ML20127B742
| ML20127B742 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/01/1984 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20125D664 | List: |
| References | |
| FOIA-84-740 NUDOCS 8406210045 | |
| Download: ML20127B742 (1) | |
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/ #g UNITED STATES O
l' n NUCLEAR REGULATORY COMMISSION f' .I CAsMiHcToN. o. c. 2csss
%, . . . . . / June 1, 1984 jg' CHAMMAN ,
( w . MEMORANDUM FOR: William J. Di rcks Executive Director for Operations FROM: Nunzio J. Palladino
SUBJECT:
DIABLO CANYON HEARING
- Congressman Udall, on May 23, 1984 sent us a letter describing his inquiry into the Diablo Canyon matter and listing items that NRC needs to address. I would like you to ensure that knowledgeable staff, e.g., those in IE headquarters who have QA expertise, focus carefully on the issues in the last paragraph in Congressman Udall's letter, especially those pertaining to-the NSC audit and related
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questions. If there are any questions on the questions, staff should check with Congressman Udall's staff. Answers (^' advance of the hearing. I cc: Commissioner Gilinsky Commissioner Roberts Commissioner Asselstine Commissioner Bernthal OGC
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UNITED STATES OF AMERICA f*b ' NUCLEAR REGULATORY Com ISSION COMMISSIONERS: '84 APR 13 P8:02 - i Nunzio J. Palladino, Chairman . .
,6 3t o Victor Gilinsky ... .." Ting a sN,:,,
Thomas M. Roberts BRANCH James K. Asselstine Frederick M. Bernthal , SENE APR 1? 'M4 l 1 In the Matter of - ll
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PACIFIC GAS AND ELECTRIC COMPANY, Docket Nos. 50-275 OL
)i 50-323 OL (DiabloCanyonNuclearPowerPlant, ,[
Units 1 and 2) / J l MEMORANDUM AND ORDER (CLI-84-5) , This decision completes the Nuclear Regulatory Comission's ("NRC" or [ _
"Cosmission") reinstatement of Pacific Gas, and Electric Company's ("PG&E" >
or " licensee") Facility Operating license No. DPR-76 (" low-power license") l toconductlow-powertests(atupto5%ofratedpower)attheDiablo Canyon Nuclear Power Plant Unit 1 ("Diablo Canyon"). The events leading up to the Consission's suspension of this license and subsequent steps to reinstate the license in part have been described in several prior crders of the Commission.1 Accordingly, this order focuses on events nich have , I The low-mer license was issued on September 22, 1981. See J+ CLI-81-22, 14 1RC 598 (1981). It was suspended on November 19, 1981. .. See,CLI-41-30,14NRC950(1981). Following substantial review and reanalysis of the desimi and construction of Diablo Canyon, and public meetings at which all < nterested parties participated, the Consission reinstated the low-power license in part to authorize PGAE to load fuel v and conduct pre-criticality tests (operational modes 6 and 5). [FootnoteContinued] l 94CA{d9+/M4
..;. , 2 .
occurred since the Comission's lagt order and refers back to previous , events only as necessary. Safety Review A Comission condition for reinstatement of Of ablo Canyon's low-pcwer license was the successful completion of an Independent Design Verification Program (IDVP). CLI-81-30,14 NRC 950 (1981).2' The IDVP was conducted by organizationsandindividualsnotassoc(atedwithPG&Eandwasmanagedby Teledyne Engineering Services (TES). PG&E conducted a separate design verification effort called the internal technical program (ITP) which was per'ormed by PG&E's Diablo Canyon Project ("OCP"), a joint organization of PGAE and Bechtel. Then, the NRC staff, with,the help of its consultant, i Brookhaven National Laboratory, conducted its own analysis. (FootnoteContinued] , CLI-83-27, 18 NRC (1983). Subsequently, the'U.S. Court of Appeals for the District oTTolumbia Circuit denied a motion to stay the Comission's authorization to PG&E. On January 16, 1984, the Comission denied Joint Intervenors' motion for a stay of fuel loading and pre-criticality testing at Diablo Canyon finding that these activities did not present significant health and safety risks and would not , prejudice subsequent Comission decisions or foreclose modifications,- if necessary, of.the plant. CLI-84-1, 19 NRC (1984). On January 25, 1984, the Comission reinstated anothee parY"of PG&E's low-power license by authorizing precritical hot system testing (operational modes 4 and 3). As a separate matter, the Comission declined to review the Atemic . Safety and Licensing Appeal Scard's decision in ALAB-728, 17 NRC 777 -
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(1983) which affirmed a decision by the Atomic Safety and Licensing Board on all issues other than quality assurance related to PG&E's
- application for a license to load fuel and conduct icw-power testing.
2 The Comission's Order required an IDVP of seismic, service-related contract activities prior to 1978. In addition, the NRC (Q staff required an IDVP of non-seismic, service-related contract activities, PG&E internal design activities and post-1978 seismic service-related contract activities. In addition to design verification, the IDVP also reviewed scme construction activities, i
o ,,,'. - 3 The scope of the IDVP and ITP, and the relation between them, is
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explained in detail in ALAB-763. 19 MRC (1984). Essentially all of Diablo Canyon's safety-related seismic design was reviewed: the ITF reanalyzed all of the seismic design for safety-related structures, systems and components, while the IOVP oversaw and verified selected portions of the work in accordance with the prcgram approved by the Comission. , The review of non-seismic safety-relatad design was not as comprehensive. The IDVP reviewed three safety-related systpms and two areas of safety-relatec analysis applicable to many other systems. Items of concern identified by the IOVP as potentially generic were addressed by the ITP for all systems designed by PG&E. In turn, the ITP verification work was sampled by the IOVP and the results reported in an Interim Technical Report (ITR). The j ITP independently reviewed other non-seismic systems. As a result of this, _
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interaction between the ITP and IDVP, the IDVP obtained a broad and ccmpre-hensive understanding of the non-seismic design of Diablo Canyon. The IDVP was completed in October 1983; PG&E's ITP is still ongoing. The NRC staff's review of the IDVP. Final Report is contained in Supplements l 18,19 and 20 to the Safety Evaluation Report (SER) for Diablo Canycn, Unit , 1. Supplements 18 and 19, PG&E's ITP, and physical modifications to the 1 i plant were the basis of the staff's recommendation of the partial rein-statement of PG&E's low-power license to load fuel and per'orm pre-criticality testing at Diablo Canyon. CLI-83-27, 18 NRC _ ,(1983). At , l that time there were still several open items and follow up items which the ! staff believed required resolution prior to reinstatement of the rest of lr the ' low-power license. [ V The staff has updated its progress on open items in Supplement 20 to l i
- the Safety Evaluation Report (SSER 20). The staff considered information
=_ __ - _ , _n-o .
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) in the seismic monthly reports from the IDVP and PG&E, the IDVP Final ,
Report, the PG&E final reports, and the Interim Technical Reports.3 SSER 20 presents the staff's safety evaluation of open items and follow up items that in the staff's view, must be satisfactorily resolved prior to the Commission's reinstatement of PGaE's authority to achieve criticality and perform low-power testing, i.e. reinstatement of the low-power license for Diablo Canyon, Unit 1. SSER 20 reports t, hat many of the open items and h follow up items previously identified fri SSERs 18 and 19 have been re-solved. On March 27, 1984, the NRC's Director of Licensing reported that in his view, all open and follow up ftems identified in SSER 20 had been resolved satisfactorily for reinstatement of the low-power license for I Diablo Canyon, Unit 1. He also stated that: (1) he knew of no new informa-l [, tion since the completion of SSER 20 which wculd affect the staff's con- _
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clasions or judgments in SSER 20; and (2) that any other issues not h addressed in SSER's 18,19, and 20 had been satisfactorily addressed for i the purposes of low power operation. ! The Comission also heard from Mr. Isa Yin, an NRC inspector at Of ablo ) Canyon. Mr. Yin reported that he had found inadequate compliance with the { quality assurance program for designing. supports for small bore and large l bore piping. He also stated that reinspection following mcdification of , the pipe suspensions would be rendered more difficult by the environmental conditions in the plant after operation at low-power. Accordingly, he ; requested that the Comission defer granting a low power license until PG&E - - 3 V The Interim Technical Reports (ITR) are called interim because they were issued before ccmpletion of the IDVP. The ITRs document the completion of technical issues.
5 had remedied the deficiencies in pi,pe supporting systems and those changes , had been reinspected by the NRC. . The Commission voted to defer reinstatement of the icw pcwer license for Diaolo Canyon until the disparity between Mr. Yin's views and those of the rest of the technical staff had been considered by the Advisory Comit-tee on Reactor Safeguards ("ACRS") - a statutorily created advisory commit-tee comprised of experts in various disciplines including nuclear engineer-ing, nuclear physics, and radiation heal'th physics. The ACRS met 'in public session on April 6,1984 and heard from Mr. Yin,other members of the NRC staff, and Mr. Stokes, a previous employee i at Diablo Canyon who had made allegations regarding the adequacy of the quality assurance program for the design of supports for small bore pipes. Mr. Yin had found that some of Mr. Stokes' allegations were correct. _
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The NRC staff infomed the ACRS that, on March 29, 1984 the NRC had convened a peer review panel of technical experts to review Mr. Yin's , concerns. The panel met with Mr. Yin, and later with representatives of g PG&E and scme of the contractors involved in the IOVp. The peer review panel also visited Diablo Canyon to examine in detail scme of the specific ? I items identified as deficient by Mr. Yin. After the visit, the peer review panel met with Mr.. Stokes, and somewhat later met again with Mr. Yin to [ discuss the panel's proposed findings. The panel concluded that Mr. Yin's concerns did not warrant delaying icw-power cperation of Diablo Canycn, but , l - l did require resolution prior to going to full-power. ,. L l Mr. Yin also addressed the ACRS. He stated that "while several , reverification and corrective action programs shculd be ccepieted by PG&E prior to NRC issuance of a full pcwer cperation license, there will be no apparent risk to the public health and safety to allcw the reactor testing
.. 6 up to five percent power at the present." On questioning by members of the -
ACR$, Mr. Yin reiterated his position in spite of his acknowledgement of some residual differences with the rest of the NRC staff. On April 9,1984 the ACR5 reported on its consideration of Mr. Yin's . concerns. Based on t:1e presentations by Mr. Yin and other members of the NRC staff and supporting documentary material, the ACRS found: We agree that it is acceptable to permit low pcwor operation at this time. We believe that sudh operation will not compromise correctiveactionsthatmaybprequired. In view of the statements by the ACR5 and Mr. Yin, the Comission
-concludes that the concerns previously expressed by Mr. Yin have been resolved satisfactorily and do not warrant deferring the reinstatement of the low-power operating ifcense for Diablo Canyon.
Qualf tv Assurance - The Joint Intervenors and the Governor of California raised issues related to design quality assurance and to construction quality assurance at Diablo Canyon. Their motion to reopen the record on the design quality assurance (0QA) program at Diablo Canyon was granted, and resulted in an adjudicatory proceeding before the Atomic Safety and Licensing Appeal Board at which the adequacy of the IOVP was a central issue. On March 20, 1984 the Appeal Board issued a 122-page decision in which it found: (T]he scope and execution of the applicant's verification program , have been sufficient to establish that Diablo Canyon Unit 1 ~, design adequately meets its licensing criteria. The applicant's .. verification efforts provide adequate confidence that the Unit I safety-related structures, systems and components are designed to
- perfom satisfactorily in service and that any significant design I
f~ deficiencies in that facility resulting from defects in the l Q applicant's design quality assurance crogram have been remedied. Accordingly, we conclude that there is reasonable assurance that
; the faciif ty can be operated withcut endangering the health and safety of the public.
7 ALA8-763, slip op. at 101. - [] ~ Additional motions filed by the Joint Inte-venors and Governor of California to reopen the record on OQA are still pending before the Appeal Board. , The Joint Intervenors and the Governor of California also sought
. reopening of the record on construction quality assurance (CQA). That
. motion was denied by the Appeal Board in ,ALA8-756,19 NRC _ (Dec.19, 1983). Petitions for review of that defision are now rending before the Cornission, and petitions to reopen the record are also pending before the Appeal Board.
In view of the pendency of the petitions for review of ALA8-756 (en construction QA), and of the fact that the time for filing petitions for
/~ review of ALA8-763 (on design QA) h'as not elapsed, we express no opinion as '
( , to the correctness of the two Appeal 8 card decisions. Nevertheless, we consider it worthy of note that there is nothing in the Appeal Board's decisions en construction quality assurance or design quality assurance to suggest that PG&E's low-power license should not be reinstated. A11ecations Since 1982, the NRC staff has received numerous allegatiens and , concerns about the design, construction, and operatien of the Diablo Canyon NuclearPowerPlant(DiabloCanyon)andthemanagementoftheseactivities . by Pacific Gas and Electric Company (PG&E)., As the IOVP neared c:moletien .. l
/ 4 'Q In early 1982, the staff received allegatices regaroing :ne design and operation of the ccmponent cooling water syste:n (C *WS) for Diablo (FootnoteContinued]
t and the target date for a Cosaission decision en reinstatement of the license apprjoached, the ficw of allegations became a deluge and the NRC staff, with Commission concurrence, established a special Diablo Canyon l Allegation Management Program ("0 CAMP") to pursue the allegations and t concerns to resolution. , The DCAMP is described in Supplement 21 to the Safety Evaluation l Reportfor,0:iabloCanyon(55ER21). The proced'ures for handling allegations under DCAMP included ccnfimat' ion of the allegation by l L contacting the alleger whenever possible, site inspections of construction i or documentation, independent measurements and evaluations where appropri-l ate, technical reviews, interviews with site personnel, public meetings en significant technical issues, discussions between the alleger and staff on-staff's findings,and reports to the Consission. So far, allegation manage-ment has involved more than 40 members of the NRC technical staff and con . l tractor personnel and required 18,000 person nours. The staff's review of l
. an allegation was not limited to the allegation itself, but included all l necessary related issues.
l i (FootnoteContinued] Canyon, Unit 1. The staff's evaluation of the allegattens is described - in Supplement No.16 to the Safety Evaluation Report (SSER 16). On the basis of that evaluation, the staff concluded that the CCWS satisfied ;, l l most design requirements, that the only deviation was acceptable on the **I basis of PG&E's satisfactory demonstration of design capability in this area, and that the allegations retardin the CCWS had no generic l implications . In ALA8-763, the Acceal card instructed the Oirector, l r% Nuclear Reactor Regulation, to ensure that FG&E's proposed technical specification on CCWS is incorporated into the plant technical Q specifications before permitting operation. The order of reinstatement of PG&E's low-power license is contingent on the Director's ccmpletion of that action.
9 On January 4,1984, the staff reported to the Comission on the .
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investfgation into 103 allegations using the procedure described above. SECY-84-3, 55tR 21. However, additional allegations continued to be received and the DCAMP has attempted *to keep up with them. Staff provided an updated written review of the allegations on February 6,1984 (SECY-84-61) and reported on them to the Consission in public meetings held on January 23, February 10, and ' March' 19, 1984. Sy mid-March, the total number of allegations was approximately,* 400. On March 20, 1984, staff issued $$tR 22, which addressed 219 of the allegations, including the ones addressed previously. Staff reported that it had examined 188 allegations in detail and determined that 31 other allegations did not warrant detailed review because they raised issues similar to those alre'ady considered or were not related to significant safety issues.
.~ In mid-March, the Consission gave public notice that it hoped to be -
able to make a decision on reinstatement of the license for criticality and low power operation on March.26,1984 In the weeks before March 26, j scores of new allegations were filed. Cne group, the Government Account-ability Project, filed allegations that were received by the Ccmission only hours before the scheduled meeting. Approximately 500 allegations f have now been filed. Needless to say, this flood of last- minute alleged ,
! new information, years after the adjudicatory proceedings began, has strained the Consission's resources. ,
As noted above, the first two hundred of the recent allegations have ,,
. been reviewed in detail under DCAMp. flo license, not even a icw pcwer license, can be issued without adequate protection to the public healtn and safety. However, special considerations apply to Icw power operatien. ! Most importantly, the possible consequences of an accident during low-power
's ,,.
10 , operation are 1imited to a very small fraction of those possible at full power. Low-power operation would generate between one-hundredth-and-one tenth of the radioactive fission products which would be generated by full power operation. Thus, any consequences of accident would be significantly less than those determined by the safety evaluation for Of ablo Canyon.
. Accident consequences would be further reduced by the lower quantity and rate of production of decay heat produced at [ow-pcwer as compared to that produced at full power. However, the e6ergy required to damage a reactor, the capacity of the heat removal systems, and safety features are not reduced by low power operation. Therefore ' accidents involving failures of these systems at low-power operation would evolve over longer periods than at full power operation and could be contained by equipment cperating at only a few percent of capacity.
[' s With the above in mind, all of the allegations have been reviewed - under one basic safety criterion: is there significant new infomation . - - - which suggests that some safety-related structure, system or component necessary for safe low power operation will not perfem its safety func-tion, or that there are such weaknesses in licensee's management or quality assurance that plant safety is called into sericus question. For the first - two hundred allegations, the results of the review are documented in SSER 21 and the transcripts of the public Ccmission meetings in January, February, and March. For the approximately 300 more recent allegations, , the Comission was faced with a choice of decision delay, while the review could be carefully documented, or reliance on a preifminary review and staff expert judgment without the more detailed documentation. The Cemis-sion has deliberately chosen the latter course. There is every reason to s , h -. -. . . . . . - -..- ... . -
g 11 'd p believe that more allegations will be filed and delay to provide written documentation will lead to paralysis in Cemission decisionmaking. All of the allegations received on or before April 13, 1984, have been reviewed under the criterion specified above and those necessary to be ,, As a result, resolved prior to license reinstatement have been resolved. c,
.none of these all egati ons warrant a delay in the reinstatement of the N low-pcwer license. Work under DCAMP will continue, both to document the reviews completed to date and to addres) those matters that need to be resolved prior to licensing at higher power levels.
Ocerator Excerience The Comission has also considered the circumstance that the regular - operating staff for Diablo Canyon has a limited amount of experience with
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operating similar facilities. T'he Comissi*cn was briefed on the issue by . PG&E as part of its cements at the public meeting of February 10, 1984 PG&E has 43 holders of senior operator licenses and 16 holders of reactor operator licenses at Diablo canyon. A typical licensee has successfully ccepleted: (1) a 30-month program on pcwer plant fundamentals, ecuipment, systems, radiation protection and administrative controls incluoing time on-shif t at the facility; and (2) an approximately year-long licensing program. Several license holders have participated in pre-operaticnal testing programs, hot functional testing programs, on-going testing, maintenance, surveillance and modification programs. Licensed operaters have also each had frem 200 hours to 300 hours of hands-on simulator training. Mcwever, because the operators have not had actual plant operational experience, additional experienced personnel will be on nand Oc I assist with startup operations. This extensive training of pG&E's
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F operators and PG&E's connitment to provide additional trained personnel - _r during start-up have led the Ccamission to find that FG&E has an adecuate operating staff for Diablo Canyon.5
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5eismic License Condition The Connission has also considered recent developments regarding the ! e characterization of the Hosgri Fault.. At the public meeting of March 26, l l l l 1984, the staff reported that it had regeived a preprint of an article by certain petroleum geologists who have used previously unavailable informa-tion developed during petroleum exploration to determine that Hosgri Fault is a thrust fault and not a strike / slip fault as previously believed. In view of this development, the staff proposed that PG&E should conduct l further seismic and geologic studies of the Hosgri Fault. Mr. Devine, a geologist.with the United States Geological Survey also discussed the new .. i
* ~ ~ - - . ..
i l 5The Consission notes that a literal reading of 10 CFR 55.25(b), which l was adopted'in 1963, would have required candidates for operator license
- examinations, at facilities that have yet to go critical,'to have had
" extensive actual operational experience" before taking the operator license examination. Since 1967, the NRC has taken the position, in
! publicly available* documents, that completion of NRC-approved training that utilizes simulators can, togetehr with other nuclear reactor activities, constitute adequate experience. Operators at Diablo Canyon and four other plants were licensed on'this basis. Because this long-standing l i interpretation of the rule does not match the literal language of the rule. l although it satisfies the rule's purpose and does not diminish safety, the . t Cosmission will shortly initiate a rulemaking proceeding to confonn the language of the rule to this long-standing practice. In the interin, the J i L Commission sees no reason to revoke or suspend existing coerator licenses, *,
- including those held by the operators at Diablo Canyon. The sophisticatien I of current simulator training provides a suitable basis for operator licensing, and similar training in lieu of operational experience consittutes no diminution of safety. Under these circumstances, tne Connission finds no reason to grant Joint Intervenors' April 10, 1984
" motion for a stay based on the operator license issue. 1 , . . . _ . ~ . .. :._.,,
. . - g3 l.-
p t,
-. findings with the Commission. In Mr. Devine's view, this new infomation
,( was not startling but more in the nature of a refinement in the understand- - l ing of the overall faulting pattern in the region arcund Ofablo Canyen, i4r. Devine supported the NRC staff's proposals for further study. He also g .
+
l l stated that, in his view, the new report did not warrant any change in the \ magnitude of the Safe Shutdown Earthquake for Diablo Canycn. j The Comission has determirfed that this new infomation does not affect its low-power decision. There is no indication that the new infor-mation undercuts the seismic design basis for Diablo Canyon. However, the Comission has asked the ACRS to review the new infonnation prior to any full power decision and to coment on a draft license condition which would require PG&E to reassess by 1988 the seismic design basis for Diablo Canyon. (, - . Additional Matters The staff has denied Joint Intervenors' petition for enforcement action under 10 C.F.R. 2.206. 00 84-8, 19 NRC _ (March 26,1984). Joint Intervenors contended that PG&E's failure to provide to the Comission a 1977 audit performed by Nuclear Services Corporation on the quality assurance program by Pullman Power Products, a PGAE contractor, required continued suspension of the low-power license. The Director, Inspection . and Enforcement found that PG&E made a material false statement by fatiing in 1978 to provide the audit to the 1.icensing Scard c:nsidering cuality J. assurance. However, the Director also found that under the circumstances. the material false statement was a violation of the icwest severity level and, as such, warranted only a Notice of 'liolation. That Of ractor's cecision is still pending before the Commissien for its detamination of
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whether to review it. 10CFR2.206(c)(1), tJnder these circumstances, the Comission expresses no opinion on the correctness of the Director's . decision. However, the Cc: mission finds noteworthy that nothing in the decision suggests that PG&E's low-power ifcense should not be reinstated. On April *.",1984, the Government Accountability Project (GAP) petitioned the Comission pursuant to 10 CFR 2.'206 to direct the Offfee gf Inspector and Auditor (OIA) to initiate.an investigation into alleged false statements by PG&E and the NRC staff regarding the resolution of allegations of deficiencies in design and construction quality assurance at Diablo Canyon. GAP also requested an opportunity to address the Ccemission on April 13, 1984 on the alleged false statements and suggested that the
.s Cemission defer any decision on reinstituting PG&E's low-power license for
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Diablo Canyon until this matter is' resolved. In addition, GAP requested , the Ccmission to direct the Office of Investigations (OI) to release transcripts of interviews with allegers to the Board considering design and construction quality assurance. GAP's request was supported by affidavits from Mr. Steven Lockert and Mr. Charles Stokes. Both have provided allegations to the Commission on several previous occasions; most recently, Mr. Stekes addressed the Advisory Cemittee on Reactor Safeguards (ACRS). Mr. Lockert's afficavit - refers to some welds, made in 1974 and corrected in 1977 for wnich, in some - instances, documentation was not provided until 1982. Deficiencies in welds and the quality assurance program for documenting repairs to welds have been the subject of many other allegations investigated by the staff. Simiiarly, Mr. Stokes' affidavit contains allegations of the type already extensively considered by the staff. Mr. Stokes' affidavit also draws
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~tal cenclusions based on his opinions of various actions taken at Diablo .
w ityon. For the most part, GAP's allegations of false statements by the NRC L .1 staff and PG&E are based on its own interpretation of the implications of ..r ;. y, various allegations regarding conditions at Diablo Canyon. Others of GAP's .' ~.1 m h.[ sty allegations are based on GAP's differences of opinion with various ujE statements by members of the NRC staff. To the extent that GAP relies on f, \t g s statements by Mr. Yin, GAP's conclusions.are not supported by Mr. Yin's iti statements to the ACRS and a Member of Congress. As for staff's k nt .
. "Je, implementation of its policy of reinterviewing allegers, the Cemission ..s.S notes that staff's policy was announced before GAP imposed additional t,$al precedural burdens on access to allegers. Finally, regarding statements y,, 4..
,(,j.d addressing compliance with 10 CFR Part 50, Appendix B, that issue is s3 Mi; '
( .. .1 ding before the Cemission in the context of its review of ALA8-756 and ALAB-763. Because those reviews are still pending, the Cemission Q,,y.[ expresses no opinion on this issue. Hcwever, the Cemission notes that the na Appeal Board found that PG&E had ccmplied with Appendix S. w'A.: s, Under these circumstances, the Cemission finds that nothing in GAP's .6
.f a,*.
2!,Gr' recent submittal requires the Ccmission to delay consideration of , , . . ,. j!%~5 reinstatement of PG&E's low-power license. Hcwever, the Ccmission has W, asked its Office of Investigations to consider GAP's request for the N protected release of transcripts of interviews to the Board anc has requested its Office of Inspector and Auditor to review the petitien and to take whatever actions it deems necessary. 4 - -.c==-- - . . . . . - - - . - - -
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~..'a' 16 f
., f,f Motion For Stay _ ,
Joint Intervenors have requested the Cemission to stay the effec- . tiv.eness of any reinstatement of PG&E's authority to operate Diablo Canyon b Unit 1 at low-pcwer until the ccepletion of all pending administrative
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matters and the conclusion of any judicial review of the Ccmission's 6 decisions underlying such reinstatement of authority. In the alternative, t f Joint Intervenors have requestee' the Cemissien to stay fc.' several days E any reinstatement of PG1E's low-power license to pemit them to apply to !l L the United States Court of Appeals for the District of Columbia Circuit for - an emergency stay pending appeal. Joint Intervenors base their request on i, three factors: (1) the issues raised in their stay request of October 31, f 1983; (2) pending allegations of design and construction deficiencies at I 01ablo Canyon and motions based on those allegations; and (3) an affidavit I ( -- by Dr. Michio Xaku. The Comission believes there is no warrant to stay _ the effectiveness of the reinstatement of PG&E's 1cw-scwer license until However, the Ccemis-all administrative and legal appeals are exhausted. sion will delay the effectiveness of this decisien until noon, April 19, 1984 (Eastern Time) to give Joint Intervenors an opportunity to read the decision and determine whether to pursue judicial review. Nothing has happened since October 31, 1983, which wculd cause the Ccmission to change its mind about Joint Intervenor's previous motion for a stay. As for recent developments based on allegations, the pregress en resolving these allegations indicates that they do not support a motion for stay. Finally, the generic nature of Dr. Kaku's affidavit reveals a lack of specific knowledge of the Diablo Canyon plant and, in ; articular, the The activities to be undertaken during start up and icw-scwer testing. affidavit does not describe any specific aspect of low pcwer cperation of
-_ ,1 17 4;.
\YkI' 3*J piablo Canyon nich would create an undue risk to public health Ql Rather, the affidavit is based on general and ,
or to the plant personnel. ,.~ well-known considerations, some of which are irrelevant to Otablo Canyon, l and hypothetical accident scenarios without any indication of their likeli- 'y,t; It is *};,;) hood of occurrence during icw-power operation at Diablo Canyon. et g well-established that speculation about a nuclear accident does not, as a tbv, f matter of law, constitute the inininent, irreparable injury required for State of.kdw York v. NRC, 550 F.2d 745, [Nh p. staying a licensing decision. 17 477 F. Supp. , e 754-57 (2d Cir.1977); Vircinia Sunshine Alliance v. Hendrie 3' 68,70(O.D.C.1979). Under these circumstances, the Cormission sees % {if. ' nothing in Dr. Xaku's affidavit which contradicts the extensive technica 10 For these reasoris, the Consission denies Join. g reviews of Otablo Canyon. < Intervenor request for a stay. c. l p (' il l l . l J ! 4, ..--..r-,re- --- e r
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s. 4 4 Conclusion The Ccamission hr.1 determined that the concerns which led it to : suspend PG&t's low-power license have been resolved to the point where that 4 license can now be reinstated in its entirety.6 g r.q Cosmissioner Gilintky dissents from this order. The separate views of Chairman Palladino and Cosmissio'ners Gilinsky a'nd Bernthal are attached. f It is so OROtRED. , f'f' For the Cosmission $.I
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/ 5AMUEL J. 1.C 'f Secretary of th Cossisston [.}
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. bI Dated at Washington, DC, y this \ N day cf 19,4 A{N l
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b, 6 5t111 pending before the Cosmission is PG&t's request for an .. extension of the expiration date of the original low-power license. As
*I the Conmission has previously stated, PG&E's extensien request is .-
subsumed within the proceeding on PGat's application for a full-power operating license. The staff safety evaluatiens, testh eny anc views o' the parties, and adhdicatory proceedings that have been held in tnis ( proceeding are all aeolicable, to the extent relevant, to PG&t's , (/ extension request. *he Cosmissicn finos that the previous adjudicatory hearings that have toen held satisfy the hearing reouests that have been ' - filed with regard to PGat's extension request and that, because PG&E's extension request does not raise any health, safety or environmental issues that have not been resolved previously, that extension request i should be granted. ,,,_,
~ ~ - - - - _ - - - - - - - _ _ - _ _ _ _ .
Chairman Palladino's Seoarate Views w N@; believe that it is important to put in context commissioner Gilinsky's statements about reactor operator experience. ; L The Commission did not " disregard a vital safeguard"; it has .
@l simply applied the same standards to Diablo Canyon that have fh n g been applied to other commercial power plants over the last 17 7 years. I see no reason to impose different standards on this $
f. plant than on the others which have. preceded it. f
?i
. e Each applicant for a reactor license is required to develop and f icplement an NRC-approved training program for its reactor operator candidates. It has been NRC practice to accept satis- i
.actory completion of an NRC-approved traini,ng program as ful-
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filling the prerequisite for an operator candidate to take an . NRC reactor operator examination. As pointed out by the staff in SECY 84-152:
"There are three phases of an NRC approved cold license training program. phase ! includes basic fundamentals and operation of a research reactor during which the trainee ,
The time normally
- performs at least 10 reactor startups.
phase !! includes ,; required to cover phase ! is 12 weeks. participatory observation of the day to-day operation of a
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, ,N pie..g nuclear power plant. n %{,p This observation includes normal
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Also included in this phase is the operation of a nuclear p,'i;}y$ power plant simulator similar in design to the facility for G. ' Ql; thich the' trainee will be seeking a Itcense. The duration r{ P . of Phase II training varies from four to six months. Phase 5 e l
!!! is the plant specific' des'ign lecture series which s
covers the features of trainee ls
- facility and normally take i}, ((f.h six weeks to complete." uw w yJ(Q.(,.'.)
40 yypy N;. 7 actor simulators have become sophisticated devices which $,hb rovide the opportunity to expose a reactor operator candidate O ( y ry p . c. a variety of plant operating conditions which is not generally t h. s i.. e on an actual plant. .
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t is also important to note that actual operating experience h:..\.~ K;3c.R s a number of components in which reactor operators are p+jM. volved. These include such activities as learning about tl,9../.
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Jte:s during construction -- a particularly good time to learn F.; PC.*s?.: Jut the plant., Ch.
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V..:n;y ; .,, , o . a-1so tant to comment on Commissioner Gilinsky's statement that , 'd.,V.h
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e, e.m visors with questionable qualifications may be positively c:t s gerous." .; iff]:.!h ,pl I categorically reject the implication that advisors ,e,- ...
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Diablo Canyon, or at any plant for that matter, are " positively J. rf*.T.o . s ..~ . )gts/s .
- Each advisor has previously had an operator ifcense ,.... .f
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at another commerical nuclear power plant and has undergone training and examination on specifics of the plant at which they : 61 are to advise. The debate that took place relative to Diablo [. Canyon was not about questionable qualifications. Rather, it was h/ E about whether the NRC1 itself administers the examinations for E these advisors or w'hdther the NRC au'd.its the examinations ;i administered by the utility. The C'ommission has decided on the t latter course of action, but neither course of action results in advisors who are positively dangerous. :
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4/13/84 IS.,tt n
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N.; ADDITIONAL SEPARATE VIEW OF COMMISSIONER GILINSKY @M fpn
. ON REINSTATEMENT OF LOW-POWER OPERATING LICENSE AT DIABLO CANYCN ;Wa:
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- 3. 3 Attached are the separate views which I distributed two *.:93
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.weeks ago when the Ccmmission last discussed the b:t&'
At j L,d reinstatement of the Diablo Canyon-icw power license. s. NN,_ if.7 e that time-I withheld approval because of the lack of actual iffn. s.p' .x operating experience on the plant's operating crews and the i rp*, absence of adequate compensating measures. The situation None of the licensed operators 7,p has not changed since then. I.i? at the plant has actua-1 operating experience at a comparable @E T v!G" commercial reactor. . w
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The Ccemissica has decided to require that the operators be , a The critical difference %n backed up by experienced advisors. m 3, between myself and the other Commissioners is over how to SM Advisors with ;? certify the advisors' kncwledge of the plant. w {t I g questionable qualifications may be positively dangerous. .. want the NRC to administer the examinations they will be 6.; given. The Ccmmission is satisfied with company '
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The view has been expressed that administered examinations. r it makes no difference who does the examining. I recard
-s]E this as naive.
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Since the Commission's last meeting on this subject a legal 6;i'{.
" has surfaced.
bar to low power operations at Diablo Can .: recuire
]Y I have discovered that the NRC's regulati-.3 -
- i. t
- r operators whose license examination is cen uered on a
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kri.i simulator, rather than on an operating plant, y-gQ -
" extensive actual operating experience at a comparable h".: w None of the Diablo Canyon, operators meet this b reactor". !%
- n Their licenses are tih,e refore invalid until such standard. .
ides M time as they either meet this test or the C:m=ission dec : !.i f the Py to exempt them frem this requirement on the basis o p.y. factors enumerated in the regulations.
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W:: After receiving a memorandum frem the General Counsel >4:c
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stating that the course followed in this case is "d
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( inconsistent with the plain meaning of tha regulations, the .;, Commission decided this morning to ignore._its regulations .. c. E.; The effect pc and simply assert that the licenses are valid. 1% v. is to disregard a vital safeguard which ensures that some : i: Had +. degree of experience is available on a planr's staff. w the regulations been followed, Diablo Canycn would not no $ The : find itself'without any experienced operaters. safety f se.: tire in the plant , operators are the most important since they have the discretion to undo all the other safety - features in the plant. It is hard to think of a more f important safety issue than the ccmpetence and experience o I the operators. I l
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~ SEPARATE VIEW OF COMMISSIONER GILINSKY REINSTATEMENT OF LOW-POWER OPERATING LICENSE AT DIABLO CANYON .R kk S':
I am withholding my approval of the reinstatement of the [@ 4
~
Diablo Canyon icw-pcwer license because I am net satisfied 2
=_..t y
with the readiness of the planti .for cperation. I.am ig g especially cencerned by the absence of commercial experience og, x on the operating crews and the failure to compensate ti
.,y.
adequately for this. 5 n' r y, There are two other a.;pects of this case -- seismic design il y
/
.and construction quality assurance -- which, while not ,_
disabling from the point of view of low-power operation, do not cast the NRC's own review in a particularly favorable t light. ! i Oceratine Staff Experience I regard the operator experience question as the most important one in this case. Seismic issues have received a is well to great deal of attention, as they should, but it remember that seismic protecticn is designed against unlikely contingencies. We rely on the operators for ensuring safety 24 hcurs a day, every day. l
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.v Diablo Canyon does not have a single cperator who has had ,%T.d. .
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actual operating experience on a co==ercial nuclear power . .' l,M,
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plant of comparable size. Four operators previously
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operated the Company's Humbolt Bay plant, a very small M% boiling water reactor -- one-twentieth the size df each ' btM- 0 9.m . -t Diablo Canyon unit -- which has been shut down for 8 years, L T. we b.J hardly relevant experience. Much has been made of the fact S@.E Jg: 4 of simulator training. This is. valuable, but it does not 2F
.wwM compensate for the complete lack of relevant commercial %g.g i
W n ,a experience. It is worth noting also that Diablo Canyon does 00.fn n
'U not have a site-specific si=ulator.
((ow v hid by W;c. c.wg 9 i This problem should have been resolved a long time ago. At H2 in {
. this point, there seems to be no alternative to --
fi .g f pg: L supplementing the shift crews with experienced advisors for 25h:. yM: l - - -the initial period of operation. The difficulty with the bhIk w-i .e way this has been done is that there is no assurance that ' 2.sfS@t
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they have the site-specific training and knowledge needed fl%a,, for safe operation. ' sM I would approve plant operation at low y 2.~ g power if the advisor on each shift previously held a senior INfdfl;i . R
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operator license on a large commercial plant, and if=he has ~ :ci@ Yf .
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, passed the site specific portion of the senior cperator g[ig w:qp license examination for Diablo Canyon. The Commission has [yy L im.2m l instead chosen to allow the Commanv itself to decide whether :-mW
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I continue to be concerned by the issue of seismic design 'Dl',,.~/
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Otandards. The root of the difficulty is that although PG&E 1. ..:s' - i,d.
.,A p, Gnd the NRC staff accepted a standard based en a Richter Qpgg mgg scale magnitude 7.5 earthquake fer the purposes of the f.-
licensing hearing, after the Hosgri. fault was discovered, M.
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in order to avoid having to make significant mcdifications 3 41 N $$$ to the design, PG&E and the NRC staff decided on a nu=her of '. Y. 9c.G. ,2 changes in the way the cost-Hosgri standard was applied. 5@3f; ,w
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i t.+ . e maximum extent. In at least one respect, which involved a }$,hMh c a, dsf..
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highly dubious technique. This reduction, referred to as ;:. , gu-the tan effect, was accepted by two licensing Boards which q i.cv,:s g
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thought that they, and the expert witnesses, understood the .N1::i?:!' RWsw technical basis. As it turns out, there is hardiv. any . h,. .n@ m.2 ...: . technical basis for the reductions. .h.%sgd Ci.swa.z ;t .
%?l.[(?,1 W p I asked the Commission to take review of this questica long $m.J.
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ago. There was cienty s of time to do a review before the 6 q:W ..< 'y.e plant was ready for operation but at each point the concern [,'h.r
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that plant operations might be held up persuaded the ; df 5 :.) e l Commission to ignore the problem. What I find particularly ~~'~.
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disturbing is that it was clear to me that the Ccemission , f - declined to take review not because it unders:ced the A
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6 5 seismic design and thought it to -be acceptable, but because (($." 1R 2 w b".: . it' looked like a can of worms,'and the Commission feared the -
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consequences of reopening the issue. @}E%
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%.hldyd The ACRS recently told the Com=ission that "we do not WM s#e.
U<fd.M believe that scientific or engineering analyses exist today M
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. . ~w reductions in free-field seisnlic spectra (the tau effect! b. m. w w/'$ 'A2 that he (Dr. Newmarkl reccm= ended for the Diablo Canyon .
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. tiny Nuclear Power Plant." Had the Committee stated this view .pQi S.m # y-t years ago when it originally reviewed the seismic design Q yF.M m.m -:s 4
standard, I doubt that the Boards would have accepted the ys.t t.W.&
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standard. WEh
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The most favorable statement that the ACRS could ultimately
;[gE mak's about the seismic standard was that the Committee $3M, w&,$
h.tM continued to feel that overall "the use of the staff approach leads to an acceptable level of safety in this O.'@ 46 instance." This does not address the tau reductions or M
%X whether the safety regulations have been satisfied. What I
[W pq take the Committee to mean is that the' earthquake chosen to M.f o , determine the seismic standard is too large and that the . L. . . , n.-t r
, g.4 plant's design is adequate for a smaller earthquake. No W
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s .t."- doubt the Committee also took into consideration the fact 'gg i *i. 3'
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- that Diablo Canyon is a relatively isolated site. The ACKS ..t did remind the Ccemis ion that it had earlier recc= mended . n. .
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T.v . that a thorough review of the entire seismic design be .. undertaken, to be completed about 1988. At yesterday's meeting, the Co= mission learned that a paper .. 95 which is to be delivered at the Scripps Institute in April C is raises new questions about the interpretation of the nature sc:- - 7, of the faults near Diablo Canyon. This new information d.k 5 v; p reinforces the need for a thorough review of the entire .., seismic design, as proposed by the ACRS. The Com=ission has .
.t now agreed in principle to such a study. I wish this had [j;':.
.?,..
been done earlier but I am prepared to accept this approach r .:v as a way of dealing with the seismic issue. s.
;4 4,'
Construction Quality Assurance . The NRC has received hundreds of allegations concerning the e Diablo Canyon plant. Because one of the allegations was sent to =e directly, I felt that I should look into how they were resolved. I chose the audit of the Pullman Pcwer Products, the prime piping contractor from 1971 to 1977, (new Quadre.x). An done by the Nuclear Services Corporation the . important conclusion of that audit report was that Full =an quality assurance system had been inadequate -- . 3 among other things, that "there is no confidence that .. welding done prior to early 1974 was performed in accordance with welding specification requirements.* Most of the The NRC staff initially piping had been installed by 1974.
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PG&E and a review of the staff',s cwn audit records for the . ',A period between 1971 and 1977.
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The NRC staff subsequently. decided to look into the f^ 5 ,i l
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allegation more closely, apparently because of the Regional @:.5< ,
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~~ December 1983, the staff issued.a supplementary Safety m. m
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"...no Evaluation Repcrt stating that it had found evidence -
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to conclude that there was a prograc=atic breakdown in P. . .K
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of the staff review are d'ocuments in Inspection Report '.:W m.
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50/275/83-37." .' . J 'TS] f '. :%;:-Q] ( -f.i,H When I asked to see the inspection rescrt three months .E later, the inseector initially refused to suppiv it to ce. $
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As'it turns out, only notes existed at the time that the l..'s a.g;: o staff wrote the SSER. So far as I can tell, the inspection .' .(.. .gg-3:WV report only began to be written at abcut the time I asked to d.d,n ! n .: .2 I see it. An explanation and correction of the reference to f '. ."wJ
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the inspection report was subsequently submitted by the :f % *.
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staff to the Ccmmission. , l
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l It now appears that the NRC staff called the leader of the NSC audit cnly in February and, when that persen said that f.. he could not remember much about the audit, did not pursue i V , q'
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-4: . .+i,v this further. More could readily have been done, and should have been done ea T4e.*..
I would have more confidence in this review if the NRC had .'. .e b S.. . .... first contacted the pecple who worked on NSC's audit, had -
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then completed the inspection report, subsequently written wn, A the SSER, and had only then. informed the Scard and the h :h
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Commission of its conclusions.*,
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-VIEWS OF COMMISSIONER SERNTFAL ON REINSTATENENT OF LOW-p0WER OPERATING ,[h![$
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.SE AT DIABLO CANYON
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. m:m..e Having gone through 2t years and literally hundreds of allegations, thousands of hours of inspections, reinspections, analysis, and i.
h investigation, we can often lose sight of the 98% that is done, since it is frequently the job of the Comission and especially the NRC staff to (% 9 e4 A
'I-focus on the 2% that remains undone. . . ;._
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*h i I would therefore like to state for the 7ecord the effort that has gone @q R.
into the long, painstaking, and sometimes just plain painful period of m
!w. 3A reevaluation and modification of the Diablo Canyon power plant. During [;'t Eh this. period the licensee, through its primary contractor, has spent some . gi 2,000,000 hours of professional effort to address the problems raised in 4 16 the fall of 1981 and thereafter; other firms have carried out % %k Mar independent evaluations to the tune of 250,000 hours; the staff of the kff$h.
m;N.u N t R". 's devoted 70,000 hours.to the technical issues, and another 18,000 q y. n M ho'b. .Jto evaluating allegations. Diablo Canyon is almost certainly the . . . . My most inspected plant ever built. fwd. All this is not to imply, of course, that legitimate questions cannot or yh. g.,
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jjf should not still be asked. I would like to focus on one or two such broad, and I believe legitimate, considerations that remain with respect
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!$;9z. .9 to the Diablo Canyon powerplant beginning operations. But first let me l note what is not reasonable or legitimate to expect in any such massive
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endeavor. What is not reasonable to expect is perfection. It is not @M{.;. W reasonable to expect all things to be perfect at any multibillion dollar g
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construction project, a project involving thousands of workers and . %$$, Gillions of independent steps ieading to ccmpletion, over a period of N.$ some 15 years. And, as might have been expected, Diablo Canyon was not serfect. What was not expected, was that it wasn't even just gcod
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!Oncugh, 21 years ago, when this second construction, as it were, began. . S In . gudgment, two important and legitimate issues deserve special . .i. . mention here today. One question, and perhaps the most fundamentally "' TJ A(0.U S U'-
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. important because it is unique to Diablo Canyon, is that of the seismic design adequacy of the Diablo Canyon facility. It should be understood that the science of geolcgy, and especially the study and forecasting of -
seismic events is an inexact science, as is the engineering of structures to withstand seismic events of a given magnitude. But the best experts available in the field today have offered rea;onable and sufficient assurance that the design basis and construction of this - plant is adequate to withstand the maximum probable earthquake in the geologic region of the Diablo Canyon plant. I have supported, and the l ACRS has recommended, a continuing review and evaluation of the state of _ the seismic art and science as it develops and relates to Diablo Canyon j over the next several years. l i In particular, I would note that the recent scientific paper, discussed l in some detail at the last meeting of the Ccmission, apparently indicates that, although the Hosgri fault may be screwhat closer than previously thought to the Diablo Canyon site, the probability is that a
. large, 7.5 Richter-magnitude quake would, under this latest hypothesis, .
be less frequent than previously thought. I therefore find no reasort, based on this latest of what I am sure wil1 be many more papers on California geology and seismology, to change my position on the seismic i adequacy of the Diablo Canyon plant. I have reached that conclusion on the basis of my perscnal inspection of the plant, the recccmendation of the ACRS, and the consensus of expert opinion. Another important issue is that Comissioner Gilinsky raises in respect j to operator qualifications. No one questions the legitimacy of that issue, and indeed, the Ccmmission is currently considering the cuestion i of how best to achieve not just adequacy, but excellence at all levels in nuclear powerplant operating staff qualifications. But the question - l here is not how PG&E and other utilities will achieve uniform excellence i I in the months and years ahead, but whether PG&E in its Ofablo Canyon . . operations today has achieved a standard that is, beyond a reasonable doubt, adequate to protect the public health and safer.y. I believe it has achieved that standard. What they have achieved is gcod, if not perfect. I would add that, consistent with the strong expressed desires i l
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- g of Comissioner Gilinsky, I believe the Comission does owe this licensee, as it does all our licens,ees, a clear statement, and soon, of ,
those further steps to be taken along the road to excellence in the operator corps as this licensee prepares for full power operation. It must be emphasized in this context that the Commission meeting this morning was not intended to address, nor is there any specific or implied need to address for low-power operations at Diablo Canyon, the question of the Comission's long. standing regulation,10 CFR 155.25, and the definition and practical application of that regulation in satisfying the literal requirement for "exi:ensive actual operating experience at a comparable reactor." The fact is, the Comission has either implicitly or explicitly concurred in the evolving application of 155.25 since its premulgation l' more than 20 years ago. The fact is, 555.25 was promulgated at a time when reactor simulators were not generally available. The fact is, in a 1967 memorandum, the General Counsel's , office explicitly cencurred in _ the criteria which the staff were then applying in determining whether - 155.25 was satisfied or not. The fact is,'the Comission participated in the development-of the ANSI standard which provided that simulator training was an acceptable means of acquiring necessary experience. The regulatory guides which endorsed that ANSI standard as a method of f complying with the requirements of 655.25 were published in their final form only after solicit.ation and consideration of public comments. L Further, the Comission was explicitly' infomed by the staff of the planned issuance of NUREG-0094 in June, 1976.
. It is both understandable and eminently reasonable that the prerequisites for operator licensing should change as the state of the art'in operator training techniques changes. Indeed, there are good ,,
reasons to rely heavily on simulator training as a prerequisite for operator licensing, not the least of which reasons is that in many respects the use of a simulator is superior to experience gained (d actually sitting at the centrols of a power plant Given the background of operator licensing criteria applied by this agency for the past 20
- s. . . .
= ..
' ~ years and the implicit, if not explicit, concurrence of the Comission in the application'of those criteria, the suggestion that any near tem J operating license applicant should'have a license denied or delayed because the Comission has suddenly changed its mind about what constitutes adequate operator cualification would be irresponsible, and would violate fundamental principles of fairness. The Comission has known exactly what'it has been doing for 20 years, what it is doing today, and what it intends to do with regard to operator training. The operators at Diablo Canyon meet Comission standards today, and will be requiredtomeetwhatmaywell,bfupgradedstan'dardsyettobeadopted t by the Commission in future regulations or regulatory guidance. Finally, I would address the cencerns raised by Mr. Yin at the last meeting of the Comission, and seemingly resolved during the intervening two weeks. I do not interpret Mr. Yin's carefully considered position to reflect total agreement with his colleagues on all technical issues. I would be surprised, and frankly a little concerned, if there were ever total agreement within our staff on such issues. But I do understand l (~ that there is new essential agreement on an action plan and timetable
~
! for resolution of the remaining questions, and more importantly, I agreement that those remaining questions and differences should not preclude criticality and 5% operation. I would caution that we are never entirely out of the woods in such matters, but I believe we have l made significant progress, sufficient to act affirmatively to reinstate the suspended license of Diab.lo Canyon. There has been a worthwhile and necessary process undemay during the E two weeks spent iesolving Mr. Yin's questions, with the help of the f expert third party oversight of the ACRS. I doubt, incidentally, that l Mr. Yin considers himself, as scme have characterized him, a "whistleblower" . Rather, he is a professional member of the NRC's own } *' l technical staff who has openly expressed several times over the last L L four months, his professional disagreement with other staff an a number of technical issues. That is as it should be. But although the issues $I r" had been on the table for months, and had been discussed extensively, r V they apparently had not been' discussed sufficiently prior to the 4
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,.' Comission's March 27 =eeting.
, So if I may pro #fer one plea,. to put,t:
kindly, to our staff and'especially t: the senior staff, it wculd be
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w. that in future, when such pecfessional disagreererts exis: a. org staff, . if the Cc= mission is expected :c resolve them in a ces fr.g, then the Comissien rust have the benefit of an active deba:e. Such a debate
., cannot occur when intrastaff ccrs:unications have bean ccor, and when there is net ever. agreement cr. what the cisagrescer.:s are.
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' , v, 4 UNITED STATES NUCLEAR REGULATORY COMMISSION y wAssmorou. o. c. 2asss APR 1315S4 Docket No.: 50-275 . -
Mr. J. O. Schuyler, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas & Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106
Dear Mr. Schuyler:
Sub.iect: Issuance of Amendment No. 8 to Facility Operating License No. OPR-76 (Diablo Canyon Nuclear Power Plant, Unit 1) By letter dated July 1,1983 the Pacific Gas and Electric Company recuested a change to the Appendix A of the Technical Specifications for the Diablo Canyon, Unit 1 Nuclear Power Plant. The chance would require certain actions to be taken if the ocean water temperature exceeds 6A*F to ensure adecuate ultimate heat sink capacity. We have ecmpleted our review and evaluation of the proposed change and conclude that it is acceptable. As you know, a notice was published in the Federal Recister regarding the above recuested change. No ecmments or petitions nave oeen received with respect C', the notice in connection with the action covered in this agreement. In addition,-- ' this matter was a subject of the Apoeal Board's recent decisien, ASLAB-763, '~ March 20,1984 which recuires incorocration of this Technical Specification change prior to authorization of plant " operation. Accordingly, the Commission has issued the enclosed Amendment No. 8 to Facility Operating License No'. DPR-76 for Diablo Canyon Nuclear Power Plant, Unit 1. A cocy of the Safety Evaluation Supporting this amendment is also enclosed. Sincerely, 0&'.- * -:--H !"". Gadc. '.'.'. J., $3 George W. Knichton, Chief Licensing Branch No. 3
. Division of Licensing Enclosures.
- 1. Amendment No. 8 to Facility ..
Ooerating License DPR-76
- 2. Safety Evaluation cc: See next page V
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Diablo Canyon Mr. J. O. Schuyler, Vice President Nuclear Pnwer Generation c/o Nuclear Power. Generation, Licensing - Pacific' Gas and Electric Ccmpany 77 8eale Street, Roem 1435
. San Francisco, California 94106 Philip A. Crsne, Jr., Esq. Resident Inspector /nfablo Canyon f!PS Pacific Gas & Electric Concany c/o US Nuclear Regulatory Comission
' Post Office Box 7442 P. O. Box 369 San Francisco, California 94120 Avila Beach, California 93424
. Mr. Malcolm H. Furbush Ms. Raye Fleming Vice President - General Counsel 1920 Mattie Road Pacific Gas & Electric Company Shell Beach, California 93440 Post Of* fee Box 7442 San Francisco, California 94120 Joel Reynolds, Esc.
John R. Phillips, Esc. Janice E. Kerr, Esc. Center for Law in the Public interes . California Public Utilities Comission 10951 West Pico Aculevard 350 McAllister Street Third Floor San Francisco, California 94102 Los Angeles, Cali*ornia 90064 Mr. Frederick Eissler, President Paul C. Valentine, Esc. Scenic Shoreline Preservation .
. 321 Lytton Avenue Conference, Inc. Palo Alto, California 90064 4623 More Mesa Drive -
( Santa Barbara, California 93105 Dr. William E. Ccocer
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Pro.fect Manager - 5511 . - - fis. Elizabeth Apfelberg Teledyrie Eroineering Services 1415 Cozadera 130 Second Avenue San Luis Obispo, California 93401 Wal tham, ifassachusetts 02254
!!r. Gordon A. Silver tir. Dick Blankenburg Ms. Sandra A. Silver -
Editor & Co ou blisher 1760 Alisal Street South County Publishina Ccmoany San Luis Obispo, California 93401 P. O. Box d60 Arroyo Grande, Cali#ornia 93470 Harry M. Willis, Esq. Bruce Norton,' Esc. Seymour & Willis Norton, Burke, Berry & French, P.C. 601 California Street, Suite 2100 202 E. Osborn Read San Francisco, California 94108 P. O. Box 10560 Phoenix, Arizona 85064 Mr. Richard Hubbard . MPB Technical Associates Mr. W. C. Gangloff Suite K !!estinohruse Electric Corocra* fen 17P.5 Hanf1 ton Avenue P. O. Box 355 - San Jose, Cali#crnia 96125 Pittsburgh, Pennsylvania 15230 - ffr. John Marrs, Managino Editor David .'. leischake*, Esc. San Luis Obisco County Teleoran Tribune P. O. Box 1178 1R1 Jonnson Avenue Oklahcra City, nkiancma 73101 , P. O. Box 112
/ San Luis Obispo, California 93406 1
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,. .s-Ar*hur C. Gehr, Esc. Mr. Themas Devine.
'Snell & Wilmer
- Government Accountabilf'.y ~
3100 Valley Center- Prn.iect Phoenix, Arizona 85073 Institute for Poliev Studies 190! Oue Street, W tir. Lee M. Gustafson, Director Washington, DC 20009 Federal Agency Pelattens
- Pacific Gas & Electric Company .
1050 17th Street, N.W. Suite 1180 Washington, DC 20036 Regional Administrator - Region V US Nuclear Regulatory Comission 1450 ftaria Lane ' Suite 210 Walnut Creek, Cali'ornia 94596 Or. Jose Roesset 3506 Ouval Road ' Austin, Texas 78759 Michael J. Strunwasser, Esq. Special Council to the Attorney General. State of California
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3580 Wilshire Boulevard, Suite 800 -
!!, Los Angeles, California 90010 -
Mr. Tom Harris Sacremanto See 21st and 0 Streets Sacracento, California 95814 Mr. H. Daniel Nix California Energy Comission 1516 9th Street, MS 18 Sacramento, California 95814 Maurice Axelrad, Esq. Lowenstein, Newan, Reis and Axelrad 1025 Connecticut Avenue, NW Washington, PC 20036 Lewis Shollenberger, Esq. US Nuclear Reculatorv Cemnission
' ~
Region V i) 1a50 ?5 aria 8.ane '~ Suite 210 Valnut Creek, California 94596
3 3 Chairman ~ San Luis Obispo County Board of Supervisors Room 220 . C6unty Courthouse Annex San Luis Obispo, California 93401 California Department of Health ATTN: Chief, Environmental Radiation Control Unit Radiologic Health Section
-741 P Street - Room 498 Sacramento, California 95814 Director Energy Facilities Siting Division
. Energy Rescurces conservation and Development Ccmmission
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1111 Howe Avenue Sacramento, California 95825 President California Public Utilities Commission . . California State Building 350 McAllester Street , . San Francisco,' California 94102 - p _ Mr. Joseph 0. Ward, Chief . Radiological Health 3 ranch State Department of Health Services 714 P Street, Office Building #8 Sacramento, California 95814 i e 6 h i
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PACIFIC GAS A'ND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-275 AMENOMENT TO FACILITY OPERATING LICENSE Amendment No. 8 License No. OPR-76
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Pacific Gas and Electric Company (the licensee) dated July 1,1983, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission; . C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health C- - and safety of the public, and (ii) that.such activities will be conducted in ecmpliance with the Ccmmission's regulations; 7 D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety o# the public; and
- E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by a change to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. OPR-76 is hereby amended to read as follows:
9
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_ _ . _ . . _ . _ . . - . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ . _ _ __________.w
T (2) Technical Scecifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 8 are hereby incorporated in this license. The Pacific Gas & Electric Ccmpan.y shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. This license amendment is effective as of its date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
-h 5:
U@.'c!t'!.di:1,'t1
. C:OrG:l . .
George W. Knighton, Chief Licensing Branch No. 3
,, Division of Licensing
~~
Date of Issuance: A?R 131554 ( ~, I S W e
- APR 13 7;gf ATTACHMENT TO LICENSE AMEN 0 MENT NO. 8 FACILITY OPERATING LICENSE NO. OPR-76 DOCKET NO. 50-275 Replace the following pages of the Appendix A Technical Specifications with the enclosed pages. The revised pages are identified by Amendment Number and contain vertical lines indicated the area of change. Also to be replaced are the following overleaf pages to the amended pages.
Amendment Pages Overleaf Pages VIII VII XIV X7 3/4 7-49 - B 3/4 7-7 . s -
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e . INDEX f , LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS
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SECTION PAGE 3/4.6 CONTAINMENTSYSTEMS 3/4.6.1 PRIMARY CONTAINMENT Contai nment Integri ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 6-1 Containment Leakage..................................... 3/4 6-2 Containment Air Locks................................... 3/4 6-5 Internal Pressure....................................... 3/4 6-7 Ai r Tempe ra tu re . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 6-8 . Containment Structural Integrity........................ 3/4 6-9 Containment Ventilation Systeh.......................... 3/4 6-10 3/4.6.2 DEPRESSURIZATION ANO COOLING SYSTEMS i("',' i Containment Spray System................................ 3/4 6-11 -- 3/4 6-12 Spray-Additive. System................................... ContainmentCooiingSystem.............................. 3/4 6.13 3/4.6.3 CONTAINMENT ISOLATION VALVES. . . . . . . . ... . . . . . . . . . . . . . . . . . . 3/4 6-15 3/4.6.4 COM8USTIBLE GAS CONTROL 4
- Hydrogen Analyzers / Monitors............................. 3/4 6-25 Electric Hydrogen Recombiners........................... 3/4 6-26 6
9 4 b6 e-. t t DIABLO CANYON - UNIT 1 VII e _ _ . .. .. ..--...y
T INDEX i LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.~7 PLANT SYSTEMS . 3/4.7.1 TURRINE CYCLE Safety Va1ves........................................... 3/4 7-1 Auxiliary Feedwater System.............................. 3/4 7-4 Condensate Storage Tank................................. 3/4 7-6 Activity................................................ 3/4 7-7 Main Steam Line Isolation Va1ves........................ 3/4 7-9 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION......... 3/4 7-10 3/4.7.3 VITAL COMPONENT COOLING WATER SYSTEM.................... 3/4 7-11 3/4.7.4 AUXILIARY SALTWATER SYSTEM. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 7-12 3/4.7.5 [^
\ '
CONTROL ROOM VENTILATION SYSTEM......................... 3/4 7-13 3/4.7.6 A0XILIARY BUILDING SAFEGUARDS AIR FILTRATION SYSTEM..... 3/4 7-16 3/4.7.7 SNUB 8ERS................................................ 3/4 7-18 3/4.7.8 SEALED SOURCE CONTAMINATION............................. 3/4 7-34 3/4.7.9 FIRE SUPPRESSION SYSTEMS Fi re Supp res s i on Wate r Sys tem. . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 7-36 Spray and/or Sprinkl er Systems. . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 7-38 CO 2 System.............................................. 3/4 7-40 Halon System............................................ 3/4 7-42 Fire Hose Stations...................................... 3/4 7-43 3/4.7.10 FIRE BARRIER PENETRATIONS............................... 3/4 7-46 3/4.7.11 AREA TEMPERATURE MONITORING............................. 3/4 7-47 ,, 3/4.7.12 ULTIMATE HEAT SINK...................................... 3/4 7-49
- P OIA8LO CANYON - UNIT 1 VIII AMENCMENT NO. 8
s INDEX BASES SECTION ' PAGE
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3/4.7 PLANT SYSTEMS - 3/4.7.1 TURSINE CYCLE............................................ B 3/4 7-1 3/4.7.2 STEAM GENERATOR PRESSURE /TEMERATURE LIMITATION........... B 3/4 7-3 3/4.7.3 VITAL COMPONENT COOLING WATER SYSTEM. . . . . . . . . . . . . . . . . . . . . 8 3/4 7-3 3/4.7.4 AUXILIARY SALTWATER SYSTEM............................... B 3/4 7-3 3/4.7.5 CONTROL ROOM VENTI LATION SYSTEM. . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 7-4 3/4.7.6 AUXILIARY BUILDING SAFEGUARDS AIR FILTRATION SYSTEM. .... . B 3/4 7-4 3/4.7.7 SNU8BERS................................................. 8 3/4 7-4 3/4.7.8 SEALED SOURCE CONTAMINATION.... ......................... B 3/4 7-5
- , 3/4.7.9 FIRE SUPPRESSION SYSTEMS................................. B 3/4 7-6
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3/4. 7.10 FIRE BARRIER PENETRATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 7-6 - 3/4.7.11 AREA TEMPERATURE MONITORING.............................. B 3/4 7-7 3/4. 7.12 U LTIMATE H EAT S INK. . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . B 3/4 7-7
. 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1, 3/4.8.2 ANO 3/4.8.3 A.C. SOURCES, D.C. SOURCES ANO ONSITE POWER DISTRIBUTION SYSTEMS....................... B 3/4 8-1 i 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE 0 EVICES. . . . . . . . . . . . . . . . . . S 3/4 8-2 1 .
t 9% f DIABLO CANYON - UNIT 1 XIV AMEN 0 MENT NO. 8 l
r ,,' 3 l INDEX
.ggjES SECiiON PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1 80RON CONCENTRATION...................................... 8 3/4 9-1 -
?
8 3/4 9-1 3/4.9.2 INSTRUMENTATION.......................................... 3/4.9.3 OECAY TIME............................................... B 3/4 9-1 ,-$h 3/4.9.4 CONTAINMENT PENETRATIONS................................. 8 3/4 9-1 3/4.9.5 C0MJN I CATI O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 3/4 9-1 3/4.9.6 MANIPULATOR CRANE....................................... B 3/4 9-2 3/4.9.7 CRANE TRAVEL - FUEL HANDLING BUILDING................... 8 3/4 9-2 3/4.9.8 RESIOUAL HEAT REMOVAL ANO COOLANT CIRCULATION. . . . . . . . . . . 8 3/4 9-2 3/4.9.9 CONT INMENT V,ENTILATION ISCLATION SYSTEM................ 8 3/4 9-2 ._ 3/4.9.10 and 3/4.9.11 WATER LEVEL-REACTOR. VESSEL and SPENT FUEL P00L.................................................... 8 3/4 9-3
. 3/4.9.12 FUEL HANDLING 8UILDING VENTILATION SYSTEM............... 8 3/4 9-3 3/4.9.13 SPENT FUEL SHIPPING CASK M0VEMENT....................... 8 3/4 9-3 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUT 00WN MARGIN......................................... 8 3/4 10-1 3/4.10.2 GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS.................................................. 8 3/4 10-1 .
3/4.10.3 PHYSICS TE5TS........................................... 8 3/4 10-1 3/4.10.4 REACTO R COO LANT L00P S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3/4 10-1 3/4.10.5 POSITION INDICATION SYSTEM - SHUT 00WN................... 8 3/4 10-1 ,, DIA8LO CANYON - UNIT 1 XV i -
.,., m P
__LANT SYSTEMS . 3fd 7.12 ULTIMATE HEAT SINK . 8.1MIT?iGCONDITIONFOROPERATION 3.7.12 The ultimate heat sink (UHS) shall be OPERA 8LE with an inlet water temperature of less than or equal to .64*F. APPLICA8ILITY: MODES 1, 2, and 3. ACTION:
- With the requirements of the above specification not satisfied, place a second
- vital component cooling water heat exchanger in service within 8 hours or be in at least HOT .*AN08Y within the next 6 hours and in at least HOT SHUTDOWN within the following 6 hours. The provisions of Specification 3.0.4 are not applicable. ,
SURVEILLANCE REQUIREMENTS 4.7.12 The UHS shall be determined OPERA 8LE by verifying the inlet water tem-perture to be within its if ait: . g -- a. At least once per 24 hours when the iniet water temperture is equal to or less than 60*F, or - -- q ,
- b. At least once per 12 hours when the . inlet water temperature is greater than 60*F but less than 62*F, or
- c. At least once per 2 hours when the inlet water temperature is equal to or greater than 62*F but less than or equal to 64*F.
I .
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P B she DIA8LO CANYON - UNIT 1 3/4 7-49 AMEN 0 MENT NO. 8
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. . i i PLANT SYSTEM BASES -
3/4.7.11 AREA TEMPERATURE MONITORING
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The area temperature limitations ensure that safety-related equipment will not be subjected to temperatures in excess of their environmental qualification temperatures. Exposure to excessive temperatures may degrade equipment and can cause loss of its OPERABILITY. The temperature limits' include allowance for an instrument error of 1* F.
.r.
3/4.7.12 ULTIMATE HEAT SINK 4
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The OPERA 8ILITY of the Component Cooling Water (CCW) System and the components that it cools is ensured if the CCW temperature remains equal to or less than
. 132*F during any condition assumed in the safety analysis. One CCW heat exchanger is required in service when the ocean temperature is 64*F or less.
Two CCW heat exchangers are required in service when the ocean temperature is greater than 64*F. If the reactor coolant temperature is less than 350*F (MODE 4), one CCW heat exchanger in service is adequate even if the ocean i temperature is greater than 64*F. ( , m 9 O f b d be ( OIA8LO CANYON - UNIT 1 8 3/4 7-7 . AMEN 0 MENT NO. 8
. -m SAFETY EVALUATION
;--7 AMENDMENT NO. 8 TO DPR-76 DIABLO CANYON NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-275 Introduction By letter dated July 1,1983 the Pacific Gas & Electric (PG&E) Company requested an amendment to the Diablo Canyon, Unit 1 Technical Specifications that would require certain actions to be taken if the ocean water temperature exceeds 64*F to ensure adequate ultimate heat sink capacity.
Evaluation In response to concerns raised about the heat removal capability of the Comconent Cooling Water System (CCWS), PG&E in letters dated March 18, Aoril 4, and May 18, 1983, provided the results of a re-analysis of the heat removal capability of the CCWS assuming the worst design-basis heat load (i.e. LOCA), and the most limiting single failure. PGAE further cennitted to placinq a Technical f s Specification on a 64*F ocean water intake temperature with appropriate surveillance, limiting conditions for operation, action . statements, and bases. (/ , In the event the ocean water temperature should exceed 64*F, the proposed change would require placing a second component cooling water heat exchanger in service within eight hours or be in at least HOT STANDBY within the next six hours and in at least HOT SHUTDOWN within the next six hours. The staff evaluation of the above concerns, including the proposed technical specification, was provided in Supplement No.16 (dated August 1983) to the Safety Evaluation Report for Diablo Canyon (NUREG-0675, Supplement 16) which concluded that the proposed Technical Specification of 64*F and the associated 7 actions were acceptable and would provide adequate assurance of the ecmponent [ cooling water heat removal capability. Contact With State Official r,y copy of a letter dated October 11, 1983 to the licensee, the NRC staff advised the Chief of the Radiologica? Health Branch, State Department of Health l Services, State of California, of its proposed deternination of no significant hazards consideration. No comments were received. \ . D l' s l
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___ , _ . . . _ , - -~ _- _. _ 2-Environmental Consideration We have determined that this amendment does not authorize a change in effluent types or total amount nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that this amendment involves action which is insienificant from the standpoint of environmental impact and pursuant 10 CFR Section $1.5(d) (4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment. Conclusion Based upon our evaluation of the proposed change to the Diablo Canyon Nuclear Pcwer Plant, Unit 1 Technical Specifications, we have concluded that: there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and such activities will be conducted in compliance with the Cemission's regulations and the issuance of this amendment will not be inimical 'to the common defense and securit,v or to the health and safety of the public. We, therefore, conclude that
/. the proposed change is acceptable. .
k _.
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Dated: A?R 131:-M , a [( l C' L -
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UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION I WASHINGTON, D. C. 20566 i '
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- APR 181984 .
Docket No.: 50-275 Mr. J. O. Schuyler, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas & Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106
Dear Mr. Schuyler:
Sub.iect: Issuance of Amendment No. 9 to Facility Operating License No. DPR-76 (Diablo Canyon Nuclear Power Plant, Unit 1) The Nuclear Regulatory Comission has issued the enclosed Amendment No. 9 to
/_ the Facility Operating License No. DPR-76.
The amendment includes two license conditions. The first condition is for
~
a revalidation program for the seismic design bases for the Diablo Canyon Nuclear Power Plant. We are currently drafting more detailed requirements that should be included in your program. We will meet with you in the near future to discuss this matter. We intend to meet also with the ACRS on this matter and will brief the Comission at a later date. The second licensa condition is for additional .iet impingment analyses by Pacific Gas & Electric for certain lines within the containment in accordance with the Atomic Safety and Licensing Appeal Board decision ALAB-763 of March 20, 1984. We have received your response to that requirement (PG&E letter DCL-84-137, dated April 9,1984) and are currently reviewing the infonnation ' to assure that your analyses are fully responsive to this requirement. This license condition must be resolved prior to the issuance of a license authoriz-ing operation at power levels above 5%. , A condition relating to the comoonent cooling water system, also contained in ALAR-763, was previously incorporated in Amendnent No. 8 to Facility Operating License nPR-76, issued April 13, 1984. _; 2 k
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In its Memorandum and Order of April 13, 1984, the Comission determined that your request for extension of the expiration date should be granted. As ; noted by the Comission: l 1
"The staff safety evaluations, testimony and views of the parties, and l adjudicatory proceedings that have been held in this proceeding are all applicable, to the extent relevant, to PG&E's extension request. .
The Comission finds that the previous adiudicatory hearings that have e been held satisfy the hearing requests that have been filed with regard 4 to PG&E's extension request and that, because PG&E's extension request does not raise any health, safety or environmental issues that have not
- ~been resolved previously, that extension request should be granted."
Accordingly, the enclosed amendment approves the extension of the expiration date in accordance with your request of August 17, 1983. l The Comission has detennined that the issuance of the amendment will not result in any environmental impacts other than those evaluated in the Final Environmental Statement since the activity authorized by the license is encompassed by the overall action evaluated in the Final Environmental Statement. Enclosed is a copy'of the related Notice which has been forwarded to the ~~ Office of the Federal Register for publication. Sincerely,
.tt Darrell G. Eisenhud Director
' Division of Licensing Office of Nuclear Reactor Regulation
Enclosures:
- 1. Amendment No. 9 to Facility Operating License No. DPR-76
?. . Federal Register Notice 3
cc: See next page _, Q )
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' Mr. J. O. Schuyler, Vice President .
Nuclear. Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas and Electric Company 77 Reale Street, Room 1435 San Francisco, California 94106 Philip A. Crane, Jr., Esq. Resident Inspectnr/Diablo Canyon NPS Pacific Gas & Electric Conpany c/o US Nuclear Regulatory Comission Post Office. Box 7442 P. O. Box 369 San Francisco, California 94120 Avila Beach, California 934?d Mr. Malcolm H. Furbush Ms. Raye Flemina Vice President - General Counsel 1920 Mattie Road Pacific Gas & Electric Company Shell Beach, California 93440 Post Of# ice Box 7442 San Francisco, California 94120 Joel Reynnids, Esc. John R. Phillips, Esc. Janice E. Kerr, Esc. . Center for Law in the Put'!ic Interest California Public Utilities Connission 10951 West Pico Aoulevard 350 McAllister Street Third Floor San Francisco, California 94102 Los Angeles, California 90064 Mr. Frederick Eissler, President Paul C. Valentine, Esc. N Scenic Shoreline Preservation 321 Lytton Avenue
, Conference, Inc. Palo Alto, California 90064 - _ __
' 4623 More Mesa Drive
- Santa Barbara, California 93105 .Dr. William E. Cooper l Pro,iect Manager - 5511 l
fis. Elizabeth Apfelberg Teledyne Enoineering Services
- 1415.Cnzadera 130 Second Avenue can Luis Obispo, California 93401 Waltham, fiassachusetts 02254 i l
Mr. Gordon A. Silver ftr. Dick Blankenburg Ms. Sandra A. Silver Editor & Co-Publisher 1760 Alisal Street South County Publishinn Comoany , San Luis Obispo, California 03401 P. O. Rox 460 I Arroyo Grande, Califnrnia 934T0 Harry M. Willis, Esc. Bruce Norton, Eso. Seynour & Willis Norton, Burke. Berry ?. French, D.C. 601 California Street. Suite 2100 202 E. Osbnen Read San Francisco, California 94108 P. O. Box 10560 , Phoenix, Arizena 85064 -< Mr. Richard Hubbard '~ ifHR Technical Associates Mr. W. C. Ganolof# Suite-K uestinchruse Electric Cn*corarien 1725 Familton Avenue P. O. Box 3FE g San Jose, Cali#crnia 96125 Pittsburch, Pennsylvan ia 15T30 tir. John Marrs, Managino Editor Pavid e. c'eischake Sc. San Luis Obisco County Telecran hibune P. O. Box !178 L WZ1 Jonnson Avenue Oklahcra City, Ok'ahora 73101 P. O. Box 112 San Luis Obispo, California 93406 9
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'Mr. Toa Harris Sacremanto Bee 21st and 0 Streets .
Sacramento, California 95814 l Mr. H. Daniel Nix California Energy Comission 1516 9th Street, MS 18 Sacramento, California 95814 Maurice Axelrad, Esq. Lowenstein, Newman, Reis and Axelrad 1,025 Connecticut Avenue, NW Washington, PC 20036 Lewis Sho11enberrJer, Esq. US Nuclear Regulatory Comission - Region V 1450 fiaria Lane Suite 210 Walnut Creek, California 94596
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Chairman San Luis Obispo County Board of Supervisors - Room 220 - County Courthouse Annex : San Luis Obispo, California 93401 California Department of Health ATTN: Chief. Environmental Radiation Control Unit Radiologic Health Section 741 P Street - Room 498 Sacramento, California 95814 Director Energy Facilities Siting Division Energy Rescitrces Conservation and Development Commission 1111 Howe Avenue Sacramento, California 95825 (' President . (' California Public Utilities Commission . _ _. California State Building . _ . 350 McAllester Street San Francisco, California 94102 Mr. Joseph 0. Ward, Chief
. Radiological Health Branch State Department of Health Services 714 P Street, Office Building #8 Sacramento, California 95814 D
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# o,, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION h WASHINGTON. D. C. 20555 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-?75 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 9 License No. DPR-76
- 1. The Nuclear Regulatory Comission (the Comission) has found that:
A.1 The applications for amendments dated August'3, 1982 and August 17, 1983 by Pacific Gas & Electric Company (the licensee) for extending the expiration date of the low power license comply with the standards and requirements of the Atomic Energy r^. Act of 1954, as amended (the Act), and the Comission's rules and regulations set forth in 10 CFR Chapter 1; ( ,
~~
A.2 The requirement for revalidating the seismic design bases is made a license condition in accordance with the Commission's vote at a meeting on March 27, 1984 and in accordance with the Comission's Memorandum and Order CLI-84-5, dated April 13, 1984; A.3 The requirement for apprnpriate iet impingment analyses for certain lines inside the containment is made a license condition in accordance with the decision ALAB-763 of March 20, 1984 by the Atomic Safety and Licensing Appeal Board; B. The facility will operate in c.onformity with the application, a: amended, the provisions of the Act, and the rules and regulations of the Comission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comisison's regulations; _ ceemms'
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_ 2 D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, Facility Operating License No. DPR-76 is hereby amended as follows:
A. Section 2.F is to read as follows: F. This license is effective as of September 22, 1981 and shall expire three years after that date. B. A new Section 2.C.9 is added to read as follows: (9) Seismic Design Bases Revalidation Program PG&E.shall develop and implement a State-of-the-Art Program j . to revalidate the seismic design bases used for Diablo Canyon.. . _ , PG&E shall submit for NRC staff review and approval the ~ proposed Program Plan and proposed schedule for implementation by January 30, 1985. The piogram shall be completed and a final report be submitted to the NRC by July 1, 1988. C. A new Section 2.C.10 is added to read as follows: (10)JetImpingementAnalyses Prior to the issuance of a license authorizing operation at pcwer levels above five percent the licensee shall perform appropriate jet impingement analyses for certain lines inside the containment. ' This license amendment is effective as of the date of its issuance. FOR THE NUCLEAR REGULATORY COMMISISON l'
. E senh'u re to Division of icensing l Office of Nuclear Regulatory Commisison Date of Issuance: E 18 N i .
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7590-01 UNITED STATES NUCLEAR REGULATORY COMitISSION DOCKET NO. 50-275 PACIFIC GAS & ELECTRIC C0tiPANY NOTICE OF ISSUANCE OF At1ENDMENT TO FACILITY OPERATING LICE?lSE On September 22, 1981, the U. S. Nuclear Regulatory Comission'(the Comission) issued Facility Operating License No. DPR-76 to the Pacific Gas and Electric Company (the licensee) for operation of the Diablo Canyon Nuclear Power Plant, Unit 1 (the facility) located in San Luis Obispo, California, limited to five percent of full power (166.9 megawatts thermal).
- On November 19, 1981, the Comission suspended the license pending the ,
completion of an independent ' design verification program. The Comission on April 13, 1984, reinstated the license and indicated that the expiration date of the license should be extended in accordance with the Licensee's request. _ As part of this decision the Comission also decided to amend the license to provide an additional condition related to the revalidation of the seismic design bases for the facility. In addition, the Atomic Safety and Licensing Appeal Board, in its decision of March 20, 1984, required appropriate jet impigement analyses. The application for the license complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Comission's . regulations. The Comission has made appropriate findings as required by the Act of and the Comission's Regulations in 10 CFR Chapter I, which are set forth j in the amended license. Prior public notice of the overall action involving 4 i , C&hf
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- A 7590-01
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the proposed issuance of an operating license was published in the Federal Register on October 19, 1973. The extension of the expiration date authorized by this amendment and the conditions contained therein are encompassed by that prior notice. The Commission has determined that the issuance of the amendment will not result in any environmental impacts other than those evaluated in the Final Environmental Statement since the activity authorized by the license is encompassed by the overall action evaluated in the Final Environmental Statement. For further details with respect to this action, see (1) the Commission's i (, Safety Evaluation Report, dated October 16, 1974, and Supplements 1 through -- 22; (2) the Final Safety Analysis Report and Amendments thereto; (3) the Final Environmental Statement, dated May 1973 and supplements thereto; (4) the Partial Initial Decision of the Atomic Safety and Licensing Roard, dated July 17, 1981; (5) the Decision of the Atomic Safety and Licensing Appeal Board dated March 20,1984; and (61 the Comission's Memorandum and Order P dated April 13, 1984. These items are available at the Comission's Public Document Room,1717 H Street, N.W., Washington, DC 70555, and at the California Polytechnic State University Library, Documents and Maos Department, San Luis Obispo, California
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7590-01 C. , '
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Dated at Bethesda, Maryland this '18th day of April, 1984. FOR THE NUCLEAR REGULATORY CON 11SSION M Darrell G. Eipe'nh~ , D rector U DivisonofLktensing Office of Nuclear Reactor Regulation (
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[ NUCLEAR RECULATCRY COMMISSION 3 WASHINGTON, D. C. 20006 O , k ***** APR 181984 (,y Docket No.: 50-275 Mr. J. O. Schuyler, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas & Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106
Dear Mr. Schuyler:
Subject:
Grder to Modify Facility Operating License No. DPR-76 (D1610 Canyon Nuclear Power Plant, Unit 1) The Nuclear Regulatory Commission has issued the enclosed Subject Order. The Order sets forth License Condition 2.C.(11) which amends the license. The condition pertains to certain piping and piping support efforts that must be C,.~ completed by Pacific Gas & Electric Company prior to Diablo Canyon Unit 1 operating above 5 percent of rated power. The staff intends to audit and evaluate your efforts as they progress, including observation of the plant walkdowns. We request that you inform us as early as possible of your schedule for the hot walkdown of the main feedwater system piping to be performed after exceeding 5 percent power. The enclosed Order will be forwarded to the office of the Federal Register for publication. Sincerely, j > Ei nhut, Dire or Divison of Lidensing Office of Nuclear Reactor Regulation
-)
Enclosure:
Order to fiodify Facility Operating License No. DPR-76 cc: See next page v' y
9 - , . Diablo Canyon Mr. J. O. Schuyler, Vice President . Nuclear Pnwer Generation c/o Nuclear Power Generation, Licensing Pacific Gas and Electric Ccmpany 77 Beale Street, Room 1435 San Francisco, California 94106 - Philip A. Crane, Jr., Esq. Resident Inspector /niablo Canyon NPS Pacific Gas & Electric Conpany c/o US Nuclear Regulatory Comission Post Office Box 7442 P. O. Box 369 San Francisco, California 94120 Avila Beach, California 934?d Mr. Malcolm H. Furbush Ms. Raye Flemina Vice Presidert - General Counsel 1920 Mattie Road Pacific Gas & Electric Company Shell Beach, California 93440 Post Of# ice Box 7442 San Francisco, California 94120 Joel Reynnids, Esc. John R. Phillips, Esq. Janice E. Kerr, Esc. Center for Law in the Public Interest California Public Utilities Comission 10951 West Pico Roulevard 350 PcAllister Street Third Finor San Francisco, California 94102 Los Angeles, California 90064 Mr. Frederick Eissler, President Paul C. Valentine, Esc. Scenic Shoreline Preservation 321 Lytton Avenue N Conference, Inc. Palo Alto, California 90064
)- 4623 More Mesa Drive Santa Barbara, California 93105 Dr. William E. Cooper Pro.iect Manager - 5511 fis. Elizabeth Apfelberg Teledyne Engineering Services 1415 Cnzadero 130 Second Avenue .
San Luis Obispo, California 93401 Waltham, fiassachusetts 02254 ftr. Gordon A. Silver ifr. Dick Blankenburg Ms. Sandra A. Silver Editor & Co-Publisher 1760 Alisal Street South County Pub 11shinn Company San Luis Obispe, California 93401 P. O. Rox 460 Arroyo Grande, California 93470 Harry M. Willis, Esq. Bruce Norton, Esc. Sevnour & Willis Norton, Burke Berry /. French, P.C. 601 California Street, Suite 2100 202 E. nsborn Rnad San Francisco, California 94108 P. O. Box 10560 Mr. Richard Hubbard i4 MHR Technical Associates Mr. W. C. Ganolof' ' ' Suite K vestinchruse Electric Coronra H en 1725 Familton Avenue P. O. Box 3FF San Jose, California 96125 Pittsburch, Pennsylvania 15?30
/ fir. John l'arrs, Mana91no Editor Pavid c. eleischaker, Eso.
C San Luis Obisco County Telearan W ibune P. O. Box 1178 1R1 Johnson Avenue Oklahena City, OHahona 73101 P. O. Box 112 San Luis Obispo, California 93406
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x Arthur C. Gehr, Esq. Mr. Thomas Devine Snell & Wilmer Government Accountability 3100 Valley Center - Pro.iect Phoenix, Arizona 85073 Institute for Policy Studies 1901 Oue Street, NW Mr. Lee M. Gustafson, Director Washington, DC 20009 Federal Agency Relations Pacific Gas & Electric Company 1050 17th Street, N.W. Suite 1180 Washington, DC 20036 Regional Administrator - Region V US Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Dr. Jose Roesset 3506 Duval Road Austin, Texas 78759 Michael J. Strumwasser, Esq. Special Council to the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 C'/ L os Angeles, California 90010 Mr. Tom Harris . Sacremanto Bee 21st and 0 Streets Sacramento, California 95814 Mr. H.. Daniel Nix California Energy Commission 1516 9th Street, MS 18 Sacramento, California 95814 Maurice. Axelrad, Esq. Lowenstein, Newman, Reis and Axelrad 1025 Connecticut Avenue, NW Washington, DC 20036 Lewis Shollenberger, Esq. ~ US Nuclear Regulatory Commission Region V - 1d50 Maria Lane Suite 210 Walnut Creek, California 94596
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Q: -_ Chainnan - San Luis Obispo County Board of Supervisors Room 220 - County Courthouse Annex - San Luis Obispo, California 93401 California Department of Health ATTN: Chief, Environmental Radiation C~ontrol Unit Radiologic Health Section
'741 P Street - Room 498 Sacramento, California 95314 Director Energy Facilities Siting Division Energy Resources Conservation and Development Commission 1111 Howe Avenue Sacramento, California 95825 President California Public Utilities Commission California State Building Cs( .
350 McAllester Street San Francisco, California 94102 Mr. Joseph 0. Ward, Chief Radiological Health Branch State Department of Health Services 714 P Street, Office Building #8 Sacramento,' California 95814 i l
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I [7590-01] UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
PACIFIC GAS & ELECTRIC COMPANY ) Docket No. 50-275 (Diablo Canyon Nuclear Power ) Plant, Unit 1) ) ORDER MODIFYING LICENSE I. The Pacific Gas and Electric Company (PG&E or the Licensee) holds l License No. OPR-76 which authorizes the Licensee to conduct low power operation of the Diablo Canyon Nuclear Power Plant, Unit 1, at up to 5% of the facility's rated power. The license was issued on September 22, 1981, and was recently fully reinstated by the Commission after having been suspended in November 1981 pending the successful completion of an independent design verification program. II. During the staff's review of the results of the independent design verification program and other matters related to the readiness of Diablo Canyon Unit I for low power operation upon reinstatement of the sus- ;; pended license, a number of concerns were raised regarding the adequacy of the design and design control measures for piping and piping supports. In recent weeks, the Commission and the staff have devoted substantial
attention to these concerns to ensure that the piping and piping supports would not pose an undue risk to public health and safety if Diablo Canyon Unit 1 were permitted to operate at low power. Among its evaluations and inspections of the piping issue, the staff convened a peer review group of technical experts to review certain concerns raised by Mr. Isa Yin, an NRC inspector who had reported, on the basis of his review and inspection, inadequate compliance with design requirements, docu-ment controls and personnel training for piping and piping supports. The peer review group met with Mr. Yin, PG&E representatives, and some of the contractors involved in the independent design verification program. The group visited Diablo Canyon, and later met with Mr. Charles Stokes, a former employee at the Diablo Canyon Project site who had made allegations concern-ing the adequacy of small-bore piping and piping supports. The group later CN - met with Mr. Yin to discuss the group's proposed findings. In addition to the staff's reviews and inspections of the piping and piping supports, the Advisory Committee on Reactor Safeguards (ACRS) met in public session on April 6,1984, to hear from Mr. Yin, other members of the NRC staff, and Mr. Stokes. The peer review group and the ACRS concluded that Mr. Yin's concerns did not warrant delaying low power operation of Diablo Canyon Unit 1. Mr. Yin informed the ACRS that, upon further review of the matter, he did not believe that resolution of the piping issues required further deferral of the reinstatement of the low power operating license for Diablo Canyon ;_ Unit 1. Accordingly, the Commission reinstated the low power license on April 13, 1984. See CLI-84-5, at 4-6.
N .. (. The peer review group, the ACRS, and Mr. Yin agree that the piping issue requi~res resolution prior to authorizing full power operation of Diablo Canyon Unit 1. On the basis of the various reviews of this matter, the staff believes that a number of actions are necessary to ensure the adequacy of small and large-bore piping and pipe supports and to ensure correction of deficiencies, if any, before Diablo Canyon Unit I can be permitted to operate above 5% rated power. III. Accordingly, pursuant to sections 103, 161(1), 161(o), 182 and 186 of the Atomic Energy Act of 1954, as amended, and 10 CFR 2.204 and 10 CFR Part 50 of the Commission's regulations, IT IS HEREBY ORDERED
'THAT the Licensee shall not operate Diablo Canyon Unit 1 above 5% power C} until the Licensee has completed the specific actions which are set forth below in new License Condition 2.C.(11) to Facility Operating License No. DPR-76:
2.C.(11): Piping and Piping Supports
- 1. PG&E shall complete the review of all small-bore piping supports which were reanalyzed and requalified by computer analysis. The review shall include consideration of the additional technical topics, as appropriate, contained in License Condition No. 7 below.
- 2. PG&E shall identify all cases in which rigid supports are placed in close proximity to other rigid supports or anchors. For these cases PG&E shall conduct a program that assures loads shared between these J
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adjacent supports and anchors result in acceptable piping and support , stresses. Upon completion of this effort, PEE shall submit.a report to the NRC staff documenting the results of the program.
- 3. PG&E'shall identify all cases in which snubbers are placed in close proximity to rigid supports and anchors. For these cases, utilizing snubber lock-up motion criteria acceptable to the staff, PG&E shall demonstrate that acceptable piping and piping support stresses are met. Upon completion of this effort, PG&E shall submit ,
a report to the NRC staff documenting the results.
- 4. PG&E shall identify all pipe supports for which thermal gaps have been specifically included in the piping thermal analyses. For i
these cases the licensee shall develop a program for periodic inservice inspection to assure that these thermal gaps are main-tained throughout the operating life of the plant. PG&E shall sub-mit to the NRC staff a report containing the gap monitoring program.
- 5. PG&E shall provide to the NRC the procedures and schedules for the hot walkdown of the main steam system piping. PG&E shall document the main steam hot walkdown results in a report to the NRC staff.
- 6. PG&E shall conduct a review of the " Pipe Support Design Tolerance i, Clarification" program (PSDTC) and "Diablo Problem" system (DP) activities. The review shall include specific identification of the following:
s r * (a) Support changes which deviated from the defined PSDTC program L scope; a (b) Any significant deviations between as-built and design configur-ations stemming from the PSDTC or DP activities; and (c) Any unresolved matters identified by the DP system. The purpose of this review is to ensure that all design changes and modifications have been resolved and documented in an appropriate manner. Upon completion PG&E shall submit a report to the NRC staff documenting the results of this review.
- 7. PG$Eshallconductaprogramtodemonstratethatthefollowing technical topics have been adequately addressed in the design of small and large-bore piping supports:
(a) Inclusion of warping normal and shear stresses due to torsion in those open sections where warping effects are significant. (b) Resolution of differences between the AISC Code and Bechtel criteria with regard to allowable lengths of unbraced angle sections in bending. . . < (c) Consideration of lateral / torsional buckling under axial loading of angle members. 9 u_
t :. * (d) Inclusion of axial and torsional loads due to load - eccentricity where appropriate. (e) Correct calculation of pipe support fundamental frequency by Rayleigh's method. (f) Consideration of flare bevel weld effective throat thickness . as used on structural steel tubing with an outside radius of less than 2T. PG&E shall submit a report to the NRC staff documenting the the results of the program.
- 8. The Director, Division of Licensing, Office of Nuclear Reactor Regulation, may relax any of the foregoing conditions for good Cause.
IV. The Licensee may request a hearing on this Order. Any request for a hearing on this Order must be submitted within 20 days of the date of this Order to the Director, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C., t 20555. A copy of the request shall also be sent to the Executive Legal i Director, U.S.N.R.C., Washington, D.C., 20555. If a hearing is to be held, the Commission will issue an Order i ! designating the time and place of any such hearing. If a hearing is
...' held on this Order, the issue for hearing shall be whether this Order should be sustained.
This Order shall become effective without further proceedings upon the Licensee's consent to the Order or upon expiration of the period within which the Licensee may request a hearing. If the Licensee requests a hearing this Order shall be effective in accordance with an Order issued following further proceedings on this Order. FOR THE NUCLEAR REGULATORY COMMISSION
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a e , sbn u , t Division of icensing Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, this 18thday of April,1984. L a
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. NUCLEAR REGULATORY COMMISSION -
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April 9, 1984 ,-[ t . .
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. Honorable Nnzio J. Palla'dino i.
Chairuan ' p U. 5. Nuclear _ Regulatory Commission . l Washington, D.C. 20555 . .
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Dear Dr. Palladino:
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SUBJECT:
ACRS REPORT ON DESIGN CONTROL MEASURES AT THE DIABLO CANYON l 'EUCLEAR POWER PLANT r During its 288th meeting, April 5-7, 1984, the Advisory Committee on Reactor Safeguards reviewed the technical issues arising from the Diablo Canyon Licensee's design control measures for small and large bore piping, l as requested in your letter dated April 4,1984. During this review we had the benefit of presentations by (members of the NRC Staff, including NRC (m Inspector Isa Yin, by representatives of the Pacific Gas & Electric Company (Licensee) and of the Independent Design Verification Program organiza. ( t- , tions, and by Mr. Charle's Stokes, a member of the public. We also had the _ benefit of the documedts listed. We were informed that there is no lpnger disagreement between the NRC Staff ! and Mr. Yin. They now agree on a series of actions that must be completed
' . by the' Licensee and by .the NRC Staff to resolve certain questions, and agree that these should be completed before operation at full power. They agree also that operation and low power testing at levels up to five
- percent of full power can be permitted without undue risk to the health and safety of the public.
! We agree that it is acceptable to permit low power operation at this time. - We believe that such operation will not compromise corrective actions that [ . may be required. p We believe that the several actions proposed by the NRC Staff for ccmiple-L
tion before operation above five percent power .will provide a suitable basis ~ for considering cperation at full power. .
The Licensee has agreed to the actions proposed by the NRC Staff before ' This exception operation above five percent power with one exception. -
. relates to the need for or desirability of " hot shimming" for closely spaced restraints on large bore piping. We believe that this requirement deserves further technical review and discussion between the NRC Staff and )
e . the Licensee. j-L , (
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; Honorable Ibnzio J. Palladino ,
- 2- April 9, 1984 ,
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- We understand that allegations such as those made by Mr. Stokes will be investigated and appropriately considered by the NRC Staff.
Additional comments by ACRS members Robert Axtmann, Jesse Ebersole, and David Okrent are presented below. .
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Sincerely, s ,- l l 1 > Jesse C. Ebersole Chairman Additional Comments by ACRS members Ro'bert Axtmann, Jesse Ebersole, and David Okreht . l We agree with the ACRS conclusion on operation at five percent power. I l
'In view of the limited time available for review of this matter, the bulk
' of documentation, and the latenets of some documents in reaching us, our review was of necessity limited in its depth. j
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Prior to an ascent 'in power. above .five percent, the NRC Staff'should pri-( pare a demsnent discussing in considerable detail how the various relevant
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l l 1ssues rawed by its inspectors and others have been handled. The NRC l Staff shoula also perform a carefp1 examination of a selected sample of actual construction details to help assure that the appropriate quality
- . has been accomplished.
We believe the ACRS should be given an opportunity to review these results . L ~0 'I ftII firior to the ' achievement of full power at the Diablo Canyon Nuclear Power Pl ant. [
References:
- 1. U. S. Nuclear Regulatory Commission Transcript of the March 26 and 27,
- 1984 meeting in the matter of Discussion /Possible Vote on Diablo Canyon i Criticality and Low Power Operation, Pages 68-102, 233-256, 263, 279, and 281-287
- 2. U ' S. Nuclear Regulatory Commission Transcript of the March 28, 1984 meeting between Staff, Applicant and Intervenor on Diablo Canyon, ,
Pages 1-124
- 3. U. S. Nuclear Regulatory Connission Transcrip of the meeting on April 2, _,
- 1984 in the matter of Pacific Gas & Electric Company on Diablo Canyon. -
, Pages 1-272 )
- 4. I. T. Yin, "Diablo Canyon 1, Summary of Findings Resulting From Follow- .
up of Allegations and NRC Independent Overview," Draft dated March 29, L 1984
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April 9,1984 ; j Honorable Nunzio J. Palladino -
- 5. I. T. Yin "Diablo Canyon 1. Draft Investigation / Inspection Report," i dev. 3, dated March 29, 1984
- 6. Memorandum, with enclosure, from Darrell G. Eisenhut Director, Division of Licensing, U. S. Nuclear Regulatory Comission, to Chairman Palladino and Commissioners. U. S. Nuclear Regulatory Comission,
Subject:
Diablo Canyon - Allegations Concerning Small - Bore Piping and Supports (Board Notification No. 83-171), dated October 27, 1983
- 7. U. S. Nuclear Regulatory Commission, " Safety Evaluation Report Related ..
to the Operation of Diablo Canyon Nuclear Power Plant Units 1 and , 2." USNRC Report HUREG-0675, Supplement No. 22 dated March 1984
- 3. Exhibit A, " Affidavit of Charles Stokes," dated November 1983 to Motion to Atomic Safety and Licensing Appeal Board,'* Joint Inter-
.venm's' Mar, ion to Augment or, in the Alternative, to Reopen the Re-
' cerd" in the Matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), dated February 14, 1984
- 9. Pacific Gas and El'actric Company's Answer in Opposition to Joint Intervenors' Motion to Augment or, in the Alternative, to Reopen the Record in the Matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2) without attach-ments, dated March 6,1984 ;
- 10. Letter No. DCL-84-131, from J. 0.. Schuyler, Pacific Gas and Electric .
Company to Mr. Harold R. Denton, Director, O.'fice of Nuclear Reactorto
Response
Regulation, U. S. Nuclear Regulatory Comission,
Subject:
Board Notificatiop 84-071 on Diablo Canyon Unit 1, dated April 4,1984 ,_
- 11. Sumary of Remarks of Charles Stokes Before the Advisory Committee' on Reactor Safeguards Concerning the Diablo Canyon Nuclear Power
' Plant, dated April 6,1984 1
- 12. Letter No. P105-6 from , Robert L. Cloud, Robert L. Cloud Associates, Inc., to Mr. G. A. Maneatis, Pacific Gas and Electric Company, Mr. H.
R. Denton, U. S. Nuclear Regulatory Commission, and Mr. J. B. Martin, ,
- Region V, U. S. Nuclear Regulatory Commission, regarding allegations at Diablo Canyon, dated February 3,1984 p .
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.s l-Testimony Before Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs U.S. House of Representatives ,
on June 14, 1984. Prepared By: I. T Yin Mr. Chairm'an ahd members of the' Congress, my* name is Isa Yin. I am a Senior Mechanical Engineer in NRC's Region III, Division of Engineering. Relative to the Diablo Canyon Nuclear Power Plant investigation effor't, my 3 assignment was to follow up on some of the allegations made by Mr. Charles Stokes. .The specific inv,estigation areas were restricted to site small bore h . (S/B) piping' suspension system design control. However, due to hardware deficiencies observed dUring plant walkdown, the licensee des'ign control measures for large bore (L/B) piping system were also included as a part of
- the overview inspection and evaluation.
I . I On March 26-27, 1984, during the NRC Commission's m;eting held to consider reinstatement of the licensee's low power test Operation License' (OL), I brought to the Commission's attention the following issues which had not been
-adequately addressed:
- 1. Substantiation of design allegations. NRC overview inspections concluded l
that there had been significant QA program deficiencies in the areas of f / Q S/B and L/B piping design control. M d'i b lo M
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- 2. A large number of calculational errors and deficiencies had not been identified through various reviews and checking stages.
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- 3. Dia51o Canyon Project Organization's lack of implementation of a sound .
design control QA program which resulted in violation of NRC regulations in personnel training, document control, audits, design verifications, and' raised questions in many technical and hardware related areas.
- 4. Reinspection, and necessary hardware re-work and modification could be performed with less complication prior to reactor criticality.
My testimony contributed to the Commissioners' decision to defer the OL reinstatement decision pending review by the ACRS.
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s. Prior to' the ACRS meeting held on April 6,1984, an NRC peer review team was formed under the direction of Mr. Dircks, the NRC Executive Director for'
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Operations. The peer review team reviewed all of the issues and discussed them with Pacific Gas and Electric Company (PG&E) representatives and with me. During the ACRS meeting, the staff presented a consensual view that: .
- 1. It was acceptable to permit low power operation prior to completing corrective actions. Such operation would not compromise corrective actions and would not be a risk to the public health and safety.
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- 2. Prior to operation above 5% power, the significant issues concluded by the NRC peer review team should be addressed and corrected by PG&E and
,,/ -evaluated and' accepted by the staff.
The ACRS letter to the Commission, dated April 9,1984, cc7 curred with the staff position, and requested further review of staff resciution of the
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various relevant issues raised by NRC inspectors and others. , The low power OL was subsequently reinstated during the April 13, 1984 Commission hearing. The Commission also asked, that the peer review team
, issues be included in a license amendment. This set forth License Condition 2.c.(11) in an Operating License Modification forwarded to PG&E on April 18, 1984.
4 - - Presently, the staff is working toward resolving the Licer.se Condition items, as well as Independent Design Verification Program (IDVP) :or.cerns and programmatic issues raised by me. m
- 1. The License Conditions included: .
- a. Re-analyses and re qualification of all S/B pipi .g support computer calculations.
- b. Evaluation and shimming of closely spaced rigid to rigid restraints
- and anchors,
- c. Performing additional piping analyses to ensure functionability of snubbers that were installed in cloie proximity o rigid supports. })
- d. Establishment of inservice inspection to maintai required thermal k gaps within the rigid support structures thoughc_t plant life.
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- e. Staff observation of hot walkdown inspections of Main Steam and
. Residual Heat Removal Systems to ensure absence of structural
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- f. Review of " quick fix" significant design changes; and design criteria that were prescribed in infor::al "Diablo Problem" correspondence.
- g. Consideration of additional technical topics raised by allegations.
The.se issues are presently handled by the NRC staff.
- 2. My written concerns on possible inadequate IDVP for L/B and S/B piping stress analyses and support calculations, and seemingly insufficient followup evaluations after deficiencies had been identified were formally submitted-to NRR management on April 25, 1984. Joint. review of the'se concerns will be conducted by NRR, IE staff, and me.
- 3. In addition to the License Conditions, I believe there are other program-matic issues that could affect the quality of ongoing and future project
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activities. In my view, the following changes are warranted:
- a. Improvement of site personnel indoctrination and training program <
as well as measures to.be taken to ensure effective implementation 4 ofprogramrequifements.
- b. More stringent control of. site procedures, including removal of
.[ outdated' documents, and avoidance of procedure revisions by
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unauthorized means, for example Inter-office memoranda.
- c. Upgrade of procedures to include better control of preliminary design data, design interfaces betwe.en site Stress and Support
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. groups, and PG&E and Westinghouse.
- d. 'Impr'uvement of timeliness of projett responses to site personnel-safety concerns, and QA audit findings. Corrective actions should include identification of underlying causes, and surveillance to prevent recurrence.
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- e. . Conducting more. extensive QA program audits that will: (1) include-broader scope and more in-depth review during the audit and prior to accepting ~ audit finding corrective actions, and'(2) ensure all aspects of design control requirements, such as design criteria, assumption, judgement basis, review, and approval are imple-mented in accordance with program provisions. .
- f. Upgrade of Tolerance Clarification program (TC or commonly called l
Quick Fixes) to ensure that adequate design reviews.will be made Eprior to major hardware modifications.
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6-I have discussed these concerns with PG&E management and I am presently
- .; reviewing the licensee's actions. As it stands to date, followup actions are" incomplete.
- Mr. Chairman, and members of the Congress, I thank you for. the opportunity to testify, and will truthfully answer any questiqns that you may wish to ask.
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[ y, ,,h g UNITED STATES NUCLEAR REGULATORY COMMISSION L%7ED coRREsD u s m crou.a.c.20sss App y3 )gg4
'84 APR 13 P3:05 Docket Nos.: 50-275 -
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anc' 50-323 3;' v u 3E'~ MEMORANDUM FOR: Chairman Palladino Comissioner Gilinsky Comissioner Roberts Comissioner Asselstine Comissioner Bernthal FROM: Darrell G. Eisenhut, Director Division of 1.icensing Office of Nuclear Reactor Regulation SitNECT: DIABLO CANYON - STATEMENT BY MR. C STAFF, APRIL 11,1984 (BOARD NOTIFICATIO@N NO. 84-082 ) x,
/ In accordance with NRC procedures for Board Notifications the enclosure is provided for your. infomation. The enclosure is a statement by Mr. Isa Yin of the NRC staff regarding conclusions and recomendations of an NRC Review Group that recently evaluated concerns expressed earlier by Mr. Yin.
By copy of this notification, the appropriate Board and parties to the Dibalo Canyon proceeding are being provided a copy of this information. k d[ [d arrel G(. C 'sen ut,1Di rector (d Division ofdLicensing Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: See next page
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The Cocriissioners , o 1 cc: J. F. Wolf, ASLB" G. O. Bright, ASLB l
'J. Kline, ASLB T. S. Moore, ASLAB W.- R. Johnson, ASLAB
.1. H. B'uck, ASLAB SECY (2)
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'Partie. .s to the P.... ..-roceeding 4
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DISTRIBUTION LIST FOR BOARD NOTIFICATION Diablo Canyon Units 1&2 ' - Docket Nos. 50-275/323 OL ACRS Members Ms. Elizabeth Apfelberg Dr. Robert C. Axtmann Maurice Axelrad, Esq. - Mr. Myer Bender ( Mr. Richard E. Blankenburg Dr. Max W. Carbon l Mr. Glenn 0. Bright Mr.~ Jesse C. Ebersole i
, Dr. John H. Buck Mr. Harold Etherington Philip A. Crane, Jr., Esq.
Dr. William Kerr l Mr. Frederick Eissler Dr. Harold W. Lewis David -S. Fleischaker, Esq. Dr. J. Carson Mark
. Mrs. Raye Fleming Mr. William M. Mathis .
Arthur C. Gehr. Esq. Dr. Dade W. Moeller Mr. Mark Gottlieb Dr. David Okrent Mr. Lee M. Gustafson 'Dr. Milton S. Plesset Mr. Thomas H. Harris Mr. Jeremiah J. Ray Mr. Richard B. Hubbard Dr. Paul C. Shewmon Dr. W. Reed Johnson Dr. Chester P. Siess Janice E. Kerr, Esq. Mr. David A. Ward Dr. Jerry Kline Mr. John Marrs Thomas S. Moore, Esq. -
. /'_N Bruce Norton, Esq.
-(' , Joel R. Reynolds, Esq.
Mr. James 0. Schuyler Lewis Shollenberger, Esq. Mr. Gordon Silver Michael J. Strumwasser, Esq. ~ Paul C. Valentine, Esq. Harry M. Willis John F. Wolf, Esq Atomic Safety and Licensing
- Board Panel Atomic Safety and Licensing Appeal Panel Malcolm H. Furbush i Rttsident Inspector /Diablo Canyon NPS
- Dr. William E. Cooper
- Mr. W. C. Gangloff j Mr. Lee M. Gustafson / Dr. Jose Roesset -< Mr. Malcolm H. Furbush .. { 1 k - lU r . O s -
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. . . . . .. __.,_.s . . . . . ,
f Diablo Canyon 1 In the past two weeks there had been discussions among the staff and the PG&E representatives on matters concerning whether or not there had been a design control QA program breakdown in the design of large bore (L/B) and s, mall bore
... . .(S/B) ,pi. ping systems., To... know th,e. an,swer, . , ,one. . . must,_fi,rst
<. ,ask the .f,ollowing ,
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questions: ,
- 1. Had there been adequate personnel training program as well as effective implementation of the program at the site?
- 2. Was there a sound document control system?
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- 3. Were there sufficient technical and QA procedures to cover all important aspects of design activities?
- 4. Did responsible personnel always follow established work proce'dures?
- 5. Were all components. proven to be functionable in accordance with design
'~ ' * ~ intentions?
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- 6. Were the licensee audits of design activities effective enough to +
. identify problems for corrective measures? ( I
'( 7. Was licensee forceful in ccrrecting identified problems?
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. : 4 The inspection findings documente in my incomplete draft report said "N0" to
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all the above questions. In the past two weeks, I worked together with the Review Team consisted of NRR, IE, Regional management and technical staff. While the difference in professional opinion, in interpretation of regulatory recuirements, .and in the
.. ... relative significance,.of.various jssues..di.scussed in my. draft repgr$.,s.til.1 existed, there was a consensus among the team members on what actions should be taken prior to full power operation. The compromises I have made included:
(1) that improvement of program and component design could be carried cut during low power testings, and (2) that the decision to reinspect all safety related piping systems to avoid structural interferences will be based on
' whether or not NRC's observation during MS and FW tests will identify any significant deficiencies. The action item list included the following:
. . Complete S/B support computer calculation review.
. Complete shiming of closely spaced rigid supports, as necessary.
. Establish program for monitoring thermal gaps, as necessary.
- t. ..
; . Review snubber loc.kup motions used to evaluate snubber / rigid restraint interactions. '
- .__ . Establish " Quick Fix" and "Diablo Problem" review program.
Staff inspection of MS and FW hot walkdown. l . 2
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. Complete review of technical allegation issues.
. Complete regional inspection (including evaluation of IDVP).
The staff's 'present position regarding the S/B support computer performed calculations is that all 100% of them should be re-evaluated by DCP.. This i-s
.- , ,;, contrary.,to t,he.., Robert .C1.ou.d. and, Asspciates . conclusion;af.ter the IDVP studies.
They believe that no additional S/B support calculation was reouired even in the face of a large amount of identified computational deficiencies. The difference of licensing criteria interpretation and the degree of tolerance in accepting calculation input errors and deficiencies between the staff and Cloud is apparent. The nature of the deficiencies relative to the L/B support ( (' calculations documented in the Cloud Interim Technical Reports will be reviewed by the staff in the near future. Results from the review of this issue and five others that are also related to the L/B and S/B piping system design evaluations performed by Cloud will form the basis for determining whether or not there should be additional actions to be taken by the licensee. Recently, there had been media and public concerns relative to my " surprise" testimony before the Commission, particularly the possibility of management
' suppression of inspection findings. Let me speak of the truth in this matter.
My work performance in the NRC in the last 9t years was well recognized inside and outside the organization. I had been decorated with NRC Meritorious ! Service Award and Special Achievement Award, and was sent to Korea and Taiwan f
, to train their technical personnel. My assignment at Diablo Canyon showed
( that the NRC management really wanted knowledgeable staff to handle the case. During the past 41 months of working on the case, there had not been any 4
m* .
~
, management pressure to.stop me from inspecting or investigating any matters
' ~
that I feit were pertinent to the issues, anc certaini; t' cre nad not cec: iny attempt made to discourage me from discussing findings with the Congressional staff, the licensee and the general public. Problems concerning some over-looking of the findings could have been caused by difference in professional opinion, and by the tremendous work loads that have burdened the understaffed
- ,.. ,. .. NRR organization for so.. long.-
.. 2,, ,., ,, ,, .. .
All the experienced NRC inspection and enforcement staffers are aware that identifying licensee program and hardware deficiencies is only 40% of the task. It takes more effort to negotiate for upgraded programs and to follow up on implementation of corrective actions. Being a graduate from Cal Poly, 20 miles ('s ' away from the-Diablo Canyon site, it is my personal interest and commitment to
.work hard with the staff to resolve all identified issues and problems. Not until all improved programs have been implemented; all identified hardware problems have been corrected; and all reinspections have been conducted, you can certainly be assured that there will be no staff recommendation for the issuance of a full power commercial operation license.
/ -
? nlP/
i
- Isa T. Yin --
~~
Senior Mechanical Engineer Division of Engineering ( ( Region III, NRC 7
- 4 .
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a Y My name is Isa Yin. I am presently working in Region III, Division of Engineering as a Senior Mechanica1' Engineer. Relative to the Diablo Canyon Nuclear Power Plant (DCNPP) t5am in~vestigation effort, I was assigned the responsibility of following up on some of the allegations made by Mr. Charles. Stokes. The specific investigation areas were restricted to the site small bore (S/B-) ( . piping suspension system design control. However, due to hardware deficiencies observed during plant walkdown, the licensee design control measures for large bore (L/B) piping system had also been included as a part (~' of the overview inspection and evaluation.
-- As a result of the investigation and inspectibn findings, ,
it is my professional opinion that the Unit 1 r,eactor
~ '
should not be permitted to go critical at this time. , i- The reasons for such determination are as follow: 1.' Almost all of the Stokes allegations assigned to me for followup had been substantiated. Based on the many assessed violations against the 10CFR50 Appendix B criteria resulting from followup on these allegations and the independent overview U-inspections, it was concluded that there had been apparent QA program breakdown in the areas of S/B and L/B piping design control. s, s
1 1 : _2_
- 2. Piping systems cannot be subjected to- true function-ability tests until after severe transient conditions, such as an earthquake, had, occurred. The ensurance of system operability relies prir:1 pally on analytical j
methods. In spite of this dependence on theory and analysis, th'e'1ack of licensee L/B and S/B piping system design control that had resulted in an alarmingly . la ge number of calculation errors and deficiencies that had slipped through various review and checking stages, is indicative of the failure of the Corrective f'% t
-) j Action Program conducted by the Diablo Canyon Project (DCP) group in the past tw'o years.
t lmn , l. 1
- 3. Issues raise,d in responding to the staff's initial concerns were . discussed during a meeting held with DCP personnel at NRC-NRR office on December 15, 1983.
t Discussions included onsite design personnel training, l document control, audits, design verification, thermal loading release within the rigid restraint gaps, < and snubber / rigid restraint interaction. At the time i L of the meeting, none of the issues was considered . ! to be a problem by DCP. However, during followup 1 inspections, all the above items had resulted in ( ~~./ staff assessment of violation items. The event .
. . . . . . , . ^- ~ . .
- s. , ,
reflected DCP's lack of concern for establishment and ~; implementation of a sound design control QA program. 4 Hardware problems involving snubber and rigid restraint interaction that could make the snubber inoperable under design conditions were identified in La Salle Unit 1 just before the NRC operation lihense hearing, and had resulted in licensee
}; .
filing of a 10CFR50.55(e) report, and removal and i
- replacement of hundreds of large and small size N mechanical snubbers. The DCP's position in regarding
- s. ~ .' l l the same situations %dentified at D'CNPP to be not g
a problem requires in-depth review and . evaluation . by the staff. ,
- l. .
At the present, with fuel loaded in the Unit 1
! 5.
ii ji, reactor, the access control including complicated ,3 1 security system, and the coor air quality resulted ( *) '", from system hot functional testings, makes inspection l [. inside the containment difficult and intolerable. With the e.w p,diat;.n
- ticr. that there' will be
- (a) sub- ;_
stantial amount of staff and licensee reinspection activities, and (b) some system hardware modification and re-work, to allow reactor low power testing before resolving the existing problems could dis-courage additional inspection effort and could l hinder any required corrective actions. ! l taf{
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# . #o, UNITED STATES
* ' ,8 g NUCLEAR. REGULATORY COMMISSION
- WASHINGTON. O. C. 20056 APR 121964
_/ .... . / 7 Docket Nos.: 50-275 p. 50-323 MEMORANDUM FOR: Chaiman Palladino Commissioner Gilinsky Comissioner Roberts Comissioner Asselstine Comissioner Bernthal FROM: Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
OJA LO. NYON - ADDITIONAL QUESTIONS AND COMMENTS FROM (BOARD NOTIFICATION NO. 84-079) In accordance with present NRC procedures for Board Notifications, the enclosed s information is being transmitted to the Comission. The attached information (questions and comments) was received from Dr. H. Meyers a staff member for the U. S. Congress House Comittee on Interior and Insular Affairs on April 12,1984. By copy of this notification, the appropriate Board and parties to the Diablo Canyon proceeding are being provided a copy of this information. . Ol,L arre . Eisenhut, Director Division of Licensing
- Office of Nuclear Reactor Regulation
Enclosure:
As Stated cc: See Next Page ,g,, a
'O 4
--~ - - - - - - - ,, - ~ - - - , - - - - - - - - , - - - - - - - - - , - - - - - , - - - - - - - - - - - - - - - - - - - - - , , , - - - - - - - - - , - - - - - - - - - , , - , - - --- - , , - - - - - -
cc: J. F. Wolf, ASLR-G. G. Bright, ASLB - J.' Kline, ASLB T. S. Moore, ASLA8 W. R. Johnson, ASLAB . .> J. H. Buck, ASLA8 SECY(2)_ OPE-EDO OGC , Parties to the Proceeding 6 6 e
- H f .' '
. s y_ / DISTRIBUTION LIST FOR BOARD NOTIFICATION Diablo Canyon Units 1&2 Docket Nos. 50-275/323 OL ACRS Members Ms. Elizabeth Apfelberg Dr. Robert C. Axtmann Maurice Axelrad Esq. Mr. Myer Bender Mr. Richard E. Blankenburg Dr. Max W. Carbon Mr. Glenn 0. Bright Mr. Jesse C. Ebersole
- Dr.' John H. Buck Mr. Harold Etherington Philip A. Crane, Jr., Esq. Dr. William Kerr
, Mr. Frederick Eissler Dr. Harold W. Lewis David S. Fleischaker, Esq. Dr. J. Carson Mark .
Mrs. Raye Fleming Mr. William M. Mathis Arthur C. Gehr. Esq. Dr. Dade W. Moeller " l Mr. Mark Gottlieb Dr. David Okrent Mr. Lee M. Gustafson 'Dr. Milton S. Plesset Mr. Thomas H. Harris Mr. Jeremiah J. Ray Mr. Richard B. Hubbard Dr. Paul C. Shewmon Dr. W. Reed Johnson Dr. Chester P. Siess i Janica E. Kerr, Esq. Mr. David A. Ward ' l Dr. Jerry Kline Mr. John Marrs . . Thomas S. Moore, Esq.
,\ Bruce Norton, Esq.
_./ Joel R. Reynolds, Esq. Mr. James 0. Schuyler Lewis Shollenberger, Esq. Mr. Gordon Silver 1 Michael J. Strumwasser, Esq. Paul C. Valentine, Esq. Harry M. Willis John F. Wolf, Esq . 1 Atomic Safety and Licensing i i Board Panel Atomic Safety and Licensing Appeal Panel Malcolm H. Furbush i Rksident Inspector /Diablo Canyon NPS Dr. William E. Cooper. Mr. W. C. Gangloff . Mr. Lee M. Gustafson , Dr. Jose Roesse. Mr. Malcolm H. Furbush ... i
~'~~'~
j i.yP< uijuns i wipv: .gge;. .
. P q f)V4h0N a/10/Ga '( NQ7E5 RE BASIW FOR 97-37 FINDINGS CN NBC AUDI ETC. .
- 1. The NSC audit of Pullman acpears to have been undertaken in response to concerns expressed by PGLE as to whether the Diablo reactors had been in constructed in a manner that complied wi th 5 the Commission *s requistions. PGLE Audit 30422 (p. 2) states l ,
"Several apparently. generic deficiencies in work perf ormed by c- Pul'Iman were previously identified
- my the General Construction
, .g Department," ., ,
i 'g - Wha't'" generic deficiencies" had been icentified by the General
. . L. Construction Department?
- a s .
' - 'Had these'ag,.enerte deficienci.es" been repceted to Th% AE:/NRC7
' 3r '
- 1- .; ,.,
- 3. lho Geope Ctetcment of the NGC aCdit encompacced "wsekmenchis
- 4. ef Who field-f abricated and installed items." 7he June 14, 1973 lettre from Mr. Wic=how to Mr. Sci n , to which the PGkE review f i
the NS: audit and Pullman response thereto aere atta:had, statzd that the Ntc audit "did net adcrecs :tself to the verification of
; .' f the adequacy of the installes hardware. 7he NSO audit was i
t superf i ci al with respect to the hareware...."
- Did NSC fulfill its commitment to verif y the adequacy of installed hardware? If not, what was the reassn der its nct
; ['5 having done so? What was done to satisf y P3LE's original concern
\ that there he an audit to verify the adequacy of installed 2 hardwar*e7 -
,[.h . - 7. PGkE undertook Audit 804:2 to verif y the adequacy of r
- Pullman's QA program; to review the validity of the NSC findings
**Jf W. and-to determine the accuracy and appropriateness of Fu11 man's Ej$f' FEE $mnaeg' and *to observe the as-installed condition of components i
l '" and* Pullman's adherence to applicable specifications, design sye? _ d e,9Wi.ngs, and quality standards.' h Aug T B0422 evaluated'a Pullman
- corporate audit conducted in
+ February 1973. Audit 80422 found discrepancies in items that had ! . i heen inspectsd by Pullman auditors who noted.no discrepancies. ! I.T Audit'BC422 concluded that "!n light of the nummer of.. 1 'd.~ discrepancies noted, it is apparent that the eullman audit did not effectively evaluate the quality of near work."
~
?. t ir,.. . ,
5,
- What*' additional audits were conducted in' light of the finding i
thatiPu11 man's, " audit did not effectively evaluate the quality of i
,. thel'c work?" In light of this finding what hardware inspections were conducted to determine the adequacy of ru11 man's work? How "'
many discrepancies were noted as the result of additional audits - ana. inspections conducted in t h e- wa k e of Audit 804227 What was done to determine why the deficient tenditions notec n l j '_ M-0725 and M-3726 had not been discovered an the ccurse of the seiginal inspection peeCess? What was the reaucn these dedi c1 ent i
,/
1
- 4 **
,r----- - , - - - , - - - - r,-,.---,------..-------nn, ..,-.-e- - - - - - - - - - - - - - , - - - -
, p. .g. . ., .
e,, Af g] conditAons/has not been noted during 'the course of the original inspection process? What was done to determine why the Pullman corporate audit had not noted the discrepancies noted by Audit 804:27 Why die the Pullman aprporate audit not discover the discrepancies? What was the basis for the 53-37 finding (stated
.on page 40) that Pullman had performed adeauste corporate audits?
What was the basis f or the 83-57 firidi ng (Id.) that Pullman's a interr)al and corporate audits had indicates tnat no fundamental GA'* program breakdown had oc=urred? CE.g. see 1978-79 findings re pipo'r"upture eeste41nts lser NCR's DCi-78-RM-008, DCi-78-RM-009, 2.[
. /-
- D21-79-MM-003, etc.3, -
tp. . v 4.4iTo what extent did recommendations listed on page 11 = 12 *of 1 '
. .i. .
.. ...g
Au'dit 504:
.. .. .. s u,.qv.. ..
..,2..
c.orrespond
.... i..* n, to def '..~i ci enci es not.ed.
.g: , .
in .the e.- .NSC audi.t?.-
- - ~ '
...!, J5.' A May 29, if79 memorandum from K. Frecd to E. Iicrwin .
.. . ' addrescos pipe rupture restraint promismc. Why had wclder
. def,teicncies not be detected and corrected at an earlier cate by
. Pu11 man's QC/QA program 7 "o wnat extent 4ru the noted welding
. deficiencies cimilar to those ,specified my -he NSC audit?
1
; 4. What audits and/or reinspections hangers were conducted to -
.. dahermine whether the types of def ects f ound in the pipe rupture
~
#~? ; restraints existed witn respe=t to pipe' hangers? What is the
.:- bests f eh a determination that def ects f ound in pipe rupture -
.:4 restraints did not exist with respect te pipe hangers 7
( N .
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= _-
'INTEROFrICE CORR.ESPQHDENCE
_~ . - to T.hin ,ct J MRC out ay 29, 1979 iga.i nen ;.'.M . h ed " M ' 'g d 4 ' DiABLO CANYON RUP R E R5)_TRA.,J,E!,,,,,,,,,,,1 ,
;s .,s .
. ar;.-
.a.,e 4 .
.y g;h {,
,7.
- Problems outside Pullman's ' responsibility g..., . .
;.4 ~. A) J0!ttf DEstGN (Primary causel
'g. y . < - - -
tM'- '
#M-4 1) Massive weldments, 5" deep x 4 5/8" wide, at 45' single bevel
_ I. T7 that would shrink unrestrained about 1/2" in a transverse
. direction ere totally restrained by huge columns and 1, cams, i in~/t - .? * . -All potential shrinkage is transformed into residual stresses -
Qm ;;,. .
. L:..
and/cr cracks,
.g;~~ - Lateral reinforcement plates (stiffences) are welded excetly
. . . . ,,1) 5 opposite, both pulling on webs as, thin as 1/2" and 3/4".
c. 1 .? l p, -
- 3) Pg,61 D.e.partm newledged int ef EnojneerJrtg Research (r.E.T.) has tek-jo%'duTgn as tne major problem by developing Q. .i.:
their investi i . .. d six (5) joints ~classified by *
. dQFts of-resgation aroun..
4 3
, ,.y trni nt. -- ~~ ~~ " . . ~ ~ - - .
*AV -
r" ' 8 ) - BASE PATERIAL (Secondary cause) [~, t& . . . .. . . . l gf ",: . [,g, .g. c
- 1) Almost all " cracks" originated at lamellar tears 'in bcse material. .
5 5,M.7 . C.d:;ts,. cIgb . .
^" - .
lC Some material has excessf M rplied laminations.
.-) 2
. , .m., v . .; , . -
[ h..-. /4,
;, 4
')3 PG&Esupo11edbase,m(-rl-to imp}ementation 6 1, was inadequately identified prior .
qic'ai,ilincf-bate *matartt1. - cw,
** .m.
'4) Low melting. point alloys formed with cop..per (in.A441) and d M. . sulfides. triggered. some tears, i%e:. rs . .'.25 s .,
"9 .h.. .. '- ~ ~E -- c) INDISCRTMit! ATE MATERfAL REMOYAL
^?."~ -
.. 3 g .
- 1) Large Destructive test samples have been rernoved.
, s:. .
. ' ~ . 2) Some. sections have been essentially destroyed chasing cracks.]
~- 3) .se Proposed repair /reglacement.
e .'* '
- 4) No consideration is given to how removal stressus ' ether .foints
~ ~
in same structure. I &h.\ (Q \ a g6 7 - s
---,,- _ _m, s -
.pe p
- _
4 va n
. .{. m .-
~E. Gerwin one l'.ay ,29, is73.
/ D suassen .DIASLO CANYOM RUPTURE RESTRA!NT3- '
~_@l ,(r r
'; P$stme. ,
%n .. .M
. tm..:. .;-- 5.d. # .(cont'd)
- l;is
. .i.Q D) CONCLUSION .
F l ', l.5.r,..U. 1) Joint- design can be improved byt
.)b- .- . . .
. . g . ,.. , ,
.' . a 5maller bevel angl.a..
ned ' es -
) .,. .. ,
. . st . - . ..
l
' h. , ,
. [.
.i.
b) Daphlg_ b.3,v3,1, ,1f,,possibl e 3 racing with gusset plates to d.istribute area
%.s. ... .! c) . .
contracted upon. TO:y j
, , . "g- ,
,0~. !) Before removal e complete rc: air / replacement plan.should
.dh-
~gsif be developed with special attention given to.ott}er joints
.::'? * - .
. ';. in the structure. -
.1g; - - -
D' - IIf Prohkems withi'n Pullman's Q.A./ Fabrication responsibility [, ;;. I'A) . PREHEAT (Early Secondary cause) 3,# 1) WELD PROCEDURE - 7/8 gj, p".-- . i.' .
.4 - 11/11/715pec.8833XRrequjresAWSD1.069 .
Rev. 11/28/73 Preheat - 50 F. min.,1753 over 1" 4 carbon over
.-' : h e '
~
30" - . F,,. , , -
*>4l ~ . ' Rev. 10/.15/76 Preheat. referehces E30 243 for AWS' Welding
- .. .mst w .. ..
4.iR. . . . . Q : P FM1 1) Q.A. VERIFICATION . 2;dd* .. 'i.3du ** 11/11/.715pec. 8833XR requires detatl'ed "Q.A Ins;fection Plans"- l v* , , Rev. 2/01/74 E50 243 net address preheat
'c
. ? 'i*:iM. '
Rev. 5/05/75 ESD 243 preheat now Q,A. hold point
- g . .
Rev. 6/10/76 E30 243 details preneats meeting and exceeding AWs
,4:-
. . .. f%
yig. 01.0-69 , ,
;p . , .fE.
.3) XNOWN DEVIAITONS . . ..
.qi,q. ,
.y . .
~v a) PG&E audit observed welders not.us.ing correct preheat on
- 7. 9/17/75 and on 9/19/75 .
. .h. .: - E- b)* 3/3/77 Q.A. Inspector terminated "
after quhstfcMble*docu." ). e mentation practices.. * -
*g..
8
'c) 8/15/78 documented preheat of 150 F., requir,ed 225'F.
i -
.*" (D.R. 3712). 8 i *y,',
d) 9/25/78 documented preheat of 15",aF. , required 225 F. (0.R.3798). . (' .
~- ,
v.
. (< z (,
cc: , A. Eck M. Evans 1. M - i UJM fAA/ . ..
.-------,,.->------------,-e - , - - - r ---
4
. . . . . ~ ~ ~
n , ;.,,, _f.. -
- h. Gerwin -
un May 29, 1979 i L
^~5masect .
DIABl.0 CANYON RUPTURE RESTRAINTS' .
*=
Y? . . .
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g -Ta'..:: cate:. - : . - p . II. (Cont'd)
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Nq,' '. . . . ' g -"" "., ' 8 ) Purported mItjoe welding and weld metal dejects are not [**f ,
~
7 prevalent. One gross weld metal de,iect has been identi. '
' fied, that being a lack of fusion between two SMAW pro- -
duced layers. Other defects exist but 'are inherent to m@ c.. -
* * ".-' the welding process (for example some porosity), are not FM ~ '
detrimental and are well within acceptable limits. Con- l
. ';?'~ - - '
fusion is occurring because PGH NDETechnicians are callinglamellar tear.ing " lack of fusion" which it dist-45~ l.
, *; inctly is not. ,
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{M.. . . * ..,,'-S%: -C) CONCt.USIONS
,,,,,. 5 .
E ".' l(o documenMd control and inadequate control of r:Suired ,
't.% .-
preheats were definita problems before 10/15/.76. This !
.. 1-
~~~'
likely contributed to cracking adjacant to fillet welds and may have contributed to cracks in heavy joints that , (G l f.:'
. originated in hardened heht affected, zones. However.
s g'; - the major factor by far in heavy joints was poor joint ~
':'** design'. The preheat situation is now under fu11'Q'.A.
1.;,
- d.,~.:
controlk prehdat . hold points .are being obsenved. fi.'
'kINT5REQUik! ACTION
..e:.n- .,,
.,,iqh). AStop indiscriminate material removai *;,, ,,,,
~
... . .; g . . '
[:,[ ,. ,, _ B) Change contract.and/or specification to include the addi-gss. :n tional examinations (M.T. and re-U.T.) being imposed. T."T' ? . Evaluate cracked joints and develop method of bracing the ,
*2 . C) joint to replace the portion of the joint that* exaiqipations l
y' -.
.C" ,. . reveal to be cracked.
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- 1) ' Brace, gusset or plate to web.
~ * *
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- 2) Arrange gusset shrinkage to tak's lead off cracked area or even to put cracks in compression.
.,N' D) Hire Welding Engineer .for _Diablo Canyon to implement ..
Hi$ture restraint repair progem, conr.ros ins u. ng~cion of heavy st' HUiTBnT a in t,Fnt t 2..ano..c.4una.tn quaMty welding r%s- program. . - . Ll
- cc:* 'A. Eck M. Evans i, g (. J. Frtto
, T.pers i
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