applicable to Diablo Canyon Unit 2 Since 1981 or Still Open j. IE

RESPONSE

RESPONSE ~ BULLETIN SUBJECT PROVIDED STATUS STATUS DESCRIPTION OF~ ACTIONS-fr 79-13 Feedwater nozzle pipe welds Jan. 1985 Open Program of inspection and testing for Unit 2 l! inspection will be completed 30 days after hot functional, l! but prior to Unit 2 fuel loading. 'i 79-14 Unit 2 safety-related piping Dec. 1984 Open The piping and pipe support review reports will include the infotration required'by this Bulletin This information will be provided in the Piping and Pipe Support Review Program Final Report, i.T 80-11 Masonary Walls 09/26/84 Closed NRC reviewing as to' acceptability of energy balance method of evaluation. Fixes to be ll completed prior to full power operation. l[ l Final' report required 30 days after surveillance.Ol 1 81-01 Schedule for surveillance of Dec. 1983 Open j mechanical snubbers Surveillance is required to be completed af ter i hot functional testing but prior to fuel load. Inspection Report 323/84-14 retains this item open for Unit 2. 82-02 Failure of gate type valves to 05/15/81 Closed PGandE letter indicates that containment completely close against isolation valves on the lines connecting to pressure, Supplement I the hydrogen recombiners would only open in a } post loss-of-coolant accident case. 1; Pressure is acceptably low so closure can be assured. No other action necessary. r 81-03 Cooling water flow block due to 07/21/81 Closed PGandE has monthly desusseling programs which mollusk infestation af ter inspection of the Unit I heat exchangers, proved effective. Unit 2 was not inspected. j! since it is subject to the same program and it l' was not in service at the time. j{ 6r 82-01 Alteration of radiographs of Closed Provided to Diablo Canyon for information only. [, welds in piping subassemblies No response required. Revision 1 Supplement 1. 1

.I Item 5 l, G;ntric Corrrepondenca Applicable to Diablo Canyon Unit 2 Since 1981 -i IE

RESPONSE

RESPONSE BULLETIN SUBJECT PROVIDED STATUS STATUS DESCRIPTION OF ACTIONS i 5. 82-02 Degradation of threaded fast-08/02/82 Closed PGandE letters provided response to Items 1 and [ eners in the reactor coolant 04/06/83 3. Stated that response to Item 2 will be i pressure boundary of pres-provided 60 days after completion of first ( surized water reactor plants refueling outage. Inspection Report 323/84-14 closes this Bulletin for Items 1 and 3. 82-04 Deficiencies in containment 02/02/83 Closed PGandE letter dated February 2, 1983 indicates electrical penetration that hard epoxy electrical penetration assemblies manufactured by the Bunker Ramo Co. have not been installed in Li.e containment at Diablo Canyo! Units 1 and 2. Inspection Report 323/84-14 closed this Bulletin. i I l f 83-01 Failure of reactor trip 03/09/83 Closed Response provided for Unit 1. Informationonly,! breakers to open on automatic no response required for plants with trip signals construction permits. See also CL 83-28. j .bi Inspection Report 323/84-14 closed this Bulletin.! 83-03 Check valve failures / raw water 06/06/83 Closed PCandE letter indicates that there are no check cooling system diesel generator valves in this closed system; therefore, this bulletin does not apply to Diablo Canyon. See Inspection Report 323/84-14 closed this Bulletin. f 83-04 Failure undervoltage function / Closed Information only. No response required because reactor trip breakers (CE AK-2) Diablo Canyon utilizes W DB type breakers. Inspection Report 323/84-14 closes this Bulletin. t 83-05 ASME nuclear code pumps and Closed PCandE has determined that there are no Hayward spare part/ Hayward Tyler Tyler pumps or spare parts at DCPP. No response Company, 10 CFR 2.790, is required. Inspection Report 323/84-14 closes this Bulletin. 83-06 Nonconforming materials supplied 11/16/83 Closed PGandE letter dated November 16, 1983 indicates by Tube-Time Corporation that PGandE has reviewed the list of purchasing facilities and receiving companies and has concluded that none of these materials have been incorporated in the Diablo Canyon Plant. Inspection Report 323/84-14 closes this Bulletin.

.. _ - _ -... _. _ -... _.__._ _ _. _ ~. I ..t ' Item 5 r, ! Gzntric Corresprudence { l Applicable to Diablo Canyon Unit 2 Since 1981 . i~ L- + .g ) IE

RESPONSE

RESPONSE [d q BULLETIN SUBJECT PROVIDED STATUS STATUS DESCRIPTION OF ACTIONS 0 ?.i \\

! 83-07 Apparently fraudulent products 03/22/84 Closed PCandE letter dated March 22, 1984 indicates O

l sold by Ray Mille. Inc. that none of the apparently fraudulent material i has been incorporated in any safety-related j items in DCPP. No further action required. Inspection Report 323/84-14 closes this Bulletin. Electrical circuit breakers 04/04/84 Closed PCandE letter dated April 4, 1984 indicates that L 83-08 I with an undervoltage trip Unit I and 2 do not use any subject circuit i f feature breakers for safety-related applications. { Determined that there are not similar appli-I j cations using the undervoltage trip feature. 1 [ 84-02 Failure of CE type HFA relays 05/08/84 Closed PCandE letter dated May 8, 1984 indicates that 5 in use in Class IE safety DCPP Units 1 and 2 do not use and do not y system contemplate use of such relays. f84-03 Refueling cavity water seal Dec. 1984 Open Reply being prepared by licensee. .[ i N t i i L 1 i i< 1 l I i l , i

- a..._.... ~ ~- - O I -- ~ 4 4 i. Item 6 7 j Enforcement History During construction and design of the Diablo Canyon Plant Unit 2 the number of minor items of noncompliance and/or violations have been fewer than other similar facilities. This is due to Unit 1 being the lead unit which allowed, the licensee to correct identified deficiencies in-Unit 2 after they were I identified by the staff in Unit 1. During the last two years more items of noncompliance have been identified during the Unit 2 construction. This is largely due to supplemental inspection effort from allegation follow-ut, er] the use of contract inspection personnel from Lawrence Livermore National i Laboratory. No enforcement conferences, confirmatory action letters, civil penalties or orders have been issued from Unit 2 of Diablo Canyon. It must be realized, however, that the staff and licensee have always concurred (in meetings and I correspondence) that information or problems discovered in Unit I would be applied to Unit 2. t At this time there are no uncorrected items of non-compliance or significant i open items. t I t ) 33

- -..~.~..-,-._.- h-i', - g i.! - i;. . g s l Item 7 i UNIT 2 DIABLO CANYON FROJECT QUALITY ASSURANCE AUDIT STATISTICS '} (a) PGandE and DCP Audits I Audits (1) Findings Observations (2) Stop Work Orders (3)* PGandE iI. 4; 1971 22 55 0 0 1972 43 124 24 0 ,j' 1973 28 77 10 0 1974 27 88 9 0 j 1975 89 114 2 0 j' 1976 32 5 0 0 1977 49 44 0 0 H 1978 134 179 0 0 1' 1979 96 88 0 0 j. 1980 81 48 0 0 j' 1981 83 68 0 0 1982(4) 68 110 0 2 j {; 1 1983 204 184 0 0 1 J> i! DCP l i *i 1982 3 0 1 0 ]! 1983(5) 20 23 14 .O A j. 1984 19 15 8 2 1 i Notes: i, (1) Includes audits which were both Unit I and Unit 2. ) e ) (2) The customary practice of PGandE was to write findings, not observations, in order to assure that mandatory corrective action took place. ).( .l N l (3) The formal Stop Work Order mechanism was sometimes not necessary since \\ mutual agreement on issues were reached and work was stopped voluntarily. ,j' (4) January 1, 1984 to September 30, 1984. i 3 (5) January 1, 1984 to October 26, 1984. e l-lt r if. i r 0 l t 34 1 . ::::==r:

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t l i 4 + 1 t { Item 7 (continued) (b) PGandE and DCP AUDITS STOP WORK ORDERS f Date Issued Reason Date Work Allowed to Resume f PCandE AUDITS i I June 15, 1982 Energy, Inc. QA Program Partial - 6/21/82 for furnishing Incore Partial - 6/28/82 Thermocouple Computer Complete - 8/16/82 Class IE Isolation System was found to be seriously deficient during an audit. September 29, 1982 Installation of Class IE Approximately 12/8/82 { Cable stopped at DCPP due Based on qualification to serious deficiencies testing. identified in the manu-facturer's QA Program during an audit. f ~ January 9, 1984 All work stopped due to Work resumed 1-19-84. serious deficiencies 1-9-84 to 1-19-84 work identified during an audit. continued under the auspices of a PGandE inspector and inspection plan. June 14, 1984 PI-42 issued May 29, 1984 June 14, 1984. Work was used in the field prior allowed to proceed once to incorporating QA PI-42, Revision 2, was comments on PI-42." issued. DCP AUDITS February 14, 1984 A number of individuals February 17, 1984. All not received Engineering personnel were trained. Manual Training. Work trained. Work allowed to proceed. August 20, 1984 Hold points bypassed, Stop work still in effect. calibrated equipment, PGandE preparing a letter welder qualification, to close out findings. uncontrolled drawings, Stop work expected to be at Hatch, Inc. in El Paso, lifted by October 31, 1984. Texas. 35 -e

9 j-.. l-Item 7 (continued) DIABLO CANYON PROJECT UNIT 2 QUALITY ASSURANCE AUDIT STATISTICS (c) Outside Agency Audits i I Audits Number of Number of StopWp3}. Audit Type Year Performed (g) Findings Observations Orders 4 .{ H. P. Foley QA Audits 1974 25 64 0 0 1975 24 48 0 0 l 1976 29 49 5 0 1977 15 19 3 0 1978 14 27 0 0 1979 16 54 0 0 l 1980 6 31 0 0 1-1-81 to 8-81 Notes: (1) Audits were both Unit 1 and Unit 2. (2) The formal Stop Work Order mechanism has not been necessary since mutual agreement on issues were reached and work was stopped voluntarily. P 36

s. - --- -

1 li Item 7 (continued) ? DIABLO CANYON PROJECT UNIT 2 QUALITY ASSURANCE AUDIT STATISTICS (c) Outside Agency Audits f Audits Number of Number of StopWg l Audit Type Year Performed (g) Findings Observations Orders Pullman j Internal Audits Scheduled 1971 1 3 0 0 1972 3 14 0 0 1973 14 62 0 0 1974 44 63 1 0 1975 30 28 1 0 1976 26 14 5 0 1977 11 7 2 0 1978 33 92 21 0 1979 31 79 13 0 1980 17 44 12 0 1981 13 31 1 0 Unscheduled 1978 5 70 0 0 i 1979 6 10 0 0 1980 9 11 4 0 1981 1 2 0 0 Pullman Corporate Audit 1972 1 4 0 0 1973 1 2 0 0 1974 1 0 0 0 1975 1 0 1 0 1976 1 6 5 0 1977 1 3 0 0 1978 3 52 0 0 1979 1 5 0 0 1980 1 8 0 0 1981 1 8 0 0 i 37

.:a..-- - ..._.z~ (......._.

  • 6 j

j f { Item 7 (continued) i 7 DIABLO CANYON PROJECT UNIT 2 QUALITY ASSURANCE AUDIT STATISTICS (c) Outside Agency Audits StopWg' Audits Number of Number of Audit Type Year Performed (3) Findings Observations Orders 4 1 Third Party Inspection Agency Audits i (Hartford) 1976 1 10 0 0 1977 1 2 0 0 i 1978 0 0 0 0 [, 1979 0 0 0 0 1980 0 0 0 0 1981 1 0 0 0 t GE Audit 1976 1 15 9 0 t NCS Audit 1977 1 79 0 0 j l ASME surveys 1980 1 0 0 0 1977 1 0 0 0 1972 1 0 0 0 l l* i> 38 _----_~...c j

.. -.. _.. ~. ..--..u...__. e Item 8 ('

  • 1 j

PGandE Construction Deficiency (50.55(e)) and Part 21 Reports -v APPLICABLE TO UNIT 2 l - R5 port Date Unit Number Subject Status Comments 50.55e Reports 'f 10/19/72 1* Unit 1&2 Possible Inadequate Hydrostatic Head Design Closed i 11/20/72 W* of concrete housing for auxiliary saltwater I pumps in intake structure. 03/29/74 1 Unit 1&2 Cracks in Unit I steam generator nozzle. Closed Investigation found no cracks on Unit 2. 04/24/74 W 07/09/74 W ! 08/28/74 W j 01/15/75 W I } 06/17/74 T Unit 2 Integrity of Thermoplastic Insulation in Closed [

07/10/74 W Switchgear Buses.

qu,03/26/75 W j e> ~ 03/18/77 T Unit 1 Leak in weld of FW nozzle to pipe. Closed Report made for Unit 1, Region V 04/18/77 W 1etter July 19, 1977 requested 05/12/77 W report contain data sufficient for i 06/03/77 W both Units 1 and 2 by NRR. Report 07/19/77 W sent on September 1, 1977. NRC 08/15/77 W

IE Report July 11, 1977 also j 09/01/77 W referenes this item.

i 03/22/78 W }'

04/17/78 W P

d l

  • LEGEND T Telephone notification W PG&E written response N NRC letter j

I: L si l' I I

,5 .._._J...._ 2, 1..L._ m...._ _ _ _...._ J_. ~ 1 ,1 'j l i Rzpert Date Unit Numbtr Subject Status Ccamento 4 .T i 'l 50.55(e) Reports (' cont'd) Nons T Unit 1 & 2 Radiographs of field welds were not recorded C1'osed Report initiated as result of a l' 4 l 06/03/77 W as required on Unit I field weld 197. May 6, 1977 Notice of Violation. I 07/13/77 W 08/04/77 W 10/26/77 W l 02/16/76 1 Unit 1&2 Improperly welded pipe hanger assemblies Closed t 03/07/78 W 05/12/81 W j

}

02/23/78 T Unit 1 & 2 Rated horsepower for auxiliary feedvater Closed 03/23/78 W pump motors inadequate to meet FSAR requirements 10/24/78 W l Nons T Unit 1 & 2 Mutually redundant Class I circuits in Closed Reported as a result of notice of-11/02/78 W control room. violation dated October 6, 1978. 01/18/79 W PCandE letter dated February 5, 1979 1 02/05/79 W closes 55(e) report. Work is to be completed following hot functional ,o-testing. ^} 11/13/78 T Unit 1 & 2 Columns on approved for construction Closed 12/22/78 W drawings'on the turbine building' exceeded allowables. 11/14/78 T Unit 1&2 Supplier provided materials with improper Closed 12/13/78 W documentation. l 01/31/79 W l

i.

4 i. ^ +

..a-..-....-, X_.---..__......------ 6 6 Report Date Unit Number Subject Stetus Commtnte l 50.55(e) Reports (cont'd) I . -i 04/04/79 1 Unit 1&2 Cracking on pipe rupture restraints made Open Final report for Unit 2 scheduled 1 05/03/79 W by Pullman. November 1984. i 12/09/80 W l' ? NONE T Unit 1&2 No specific bolt mounting requirements on Closed Reported as a result of notice of 05/22/79 W drawings. violation May 2, 1979. 06/08/79 1 Unit 1&2 Deficiency in manufacturing procedure used Closed 08/26/79 W .to check performance of Barton Lot 1 j transmitters. 06/25/79 T Unit 1&2 System generator water level measurement Closed NRR to investigate, rather than 07/26/79 W system. than Region V PGandE letter of ? 03/13/80 W March 13, 1980 closes 50.55(e). SSER 9. Section 7.8, Item d. i closes issue. j: i. 4 I 06/25/79 T Unit 1&2 Design of lateral seismic bracing Closed Deficient supports have been 07/23/79 W supporting electrical conduits and modified to comply with design

raceways, requirements.

C 02/29/80 T Unit 1&2 Insulation failure on electrical conductors Closed Unit 2 conduits have been realigned 03/21/80 W and embedded in concrete. 12/12/80 W i I s f il

'.. ^.' ~ ~ ~ 2. ..a.- e. 1-Report Dzte Unit Numbar Subj ect Statun C mments '[~~ b' } j 50.55(e) Reports (cont'd) - '} p. 09/29/80 T Unit 1&2 Control and inventory of aluminum. Closed 10/27/80 W j 12/04/80 T Unit 1 & 2 Containment spray pump start timing. Closed 01/19/81 W (diesel) 07/31/81 W i 01/29/81 1 Unit 1&2 Deficient 1-inch expansion anchors Closed ! 03/12/81 W manufactured by HILTI. ~ 05/05/81 W 07/21/81 W 02/06/81 T Unit 1&2 Hagan Model 118 (output 60% of full scale Closed Transistors in all Class IA 'j 03/09/81 W when input was open circuited). installations have been replaced. 05/14/81 T Unit 1&2 Design deficiency in 120 VAC vital Closed 06/12/81 W instrument power supply. panel. t l 06/17/81 W + [* 07/28/81 T Unit 1&2 Modification on doors to Hagan racks. Closed 08/27/81 09/15/81 T Unit 1&2 Containment spray pump start. timing Closed i 10/15/81 W (Containment Pressure)- l 01/09/84 W i h P r I t

~....__.T.. ..... _.. _ e; #... _..1. ,~ r i~ I J' . Rtport Date Unit Number Subject Status Comments 50.55(e) Reports (cont'd) f09/28/81T Unit 2 Deficiencies in design of systems contained Closed Closed since NRR is 'following [i i 11/05/81 W within the annulus area of the containment deficiency. Other deficiencies 03/16/82 W

building, that arose during verification program were identified in the verification program semi-monthly reports.

10/08/82 T Unit 2 Water hammer phenomenon in ASW system. Closed Vacuum breaker and piping 11/08/82 W modifications complete. One hanger remains to be installed. + 05/26/83 T Unit 2 Malfunction of Limitorque Valve Operator Open Screws will be replaced prior to 06/27/83 W fuel load. (DC2-EJ-12615) ! 03/01/84 W f.; i [' j Part 21 Reports ,G l l 03/31/78 1 Unit 1&2 Springs in NEMA motor controllers do not Closed Kick-out springs have been replaced. ! 04/03/78 W meet specifications. I 08/17/78 W ' 12/07/78 W i l I ? i; i-1 4. l l

.m_..__ -m----- i a-I 't i Item 9 i + DIABLO CANYON PROJECT UNIT 2 CONSTRUCTION STATUS -j i i Construction is essentially complete; however, minor modifications j remain. Hot functional testing will be completed by the end of November; and December 1 through 21, construction will be completed for the majority of the 4 j remaining items. Approximately 4,500 personnel associated with the project j team or construction are working at the site. The remaining construction activities and scheduled completion dates are listed below, t Rupture Restraints j All modifications inside and outside containment 12/21/84 i Civil / Structural / Architectural Minor structural steel mods: stiffener, plates, gussets, etc. (now 98% complete) 12/21/84 Misc. Steel: platforms, grating, handrails: removed or modified to facilitate other installation (now 85% complete) 12/21/84 Door installation / modifications (now 95% complete) 12/21/84 Painting required for fuel load 01/28/85 l Penetration seals 12/21/84 Mechanical Equipment Polar crane main hoist gear repair / replacement 12/14/84 j Replace media filter tank 11/26/84 Install tube lane blocking devices 01/11/85 Miscellaneous equipment repair 12/21/84 Pipe Supports (Approximately 500 left) 01/13/85 HVAC 01/13/85 Duct supports (Approximately 30 left) 11/16/84 HVAC for box and drum compactor areas 11/24/84 HVAC for penetration area 12/28/84 Electrical Penetration foaming 12/21/84 Rad monitor installation (RE-58 and 59) 12/28/84 Flux monitoring system 12/21/84 PA system (power block) 01/11/85 l l PA system (intake and yard) 03/22/85 Miscellaneous electrical and startup support 01/28/85 1 1 l 44

m. _._

=- 2._._ }. A. Tp..,., ~1, i Item 9 (Continued) ? 1 DIABLO CANYON PROJECT UNIT 2 CONSTRUCTION STATUS q l 3 Instrumentation 1 - J-t Transmitter changeouts (Rosemont) 01/28/85 i RVLIS 12/21/84 Miscellaneous instrumentation /startup/NPO support 01/28/85 i i t i 2 i 4 h 45 1 - u... s. i .J

. - =... -... -.. ~ es e "1" V

  • i

. Item 10 DIABLO CANYON UNIT 2 PREOPERATIdNAL TESTING The licensee's preoperational tes' ting program was 82.1% complete as of November 27,1984. ~ The Hot Functional Test is currently in progress with completion scheduled for December 20, 1984. Following Hot Functional Testing, only the following seven properational tests remain, of which all but the Condensate Booster Pump Initial Start and Condensate System Preoperational tests will be completed prior to fuel load. These two tests l will be subsequently completed prior to reactor coolant system heatup. Fuel Handling Procedures (System 34), Secondary Plant Chemical Cleaning, Condensate Booster Pump Initial Start, Condensate System Preop, Pipe Break Isolation Test, Backup Instrument Air Performance Demonstration, and Miscellaneous Addenda for non-aafety related systems. i I 46 .}}