ML20031E526
| ML20031E526 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/14/1981 |
| From: | Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CALIFORNIA, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8110160066 | |
| Download: ML20031E526 (13) | |
Text
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10/14/81 N
s scre. A ff[,gg(kp g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,-i DCT15193;
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD W.a.
-12 In the Matter of f
PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
(.o to 50-323 0.L.
(Diablo Canyon Nuclear Power Plant Unit Nos. I and 2)
)
NRC STAFF'S SECOND SET OF INTERROGATORIES TO GOVERNOR EDMUND G. BROWN, JR.
Pursuant to 10 C.F.R. 6 2.740(b), the NRC Staff serves the following interrogatories on Governcr Edmund G. Brown, Jr.
INSTRUCTIONSANDDEFINITIbNS 1.
Infonnation sought in these interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Governor Brown.
2.
As used herein, " documents" includes, but is not limited to papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, noi.es and ninutes of meetings or of conversations or of phone calls, interoffice, intra-agency or interagency memoranda or written communicati os of any nature, recordings of conversations either in writing or upon Ra mechnical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, e
T opinions, turveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, 950'l DESICEATED ORIGINAL 3p[
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Certified Ey_ '[ /p'4A
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8110160066 811014 L
letter agreemer.ts, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and also all copies of any of the foregoing which differ x.
inanyway(includinghandwrittennotationsorotherwrittenorprinted matter of any nature) from the original.
3.
Each interrogatory should be answered in five parts as follows:
a.
Answer the direct question asked or provide the information requested.
b.
State completely any documents used as the basis for the answer to the interrogatory.
c.
State completely any documents consulted, but not relied upon as a basis for preparation of your response to the inter-rogatory.
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d.
Give the name and professional qualifications of any individual who will testify on behalf of Governor Brown as to the answer given in the interrogatory.
Include a statement of professional qualifications for any identified individual.
e.
Give the name and address of any individual, corporation.
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business, professional association, state or local official, l
or other organization which served, serves, or it is planned will serve as advisor, witness or consultant to Governor Brown
.on the issue addressed in each interrogatory.
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3-Interrogatary 1 Name occh piece of equipnent associated with Diablo Canyon's pressurizer heaters that Governor Brown believes should be required to meet all applicable safety-grade design criteria, including but not limited to diversity (GDC 22), seismic and environmental qualification I
(GDC 2 a1d 4), automatic initiation (GDC 20), separation and independence (GDC 3 and 22), quality assurance (GDC 1), adequate, reliable on-site power supplies (GDC 17) and the single failure criteria.
Interrogatory 2 What is the basis for Governor Brown's belief that the equipment identified in the answer to Interrogatory #1 should be required to meet all applicable safety-grade criteria?
Interrogatory 3 For each piece of equipment identified in the answer to Interroga-tory #1, identify a) the design criteria Governor Brown believes it l
should be required to meet; and b) the applicable NRC regulation (s) or other statutory provision (s) which Governor Brown believes requires the equipnent to meet the criteria identified in his response to 3(a).
Interrogatory 4 l
Identify the NR" regulation (s) or other statutory provision (s) which 1
Governor Brown believes rcauires PG&E to have Diablo Canyon's pressurizer Y
B heaters and associated controls meet all applicable safety-grade design ct'iteria, including but not limited to diversity (GDC 22), seismic and ii r
I
environmental qualification (GDC 2 and 4), automatic initiation (GDC 20),
separation and independence (GDC 3 and 22), quality assurance (GDC 1),
adequate, reliable on-site power supplies (GDC 17) and the single failure criterion.
Interrogatory 5 Specifically state why Governor Brown believes the equipment associated with Diablo Canyon's pressurizer heaters should be classified as " components important to safety."
Interrogatory 6 Contention 10 alleges that the heater groups should be required to meet certain GDC's identified in the contention.
How does Governor Brown believe the applicant's proposal to connect two out of four of the heater groups to Diablo Canyon's present on-site emergency power supplies fails to provide an equivalent or acceptable level of protection to the level of protection which would be provided if the identifie# GDC's were met?
Interrogatory 7 Under NRC regulation (s), what general design criteria does Governor Brown believe must be met by PG&E in order to connect two out of four of the heater groups to the present on-site emergency power supplies?
l Interrogatory 8
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1 Specify now G>vernor Brown believes PG&E has failed to comply with the NRC regulation (s) identified in the answer to Interrogatory #4 and
l with the general design criteria identified in the answer to Interrogatory #7.
Interrogatory 9 Specify how Governor Brown believe: the pressurizer heaters and associated controls at Diablo Canyon fail to comply with (GDC 20)
" automatic initiation"; (GPC 17), " reliable on-site power supplies";
(GDC 22), " protection system independence"; (GDC 2), " seismic and environmental qualification"; (GDC 4), " seismic and environmental qualification"; (GDC 3) " fire protection"; and (GDC 1) " quality standards and records" in 10 C.F.R. 6 50, Appendix A.
Interrogatory 10 State specifically the reasons why Governor Brown believes that PG&E's proposal to connect two out of four of the heater groups to Diablo Canyon's present on-site emergency power supplies fails to protect the public health and safety and give the reasons why Govenor Brown believes that the equipment associated with Diablo Canyon's pressurizer heatere, fails to protect the public health and safety.
Interrogatorylfg What additional information does Governor Brown believe should be provided by PG8E to insure that the equipment associated with Diablo Canyon!s ressurize.r heaters is adequate to protect the public health and safety and that the proposal to connect two out of four of the heater m
groups to Diablo Canyon's present on-site emergency powee supplies is adequate to protect the public health and safety?
Interrogatory 12 Specify the NRC regulation (s), safety ' Jde criteria, NUREG(s),
Standard Review Plans, Regulatory Guide (s) or statutory provision (s)
Governor Brown believes the prassurizer power-operated relief valves (PORVs), safety valves and block valves at Diablo Canyon are required to meet.
Interrogatory 13 State specifically the reasons why Jovernor Brown believes that PG&E hr.s not met the requirements, criteria and guidance stated in the answer to Interrogatory 21.
Interrogatory 14 Give detailed reasons why Governor Brown believes that Diablo Canyon's PORVs, safety valves and block valves must be classified as components important to safety.
Interrogatory 15 Explain every scenario and the probability of occurrence in which Governor Brown believes failure of Diablo Canyon's PORVs, safety valves and blDck, valves co.uld cause or aggravate a LOCA or operational
- t t
l 7-Interrogatory 16 State specifically the reasons why Govern;. Brown believes that the operation of Diablo Cr.1 yon's PORVs, safety valves, and block valves are deficient.to protect the public health and safety.
5 Interrogatory 17 What additional information does Governor Brown believe should be provided by PG&E to insure that operation of Diablo Canyon's PORVs, safety valves and block valves is adequate to protect the public health j
and safety?
Interrogatory 18 Name each instrument and control Governor Brown believes is associated with Diablo Canyon's PORVs and associated block valves.
Interrogatory 19 Why does Governor Brown believe the instrument (s) and control (s) identified in the answer to Interrogatory 18 should be classified as safety-graded design criteria?
Interrogatory 20 For each instrument and control identified in the answer to Interrogatory 18, identify the design criteria Governor Brown believes it should be required to meet.
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8-Interrogatory 21 Specify how Governor Brown believes the pressurizer PORVs, and safety valves at Diablo Canyon fail to meet (GDC 1), " quality standards and records"; (GDC 14), " reactor coolant pressure boundary"; (GDC 15),
" reactor coolant system design"; and (GDC 30), " quality of reactor coolant pressure boundary" in 10 C.F.R. 50, Appendix A.
Interrogatory 22 Specify how Governor Brown believes Diablo Canyon's pressurizer PORVs and pressurizer safety valves fail to meet Standard Review Plan (3RP) 3.9.2, " Dynamic Testing and Analyses of Systems, Components, and Equipment"; (SRP) 3.9.3., "ASME Code Class 1, 2 and 3 Components, Component Supports, and Core Support Structures"; Regulatory Guide 1.48
" Design limits and loading combinations for seismic Category 1 fluid systems components"; and Regulatcry Guide 1.68 " Pre-operational and Initial Startup Test Programs for Water Cooled Power Reactors."
Interrogatory 23 Why does Governor Brown believe the safety-classification as showr in the FSAR for pressurizer PORV block valves at Diablo Canyon is not adequate to protect the health and safety of the public?
Interrogatory 24
.What additio.nal information does Governor Brown believe should be i
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provided by PG&E to insure that the pressurizer PORV block valves at w
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Diablo Canyon are adequate to protect the health and safety of the publi:?
Interrogatory 25 What does Governor Brown believe that designating block valves as safety-related equipment is not adequate to protect the health and safety of the public?
Interrogatory 26 What are the reasons why Governor Brown believes that block valves should be designated as safety-grade equipment?
Interrogatory 27 Explain in detail how Governor Brown believes the pressurizer power-operated relief valves, safety valves and PORV block valves should be tested and qualified for correct and reliable operation over the range of accident conditions which the Diablo Canyon plant ray experience.
t Interrogatory 28 i
For each of the statements in NRC Staff's Request for Admissions by Governor Edmund G. Brown (October 14,1980) which Governor Brown does not admit, identify the witness (es) which Governor Brown will present on that issue.
l t
5-Interrogatory 29 For each of the statements 1. NRC Staff's Request for Admissions by Governor Edmund G. Brown (October 14,1980) which Governor Brown does not admit, explain the basis for Governor Brown's position on that statement including any documents relied upon.
Interrogatory 30 What is the basis for Joint Intervenors' belief that, if classified as " components important to safety," the pressurizer heaters and valves identified in admitted Contentions 10 and 12 from the low power proceeding must meet the GDCs and other requirements listed in those contentions.
Interrogatory 31 State any rule (s), regulation (s) or other statute (s) which require equipment or systems designated as " components important to safety" to meet the GDCs and other requirements listed in Contentions 10 and 12 from the low power proceeding.
Document Requests 1.
Provide all documents identified in Governor Brown's answers to Interrogatories 1 through 31 which are not already in the possession of the U.S. Nuclear Regulatory Commission.
2.
, Provide all documents within the possession or control of i
?
Governor Brown which relate to the pressurizer heaters for the Diablo Canyon Nuclear Facility, which are not already in the possession of the U.S. Nuclear Regulatory Commission.
3.
Provide all documents within the possession or control of Governor Brown which relate to power operated relief valves, safety valves, associated block valves tnd the instruments and controls for these valves for the Diablo Canyon Nuclear Facility, which are not already in the possession of the U.S. Nuclear Regulatory Cormission.
Respecfully submitted. y Bradley W. Jones.
Counsel for NRC Staff Dated at Bethesda, Maryland this 14th day of October, 1981 v
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0W4ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant Unit Nos. 1 and 2 CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF'S SECOND SET OF INTERR0GATORIES TO GOVERNOR EDMUND G. BROWN, JR. in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 14th day of October, 1981.
John F. Wolf, Esq., Chairman Richard E. Blankenburg Administrative Judge Co-publisher Atomic Safety and Licensing Board Wayne A. Soroyan, News Reporter U.S. Nuclear Regulatory Commission South County Publishing Company Washington, D.C.
20555
- P.O. Box 460 Arroyo Grande, California 93420 Glenn 0. Bright, Esq.
Administrative Judge Atomic Safety and Licensing Board 6
U.S. Nuclear Regulatory Comission Washington, D.C.
20555
- Dr. Jerry Kline Mr. Gordon Silver Administrative Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Comission San Luis Obispo, California 93401 Washington, D.C.
20555
- Arthur C. Gehr Esq, Elizabeth Apfelberg Snell & Wilmer 1415 Cozadero 3100 Valley Center San Luis Obispo, California 93401 Phoenix, Arizona 95073 Philip A. Crane, Jr., Esq.
Paul C.' Valentine, Esq.
Pacific Gas and Electric Company 321 Lytton Avenue P.O. Box 7442 Palo Alto, California 94302 San Francisco, California _94R0,_l Bruce Norton, Esq.
Mr. Frederick Eissler 3216 North 3rd 3treet Scenic Shoreline Preservation Suite 202 Conference,tInc.. '
Phoenix, Ari;:ona 85012 Y
4623 More Mesa Drive Santa Barbara, California 93105 Andrew Baldwin, Esq.
124 Spear Street Mrs. Raye Fleming San Francisco, California 94105 1920 Mattie Road Shell Beach, California 93449
s John R. Phillips, Esq.
Atomic Safety and Licensing Appeal Simon Klevansky, Esq.
Panel Margaret Blodgatt, Esq.
U.S. Nuclear Regulatory Comission Marion P. Johnston, Esq.
Washington, D.C.
20555
- Joel Reynolds. Esq.
Center for Law in the Public Atomic Safety and Licensing Board Interest Panel.
10203 Santa Monica Boulevard U.S. Nuclear Regulatory Commission Los Angeles, California 90067 Washington, D.C.
20555
- Byron S. Georgiou Docketing and Service Section Legal Affairs Secretary U.S. Nuclear Regulatory Commission Governor's Office Washington, D.C.
20555
- State Capitol Sacramento, California 95814 Mark Gottlieb California Energy Comission David _S. Fle.ischaker, Esq.
MS-18 P. 0._. B. _x_1 ] 78_ _. _...__
1111 Howe Avenue o
Oklahoma City. Oklahntna._.73101 Sacramento, California 95825 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 John Marrs, Managing Editor
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San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 Herbert H. Brown Hill, Christopher & Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Harry M. Willis Seymour & Willis 601 California St., Suite 2100 San Francisco, California 94108 Janice E. Kerr, Esq.
l Lawrence Q. Carcia, Esq.
350 McAllister Street SanFranciscy, California 94102 Mr. James 0. Schuyler Bradl y. Jon Nuclear Projects Engineer Counsel for C Staff 7
Par,ific Gas and Electric Company 77 Beale Street San Francisco, California 94106
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