ML20081J790

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Opposes Joint Intervenors 831104 Request for Stay to Delay Vote on Restoration of Low Power Testing License.Info Relied on by Joint Intervenors Available Almost 5 Months Ago & Represents No Significant QA Program Deficiency
ML20081J790
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/08/1983
From: Locke R
PACIFIC GAS & ELECTRIC CO.
To: Gilinsky V, Palladino N, Roberts T
NRC COMMISSION (OCM)
References
NUDOCS 8311090119
Download: ML20081J790 (3)


Text

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DOCKETED USNR0 PACIFIC G- A S AND E LE C T RI C C O M PANY hC"W3 l WASHINGTON. D C. OFFICE

  • 1050 17TH STREET. N.W. 2 6-E 2 - 80 CFFICE OF SEEPini 00ChEitNG & SEPhfi.

November 8, 1983 BRANCH Nunzio Palladino, Chairman Victor Gilinsky, Commissioner Thomas Roberts, Commissioner James Asselstine, Commissioner Frederick Bernthal, Commissioner United States Nuclear Regulatory Commission Washington, D.C. 20555 Re: In the Matter of Pacific Gas & Electric Company (Diablo Canyon Nuclear Power Plant, Units No. 1 and 2), Docket Nos.

50-275, 50-323.

Dear Chairman Palladino and Members of the Commission:

By letter dated November 4, 1983 the Joint Intervenors have filed yet another eleventh hour submission with this Commission obviously designed to influence or delay a vote on the restoration of the low power testing license for Diablo Canyon.

In this latest filing the Joint Intervenors have thrust upon the Commission two documents which in their opinion contain "new l

information" outlining deficiencies in the current PGandE Quality Program. However, they pointedly fail to apprise the Commission that the two documents were produced by PGandE for Joint Intervenors, Governor Deukmejian and the NRC Staff in response to a document discovery request on June 10, 1983--almost five months ago. Instead the letter conveys the impression that the information has just come to their attention.

Turning now to the documents, we would note that they are reviews of certain PGandE QA manuals and implementing procedures contracted to separate companies by PGandE management as part of its continuing effort to review and evaluate its Quality Assurance Program. These reviews were intended to be used as a basis for further improving PGsandE's quality programs. To anyone familiar with the consulting business in general and quality assurance matters in particular, the fact that these reviews contain some 8311090119 831100 - -

PDR ADOCK 05000275 PDR g

GENERAL OFFICE

  • 415 781-4211

U.S. Nuclear Regulatory Commission November 8, 1983 Page Two

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recommendations for improving the program should not come as a surprise. What is distressing, although not unexpected, is the Joint Intervenors' partisan insinuation that these reviews represent significant and continuing deficiencies in PGandE's quality program. Equally distressing is the accusation that PGandE has been less than candid with the Commission with regard to these reviews.

Simply stated, PGandE has considered these reviews as opinions and recommendations of third parties to be evaluated as part of an overall continuing assessment of our QA Program. Taken out of context, as Joint Intervenors have done, the material presents an erroneous and misleading impression. Instead, we have assessed these reviews in the broader context of the overall program. We do not agree with all of the so called " finding reports" and recommendations. We have, however, retained one of the companies, Project Assistance Corporation (" PAC") to provide staff support to PGandE in revising the PGand E QA manual and implementing procedures to improve their clarity and tc remove any remaining ambiguities.

We have also submitted an FSAR amendment regarding our Quality Assurance Program which changes the QA line of reporting. 1/ These actions, contrary to Joint Intervenors November 4 letter, demonstrate PGandE commitment to continually review and, where necessary, further improve the effectiveness of our quality program. Furthermore, we are confide'nt that our current Quality Assurance Program and implementing procedures are in conformance with the requirements of 10 CFR Part 50, Appendix B. 2/

Since we have fulfilled the requirements of the Commission order and Staff Letter for Steps 1 and 2 of the Commission's licensing process, we believe that the Commission should restore our license to load fuel and perform low power testing at the earliest possible time.

-1/ This amendment provides for the Manager of QA to report to the Executive Vice President for Facilities and Electric Resources Development rather than the Vice President for Nuclear Power Generation.

-2/ The ITR's and Final Report of the IDVP and the NRC Staff SSERS 18 and 19 further document the quality and adequacy of the verification work by the joint

- PGandE/Bechtel Diablo Canyon Project.

U.S. Nuclear Regulatory Commission November 8, 1983 Page Three As for Joint Intervenors request for a stay, we believe that is premature and not in conformance with the Commission's regulations (10 CFR 2.788). The Appeal Board has not denied Joint Intervenors' Request for a stay. Rather it ruled that the request was premature and that the Board stood ready to act expeditiously on the request depending upon the action the Commission takes on November 8, 1983.

3/

3/ Reopened Design Hearing Transcript AD-1081 Very truly yours, Malcolm H. Furbush Philip A. Crane, Jr.

Richard F. Locke Pacific Gas and Electric Co.

4 Bruce Norton Norton, Burk, Berry and French Arthur C. Gehr Snell and Wilmer Attorneys for Pacific Gas and Electric Company By: -/v /-~ _

_ Richard F. Locke cc: Service List Honorable Morris Udall Honorable Leon Panetta