ML20035D389
| ML20035D389 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/24/1993 |
| From: | Culver N FRIENDS PEACE EXCHANGE (FORMERLY MOTHERS FOR PEACE) |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| CON-#293-13837 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9304130160 | |
| Download: ML20035D389 (6) | |
Text
-
/383 7 e
'93 U" -2 P 3 20 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Motter of Pacific Gos and Electric Company Docket Nos. 50-275-OLA-2 Dicblo Canyon Nuclear Power Plant 50-323-OLA-2 Units 1 and 2 ASLBP No. 92-659-03-OLA-2 Facility Operating Licenses No. DPR-80 and DPR-82 March 29, 1993 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 Nothers for Peace ire:
Contention 13 On February 16, 1993, the Son Luis Obispo Mothers for Peace ("SLOMFP"3 filed its First Set of Written Interrogatories and Requests for Production of Documents to Pacific Gos and Electric Company.
Pacific Gas and Electric Company C"PG&E"] responded to SLOMFP Interrogotories and Requests for Documents relating to Contention I in PGBE's Response to First Set of Interrogatories and Request for Production of Documents Filed by SLOMFP CRe:
Contention 13 CMorch 12, 19933.
SLOMFP finds that many of the documents referenced by PGSE are not completely responsive to the SLONFP requests.
Many of PG&E's answers to SLONFP inquiries are inadequate and incomplete.
The SLOMFP moves to compel i
PGSE to answer the following SLOMFP interrogotories and requests for production of documents which PGSE hos objected to or insufficiently answered.
Interrogatory 1 Despite the length of PG&E's answer, the SLOMFP connot tell from the information provided whether "the octual environment in the os-installed position, for both operating and occident conditions over the plant design lifetime, for each safety-related structure, system and component is j
9304130160 930324 PDR ADOCK 05000275 O
Q PDR
' T)S '
e i
bounded by the conditions in its environmental and seismic tests for life and aging."
SLOMFP requests that PG&E provide one copy of each document:
NECS E.13, AP D-755, DCM T-20, DCM T-12, DCM T-15, CPD]TSI " Plant Aging f
Management," procedure C-4052 " Plant Equipment Foilure Tracking and Trending," and NECS-E3.6DC "Diablo Canyon Power Plant Design Changes."
I These documents were not provided at the site visit.
I l
Interrogatory 3 i
PGSE does not answer this question.
The interrogatory is intended to identify structures, systems and components that do not have 90 year i
qualified lives.
SLOMFP seeks rn onswer to this question from PGSE.
Interrogatory 4 I
The question is not fully answered.
PGSE does not explain how system testing, stortup testing and operation prior to full power license is not considered to effect a component's qualified life.
SLOMFP requires i
quantitative criterio.
In order to complete the response to the seismic portion of this interrogatory, PGSE must provide one copy of Appendix to DCM T-10, NEP001, which provides o list of equipment and components that have been seismically qualified.
i t
Interrogatory S PGSE's refers SLOMFP to the answer to Interrogatory 4.
But PG8E's answer to Interrogatory 9 is not responsive to Interrogatory S; it does not explain or identify the requested information.
PG8E should be ordered to ensuer the question and provide the details that have been requested.
Interrogotory 6 In order to provide the information requested as on answer to Interrogatory 6, PG&E must provide the SLOMFP with one copy of
.i 1
i f
l Administrative Procedures AP C-3S1, which describes the surveillance testing and inspection progrom used at Diablo Congon Nuclear Power Plant
["DCNPP"].
i, Interrogatory 7 l
1 SLOMFP is willing to modify this interrogatory, but PGSE should at the I
i very least be required to provide information on safety-related structures, systems and components that have been unovailable due to maintenance or surveillance which exceeded plant Technical Specifications.
For each such structure, system, or component, SLONFP seeks the length of time it was-unavoilable and the month and year during which the unovcilobility occurred.
Interrogatory 8 In order to be responsive to this request, PG&E should be required to provide the SLOMFP with one copy of INPO 90-008 which includes the criterio mentioned in its reply.
Interrogatory 12 and Document Requests 20 and 24 PGSE objects to these requests, claiming that the information is unrelated to the current performance of the maintenance and surveillance l
programs at DCNPP.
SLOMFP disagrees and finds it necessary to evoluote events and procedures throughout the entire operating life of the plant Cwhich is not that lengthyJ.
SLOMFP feels that it is essentici that these r
basic evoluotive documents be provided; PGSE's post maintenance and i
surveillance record is certainly relevant to current operation.
PGSE hos responded to the interrogatory and document requests with a restrictive list of documents.
SLOMFP is worried that this list is not i
fully responsivs even for the limited time that was provided.
PGSE should i
h E
be ordered to provide all the requested documents for the entire operating life of the plant.
Document Request 2 PG&E refuses to provide correspondence between PG&E and the NRC l
r related to the proposed maintenance rule CIO CFR 50.653.
PG&E refers s
SLDnFP to the Public Document Room.
But the Public Document Room may not have all of this correspondence.
Furthermore, at the very least, PG&E should be required to identify this correspondence.
Document Request 12 PGGE objects to this request, claiming that maintenance of non safety-related equipment has no bearing on the effectiveness of the maintenance program at DCNPP.
SLOMFP, however, finds that the maintenance of equipment not safety-related con indicate the general health ni' the maintenance program.
Additianolly, non sofety-related equipment that is not well l
maintained could effect the function of safety-related equipment.
SLOMFP requests that PGSE onswer this request.
Providing o list and descriptive titles will be acceptocle.
Document Request 13 In crder to be responsive to this request, PG&E must provide FSAR
)
references, including sections and page numbers.
This document was not provided at the site.
Document Request 19 In their refusal to respond to this document request, PG&E ottempts to prevent evoluotion of their maintenance program.
This question is relevant.
SLONFP is entitled to evoluote maintenance procedures for equipment with o qualified life that is less than the duration of the 1
i
l Certificate of Service 33 #e m '9 n-e r.
' F "M
i 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 Int.errogatories and Requests for Production of Documents Filed by San Luis Obaspo Mothers for Peace CRe:
Contention IJ have been served upon the following persons by U.S. mail, first class.
Office of Ccmmission Appellote Administrative Judge Adjudication Charles Bechhoefer, Chairman U.S.
Nuclear Regulotcry Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S.
Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Sofety and Licensing Socrd Frederick J. Shon U.S.
Nuclecr Regulatory Commission Atomic Sofety and Licensing Board 1
Washington, DC 20555 U.S.
Nuclear Regulatory Commission i
Washington, DC 20555 Edword O'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.
California Public Utilities Commission Joseph E.
- Knotts, Jr.,
Esq.
505 Von Ness Avenue i
U1nston & Strown Son Francisco, CA 99102 1900 L Str eet,
N.W.
Ueshington, DC 20005 Adjudicotcry File Secretary of the Commission U.S.
Nuclear Regulatory Commission Docketing and Service Branch Ueshington, DC 20555 U.S.
Nuclear Regulatory Commission Uoshington, DC 20555 Robert R.
Wellington, Esq.
Diablo Canyon Independent Safety Committee 857 Coss Street, Suite D Monterey, CA 93990 Christopher Warner, Esq.
Richard Locke, Esq.
Pacific Gas and Electric Co.
77 Beole Street Son Francisco, CA 99105 Dated north 24, 1993, Son Luis Obispo County, CA Jill ZomEk OYD
~D i
current plant license.
PGBE should be required to provide this information.
Interrogatory 19 and Document Request 22 SLOMFP requested all LERs and NCRs issued by PGSE relating to mointenance and surveillance activities at DCNPP.
PGSE limits this request and responds with a list of the LERs and NCRs since 1990.
This list, however, is not even complete; many documents that are cited in the NCRs that PGSE has provided have not been listed or mode available to SLOMFP.
PGSE should be required to provide all LERs and NCRs for the entire period of plant operation.
Document Request 27 PGSE's objection is noted, but PGSE is wrong.
ED is certainly o design consideration, but depending on the octual environment that this equipment operates in, it may be become on operating consideration as well.
SLOMFP seeks to learn what environment PGSE is assuming and whether or not this environment is cctually being maintained.
PG&E should be compelled to provide this information.
At the very least, PG&E should be required to answer the lost sentence:
"For each such volve, provide all records of ombient temperature, rodlotion, and humidity at the location of the volve during its operating life."
Respectfully submitted, 1
db'I dd AI /\\#
Nancy C ver, President i
San Luis Obispo Mothers for Peace P.O.
Box 159 Pismo Beach, CA 93998 l
- - - - -