ML20087Q074
| ML20087Q074 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/06/1984 |
| From: | Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20087Q072 | List: |
| References | |
| OL, NUDOCS 8404100279 | |
| Download: ML20087Q074 (70) | |
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NUCLEAR REGULATORY COMMISSION '9 p.7 , BEFORE THE APPEAL BOARD
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In the Matter of )
)
PACIFIC GAS AND EL5CTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power ) Plant, Units 1 and 2) )
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JOINT INTERVENORS' SUPPLEMENT TO MOTION TO AUGMENT OR, IN THE ALTERNATIVE, TO REOPEN THE RECORD
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On February 14, 1984, the Joint Intervenors filed a Motion to Augment or, in the Alternative, to Reopen the Record in the reopened design proceeding to receive further evidence regarding significant and highly relevant new information obtained through former Diablo Canyon Project engineer Charles Stokes and the subsequent NRC investigation of those allegations. Following receipt of responses to that motion, this Appeal Board deferred consideration of the inf :mation and issued its decision in the reopened proceeding. ALAB-763, at 103 (March 20,1984) . Less than one week thereafter, the Commission received written testimony from NRC Region III Inspector Isa Yin, who was principally responsible for a substantial part of the NRC Staff's investigation of the Stokes allegations. In his Statement, Mr. Yin portrayed a far different picture of the NRC Staff's investigative g4g{9 0 000 . .
Y e- , findings than was presented to this Board in the Staff's opposition to the Joint Intervenors' motion. In contrast to the Staff's denigration.of the significance of the information, Mr. Yin concluded: (1) Almost all of the Stokes allegations assigned to me:for follow-up
.had'been substantiated; (2) Based on the number of assessed violations of 10 C.F.R. 50, Appendix B criteria resulting from follow-up on these allegations and the independent overview inspections,_it was concluded that there had been apparent.QA program breakdown in the areas of.S/B and L/B piping design control;
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(3) The lack of licensee L/B and S/B piping system design control that had resulted in an alarmingly large number of calculation-errors and deficiencies that
.had slipped through various review and checking stages, is indicative of the failure of the Corrective Action Program conducted by the Diablo Canyon Project group in the'past two years;
.(4) Discussions-[with the DCP]
included onsite design personnel training, document control, audits, design verification, thermal loading release within.the rigid restraint gaps, and snubber / rigid restraint interaction. At I the time of the meeting,-none of the issues was considered to be a problem l byDCP. However, during follow-up
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-inspections, all of the above items had resulted in staff' reassessment of violation items. The event reflected DCP's lack of concern for establishment l and implementation of a sound design control QA. program; (5) Hardware problems involving snubber and rigid ~ restraint interaction . . .'had resulted (at La Salle] . . .-in removal and replacement of
. hundreds of large and small size mechanical snubbers. The DCP's position i
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f f in regarding the same situations identified at DCNPP to be not a problem, requires in-depth review and evaluation by the staff. Based on these conclusions, Inspector Yin urged the Commission not to allow the plant to "go critical" at this time. (See attached Differing Professional Opinion of Isa Yin, Inspector, NRC Region III (March 26,1984) . This new information bears obviously on the Joint Intervenors' pending motion and on the accuracy of the Board's conclusions in ALAB-763. Moreover, it contradicts the NRC Staff's representations in its opposition to the Joint Intervenors' motion and, in light of Mr. Yin's key role in the Staff's investigation, it raises the question why the Staff failed even to mention Mr. Yin's findings, his opinion, or the fact that the Staff was adopting a position significantly different than that. conveyed by the inspector principally responsible, and described by Mr. Yin in his testimony to the Commission.1/ 1/ When the Joint Intervenors' counsel asked NRC Staff counsel by telephone on March 27, 1984 why no affidavit by Inspector. Yin had been included in the Staff's response, he stated simply that Mr. Yin was "out of town." That excuse is patently inadequate. The Staff has an obligation of full disclosure to the Board of all relevant information. We
-consider a serious breach of that obligation the Staff's failure to inform the Board'and all parties of Inspector Yin's findings, in light of their significance and the fact that Yin was assigned lead responsibility for investigation of many of the Stokes allegations. The Staff's material false statement by omission is a clear example of the Staff acting not as a representative of the public, but as an advocate for the application.. Such-conduct renders these licensing proceedings little better than a farce.
7-Other documentation recently released relating to Inspector. Yin's findings includes his oral testimony to the Commission-on March 26-27, 1984 (attached hereto as an exhibit), the transcript of a March 28, 1984 meeting of Mr. Yin and representatives of PGandE (served on the Board and all parties by Board Notification 84-068 (March 28, 1984) ) , and the draft Inspection Report (Rev. 3), and Sun. mary of Findings by Isa Yin (served on the Board and all parties by Board Notificatioh 84-071 (April 3,1984) . Each of these documents provides further explanation of and support for the findings of QA and design deficiencies referred to in his written testimony to the Commission. In particular,'the March 28, 1984 transcript and the draft Inspection Report and Summary of Findings provide a highly detailed description of the basis for the finding,.the sources of th- information, the proposed NRC Staff conclusion, and the regulatory. provision violated by the deficiency. The general categories of deficiencies include personnel indoctrination and training, identification of nonconformances and corrective action, document control, procedures, implementation of procedures, design control, audits, and
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control of. contractors. Within each category, numerous examples
.are provided based on the Staff's investigation, examples that undermine both the adequacy of the Diablo Canyon design as a whole and the reliability of the IDVP conclusions.
All of this new information is significant and
-directly relevant to the matters raised in the Joint Intervenors' motion and considered in ALAB-763. Accordingly, I
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t for all these reasons, the Joint Intervenors reaffirm their pending motion and supplement that motion with the following materials relating to the Yin testimony: (1) Yin Testimony to Commission (March 26, 1984) (attached); (2) Transcript, Commission Meeting (March 26-27, 1984) (excerpts attached); (3) Transcript of Meeting between Yin and PGandE (March 28,1984) (served on Board and all parties by Board Notification 84-068 (March 28, 1984)); (4) Draft Inspection Report (Rev. 3) and Summary of Findings by Isa Yin (served on Board and all
. parties by Board Notification 84-071 (April 3, 1984)).
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Based on the foregoing, and for all the reasons previously stated, the Joint Intervenors urge that their motion to augment or, in the alternative, to reopen the record be granted. Dated: April 6, 1984 Respectfully submitted, JOEL R. REYNOLDS, ESQ. ETHAN P. SCHULMAN, ESQ. ERIC R. HAVIAN, ESQ. JOHN R. PHILLIPS, ESQ. Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ. P. O. Box 1178
. Oklahoma City, OK 73101 By .
EL R. RE6CMOgos Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC. [ ECOLOGY ACTION CLUB SANDRA SILVER
- i. ELIZABETH APFELBERG JOHN J. FORSTER i
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My name'is Isa Yin. I am presently working in Regien III,
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Division of Engineering as a Senior Mechanical Enzineer. Relative to the Diable Canyon !!uclear Power Plant x (DCIIPP ) 'tepp, l'nvestigation effort, I was assigned the i 4f respons'ibility of following up on sone of the a'.leantions 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. i As a result / the investigation and inspection findings, it is my professional opinion that the Unit I reactor should not be permitted to go critical at this time. The reasons for such determination are as follow: i ..
- 1. Almost all of the Stekes allegations assigned to
[ me for followup had been substantiated. Based on l . the many assessed violations against the IOCFR50 Appendix B criteria resulting from followup on these Allegations and the independent overview inspections, it was conclu'ded that there had been ' apparent GA program breakdown in the areas of S/S and L/B piping design centrol.
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, 2. Pipin ' systems cannot be subjected tc true function-j s' ability' tests until after severe transient conditions, such as an earthquake, had occurred. The ensurance f cf systen cperability relies principally en analytical methods. In spite of this dependence en theory and analysis, the lack of licensee L/B and S/S piping .
system design control that had resulted in an alarmingly
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large number of ' calculation errors and deficiencies that had ipped through various review and checking stages, is indicative of the failure of the Corrective Action Program conducted by the Diablo Canyon Project
-s (DCP) group in the past two years.
- 3. Issues raised in responding to the staff's initial concerns were discussed during a meeting held with DCP personnel at NRO-NRR office on December 15, 1983.
Discussions included onsite design personnel training, document. control, audits, design verification, thermal loading releaae within the rigid restraint gaps, and snubber / rigid restraint interaction. At the time of the meeting, none of the issues was considered to be a problem by DCP. However, during follewup
. inspec.t' ions,.all the'above itens had resulted in staff asse'ssment' of violation' items. The event , ..
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t and . i re'flected DCP's Icek of concern for establishme . .
' mplementation of a sound design control CA program i ,
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s involving snubber'ah'd' rigid 4 Hardware probi snubber restra' int interretion that could make fied the inoperable under design conditionsation were identi in La Salle Unit 1 just before the HRC oper
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license hearing, and had resulted in licensee report, and removal and
' filing of a 10CFR50.55(e) ll size replacement of hundreds of large and sma in regarding mechanical snubbers. The DCP's position PP to be not the same situationsidentified i atvaluationDCH a problem requires in-depthi re, view and e*
by the staff. Unit 1 At the present, with fuel loaded in the
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, reactor, the access controthe coor air quality 'resulted
,,se'curity system >, and k inepection *
- from system' hot functional testinis, ma . es . '
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'. inside 4.w the,4tatien containment difficult /and into er '
that there will be: (a) subJ
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- Wi'th:the inspection stantial amount of staff and licensee re d are modification activities, and (b) some system har w .
to allow reactor low power testing and re-work, the existing problems could dis- ' before.; esolving co'urage
'r additional inspection effort and could
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hinder any required corrective ac i
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. . EXH. 2' -
UNITED STATES OF AMERICA
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at five percent anyway. So they only go up to two, three, 2 l four, five percent, to do the physic test or moderator 3 expansion, and these kinds of things, and shut back down. 4 So remember, we did look at the exposure, in terms 5 of megawatt days, at the time and decided it wasn't needed. 6 CHAIRMAN PALLADINO: I should call attention that 7 out of the six items, it's taken an hour and three quarters 8 for the first one, and we still have part of the first one. 9
; I don't mean to rush you, but --
10 (Laughter.) a 11 But I just call your attentior. to making sure that 12 we don't duplicate question. . 13 MR. EISENHUT: Perhaps we can move to the last cart 14 of the first item then, which was the small bore oicing 15 area. And Jim Knight is here to address that. 16 MR. DENTON: This is one that you should here. It 17 has forced us to do quite a bit more review and Jim Knight, i 18 - the Assistant Director of Engineering, will describe that. 19 MR. KNIGHT: If I may, just by opening -- and before ' 20 I forget the question and its relationship to this subject, 21 r you eariier had asked, Commissioner Asselstine, if we would 22 go to five percent power make anything more dif ficult? Just 23 to add to what was already said, . 24 one possibility -- in thinking in terms'of something like piping that'is bervasive all i 25 throughout the plant -- is the necessity for scheduling times
7.- H o ilbl4 1 i 69 for either getting in to do work or i 2 type of thing, nscecting, and this 3 since there may well be some areastheof plant where it would be difficult 4 to conduct an orderly inspection or an orderly operation 5 when, in fact, it's hot. 6 But I think that's something that can be managed on the administrative basis. . 7 8 One other earlier question was r l remember properly, e ated to, if I 9 what portion of the allegations went to issues that were treated by th 10 e IDVP. And I would concur [1 11 1 with Darrell's initial estimate that out of the first batch of allegations, roughly a quarter of them, 12 few, if any, there are in the structural and system d , 13 esign areas that . fI 14 ' go directly to the subject of the all egation. They dealt with the same subject 15 area, like the component cooling water systen . 16 And there were a number ' that were in the structural area . 17 As a matter of fact, I
. r j think those were some of the earli 18 est allegations we have. $
d When we get into the piping area II f 19 f !5 that start , there are some to deal rather specifically with i ;. { 20 ssues that the i IDVP did treat. I'm sorry, yes, the IDVP. S' 21 i Is that an answer to your question? ( 22
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A COMMISSIONER ASSELSTINE: It is, 23 have a follow up, and I guess I I y 24 which is could you talk a little bit the significance of that? about 25 j i. allega tions, Given the fact that these are - if the allegations orove to be corr ect, what 1 h 8
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I significance do you attach to that, in terms of the IDVP '
; 2 work? Were they caught by the IDVP? ..
1 ) If they were not caugh t 3 by the IDVP review, . what significance do you attach to it, in-4 terms of the quality of the IDVP effort? 5 MR. KNIGHT: ? Because there were so many situations 6 i where the allegation did not go specifically to the matter 7 looked at, the IDVP was a sampling program and it took certai n 8 specific areas and looked at them. It's difficult to draw ' 9 a linear correlation between what did the IDVP lcok at and 10
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? were the allegations, in those matters, in fact borne out r' 11 or not. s 12 I !
think you almost have to take them by category.
- 13 In the str'uctural area there were no instances, to my I
14 recollection, where the allegation was shown to be 15 substantiated. Let me be cautious. 16 There were areas where it might have been substantiated but the imoact was i 17 negligible. 18 s' 9 I remember one, a classic, where the allegation t 19 8: was that a certain computer code in use in the structural
- 20 area did not have the capability to treat torsion in built 21 up sections.
That was true. When we reviewed the matter we 22 found that the oeople who were responsibIe for structural 23 design had realized that fact and had, in fact, done an 24 initial hand calculations and synthesized the resuits of l l M the hand to computer calculations to come un with what we
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believe is an acceptable result. 2 And that, largely, was the same kind of finding tha t 3 you saw made in the IDVP. ' s 4 CHAIRMAN PALLADINO: On page E8 of 22, you speak 5 about the computer calculations. And one of the questions 6 I have is when will computer calculations on small bore pipin g ; 7 will be done? Will they be done -- , 8 ! MR. DENTON: i We have a whole story that we want to ' 9 tell you, about small bore piping, And maybe now is the time 10 to get into that. 11 MR. KNIGHT: These computer calculations I was ' 12 ; talking about a distinct -- there are two separate sets of 13 calculations. (l Perhaps I could finish on this first question. 14 Particularly in the area of piping, the IDVP for 15 istance, did find in a number of areas, the same kinds of 16 problems that we are seeing. And we'll talk about them in l' 17 a minute, where they looked. And again, they didn't look . 18 b N at a number of areas that we have looked into, 7 h 19 i' In those instances, as was the mandate of the IDVP, 20 they looked at the problems they saw. They looked at what 21 they felt was the overall quality of engineering being performed
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and they made a judgment that -- and I would say a succorted 23 judgment -- that albeit there were these orablems, the '. ;
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24 . final quality of engineering was adequate. ~ i \ .- M And I think that's an important point to recognize, 3 m
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! 17 f 1 that the IDVP was designed to have a professional experienced ,1 r
2 group go in and take an overview, and base a judgment on { 3 that overview. 4 COMMISSIONER ASSELSTINE: I gather that, at least 5 in terms of these calculations for small bore piping, the . 6 Staff'has now reached the conclusion that something more '. i, 7 Ii than what the IDVP program called for really is warranted . 8 { Should I draw anything, in terms of singificance, from that, .I 9 in terms of the adequacy of the IDVP effort or not? Or is 10 that -- I
. I 11 ' l MR. KNIGHT: My response is not at this time. 1 12 I i?
think it's,a very significant aspect of all that the Staff
- 13 I I 1 has done and of the Sbaff's recommendation in these areasUi e. i. ,
is 14 ~ based on the fact that despite finding some of these problems , - 15 which are not all that unique in type to Diablo Canyon, but r 16 li may in some instances be above what we consider to be an 17 { acceptable level in terms of frequency of occurrence. p 18 j.u
' Despite this, we have not found inadequacies in the ;
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hardware, as installed in the plant. And that, too, was 4 20 the principal thrust of the IDVP, to reach that bottom line, ! 21 to look for that bottom line, l,, 22 If, for' instance, i
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we are seeing unacceptable hardware as designed, in capable of \ y 24 l* meeting the loads that are required, then we would have to ' 25 step back and look and see what it means. ', 5: '! x 4 k ! I i
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I 73 1 One area that might be interesting to discuss ; 2 along those lines is a question that has arisen as to the 3 prevalence of snubbers, mechanical snubbing -- mechanical 4 hydraulic snubbers -- but are not, in the final analysis, 5 necessary. This is an area where the IDVP simply did not - 6 look. In some instances, it has taken it almost as a given f 7 i that this is a problem that exists and needs to be fixed, but 8 not as a problem which speaks directly to functional adequacy 9 f of the systems. 10 - With that, I would perhaps move on into the small 1 11 l bore piping area. Some 11 or 12 of the original allegations 12 were treated'under this heading of small bore piping, and after 13
) an initial period ofinspection, the subject was transferred 14 to NRR as a matter of better administration for the follow-up 15 on the allegations since NRR would become involved. 5 16 l' The effort was carried out by inspectors from 3 17 Region III, the NRR staff. l We used some of our consultants r 18 [1 l from Brookhaven and on one special inspection, received h D
assistance from an inspector from Region I. All of this [ 20 i covered about the past, oh, I guess it's going on four months, 21 and the result has been that we have reached a point now where ,. we see problems in the design OA program conducted, particularly 23 the on-site engineering group. [ Ne have, aside from both programmatic and ' 25 implementation problems, we have discerned what we consider 1
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2 an unacceptable error rate in the one class of calculations l 1 8 and those were the calculations performed by computer on the l small bore piping supports. i- { Following up on -- i 5
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COMMISSIONER GILINSKY: ' j 6 Can I ask you something i j about that? I 7 I noticed in one of the documents that the 8 error rate was something like 20 percent as opposed to the i usual 10 percent. l O 9 Now, the 10 percent sounded a little bit i*
, high.
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; l MR. KNIGHT:
' 11 Yes, and I suppose you might get, [
some argument. g 12 The consensus of people both on the staff 13 and industry'and talking to people on piping committees is that 14 if you go in to look at a mass of calcula, tion tasks i 15 like small bore piping, you will find on the order of a 16 10 percent error rate. Now, that doesn't say that 10 percent
*I 17 of the calculations or that 10 percent of the calculations [
18 are giving an erroneous finding, but it's saying that in I I' i 19 10 percent of those calculations you'll find something ';;: M ranging anywhere from an inadequate round-off to a rather i significant error in computer input or modeling. But I 31 i that's a judgment call. There is no extensive study to 22 . back that up. 23 But 24 in talking to the people who have been '
,j 25 involved in this for a number of years, that's the figure we g,
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CHAIRMAN PALLADINC: But why in this case did 2 we get the 20 percent? 3 MR. KNIGHT: Well, I think clearly the problems 4 that are going to be discussed in the not too distant future 5 y both here at the table and also with the utility in design
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implementation and document controls and in the general 7 conduct of the design program, led to, first of all, the 8 situation where errors were created and secondly, where 9 they were missed. 10 These calculations were checked. COMMISSIONER GILINSKY: Was small bore piping, 11 handled differently than larger piping? Handled by a 12-different' group? . l ) 13
. MR. KNIGHT: It's handled by a,different group.
14 15 It's handled by a group onsite as opposed to the large bore piping, which is done by engineers in the design 16 l 17 offices at the home office ar.d in this particular case in [ PG&E and Bechtel, San Francisco. l-18 And that's the usual ( procedure. It's done by usually a self-contained group I l 19 [i 20 onsite because there is such an intensive interaction. ; This piping is one of the last things done in the plant, it 21 ! 22 has to be run in and around structures and other equipment, - 23 and a lot of custom work has to be done. ' ' COtiMISSIONER GILINSKY: Could you give us just \' i 24 l 'I -j 2 a bit of a feeling for the significance of the systems in i, q- 'which this piping plays a role? Or the significance of : 'l-Ig .'
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It ranges all the way from sample
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I'J. lines; half-in'ch, quarter inch' sample lines up to systems 1 4 - like the reactor coolant pump seal ~ injection. Reactor . 5 ' : coolant pump seal cooling, excuse me. It's two inches in 1 i 6 d ameter and belowjin hiaJcase p - 7^ Of course, all of our di ussions_ related -- 8 it's safety related systema, rand.;ea6h has its assigned {
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9 . d # safety fuctions. _s 1 _7 10 _ - MR.~DENTON: What we're talki.sg about is the II _ [( supports for this piping mainly. ,. , 12 - MR. KNIGHT: Yes.
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, , MR. DENTON: Seismic sup' ports, hangers, any -i 14 ~l' kind of support, and these,used to be' one relatively 15 ,
simple, through:. handbook type equations',. and today has ' i, 2 - Ii 16 . become practically an art form as to' h6w to properly 8 8
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(- compensate for alb-the stresses, includin6 seismic. I! 18 CHAIRMAN PALLADINO: It was my understanding 19
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from reading -- if I read it correctly -- that the errors il crept in primarily on computer analysis. Is that right? 21 ' '
. IR . KNIGHT: There are, fc r purposes of discussion, 22 c6Eentially two broad groups of these calculations.
d One is-
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those which are.done I;y hand, essentially using either span
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code, and the error rate tras -- that we're discussing here 2
)
was in that group of calculations which were done by 3 computer. 4 MR. DENTON: I would just say we were unhappy with the result that we found and required the utility to ; 6 do samples. They did some samples, and you might relate, ; 7 Jim, what was found when you had them redo a bunch of I 8 ' calculations. 9 MR. KNIGHT: They have now -- or at least at 10 last report 11
-- had taken 130 of the calculations, includ,ing those that were originally found to contain errors by the 12 staff, and redone those calculations for the purpose of 13
{ 1 . I il discerning whether or notsith the error corrected there 'Y j 14 . t were still deficiencies, or would be deficiencies, in the k 15 , functional 16 capability. In otner words, with the errors ,[ g 17 corrected, would the supports be shown to meet the original S design criteria. . 5-r 18 {;l;
': (
19 The answer to date has been that in each of those '! ! cases, 20 ultimately the support was shown to be adequate as i installed. 1, 21 22 Since there were pressing questions on the adequacy of the design control measures employed when those I. 23 i 24 calculations were done the first time, we sent the Region I
~
{ inspector out 25 to observe the process of re-reviewing those calculations to assure ourselves that it wasn't the faulty
M sy& 1 78 I Ie I I process, reviewing calculations and making some of the same 2 l- \ ) mistakes. In this instance, the group that did the review 'j 3 t was back at the main office in San Francisco, and the d 4 inspector's report indicates that both the process, the j 5 I qualification of the people and the process employed was i 6 I' sound. f1 t 7 I guess at this point it's important to try to 1 8 sum up the staff's posture here. Having found these 8 problems in design control, although we haven't completed the 10 process whereby we would identify on one concise list each II and every problem as we now see them, get a utility response 12 and develop a corrective action, it certainly has gone far 13 j enough for us to be able to say these problems do exist, to recognize that they do exist and' to look into that next 15 step which was the adequacy of the plant as best we can 16 a discern it. And I think we've taken a pretty good look at 17 that. 18 Given that to date we have not seen any 19 significant impacts on the actual installed equipment in 20 the plant, given that the plant has been through one or more 21 heatups so if there were some broad scale inadequacy in . 22 support that would indicate a process out of control -- 23 large interferences and supports over stressing or not j function, given that that has not occurred, we feel that 25 it's desirable and prudent at this point to proceed with
f
.sy7 o l' 79 i
t I the 5 percent license and over the next several months as s 2 l} an integrated program, correct the programmatic deficiencies i 3 I, that we've seen in the piping area and then continue on 4 f( with staff review and audit of those corrective actions 5 prior to full power licensing. 6 Now, sitting at my right is Mr. Yin from 7 Region'III who has been a principal inspector in this 8 effort, and MR. Yin has some comments that he would like to , 8 1 make. 10 I CHAIRMAN PALLADINO: Okay, li 11 MR. YIN: Mr. Chairman and members of the 12 Commission, I'd like to ask your permission to let me read 13 a short deposition that I made. 14 CHAIRMAN PALLADINO: Okay. 15 MR. YIN: My name is Isa Yin. I am presently 16 p working in Region III, Division of Engineering, as a 17 Senior Mechanical Engineer. Relative to Diablo Canyon 18 f Nuclear Power Plant team inspection effort, I was assigned 19 the responsibility of following up on some of the allegations 20 made by Mr. Charlie Stokas. The specific investigation 21 areas were restricted to the site small bore piping 22 suspension systen design control. However, due to hardware 23 deficiencies observed during plant walkdown, the Licensee 24 l l design control measures for large bore piping system had 23 also been included as a part of the overview inspection and
F sy8 80 1 evaluation.
) 2 lI As a result of the investigation and inspection 3
( findings, it's my professional opinion that che Unit 1 I reactor should not be permitted to go critical at this time. 5 The reasons for such determination are as follows: . 6 One, Almost all of the Stokes allegations 7 assigned to me for follow-up have been substantiated. Based 8 on the many assessed violations against the 10 CFR 50 : Appendix B criteria resulting from followup on these 10 allegations and the indepedent overview inspections, it was , I g 11 ;
~
concluded that there had been apparent QA program breakdowns , 12 ; in the area's of small bore and large, bore piping design : I 13
) control. - ' 14 '
Two, Piping systems cannot be subjected to true '
) functionability tests until after severe transient conditions ,,
16 la such as an earthquake had occurred. The ensurance of I 17 l 5 system operability relies principally on analytical methods. 18 [3 1 t!. In spite of this dependence on theory and analysi s, 'g 19 I I the lack of licensee large bore and small bore piping system 20
. design control that aad resulted in an alarmingly large 21 l
~ number of calculation errors and deficiencies that had -
22 j.', slipped through various review and checking stages, is
- o' n
indicative of the failure of the Corrective Actior. Program .+ 24
!f conducted by the Diablo Canyon Project group in the past k 2 l ;j two years.
c i b I w , s i
Y
. . 1 81 1 1 Issues raised in responding to the staff's [
2 initial concerns were discussed during a meeting held with b 3 .n the Diablo Canyon Project personnel at the NRC-NRR offices }s 4 on December 15, 1983. Discussions included onsite design 5 personnel training, document control, audits, design 6 r verification, thermal loading release within the rigid ; 7 restraint gaps, and snubber / rigid restraint interaction. 8 At the time of the meeting, none of the issues was considered : 9 i to be a problem by the Diablo Canyon Project. However, during t' ItL i follow-up inspections, i all the above items have resulted;in i 11 staff assessment of violation items. The event reflected 12 Diablo Canyon Project's lack of concern for establishment i ! and implementation of a sound design' control QA program. 14 Four, Hardware problems involving snubber and
- 15 l
rigid restraint interaction that could make the snubber 16 , inoperable under design conditions were identified in 17 LaSalle Unit 1 just before the NRC operation license hearing I 18 .
.(!
h and have resulted in licensee filing of a 10 CFR 50.50(e) 19 'l report, and removal and replacement of hundreds of large 20 and small bore mechanical snubbers. ' 21 ' The Diablo Canyon Project's position in regarding , 22 the same situc.; ions identified as the Diablo Canyon Nuclear
- Z3 ,i sc Power Plant to be not a problem requires in-depth review
& ; 24 F ) { and evaluation by the staff. C 25 C Five, At the present, with fuel loaded in the E. 7 2
u 82 1 Unit 1 reactor, 2 the access control including complicated g) , 3 security system and rhe poor air quality resulting from 4 system hot functional testings, makes inspection inside the 5 containment difficult and interolerable. With the expecta-tion that there will be, one, a substantial amount of staff 6 and licensee re-inspection activities and, two, some system 7 8 hardware modification and rework to allow reactor low power 9 testing before resolving the existing problems could dis-10 courage additional inspection effort and could hinder any ! required corrective actions. 11 , 12 This is the end of my deposition. CHAIRMAN PALLADINO: 13 You say you were reading e from a deposition? Is that something we have? A I l 14 : ( MR. YIN: 1 15 This is -- I wanted to cover everything '. in my mind, and then -- : 16 , CHAIRMAN PALLADINO: I was just wondering do we
- 17 have something to look at? i.r-18 j' MR. KNIGHT : It's a written statement. I 19 .'.
CHAIRMAN PALLADINO: Can we get it so that we . 20 can deliberate on it? Does the staf f have comment on it? i I 21 , n MR. DENTON: Well, it's a clear difference of 22 opinion but on a narrow issue. I think it would .be helpful 23 , 1 to let me try to summarize the differences. I don't think I i 2s there are any technical differences between them as to what needs to be done, forgetting about when they're done, for al A
.T ; =
! 83 I
1 the moment. I think we've told the licensee to do it and l 3 I think the policy issue is do they do it before fuel load 4 or should the'y be allowed to do it during low power testing. 5 It's my view, taking everything into account and what goes on during low power and the fact that no
- 6 7
hardware changes have been found to be necessary so far, that this can be done during low power testing. So the 8 staff's view is that it's not necessary to do this prior to 9 fuel load, but I did want to call th'is different view to the 10 11 Commission's attention and get your guidance on that poin.t. CHAIRMAN PALLADINO: So the issue is when we 12 do it?~ Is that the way you understand it, Isa? 13
}
{ 14 MR. YIN: There usually is -- right now there 15 are approximately 49 violation items outstanding, and it 16 would seem to me difficult to even imagine thinking about 17 going critical without talking about resolving at least 18 some of the critical issues that caused the almost total QA breakdown in this particular area. 19 CHAIRiiAN PALLADINO: 49 violations -- is this 20 something that I missed earlier? 21 MR. DENTON: I think -- you need to understand 22 that 23 there's a team of people doing this, involving Isa 24 from Region III, people from Region I and people from l Region II and Brookhave, and I think Jim told me that the next step would be to -- once Isa has produced his report --
y , 84 1 to have it peer reviewed by the other people from the other
$l 2 regions and then decide what to do.
9 I think Isa is telling 3 you his opinion of what the situation is there. 4 MR. YIN: The 49 violation items are all 5 resulting from my own investigation and inspection effort. 6 And it's divided up into eight different criteria against the 10 CFR 50 Appendix C criteria. CHAIRMAN PALLADINO: Aren't these accepted by 8 the staff as being -- 10 MR. YIN: I'm not too sure they even reviewed them. 12 MR. KNIGHT: We haven't reached that point yet. I I As I said earlier, it needs to be -- Isa has, I believe, a few more days of inspection activity. The report then would 15
- be prepared and take its normal course to review. Here we 16 have the task of bringing together an inspection effort 17 conducted out of NRR, for good reason, and then to be 18 combined with the activity now underway in Region V, since 19 the final effort, final enforcement ef fort, will come out 20 of Region V.
21 MR. DENTON: And if enforcement actions are 22 necessary they'd be taken in due time. But I was focusing 23 on rectifying the deficiencies in the plant, if there are ll any, and that's where I didn't think there was any major 25 technical differences between Isa and the others on what
t . l a , 85 1 needs to be done with regard'to doing a proper calculation 2 and then checking the plant to see if it's still proper. 3 And that's why I wanted to emphasize that the company has 4 been required to begin this process, has done a relatively 5 small number but the number that they have checked they 6 didn't find the need to make the hardware changes. If 7 that had come out another way, then the staff view might 8 be different. But you have to look at it in that perspective , CHAIRMAN PALLADINO: Jim, you had mentioned 10 something about a peer review. Was the peer review going II to be with regard to these 49 violations, or is the peer review going to be on the timing of. corrective action? I MR. KNIGHT: Isa has done a lot of work and I4 covered a lot of ground. We need to sit down with the group 15
. of people that we have assembled from all of the regions to 16 be sure that we have a good uniform approach, and look at -
Isa's findings, categorize them as to significance from the 18 f standpoint of enforcement actions, if necessary, and talk { about correct action programs that would address those
, findings. That was what I mean by a peer review.
S 21 MR. DENTON: Let me ask,to what extent was l ? 22 4 LaSalle allowed to make these kind of corrections during
? n f low power testing?
I I$ MR. YIN: It was not. It was corrected before r o 25 y the low power tests. It was corrected in construction. E
, k5:
s I&
e T '1 a - 86 1 There was really a concerted effort by Commonwealth Edison people, and I was the one who oversaw the effort and make
' 3 sure everything was replaced or corrected.
4 i CHAIRMAN PALLADINO: Do we know what needs to ' 5 be corrected? Go ahead. 6 MR. DENTON: I think one issue, too, that t 7 complicates this is a question of what's adequate versus - 8 what's better. In other words, Isa thinks that many plants 9 '
- have too many snubbers and they could lock up and cause 10 ,
problems, and I think at LaSalle, through your efforts, you , ( 11 were able to get them to remove a large number of snubbers. 12 . y MR. YIN: More than 600. _. 13 l .g MR. DENTON: So he's like to see the same _. 14 { approach taken at La Salle taken here.
~
15
,--. COMMISSIONER GILINSKY: 600 snubbers removed at
; 16
~
LaSalle as a result of your review? I 17
$r MR. YIN: i i Yes. So it's really a significant ,
4:
# 18 {
1 F N. problem. T. 19 1e COMMISSIONER GILINSKY: Could you say something ,
*A N i
'N about your background or qualifications in this area? ,,
1 2d 21 ,
,$ MR. DENTON: I think they're quite good.
r 35 n!' 22 h MR. YIN: My previous experience was with ,! 23
}k, Bechtel, Parsons and Generl Electric, San Jose. And I've C 24 g
l f'[ been with the Commission for about 10 years. U y{ ( COMMISSIONER GILINSKY: And in terms of your 4 3 .
t 87 I expertise on the piping, would you say something about that? 2 -
'MR. YIN: I have a stress analyst for many years 3
with GE and with Bechtel. 4-COMMISSIONER GILINSKY: Have you worked with 5 these systems in particular? 6 MR. YIN: Yes. Ex tensively. COMMISSIONER GILINSKY: Could you just say 8 briefly once again in a couple of sentences why turning 9 the plant makes it more difficult to correct the problems? 10 MR. YIN: Well, I was only invited to go to , 11 Diablo Canyon four months ago, so before that, I have no 12 knowledge about what was going on in Diablo Canyon. ( l 13 COMMISSIONER GILINSKY: But in terms of why 14 turning the plant on makes it more difficult to deal with 15 these problems. 16
- MR. YIN
- Well, I was in the containment about 17 l two or three weeks ago, and the air was so irritating, my 18 eyes were watering and my breathing was difficult because 19 of the whole containment shut tight, and a lot of testing 20 was going on. Not to mention the heat and the noise; just 21 the air itself is so bad you just couldn't stay there for 22 more than two hours. And I stayed there about four hours 23 so by the time I got out I almost felt sick.
24 l l COMMISSIONER GILINSKY: So you're saying it's 25 more difficult to inspect the pipe?
88 i 1 1 f!R . YIN: Well, it's more difficult if not l 2 impossible because if you let it go critical, then you have ! l 3 to wear a mask or a half mask or a full mask or maybe you l 1 4 have to suit up, and climbing up and down, it's almost -- 5 well, it can be done but it's almost like discouraging , 6 not to do too much because physically you can't stand that 7 kind of environment for too long. 8 CHAIRMAN PALLADINO: Harold, when they do low 9 power testing are there periods tihere they cool down? Is 10 there any difficulty in cooling down if they had to make 11 repairs? 12 . MR. DENTON: No, it's quite common I think in 13 { l this period to find operational problems that didn't turn 14 up before and require the plant to go cold shutdown and 15 make repairs on things like valve leakage and pump seals and 16 these kinds of things. Certainly nothing precludes going 17 back to cold shutdown. 18 It's a question of degree. Certainly, it would 19 be easier to do it in terms of controls and those kinds of 20 things, and this plant has an operating license, it's 21 operating under a health physics program of sorts, even 22 though it's not allowed to go critical yet. And certainly 23 it's easier to do it than before. g I think the question that we faced here is, is it necessary to do it before, and I think if this were a
89 1 normal plant we wouldn't require it to be done before this 2 time. 3 COMMISSIONER GILINSKY: Well, what is it we're 4 talking about doing? Mostly this is a recalculation. 5 MR. DENTON: Recalculation, which is in progress 6 now and which the licensee has agreed to do, and agreed to 7 complete before going above low power. So the question is i 8 what's going to result from these calculations. The early 9 returns don't show much hardware changes, and that's where
; 10 the judgment comes in. Do you make them complete it, and 11 then there's the enforcement side. It seems to me it's not 12 necessary in this case from a public safety standpoint --
13 COMMISSIONER GILINSKY: MR. Yin is shaking his 14 head there. ' 15 MR. KNIGHT: Well, there are some other things. 16 Certainly a large part of it is recalculation -- 17 COMMISSIONER GILINSKY: Well, that you don't 18 do in recalculation. ! 19 MR. KNIGHT: In addition, we have this matter of 20 the excess snubbers. Now, there's a question as to whether 21 that's something that needs to be done now or whether that's 22 something that's a program that has, at least in other 2 facilities, been scheduled for completion, say,'by the first 24 refueling. 2 In addition, there are a number of other things
v 90 1 that -- ll 2 COMMISSIONER GILINSKY: How would you decide on 3 exceed numbers? Is it a matter of walking down the systems 4 and taking a look at them, or recalculating them? 5 MR. KNIGHT: in part. Both that and primarily . 6 looking at situations where che snubber is, say, adjacent 7 to a rcstraint or adjacent to some penetration, for openers. 8 But it would be a combination of inspection and calculation. 9 MR. YIN: Let me address that question. The 10 subject matter of snubber-rigid restraint interaction, there 11 are three categories of problems. First, if the snubber is 12 installed too close to a rigid restraint, the snubber will 13 not lock up because the rigid restraint will prevent I# adequate snubber movements to allow it to lock up. 15 So if the snubber doesn't lock up, you will load up the rigid restraint right next to it in the vicinity, 17 so that will cause a safety problem. 18 This area of the problem must be fixed before 19 any full power operation. 20 The secondary category involves if you review 21 those calculations they show many snubbers with essentially 2 no thernal movement. So the logic behind it is unknown to 23 me because if there is no thermal movement, we don't really ( I 24 need a snubber; you can easily replace it with a rigid 25 restraint. Because the wro'.e purpose of a snubber is to i
'5
1 Nf i 91 1 1 l 1 allow free thermal movement during normal operation i l conditions, and yet restrict the piping movement during , 1 3 I a transient condition. So if there's no thermal movement 1 1 4 there should not be any snubber; there should be a rigid 5 . restraint. I l 6 And the third category is the ALARA considera-7 tion. Those excessive snubbers that are unnecessary and 8 are in the plant and in the tech specs, it requires almost 9 annual inspection. So those people performing the inspection 10 and functional testing of those snubbers will receive an 11 unnecessary dosage. So it's a violation of the ALARA 12 consideration criteria. 13 { j So they are the three categories that we have to deal with. 15 COMMISSIONER GILINSKY: Are we talking about 16 looking at tens of locations or hundreds of locations or 17 what? 18 MR. YIN: For LaSalle there were more than 600. 19 For this plant I have no idea. I just casually walked 20 through some areas -- we already identified a whole bunch. 21 COMMISSIONER BERNTHAL: Does Staff have any idea? 22 Anybody know? Phat's a whole bunch, by the way? How many 23 did you identify? 24
} MR. YIN: I selected about 16. Later on, I 25 found, just casually walking for the unintentional restraint,
y g 92 I which is another issue, quite a few. It's all talked about i in the report with a table, evaluation, everything. 3 CHAIRMAN PALLADINO: Which report, Isa? 4 MR. YIN: 5 This is my -- the report in my hand is my draft investigation inspection report, which is 6 7 incomplete and some of the information are preliminary . MR. DENTON: 8 I think there are several issues that are important here. We don't know the specifics of 9 Diablo Canyon. 10 They have a lot of snubbers because they are one of the highest seismic designs in the U.S., so they may 11 be necessary. I want 12 to be sure that Isa 's findings are 13 properly reviewed and that we don't take out necessary l snubbers. ( 14 15 I do think it's the kind of program that can be 16 accomplished during this low criticality and low power Lesting. 17 I don't think it cannot be straightened out before full power. 18 CHAIRMAN PALLADINO: But you do plan to 19 straighten it out before full power? 20 MR. DENTON: That's right. 21 So I think we can -- 22 I don't think ALARA is a real issue here during this period, andI don't 23 think it would preclude proper inspection and testing. 24 l ) 25 In terms of the level that we may have to assure it's properly.done, I think Isa thinks he's more likely to i
y-
. +
93 1 get it done properly if you don't start up until it's all 2 done. But I don't doubt our ability to get a proper review 3 and all the changes that are necessary done during this 4 period. 5 CHAIRMAN PALLADINO: Let me say I want to thank 6 Isa for coming forward with his comments. 7 I think he has demonstrated by his past experience that we ought to look at 8 the snubbers and fixed supports in relationship to each 9 other, and I think the Commission will have to weigh whether 10 it's necessary to do it before low power. It certainly 11 . appears, based on both of your statements, that it ought to 12 . be done before full power. 13 l I COMMISSIONER ASSELSTINE: Joe, I had a couple 14 of questions, if you're getting ready to'go on. 15 CHAIRMAN PALLADINO: No, I was getting ready to 16 call a break, and I tink during that break we have to assess 17 the improbability of completing everything on this agenda I8 this afternoon, and try to develop a plan that we can come 19 back and perhaps announce after the break. 20 COMMISSIONER ASSELSTINE: I'd like two questions 21 for Isa. 22 CHAIR'4AH PALLADINO: Go ahead. 23 COM'11SSIONER BERNTHAL: I have a couple, too. 24 COMMISSIONER ASSELSTINE: Before I ask my k 25 questions, Isa, I want to tell you that at least at one
m-94 1 previous meeting I've commented -- you weren't here at the 2 kI time, but I commented on one of the transcripts or a couple 3 of the transcripts that I'd read of your meetings and the 4 staf f's meetings with the licensee on this whole small bore 5 piping and snubber issue. And I'll just tell you now that 6 you're here that I was very impressed with the aggressiveness 7 and the commitment that it was apparent from those trans-9 cripts and the way that you were pursuing these issues, and 9 I was very impressed with that when I read the transcripts. 10 MR. YIN: Thank you. 11 COfDilSSIONER ASSELSTINE: The two questions that 12 I had, under your f. st point you mentioned an apparent QA j 13 j program breakdown in the areas of small bore and large bore 14 piping design control. I had not sensed'that there was the 15 same kind of concern about the QA program on large bore 16 piping in the other documents that I'd looked at from the I staff. Is this something that is a new element? 18 MR. YIN: Right. Really, my concerns are more
- 19 with the large bore than the small bore.
COMMISSIONER ASSELSTINE: Could you talk a little 21 bit about what the basis for your concerns are there, 22 because again, I didn't have the sense from things that 23 had gone on before that that was a real problem, but I'd 24 { j be real interested to hear what the basis for your 25 concerns was.
e
- 95 1
MR. YIN: The 49 violation items -- maybe 2 # l i perhaps more than half of them were assessed against large 3 bore, which is not really any allegation; it's all the 4 NRC ovsrview. 5 COMMISSIONER ASSELSTINE: Is it the same kinds 6 7 of concerns that we have about the small bore in terms of the calculational work that was done? 8 MR. YIN: It's a lot more complicated. 9 COMMISSIONER ASSELSTINE: I gathered from what 10 Jim had said before it's a different group that had done 11 . those. 12 MR. YIN: That's correct. It involved CIGNA, 13 j , it involved INPO, involved Westinghouse, also involved 14 Bechtel themselves. So the lack of control of the whole 15 operation and interface among them -- if I have to talk 16 about it, it's going to take time. 17 COMMISSIONER ASSELSTINE: Okay. I guess the 18 second maybe -- I don't know. I guess I'd like to hear or 19 see Lanething additional on some of the problems and the like. 20 CHAIRMAN PALLADINO: Yes, we'd be interested in 21 the nature of the control problems. 22 Is it again an interaction between snubbers 23 and fixed point support and the expansion problem? 24 MR. YIN: Well, you really trace it back 25 perhaps as an inadequate independent design verification
1 -
, . 96 1
program by itself, and the corrective action program may not jl be working at all. So it's -- I haven't really drawn that 3 conclusion yet, but it's really pointing in that direction 4 from the many violations that we identified during the 5 course of the inspection. 6 Now again, I think we are treating the licensee 7 rather unfairly because on many of the items I was able to 8 talk to you about it; I was not given the permission to even 9 discuss with the licensee. So it may be a surprise to all 10 the audience that we have here today, but that's the rule 11 I have to go by, and unless the rule is citanged I'm not 12 about t,o talk about the findings and not talk about anything 13 g which is kind of strange.
}
14 CHAIRMAN PALLADINO: We're g6ing to have to 15 l discuss this one some more, I can see. 16 MR. DIRCKS: Before you break there's one other 17 concern we'd like you to get to this afternoon, and that's 18 on this new geology, new seismology information because we 19 do have someone here from the USGS and we hate to tie him 20 up for another day. 21 i CHAIRMAN PALLADINO: Well, could we take a 22 15-minute break anyhow? I think it's important to do that. 23 l Did you have a question? 24 COMMISSIONER BERNTHAL: Are we going to come { 25 back to Mr. Yin's concerns, or is that supposed to be
m 97 I finished now? I CHAIRMAN PALLADINO: For the moment I was going 3 to leave it. That doesn't mean that we're finished with it. 4 COMMISSIONER BERNTHAL: Does that mean for 5 15 moments, or -- 6 CHAIRMAN PALLADINO: No. If you have questions-- 7 COMMISSIONER BERNTHAL: I'll be very brief, 8 then. First of all, I want to compliment our staff and 9 you, Bill, for putting the disagreement here on the table 10 and for Mr. Yin being willing to come forward and state h.is 11 disagreement with some of our staff. At the same time, I 12 guess I'll reserve judgment on whether to chastise the ( } staff for not recalling that on this five-member Commission 14 ' there are only two engineers, and there's only one nuclear 15 engineer that I'm aware of. And it seems to me that on an 16 issue that's an engineering judgment issue of this type, 17 ' I at least have to ask myself the question of whether it's -- 18 I don't know where it is, ACRS perhaps where we seek 19 independence, blue ribbon, third party evaluation of some 20 of these things, whether they should not have sat down and 21 tried to resolve the issues or exactly where we should turn 22 at this point. But in any case, it's good that it's on 23 the table. I'm not quite sure what to suggest from here on. 24 g ) One quick question. Mr. Yin, you noted how 25 difficult it was at.zero power to carry out the kind of
I 98 1 inspections within the containment that you feel are
$ I 2 necessary. It wasn't clear to me with the possible exception 3
of the obvious difficulty on increased radiation levels, 4 whether you feel that the same difficulties of atmosphere 5 and the environment that you might have to work in are 6 exacerbated at 5 percent power or not. 7 MR. YIN: Based on the conservatism we approached 8 in the radioactive protections, sometimes even --I go in and 8 out many of the nuclear power plants in operation, and I 10 come out with zero exposure. Dosage just doesn't show 11 anything. I have to wear all kinds of things. And even 12 writing some notes is difficult. { } So that's the name of the game. Once you I4 ' get started up and you have to wear all those things, you 15 have to wear all those -- the mask and all kinds of things, 16 you will make the working inside already difficult even 17 more impossible. 18 COMMISSIONER BERNTHAL: But it is the background 19 radiation level, then, it's the incremental -- 20
.1R . YIN: It's not the radiation that was really 1
. of concern. It's the crazy regulations are what the 22 problem is.
23 (Laughter.) 24 ( CHAIRMAN PALLADINO: Harold, can I ask you one 25 question. Isa spoke about large bore piping and your t i
v 99 I comments related to what he found on the small bore piping 'l I 2 Do youluve a feel for what the issue is on the large bore? 3 ' MR. DENTON: Let me defer to Jim on that, and I 4 do want to emphasize this was not being approached just with 5 one person. Because of the original findings we did put 6 together this team of people from other regions and 7 consultants all under Jim's direction, so he's getting input 8 on these same issues from a variety of people and I don't 8 think he's necessarily had the benefit of Isa's latest to report on this topic, but let me ask him to address this II question of large bore piping. 12 - MR. KNIGHT: That's true, and our focus to date 13 i l on the allegations has been on the small bore piping. We have pursued large bore piping for some period of time. As 15 a matter of fact that was one of the holdover items on the . 16 IDVP. We required them to take two additional large bore 17 piping problems and go completely through them from 18 beginning to end as additional assurance for ourselves, 19 and that worked out well. m . As I said, I haven't had the full benefit of 21 Isa's findings on large bore piping. To the extent that some 22 of the same QA problems are starting to show up, I've been 23 generally aware that we might be seeing that but at this j 24 F 4 l juncture, I have not been aware, and I'm still at this 25 juncture not fully informed as to what the extent of the
T lQ0 1 problem is, i l 2 COMMISSIONER ASSELSTINE: Wouldn't that be even 3 more significant than the small bore piping concerns in 4 terms of the adequacy of the IDVP? 5 MR. YIN: Yes. 6 MR. DENTON: Well, I think I'm reluctant to 7 make that large leap, that taking out snubbers invalidates 8 the IDVP. I think it would be a substantial effort. There 9 may be some better refinement of snubber and hanger locations 10 that would minimize the need for inspection on this kind of 11 thing, but I haven't reached that point. 12 . One other point I guess that comes to mind, too, I ' I think if you require it prior to fuel loading it does 14 ' certainly put the pressure on the utility to do a very rush 15 job in this case. I think since it doesn't trip my 16 threshold for public health and safety protection during 17 low power, I think it could be accommodated during that 18 period, whereas if you require it to be done in advance I 19 think you'll stop everything else they're doing out there 20 and go to doing recalculations here. And you'd have to be 21 careful that we don't lay on something which is a rush 22 effort because it could take several months. Maybe you'd 23 like to estimate how long it might take to do the program l ' that'they've already agreed to do and have started. 25 MR. YIN: Based on my personal experience
r T 101 ! I involving another project for similar problems, it takes 2 l about six to nine months to get it done, all depending on 3 whether or not the individuals are given specific 4 responsibility. In this particular job, you know, -- I'm 5 with Region III and it's under the control of Region V, 6 and the lead is from NRR. So it's in kind of a confusion 7 stage. 8 So sometimes the licensee is asking who is in 9 charge. So if we define who is going to -- 10 COM?lISSIONER BERNTHAL: We ask that a lot here. 11 (Laughter.) 12 MR. YIN: -- to correct the problem, I think 13 we'll get it done easy. 14 CO!1MISSIONER GILINSKY: But You're not talking 15 about a six to nine-month process, Harold, I take it. 16 MR. DENTON: I didn't think it would be that 17 ' long. I thought it could be accomodated, myself, during 18 the low power testing phase, and I really didn ' t know -- 19 COMMISSIONER GILINSKY: Which is sort of a 20 two-month process or something. 21 MR. DENTON: Well,-seldom are they quite that 22 short, but I didn't know what the answer would be, and I 23 guess that's the best experience we've had. But going back 24 again, they have been required to do a bunch of these and
} 25 the ones they've done didn't result in changes. So it's --
+
102 r I we shouldn't jump to the conclusion that 2 it's automatically going to require, changes here. 3 COMMISSIONER GILINSKY: Let me just say for 4 myself that I second Mr. Bernthal's remarks, since I 5 haven't been critical in the past of some practices. I 6 , think it's a very good thing that you have laid out the 7 various points of view here. And I think also, MR. Yin, 8 I know it's not an easy thing for a staff member to step 8 forward and present his own views where they differ from 10 those of others, and I commend you for it. 11 . MR. YIN: Thank you. 12
. CHAIRMAN PALLADINO: We all agree on that. We 13 thank you, and l I I would like to declare a 15-minute break.
I 15 We will come back and at least discuss th'e USGS comments on the new report and the staff comments. 16 So we'll come back in 15 minutes. 1 (A short recess was taken.) 18 19 20 l 21 22 23 24 25
4 0 UNITEh STATES OF AMERICA NL*CLEAA REGtlLATORY Commission l . . . r
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f' , . E. ,.;- In the matter of: n( U" q
- i I ,f . DISCUSSION /POSSIBLE VOTE ON DIABLO '
",' - CANYON CRITICALITY AND LOW POWER OPERATION Docket .No.
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136 - 287 ,f
,;ff Location: Washington, D. C. i .V
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Date: Tuesday, March'27, 1984 '
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s. 233
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continuation. of the. suspension,
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Mr. DeYot$ncr's reply dated March 26, yesterday, 8 ' detiermined that first, hC&E did in fact commit a material 4 false statement.for failing to" report the 1977 NSC audit. 5 - They determined tnat-it was a severity level four with no 6 / civil penalty. They den.ted the request for revocaticn or 7 continuation of the sur. pension of the low power license and 8 as under any 2.206, we noted that the Commission in fact can 8 undertake a review of the IE decision under 2.206 (c) . 10 So this was issued yesterday. I just wanted . 11 ' for completeness to make sure we pointed out that that s 12 ' is where the ,' staff had come down. '- ' 13 CHAIRMAN PALLADINO: If we issue an order on this 14 ' ' plant, would that settle that? 15 MR. EISENHUT: I think the Commi.ssion can certainly 16 /
/ r review this on a normal timeframe. Tnir. was just signed 17 '
yesterday and I think certainly we would yiew it that 18 thati petition isja separate matter that'you would be able to , undertake a review on. l , i 20 i The last item.Iw wanted to mention is so'rt of a ~ 21 ~ recommendation and our proposal on the ar'ea'of small bore 22 t , piping, principally small bor,e' piping, but large bore piping
.4 also. This is in response to a number of questions and 24 l
c i concerns about where we are really heading in this area. y . CHAIRMAN P,ALLADINO: I particularly want.to have the j -
- i a
, f
T M 234 1 staff state its position and approach in dealing with the 2 issues raised by Isa Yin regarding small bore and large bore Pi Ping, 4 MR. EISENHUT: I can do that and let me try to back 5 up a little bit and reflect on these issues. These concerns 6 started coming up from the staff in probably late December or ' 7 early January. 8 Those of you who are into reading transcripts will 9 notice that we had a number of meetings on this subject. By 10 the end of January, it had elevated to a concern level where, 11 in fact, I chaired a meeting or attempted to chair a meeting 12 in San Francisco on January 31-
< I3 At that time I characterized 1 these concerns basically as they are not Mr. Yin's concerns, 4
they are the staff's concerns. . 15 I attempted to reflect them as these are questions 16 we put to PG&E, They are questions that we thought we needed to get an answer from PG&E on. This is somewhat of our 18 I usual approach of if we have questions, we put them back to 19 the utility. We formally documented it with a transcript so 20 we could keep track of where we are going. 21 As a result of that meeting, we and I haven't gone 22 back and read the transcript, but I am pretty sure that at the 23 end of that meeting, we identified a number of areas where we 24 thought the utility would have to provide information to the 25
- staff to assist us to do our evaluation.
m 235' l 1 The utility has done that. It was my understcnding 2
)
3 thatc.( the principal concerns up through that point in time up 4 until very recently, the principal concern related to the 5 reevaluation of small bore piping supports principally 6 those that were done by a computer calculation. You get - 7 to something on the order of about 1,800. Furthermore, it 8 is my understanding that the principal problems were identifie d . 9 A program was in place by the utility. The utility has submitted a proposal. 10 11 To date, he has evaluated something on the order 12 of over 100 of those. No physical changes or problems have 13 been identified to date. But it is fair to say -- it not l 14 fair to say that it is just Mr. Yin's concern of the technical nature of the problem. 15 The probleras to date principally have 16 related to the field engineering approach to small bore piping supports. 17 18 There were allegations that this group worked under extreme pressure. 19 They were given mandates to perform so many 20 calculations ,in a certain period of time. We have concluded 21 that there are questions about the training thatrthose 22 individuals received. I don't think there is any debate on that at this point. 23 I 24 think the staff generally feels that those things h appened and I believe the utility recognizes that some things happened. But bottom line again is that of the ones that
f
. . 236 l 1 have been reanalyzed to date, the significance of the ones
( 2 1 J th'at' ire reanalyzed have appeared to be minc
' ' - in the physical 3
hardware final end product. ( 4 5 Yesterday morning for the first time the staff learn ed of the three-page statement of Mr. Yin. During the last few 6 7 days and, in fact, what may have led to that in some way is 8 in fact we have polled the staff asking them, "Do you have any 9 questions, do you have any' concerns with where we are going up to this point in time?" The only member that came forth 10 was Mr. Yin. 11 12 Yesterday morning for the first time is where we 13 saw the three-page statement that was read yesterday. So where this leads us -- CHAIRMAN PALLADINO: Was that the first time you 15 16 heard about his concerns about large bore piping? MR. EISENHUT: Yes, it was. It may have actually 17 18 preceded it somewhat of a day or two in terms of the fact 19 that he was differing with the bottom line so-to-speak. There
, m were questions as far back as January about some large bore 21 piping. We, in fact, did a couple of sample calculations 22 and I will get to those if we want in just a minute.
23 To wrap it up though so-to-speak, what we would 24 propose is that first from a staff evaluation standpoint, we { need to complete the job. We haven't completed the job. We 25 are going to be going back out to the' plant next week. Mr. i e .
m 237' I Yin is going to be doing some continuing review work 2 . That is
) number one.
4 Number two is we have to complete our inspection report. 5 CHAIRMAN PALLADINO: 6 . You say complete the job. I 7 am not sure I understand. MR. EISENHUT: 8 In terms of inspections at the facility and at one of the PG&E's contractors. 9 So Mr. Yin 10 feels he has three or four days of work that has previously 11 been identified that has to be conducted yet, field work. COMMISSIONER ASSELSTINE: 12 Is that related to large bore, small bore or both? 13 MR. EISENHUT: I think it is a combination of the overall problem. i 15 I want to make sure that it is not broken out so specifically. 16 17 COMMISSIONER ASSELSTINE: All right. MR. EISENHUT: 18 That is the first item. The second
\
19 item is he would have to take time to complete his i nspection report. 20 - We have a partial draft inspection report but it is c 21 lear that it is preliminary findings and it is not completely together. 22 Third, 23 in fairness to the way we have been doing this effort, . 24 we have probably a month to a month and a half a go, we undertook to bring in inspectors from other regions . W e brought in an inspector from Region I, a supervisor from
m " 238 ' 1 Region I, 2 a supervisor from Reaion II and a supervisor from Region' III to assist in this effort. 3 4 We have proposed going through that process and finishing the review of that by this panel of superviso rs. 5 6 The fourth step we would propose is when that is complete, 7' we would propose taking this to the ACRS . Subcommittee , 8 You will recall that we just went to the ACRS Subcommit tee on a nubmer of allecations last month, I believe. 8 He would propose taking this product back there. 10 II Then we would propose, of course, bringing it to the Commission. 12 We hope to wrap that evaluation effort up 13 prior to coming down with any recommendation for full power . i i It is the staff's view though that the problems 14 principally have been identified. 15 There is 'no real debate on the technical issues, 16 g se, at this point in time albeit there are some differences in terms, I am sure, of some of I I8 the details and we are first learning of some of the deta il s at this point in time. IO 20 For small bore piping there is a program in place s 21 mall bore piping and the area around it was principally where t he issues have been brought up over the last 22 two or three months. That program is in place. 23 It is continuing. No p 24 hysical modifications have been the result of that evaluation to date. (l 25 So we would recommend going forth with the low power license. L
9 239 ' 22 g MR. KNIGHT: 2 I feel it necessary just to make sure
)
3 that the record is clear, Mr. Yin has been largely repor ti ng 4 to me in this effort and I certainly have been aware from 5 the onsight of his efforts that Isa was developing conc erns 6 related to starting with matters of training and documentation that we discussed at the meeting in San Francisco. 7 As a matter of fact, I 8 think it was a full airing l 8 of concerns up to that, I would believe since he was performing that effort, up to that point. O There has been , 11 dialogue between us as to what steps are appropriate before 12 full power and what steps are appropriate for five percent power. 13 ( l I have been taking. his input and synthesizing it with 14 15 , inputs from other people involved and my own experience na d
' judgment.
16 So I just wanted to be clear that this dialogue 17 has been going on throughout this process and I would 18 anticipate would continue throughout the process. There is, I 19 think, beyond question a focus now 20 on a significant philosophical difference as to how one 21 should approach such an assurance program or reverification program. That is something that I 22 think we need to work out. COMMISSIONER GILINSKY: 23 What are your thoughts on 24 , his observation that it is difficult to do the work once the i plant goes hot? l 25 MR. EISENHUT: I would like to comment on that if I 1 5
9r 240 1 could.
) COMMISSIONER GILINSKY: Sure.
3 MR. EISENHUT: I don' t really see it that way. 4 Historically in fact any plant, of course, that we have been 5 to that is an operating plant when it is actually operating 6 and operated for some time and of course it is not only a 7 temperature environment, but there is a radiation environment. 8 This plant though is a low power license. It is a very, 9 very minimal amount of actual exposure the core is going to see 10 and really no build-up of radioactive products. You go into 11 any confined enclosed containment with operating temperatures and pressures, of course, it is going to be not the best environment to be in. Some are worse than others. 14 However, for modifications you can'certainly after 15 you have conducted the low power testing program generally 16 you purge the containment, they can bring the plant down 17 and do any modifications that are necessary and you can bring 18 it back to essentially the same environment that you have at 19 this point. 20 The radioactive fission product should essentially 21 he no real significant contribution to that. If you have ever 22
, gone to any operating plant just in the southern half of the 23 United States in the summertime and gone inside the contain-24 ment, you can very easily know that it is well over 100 25 degrees inside the containment.
L 1, 4
7r-241 I p (Whereupon, at 11:45 o' clock a.m., Commissioner 2
)
Roberts exited the heariug room.) 3 COMMISSIONER GILINSKY: He was talking about the 4 need to suit up and so on. 5 MR. EISENHUT: 6 Again, you really don't expect a a 7 major -- 'ny amount of radioactivity after you conduct a low power testing program which is of a very short duration and 8 you can shut the plant down and you purge the containment. 9 In fact, 10 many plants actually purge the containment as wo have discussed on many, many occasions even during operation 11 and certainly during shutdown. 12 13 So we don't see that low power testing would preclude l 14 them from going in and doing any necessary moditications that might come out of this effort. , 15 MR. KNIGHT: 16 I think I would like to add just one
, other point, that 17 in a program such as we are viewing here 18 it would certainly be appropriate to set aside times for 19 inspections or for other work so that you have agreed upon 20 times when the plant will be in the best condition for that effort.
21 MR. EISENHUT: 22 I think that is correct and I think t hat can be accommodated very easily. 23 CHAIRMAN PALLNDINO: Any other points? 24 ( (No response.) 23 CHAIRMAN PALLADINO: If there are no other points, I s
m-O
- 1 242 1
25 was going to ca'll on GAP for three minutes. I COMMISSIONER GILINSKY: Before you do that, I have 3 one question. 4 COMMISSIONER ASSELSTINE: I have questions on this, 5 too.
- 6 COMMISSIONER GILINSKY: If you want to ask about tha t, 7
I had a question on another point. 8
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9 COMMISSIONER ASSELSTINE: All right. I had just a couple on this. 10 Darrell, the sense I got yesterday was that
. 11 particularly with respect to the large bore piping area although there has been some discussion of Mr.
12 Yin's concerns 13 and you can get that from reading the. transcript of the { previous meeting, that
. 14 there was some additional information l .
15 really that had come out of these most recent inspections 16 where the inspection reports weren't available yet and that 17 that was information that he thought was particularly signifi-cant. 18 i 19 I guess my question is what is the basis for and how can the staff reach the judgment that this isn't a concern 20 21 for low power operation until you have had a chance to look
, 22 at that information and to conduct the kind of review that i ,
I 23 think you and Harold were talking about doing yesterday? 24 I am trying to get a feel for what the basis is for saying,
.{ Yes, we can g'o ahead pA cularly in those areas where they s
~ eem to be new concerns that the staff had not focused on n
D
r -- T 243 i 26 1 2 specifically or certainly as much as they focused on the smal l s I bore piping concerns." 9 3 MR. KNIGHT: 4 I would like to start at least in response. 5 As I said yesterday, the issue of piping in aenera l 6 and small and large bore piping in particular is not in and of itself a new item or a new issue. As a matter of fact, one 7 t 8 of the items tha.t is on the list of holdovers on the IDVP is , in fact,. additional piping analysis. 9 That effort is directed at what is nominally large bore piping. 10 11
' There are two systems the staff picked because of 12
'their complexity and because of much of the same backgro und, I think, has given Mr.
13 . Yin concerns and that is problems that k 14 arose during the reverification analysis where there were in the ITR's identified errors if you will or misapplication of 15 specification factors, 16 some of the nitty gritties, in the analysis. 17 Based on that, 18 we required the utility to go back and take two systems that we picked because of their 19 complexity and do a complete analysis, piping and supports, 20 large bore pipe and supports. 21 We received that report in January. At about that time we were starting to heavily 22 23 commit our resources to allegation review so we did take the time to look at 24
- the report and review its conclusions which l 25 are that both of the systems picked in all aspects were satisfactory.
,. H 2
I
,t-244 27 g In my view and I think the view of some of the other s h(I of the staff, this is a significant step, a significant piece 3 of information that says we don't have some large scale 4 problem in the design of this piping. 5 ( COMMISSIONER ASSELSTINE: Now you have the 6 inspection that comes after that, am I right? MR. KNIGHT: The inspection largely relates to the 8 same information that was available to the staff. 9 10 COMMISSIONER ASSELSTINE: Prior to this reverifica-tion program? 11 MR. KNIGHT: Yes. If what is troubling you is the 12 remarks yesterday that Mr. Yin's report is new, part of my 13 j information is based on discussions with him this morning 14 ' and he may well want to talk about that. As I said, in my 15 view what you have here is a rather distinct philosophical 16 difference, one that says just looking at some systems, some 17 piping, and the fact that they turned out all right isn't or 18 may not be enough. That if you had problems in your program, 19 that is not enouch confidence. You need more somehow. That 20 ' is an area that really represents a standard that hasn't been 21 applied before. 22 COMMISSIONER ASSELSTINE: How do you respond to his 23 concern that 24 the problems that he found seem to slip through j a number of dif ferent reviews and 'I guess including the one 25 3 that is of particular concern to me,'the IDVP. I asked you
?
i a
9 T 245
;8 1
that yesterday before we talked about or before Mr Yin . 2 ~
- I talked about his concerns. I wonder if you want to take 3
another crack at that and respond to that. 4 MR. KNIGHT: 5 I don't believe that the record shows that the concerns slipped through the IDVP. 6 I think where . the IDVP looked at some of these areas, they saw some of the 7 same problems. 8 The difference is the conclusion one draws based on other elements of information. 9 Again the philosophical modus behind the IDVP 10 was to look at a sample, II to apply engineering jugment, to 12 make a bottom line judgment as to the quality and I use that word of the overall engineering effort, and with that 13 ' I4 perspective would one either conclude that there was bad 15 engineering and therefore an unacceptable system or generally good engineering and therefore an acceptable system. 16 COMMISSIONER ASSELSTINE: II The only other thing I was going to ask you was perhaps if Mr. 18 Yin wanted to make 19 a couple of brief rebuttal comments, if there was anything else that he wants to add at this point. I guess the part 20 21 that is still troubling to me is and maybe I just don't ha ve the chronology well in place, but 22 the concern I have is if these problems were still continuing now, we are still 23 24 finding these kinds of items of concern, why that is the case a
\
u nd should be sorted out at least in terms of their signifi-c ance before low power operation.
l
. o 246 29 1
MR. KMIGHT: 2 There certainly is still some sorting
}
out still to do. There is no question about that. Fundamen-3 tally we are saying that the information to the best of my 4 knowledge at this time that we have indicates that the basis 5 for our moving ahead, for acceptance of the IDVP and for 6 proceeding through the hearing is still there. I don't 7 belive that 8 there has been sufficient or substantive new information to say that that has chanced. There is reason 9 10 to look, but I don't think there is information to say that that has changed. 11 CHAIRMAN PALLADINO: Is more inspection needed? 12 Is that one of the contentions? 13 l MR. KNIGHT: I think the need for more inspection 14 is based on Mr. Yin being satisfied having been given this 15 assignment that he has to the best of his ability developed 16 17 all of the information necessary to fulfill his assignment. COMMISSIONER BERNTHAL: I must say that I share 18 Jim's concern and chagrin, I guess, that this issue was 19 raised in December. It was raised again in a meeting in M 1 1 January and the staff was specifically asked about it. It 21 I was raised again in February and while you explained to some 22 I
; 23 extent what was my principal question at the end of yesterday's seesion which was what in the world has been going on for the 24 last three and a half months, it just seems to me that it is 25 not very satisfactory for us to come to this point with a u
1 > 1 II 1 e
\ .
N 247 ' fundamental difference in engineering judgment. My preference 2
)
would be if that can be worked efficiently and I appreciate 3 the third-party review you have suggested there, that I 4 thought that one of our reasons for having the ACRS was 5 in such cases perhaps that they would serve as a third-party 6 expert outside opinion group who would give us their 7 engineering judgment on what clearly appears to be a differenc e 8 in engineering judgment here. 9 CHAIRMAN PALLADINO: Is there a difference? I 10 gather there is going to be the continued inspection. There 11 is going to be the analysis and I presume the analysis would 12 be such tha,t it would satisfy peer review and then decisions 13 on what changes if any need to be made to the hardware. Is 14 that not the plan of action? , 15 MR. EISENHUT: I think you are correct. In fact, 16 as Commissioner Bernthal said, certainly we don't like to see 17 in a situation on any issue on any plant where we get to the 18 point where ultimately in the final analysis we don't have a 19 collegial concensus. In some cases that does not happen. 20 In some cases it evolves up to the very late in the exercise 21 before we even realize or anyone comes forth and says they 22 I have a basic concern with the bottom line. 23 24 Believe me, it is a situation that we certainly don't like to be in. We have another one where I called off 25 o r proposed to call off a Commission meeting because i
g
. a 248 i 1
2 at sort of the eleventh hour we had a different opinion even 3 though all through the line through the process we ha d the 4 formal concurrences and didn't~ realize there was this situation 5 developed to within a week of the Commission meeting. I think on a more generic subject, 6 the answer would 7 have been let's go back home and reevaluate some more at but 8 the same time when ycu are ta1 king about a plant
, , you at the 9 same time have to -- it is a collegial process just as the 10 Commission is and from time to time one element isn't as happy as other elements.
11 COMMISSIONER GILINSKY: 12 I don't think Fred is saying that everybody has to agree. 13 As I understood it, he was addressing more the fact that the disagreement should hav e been addressed earlier. 15 MR. CASE: 16 You can't know, Commissioner Bernthal, 17 until you vote whether you and Commissioner Gilinsky are going to agree. l 18 That is 1 the situation you have here. ! 19 I I don't want sa criticized or Jim. They tried to work together as best
'20 t
l 21 hey could and eventually they disagreed and there i w rong with that but s nothing 22 they did make the effort to work together . COMMISSIONER BERNTHAL: 23 I understand. CHAIRMAN PALLADINO: 24 What did they disagree on? MR. EISENHUT: L M Principally not on technical issues. I think that is the key.
- - The record clearly speaks out that e ' , , , , - -
e 4 o 249 N l 2 the staff has technical reservations. It is a matter then t 3 of what do you do with those and how you paint those i technical questions. ; 4 In one person's mind they are more severe than the other and on one hand, 5 someone who has been 6 evaluating it with dozens of diffdrent evaluations for the 7 last 15 years, Jim has to factor that in the back of his mind. You come to an integrated judgment. 8 COMMISSIONER BERNTHAL: 9 Maybe if Isa could address 10 the question without having a back and forth here of a t 11 least as it has been portrayed today and yesterday ofwhether in your judgment the question primarily is one 12 of the timing i of the hardware fixes and not one of technical disagreement 1 over what needs to be done. 14
- COMMISSIONER ASSELSTINE:
15 Or is it the significance of the technical issue. MR. YIN: 17 I would like to address that but before I go into that, let me just clear the air a little bit.
& 18 i; E arlier Darrell kind of characterized by input to th e i 3 t 19
?
- s ';
i? 20 Commissioner's as a kind of surprise but it is reall y far from i{ the truth. 5 21 I was only asked to prepare the statements on 1 Friday.
$. 22 So I worked all day Saturday and Sunday. As a h
a matter of fact, W: 23 I even asked my wife to type it up because p, n o secretary was available. 24 di b 25 So it is a short iteration of asking that informa { tion that caused the element of surprise. As a ma.tter of fact, h i d
Y' m - 250 I have been providing the inspection inputs, January, 2 February and March. So every time I have inspection 3 problem findings, I always communicate in a timely manner 4 with Mr. Jim Knight and it was kind of surprising, there was no discussion at all. So it is not my fault not to h/ 6 communicate. I think it was lack of discussion from the 7 management reaarding my findings is probably the cause of the 8 surprise element. 9 Besides that, as far as technical problems we do 10 have some substantial philosophical differences as Mr. Knight 11 has addressed it. Basically if I have reviewed the IDVP so-12 ~ called sampling program, they were about 15,000 feet of small 13 i pipe which amounts to about 35 percent of the small bore 14 piping population and it includes something like 1,500 15 supports and it amounts to about 40 percent of the total 16 population of small bore supports that has not been 17 evaluated in any form or shape. 18 l So if you look at the basis for accepting those 19 nonevaluated systems, when I reviewed the ITR, the independent 20 - design verification report, it was stated that the original 21 design criteria is based on the Blume curve. 22 The Blume curve has been widely used by the industry 23 in the past but a problem with using the Blume curve, there I was no assurance on uniformity on how to apply it because 25 there was inadequate procedure on how to apply the. usage of
'i
O ' 251 t 1 i those criteria.
' 2 So it is very hard for me to visualize
\}
$ when you pick maybe 100 or 200 feet of pipe and say that 3
4 it is all right and assume the rest of it is correct , just as if you are inspecting some of the cars. 5 You check three 6 Chrysler products and you check one Ford Motor and you assume all GM's are okay, also. 7 So it is that kind of a situation 8 that we have philosophical difficulties involved . Furthermore, 9 if you look the large bore evaluation, 10 the Westinghouse calculation was not covered in the IDVP . I 11 guess the assumption is that Westinghouse knows what they are doing. 12 To the contrary, we have inspection findings involving 13 hardware, i,nvolving procedure, even involving the computer 14 input problems that were identified in the past so it was to 15 my belief that the Westinghouse calculation has never been reviewed. 16 Furthermore, 17 if you review the IDVP on the large i bore support and piping analysis, they are full of 18 deficiencies and pages and pages of deficiencies 19 . How can we 20 assure that the rest of it would not have the same problem
; is questionable.
21 i
' 22 Basically the philosophical difference between myself a nd the management 23 is to me the definition really on the licensee criteria.
24 The management's belief is you sharpen your p y I 2 encil and 'ou do a rigorous calculation and you still meet the cold requirements that is acceptable. But to me, the e, ~
r
-l 252 5 :
1
, licensee criteria.really extended to the fact whether or not ! \ 2 you can handle the original' calculation in accordance with 3
the QA program procedural requirement. If you are not doing 4 that even in the final analysis showing the support of piping 5 meets the requirement, doesn't really give me the confidence 6 to insure the rest of the piping and the supports are luckily 7 also meeting the requirements. 8 It is just like a table. If you say you have four 9 . legs of the table and you find that there is one weak leg and 10 say the table is not going to collapse. I am not too sure. 11 If all four legs are weak, whether or not if you shake the 12 table hard enough, if it will not collapse. So this is the i 13 kind of situation we may be facing. 14 However extensive the problem, I have not really 15 concluded yet. I am still in the process of trying to get 16 to the bottom of it. 17 Another factor that caused me concern in the large 18 bore piping area is the fact that contrary to our belief 19 that it is all handled by'Bechtel, it is in fact handled not
; 20 only by Bechtel but it is also handled by Cygna, it is 21 handled by.Impell. Impell is the old OEDS and also be 22 Bechtel themselves.
23 But there is no indication that there has been { 24 any consideration of the evaluation in proportion to that 25 there are many jobs assigned, many systems assigned and there rw
;6 . l
e o 253 36 I was no consideration, for instance, if the Cygna did 30 2 percent of the work, 8 at least the sample size should reflect in proportion to the work assignments that they had received. 4 So if we go through that, there is really a lot of questions that I need to look into. At this particular time, it is 6 kind of premature to -- it is questionable, but I am not 7 ready to draw the conclusion but I have discussed this problem 8 with the management so everything I talk about has been 9 discussed with our people. 10 CHAIRMAN PALLADINO: Isa, it still comes down at 11 least in my understanding to whether we are talking about 12 possible improvements that have to be made before you go to 10 low power versus making them after they go low power. Is that 14 still the issue in your mind?
- 15 I agree that you have to get to a technical resolution of the issues but after you have 16 reached'that point as Harold put it yesterday, it came down 17
- to when do you make whatever modifications turn out to be i
18 t necessary. 19 20 COMMISSIONER ASSELSTINE: Or is it the question of 3 the extent to which we now understand the problem. Do we a s 21 u nderstand it enough to make the decision on low power s 22 operation? 1 i '. ; 23 MR. YIN: That
'24 is the whole problem here because w
e don't know exactly what the magnitude of the problem is
. 25
, a nd also I recognize I am only involved in a very restricted A
i j i , :;
F , 4 0 254 I aras, I am just providing the input for your consideration and decision. I cannot really in any way second quess the 3 overall consideration. 4 COMMISSIONER GILINSKY: Yesterday you said that 5 6 it would take many months to get this straightened out, as I recall. 7 8 MR. YIN: Based on my experience in Region III of similar problems, it takes about that much time. It takes 9 much less time but this problem seems to be greater than what 10 I ever experienced. So I extended it to just three or four 11 12 months just in case I encounter any possible difficulties. CHAIRMAN PALLADINO: Isa, Harold Denton did say g 13 14 that in his mind in the end it came down to a question of when you made whatever hardware changes turn out to be 15 - necessary. Do you agree that that is the essence of the 16 pr oblem or is it different from that? 17 MR. YIN: Based on my experience as far as the small 18 19 bore is concerned, probably very little or no changes 4 23 because the criteria and everything is quite conservative. 21 But I cannot really second guess anything on the large bore i _ because of the loading and the severe condition that we 22 encountered. On the large bore, I have no idea what is i 23 going to be the outcome but for small bore, I would think 24 it would probably be minimum design changes. 25
; CHAIRMAN PALLADINO: And on the large bore, you don't
?
3 N* b-
r
., o 255 I ; know?
I ( 2 MR. YIN: Yes, large bore, I don't know. 3 COMMISSIONER BERNTHAL: So you are saying on 4 Commissioner Asselstine's point that you feel that you ; 5 I understand the small bore problem sufficiently that you 6 would agree with the characterization that has been made 7 that it is more of a question of timing difficulty of making
~
8 the fixes rather than questions of technical judgment on 8 what needs to be done? In the case of the large bore, you 10 are saying that you are not so confident. MR. YIN: It is a different ballgame. 4 COMMISSIONER BERNTHAL: Yes. I CHAIRMAN PALLADINO: I still expect that on the 14 technical issues, you and the rest of the staff will continue 15 to work to try to get an acceptable resolution. 16 MR. YIN: Yes. I intend to work. I COMMISSIONER ASSELSTINE: Let me go back to if I i could briefly, the question that Commissioner Gilinsky raised. 19 You mentioned yesterday a period of several months. I gather 20 that was not only to do the analysis, the evaluation, to 21 understand the significance of the problem but also then to 22 decide what corrections need to be made and to make the 23 changes. If you were focussing on the large bore piping { i question alone, would it be possible with any briefer period 25 of time than that to do the remaining inspections and to do an 1 . l
1 ( , = l 256 I I 2 evaluation to conclude or to reach a judgment in yourview 3 on the significance of the problem and, if so, about how I t 4 long do you think it would take to do something lik e that? MR. YIN: t 5 My estimate of six to nine months already included large bore. 6 As a matter of fact, it may be proportionately less for the small bore 7 . It would be 8 a lot more involved in the large bore. 9 COMMISSIONER ASSELSTINE: All right. CHAIRMAN PALLADINO: Any other questions? 10 COMMISSIONER GILINSKY: 11 I had a question I wanted to 12 ask on another subject if you are finished with that 13 COMMISSIONER ASSELSTINE: Yes. COMMISSIONER GILINSKY: 14 I remember some' time ago that Jack, you were telling us, I think, about the 15 16 electrical contractor's documents and there was some question 17 about whether they had been secured or turned over o PG&E t or audited by NRC. 18 Do you remember that?
,, It was a con'dition
- 19 or a statement in one of our SER's that said that as this w
, 3) to be straighted out before criticality .
,, 21 Can you deal with that?
1
' MR. MARTIN: Yes.
That was the Foley document 22 r i n eview where we had numerous alleaations a lleger from an ano nomous and spent 24 a lot of time looking at the H. P. Foley
- i do 1
cument control and found some problems.
-y 23 Some things needed j 4 to be straighted out.
- JA There was the caper of the documents in ML in 1." P
+-
\
- - - , , - ,,w--m,--,,-----,r-,,----.---,-------ww-----, ,w,_ - - -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power ) Plant, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 6th day of April, 1984, I have served copies of the foregoing JOINT INTERVENORS' SUPPLEMENT TO MOTION TO AUGMENT OR, IN THE ALTERNATIVE, TO REOPEN THE RECORD, l l mailing them through the U.S. mails, first class, postage prepaid, to the attached list. b66/iWi ACfm CHRISTINA CONCEPCION i
y-I
. .. o SERVICE LIST Nunzio Palladino, Chairman James Asselstine, Commissioner U.S. Nucler' Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Victor Gilinsky, Commissioner Frederick Bernthal, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Thomas Roberts, Commissioner Samuel J. Chilk, Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
- Thomas S. Moore, Chairman *Dr. W. Reed Johnson Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S.. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission '
Washington, D.C. 20555 Washington, D.C. 20555
*Dr. John H. Buck
- Docket and Service Branch
. Atomic Safety & Licensing Office of the Secretary Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Lawrence Chandler, Esq.
Office of the Executive Legal Director - BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 David S. Fleischaker, Esq. Post Office Box 1178 Oklahoma City, OK 73101 Bruce Norton, Esq. Norton, Burke, Berry & French P.O. Box 10569 Phoenix, AZ 85016 Malcolm H. Furbush, Esq. Vice President & General Counsel Philip A. Crane, Esq. Pacific Gas and Electric Company Post Office Box 7442 San Francisco, CA 94120
I John Van de'Kamp, Attorney General Andrea Sheridan Ordin, Chief Attorney General Michael J. Strumwasser, Special Counsel to the Attorney General Office of the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, CA 90010 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue Suite'K San Jose, CA 95125
' Virginia and Gordon Bruno Pecho Ranch Post Office Box 6289 Los Osos, CA 93402 Sandra and Gordon Silver 1760 Alisal Street San Luis Obispo, CA 93401 <
Carl Neibugger Telegram Tribune Post Office Box 112 San Luis Obispo, CA 93402 Tom Devine
' Government Accountability Project 1901 Que Street, N.W.
Washington, D.C. 20009 Eric Havian, Esq. l Heller, Ehrman, White & McAuliffe i 44 Montgomery. Street., 31st Floor San Francisco,.CA 94133 -
- By Express Mail
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