ML20024C381

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Suppl to Joint Intervenors 830510 Motion to Reopen Record on Const Qa.Documents Submitted Are PNO-V-83-022A,notice of Violation & IE Insp Rept 50-275/83-20.Certificate of Svc Encl
ML20024C381
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 07/06/1983
From: Reynolds J
CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
ISSUANCES-OL, NUDOCS 8307120571
Download: ML20024C381 (4)


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NUCLEAR REGULATORY COMMISSION (. E, & N.

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BEFORETHEATOMICSAFETYANDLICENSINGAPPEALBOARD((gg/

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In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

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SUPPLEMENT TO JOINT INTERVENORS' MOTION TO REOPEN THE RECORD ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE Pursuant to the June 28, 1983 Order of this Appeal Board, the Joint Intervenors hereby submit two documents as a supplement to their May 10, 1983 Motion to Reopen the Record on the Issue of Construction Quality Assurance. The first is a June 23, 1983 Preliminary Notification -- PNO-V-83-22A -- which describes the discovery at Diablo Canyon that reactor coolant system piping in areas of ten welds may be less than the minimum wall thickness specified by code. The second is a Notice of Violation Concerning Reporting Requirements for Diablo Canyon, issued by the NRC to PGandE on June 24, 1983, based on PGandE's failure to report the discovery of minimum wall thickness violations within the 24-hour period prescribed by the Technical Specifications. Instead, PGandE waited almost five months to notify the NRC of the discovery.

Because both documents relate to the matter of construction quality assurance, they are plainly relevant to the 8307120571 830706 PDR ADOCK 05000275 3$3

I motions set for hearing in this proceeding on July 19, 1983.

The Joint Intervenors intend to rely on the attached documents as further evidence that PGandE has failed to establish and implement an adequate construction quality assurance program that complies with regulatory. requirements.

DATED: July 6, 1983 Respectfully submitted, JOEL R. REYNOLDS, ESQ.

JOHN R. PHILLIPS, ESQ.

ERIC HAVIAN, ESQ.

KENNETH GOLDENBERG, 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 O

By s L R. R2 LDS Attorneys for Joint Inter-venors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC. .

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER u a

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....m.

.,q_..,.,.. m l This preliminary notificaticn constitutes EARLY notice of events of POSSIBLE safety or public

' interest significanc2. Th2 infonnation is as initie.lly rcceived without v::rification or evaluation and is basically all that is known by IE staff on this date.

FACILITY: Pacific Gas & Electric Company Diablo Canyon Unit No. 1

  • Notification of Unusual Event e ui bb ounty, California Alert Site Area Emergency

SUBJECT:

POTENTIAL VIOLATION OF MINIMUM WALL THICKNESS

. ON REACTOR COOLANT SYSTEM PIPING General Emergency . ,

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X Not Applicable ..,"3' 29 .

On June 22, 1983, licensee personnel determined that the RCS piping in areas of welds .

Other than reported on May 10, 1983 may be less than the minimum wall thickness specified by code. A total of ten welds in cold leg, hot leg, and cross over (between steam generator and reactor coolant pump) piping appear to be less than required minimum wall thickness.

The condition was discovered while performing additional ultrasonic examinations at each 45 degree increments around the welds. The tests were to be used to improve the quality of the base-line preservice examination. The-licensee identified the additional problems after determining that incorrect minimum wall thickness criteria had been applied to the hot legs and cross over piping. All four RCS loops are involved. The reduction in wall thickness appears to have occurred during the original preservice examination (1975-76) when welds were ground smooth to remove the potential for irre' vant indications when performing ultrasonic and/or radiographic examinations. The 1 .asee plans to take additional thickness measurements at 3-inch circumferential ops around the weld: to termine if any other minimum wall thickness conditions exiat.

He9i on V will closely follow this situation. -

Media interest is not. expected. _Neither the -licensee nor the NRC plans to issue a news release at this time. Region V (San Francisco) received. notification of this occurrence from the Resident Inspectors at about 11:00 a.m. on June 23, 1983. This information is current as of 2:00 p.m. on. June 23, 1983._

CONTACT: D. F. Kirsch 463-3723 DISTRIBUTION:

H St. 4M MNBB (!)$ PhillipsM[E/Wf,)D Willste 1)30 Air Rights 4:32. Mail:

Chairman Paliadino NRR IE NMSS ADM:DMB Comm. Gilinsky ED0T!pII PA OIA RES DOT: Trans

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...an. Asselstine Regions: W.II SECY '

i INPO / N5AC / I ACRS  ! O Licensee: l CA REGION V: FORM 211 i (Reactor Licensees)

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Resident Inspector (revised 3/14/83)?

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[@ Mhg'#o UNITED STATES E j 3 ;.. ( , NUCLEAR REGULATORY COMMISSION

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Mi41983 Docket No: 50-275 l MEMORANDUM FOR: Chaiman Palladino warnWiirniFr GilFnny Comissioner Ahearne Comissioner Roberts Comissioner Asselstine FROM: Darrell G. Eisenhut, Director Division of Licensing l Office of Nuclear Reactor Regulation

SUBJECT:

NOTICE OF VIOLATION CONCE WING REPORTING REQUIREMENTS FOR DIABLO vJ1 YON (Board Notification No. 83-83)

According to the procedures for Board Notification, the enclosed information is being transmitted directly to the Comission. The Boards and Parties are being notified by copy of this memorandum.

This information concerns a violation of NRC reporting requirements. The subject of the notice of violation was previously reported to you and was the subject of Board Notification 83-72.

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Darrell

\ EI;s)e)nhut,

' . Ii a-U.'Director Division of Licensing Office of Nuclear Reactor Regulation

Enclosure:

As Stated cc w/ encl: '

See Next Page 8305110492

Contact:

B. Buckley, NRR Ext. 28279 a m_

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-2 cc: w/ encl: l J. F. Wolf, ASLB G. O. Bright, ASLB J. Kline, ASLB -

T. S. Moore, ASLAB .-

W. R. Johnson, ASLAB /

J. H. Buck, ASLAB ,/ ,

SECY /

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OPE EDO Parties to Proceeding k

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DISTRIBUTION LIST FOR BOARD NOTIFICATION Diablo Canyon Units 1&2 Docket Nos. 50-275/323 OL" ACRS Members Ms. Elizabeth Apfelberg Dr. Robert C. Axtmann Mr. Richard E. Blankenburg Mr. Myer Bender Mr. Glenn 0. Bright Dr. Max W. Carbon Mr. Herbert H. Brown Mr. Jesse C.' Ebersole Dr. John H. Buck Mr. Harold Etherington Philip A. Crane, Jr. , Esq. Dr. William Xerr au. - u .a .u x t David S. Fleischaker, Esq. Dr. J. Carson Mark Mrs. Raye Fleming Mr. William M. Mathis

- Arthur .C. Gehr, Esq. Dr. Dade W. Moeller Mr. Mark Gottlieb Dr. David Okrent Mr. Thomas H. Harris Dr. Milton S. Plesset Mr. Richard B. Hubbard Mr. Jeremiah J. Ray Dr. W. Reed Johnson Dr. Paul C. Shewmon Janice E. Kerr, Esq. Dr. Chester P. Siess Dr. Jerry Kline Mr. David A. Ward Mr. John Marrs Thomas S. Moore, Esq.

Bruce Norton, Esq.

Joel R. Reynolds, Esq.

Mr. Janes 0. Schuyler Mr. Gordon Silver Michael J. Strumwasser, Esq.

Paul C. Valentine, Esq.

Harry M. Willis John F. Wolf, Esq Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Panel Mr.. Malcolm H. Furbush 1 Resident Inspector /Diablo Canyon NPS Dr. William E. Cooper Mr. W. C. Gangloff Mr. Owen H. Davis Dr. Jose Roesset l

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[enco %, e UMTED STATES

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g 7"*Y,[ p 145o MARIA LANE.SutTE 210 WALNUT CREEK, CALIFORNIA 94996 JUN 17 583 Docket No. 50-275 Pacific Gas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Attention: Mr. J. O. Schuyler, Vice President Nuclear Power Generation Gentlemen:

Subject:

NRC Inspection of Diablo Canyon Unit No. 1 Th:.s refers to the routine inspection, conducted by Messrs. G. H. Hernandez and M. M. Mendenca of this office on May 23-June 6, 1983, of activities authorized by NRC License No. DPR-76 and to the discussion of our findings

- with Mr. R. C. Thornberry and other members of the Pacific Gas and Electric Coepany staff at the conclusion of the inspection.

Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations o-! procedures and representative records, interviews with personnel, and observations by the inspectors.

Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.

Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of "#alation.

In accordance vi.h 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Docu=ent Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

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Pacific Gas and Electric Company 2 g

Should you have any questions concerning this inspection, we will be glad to l discuss thers with you.

The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as requued by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, g T. W. Bishop, Chief Reactor Project Branch No. 2

Enclosures:

A. Notice of Violation

3. Inspection Report Nos. 50-275/83-20 cc w/ enclosure:

G. A. Manestis , PG&E P. A. Crane, PG&E

  • S. D. Skidmore, PG&E R. C. Thornberry, PG&E (Diablo Canyon)

R. D. Et ler, PG&E (Diablo Canyon)

I I

i APPENDIX _A NOTICE OF VIOLATION Pacific Gas and Electric Company Docket No. 50-275 l P. O. Box 7442 Licensee No. DPR-76 -

l San Francisco, California 94120 l

As a result of the inspection conducted on May 23 . Tune 3,1983, and in accordance with NRC Enforcement Policy, 10 CTR Part 2, Appendix C, the following violation was identified:

Technical Specification 6.9.1.11 states, in part, Inat Ine urvnan3I.I OCCURRENCES of Specifications 6.9.1.12 and 6.9.1.13 helow, including corrective actions and measures to prevent recurrence, shall be reported to the NRC..."

Technical Specification 6.9.1.12 lists the types of events which shall be reported by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Director of the Regional Office, or his designate, and confirmed by telegram, mailgram or facsimile no later than the first working day following the event, with a written followup report within 14 days.

Technical Specifiestion 6.9.1.12.1 describes a type of event which shall be reported pursuant to Technical Specification 6.9.1.12 and states as follows:

" Performance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the safety analysis report or Technical Specifications bases; or discovery during unit life of -

conditions not specifically considered in the safety analysis report or Technical Specifications that require remedial action or corrective seasures to prevent the existence or development of an unsafe condition."

Contrary to the above requirements, on December 17, 1982 the licensee identified that certain areas of Veld No. WI3-RC-2-17 were less than the ninimum wal'. thickness specified by design and the applicable codes. Veld No. WLB-RC-2-17 is in Loop No. 2 of the Reactor Coolant System. This I condition was not reported to the NRC until May 10, 1983.

This is a Severity Level IV Violation (Supplement I).

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2 Purusaut to the provisions of 10 CFR 2.201, Pscific Gas and Electric Company is hereby required to substL to this office within thirty days of the date of this notice, a written statement or explanation in reply, including: (1) the correctzve steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause

! shown.

JUN 1 7 1983 Date

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U. S. NUCLT.AR REGULATORY COMMISSION REGION V Report Nos. 50-27!/83-20 Docket Nos. 50-275 License No. DPR-76 i Licensce: Pacific Gas and Electric Company 77 Beale Street. Room 1435 San Francisco. California 94106 Facility Name: Diablo Canven Unit No. 1 Inspection at: Diablo Canven Site, San Luis Obisco County, California Inspection conducted: May 23-June 6. 1983 Inspectors: _ #M M M S !/7 G. H. Hernand#1, Reactor Inspector ' Dared

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- . . Mendonca, Resident Inspector ~/ Dated' Approved by: 1

/ /h /$I Mk' D5-ef'KirsEh, Chief, Reactor Projects / Dated Section No. 3 Summa ry:

Inspection,during the period of May 23-June 6. 1983 (Report No. 50-275/83-20 Areas Iasteeted: Unannounced inspection by a regional and resident inspecter of actions related to recent licensee identified items including indications of less than minimum wall thickness in certain areas of a Reactor Coolant Piping Loop weld; a leaking shop weld in the Component Cooling Water System; repair activities related to gouge and grinding marks in one area of Reactor Coolant piping. Loop No. 1-3; and resolution of Unit 1 Reactor Vessel preservice inspection indications.

The inspection involved 67 inspection-hours by two KRC inspectors.

Results: Of the areas examined, one item of noncompliance was identified in the fatlure of the licensee to promptly notify the NRC of a potentially reportable condition in accordance with the technical specifications (paragraph 5).

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  • - . .. , j DETAILS
1. Individuals Contacted
a. Pacific Cas and Electric Ccmoany (PG&E)
  • W. A. Raymond, Assistant Manager for Nuclear Plant Operations

+*R. C. Thornberry, Plant Manager

+*R. Patterson, Plant Superintendent

  • R. D. Eztler, Project Superintendent, General Construction

+*W. B. Kaefer, Technical Assistant to Plant Manager

a . n. sexton, supermor ex vpumuw=

  • D. B. Miklush, Supervisor of Maintenance
  • J. V. Boots, Supervisor of Chemistry and Radiation Protection
  • R. G. Tadaro, Security Supervisor

+eR. T. Twiddy, Supervisor of Quality Assurance

  • D. R. Bell, Quality Control Engineer, General Construction
  • J. M. Giscion, Power Plant Engineer
  • E. M. Conway, Personnel and General Services Supervisor
  • M. N. Norem, Lead Startup Engineer
  • R. M. Luckett, Regulatory Compliance Engineer T. D. Smi th, Senior Quality Control Engineer D. A. Gonzales, Quality Control Inspector
b. Bechtel Corporation (Bechtel)

+*J. W. Shryock, Site Completion Manager D. O. Henery, NDE Level III Engineer

c. Pullman Power Products Corporation (Pullman)

H. W. Karner, Quality Assurance / Quality Control Manager

+ Denotes personnel attending the exit management meeting of May 27, 1983.

  • Denotes personnei attending the exit management meeting of June 3,'

1983.

2. Licensee Action on Previous Inspection Findings (Open) Followup Item (50-275/83-17/05): Degradation of the Reactor Coolant System Pressure Boundary On May 3,1983, the licensee submitted LER No.83-004 concerning the I discovery of gouges and marks in the reactor coolant system piping. The marks and gouge were discovered on the discharge side of the No. 3 Reactor Coolant Pump. Of the four blemishes discovered the most severe is I a gouge approximately 0.150 inches deep by 2.0 inches long and 0.150 inches I wide. The licensee has completed an ASME Section XI repair plan which has been submitted to their engineering department for review and i

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2 approval. The licensee has determined that the gouges can be renoved by grinding and blending without violation of minimum pipe wall thickness criteria.

The licensee's repair and inspection activities on this item will be examined during future inspections.

No items of noncompliance or deviations were identified. ,

l 3. Unit 1 Preservice Inspection (Baseline)

The Vestinghouse Preservice Inspection summary for Unit 1 is currently 1 under review by the licensee. Discussions with licensee personnel I determined that the ~four indicitions requiring evalua~ tion ' nave ~been resolved. The four indications are located on the base material <

spproximately four and one-half inches below the centerline of the l flange-to-upper shell weld at vessel azimuths of approximately 25",115*, '

205' and 295*. Evaluation of the indications suggest that they are the result of handling lugs which may have been attached during vessel manufacture.

No items of noncompliance or deviations were identified.

a. Comoonent Cooline Water Veld Discrepanev On May 23, 1983 the licensee submitted LER No.83-007 concerning a
  • discrepancy in a shop weld in the Component Cooling Water System.

Licensee personnel observed that in the process of welding a reinforcement pad on a branch connection to the non-vital loop C of the Component Cooling Vater System, water began leaking from the weld area.

The discrepancy was determined to be a f2sw in the root pass of the shop weld joining the branch connection to the header. The licensee indicated that repairs will be made using an approved ASME Section XI repair program. In the interim the branch connection has been cut out and sent to a materials laboratory to determine the failure mechanica.

As indicated in LIR No.83-007, the initial ultrasonic examination of the dicerepant veld and ten other similar welds indicated that the code required full penetration welds may not have been made. However, when the branch connection with the discrepant weld was cut out, a full penetration weld was found. The presence of the full penetration weld raises questions regarding the applicability of this type of NDE method for this weld con:iguration. Examination of the weld detail for the

! discrepant veld determined that the weld detail did not clearly specify l what type of weld was required. Based on these findings the inspector considers that a document review of other similiar type branch connection weld packages would assure that the welds complied with code requirements. In addition, the inconclusive results of the ultrasenic examination on the ten similiar type welds indicates that this type of acndestructive examination would not provide credible results.

The above expressed concerns sad the licensee's repair program and inspection activities will be examined during a future inspection.

(50-275/83-20/01)

3 I

5. Violation of Minimum Wall Thickness on Reactor Coolant System Pioing On May 23, 1983, the licensee submitted LER No.83-006 describing four areas of Weld No. WIB-RC-2-17 that were found to be less than the minimum wall thickness specified by design. Weld No. WIB-RC-2-17 is in Loop No. 2 of the cold leg between the reactor coolant pump and the reactor vessel. During this inspection the inspector was informed that subsequent examination by the licensee of twenty additional welds (located inside the biological shield) identified two more welds with potential minimum wall violations (Weld Nos. 2-19 and 4-17). The licensea is performing additional confirmatory NDE examinations to verify the validity of the initial findings. If a minimum wall problem is confirmed the licensee will document the discrepant welds on the same nonconformance report documenting Weld No. WIB-RC-2-17. This weld is documented on Nonconformance Report No. DCI-83-QC-N024.

During examination of licensee activities related to this item the inspectors became aware of an apparent failure by the licensee to follow thei nonconforming report procedure for the identification of discrepant conditions. This failure resulted in a delay in notifying the NRC of a potentially reportable condition in accordance with the provisons of the Technical Specifications. The chronology of events, from the initial discovery of the discrepant condition to the May 10, 1983 NRC notification

. is described as follows:

. December 1982 - the licensee formulated plans to examine Reactor Coolant System Piping welds.

. December 7, 1982 - We?4 No. WIB-RC-2-17 is measured with a NORTEC 131-D, ultrasonic tester.

l l . . December 13, 1982 - a wall thickness measurement report is submitted.

l This report describes potential minimum wall problems with Weld Nos.

VI3-RC-2-17 and WIB-RC-3-13. This report is distributed to appropriate levels of plant management including the plant escager, plant superintendent, and project superintendent.

. December 17,1982 .a Nuclear Plant Problem Report (NPPR) is written j on Welds Nos. WIB-RC-2-17 and WIR-RC-3-13.

. January 7,1983 - Weld Nos. WIB-RC-2-L7 and WIB-RC-3-13 are re-examined. Weld No. 2-17 is confirmed below minimum wall and Weld No. 3-13 is found to be within design limits.

. Februa ry 16. 1983 - Westinghouse attempts mechanical measurements from inside pipe, the results are not conclusive but some low areas are detected.

. March 28, 1983 - Weld No. " DIS-RC-2-17 is exa=ined again using a new ultrasonic tester (K3/USL-38). The weld is again confirmed delow minimum wall.

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. April 1,1983 - ISI/NDE weekly reports indicate that Weld No. WIB-RC-2-17 examined and confirmed below minimum wall. .

. April 13, 1983 - Westinghouse Field Deficiency Report is issued with a proposed disposition.

. May 5,1983 - a Nonconformance Report is written on Weld No.

WIP-RC-2-17.

. May 6,1983 - Licensee requests that examinations on Veld No.

VIB-RC-2-17 be repeated to confirm and determine to what extent the ~conEitres eminu.

. May 9,1983 - Weld No. WIB-RC-2-17 is examined again using a K3/CSL-38 ultrasonic taster and confirmed as being below minimum wall.

. May 10, 1983 - NRC informed of minimum wall conditions for Weld No.

WIB-RC-2-17.

The inspectors noted LhaL 10 CFR 50.36(c) specifies that Technical Specifications include items in the categories delinated therein.

Category No. 4, which is entitled " Design Features" states that, " Design features to be included are those features of the facility such as

saterial of construction and geometric arrangements which if altered or modified would have a significant effect on safety..." Section 5.4.1 of the Technical Specifications for the Diablo Canyon Nuclear Power Plant

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Unit No. I states that, "The reactor coolant system is designed and shall be maintained...in accordance with the code requirements specified in Section 5.2 of the FSAR..." Section 5.2.3 of the Diablo Canyon FSAR states in part that, "The minimum wall thickness of the pipe and fittings are not less than that calculated using ASA 331.1, Sectica 1 formula of paragraph 122..."- .

The inspectors reviewed Westinghouse Equipment Specification No. G-676341, dated April 4, 1967, which describes the design and construction of the reactor ecolant syste= piping. Parsgraph 3.2 ef this

, specification requires that the minimum wall thickenss shall not be less than that calculated using ASA 331.1, Section i paragraph 122.

Calculations by the inspectors verified the minimum wall desiga '

requirement.s for the cold leg of the reactor coolant piping is 2.22 inches. Southwest Fabricating Drawing No. 7524-T, Sheet 9 specifies the minimum wall for the RCS cold leg piping as 2.215 inches.

Ice inspectors further noted that Nuclear Plant Administrative Procedure No. C-12, "Indentification and Resolution of Problems and Nonconformances," states in part in paragraph C.I.a that, "The Plant

. Manager and the plant department heads have been delegated the responsibili:y for determining -hether a ;r:blem identified in a Nuclear e

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Plant Problem Report is a nonconformance." A n::::nfernance is defined

  • in paragraph C.I.b. of this procedure as a, ~"Ois : pancy or depar ure from requirements in purchase specifications, drawtugs, approved practices, established Quality Assurance policies or procedures, or NRC regulations which require resolution...and...if left uncorrected could have resulted in degradation or loss of integrity of the reactor coolant '

pressure boundary." Appendix A of the procedure provides examples to aid in determining whether a problem or potential problem is a nonconformance. Paragraph E.1. of Appendix A to the procedure states that, "A discrepancy or departure from requirements in design documents or activities shall be identified and documented ashad a nonconformance lean approved and it If. . .Ii. wi wm.... 4fter

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was issued for use as a basis for further design." The departure of Weld No. WIB-RC-2-17 from specified design requir=ments appears to fall into the category of a nonconformance.

Therefore, as the previously presanted chronology of licensee actions indicate that by December 13, 1983 appropriate levels of plant management were informed of the discrepancy. In addition, on December 17, 1982 a J

Nuclear Plant Problem Report No. DCI-82-QC-P0300 was written describing j the discrepast condition, though it was not reported at this time as a condition requiring a nonconformance report. It appears that sufficient evidence was available at this time to warrent issuance of a i noncoformance report. If a nonconformance had been written the Technical Review Group would have been required to review the discrepant condition for reportability under the Technical Specifications. Further, paragraph 6.9.1.12.i of the Technical Specifications requires that,

" Discovery during unit life of conditions not specifically considered in the safety analysis report or technical specifications that require remedial action or corrective measures to prevent the existence or development of an unsafe condition," be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC. Discussions with the Office of Nuclear Reactor Regulation (NRR),

?tandard Technical Specifiestion Group indicate that corrective measures includes engineering analysis. It appears that the late documentation of the condition in the nonconformance reporting system contributed to the untimely reporting of this problem to the NRC.

The failure of the licensee to comply with technical specifications and report the defective weld in a timely manner is coasidered an apparent item of nonccmpliance. (50-275/83-20/02)

6. Management Meeting on May 27 and June 3, 1983, the inspectors met with licensee representatives denoted in paragraph 1. The scope of the inspection, the observations, and the findings of the inspectors were discussed. The i

licensee acknowledged the inspectors concerns and the apparent item of '

noncompliance as described in this report.

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. 1 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) )

)

)-

'N 7

CERTIFICATE OF SERVICE I hereby certify that on this 6th day of July, 1983, I have served copies of the foregoing SUPPLEMENT TO JOINT INTERVENORS' MOTION TO REOPEN THE RECORD ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE, mailing them through the U.S. mails, first class, postage prepaid.

  • Thomas S. Moore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Commission Conference, Inc.

Washington, D.C. 20555 4623 More Mesa Drive Santa Barbara, CA 93105

  • Dr. W. Reed Johnson Atomic Safety.& Licensing Malcolm H. Furbush, Esq.

Appeal Board Vice President & General U.S. Nuclear Regulatory- Counsel Ccmmission Philip A. Crane, Esq.

Washington, D.C. 20555 Pacific Gas & Electric Company Post Office Box 7442

  • Dr. John H. Buck San Francisco, CA 94106 Atomic Safety & Licensing Appeal Board-U.S.. Nuclear Regulatory Commission Washington, D.C. 20555 l

Docket & Service Branch David S. Fleischaker Office of the Secretary Post Office Box 1178 U.S. Nuclear Regulatory Oklahoma City, OK 73101 Commission Washington, D.C. 20555 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95725

  • Lawrence Chandler, Esq.

Office of the Executive Legal Arthur C. Gehr, Esq.

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