ML20024E839
| ML20024E839 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/02/1983 |
| From: | Durbin S CALIFORNIA, STATE OF |
| To: | PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML20024E836 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309070126 | |
| Download: ML20024E839 (31) | |
Text
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00CKETED UNITED SS.TES OF AMERICA NUCLEAR REGUIATORY COMMISSION N P -6 N :32 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD Orn;gc7ggcm,
US.'E Tyj'.j f y In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
)
50 -32 3 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
GOVERNOR DEUKMEJIAN' S THIRD SET OF INTERROGATORIES AND SECOND DOCUMENT PRODUCTION REQUEST TO APPLICANT PACIFIC GAS AND ELECTRIC COMPANY Pursuant to 10 C.F.R. section 2.740(b), Governor Deukmejian hereby propounds the following interrogatories to applicant Pacific Gas and Electric Colapany.
INSTRUCTIONS 1.
All. information is to be divulged which is in the possession of the individual, association, or corporate party, l
their attor neys, consultan ts, investigator s, agen ts, employees, witnesses or other representatives of the tiamed party.
2.
Where you have incomplete information that precludes your fully a,nswering an interrogatory, give such information as you have and state what information you do not have.
If you are unable to give the information in the f orm sought but have the information aggregated dif ferently, give the information in l
the form in which you have it and explain the reason for the deviation.
3.
When asked in the interrogatories below to identify or 8309070126 830902 PDR ADOCK 05000275 1.
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bo give the identity of a person, please give the following information about him or her:
(a) full name; (b) present job title, employer, and telephone number.
4.
When asked in the interrogatories below to identify or to give the identity of a document or writing, please give the following information about the document:
(a) its title, if any; (b) its nature (e.g., letter, memorandum, chart, computer printout, ledger);
(c) the date, if any, stated on the documente (d) the iden tity of each person who signed it; (e) the identity of each person to whom it is addressed; 5.
Where an individual Interrogatory calls for an answer which invloves more than one part, each part of the l
answer snould be clearly set out so that it is understandable.
6.
These interrogator ies are intended as continuing in te rr oga tories, requiring you to answer by supplemental an swe r, setting forth any information within the scope of the interrogatories as may be acquited by you, your agents, j
attorneys or representatives following your or iginal answers up to the time of hearing.
7.
"Documen ts" include printed material,' writings, 1
handwritten notes, photographs, xerox repr oductions, and audio or video recordings. " Writings" and " recordings" consist of 2.
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letters, words, or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostating, photographing, magnetic impulse, mechanical or electronic recording, or other form of data compilation, as defined in Rule 1001 of the Federal Rules of Evidence 28 U.S.C.
8.
When asked in the interrogatorles below for your position with respect to a numbered contention; f or the f acts, and documents which support that position; and for the witness or witnesses who will testify at the hearing on your behalf with respect to that position, the contentions referred to are those contentions and any subsequent amendments or additions thereto which are set forth in the Atomic Safety and Licensing Appeal Board's August 26, 1983 order at pages 4 through 7.
D3 FIN ITIONS i
(1)
" Appendix B" means Appendix B to part 50 of 10 C.F.R.
(2) 9Diablo Canyon" means units 1 and 2 of the Diablo Canyon Nuclear Power Plant, including all structures, sys tems, and componen ts at the site.
(3) 931ablo Canyon Project" (DCP) means PG&E, Bech tel, all joint projects of PGsE and Bechtel concerning Diablo Canyon, and all contractor s, subcontractor s, consultan ts, and agen ts of the foregoing, excluding the IDVP.
(4)
" Internal Technical Program" means the activities of the DCP undertaken to verify the adequacy of design of Diablo Canyon.
(5)
"Independen t Design Verification Program" (IDVP) me ans the program established by the November 19, 1981, order of the 3.
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Nuclear Regulatory Commission (NRC), the November 19,'1981, letter from Harold Denton to Malcolm Furbush, and implementing directives of the NRC staff, as that program may have been modified since that date.
(6)
" Person" includes natural persons, corporations, 4
partnerships, other business entities, and public agencies.
(7)
"PGEE" means the Pacific Gas and Electric Company and its agents, employees, contractors, subcontractors, affiliates, departmen ts, divisions, units, subunits, and attor neys, excluding the IDVP.
(8)
" Quality assurance" means all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.
Quality assurance includes quality control.
(9)
" Quality control" means those quality assurance actions related to the physical characteristics of a material, struc ture, componen t, or system, which provide a means to control the quality of the material, structure, component, or system to predetermined requiremen ts.
(10) " Safety-related" means those SS&Cs necessary to assure:
(1) the integrity of the reactor coolant pressure I
boundary; (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the l
guideline exposures of 10 C.F.R. part 100.
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l (11) " Verification Program" means all activities of the DCP and the IDVP.
(21) "You" and "your" refer to PGEE.
INTERROGATORIES j
1.
With respect to contention 1(a), do you deny that the scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures and components was too narrow in that the IDVP did not verify samples f rom each design activity (seismic and non-seismic)?
2.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please iden tif y each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
3.
With respect to conten tion 1(b), do you deny tha t the scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures l
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and components was too narrow in that in the design activities the IDVP did review, it did not verify samples from each of the design groups in the design chain performing the design activity?
4.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
5.
With respect to conten tion 1(c), do you deny that the scope of t'he IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures and components was too narrow in that the IUVP did not have statistically valid samples f rom which to draw conclusions?
6.
If your answer to the preceding interrogatory is a denial of the conten tion stated therein:
6.
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you l
rely in suppport of the denial of this contention.
7.
With respect to conten tion 1(d), do you deny that the scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures and components was too narrow in that the IDVP f ailed to verify independently the analyses but merely checked data of inputs to models used by PG&E?
8.
If your answer to the preceding interrogatory is a denial of th,e contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
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(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
9.
With respect to conten tion 1(e), do you deny that the l
scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, struc tures and components was too narrow in that the IDVP failed to verify the design of Unit 27 10.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you relf in support of your denial.
f (b)
Please iden tif y each and every document on which you rely in support of your denial.
(c)
Please iden tify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on l
which you base your denial.
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(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contention.
11.
With respect to contention 2(a), do you deny that the scope of the ITP review of both the seismic and non-seismic aspects of the designs of the safety-related systems, structures and components was too narrow in that the ITP did not verify samples from each design activity (seismic and no n-seismi c) ?
12.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please iden tif y each and every document known to you or believed by you' to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you l
rely in suppport of the denial of this contention.
13.
With respect to conten tion 2 (b), do you deny that the scope of the ITP review of both the seismic and non-seismic 9.
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aspects of the designs of the safety-related systems, structures and components was too narrow in that in the design activities the ITP did review, it did n3t verify samples from each of the design groups in the design chain performing the design activity?
14.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please iden tif y each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
15.
With respect to conten tion 2 (c), do you deny that the scope of the ITP review of both the seismic and non-seismic aspects of the designs of the safety-related systems, structures and components was too narrow in that the ITP did not have statistically valid smples f rom which to draw conclusions?
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16.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
17.
With respect to conten tion 2 (d), do you deny that the scope of the ITP review of both the seismic and non-seismic aspects of the designs of_the safety-related systems, structures and components was too narrow in that the ITP has failed systematically to verify the adequacy of the design of Unit 2?
18.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
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(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend bo call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
19.
With respe,ct to conten tion 3 (a), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it accepted the mean measured performance of structures and materials in lieu of code-specified minima and that the IDVP either used or approved the use of such an improper standard or did not verify l
it at all?
20.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
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(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please iden tify each and every documen t on which l
you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
12.
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(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contention.
21.
With respect to contention 3(b), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it failed to verify that the stress and load factor s for steel used in the containment building were within code values and that the IDVP either used or approved the use of such an improper standa rd or did not verify it at all?
22.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every documsat known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the val.idity of your denial or upon those f acts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
23.
With respect to conten tion 3 (c), do you deny that the 13.
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design activities met license criteria in that it f ailed to specify all damping values used in various seismic modes in the containment and auxiliary buildings and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
24.
If your answer to the preceding interrogatory is a 1
denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please iden tify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend to cell as a witness whom you xpect to testify concerning l
your denial of this conten tion or the facts on which you 1
l rely in suppport of the denial of this contention.
l 25.
With respect to conten tion 3 (d), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it f ailed to verify that PG&E's use of the double algebraic sum method of
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calculation (rather than the sum of the squares method) was acceptable as a substitution and that the IDVP either used or 14.
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approved the use of such an improper standard or did not verify it at all?
26.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsistest with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend bo call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
27.
With respect to conten tion 3 (e), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it used time-history modeling techniques for some accelerations, displacemen ts and shell forces in the containmen t structure and I
Blume response spectra for other accelerations, displacements and shell forces in the same stro:ture and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
28.
If your answer to the preceding interrogatory is 15.
a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely ~ in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, oc tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning l
l your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
l 29.
With respect to conten tion 3 (f), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria with respect to its modeling of the soil properties for the containment and auxiliary buildings and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
30.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
i (a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please iden tify each and every document on which l
you rely in support of your denial.
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(c)
Please identify each and every document known to 1
you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
31.
With respect to conten tion 3(g), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria with respect to its modeling of the crane in the turbine building and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
32.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document krown to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
17.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this ' contention or the f acts on which you rely in suppport of the denial of this contention.
l 33.
With respect to contention 3 (h),do you deny that the ITP used improper engineering standa rds to determine whether design activities met license criteria by virtue of its modeling of the tor sion factor s for dif ferent buildings by differing techniques and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
34.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please iden tify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the, validity of your denial or upon those f acts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you l
rely in suppport of the denial of this contention.
35.
With respect to conten tion 3 (i), do you deny that the 18.
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ITP used improper engineering standards to determine whether design activities met license criteria with respect to its modeling of hydrodynamic forces for the intake structure and that the IDVP either used at approved the use of such an improper standard or did not verify it at all?
36.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
37.
With respect to conten tion 3 (j), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that for its modeling of the intake structure it used different models for horizontal j
and vertical seismic loadings and combined the results of these different models for vertical and horizontal responses and that l
l the IDVP either used or approved the use of such an improper standard or did not verify it at all?
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38.
If your answer to the preceding interrogatory is a 1
denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts en which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning f
your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
l 39.
With respect to conten tion 3 (k), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that for its modeling of the intake structure it used im roper ductility f actors for steel and concrete and that the IDVP either used or approved the use of s,uch an improper standard or did not verify it at all?
40.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
(b)
Please iden tif y each and every document on which i
you rely in support of your denial.
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l (c)
Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend bo call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
41.
With respect to conten tion 3 (1), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria with respect to its computations of modes in the containment building having frequencies between 20 and 33 HZ and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
42.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
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(b)
Please iden tify each and every document on which you rely in support of your denial.
(c)
Please iden tify each and every documen t known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on l
which you base your denial.
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(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contention.
43.
With respect to contention 3 (m), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that in modeling the containmen t building it f ailed to use two hor izontal componen ts for the DE and DDE and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
i 44.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every fact on which you rely in support of your denial.
l (b)
Please identify each and every document on whid1 1
you rely in support of your denial.
(c)
Please iden tify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the, validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
45.
With respect to conten tion 3 (n), do you deny that the 22.
ITP used improper engineering standards to determine whether design activities met license criteria by virtue of the stress values it used for concrete in shear walls in modeling the auxiliary building and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
46.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please iden tif y each and every document on which you rely in support of your denial.
(c)
Please iden tify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please iden tify each and every person you intend bo call as a witness whom you expect to testify concerning j
your denial of this contention or the facts on which you rely in,suppport of the denial of this contention.
47.
With respect to conten tion 4, do you deny that the IDVP has accepted deviations from the licensing criteria without providing adequate engineering justification?
48.
If your answer to the preceding interrogatory is a denial of the conten tion stated therein:
23.
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(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that
)
l cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
49.
With respect to contention 5, do you deny that the verification program has not verified that Diablo Canyon Units 1 and 2 "as built" conform to the design drawings and analyses?
50.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that co nt ra dict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
24.
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(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning ycur denial of this contention or the f acts on which you rely in suppport of the denial of this conten tion.
51.
With respect to contention 6, do you deny that the verification program failed to verify that the design of safety related equipment supplied to PGGE by Westinghouse met licensing criteria?
52.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning t
your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
53.
With respect to contention 7, do you deny that the verification program failed to identify the root causes for the failures in the PG&E design quality assurance program and f ailed to determine if such failures raise generic concerns?
25.
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54.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to l
you or believed by you to contain facts or allegations that co nt radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conte 1 tion or the facts on which you rely in suppport of the denial of this contention.
55.
With respect to conten tion 8, do you deny that the ITP failed to develop and implement in a timely manner a design quality assurance program in accordance with 10 C.F.R. Part 50, Appendix B to assure the quality o' the recent design modifications to the Diablo Canyon facility and that the IDVP f ailed to ensure that the corrective and preventative action programs implemen ted by the ITP are sufficien t to assure that the Diablo Canyon facilities will meet licensing criteria?
56.
If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a)
Please state each and every f act on which you rely in support of your denial.
l 26.
(b)
Please identify each and every document on which you rely in support of your denial.
(c)
Please identify each and every document known to you or believed by you to contain facts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d)
Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
57.
Do you contend that the design quality of all the safety related equipment supplied to PG&E by Westinghouse was assured by a quality assurance program or programs which met each and every requirement of each and every criterion of I
Apper. dix B to 10 C.F.R. Part 50 ?
58.
If your answer to the preceding interrogatory is in the affirmative:
(a)
Please state each and every f act on which you rely in support of your answer.
(b)
Please iden tify each and every document on which you rely in support of your answer.
l (c)
Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your answer or upon those f acts on l
which you base your answer.
27.
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59.
Do you contend that the design quality of all the safety related equipment supplied to PG&E by Westinghouse was assured by a quality assurance program or programs whose implementation met each and every requirement of each and every criterion of Appendix B to 10 C.F.R. Part 50 ?
60.
If your answer to the preceding interrogatory is in the affirmative:
(a)
Please state 'each and every fact on which you rely in support of your answer.
(b)
Please identify each and every document on which you rely in support of your answer.
(c)
Please iden tify each and every documen t known to you or believed by you to contain f acts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your answer or upon those f acts on
~
which you base your answer.
61.
For each and every person identified in your answers to the preceding interrogatories as a prospective witness in these proceedings, please state:
(a)
Whether he or she will be offered as an expert wi tn es s.,
(b)
If the witness will be offered as an expert, the specific subject matter about which the witness will be expected to testif y.
(c)
If the witness will be offered as an expert, the specific qualifications of the witness that you contend would qualify the witness to give opinion testimony on each l
l 28.
specific subject matter about which the witness will testify.
(d)
Each and every professional article, book, or the like, if any, the witness has authored or co-authored concerning each specific subject matter set forth in your answer to subpart (b), above.
(e)
The identity of each and every document the witness will rely on to reach any opinion testimony and specifically cor relate each such documen t (by page and paragraph number) to each specific subject matter on which the witness will render an opinion.
(f)
As to e ach specific subject matter identified in your answer to subpart (b), above, the identity by docket number and case name of each case (court or administrative agency) where the witness has previously given expert testimony concerning each specific subject matter.
l (g)
As to each such case, (1) the date(s) the expert testimony was given; (ii) whether you have a copy of the testimony given; (iii) whether you have a copy of the transcript covering any or all of the witness's examination or cross-examination fcr each such pr oceeding; I
29.
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(iv) whether you have a copy of any notes which the witness made in preparation for, or utilized during, the witness's examination or cross-exanination in each such proceeding.
62.
Please identify each and every document--excluding the IDVP and DCP Final Reports, the Interim Technical Reports, and Supplement 18 to the Safety Evaluation Report--that:
(a)
Describes how the DCP, the IDVP, or the staff drew inferences from sample observations of design activities and products concerning the quality of design of Diablo Canyon.
(b)
Discusses the validity of the methods used to draw inferences about the quality of design of Diablo Canyon from sample observations.
(c)
Discusses the validity of the inferences about the quality of design of Diablo Canyon drawn from sample observations.
(d)
Discusses the method by which any one or more sample was drawn for the purpose of assessing the quality of design of Diablo Canyon.
(e)
Discusses the validity of the sampling methods used.
DOCUMENT PRODUCTION REQUEST l
1.
Pursuant to 10 C.F.R. section 2.241, you are requested to produce each documsa t iden tified in the answers to the interrogatories above.
30.
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The documents shall be produced on October 4,1983, at 3580 Wilshire Blvd., Suite 800, Los Angeles, California 90010, at 10:00 a.m., unless other arrangements are made with counsel.
DATED: September 2,198 3JOIN K. VAN DE KAMP, Attor ney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attor ney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General By
((
AkIb SUSAN L. DURBIN Attorneys for Governor George Deuk7ejian 3580 Wilshire Boulevard Suite 800 Los Angeles, Calif ornia 90010 (213) 736-2105 l
l 31.
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