ML20031G935
| ML20031G935 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/15/1981 |
| From: | Norton B PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| References | |
| ISSUANCES-OL, NUDOCS 8110260235 | |
| Download: ML20031G935 (10) | |
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UNITED STATES OF AMERICA IJUC L E AR REGULATORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING DOARD In the Matter of
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Docke t Nos. 50-275 0.L.
PACIFIC GAS AND ELECTRIC COMPANY
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50-323 0.L.
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( Diablo Canyon Nuclear Power Plant,
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Full Power Proceeding
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APPLICANT PACIFIC GAS AND ELECTRIC COMPANY'S k(
THIRD SET OF I N" E RROG ATORI ES j
4 TO JOINT INTERVENORS gr8~o d. 193}s [-
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x Pursuant to 10 C.F.R.
SS2.740-2.74L, and the Board Order of, il nt 4, 1981, Applicant PACIFIC GAS AND ELECTRIC cot 4PANY
,( g" Wiicant") hereby propounds the 1.ollowing Interrogatorien to
"'f,QldtTo i n t Intervenors.
INSTRUCTIONS 1.
All i n to uua t ion is to be divulged which is in the possession af the individual or corporate part.y, their attorneys, i nve s t ig a to rs, agents, employcen or other representativen of the namr d party and their attorneys.
2.
khere an individual Interrogatory calls for an answer which involves more than one part, each pa rt. of the answer should be
.learly set out so that it is und e rs t.a nda ble.
3.
In the event the space provided in not sufficient for your answer to any of the quentions, please attach a separate sheet of paper with the additional information.
4.
These Interrogetories are intended as continuing Interroga-tories, re_juiring you to anawer by supplemental answer, netting forth any information within the scope of the Interrogatories as may '>e acquired by you, your agents, attorneys or represent.itives following your original answers up t.o t.he time of hearing.
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L 1.
State in detail each and every fact upon which you base your contention that the proper operation of power operated relief valves ano associated block valves is essentia) to mitigate the consequences of accidents at Diablo Canyon.
9 2.
State in '.etail each and every fact upon which you base your contenti;n that the proper operation of the instruments and control; for power operated relief valves and associated block valves is essential to mitigate the consequences of accidents at Diable Canyon.
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r 3.
Describe in detail each and every way in which the failure of power operated relief valves, associated block valves or the instruments and controls for these valves can cause a LOCA at Diablo Canyon.
4.
Describe in detail cach and overy way in which the f ailure of powe r operated relief valves, associated block valves or the instruments and controls for these valves can aggravata a LOCA at Diablo Canyon.
5.
Is it Joint Interveno s' contention that all power operated relief valves and all associated block valves at -Diiiblo Ccnvort must be classified as components important to safety? 1 l
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6.
Is it Joint Intervenors' contention that all power operated relief valves and all associated block valves at Diablo Canyon must be required to meet all safety-grade design criteria?
7.
If Joint Intervenors' answer to interrogatory number 5 is in the negative, please list with specificity which relief and block valves at Diablo Canyon should be classifi^d as components important to safety.
8.
If Joint Intervencrs' answe-c to interrogatory number 6 is in the negative, please list with r ificity which relief and block valves at Diablo Canyon showmd be required to meet alt safety-grade design criteria.
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i 9.
Is it Joint Intervenors' position that none of the power operated relief valves or associated block valves at Diablo Canyon have met all safety-grade design criteria?
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10.
For each and every power operated relief valve and/or associated block valve at Diablo Canyon that Joint Intervenor believes has not met all safety-grade design criteria state:
(a)
The locatic n of each such valve.
(b)
The intended purpose of each such valve.
(c) llow each such valve's feilure could cause a LOCA.
(d)
Ilow each such valve's failure could aggravate a LOCA.
(e)
Each and every fact upon which you base your belief that the valve has not met all safety-grade design criteria.
11.
State each and every fact upon which Joint Intervenors base their allegation that the " staff recognizes that pressurizer heaters and asrlciated controls are necessary to maintain natural circulation at hot stand-by conditions.".
12.
State eac'. and every f act upon which Joint Intervenors base their allegation that pressurizer heaters and associated controls should be classified as components important to safety.
13.
Is it Joint Intervenors' position that the pressurizer heaters and associated controls at Diablo Canyon do not meet any safe ty-grade design criteria?
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14.
For each applicable safety-grade design criteria that Joint Intervenors allege the pressurizer heaters and associated controls at Diablo Canyon do not meet, state:
(a)
The specific criteria.
(b)
All f acts upon which you base your allegation that i,
cach suci criteria is not met. 1
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15.
State in detail each and every fact upon which Joint Intervenors base their allegation that the Applicant's proposal to connect two out of four of the heater groups to the present on-site emergency power supplies does not provide an " equivalent or acceptable level of protection."
16.
Identify each and every document upon which you base any answer to the preceding interrogatories and for each such document:
(a)
State the name, author, and date of the document.
(b)
Identify the interrogatory answer to which the document relates.
(c)
Identify the specific page(s) of the document which relates to the answer.
17.
Identify each and every document or exhibit Joint In tervenors may introduce into evidence as respects any pending contentions in these proceedings. %
18.
Identify each and every witness Joint Intervenors may call or subpoena to the hearing on the matters presently pending.
For each such witness, state:
(a)
The name, occupation, address and telephone number of each such person and whether that person may appear for you as a voluntary witness or as subpoenaed witness.
(b)
The field or science in which each such pebson is sufficiently schooled to enable him to express opinion evidence in this matter, if any.
(c)
Whether such witness will base his opinion:
(i) in whole or in part upon facts acquired personally by that person in the course of an investigation or examination as'to the facts; or (ii) solely upon information provided that person by others.
(d)
The qualifications of each such person that would qualify that person, if possible, as ar. expert witness.
(e)
If any such witness has made a personal investigation or examination relating to any of the facts or bases set fo r th in the answers to preceding interrogatories, state the date(s) and nature of each such investigation or examination.
(f)
Each and every fact, and each and every document, photograph, report, item, or other tangible object supplied or made available to each such person for purposes of tormulating his opinions in this matter.
(g)
Whether each such person has rendered written reports, regarding facts, bases, or opinions ac teapects your answers to the preceding interrogatories or that person's contemplated testimony.
If so, state:
(i) the date(s) of each such report; and (ii) the name and address of the custodian of each such report..
.n UNITED. STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE_ Tile ATOMIC SAFETY AND_ LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-275 0.L.
PACIPIC GAS AND ELECTRIC COMPANY
)
50-323 0.L.
)
j (Diablo Canyon Nuclear Power
)
Plant, Units No. I and 2)
)
(Pull Power Proceeding)
CERTIP_ICATE OF SERVICC I hereby certify that copies of " APPLICANT PACIPIC GAS AND ELECTRIC COMPANY'S TIIIRD SET OF INTERROGATORIES TO JOIN? INTERVENORS AND GOVERNOR BROWN", dated October 15, 1981, have been nerved on the following by deposit in the United States mail, postage prepaid, this 15th day of October, 1981:
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The lion. John P. Wolf, Chairman Gordon Silver j
Atomic Safety and Licensing Board 1760 Alinal Street Mail Drop East West 450 San Luis Obispo, CA 93401 i
U. S. Nuclear Regulatory Comm'n Washing ton, 3.0.
20555 Sandra A. Silver 1760 Aliaal Street The-Ilon. Glenn O.
Bright San Luis Obiapo, CA 93401 l-Atomic Safety and Licensing Board Mail Drop East Went 450 Ilarry W. Willis, Esq.
U.
S. Nuclear Regulatory Comm'n W. Andrew Baldwin, Esq.
Washington, D.C.
20555 601 California Street Suite 2100 The Ilon. Jerry R.
Kline San Francisco, CA 94108 Atomic Safety and Licensing Board Mail Drop East West 450 U. S. Nuc1 car Regulatory Comm'n Washington, D.C.
20555 Mrs. Elizabeth Apfelberg John R. Phillips, Esq.
c/o Nancy Culver Center for Law in'thu 182 Luneta Drive Public Interest San Luis Obispo, CA 93401 10203 Santa tionica Blvd.
Los Angeles, CA 90067 David P.
Pleischaker, Esq.
Mrs. Rayo Pleming P. O. Box 1178 1920 flattic Road Oklahoma City, OR 73101 Shell Beach, CA 93449 Mr. Frederick Einuler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105
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William J. Olmstead, Esq.
Charles Barth, Esq.
Carl Neiburger Lucy Swartz, Esq.
P.
O. Box 112 Edward G.
Ketchen, Esq.
San Luis Obispo, CA 93402 Office of Executive Legal Director BETH 042 U. S. Nuclear Regulatory Comm'n washington, D.C.
20555 J.
Anthony Kline, Esq.
Byron S. Georgiou, Esq.
Legal Affairs Secretary Atomic Safety and Licensing Board co the Governor Panel State of California U.
S. Nuclear Regulatory Comm'n State Capitol Building Washington, D.C.
20555 Sacramento, CA 95814 Herbert H. Brown, Esq.
Docketing and Service Section Lawrence Coe Lanpher, Esq.
Office of the Secretary Hill, Christopher & Phillips U. S. Nuclear Regulatory Comm'n 1900 M Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20036 Janice E.
Kerr, Esq.
Lawrence Q. Garcia, Esq.
350 McAllister' Street San Francisco, CA 94.'92 Bruce Norton
. _ -.