ML16340D315
| ML16340D315 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/12/1983 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Voges P SAN LUIS OBISPO, CA |
| Shared Package | |
| ML16340D316 | List: |
| References | |
| NUDOCS 8304220022 | |
| Download: ML16340D315 (14) | |
Text
IIs. Pamela Voges City Clerk Office of the City Clerk Post Office Box 321 San Luis Obispo, California 93406-0321
Dear f)s. Voges:
I am pleased to respond to your letter of March 7, 1983 to Chairman Palladino which has been referred to me for reply.
Your letter transmitted Resolution Ho. 5056, which was adopted by the San Luis Obispo City Council, urging the Nuclear Regulatory Cormission to defer the licensing of Diablo Canyon, Unit 1 until completion of the reverification program and associated safety studies and completion of all plant modifications to safety related structures, systems and components.
Your letter also raised two areas of concern which we have addressed separately in the Enclosure.
With respect to the Resolution, the NRC Order of llovember 19, 198l, clearly sets forth the requirements that must be met and procedures that are to be followed for the authorization of fuel loading.
In Section 5 of Attachment l, the Order states:
"Prior to authorization to proceed with fuel loading the NRC shall be satisfied with the results of the seismic design verification program referred to in paragraph I, and with any plant modification resulting from that program that may be necessary prior to fuel loading.
The IIRC may impose additional requirements prior to fuel
,loading necessary to protect health and safety based upon its review of the program or any of the information provided by PGBE pursuant to paragraph 4.
This may include some or all of the requirements specified in the letter to PGBE, dated November 19, 1981."
Our approval of a two-step process for a decision regarding reinstatement of the license does not permit any deviation from these requirements.
The approval is limited to the concept of two steps for decisions regarding reinstatement of the license, but is in n'o way restricted to the target schedule proposed by PGSE.
At this time, PGEE and the independent design verification program (IDVP) are, providing us with much information in the form of semi-monthly reports, interim technical
- reports, and sections of their final reports on the various facets of the design verification effort.
Although we intend to give substantial weight in our decision to the findings, conclusions, and recommendations of the IDVP, under no condition will we consider the IDVP to take the place of the necessary and adequate HRC 8304220022 8304i2 PDR *DOCK 05000275 PDR OFFICE/
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Patnela Yoges review.
Ile will not be restt icted in our own review efforts by the specific schedule proposed but will take the time'necessary to assure ourselves and the public that there are no deficiencies that would prevent safety-related structures, systems and components from performing their intended safety functions.
Let me assure you that under no condition will we authorize the Diablo Canyon facility to begin operatjon until we have reasonable assurance that the public health and safety is adequate'Iy protected.
Ilore specifically we will require a high level of confidence that no significant design or construction deficiencies affecting safety at any authorized level of operation exist at the facility before reaching a decision to authorize that level of operation.
Sincerely,
Enclosure:
As stated Originni Signed by H.R. Dentna Harold R. Denton, Director Office of Nuclear Reactor Regulation
- See previous concurrence.
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Hs Pamela Voges Cit Clerk Offic of the City Clerk Post 0
ice Box 32l San Luis ispo, California 93406-0321 Dear Hs. Yog I am pleased to spond to your letter of Harch 7, I983 to C
~rman Palladino which has been re red to me for reply.
Your letter tran itted Resolution Ho. 5056, which was dopted by the San Luis Obispo City uncil, urging the Nuclear Regulatory Co 1.lisslon to defer the licensing o
Diablo Canyon, Unit 1 until completion of the everification program and ociated safety studies and completion of all pla t modifications to safe related structures, systems and components.
Y 1r letter also raise wo areas of concern which we have addressed sepa tely in the Encl sure.
With respect to the Resolution, he NRC Or r of November 19, 1981, clearly sets forth the requirements that
. st be iet and procedures that are to be followed for the authorization f
1 loading.
In Section 5 of Attachment 1, the Order states:
"Prior to authorization to p ceed
~ith fuel loading the fIRC shall be satisfied with the resu s of the seismic design verification program referred to in p agraph 1,
a with any plant modification resulting from that pro ram that may be ecessary prior to fuel loading.
The NRC may mpose additional quirements prior to fuel loading necessary t protect health and sa ty based upon its review of the program or ny of the information pro ded by PGBE pursuant to paragraph 4.
his may include some or all f the requirements specified in t letter to PGBE, dated November 9, 1981."
Our approval of two-step process for a decision regar
'ng reinstatement of the license oes not permit any deviation from these r quirements.
n The approva is limited to the concep of two steps for decisions regarding reinstatemen of the license, but is in no way restricted to the target schedule proposed by G8E.
At this IDYP) are providing us with much information it the form of semi monthly reports, interim technical repor ts, and sections o
their final eports on the various facets of the design verification effo tp m P
Although we intend to give substantial weight n our decision to the findings, conclusions, and recommendations of ~+dyne the IDYP, under no condition will we consider the IDYP to take the place of the necessary and adequate IIRC OFFICf/
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NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USOPO1 1991~9.960
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is. Pamela Voges review.
We will not be restricted in our own review e orts by the specific schedule oposed but will take the time necessary t assure ourselves and the public at there are no deficiencies that wo d prevent safety-related structures, s
ems and components from perform' their intended safety functions.
Let me assure you that ader no conditio will we authorize the Diablo Canyon facility to begin operati>
until we h
e reasonable assurance that the public health and safety is adequat pro cted.
nore specifically we will require a high level of confidence that significant design or construction deficiencies affecting safety at any authori evel of operation exist at the facility before reaching a decision to uthor e that level of operation.
I hope this letter and it enclosure prove information responsive to your concerns.
Sincerely, Enc sure:
A stated Harold R. Denton, Dir tor Office of Nuclear React Regulation OFFICE%
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Enclosure Res onse to Two Concerns The first concern is that "the NRC recently adopted a licensing schedule which permits restoration of the plant's license and fuel loading before the reverification program is completed, before the results are analyzed, and before any corrective action called for in that program, if any, can be implemented."
We have not adopted a licensing schedule, we have approved a process for reinstatement of the license consistent with the Commission Order.
The Commission Order of November 19, 1981, which suspended the low power
- license, sets forth the requirements that must be completed prior to reinstatement of the license.
These requirements relate to seismic analyses and design activities performed prior to June 1978 by PG&E and its contractors (i.e.,
service-related activities) and to the implementation of the quality assurance pr'ogram for those efforts.
The activities associated with the Commission Order have become known as Phase I of the independent design verification program
( IDVP) and will be completed in two steps.
In addition, the NRC Office of Nuclear Reactor Regulation required PG&E in a letter, also dated November 19, 1981, to initiate an independent design verification effort of safety-related structures, systems and components with respect to seismic analyses and design activities performed after 1978 and with respect to non-seismic analyses and design efforts performed by PG&E and its contractors.
These efforts have become known as Phase II of the design verification program.
By the Commission's approval of the program plan on December 8,
- 1982, the utility is required to submit a status report on all Phase II activities prior to any decision regarding restoration of the license.
Such work must be sufficiently complete to ensure that all major deficiencies were detected.
The design verification efforts for Phase I and Phase II are well underway.
The activities that we require now to be completed prior to a fuel load decision exceed those originally specified in our Order.
We have expanded the program to include the following additional IDVP activities:
(1) audit of the implementation of the Diablo Canyon Project quality assurance program (2) audit of a sample of quality assurance program implementation of construction activities, (3) review of the PG&E/Westinghouse design interface, and (4) verification of the appropriate Hosgri and non-Hosgri spectra.
At the time of authorization for fuel loading all efforts required for reinstatement of the license will be completed except for modifications to those structures, systems and components that are not required for Step 1, in order to protect the public health and safety.
In addition, the Phase II activities (i.e., non-seismic, safety-related analysis and design) of PG&E and the IDVP will have proceeded to an extent that will allow us to reach a conclusion with respect to any additional design verification that might be required.'t this time the IDVP has completed its review of those structures, systems and components that comprise the initial sample to be verified under Phase II. Prior to fuel loading, PG&E and the IDVP will both submit to the NRC a report on the status of their respective Phase II activities.
- Again, we will require a high degree of assurance, at the time of a decision regarding fuel loading; that any further design verification efforts in the seismic and non-seismic area will not reveal any major deficiency in Diablo Canyon Unit 1.
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The second concern is "the licensing schedule for the plant also has no provision for the completion of studies of three plant safety systems ordered by the NRC, nor for the analysis of those studies, nor for the implementation of their recommendations."
The results of the seismic design analyses that have been ongoing at Brookhaven National Laboratory (BNL) since late 1981 will be fully taken into consideration in the NRC evaluation and determination regarding the seismic design adequacy of Diablo Canyon Unit 1.
The'first BNL effort involved the containment annulus structure and selected associated piping systems-and was documented in a report.
We have requested the IDYP to review this report, consider the results in its own design verification efforts, and provide us with its conclusions.
The NRC staff is evaluating the BNL report in parallel and will have the additional benefit of the independent view provided by the IDVP.
In mid 1982 the NRC requested continued participation by BNL to undertake a horizontal seismic analysis of the containment annulus structure, seismic and stress analyses of a buried tank,'nd additional analyses of piping systems.
The purpose of the BHL analyses is to provide the NRC with additional insight as to the character of results obtainable by use of current state-of-the-art analytical techniques without regard to methods or procedures previously approved in the licensing process for Diablo Canyon.
These analyses are therefore not intended as a substitute for the design and evaluation efforts now underway nor are they a substitute for the analytical effort being performed by the IDVP.
Our experience has
- been, however, that such analyses often provide insights to assist in our review.
The BNL analyses will be sufficiently completed and taken into consideration prior to any decision regarding restoration of the license.
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PaaIe)e TIoges Catty of San tu$s-Obispo>>
ACTION CONTROL COMP L DEADLINE INTERIM REPLY DATES CONTROL NO DATE OF DOCUMENT TO:
ANAL REPLY FILE LOCATION DESCRIPTION
'ETTER Cl MEMO 0 REPORT I-I OTHER Encloses Resolution Ho. 6055 ()983 Serfes) r questfng ARC defer re)fcensfntt of Nab)o Canyon ante) reverfftcat4on prograe h safety studies are completed SPECIAL INSTRUCTIONS OR REMARKS PREPARE FOR SIGNATURF OF:
CIOHAIRMAN I-IEXECVTIYE DIRECTOR OTHER:
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t IIV DATE INFORMATION ROUTING Ofrcks Rae Retm Enctelken
,'unn)ngham Case/Oent4n6 PPAS 2.
IPefs 3.
Nattson l-1mer 0IItpson k
yder NRC FORM 232 (640)
EXECUTIVE DIRECTOR FOR OPERATIONS PRINCIPAL CORRESPONDENCE CONTROL
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