ML20031E528
| ML20031E528 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/14/1981 |
| From: | Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| References | |
| ISSUANCES-OL, NUDOCS 8110160069 | |
| Download: ML20031E528 (13) | |
Text
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i 10/14/81
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275 0.L.
50-323 0.Lfcp g,,L@g(C
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(Diablo Canyon Nuclear Power Plant )
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C' gv.s. T15 1984 NRC STAFF'S SECOND SET OF T
INTERR9GATORIES TO JOINT INTERVEN0RS as h
f Pursuant to 10 C.F.R. 5 2.740(b), the NRC Staff serves the fd seppg g
interrogatories on Joint Intervenors.
INSTRUCTIONS AND DEFINITIONS 1.
Infomation sought in these Interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Joint Intervenors.
2.
As u3ed herein, " documents" include, but are not limited to papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-agency or interagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, surveys, evaluations, projections, hypotheses, fomulas, desigris,yrawings, manuals, notebooks, worksheets, contracts, agree-F, ments, letter agreements, diaries, desk calendars, charts, schedules, S0$
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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 in any way (including handwritten notations or other written er printed matter of arty nature) from the original.
3.
Erch 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 interrogatory.
d.
Give the name and professional qualifications of any individual who will testify on behalf of Joint Intervenors 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, business, professional association, state or local official, or other organization which served, serves, or it is planned will serve as advisor, witness or consultant to the Joint Intervenors on the issue addressed in each interrogatory.
INTERR0GATORY 1 Name each piece of equipment associated with Diablo Canyon's pressurfter heaters that Joiret Intervenors believe should be required to meet all applicable safety-grade design criteria, including but not
limited to diversity (GDC 22), seismic and 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 2 What is the basis for Joint Intervenors' belief that the equipment identified in the answer to Interrogatory #1 should be required to meet all applicable safety-grade design criteria?
INTERROGATORY 3 For each piece of equipment identified in the answer to Interrogatory #1, identify a) the design criteria Joint Intervenors believe it should be required to meet; and b) the applicable NRC regula-tions or other statutory provision (s) which Joint Intervenors believe requires the equipment to meet the criteria identified in their response to 3(a).
INTERR0GATORY 4 Identify the NRC regulation (s) or other statutory provision (s) which Joint Intervenors believe requires PG&E to have Diablo Canyon's pressurizer heaters and associated controls meet all applicable safety-grade design criteria, ir;cluding but not limited to diversity (GDC 22); sejsmic and-environmental qualification (GDC 2 and 4), automatic initiatlon (GDC 20), separation and independence (GDC 3 and 22), quality
4-1 assurance (GDC 1), adequate, reliable on-site power supplies (GDC 17) and the single failure criterion.
INTERR0GATORY 5 Specifically state why Joint Intervenors believe the equipment I
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 c; Joint Intervenors believe that 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 identified GDC's were met.
INTERROGATORY 7 under NRC regulation (s), what general design criteria do Joint Intervenors 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?
INTERROGATORY 8 Specify how Joint Intervenors believe PG&E has failed to comply with F
the NRC begulation(s) identified in the answer to Interrogatory #4 and the general design criteria identified in the answer to Interrogatory #7.
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5-INTERR0GATORY 9 Specify how Joint Intervenors believe the pressurizer heaters and associated controls at Diablo Canyon fail to canply with (GDC 20),
" automatic initiation"; (GDC 17), " reliable on-site power supplies";
(GDC 22), " protection system independence"; (GDC 2), " seismic and environnental qualification"; (GDC 4), " seismic and environmental qualification"; (GDC 3), " fire protection"; and (GDC 1) " quality standards and records" in 10 C.F.R. 9 50, Appendix A.
INTERROGATORY 10 State specifically the reasons why Joint Intervenors believe 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 Joint Intervenors be eve that the equipment associated with Diablo Canyon's pressurizer heaters fails to protect the public health and safety.
INTERROGATORY 11 L' hat additional information do Joint Intervenors believe should be provided by PG&E to insure that the equipment associated with Diablo Canyon's pressurizer heaters is adequate to protect the public health and safety and that the proposal to connect two out of four of the heater groups to Diablo Canyon's present on-site emergency power supplies is adequate to protect the public health and safety?
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. INTERR0GATORY 12 Specify the NRC regulations, safe'ty-grade criteria, LUREG(s),
Standard Review Plan (s), Regulatory Guide (s) or statutory provi-sion(s) Joint Intervenors believe the pressurizer power-operated relief valves (PORVs), safety valves and block valves at Diablo Canyon are required to meet.
INTERR0GATORY 13 State specifically the reasons why Joint Intervenors believe tt,at PG&E has not met the requirements, criteria and guidance stated in the answer to Interrogatory 12.
INTERROGATORY 14 Give detailed reasons why Joint Intervenors believe that Diablo Canyon's PORVs, safety valves and block valves must be classified as canponents important to safety.
INTERR0GATORY 15 Explain every scenario and the probability of occurrence in which Joint Intervenors believe failure of Diablo Canyon's PORVs, safety valves and block valves could cause or aggravate a LOCA or operational transient.
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INTERROGATORY 16 State specifically the reasons 'why Joint Intervenors believe that the operation of Diablo Canyon's PORVs, safety valves and block valves are deficient to protect the public health and safety.
INTERROGATORY 17 What additional information do Joint Intervenors 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 and safety?
INTERR0GATORY 18 Hame each instrument and control Joint Intervenors believe is associated with Diablo Canyon's PORVs and associated block valves.
INTERROGATORY 19 Why do Joint Intarvenors believe the instrument (s) and control (s) itentified in the answer to Interrogatory 18 should be classified as safety-grade design criteria?
INTERR0GATORY 20 For each instrument and control identified in the answer to Interrogatory 18, identify the design criteria Joint Intervenors believe it should be required to meet.
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. INTERR0GATORY 21 Specify how Joint Intervenors believe 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 in 10 C.F.R. 5 50, Appendix A.
INTERROGATORY 22 Specify how Joint Intervenors believe Diablo Canyon's pressurizer PORVs and pressurizer safety valves fail to meet Standard Review Plan (SRP) 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 Regulatory Guide 1.68 " Pre-operational and Initial Startup Test Programs for Water Cooled Power Reactors."
INTERR0GATORY 23 Why do Joint Intervenors believe the safety-classification as shown in the FSAR for pressurizer P0RV block valves at Diablo Canyon is not adequate to protect the health and safety of the public?
INTERR0GATORY 24 What, additional information do Joint Intervenors believe should be F
l provided by PG&E to insure that the pressurizer PORV block valves at Diablo Canyon are adequate to protect the health and safety of the l
public?
INTERR0GATORY 25 Why do Joint Intervenors 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 Joint Intervenors believe that block valves should be designated as safety-grade equipment?
INTERROGATORY 27 Explain in detail how Joint Intervenors believe the pressurizer power-operated relief valves, sLTety 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 may experience.
INTERROGATORY 28 For each of the statements in NRC Staff's Request for Admissions by Joint Intervenors (October 14,1980) which Joint Intervenors do not admit, identify the witness (es) which Joint Intervenors will present on that issue.
INTERROGATORY 29 For each of the statements in NRC Staff's Request for Admissions by JointIn3ervenors-(October 14,1980) which Joint Intervenors do not e
admit,-eiplain the basis for Joint Intervenors' position on that
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statement including any documents relied upon.
INTERR0GATORY 30 What is the basis ice 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.
INTERR0GATORY 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 Joint Intervenors' answers to Interrogatories 1 through 31 above which are not already in the possession of the U.S. Nuclear Regulatory Commission.
2.
Provide all documents within the possession or control of Joint Intervenors 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 documer.ts within the possession or control of Joint Intervenors which relate to power operated relief valves, safety valves, assoct, ted block valves and the instruments and controls for these valves a
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for the Diablo Canyon Nuclear Facility, which are not already in the possession of the U.S. Nuclear Regul'atory Comission.
Respectfully sutinitted, y,"- - -
Bradley W.
nes Counsel for NRC Staff Dated at Bethesda, Maryland tnis 14thday of October,1981.
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John R. Phillips, Esq.
Atomic Safety and Licensing Appeal Simon Klevansky, Esq.
Panel Margaret Blodgett, Esq.
U.S. Nuclear Regulatory Commission 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 San' 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 Coninission Dayid.S._F.leischaker, Esq.
MS-18 P 0. Box 1178_.... _ _. _ _ _
1111 Howe Avenue Oklahoma City. Oklahotna _73101 Sacramento, California 95825 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 3
John Marrs, Managing Editor 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.
Lawrence Q. Carcia, Esq.
350 McAllister Street SanFran'cisgo, California 94102
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Mr. James'0.'Schuyler Bradly/W. Jong
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Nuclear Projects Engineer Counsel for)fRC Staff Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 E CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF'S SECOND SET.0F INTERROGATORIES TO JOINT INTERVENORS 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 Co-publisher Administrative Judge i
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 4
U.S. Nuclear Regulatory Commission 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 Commission 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 9.4RO _j Bruce Norton, Esq.
Mr. Frederick Eissler 3216 North 3rd Street Scenic. Shoreline Preservation Suite 202 Conference,$Inc..
Phoenix, Arizona 85012 i
4623 More Me'sa 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
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