ML20024E847
| ML20024E847 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/02/1983 |
| From: | Durbin S CALIFORNIA, STATE OF |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20024E836 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309070133 | |
| Download: ML20024E847 (41) | |
Text
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80CMETED UNITED S'mTES OF AMERICA USNRC NUCLEAR REGUIATORY COMMISSION Y?-6 R2:32 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD r:c. ,
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In the Matter of )
) .
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.
) 50 -32 3 0.L.
(Diablo Canyon Nuclear Power )
l Plant, Units 1 and 2) )
)
GOVERNOR DEUKMEJIAN' S FIRST SET OF INTERROGATORIES AND FIRST DOCUMENT PRODUCTION REQUEST TO THE NRC STAFF Pursuant to 10 C.F.R. section 2.740 (b), Governor Deukmejian hereby propounds the following interrogatories to the NRC staff.
l IN STI UCTIONS
- 1. All information is to ce divulged which is in the l
6 possession of the individual, association, or corporate party, their attorneys, consultants, investigators, agents, employees, witnesses or other represen tatives of the named party.
- 2. Where you have incomplete information that precludes your fully answering an interrogatory, give such information as you have and, state what information you do not have. If you l are unable to give the information in the form sought but have l
l the information aggregated differently, give the information in 1
the form in which you have it and explain the reason for the deviation.
- 3. When asked in the interrogator les below to iden tif y or 8309070133 830902 1*
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to give the identity of a person, please give the following information about him or hers (a) full name; (b) presen t 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 document; (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 answer should be clearly set out so that it is understandable.
- 6. These interrogatories are intended as continuing interrogatories, requiring you to answer by supplemental an swe r , setting forth any information within the scope of the interrogatories as may be acquired by you, your agents, attorneys or representatives following your original answers up to the time of hearing.
- 7. "Docummits" include printed material, writings, handwritten notes, photographs, xerox reproductions, and audio or video recordings. " Writings" and " recordings" consist of 2.
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 interrogatories below for your position with respect to a numbered contention; for the f acts, and documents which support that position; and for the witness or witnesses who will testify at the hearing on your behalf a
with respect to that position, the conten tions 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.
DEFIN ITIONS (1) " Appendix B" means Appendix B to part 50 of 10 C.F.R.
(2) "Diablo Canyon" means units 1 and 2 of the Diablo Canyon Nucl2Ar Power Plant, including all structures, sys tems, and componen ts at the site.
l (3) 9Diablo Canyon Project" (DCP) means PG&E, Bech tel, all joint projects of PG&E and Bechtel concerning Diablo Canyon, l 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 l the DCP undertaken tc verify the adequacy of design of Diablo Canyon.
(5) "Independen t Design Verification Program" (IDVP ) mean s I 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 modifled since that date.
(6) " Person" includes natural persons, corporations, partnerships, other business entities, and public agencies.
(7) "PG&E" means the Pacific Gas and Electric Company and its agents, employees, contractors, subcontractors, affiliates, i
departmen ts, divisions, units, subunits, and attorneys, excluding the IDVP.
(8) " Quality assurance" means all those planned and systematic actions necessary to provide adequate confidence that a struc ture, system, or componen t will perform satisf actorily in service. Quality assurat.ce includes quality control.
(9) " Quality control" means those quality assurance actions related to the physical characteristics of a material, str uc 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 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 poten tial off-site exposures comparable to the guideline exposures of 10 C.F.R. part 100.
4.
(11) " Verification Program" means all activities of the DCP and the IDVP.
(21) "You" and "your" refer to NRC staff.
INTERROGhTORIES
- 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 from each design activity (seismic and non-seismic)?
If your answer to the preceding interrogatory is a
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2.
denial of the conteation 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 on l which you base your denial.
l (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.
- 3. With respect to contention 1(b), do you deny that the scope of the IDVP review of both the seismic and ,non-seismic
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aspects of the designs of safety-related systems, struc tures 5.
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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 iden tify 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 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 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 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 j cont radict, are inconsistent with, or tend to cast doubt l
upon the validity of your denial or upon those facts on which you base your denial.
l (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 conten tion or the facts on which you 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-seisudc i
aspects of the designs of safety-related systems, structures and components was too narrow in that the IDVP failed to verify independently the analyses but merely checked data of inputs to models used by PGEE?
l 8. If your answer to the preceding interrogatory is a denial of th,e 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 l
you rely in support of your denial.
7.
l (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 l
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.
- 9. With respect to conten tion 1(e), 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, struc tures and components was too narrow in that the IDVP failed to verify the design of Unit 2?
- 10. 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 tify each and every documen t 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.
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(d) Please identify end 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 whid 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 I denial of the contention stated therein: ,
(a) Please state each and every f act on which you l rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
l (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 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.
I 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.
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 not 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 iden tify each and every documen t on whida you rely in support of your denial.
(c) Please iden tify each and every documen t known to 3
you or believed by you to cantain 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 i 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 conten tion or the facts on which you rely in suppport of the denial of this contention.
- 15. Wit,h respect to conten tion 2 (c), do you deny that the secpe 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 co nclusions?
10.
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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 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 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.
l 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 f ailed systematically to verify the adequacy of the design of i
Unit 2?
- 18. If your answer to the preceding interrogatory is a l
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 documen t on which l
you rely in support of your denial.
11.
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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 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.
- 19. With respect to conten tion 3 (a), do you deny that the ITP used improper engineeri'ng 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 minina and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 20. 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 l 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 l
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.
1 (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 l
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 tl:e use of such an improper standard 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 f act on which you rely in support of your denial.
(b) Please iden tify each and every documen t 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 contr in 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 den ial.
l (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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ITP used improper engineering standards to determine whether 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 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 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 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 conten tion or the facts on which you l
rely in suppport of the denial of this contention.
- 25. With respect to conten tion 3 (d), do you deny that the l 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 calculation (rather than the sum of the squares method) was l
l 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 bo contain f acts or allegations that contradict, are inconsistait with, or tend to cast doubt upon the validity of your denial or upon those f acts on which yoo 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 er 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 Blume response spectra for other accelerations, displacements and shell forces in the same structure 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 draial.
(c) Please identify er.ch 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 conten tion or the facts on which you rely, in suppport of the denial of this contention.
- 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:
(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.
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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 conter. tion 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 sw:h an improper stan.dard 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 fact on which you i rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
j (c) Please identify each and every document known to you or believed by you ba 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 4
which you base your denial. .
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l (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 conten tion.
- 33. With respect to contention 3(h),do you deny that the ITP used improper engineering standards to determine whether t design activities met license criteria by virtue of its l
l modeling of the tor sion factor s for dif feren t 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 l all?
- 34. If your answer to the preceding interrogatory is a i denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial. e (b) Please iden tify each and every document on whid1 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 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.
- 35. With respect to conten tion 3 (i), do you deny that the 18.
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 or 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 iden tify each and every documen t 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, at tend to cast d0ubt 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 t
to call as a witness whom you expect to testify concerning l
your denial of this conten tion or the f acts 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 l design activities met license criteria in that for its modeling l
of the inteke structure it used different models for horizontal and vertical seismic loadings and combined the results of these different models for vertical and horisontal responses and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
19.
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- 38. If your answer to the preceding interrogatory is a denial of the conten tion 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 iden tify each and every person you intend l 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.
- 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 improper ductility f actors for steel and concrete and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 40. If your answer to the preceding interrogatory is a I
l 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 iden tify each and every documen t on whid1 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 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.
- 41. With respect to conte 1 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 f act on which you rely in support of your denial.
(b) Please iden tify each and every documen t 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 which you base your denial.
21.
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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 conten tion.
- 43. With respect to contention 3 (m), do you deny that the ITP used . improper engineering standa rds to deternine whether design activities met license criteria in that in modeling the containmen t building it f ailed to use two horizontal componen ts i 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?
- 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.
(b) Please iden tify each and every documen t on whida you rely in support of your denial.
(c) Please iden tify each and every documea 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 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 conten tion 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 vir.tue 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 fact on which you rely in support of your denial.
l (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 inconsisten t with, or tend to cast doubt l 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 conten tion 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 contention stated therein: .
i 23.
.v - .. - - - . .-.,-. -.--. ,,--v.....,e--.e,, , , - - . .-
(a)
Please state each and every f act on which you rely in support of your denial.
(b)
Please identify each and every doct ment on which you rely in support of your denial.
(c) Please identify each and every doctrient known to you or believed by you to contain facts or aliegations that cont radict, are inconsistent with, or tend to :ast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please idelitify each and every person you intend to testify concerning to call as a witness whom you expect the facts on which you your denial of this contention or 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 l
' denial of the contention stated therein:
(a)
Please state each and every f act on which you l
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 e ach 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.
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 your 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 PG&E 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 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.
J (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 l which you base your denial.
(d) Please iden tify each and every person you intend l bo call ,as a witness whom you expect to testify concerning j your denial of this conteition or the facts on which you rely in suppport of the denial of this contention.
- 53. With respect to conten tion 7, do you deny that the verification program failed to identify the root causes fe: the failures in the PG&E design quality assurance program and failed 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 you or believed by you to contain facts or allegations that cont radic t, 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 conten tion or the facts on which you rely in suppport of the denial of this contention.
- 55. With respect to contention 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 of the recent design modifications to the Diablo Canyon facility and that the IDVP failed to ensure that the corrective and preventative action programs implemen ted by the ITP are sufficient 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 fact on which you l
rely in support of your denial.
l 26.
l l
(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 bo 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.
- 57. Do you contend that the design quality of all the safety related equipment supplied to PG&E by Westinghouse was j assured by a quality assurance program or programs which met each and every requirement of each and every criterion of Appendix 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.
(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 answer or upon those f acts on which you base your answer.
27.
l I
- 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 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.
(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 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 tness.
(b) If the witness will be offered as an expert, the l
l specific subj ect matter about which the witness will be expected to testify.
(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 28.
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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 documeat the witness will rely on to reach any opinion testimony and specifically cor relate each such document (by page and paragraph number) to each specific subject matter on which the witness will render an opinion.
i (f) As to each specific subject matter identified in your answer to suhpart (b), above, the iden tity by docket l
l number and case name of each case (court or administrative agency) where the witness has previously given expert testimony concerning each specific subj ect matter.
(g) As to each such case, (i) the date(s) the expert testimony was l
l 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 l
examination or cross-examination for each such pr oceeding; 29.
1
(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-exandnation in each such proceeding.
- 62. Please identify each and every document--excluding the IDVP and DCP Final Repor ts, the Interim Technical Reports, and Supplement 18 to the Safety Evaluation Report--that:
i (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.
l (d) Discusses the method by which any one or more sample was drawn for the purpose of assessing the quality j of design of Diablo Canyon.
(e) Discusses the validity of the sampling methods used.
l DOCUMENT PRODUCTION REQUEST 1
- 1. Pursuant to 10 C.F.R. section 2.241, you are requested to produce each documen t iden tified in the answers to the interrogatories above.
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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 3 JOIM 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 Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General n
- C -
' By hd ( Cll v l( .MI. ! - lb'~/ '
SUSAN L. DURBIN Attorneys for Governor l
George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2105 l
l l
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I3 - @ -6 pg ;37 BEFORE THE ATOMIC SAFETY AND LICENSING APPEA4ppOARD
- ' Nh[hefu
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
! ) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
, )
)
CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing GOVERNOR DEUKMEJIAN'S THIRD SET OF INTERROGATORIES AND SECOND DOCUMENT PRODUCTION REQUEST TO APPLICANT PACIFIC GAS'AND ELECTRIC COMPANY, GOVERNOR DEUKMEJIAN'S THIRD SET OF INTERROGATORIES AND SECOND DOCUMENT PRODUCTION REQUEST TO CONTRACTORS OF THE INDEPENDENT DESIGN l VERIFICATION PROGRAM, GOVERNOR DEUKMEJIAN'S FIRST SET OF INTERROGATORIES TO THE NRC STAFF, and LETTER TO CHAIRMAN AND COMMISSIONERS, were served on the following by United States Mail, First Class (except for those persons marked with an asterisk ("*"), to whom the envelope was posted Express Mail),
postage prepaid.
Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 ,
1.
Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 Hon. James Asselstine, Commissioner -
U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 Hon. Frederick M. Bernthal, Commissioner j U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. Thomas S. Moore, Chairman
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. W. Reed Johnson
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Hon. John H. Buck
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge Glenn O. Bright Atomic Safety and Licensing Board
! U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
2.
. . .z ... ._. - - - --
Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Leonard Bickwit, 'Esq.
Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence Chandler, Esq.
- Henry J. McGurren, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E. Kerr, Esq.
Public Utilities Commission 5246 State Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Beach, CA 93449 i
Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 Gordon Silver San 6ra A. Silver 1760 Alisal Street San Luis Obispo, California 93401 3.
_ _ _ = _ _ . _ _ _ . . _ _ _ _ . _ _ _ - _ .____ . _ . . . _ - . _ _. _ - _ _
Joel R. Reynolds, Esq.
Eric Havian, Esq.
John Phillips, Esq.
Center for Law in the Public Interest 10951 West Pico Boulevard, Third Floor Los Angeles, CA 90064 ^
Bruce Norton, Esq.
- Norton, Burke, Berry & French 2002 East Osborn Phoenix, AZ 85064 Philip A. Crane, Jr. , Esq.
- Richard F. Locke, Esq.
Pacific Gas and Electric Company San Francisco, CA 94120 l
David S. Fleischaker, Esq.
- P. O. Box 1178 Oklahoma City, OK 73101 Arthur C. Gehr, Esq.
l Snell & Wilmer 3100 Valley Bank Center Phoenix, AR 85073 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, CA 95125 Mr. Carl Neiberger ~
Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Virgina and Gordon Bruno Pecho Ranch P. O. Box 6289 Los Or.os, CA 93402 Nancy Culver 192 Luneta San Luis Obispo, CA 93401 4.
L _ - - - _._ _ _--
Maurice Axelrad, Esq.
- Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 DATED: SEPTEMBER 2, 1983 JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General S USAN L . DURBIN ,
i PETER H. KAUFMAN, Deputy Attorneys General By /( !A SUSAN L. DURBIN Attorneys for Governor George Deukmejian l
l 3580 Wilshire Boulevard Suite 800 Los Angeles, California 9010 Telephone: (213) 736-2105 0
5.
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