ML20035B561
| ML20035B561 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/22/1993 |
| From: | Culver N FRIENDS PEACE EXCHANGE (FORMERLY MOTHERS FOR PEACE) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13808 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9304020153 | |
| Download: ML20035B561 (5) | |
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UNITED' STATES OF-AMERICA f
NUCLEAR REGULATORY COMMISSION.
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y ATOMIC SAFETY AND LICENSING BOARD
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In the Motter of Pacific Gas and Electric Company Docket Nos. 50-275-OLA-2
-i Diablo Congon Nuclear Power Plant 50-323-OLA-2.
Units 1 and 2.
ASLBP No.'92-SS9-03-OLA-2:
Facility Operating Licenses No. DPR-BO and DPR-82 March 22, 1993 l
Intervenor Son Luis Obispo Mothers for Peace Motion to Compel Pocific Gas and Electric Company to Respond to the First Set of Interrogatories and: Requests for-Production of Documents Filed by Son Luis Obispo Mothers for Peace CRe:
Contention U3 On February.16, 1993 the Son Luis Obispo Mothers for Peace C"SLOMFP")
i filed its First Set of Written Interrogatories and Requests for. Production of Documents to Pacific Gas and Electric Company ("PG&E").
PG&E responded f
to inquiries regarding Contention U on March 10, 1993:
PGBE's Response to
^
First Set of Interrogotories and Request for Production of Documents Filed by SLOMFP [Re:
Contention U3 ["PGSE's Response to Contention U"J.
In its Response to Contention U, PG&E put.forth a " general objection."
i PGSE refused to respond to over half of the SLOMFP interrogatories and requests for production of documents based on the belief that PG&E must respond only to interrogatories concerning "the' effectiveness of.PG&E's i
AEplemeDtatlpD_of interim compensatory measures" and need not respond to inquiries into the issues of Thermo-Log or the adequacy of PGSE's fire f
protection at Diablo Congon Nuclear Power. Plant.
PG&E's Response to-Contention U ot 2.
[
The SLOMFP disagrees with PGSE's orgument and justifies its-requests l
1
-ond inquiries of PGSE by the following needs i
) Sp3 9304020153 930322 PDR ADOCK-05000275 0
s The SLOMFP needs o comprehensive description of creas in ~ w?.ich fire watches and fire suppression systems are corried out.
SLOMFP needs to know if personnel are physically able to perform the hourly fire watches.
CSLOMFP Document Request 18]
SLOMFP seeks to learn the implications to fire protection from hozords such as combustibles and seismic events. CSLOMFP Interrogatories 21Co],
21Cb3, 21Cc], Document Requests 2, 7,
13, 19, 31]
SLOMFP wants to know Cond verify] what safety-related equipment and components may be disobled in the event of a fire.
CSLOMFP Interrogatories 1C03, ICb], 22, Document Request 21]
SLOMFP needs to know the expected duration from fire detection to fire i
suppression to determine the impact on nearby systems and components, t
CSLOMFP Interrogatories icd), ice), 1Cf],
B, 29, 29, 30, 31, 27, Document Requests 34, 35, 35]
SLOMFP seeks to learn about Thermo-Log installotion at Diablo Congon Nuclear Power Plant ("DCNPP"] and how it may react in the event of a fire.
ISLOMFP Interrogatories 14, 15, 15, 25, Document Requests 15, 37]
SLOMFP needs to learn of recent experiences at DCNPP involving fire, i
deficiencies in fire bcrriers, problems with missed fire watches, etc. in order to better evoluote the implementation of PG&E's fire protection proDrom.
CSLOMFP Interrogatories 17, 18, 19]
Note that PGBE refused to 1
answer interrogatory 17 and only portially answered SLOMFP interengatories 18 and 19.
PG&E responder 2th LERs "since NRC Bulletin 92-01 was issued."
PG&E Response to Contention U ot 16, 17.
The SLOMFP interrogatories reauested all LERs by PGBE for deficiencies in fire barriers and for problems with hourig ond/or continuous fire watches (e.g.,
missed fire 3
watches or failure to set up a fire watch in o timely manner given a known
i 4
degraded fire barrier].
First Set of Written Interragotories and Requests for Production of Documents to PGEE CFebruary 18, IS933 at B-S, B-6.
l SLOMFP needs to know how the interim compensatory fire protection J
measures interact with other fire protection measures.
CSLOMFP Document i
i Requests S, 16, 20, 333 SLOMFP wants to know how fire protection hos changed / improved as a result of compensation for the faulty fire barrier, Thermo-Log.
CSLOMFP.
Interrogatories 6, 7, 23, 27, 28, 32, Document Requests 3, 17, 253 SLOMFP seeks to learn of the advice PG&E has received and if that advice was implemented.
CSLOMFP Interrogatories 20, Document Request 6, 11, 12, 293
.i The SLOMFP further relies on the recent Atomic Sofety and Licensing Board's Memorandum and Order CDiscovery Motions] which states that "Ci]n the context of discovery... matters reasonably calculated to lead t-information pertinent to the contention ore also included.
10 C.F.R. 2.790Cb3C1]." (March 11, 19933 at 3.
PGGE refers the SLOMFP to the Public Document Room for certoi, information.
In Document Request 1, SLDMFP requested the current, interfiled, portions of the Diablo Congon Nuclear Power Station Updated e
Sofety Analysis Report which oddresses fire protection issues.
SLOMFP First Set of Written Interrogatories and Requests for the Production of l
Documents to PGSE CFebruary 16, 19933 at 1.
PG&E referred the SLDMFP to Chapter 9 of the Updated FSAR in the Public Document Room.
PG&E quotes CFR 2.790Cb3C13 "Where ong book, document or other tongible thing sought is reusonobig ovoilable from another source... o sufficient response to on interrogatory involving such materials would be the location, the title ond. !
o page reference to the relevant book, document, or tongibic thing."
PGBE
+
~ s Response to Contention V, at 26, 27.
But it is not reasonable for the.
SLOMFP to have to put forth the extraordinary effort to sift through the many amendments and revisions to the original document when Cit.is assumed]
I that PG&E has on updated version on its shelf.
At the very least, PGSE
.must provide the SLOMFP with the locations, titles, dates and page numbers
)
of each relevant revision.
For the reasons stated above, the SLOMFP hereby moves to compel PS&E t
to respond in full to the SLDHTP interrogatories and requests for l
production of documents filed on February 16,: 1993 and noted above.
l i
I Respectfully submitted, 0
Noney C' ver, President Son Luis Obispo Mothers for Peace
[
P.O.
Box IBM Pismo Beach, CA 93998 I
i i
E t
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J Certificate of Service O U I hereby certify that copies of the foregoing Intervenor Son Luis Obispo Mothers for Peace Motion to Compel Pacific Gas and Electric Company to Respond to the First Set of Interrogatories and Requests for Production of Documents Filed by Son Luis Obispo Mothers for Peace [Re:
Contention U3 have been served upon the following persons by U.S.
mail, first class.
Office of Commission Appellote Administrative Judge Adjudication Chorles Bechhoefer, Chairman U.S.
Nuclear Regulatory Lommission Atomic Sofety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Sofety and Licensing Board Frederick J. Shan U.S.
Nuclear Regulatory Commission Atomic Sofety and Licensing Board Ucshington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Edward D'Neill Ann P.
Hodgdon, Esq.
Peter Arth, Jr.
Office of the General Counsel Trumon Burns U.S.
Nuclear Regulatory Commission Robert Kinosion Washington, DC 20555 Peter G.
Fairchild, Esq.
Californio Public Utilities Commission Joseph B.
- Knotts, Jr.,
Esq.
505 Uon Ness Avenue Winston 8 Strown Son Francisco, CA 94102 1900 L Street, N.W.
Woshington, DC 20005 Adjudicatory File Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Branch Washington, DC eosss u.s. Nuolear aeoulatoru commission Washington, DC 20555 Robert R. Wellington, Esq.
Dicblo Canyon Independent Safety Committee B57 Cass Street. Suite D Monterey, CA 93990 Christopher Warner, Esq.
Richard Locke, Esq.
4 Pacific Gas and Electric Co.
77 Beale Street Son Francisco, CA 94106 Dated March 22, 1993, Son Luis Obispo County, CA Jill ZomEk bd/ k Lh- $'
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