ML20034H817

PG&E Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace (Re Contention 1).* Related Correspondence

ML20034H817
Person / Time
Site:	Diablo Canyon
Issue date:	03/12/1993
From:	Repka D PACIFIC GAS & ELECTRIC CO., WINSTON & STRAWN
To:	Atomic Safety and Licensing Board Panel
References
CON-#193-13724 OLA-2, NUDOCS 9303220107
Download: ML20034H817 (61)

Text

{{#Wiki_filter:jyf2f .g. RELATED CORRESPONDENCE March S h 93~ 9

15. P3:00 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

) ) Docket Nos. 50-275-OLA - Z Pacific Gas and Electric Company ) 50-323-OLA ) (Construction Period (Diablo Canyon Nuclear Power ) Recovery) Plant, Units 1 and 2) ) ) PACIFIC GAS & ELECTRIC COMPANY'S RESPONSE TO FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE (RE: CONTENTION Il Pacific Gas & Electric Company ("PG&E") herein responds to all remaining portions of "Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories and Requests for Production of Documents to Pacific Gas & Electric Company," dated February 16, 1993 ("MFP's First Set").l' This response includes answers and objections in accordance with 10 C.F.R. SS 2.740b(b) and 2.741(d), and specifically addresses in full the portions of MFP's First Set that relate to Contention I (Maintenance).F Facsimile copies of l' For previous responses to other aspects of MFP's First Set, see " Pacific Gas & Electric Company's Response to First Set of Interrogatories and Request for Production of Documents Filed by San Luis Obispo Mothers for Peace (Re: Contention V)," dated March 10, 1993. F This response is being timely filed in accordance with the schedule for discovery responses adopted by the Atomic. Safety and Licensing Board in this proceeding. See Memorandum and Order (Discovery and Hearing Schedules), February 9,

1993, (continued...)

D O 9303220107 930312 PDR ADDCK 05000275' O PDR

1: 1 the affidavits required by 10 C.F.R. S - 2.740b(b). for the answers to Lthe discovery requests are included in this response; due to I logistical ^ difficulties, originals will follow within-the next several days. Copies of documents identified in. Attachment 1. related to Contention I are being provided to the San Luis Obispo Mothers for Peace ("MFP") herewith. I. GENERAL OBJECTION (Contention I: Maintenance) Maintenance and surveillance quite obviously encompass a broad range of programs and activities at the Diablo Canyon Nuclear Power

Plant, Units 1 and 2

("the Diablo Canyon plant"). Equally obviously, these programs and activities encompass and impact numerous plant systems, structures, and components. Documentation of maintenance activities (e.g., procedures, vendor manuals, maintenance records) is correspondingly voluminous. In the context of the universe of maintenance and surveillance documentation that' exists at the Diablo Canyon plant, MFP's First Set reflects an' unfocused, shotgun approach to discovery on the maintenance contention that could unnecessarily burden PG&E and result only in overwhelming MFP in paper. Accordingly, as discussed below.in the specific responses, PG&E. is objecting to some of the requested maintenance discovery based on the sheer' breadth of documentation 2'(... continued) at 4, 5 2. In fact, in an effort to accommodate 'the intervenor by providing information in advance of a requested site visit (tentatively the week of March 15, 1993), these responses 'are being filed-.in advance of the due date of March 19, 1993.- A' - t. 7.; j involved.: PG&E.is specifying thatl these documents l will-not?be' provided simply as a convenience to ' MFP. - Rather, upon a.more i

narrow-focusing '.or ident'ification of documents requested, PG&E will.

[ ~ .make documents available for -inspection and~ copying by MFP (at MFP's expense) at the Diablo ~ Canyon site. This. responsel is: t consistent with what is required" of-.PG&E under 10 C.F.R.- J! 4 SS ' 2.741(a) (1). and 2.741(d). l .i As' originally proffered, MFP's Contention I related to PGEE's historic implementation.of the maintenance program at the Diablo~ -[ Canyon plant. MFP cited isolated examples of alleged' errors in maintenance implementation (" lack of attention'to detail,_ poor.or-

r incomplete work.

") and isolated examples of an. alleged." slow' I response.to correct maintenance problems." Egg " San.LuisLObispo: Mothers for Peace Supplement to Petition to Intervene," October-26, 1992, at 5-13. On - the. basis of ' these alleged implementation difficulties, MFP contended :that: PG&E lacks-'a" sufficiently- { -effective and comprehensive-maintenance program.- Sag Prehearina-l Conference Order (Ruling'Upon Intervention Petition and Authorizing-Hearing), LBP-93-1, January 21,-

1993, at-15-16..("Prehearing Conference Order").

However, none of this ~ focus remains in MFP's First Set. t Instead,: 'MFP seeks all manner ^ of' minutiae -related to the plant; maintenance / surveillance. program; including,.for. example, vendor'- { manuals and " equipment' literature" for? twelve categories of; .- i r l r 1 i

s s k equipment.. See MFP's First Set, Attachment E, Request-16, at'E-4. f ? MFP draws no distinction between maintenance program information ~ and maintenance program implementation data. (Only the latter appeared to be the basis. for the contention admitted by the Licensing Board.) MFP also seeks infermation addressing generic equipment aging issues of a type ' originally raised by MFP in i proposed Contention IV, deemed inadmissible by the Licensing Board. Prehearing Conference Order, at 32-34. PG&E objects, as specified. below, to requests that appear to be unnecessarily broad and insufficiently fccused on issues subject to litigation in this proceeding. PG&E remains open to more precise requests to review documents at the Diablo Canyon plant. f MFP, in its February 1, 1993, request for discovery by entry upon the Diablo Canyon site,l' at 4-5, offered to focus its Contention I discovery. This is an offer that PG&E,- in its response of February 12, 1993,F at 2-3, welcomed and accepted, at least to the extent the discovery was limited to the scope of the admitted issue and conformed to NRC's Rules of Practice. ~MFP's First Set of interrogatories and document' requests, however, is 2' "Intervenor San Luis Obispo Mothers for Peace Request to-Pacific Gas and Electric Company for ' Entry Upon the Diablo Canyon Nuclear Power Plant, Units 1 and 2, Pursuant to 10 CFR " dated February 1, 1993 ("MFP Discovery 2.741(a) (2) Request"). F " Pacific Gas and Electric Company's Preliminary Response to Discovery Request Filed Pursuant to 10 CFR 2.741(a) (2) and Motion for Protective Order," dated February 12, 1993 ("PG&E Preliminary Response"). 1

I '.1,; q 4: c: A,

Nonetheless,1 q

E -. completely inconsistent.'with the earlier approach'. PG&E remains willing to cooperate with MFP"in an approacli' along tlien if ~1ines' originally proposed by MFP. This can.be accomplished:at the-s j r time of the previously requested MFP site. visit. q -II. ANSWERS TO INTERROGATORIES e Interroaatory 1: Please identify the programs and procedures ' used to verify that-the actual environment 'in-the' as-installed-position, for both operating and accident conditions'over; the plant design lifetime,. forL each -safety-related-u structure, system and component' is, bounded >-by.the- ~ conditions - in its environmental and seismic? tests for life and aging. Answer to Interroaatory 1:. j Equipment at the Diablo Canyon plant meets the requirements of 10 CFR 50.49 and:10 CFR 50 Appendix A, " General Design Criteria;for ' + Nuclear Power Plants," " Criterion-4" (GDC 4).- Safety-relatedF items required' lto .be environmentally l qualified ~ are stipulated in .10 CFR 50J49,- " Environmental; q Qualification of Electric Equipment Important to Safety for Nuclear - Power Plants". Verification that installed safety-related electric! equipment is qualified for use' .in. normal-and' accidental? j l environmental conditions is controlled under theLrequirements of L. 10 CFR 50.49. Equipment'in this program is qualified to operate -{ l l' For.the~ purposes of; answering these Interrogatories, the: q terminology safety-related:. - and'. important-to-safety.. are: y considered synonymous': at ~ the Diablo. Canyon plant. This y position is established.in Inter-Departmental ~ Administrative' 3 Procedure ADl.ID1'.. ! s 'i P 2 ...l_,-

.s during its normal qualified life and for design basis' accidental conditions. The qualified life of such components is generally greater than 40 years. If the qualified. life for equipment in this program is less that-40 years, it is replaced at the end of its qualified life to ensure that it will perform its intended function during normal and design basis accident conditions. The. qualified life of these components is based on plant normal operational and accident design basis conditions. The procedures utilized to meet the requirements of 10 CFR 50.49 are NECS E3.13, AP C-451, AP D-756, DCM T-20, DCM T-12 and DCM T-15. GDC 4 requires that structures, systems and components important. to safety be designed to function when subjected. to -[ expected and postulated:

1) environmental effects associated with normal, maintenance, testing and accidents; and 2) dynamic effects of missiles, pipe whip and jets.

For safety-related equipment not within the. scope of.10 CFR. 50.49, controls are in place at the Diablo Canyon plant to address. I equipment design life. Program Directive (PD) TSI, " Plant Aging. Management" outlines the policy for programmatic activities directed to control age-related effects for systems, structures'and I components ("SSCs") to meet the plant design and licensing basis over the life of the plant. The Plant Aging Management Program is established to meet several objectives. These objectives - are:

1) to provide technical assurance that SSCs will continue to meet

! i i

t 1l t the plant design and licensing basis over'the' life of the' plant;

2) to further develop evaluation methods necessary to support aging management decisions; 3) to provide for plant SSC data collection.

and evaluation to support regulatory requirements concerning plant aging; and 4) to provide a process to integrate PG&E, industry and NRC aging experience and research with existing plans. Several procedures assist in supporting PD TGI objectives.- AP C-62, " Preventive Maintenance (PM) Living Program," states that the objective of the PM program is to ensure that safety-related and. certain non-safety related structures, systems and components are maintained such that they will perform their intended function during normal and emergency conditions. NPAP C-40, " General Requirements for Plant Maintenance Programs" requires that a PM program for equipment be established and maintained. It. requires that PM schedules be developed to specify schedules for equipment inspections and replacement of items that have a limited life or are susceptible to aging degradation, such as lubricants, filters, strainers, wear rings, bearings, seals, diaphragas, electrolytic capacitors, and power transistors in printed circuit boards. Procedure, AP C-750, " Maintenance Department Preventative Maintenance Program," describes the PM' program used by.the DCPP Maintenance Department. This procedure defines PM as "a program of scheduled tasks necessary to ensure safe and reliable equipment operation." The objective of the PM program outlines in AP C-750 s' t i is to ensure that safety related and non-safety related structures, systems and components arel maintained at the quality required to perform their intended functions. PM frequency considerations identified in AP C-750 consist of manufacturers' recommendations, operating experience, equipment history, licensing requirements, personnel safety, cost / benefit analysis, consequences of failure, system interactions, equipment duty cycle, environment in which the equipment operates, and ALARA. AP C-450, " Instrument and Controls Preventative Maintenance Program," describes the I&C PM program. The objective of this program is to ensure that plant equipment is maintained in a condition so that it will perform its intended function when-required. This goal is accomplished through periodic inspections, i calibrations, and functional testing. Equipment procurement specifications outline technical requirements of equipment supplied to the Diablo Canyon. plant in order that this equipment perform its design function. The equipment supplier typically recommends maintenance activities to provide assurance that the equipment performs as specified.- Reliability Engineering efforts are designed' to ass'ist; ' in - P establishing equipment f ailure mechanisms. Trending and reporting. of equipment failures is' performed in accordance with Procedure AP-

,4 C-40S2, " Plant Equipment Failure Tracking and Trending". This procedure provides guidelines for the systematic tracking, trending and' reporting of plant equipment failures. Equipment failure data is obtained from Action Requests, the Institute of Nuclear Power-Operations ("INPO"), the Nuclear Plant Reliability Data System ("NPRDS"), and supplemental data on specific components' and component failures supplied by the plant maintenance organizations. Spare and Replacement Parts Evaluations ("RPEs") are performed .nder procedures NECS E3.12, " Spare and Replacement Parts-Evaluation." This procedure establishes engineering evaluations for spare and replacement parts, and 'new items utilized for modification as well as new designs at the Diablo Canyon plant. This procedure is mandatory for safety-related items and applies to parts that are not " identical" spare or replacement items.- Under this procedure, technical evaluations establish that the replacement material, interface, inter-changeability, fit, form, and function attributes are satisfactory to establish application suitability. Design changes are controlled by procedure NECS - E3.6DC, "Diablo Canyon Power Plant Design Changes." This procedure sets forth how engineering initiates, processes, approves and documents design changes for the Diablo Canyon plant. Under this procedure, design changes are reviewed for safety and technical considerations. r - 0 i I Industry awareness of any failures of critical safety-related .i equipment-is also typically facilitated by NRC: correspondence,. usually in'the form of Information Notices, Generic-Letters, and l ( Bulletins. Procedurally, disbursement of this information is controlled by Inter-Departmental Administrative. Procedure (IDAP). XII.IDl, " Regulatory Correspondence Processing" and IDAP OP4.ID1,. " Assessment of operating Experience". This is extremely valuable since most of the equipment at the Diablo Canyon plant is'similar to that at other nuclear plants; consequently,. information on j failure trends is gathered from a much larger data base. l t Other procedures for inspection,. maintenance,. calibration, periodic equipment walkdowns, monitoring, surveillance, and testing are found in Volumes 1, 1B, 5A SB, SC, 6 and 16 of the. Diablo - l Canyon Plant Procedures. These procedures will be available for review at the Diablo Canyon plant at the time of the MFP site s visit. Interrogatory 2: Please identify the programs and procedures 'used to' verify that the actual environment in.the as-installed. position (for both operating and accident conditions over l the plant design lifetime) for each non-safety structure, l system and component whose failure.could.' prevent satisfactory accomplishment.'of safety functions, is j bounded by the conditions in its environmental and seismic tests for life and aging. Answer to Interrogatory 2: See Answer to Interrogatory 1. The non-safety related SSCs j that are qualified by environmental or seismic testing, i f --

~1 N L applicable, due to their relationship with safety-related SSCs also consider service life and use through the whole process of design, testing,. maintenance, and surveillance. r Interroaatory 3: Please identify each safety-related and important-to-safety structure, _ system and component .whose qualification and aging tests do not bound the possible environmental and seismic conditions over the - plant design lifetime in its installed location. For each such identified item, please provide the details of actions that have already been taken and actions that are planned 1 to be taken in response to this situation. Answer to Interrocatorv 3: There are no safety-related structures, systems and components - whose testing and/or qualification does not bound the design environmental conditions at DCPP. Items within the scope of 10 CFR 50.49 have established qualified lives (and replacements installed, when required) for the lifetime of the plant; items not in the scope of 10 CFR 50.49 are designed, purchased, and maintained to ensure operability over the lifetime of the plant. Interroaatory 4: Please identify each safety-related and each important-to-safety structure, system and component whose testing and operation during manufacturer's checkout, burn in, environmental qualification, and aging tests, combined with PG&E's system testing, startup testing and operation i prior to full power license have rendered the remaining qualified life less than the plant design life as, reflected in the current operating ' license. For each such identified item, please provide the details of actions that have already been taken and actions that are planned to be taken in response to this situation. r < h

Answer to Interroaatorv 4: Qualified life, as the term is apparently used in this interrogatory, is applicable to ' safety-related items within the scope of 10 CFR 50.49. The qualified life-is' based on informal design operation and design basis accident parameters. System-testing, startup testing and operation prior.to full power license is not considered to affect a component's qualified life. Test specimens utilized in environmental qualification and aging testing are not used in the plant. Generally, plant normal environmental conditions used to determine qualified lives are more severe than actual normal operational conditions. Components that have-qualified lives less than expected plant life are replaced so that they will operate properly and within the design basis over'the life of the plant. The seismic qualification of all safety related equipment and components have been performed using DCM T-10. The Appendix to DCM T-10, NEP001, provides a list of equipment and components that ~have been seismically qualified. All safety-related equipment. and components have been seismically qualified for at least 40 years of plant life. 7 Interroaatorv 5: Please identify each; safety-related'and each important-to-safety structure, system.and component whose testing and operation during manufacturer's. checkout, burn in, i environmental qualification,.and aging-tests,l combined with PG&E's system testing, startup-testing and operation prior to full power license have rendered the~ remaining qualified life less'than the plant life as reflected in the current operating license plus the extension request in this proceeding. For each such: identified. item, please provide the details of actions that have already been taken and actions that are planned to be taken in-response to this situation. Answer to Interrocatorv 5: See Answer to Interrogatory 4. Interrocatorv 6: Please describe in detail how PG&E demonstrates that the performance or condition of a safety-related or important-to-safety structure, system or component is being effectively controlled through the performance of appropriate-preventive maintenance. Answer to Interrocatorv 6: PG&E's surveillance inspection and-testing programs provide assurance that systems ~, structures, and components needed for safe and reliable plant operation will perform within their required-limits. Administrative Procedures AP C-3S1 describes the surveillance testing and inspection program used at the Diablo canyon plant, including responsibilities, scheduling, performance, determination of equipment operability, review and reporting of f results. I !

x .r t i Diablo Canyon's Predictive Maintenance Program enhances plant safety and reliability through early. detection and diagnosis - of equipment degradation prior to equipment failure..The tools used t in the predictive maintenance area include' thermography, vibration - analysis, oil analysis, acoustic monitoring and ~ motor operated-valve diagnostics. Administrative Procedure AP C-751 describes the - details of the Predictive Maintenance Program. In addition to the above, the Preventive Maintenance Living Program determines the applicable Preventive Maintenance ("PM") tasks, documents engineering evaluations, makes modifications-to existing PMs, and tracks performance thereafter. Specific details. of this-program are contained in the AP C-62 series of administrative procedures, which will be available at the Diablo Canyon plant for review. Interroaatorv 7: During the operating life of the Diablo Canyon plant, what structures,

systems, and components that are important-to-cafety (and/or - safety-related) have - boon unavailable due to performance of monitoring or maintenance?

For ;each such structure,

system, or component, please state ' the length of time it. was unavailable and the month' and year during which the unavailability occurred.

Answer to Interroaatorv 7: PG&E objects to this interrogatory. The interrogatory is overly broad and requests information outside the scope of the-contention, as admitted by the Licensing Board. Plant Technical -t specifications allow equipment to be unavailable for limited , i b

t E. i amounts of time.- Therefore, it'is' routine'for equipment to be -s " unavailable due to performance of monitoring or maintenance." Production 'of all' such information not only would result in : a voluminous quantity of documentation, but also would obscure the- ? issue posed by Contention I; i.e., the. implementation of. an i effective and comprehensive maintenance and surveillance program at 7 the Diablo Canyon plant. This is an example of an unfocused, "finhing expedition" approach to discovery. Interroaatorv 8: What actions, if any, has PG&E taken in. response to the INPO standard (INPO 90-008) Maintenance Proarams in the Nuclear Power Industry? What quantitative results does PG&E attribute to the actions taken.in response to INPO j 90-0087 Please provide these results for each unit of Diablo Canyon compared to performance prior to applying the standard, and to the industry as a whole. Answer to Interrocatorv 8: PG&E has taken no specific actions in direct response to INPO 90-008, but generally strives to meet the qualitative criteria stated in INPO 90-008. Interroaatorv 9: Please provide the. definition of " surveillance" as currently used in the Diablo Canyon quality assurance (QA) program. Answer to Interroaatorv 9: The " Quality Assurance Manual'for Diablo Canyon Power Plant - Glossary of Terms," dated November 1, 1985, defines " Surveillance b Tests" as "[t]esting required by the facility Technical' I Specifications to assure failures, degradations, or substandard :

performance of important plant equipment do'not remain undetected j and reliability of safety-related systems is maintained.(Source ANSI N18.7)." Interrocatory 10: Please provide the definition of " surveillance" as used in the Diablo Canyon Units 1. and 2 Technical. Specifications. Answer to Interrocatory 10: Technical Specifications ("TS") for the Diablo Canyon. plant do not explicitly define " surveillance." However, TS Section 3/4 specifically identifies the required " surveillance testing." Interrocatory 11:. Please provide the definition of " surveillance" as used in the Maintenance Program for Diablo Canyon Units.1 and j 2. Answer to Interrocatory 11: Nuclear Plant Administrative Procedure (NPAP) C-3, " Conduct of l Plant and Equipment Tests," defines " Surveillance Tests" - as " Periodic tests and/or inspections to verify that structures,. systems, and components continue to function in accordance with predetermined specifications,.or are in a state of readiness.to i perform their safety functions." Interrocatory 12: Please identify all reports and audits by PG&E and/or outside consultants which have reviewed the maintenance and/or surveillance. of safety-related structures,

systems, and/or components.

In identifying these documents and studies, please indicate the titles, dates, authors, number of volumes, and the number of pages'in each volume.

i 1

' Answer to Interroaatorv 12: PG&E objects-to this request to the extent 'it requests 'f information unrelated to the current performance and effectiveness f of Diablo Canyon's maintenance and surveillance programs. Such.a request, unfocused in time, is.overbroad and burdensome. A' substantial level of effort would be required to identify all of the requested information for the life of the plant (both units). The contention at issue should, of necessity, focus - on curre'nt maintenance and surveillance efficacy. Historic performance in~ general, and specific long past " reports and audits" would have no [ I materiality or probativity in the present proceeding. Accordingly, PG&E has restricted its review, of the-Interrogatory to responsive information for calendar years.1990 to present, which roughly corresponds to the last two NRC Systematic Assessment of Licensee Performance ("SALP") periods. With this restriction, the following is or will be provided:- A. list of Maintenance and Surveillance Non-conformance. Reports ("NCRs") (provided as Attachment 2);' A list of-Quality Assurance Department audits and'other assessments and oversight reports (which will be provided. at.the Diablo Canyon plant at the time of the MFP site visit); A list of Quality Control inspection reports (i.e., the "QC Surveillance Log" - (dated' 2/26/93) provided in the. l Answer to Document Request 20); Onsite Safety Review Group monthly summaries, January, 1990- December,1992 (which will be made available at the Diablo Canyon plant at the time of the MFP site visit); A copy of the Maintenance Process Improvement Project ("MPIP") Final

Report, "Taking Maintenance Beyond',

Excellence," December 1992 (provided _in the Answer to - t Document Request 20); 'A, copy of Nuclear Excellence Team,.-Diablo Canyon Maintenance Program Assessment,. Final Report, dated August 27, 1991 (which is provided herewith); j "1992 NPG Self Evaluation -- Maintenance : Services" (a copy of which will be provided at the' time of the MFP plant visit). Interroaatory 13: Please describe the process used at Diablo Canyon for tracking the surveillance activities wnich'are required a to be performed. Answer to Interroaatory 13: To respond to this Interrogatory, PG&E is providing a copy'of

i Diablo Canyon plant Administrative Procedure AP C-3S4,. "Use of PIMS Recurring Task Scheduler."

_i Interroaatory 14: Please provide a. description of.PG&E's document control system used .to track and control safety-related documentation. for Diablo Canyon - (including hard' copy, i computer systems, microfiche, and other media such as - CD-ROM). j Answer to Interroaatory 14:. As responsive to this Interrogatory, ~ PG&E is providing ~ copies of four documents: Program Directive AD3, " Document Control"; Diablo Canyon Plant Procedure AP E-2, "PG&E Drawing, Aperture Card and Record Print Control"; Program Directive AD10, '! Records"; and NPAP E-1, " Retention & Extended Storage of Operation Phase Activity Records." i i r n

u ? E Interrocatory 15: Please identify all safety-related' structures, systems, a and components which have experienced degradation or life a reduction due to plant testing in the 1970's'and 1980's. j Answer to Interroaatory 15: See Answer to Interrogatory 4. Any such equipment is covered by normal maintenance and surveillance programs as described in'the Answer to Interrogatory 1.

l Interrocatory 16

1 Please describe the number and classification of j personnel working on the maintenance and surveillance r activities related to safety-related structures, systems and components at Diablo Canyon Units 1 and 2. Answer to Interrocatory 16: As responsive to this request, PG&E is providing a one page i document titled " Manpower Levels Summary." Interrocatory 17: P'. ease describe the number of maintenance ~ items gincluding both routine and non-routine items) which were backlogged at the end of each calendar quarter in 1991 and 1992. (If data is not available 'on a quarterly basis but is available on some other interval, such as monthly, please provide the other data.) Answer to Interroaatory 17: As responsive to the Interrogatory, PG&E is providing - a document titled " Maintenance Department Backlog" and Explanatory Notes. Interroaatory 18: Please describe the training procedures and retraining schedules for maintenance personnel at Diablo Canyon. i l

a Answer to Interrocatory 18: The. training procedures governing maintenance personnel are: Mech'anical Maintenance, 'AP B-751; Electrical Maintenance,.AP' B-752; Instrument and Controls, TQl.DC30; and General Construction, GCP 2.2, GCP 2.3, and PI-64. These procedures will be-available for-review at the Diablo Canyon plant. The maintenance training programs at the Diablo Canyon plant are accredited by the Institute of Nuclear' Power Operations ("INP0"). They are based on a Systematic Approach to Training-process (" SAT"), that involves analysis, design, implementation,- evaluation and revision. The SAT process is a form of continuous-improvement. Maintenance workers are qualified on specific tasks prior to being allowed to perform the task independently. Each. procedure delineates the program specifics for-the various disciplines. Each defines a basic level of training that'is given: to all journeymen as well as specific advance tasks given ' to selected individuals. 'i Continuing training consists of 40 to 80 hours of training per year on: industry and plant lessons learned, procedures / program changes, advanced task training, and refresher training on selected 4 topics. General construction ("GC") training is not_ task-based for crafts. It is procedure-based. GC crews are trained on how to

' d/ 9-1 M conduct maintenance. GC crews do not work. independently;[th'ey_ work ~ @"i under const' ant: supervision. and direction [of - al field; engineer, eInterroaatorv'19: e Please : identify all Licensee Eventi Reports n (LERs) and' L Non-Conformance Reports (NCRs)~ issued by PG&E;for Diablo; Canyon. Units 1 and/or'2 which relate to' maintenance ^or surveillance activities. Answer to Interroaatory 19: A list of ' NCRs which relate to maintenance' or surveillance activities is provided as part of Answer to Interrogatory 12, above ' ); .o (see Attachment 2). 1 A list of Licensee Event Reports ("LERs") issued;from 1990 to? -4 present which relate to maintenance and/or, surveillance activitiies f i! is being provided in response to this interrogatory..(see' Attachment':, j

3. ) -

i For the same reasons stated in Answer to Interrogatoryil2, .above, PG&E objects to'~ Interrogatory 19 to th'e extent it-: requests: 73 information unrelated to the current performance:and'effectivenessi of PG&E's maintenance and surveillance programs. PG&E Ilas: issued' 3 1 1990 as a cut-off date for identifying NCRs'and LERs. 's Interroaatorv 20: Please describe. the procedures for verifying and ~ j documenting the experience-level'and qualifications.of-3 contract personnel brought into Diablo Canyon to work on. maintenance and' surveillance activities. 1 l ; i 4 - - t,

Answer to Interroaatory 20: 1 Incoming contract-personnel for outages are trained, qua'lified and documented in conformity to the following procedures:. Mechanical Maintenance, AP B-751; Electrical Maintenance, AP B-752;- Instrument & Controls, TQ1.DC30; General Construction, GCP 2.2, GCP - 2.3, PI-64; Quality

Control, NPAP B-800, AP B-850.

These. procedures will be available for review at the Diablo Canyon plant. supporting craft personnel are hired from local union halls. The unions are responsible for tracking and determining the requirements for a journeyman classification within their respective unions. Once workers are brought on site, they are processed through the access organization and receive General Employee Training. At that point, they may be assigned to the [ plant line departments or to a General Construction crew. If they are assigned to the plant line departments, they are tested, i trained and qualified on the specific tasks. If they are assigned to General Construction, they receive training on how maintenance is performed at the plant. They are then assigned to a crew which has a full time supervisor responsible for directing the work. Instrument & Controls technicians for outages are hired either from local union halls or through a contracting agency. In both cases, applicants' resumes are reviewed and selected for hire. The ] technicians are processed through Access and General Employee l Training and then tested and qualified to perform specific ~ tasks. s

m 1 Individuals-brought in to work for contractors - such as Westinghouse are considered task specialists. Task specialists are= exempted from the above procedures. Their training and qualifications are the responsibility of the contractor bringing them on site. Often additional training is conducted - on site. specific mockups once they are on site. An example would be the Steam Generator crews brought in by Westinghouse.: -Contract inspectors brought in for outage work are assigned to either the plant or General Construction. In both cases, the individual resumes are reviewed and the contractors are trained and tested on the specific tasks they are to inspect. -Jnterroaatory 21: What is the staffing level at each unit of'the Diablo- [ Canyon plant devoted to preventive maintenance activities and to corrective maintenance activities? Answer to Interroaatory 21: There are three Sections within the Maintenance organization at the Diablo Canyon plant: Mechanical, Electrical, and Instrument & Controls. Total staffing equals approximately 315 PG&E personnel during non-outage periods. Each Section is responsible for preventive and corrective maintenance activities which fall under-their jurisdiction for both units. No Section or part thereof is devoted exclusively to corrective maintenance. or preventive maintenance activities. Interroaatorv 22: Please identify the INPO document (s) which provide recommendations concerning the magnitude of outstanding ;

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o q

'f preventive'and corrective maintenance activities which nuclear power plants should strive not to exceed. Answer to Interrocatory 22: There are 'no current INPO documents that provide such' recommendations. Interroaatory 23: Based on INPO-recommended levels of outstanding i preventive and corrective maintenance activities (i.e., backlog), how have the. levels of outstanding items over each of the last three years at each unit of the Diablo Canyon plant compared to the INPO average?- Answer to Interroaatory 23: INPO performance indicators on preventive and corrective maintenance were discontinued in 1991 because of their limited I usefulness for plant-to-plant comparisons. PG&E objects to' ~ the - 1 request to the extent it would request INPO performance-indicators.- .t for years prior to 1991. INPO performance data, including plant comparisons, is generally and customarily withheld from public disclosure. See cenerally critical Mass Enercy Proiect v. Nuclear Beaulatory Comm'n, 931 F.2d 939, 946 (D.C. Cir. 1991). .This' practice, stems from the fact that the confidentiality of INPO data --3 is crucial to the accuracy and value of that data. & at 941. More importantly, in the context of the present case, the requested: INPO industry performance indicators would be immaterial and unnecessary to a proper decision. As mentioned, these indicators were discontinued in 1991 expressly due to-their lack - of usefulness. Furthermore, industry performance prior.to - 1991 is very remote to the issues in this proceeding. Such data would have 4,

t little; bearing on the current _ effectiveness of implementation by PG&E of the maintenance program. Jnterroaatory 24: Have you identified important-to-safety components for which the actual operating environmental conditions are not bounded by the environmental parameters used to precondition the equipment to its end-of-installed life conditions? If so, for. each such case, identify - the component and describe the action (s) that have been taken or are planned to be taken. Answer to Interroaatory 24: No. There are no important-to-safety components for which the actual operating environmental conditions are not bounded by the environmental parameters used to qualify the equipment. Safety-related components that could be exposed to harsh-design basis accident environmental conditions that have qualified lives that are less than the design life of the plant are replaced before they reach end-of-life condition. III. REOUESTS FOR PRODUCTION OF DOCUMENTS B. Maintenance and Surveillance (Attachment E) Document Recuest 1: Please provide a copy of PG&E's comments to the NRC regarding the proposed maintenance rule (now-in the regulations as-10CFR50.65 to be effective by July 10,. 1996). This should include comments by PG&E and by any and all organizations representing PG&E's interests (e.g. NUMARC). Answer to Document Reauest 1: PG&E objects to this request. PG&E can discern no relationship between generic comments on the proposed maintenance rule and the specific maintenance program now being implemented at w the Diablo Canyon plant. Moreover, any_ issues of compliance with the maintenance rule are outside the scope of this proceeding. The rule,10 C.F.R. S ~ 50.65, does not become ef fective until_ July 1996. Nonetheless, all comments on the proposed rule would be available-to MFP in the NRC's Public Document Room. Document Reauest 2: Please provide a copy of all correspondence between PG&E and. the NRC related to the proposed maintenance rule (10CFR50.65) and its implementation at Diablo Canyon. Answer to Document Reauest 2: f PG&E objects to this. request essentially for the same reasons-stated in response to Document Request 1 above. Compliance with the maintenance rule, or even present plans for compliance, are not matters in issue in this proceeding. At such. time as the maintenance rule becomes effective, PG&E's compliance - will be a - matter for NRC inspection and/or enforcement oversight. Nonetheless, docketed correspondence between PG&E'and the~NRC on this matter would be available to MFP in the NRC's Public Document Room. Document Recuest 3: Provide a copy of the program and procedures used to verify. that the actual environment in the as-installed position, for; both operating and accident conditions over the plantLdesign.

lifetime, for each safety-related structure, system.and-component is bounded by_the conditions in its environmental and seismic tests for life and aging.

Answer to Document Reauest 3: See Answer to Interrogatory 1. Copies of documents referenced. therein will be made available at the Diablo Canyon plant. [6< t Document Reauest 4: t Provide a copy of.the program and procedures used to-verify that the actual environment in the as-installed position, for -i both operating and accident conditions over the plant design lifetime, for each important-to-safety structure,' system and component is bounded by the conditionsL in its; environmental and seismic qualification tests for life'and aging. Answer to Document Reauest 4. See Answer to Interrogatory 1. Documents referenced therein-will be made available at the Diablo Canyon plant. Document Reauest 5: r Provide a copy of the procedures covering maintenance and surveillance of safety-related and important-to-safety structures,

systems, and components. whose testing 'and operation during manufacturer's

checkout, burn in, environmental qualification, and aging. tests, combined with PG&E's system testing, startup testing and operation prior'to

-full power license have rendered the remaining qualified life less than the plant design life and reflected'in the current operating license. l Answer to Document Reauest 5: See Answers to Interrogatories 1 and 4. Documents referenced j r therein will be made available at the Diablo Canyon plant. Document Reauest-6: Provide a copy of the procedures covering maintenance and-surveillance of safety-related and important-to-safety structures, systems,. and components whose testing and j operation during manufacturer's

checkout, burn in, environmental qualification, and' aging tests, combined with i

PG&E's system testing, startup testing and operation prior to full power license have rendered the remaining qualified life less than the plant life as reflected in the current operating license plus the extension request-in this proceeding.- ? . j

Answer to Document Reauest 6: See Answers to Interrogatories 1 and 4. Documents referenced therein will be made available at the Diablo Canyon plant. Document Reauest 7: Please provide the latest (most recent) report from the tracking system used to track the surveillance of safety-related structures, systems, and components at the Diablo Canyon plant. Answer to Document Recuest 7: The requested report, "STP Report (03/03/93)," is. being provided.- r Document Feauest 8: Please provide a list of the Diablo Canyon plant structures, systems and components which are safety-related. If a key to acronyms and abbreviations is available for this' listing, please also provide this key. Answer to Document Reauest 8: PG&E objects to this document request as vague. It is not clear what " list" is referred to. PG&E has previously provided MFP with the Diablo Canyon plant "Q-list". In addition, the Updated' FSAR generally contains descriptions of safety-related and important-to-safety systems, structures, and components. l Document Beauest 9: Please provide a list of the Diablo Canyon plant structures, -i systems and components which are'important-to-safety but are not safety-related. If a key to acronyms and abbreviations is available for this listing, please'also provide this key. Answer to Document Reauest 9: See Answer to Document Request 8., [

.e 'd Document Reauest 10: P12ase provide a copy. of the

policy, procedures, and instructions for maintenance of structures, systems and components which are safety-related to Diablo Canyon. Units 1L and 2.

- Answer to Document Reauest 10: PG&E is providing relevant Tables of Contents listing maintenance and surveillance procedures. .MFP can review these. lists to select procedures that it would.like to review while-at-L -the Diablo Canyon plant. In addition, PG&E has already provided to - the technical consultants for MFP (by letter from PG&E-counsel dated March 3, 1993) copies of three " umbrella" maintenance -procedures. These are identified in Attachment 1. l Document Reauest 11: Please provide a-copy of the

policy, procedures,.~and instructions for maintenance of structures, systems and; components which are important-to-safety but not safety--

related at Diablo Canyon Units 1 and 2. Answer to Document Reauest 11: See Answer.to Document Request 10. Document Reauest 12: l Please provide a copy of the

policy, procedures, and instructions for maintenance of structures, systems' and con.ponents which are neither important-to-safety nor safety-related at the Diablo< Canyon plant.

Answer to Document Reauest 12: PG&E objects to this request. The request, by. its terms, ~ relates to equipment'that is neither safety-related nor important-to-safety. Maintenance with respect to such equipment would appear ; l' I L

to have no bearing on either the ef'fectiveness of the Diablo Canyon plant maintenance program or PG&E's implementation of that program, at least to the extent that the program or its implementation would - have relevance to the license amendment at issue in this proceeding. Maintenance on equipment unrelated to safety is not a factor of significance in determining whether the amendment to allow the full, design basis, 40-year operating life should be granted. Document Reauest 13: Please identify the location, within the Diablo Canyon Updated FSAR and other plant descriptive documents provided to the NRC in the licensing

process, of the description of the requirements and process for conducting-surveillance maintenance and periodic' replacement of structures, systems and components which are safety-related but have a-qualified life shorter than the licensed plant life.

Please provide the + Updated FSAR references including sections and page numbers. If the requirements and descriptions are in documents other than the Updated FSAR or are in documents other than those provided to the NRC, please also provide a copy of these additional documents. Answer to Document Recuest 13: See Answers to Interrogatories 1 and 4. Documents referenced therein will be made available at the Diablo Canyon plant. Document Reauest 14: Please provide a list of the structures,

systems, and components which are safety-related but which are known-(for

example, as a

result of environmental and/or seismic qualification testing) to have a qualified design life that is less than the duration of the current plant license. For' each such' structure,

system, and/or component, please provide copies of the surveillance and maintenance procedures and instructions applicable to that item.

' i 1

1 Answer to Document Recuest 14: PG&E objects to this request as overbread. It can be accepted as a given that, over the operating life of a nuclear power plant, some equipment will degrade 'and/or wear out. That is, the 'l qualified or operational life of the equipment is less than'the full operating lifetime of the nuclear plant. Maintenance. and surveillance programs are designed to address exactly this consideration. These programs include both predictive and reactive maintenance. Structures, systems, and components, that are safety-related or important-to-safety and subject to maintenance' are i generally described in the Updated FSAR. A " list" of such t equipment would impart very little useful information in the-context of this proceeding. The request for " copies of surveillance and maintenance procedures and instructions" applicable to all such equipment would encompass voluminous I documentation and is simply overbroad. i Document Reauest 15: l Please provide ~ a list of all safety-related structures, ~ systems, and components that have a qualified design life - i measured from a date prior to receipt of the full-power i Operating License. For each item identify the start date of-the qualified design life period (month and year) and the qualified life (in year). ~ Answer to Document Reauest 15: No list responsive to this document request exists. See instead Answer to Interrogatory 1. Documents referenced therein i will be available for review at the Diablo Canyon plant. f :

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c

' Document " Recruest ' 16: Forf each 'of, thei equipment components.' or. systems : described. below,:please provide a copy 1of the maintenance.information' ~ from the equipment literature and instruction manuals provided-by the.vendorsE(vendor manuals)L:- ~ (a). Auxiliary l Saltwater System Pumps;- (b) Auxiliary Saltwater System Motors; (c) Atmospheric Steam' Dump' Valves; (d)- ' Suction ~ Cooling Suction Valves;- g q (e) Emergency. Diesel Generators; l (f) Supply l Fans for 480 volt'Switchgear Ventilation System;; d (g) Inverters for Vital Instrument Channels;; M (h) RWST Level Instruments; j a (i) Pressurizer Pressure Instrumentation; i i (j) 125 V DC Battery Chargers; l d (k) Emergency Lighting Batteries; andI u (1) Out-of-Core Start -up Neutron Detectors. Answer to Document Recruest 16: } PG&E objects to this request ~only insofar as.'it seeksia copyf S ~ of all the maintenance information'(vendor:information and; manual's): -for the equipment identified. ' PG&E' is providing, ' a : listE of :' .i documents available, within the scope - of. ' the request, for : the! equipment.. identified.. S _e Attachment 4. PG&E?does'notyagree to ee e [ unnecessarily copy-this information. PG&E[. willi make 'thisi M finformation available-to.MFP,-or its technical consultant,.at=thei 'Diablo Canyo'n plant. MFP may, at that time,/ review. documents andj j make such copies'as it wishes'. d Ll a. - .d -) }ja.t 1

e Document Recuest 17: Please provide the process of tracking the maintenance activities which are normally required to be. performed on systems, structures, and' components which are important-to-safety (including safety-related structures,

systems, and components), and provide a copy of the most recent report (s) generated by this tracking system.-

Answer to Document Reauest 17: In response to this request, PG&E is providing a printout of Electrical Work Orders and Recurring Task Activities. Document Reauest 18: Please describe the process of tracking maintenance activities which need to be performed but have not yet been completed (i.e., backlogged), and provide the most recent report (s) generated by this tracking system. Answer to Document Reauest 18: PG&E is providing a Mechanical, Electrical, and Instrument &' Controls Backlog Statistics report. Document Reauest 19: Please provide a copy-of the policies and procedures setting forth the requirements and qualifications. of contract + personnel to be used in maintenance and surveillance activities at Diablo Canyon Units 1 and.2. Answer to Document Reauest 19: Copies of the following procedures (as referenced in the Answer to Interrogatory 20) will be available during the upcoming plant visit: Mechanical Maintenance, AP B-751; Electrical Maintenance, AP B-752; Instrument & Controls, TQ1.DC30; General Construction, GCP 2.2, GCP 2.3, PI-64 ; Quality Control, NPAP B-800, AP B-850. l . l

Document Reauest 20: Please provide copies of. all reports and audits by PG&E and/or outside consultants which have reviewed-maintenance and/or surveillance activities at Diablo Canyon. Answer to Document Recuest 20: See Answer to Interrogatory 12. A copy of the MPIP Final Report, "Taking Maintenance Beyond Excellence," as referenced in I the Answer to Interrogatory 12, is being provided.- In addition, PG&E is providing the Diablo Canyon plant "QC Surveillance-Log," dated February 26, 1993. Other documents and lists of documents' l identified in the Answer to Interrogatory 12 will be available for. review at the Diablo Canyon plant. Document Reauest 21: Please provide the policy, procedures, and instructions for performing surveillance of the safety-related structures, systems, and components at Diablo Canyon Units 1 and 2. Answer to Document Reauest 21: PG&E is providing copies of the following procedures: Nuclear. Power Generation Program Directive AD 13, Te st Control"; Administrative Procedure AP C-3S1 " Surveillance Testing and-Inspection"; Administrative Procedure NPAP C-3, " Conduct of Plant and Equipment Tests." Document Reauest 22: 1 Please provide copies of all Licensee Event Reports (LERs) and Non-Conformance Reports (NCRs). issued by PG&E for. Diablo' Canyon Units 1_ and/or 2 ' which related to maintenance or' l surveillance activities. i l ; i 1

Answer to Document Recuest 22: See Answer to Interrogatory 19. Copies of-the listed LERs and NCRs will'be made available at the Diablo Canyon plant. Document Reauest 23: Please provide copies of the procedures for verifying and documenting the experience level and qualifications of contract personnel brought into Diablo Canyon to work on - maintenance and-surveillance activities. Answer to Document Reguest 23: See Answer to Interrogatory 20. Copies of documents will be-available for review at the Diablo Canyon plant. Document Reauest 24: Please provide copies of all reports and audits by PG&E and/or outside consultants which have reviewed the maintenance and/or' surveillance of safety-related structures, systems,- and components. Answer to Document Reauest 24: See Answers to Interrogatory 12 and Document Request 20. Document Reauest 25: Please provide copies of the INPO document (s) which provide. recommendations concerning the magnitude of outstanding. preventive and corrective maintenance activities which nuclear power plants should strive not to exceed. Answer to Document Reauest 25: i See Answer to Interrogatory 22. Document Reauest 26: Please provide copies of the numeric, graphic, and written descriptions prepared by PG&E over the last three years of the Diablo Canyon plant's performance compared' to the INPO recommendations for outstanding preventive and corrective maintenance activities. l l 1

Answer to Document Recuest 26: See Answers to Interrogatories 12 and 23. Document Recuest 27: Please provide equipment qualification files for all electrically-operated valves inside containment (e.g., motor-operated valves, solenoid-operated valves,. and pilot-operated valves) that are on systems important-to-safety. For each such valve, provide. all records of ambient temperature, radiation,'and humidity at the location of the valve during its operating life. Answer to Document Reauest 27: PG&E objects to this request. The request for equipment qualification ("EQ") files addresses an irrelevant matter and,'in any event, is overbroad. The Diablo Canyon EQ program is'not an issue in this proceeding. EQ is a design consideration; not a maintenance matter. Contention I does not create the opportunity to litigate design matters that were subject to review.. and litigation prior to initial licensing. Moreover, it is a~given-that the EQ files define-a qualified life for electrical equipment and that equipment will be changed out at the end of the qualified life. This fact has no bearing on whether the requested license amendment should be granted. In addition, to the - extent PG&E's implementation of EQ maintenance is-an issue, the request for the EQ files is overbroad. 5 i

.i 1

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-?.

i ~ 4.; 6.s o. ? .'i$- .r The fil'es representia. vast amount;;of'. design'information"with1no;- bearing on plant _ maintenance.

[-

. Respectfully submitted,: h \\= ~ { l, [ J_oseph;B.".Knotts,. A.. E David;A.-:Repkall_ _ b 'Kathryn Mc-lKalowskya s WINSTON4 &iSTRAWN 1400;LLStreet,TN.W.. _. Washington,7DCi.:20005-3502'- (202)'.371-5726; ChristopherfJ.0 Warner, f Richard F.(Locke'. PACIFIC GAS AND ELECTRIC COMPANYI r

77 Beale1StreetJ o

r-:

San-Francisco,.-CAOi94106

.-Attorneys for'PacificLGas}andll l Electric. Company: ' Dated-in Washington',;DC this 12th day of March,.1993-c 4 4 l.g c?; ?

il? 4 - ;

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== E00"3Ded-16101 ac r . UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter oft ) } Docket Nos. 50-275-OLA Pacific Gas and Electric Company ) 50-323-OLA ) { Construction-Period (Diablo Canyon Nuclear Power l' Recovery) Plant, Units 1 and 2) ) ) t AFFIDAVIT I, Bryant W. Giffin, being duly sworn, hereby state as follows. 1. I am employed by Pacific Gas and Electric Company as Manager, Maintenance Services. 2. My business address and phone number are: Diablo Canyon Power Plant 104/5/505 P. O. Box 56 'Avila Beach, CA 93424 (805) 545-4168 3. I have provided the information which forms the basis for.the. answers to Interrogatories C-6, C-8, C-9, C-10,-C-11, C-12, C-13, C-14, C-15, C-16, C-17, C-19, C-21 and Document Requests'E-7, E-10, E-11, E-16, E-17, E-18, E-20, E-21, E-22, E-24, E included in the attached " Pacific Gas and Electric Company's Response to First Set of Interrogatories and Request for Production of Documents Tiled by San Luis Obispo Mothers for Peace." The information contained in the referenced interrogatory answers 4. and responses to requests for documents is.true and correct to the best of c:y knowledge and belief. - ) s ~ STATE OF CALIFORNIA Y""' "' "Ib" SS* COUNTY OF SAN LUIS OBISPD sworn and, subscribed to before me this @ day of March, 1993 oFfow.rsnAny s6At 4 a 1h8 CiSPROUL Notary Publict i

1. emmy Pwedio-Camponne t

cam t.us cepoooumY l Coun tgees SEPooses - A---- My commission expires: E00*3DWd MU7-53Nuem 01 E0073 HIG DN!n 33X3 WOMd PS:8 C64 ZILBWW' TOTAL P.02l

.. MAR 41 '93. 9:05 FROM TO~BISHOPCOOK PAGE 002/003 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THR ATOMIC SAFETY AND LICENSTNG BOARD In the Matter of: ) ) Docket Nos. 50-275-OLA-Pacific Gas and Electric Company ) 50-323-OLA ) (Construction Period (Diablo Canyon Nuclear Power ) Recovery) Plant, Units 1 and 2) ) ) AFFIDAVTT I, James A. Davis, being duly sworn, hereby state as follows. I am employed by Pacific Gas and Electric Company as Senior 1. Supervisor, Quality Assurance. 2. My business address and phone number are: 1 California Street,-Room 1820 San Francisco, CA 94111 (415) 973-3249 3. I have provided the information which forms the.-basis for the-answers to Interrogatories C-12, C-19 and Document Requests E-20, E-22, E-24 included in the attached " Pacific Gas and Electric Company's Response to F^rst Set of Interrogatories and Request for Production of Documents Filed by San Luis Obispo Mothers for Peace." The information contained in the referenced interrogatory answers 4. and responses to requests for documents is true and correct to the' .best of my knowledge and belief. t es Al'1Tavis .5YMd 0/~ 04bNog4jf Comry of 3dd Lai.s DAE/*b -Sworn and subscribed to before me this /pr# day of March, 1993 amsuu Y m 7 Notary Public W P w ar - c o mmen am uns onerocouwry 44 h Eames JuL gm g jf Q[ My #comad.s'sion expires: t

i ngpf"11.793 9:06-FROM TO BISHOPCOOK PAGE;003/BB3 ~. - 't 5 g UNITED STATES OF AMERICA NUCLEAR REGULATORY Col 45ISSION. BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .E In the Matter of: ) ) Docket Nos. 50-275-OLA Pacific Gas and Electric Company ) 50-323-OLA' I ) (Construction Period (Diablo Canyon Nuclear Power ) Recovery). Plant, Units 1 and 2) ) ) AFFIDAVIT i I, Paulette L. Prudhon, being duly sworn, hereby state as follows. i 1. I am employed by Pacific Gas and Electric Company as Engineer, Quality Control. 2. My business address and phone number are: Diablo Canyon Power Plant 104/3/8A. I P. O. Box 56 Avila Beach, CA 93424 1 (805) 545-4412 3. I have provided the information which forms the-basis for th'e - answers to Interrogatories C-12 and. Document Requests-E-20, E-24 included in the attached " Pacific Gas and Electric' Company's-Response to First Set of Interrogatories and Request for-Production of Documents Filed by San Luis Obispo Mothers'for. Peace." The infomation contained ~in the referenced interrogatory answers' I .4. and responses to requests-for documents is true-and_ correct to the~ i best of my knowledge and-belief. / A?/ k N V8>LJ Paulette L. Prudhon Sworn and subscribed to before j me. this jj26 day of March, 1993 j Notary Pub ic l omwoyAnyn [ ' j KATHY EhECK - h Notwy hanc-CaWome _._ mig // j/'fy g SAN WS OB4SPo CouvrY l Ny.@mmi[Asion' expires: My Cunn Eques ful3U996 I

• • TOTALEPAGE.00'31**L

~

11 AR.12b' 93 14: 21 F ROfi ~ T0 BISHOPCOOK PAGE.ue2<ua3L .

• nW-12-1993.15:15 FR31' 10 TEA'11TH FLO R P.C1 UNITED STATES OF AM2RICA.

NUCLEAR REGULATORY COMt4ISSION BEFORE *THE ATOMIC SAFE *lY_ AND L1t' WRING BOARD In the Matter of: ) ) Docket Nos. 50-275-OLA Pacific Gas and Electric Company ) 50-323-OLA ) (Construction Period (Diablo Canyon Nuclear Power ) Recovery) Plan t., Units 1 and 2) ) ) j Arr: DAVIT I, Richard C. Anderson, being duly sworn, hereby state as follows. 1. I am employed by Pacific Gas and Electric Company as Interimf Manager, Nuclear Construction Services. 2. My business address and phone number are: 333 Market Street, Ac,om A1411 San Francisco, CA 94105 t (415) 973-1252 3. I.have provided the infor:r.stion which forms the basis for, the answers to Interrogatuscles C-1, C-2, C+3, C 4, C-5, C-24 and Document Requests E-3, E-4, E-5, E-6, E-13, E-14, R-15 included.in-the attached " Pacific Gas and Electric Company's Response to-First Set or, Interrogatories and Request.for Production-of Documents Filed by San Luis Obispo Mothers for Peace." 4. The infomation contained in thw 4.eferenced interrogatory answers and responses to requests for documents:is true and correct to the best of my knowledge and belief. ff_ 0 STATE OF CALIFORNIA Richard C. Anderson 1 COUNTY OF SAN LUIS OBISPO 55' 1 Sworn and subscribed to before me this y day of March, 1993 f i Notary PubliM i WDoym morr eanc-c s4Ntus cesseo coucy 9-9-94 W asecem I My cot:enis'sion expires: '~~~'"~~~~~- i f ?!AR 12 '93 14:38 PAGE.001

93-14: 22 FROM. To BISHOPCOGN PAGE.003/003' f1 AR f12 # .. MrW-12-1993 15 16 FROr1 - TO f4tR -11TH FLIIJR P.22 UNITED STATES OF AMERICA NUCLEAR REGULA'ICRY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) ) Docket Nos. 50-275-OLA Facific Gas culd Electric Company ) 50 - 323 -01.A ) (Construction Period (Diablo Canyon Nuclear Pcwer ) Recovery) Plant, Units 1 and 2) ) ) AFFIDAVIT I, John M. Gisclon, being duly sworn, hereby state as follows. 1. 1 am employed by Pacific Gas and Electric Company as' Manager, Nuclear Operations Support. 2. My business address and phone nur.ber are: 77 Beale Street, Room 1485 San Francisco, CA 94105 (415) 973-475H 3. I-have provided the information which forms the basis.for the answers to Interrogatories C-22, C-23 and Documanc Requests E-25 included in the attached " Pacific Gas and Electric Company's Response to First Set of Interrogatories and Request for Production of Documents filed by San Luis Obispo Mothern for Peace." 4 The information contained in the referenced interrogatory'answere and responses to requests for docu:nents is true and correct to the best of my knowledge and belief. L 914. ck STATE OF CALIFORNIA . John M. Gisclou COUNTY OF SAN LUIS OBISPD Sworn and subscribed to before me this Rhday of March,1993 $4f t$lAk ot?ciduohnf 5 i. ) l Notary PubliM aws oasspomw j Comm Ee*= sEP 03,1gr,,4 ___ 9-9-94 My cccr:nission expires: T fMR 12 *93 14 18 TOTCt. P.22T - P AGE. BB2 '. ~,

• • TOTAL.PAGE.003 **:

ftAR 10 '93 16:27~'FROM TO BISHOPCOOR' PAGE.002/002 .11RR-10-1E393 ' 17:08 FRU1 TO. t5iR 31TH FLZ R. P.02 UNITED STATES OF' AMERICA f NUCLEAR REGULATORY COMMISSION-j BEFORE TEE ATOMIC EAFETY AND LI N Sht.EQARD In the Matter of: ) ) Docket Nos. 50-275-OLA-Pacific Gas and' Electric Company ) 50-323-OLA ) (Construction Period (Diablo Canyon Nuclear Power ) Recovery) planr., Units 1 and 2) ) ) AFFTTuvTT I, Dale R. Clifton, being duly sworn, hereby state as follows. 1. I am employed by Pacific Gas and Electric Company as Supervisor, Training. 2. My business address and phone :nzmber are: Diablo Canyon Power Plant 119/2/247 4 P. O. Box 56 Avila Beach, CA 93424 (805) 545-3380 3. I have provided the information which forms the basis for the answers to-Interrogatories C-18, C-20 and Document Requests E-19, E 23 included in the attached ' Pacific Cas and Electric Company's Response to First Set of Interrogatories and Request for Production of Documents Filed by-San Luis Obispo Mothers for Peace." 4. The information contained in the referenced. interrogatory answers. and responses to requests for documents is crue and correct to the best of my knowledge and belief. 1 /^ ,^ j / IIal'e R. Clifton [ i ' Sworn and subscribed to before me this /oA day of March, 1993 db I Nothry Ilfblic unnsecsc Noury PWWe-Camrne fao a am we e coumv 4/ /7/ Wr m 89rusJutst m e 4 f i TOTAL P.22 MAR 10 '93 16: 10 PRGE.222 .** TOTAL PAGE.002 **.

i ATTACHMENT 1 l CUMULATIVE INDEX OF DOCUMENTS PROVIDED TO MFP i Starting Ending Document-Bates No. Bates No. Date Document Descriction I.- DOCUMENTS PREVIOUSLY PROVIDED fBY LETTER DATED 3/3/931 i 000001 000233 06/14/92 Report-by PG&E titled " Classification of . Structures,, Systems, ar d Components for Diablo Canyon Units 1 and 2 (Q-List)," Rev. 14; USNRC Docket Nos. 50-275 and 50-323. 000234 000249 02/10/86 Diablo Canyon Plant Administrative Procedure,. " General Requirements for Plant Maintenance Programs," NPAP C-40, Rev. 3. 00025C 000271 09/01/92 'Diablo Canyon . Plant Administrative Procedure, " Instrument and.. Controls I Preventive Maintenance Program," AP C-450, Rev. 9 000272 000287 07/06/89 Diablo Canyon Plant Administrative Procedure, " Maintenance Department Preventative Maintenance Program," AP C-750, Rev. 10. II. THERMO-LAG fCONTENTION V) DOCUMENTS Interroaatory 4 000288 000296 12/05/88 Diablo Canyon Plant Administrative Procedure, " Plant Organization for Fire. Loss Prevention,* NPAP A-13,.Rev. 7 Interrocatory 5 000297 000334 04/28/92 Diablo Canyon Plant Administrative Procedure " Fire Loss Prevention," AP C-13, Rev 13. Interroaatorv 9 000335 000340 09/11/90-Diablo Canyon. Plant . Administrative-Procedure, " Qualification and Training. Requirements of-Plant Personnel. Specifically. Concerned with Fire Loss Prevention," NPAP,B-13,'.Rev. 5. =. Document Peauest 4 000341 000353 02/24/93 .Diablo Canyon. Plant Instructor Lesson-l Guide, Fire Prevention, FEFA320. Document Recuest 5 000354 000364 1989 NFPA 51B, " Standard for Fire Prevention in Use of Cutting and Welding Processes", 1989 Edition.

i e i h. -q',, It-Starting. Ending Document Bates No. Bates No. Date - Document'Descrirtion. Docun,ent Recuest 8-000365 000373-12/11/91' Diablo -Canyon. Plant-Administrative F' Procedures ". Fire System Impairment," NPAP-C-113, Rev. 7. 3, Document Recuest 9 000374 000390 10/8/92 Diablo,' Canyon : Plant ' Surveillance-Testa Procedure,' " Portable Detection. System. Installation,. Testing .and-

Operation.

1 Procedure," STP I-34J,.Rev. 0. ~' Document Recuest 19 l] Diablo Canyon Plant General ' Arrangement- ] 000391 000399 1 Drawings 515562, -63,l-68,L-69,--70,,-73,' -77, -78, and -80. Document Reauest 26 I Fire Watch Logs- (February 1,;1993, through.' O ~. 000400 001286-February 28, 1993).' 1 III. MAINTENANCE fCONTENTION I)' DOCUMENTS lll Interrocatory 12 002238 002262 08/28/91 . Nuclear Excellence.!. Team, Diablo.:- Canyon 4 Maintenance,. Program Assessment,. Final. , ;j Report,. August.27,

1991,

and-' cover memorandum from-E.C.:

Connell-to, B.W. l Giffin, dated: August 28,11991.c'" .M Interrocatory 13 j -001287 001300' 03/04/92 Diablo1 '. Canyon ' T Plant?.~Administratives 31 ? Procedure, "Use of e PIMS! Recurring e Task -- Scheduler, " AP C-354, Rev. 1. - Interroaatory 34-001301 001314 05/13/91 PG&E. Nuclear Power. Generation ' : Business Unit Program'. Directive,- - " Documents ' Control,". AD3,; Rev. O. I 001315 001323 ~08/09/91 Diablo3. Canyon . Plant' : Administrative 1 Procedure,.. -'

• PG&E '. Drawing, 3 Aperture ? Card.

1 and Record Print Control' " AP E-2,"Rev.- 7. e (. d - PG&E.' Nuclear.- Power Generation f Business L 001324 001330 01/12/93 . Unit Program > Directive,

• Records,." AD10, :

l . Rev. O.' 'j ' ? i .{ ci l') .t I r. s en m

Starting Ending Document Bates No. Bates No. Date' Document Description 001331 001337 11/03/89 Diablo Canyon Plant Administrative Procedure, " Retention and Extended Storage of Operation Phase Activity Records,* NPAP ' E-1, Rev. 6. ~ Interrocatory 16 a Diablo Canyon Power Plant Manpower Levels 001338 001338 Summary (Chart). Interroaatory 17 Explanatory Notes and Maintenance 001339 001340 Department Backlog (non-outage) Chart. Document Recuest 7 001341 001352 03/03/93 Diablo Canyon Power Plant.STP Report (TCR, 4080). Document Reauests 10, 11 Administrative . Procedures- ' Table-of 001353 001479

Contents,

.Vol.. 1; Plant. Electrical Maintenance' Procedures Table of Contents, Vol. 5A (2/25/93); Mechanical Maintenance Procedures Table of-Contents, Vol, 5B- ~ * (2/25/93); Instrument and Controls Maintenance Procedures Table of Contents, 't Vol. SC '(2/25/93); Surveillance. Test Procedures Table. of' Contents,- Vol. 6-(3/1/93); Instrument and controls Loop Test Procedure Index (2/27/93). Document Recuest 17 001480 001847 Lists of Electrical - RT-Work Orders and' Recurring Task Activities. Document Reaueet IB 001848 -001876 02/23/93 Explanation ~.of Terms. and Mechanical, Electrical' and Instrument and Controls (and all other Department STPS) Backlog Statistics: By Department. Document Recuest 20. 001877 001998 02/26/93 Diablo. Canyon Plant Quality control Surveillance / Inspection Log. 001999 002152 12/92 Maintenance Process-Improvement ~ Project - (MPIP) Final Report, "Taking MaintenanceL Beyond Excellence." ).

Starting.Ending Document ' Bates No. Bates No. Date Document Description Document Recuest 21 002153 002169 10/03/92 PG&E Nuclear Power ' Generation Business Unit Program Directive, " Test Control," AD13, Rev. O. 002170 002223 09/08/92 Diablo-Canyon Plant Administrative-Procedure, " Surveillance Testing and Inspection," AP C-3S1, Rev. 16. 002224 002237 03/24/92 Diablo . Canyon Plant Administrative Procedure, '" Conduct of Plant and Equipment : . Tests,"'NPAP C-3, Rev. 9. ~ 1 i I r b .) 4 e

LAttachm:nt?2 'Interrocatorv'12 ,g u . MAINTENANCE AND SURVEILLANCE NCRs' NCR NUMBER LINITIATE DATE JSUBJECTc-DCl-90-EM-NOO1 1-12-90 DedicationLof relayst DC2-90-EM-N028 4-19-90 'BTC 232/High" charging-current DC2-90-EM-N029 4-19-90 Valve 8805B'failhdt to meet- ~ ~ stroke.open-time DC1-90-EM-N042 11-90 SI-1-8805A Failed 4to; cycle- ~ on actuation signal 1 DC2-90-EM-N044 '6-11-90 1 Main generator load rejection l DCO-90-EM-N070 10-17-90 RHR motorT1-2 Work not_done-t in accordance with-work-9 order DCO-90-EM-N081 12-4 Uninterruptible power:-.supplyi -i for. Units 1: and 2 AMSAC:- (ATWS mitigationLsystem1and y circuitry).. failed. 'i i DC1-90-MM-N002 1-15-90 Failure 1 sleeves"onLcondenserv ~ DCO-90-MM-N013 3-16-90 Crosby relief valves "f DC2-90-MM-N016-3-28-90 Snubbers found'-locked. DC2-90-MM-NO23-4-17-90' ' Check valve MS-2-516' was 6 Efoundistuck open j

DC2-90-MM-N055 8-28-90 Snubber pinimissingj f

Et DC2-90-MM-N071 10-25-90 -FW-2-LCV-106 and.107J 3 -actuators 11nstalled- ~ DC2-90-MM-N078 111-16-90 FCV-152)leakoffiline ~ j supports ~not'per designL v DCO-90-MM-N089 12-21-90 Mechanical maintenance lM&TE DCO-91-EM-N009~ 1-21-91' IFCV-495/496[ corrosion) 7; prevented manualtvalve, 9 operation. .l

Iq

- Marchill,[1993l d l + a = li .w. L,

II MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE SUBJECT DC1-91-EM-NO27 3-6-91 RHR pump motor; screws missing from bearing housing cap DC1-91-EM-N041 2-5-92 ESF actuation - CVI DC1-91-EM-N046 4-29-91 Unit 1 trip, 4-24-91' manual trip of Unit 1 due to power increase DC2-91-EM-N077 9-12-91 MOV 9001B motor leads not joined with Raychem splices DC2-91-EM-N084 10-3-91 Bus 2-G fire in 480v motor control center after start of diesel ~ engine 2-1_ DC2-91-EM-NO86 10-3-91 Motor operated _ valve actuator failure DC2-91-EM-N095 10-25-91 Circuit breaker failed to open on power transfer-from auxillary.to: start-up transformer DC1-91-MM-NO15 2-13-91 ASW pipe support 286-72R unable.to perform design function DC1-91-MM-N018 2-19-91 Pipe. support stud found not welded to containment liner DC1-91-MM-N028 3-8-91 -Loss offoff-site power _to U1 because of grounding. incident between 500kv line and crane boom DCO-91-MM-NO34 3-15-91 Rigging from unapproved ~ structures s DCO-91-MM-NO37 3-22-91 Weld filler material not' controlled in accordance with nuclear weld control-manual , March 11, 1993 =

' MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER. INITIATE DATE FUBJECT DCO-91-MM-N042 4-3-91 Foreign material exclusion area control less than adequate DCO-91-MM-N049 6-6-91 DEG 1-3' test cock valve broke-when tightened DCO-90-MM-N057 8-31-90 Fire pump 0-21maint deficiencies DCO-91-MM-N061 7-12-91 Lubrication storage and handling discrepancies DC1-91-MM-N066 8-6-91 Component cooling water heat exchanger 1-1 flooding DC1-91-MM-N067 8-13-91 Auxillary salt _ water pump vault drain. ' Check' valves DC2-91-MM-N069 8-14-91 Leaking from charging-subsystem of chemical.and volume control system DC2-91-MM-N072 8-27-91 MS-2-RV-225/60 relief valve declared inoperable due to faulty test equipment DC2-90-TI-N025 4-18-90 Spurious CVI due to a voltage transient DC2-90-TI-NO31 4-24-90 Steam line isolation DC2-90-T1-N068 10-15-90 Electrical room temperature monitor DC1-90-T1-N090 12-24-90 Pressurizer sprug valve, 1-PCV-455B,' failed open DC2-91-T1-N003 1-15-91 Wrong channel adjusted DC2-92-T1-N062 7-16-91 CVI during maintenance. i 'DC1-91-T1-N068 8-13-91' CVI curing maintenance DC2-91-T1-N088 10-7-91 Inadvertent SI due to personnel. error 9 March 11~, 1993 i c;

.\\1 f' rk ' E . MAINTENANCE AND SURVEILLANCE-NCRs i F NCR NUMBER INITIATE'DATE SUBJECT 'DC1-91-T1-N096, '10-25-91 Containment wide range' level . failed lowf 'DC1-92-T1-NO39 9-8-92

FHBLventilationjswapfduelto.

personnel! error f- .DC2-90-OP-N020 4-16-90 Inadvertent ESFfventilationL systems mode transfer-4 . Unit ^11 rip;<12-5-90,Ldue:to; t DC1-90-OP-N082 12-6-90 turbine runback' failed to: d reduce generator level--' ESFfactuation due to leaking .f E DC1-90-OP-N083 12-10-90 -feedwater.: Check 1 valves: .? DCD-92-QA-N003 1-31-92 ! Maintenance program %. [ ~ commitment had notlbeen.-meti j DCO-91-MM-N079 9-18-91 Diesel generator.2.2nloose?. camshaft; dampener. fastener 'DC2-91-MM-N094

10-21-91 STP V-3P3 failure /FW-2-5321 r

DCO-92-MM-N007 2-12-92 Containment fan coolers.'-' 7 counterweiglits.on backdraft) dampers missingsor. lacking 5; locknuts' DC1-92-MM-N021 5-15-92 1-171SL snubber' damage. DCO-92-MM-NO22 5-26-92 HVAC; maintenance practicesL-- are.they sufficient toL O assure equipment reliability; andisafety. g DC1-92-MM-NO33 .7-8 Centrifugal' charging-pumplDH motorhold down bolts found. {SSPS?halon)1 ~ - damper failed to'close 1 Marchill,. 1993-U .g j n a i r .--m

p r. l' ~ =- [. : MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE SUBJECT upon operation of the halon system DCO-90-SE-N080 11-21-90 Fire in. electrical panel DC1-90-WP-N093 12-28-90 Inadvertent ground'causes CV1 in UnitL1. DC1-91-WP-N012 2-1-91 Reactor trip.- FW-1-530 &. i 540_ closure resulting in a low steam generator level' ~ trip DC1-91-WP-NO21 2-20-91 Quality-related' maintenance work-performed w/o a work; order as required by.APC-4053 DC2-91-WP-N097 10-25-91 Missed-PMT (post maintenance test not performedLfollowing maintenance on a safety. injection valve-DC1-92-EM-N054 10-31-92 H0. POT on ASW PP motor l'-2 cable' failed DCO-90-MM-N057 8-31-90 Fire pump 0-2 maintenance deficiencies DCO-90-TN-N064 10-15-90 Numerous pump STPs.do'not strictly meet. requirements of ASME Code section'XI DCO-91-TN-N026 3-5-91 ~Various check valves not verified stroked closed as part'of IST testing program DCO-92-TN-N055 11-2-92 Vibration data for STP P-613 potentially taken at wrong location on-pump DCO-92-EN-N005 3-20-92 Reactor head vent solenoid valve terminal block material substitute may:not-meet'EQ requirements-March 11, 1993

4: ~ ~ I MAINTENANCE AND SURVEILLANCE NCRs 2 ~ .NCR NUMBER INITIATE DATE SUBJECT-DC2-90-T1-NO31 5-18-90 St'eam flowLtransmitter. I reinstalled with(sensing. i lines. crossed DC092-MF-N025 5-29-92 Designilife/ shelf: life) limitations 4for;non-EQL. . i -equipment-not adequately; y implemented. - DCO-91-TR-N044 4-4 Maintenance' Department's i implementation of: program. ,l requirements regarding'- personnel qualifications; 9 i DCO-92-TN-N004 '1-28 Longltermicooling.waterf. i hoses:hydo. tested,; failed-l andtwere not replaced,;other- 'LTCR hose were not tested-TimeDlimit-for. surveillance' d - DC1-92-TC-N041 required by. Tech. Specs-j includingLextension~ exceeded when a' technician to. perform. 1 gasidecap-tank; surveillance. DCO-91-EN-N024 6-14-91 Safety related solenoid valve.with1 unidentified electrical splice i DCl-91-EN-N019 5-6-91 DielectricJmaterialDin a 1! connector;differentLthan 1 .specified'in'thet ~ . environmental qualification-- report .DC2-91-TN-N023 2-21-91~ Undersized 1 welds-installed? .in plant'during. work for the i CVCS'letdownfline~ repair;- l DCl-92-TP-N052 10-12-92 Failed;toirecognizeiASW:pumpi j was intalert-range ( Therefore,. tests were.not: performed on an' accelerated?' . frequency d

! -March'11, 1993e a

.I 5 L i

Iy l ': -4 MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE'DATE SUBJECT-DC2-91-SS-N101 11-26-91 One damper failed during the cable spreading room.cardox. surveillance test DC2-91-TN-N102 12-5-91 Work controls not effective in controlling accumulation-of unsecured loose material- .inLeontainment DCO-90-SS-N063 9-21-90 Spurious discharge.ofLcardox system during diesel ~ generator cardox' system testing DCO-91-TN-N048 .5-28-91 Certain check valves'are not verified for full stroking open, as per'ISTLProgram DCO-91-TN-N065 '7-31 NRC.violationifor.not having-appropriate acceptance criteria for diesel-generator starting air compressor'- DC1-90-WP-N003 1-17-90 Boric. acid heat tracingx functional test notL performed on schedule. DC1-91-EN-N016 6-11-91 Newly' installed RHR valve failed to close during: surveillance test DC1-91-OP-N059 7-5-91 -During STP M-16E operator. . error caused an inadvertent. ' actuation of ESF - DCl-91-OP-NO38 3-25-91 During performance-.of surveillance test'an-inadvertent:ESF occurred: DCl-91-TN-N007 1-18-91' Fuel handling building: ventilation _ system failed tech spec: requirement DCl-92-TN-N003 1-23-92 Boric acid transfer pump was not performed on an. March'11,'1993 e

4 MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE ' SUBJECT ~ -accelerated frequency as' required DC2-92-OP-N032 7-2-92 Missed' step in STP I-1B performance-DC1-92-EN-NO31' 11-19-92 . Recovery time determined during STP.did not meet DCPP i commitments for the diesel generator DC1-91-TN-N002 1-3-91 Back leakage through main-feedwater check valve may. impact AFW system flow operability P1/NCRs2. dis March.11, 1993 ~

'Attachmtnt.3. Interrocratorv 19 q I 1990-1993 LERS RELATED TO MAINTENANCE /SURVETT TANCE 5 2-90-004-00 Containment Ventilation Isolation and FHB l Ventilation System' Shift-to Iodine Removal Mode Due.to Personnel-- Error During Troubleshooting 2-90-005-01 Closure of the MainLSteamline Bypass Valves l Due to Inadequate Backfilling of.TransmitterLSensing Lines 4 2-90-006-01 Violation of Technical Specification Because of Inoperable Steam Flow Transmitters Due to Personnel Error-1-90-007-00 Missed Surveillasnce of Sealed Sources Due to - [ Personnel Error 2-90-009-01 Inoperable Room Temperature Monitor-.Due to. Personnel Error i 1-90-014-00 Reactor Trip on Turbine Trip Due to-Inadequate Evaluation of Runback Limit Setpoint t 1-90-015-00 ESF Actuation, P-14.-(High-High Steam -Generator Water Level) Due to Feedwater Regulating and Bypass Valves Leakage 1-90-017-00 Reactor Trip. Resulting from Failed-Pressurizer Spray Valve Due to Incorrect Screw Installation 1-90-018-00 Fire Damper Cardox Actuation Fusible Link ) Assembly Incorrectly Installed for Indeterminate' Reason 2-91-001-00 Oontainment Ventilation' Isolation Resulting From a Voltage Transient Due.to Personnel Error j 1-91-002-00 Reactor Trip on Steam Generator Low Level. i with Steam Flow /Feedwater Mismatch due to Personnel Error 2-91-002-00 Potential Missetting of Main Steam Line Code l Safety Valve due to Failure of Test Equipment 1-91-004-00 Loss of Offsite Power During Refueling Caused by Crane Due to Personnel Error ~! 2-91-007-00 Inadvertent Safety Injection While in Mode 5 Due to Personnel Error 1-91-008-00 ManualfReactorl Trip Caused by Rod-~ Control-Power Supply Fuse Failure Due to Personnel Error 1-91-009-00 Reactor. Trip Due to Personnel Error on Safety l Injection Due to Leaking Steam Dump Valve 1 .l I i ?

Eg: 7 ~ q i l75 , Ai - 1 Ei ~ ' s it:; O j g. '2-91-009-01110'CFR 100' Dose-: Limits Potentially Exceeded ti fi ,insEvent-:-of DesigniBasis Loss of-Coolant Accident: Recovery as?a< Result of Valve' Leakage ~ 2-91-011-00" Failure.to Test Valve-Following Maintenance? -l -Due to Personnel ~' Error.

1-91-012-00-- : Emergency

. Diesell : Fuel ' 011l-Inventoryf Surveillance Missed Due to Personnel' Error ~ + [ 2-91-012 Debris-in Contiainment, Lack of Visuali. b Inspections ~ t 1-91-013-00 Containment Ventilation. Isolation During' Maintenance due to Personnel Error 1-91-019-00'CFCUs Maintenance.' 'l t 1-92-005 LContainment Ventilation Isolation : - Due1 tol Spurious High Radiation' Signal l 1-92-006-00 Diesel Fuel Oil Transfer System Corrosion a

l

'~ 'l-92-010-00 MOV Fails Stroke Test' l ^r 1-92-013-00 FHB I&C Test Error

l 1-92-017-00 Missed Chemistry Surveillance l.

l'-92-024-00' Missed' Accelerated Surveillance 3 l1 1-93-002-00 Containment Isolation Valve Not-IsolatedEin Accordance with Technical' Specifications-a i -f a i . i r v s.

.a r

- ? .[

, _~ -. +. ~ j i

r

-rp.

. ; C. cr.-

d 1 .p (.9 - - Attachment 4: L ,i Document Reauest 16' lq (a) Auxiliary' Saltwater System Pumps l (b) Auxiliary Saltwatier-System Motors:l j t a Instruction Manual-Auxiliary Saltwater. Pumps,& MotorsI .j j ~ (c) Atmospheric Steam Dump Valves: '{ Instruction. Manual-Copes-Vulcan-'. 8"-600#.

Diaphragm!

q Operated Globe Valves 4 ^ j Instruction Manual-Copes-Vulcan D-100 Control Valve' with ( D-100-160 Direct Acting Pneumatic Actuator ji 3 (d) Suction Cooling Suction Valves: "i 1 There is no-such equipment'at the Diablo' Canyon' Plant. [ .l (e) Emergency Diesel. Generators: Instruction' ~ Manual-Westinghouse 3630/43302 BHP Dihsel I Engines for 2600-KW Generator. Sets-j i' s. t (f) Supply: Fans for~480 volt Switchgear-' Ventilation Syst'em: ~ M Instruction : Manual-Joy. Series..1000/2000,:.. Axivane' Fans, .l 4 Direct Connected Single'and Two? Stage. Axial-Flow Fansf -( (g) Inverters for Vital Instrument-Channels: 1 1 Instruction Manual-Inverter for Instrument PowerTSupply ' 60-HZ 1 Phase-w/460 V AC, 3 Phase,--60 HZ? 7.5KVA, .t (h) RWST Level Instruments: g Instruction Manual-Main Control-Boards-Recorders. j Instruction Manual-AP.. 4300-16"' Actionpack ' : Isolating'. [ Transmitter, Action--Instruments Co.- [

3 Instruction. Manual-Models 764 Differential Presrure~

Electronic Transmitter,LITT Barton' i ~ (i)' Pressurizer. Pressure Instrumentation:- -l l Instruction. Manual-Control and Protection Instrumentation - 1.i System: 1 s 1 n ~

g.

~ . '(j ) 125 V Battery Chargers: ~ - Instruction Manual-Exide Filtered Constant Voltage Float L Charger Model UPC, Three Phase.- Instruction Manual-Exide Constant Voltage-Filtered Float'. Charger Mode ' UPC-13 0-3-4 00 Three~ Phase, 60 Hertz ' AC Supply (k) Emergency Lighting Batteries: Instruction Manual-Series SGL and S6N Batteries-(1) Out-of-Core Start-up Neutron Detectors: Instruction-Manual-Nuclear Instrumentation System V 4 i 6 m ese i

=

pptJgTED copp,ESPONDENCE

• 6 UNITED STATES OF AMERICA Si

'M NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING Eg RDR 15 P3 :00 In the Matter of: ) 9y;. t ;g u,r c ) Docket Nos'USD-27,5-OLATI k Pacific Gas and Electric Company ) 50-323 DLA ) (Construction Period-(Diablo Canyon Power ) Recapture) Plant, Units 1 and 2) ) ) CERTIFICATE OF SERVICE I hereby certify that copies of " PACIFIC GAS & ELECTRIC COMPANY'S RFSPONSE TO FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE (RE: CONTENTION I)" 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 (*), by Federal Express overnight delivery, this'12th day-of March, 1993. Copies of documents being provided, as referenced in the discovery response, are being provided only to parties indicated by the (t) symbol. Charles Bechhgefer, Chairman Frederick'J. Shon Administrativ6 Judge-Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Jerry R. Kline Office of Commission Appellate Administrative Judge Adjudication Atomic Safety and Licensing Board U.S.-Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Office of the Secretary Ann P. Hodgdon, Esq.(t) U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear' Regulatory Commission Attn: Docketing and Service Washington, DC 20555 Section (original + two copies) Adjudicatory File Peter Arth, Jr. Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G.-Fairchild U.S. Nuclear Regulatory Commission California Public Utilities Washington, DC 20555 Commission 505 Van Ness Avenue San Francisco, CA 94102

4 s k.

s.'

L2, M'b }; y".,) a 7 ,-g c Nar.tM Culver, President ' Truman: Burns M ard;of. Directors. ~ California ~Public Utiliti'es? M'[ San? Luis obispo-Motliers fo. peace - ' Commission. [ c.[AM P.O.T Box 164;.' - 505 Van ' Ness (J Rm. =.~ 4103:- Pismo-Beach, -CA-..93448 San; Francisco, CA -94102. 4 4't ~ L. L - . Robert'R.LWellington, Esq. Christopher J.-Warner,.Esq. 1i Q Diablo Canyon Independent" Safety Richard F. - Locke, LEsq.' - 1 Committee- --Pacific Gas'T& Electric l Company; 77 Beale' Street-i 857.'Cass? Street, Suite:D Monterey,ECA 93940 . San-Francisco,-CA< 94106 ? Robert Kinosian ' Jill'ZamEk* ' California-Public Utilities 1123' Flora Road' Commission Arroyo Grande,'CA ~93420; I O 505 Van Ness, Rm. 4102 t N San Francisco, CA 94102 1 Mr. Gregory Minor *(t) MHB Technical Associates l I 1723-Hamilton Ave., Suite-K San Jose, CA 95125 5 h \\ g -David A..Repka-- 1 j Counsel.for Pacific' Gas >&- Electric Company. O r 'i 9 k .g i I. .- f g-L l k 4 ~ 'h f.}}