ML20035H618
| ML20035H618 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/26/1993 |
| From: | Culver N SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13922 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9305060099 | |
| Download: ML20035H618 (5) | |
Text
- 4 (prz &
4
- r i.. u i
thht UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 93 APR 29 P4:07 before the ATOMIC SAFETY AND LICENSING BOARD
- w;
.>:s '
..t
, > +
In the matter of UE' id Pocific Gas and Electric Company Decket Nos. 50-275-OLA-2 Dichlo Congon Nuclear Power Plant 50-323-OLA-2 Units 1 and 2 ASLBP No. 92-669-03-OLA-2 Facility Operating Licenses No. DPR-BO ond DPR-82 April 26, 1993 Intervenor Son Luis Obispo Mothers for Peace Motion for Leave to Reply to Pacific Gas and Electric Company's Opposition to Additional Discovery Re: Cobles On April 2, 1993, the Son Luis Obispo Mothers for Peace ["SLCMFF"]
filed a Motion for Leove to File Addit 1onal Discovery Re: Okonite Cables 8
with Bonded Jockets.
Additionally, this motion was accompanied by SLOMFP Supplemental Interrogatories Related to SLOMFP First Set of Uritten Interrogatories and Requests for the Production of Documents to the NRC Stoff Re: Okonite Cables with Bonded Jockets and SLOMFP Supplemental t
Interrogatories Related to SLOMFP First Set of Uritten Interrogatories and Requests for the Production of Documents to Pacific Gas and Electric Company ["PGSE"].
On April 19, 1993, PBSE responded by filing on Opposition to Request for Additional Discovery Re Cobles.
SLOMFP moves for leave to reply to PG&E's opposition to its request for additianol discovery.
A reply is needed in order to respond to PG&E's orgument that environmental qualification is not related to maintenance and surveillonce.
SLOMFP believes that environmental qual.Ification is on extremely important ospect of maintenance and surveillance.
Therefore we seek the Board's leave to reply to PG&E.
PG&E claims that none of the cable failures at Dicblo Congon Nuclear Power Plant ("DCNPP"3 are related to Contention I - maintenance and surveillance progrcms that are in question in this proceeding.
But 9305060099 930426 i
PDR ADDCK 05000275
})S33 G
l
/
/*
. ~
l environmental qualification is related to maintenance because the j
degrodotion of safety equipment and the ensuing loss of envlonmental i
quellfication con be due to insufficient maintenance.
As a matter of fcct, SLONFP understands that some of the failed cobles at DCNPP have been submerged under 3 to 9 feet of water for long periods of time Cond degraded] because the sump pump had not been maintained and, in fact, was I
found inoperable.
Additionally, it was discovered that a six-inch ABS I
conduit oppeared to have been broken.
NRC Inspection Report 93-03 CApril 8.
1993) at 7.
Environmental qualification may be o design consideration, I
but if the octual environment that the equipment was designed to operate in is not being maintained - and in this cose it certainly hasn't been - it becomes o maintenance issue.
1 PG&E also remarks that the cable failures at DCNPP on February 5 ond March 12, 1993 ore irrelevant because neither have Hypolon jockets, but neoprene - without bonded jockets.
Regardless of the type of jockets and i
whether or not they require environmental qualification, it is clear that l
PGSE is experiencing maintenance difficulties with a variety of cables.
Additional discovery is worronted.
PG&E continues to criticize SLOMFP's conduct of discovery, particulcrly its shortcomings during the site visit.
PG&E claims that i
SLOMFP did not request NCR DCl-52-EM-NCS9.
This is untrue.
SLOMFP records shou that SLOMFP requested all the NCRs and LERs that were listed as l
responsive to Interrogotories 12 and 19 and Document Request 22 on j
! in PGSE's Response to First Set of Interrogatories and Request for Production of Documents Filed by SLOMFP CPe:
Contention I]CMorch 29, l
1993].
See Attachment A.
Of the 93 NCRs listed, PGEE provided the SLOMFP I
with only 8.
Of the 29 LERs listed, PGSE provided SLOMFP with 20.
See l
tn- '*
i I
I SLOMFP Motion for Extension of Time to Examine Documents at DCNPP CApril 26, 1993).
SLOMFP hos requested these " missing" documents in its Motion to i
Compel PG&E to Respond to the First Set of Interrogatories and Requests for f
Production of Documents Faled by SLOMFP CRe: Contention IJCMorch 24, 1993].
PG&E believes that SLOMTP is unjustified in its discovery request l
because :t foiled to follow up on IN 92-81 CDecember 11, 1992).
Yet SLOMFP f
l did not identify this issue os being specific to DCNPP until it learned of the occurrence of the electrical ground on February 5, 1993.
SLDMFP p
learned of this event on March 25, 1993 and responded in a timely manner with appropriate motions and interrogatories.
SLOMFP's request for f
odditional discovery regarding the degraded Dkonite cables is justified and j
should be granted.
I I
J i
4 i
l Respectfully Submitted, i
e I &
L l
Nonty Culver, President Son Luis Obispo Mothers for Peace P.D. Box 169 Pismo Eecch, CA 93948
AbillM MOTHERS FOR PEACE REQUEST FOR INFORMATION DCPP SITE VISIT - MARCH 16, 1993 INITIALS DATE/ TIME DDCUMENT RE00ESTED PROPRIETARY?
CDPIES REOUESTED?
U 4
L66 ff-1%o-93 rdd) b neinNe aub f4A(LTi}{M CL.-
m
\\ db M90-0 rdg4al 4 maik u-ad SWWilbr10L_
4 m
u p f S A f_.
szd a s c,v maihru_ -
y A04.1Di
/
- J E / z-
_ J Z_ /z:/f 9 ST P A H 2-
- c. 6 7
fz.3g Aq-bA r.t g,Q[
I?'DI 5 M - HSA r. 4
{
a: ox
,_3 n u,.i
,e u
an g6
/[ -5 r.N/Z(h_
<3
/N R-10 r. 6 dl'*
N p
f-Zb i y. i o T-/'
i i
i Jer t I
i
'93 TD 29 P 4 :09 i
Certificate of Service I Pereby certify that copies of the foregcing Son Luis Obispo'. Mothers'for Peace ("SLOMFP"3 Motion for Extension of Time to Examine Documehts at I
Diablo Canyon Nuclear Power Plant and Intervenor SLONFP Repig to Pocific-l Gas and Electric Company's ["PGSE"3 Motion to Strike in Port SLOMFP Filing l
Regarding Addendum to FES cnd Intervenor SLOMFP Motion to Compel PGSE to Respond to the-Second and Third Sets of Interrogatories and Requests for i
Production of Documents Filed by SLOMFP and Intervenor SLDMFP Motion to Compel the NRC Stoff to Respond to the First Set of Interrogatories and Request for the Production of Documents Filed by SLOMFP cnd SLOMFP Motion for Leove to Reply to PG&E*s Opposition to Additianol Discovery Re: Cables "cve been served upon the fc11 cuing persons by U.S.
mail, first class.
l i
Cffice cf Commissicn Appellcte Administrctive Judge adjudication Charles Eechhcefer, Chairman l
U.S.
Nuclear Regulatcry Ccmmissicn Atomic Safety and Licensing Eccrd
[
Ucshington, DC E0555 U.S.
Nuclear Regulatory Commission j
Ucshington, CC 20555 Administrative Judge
{
Jerry Kline Administrctive Judge j
Atcmic Safety cnd Licensing Eccrd Frederick J.
Shon I
U.S. Nuclect Regulatcry Ccmmission Atomic Sofety cnd Licensing Bocrd Ucshington, DC 20555 U.S.
Nuclear Regulatory Commission Ucshington, CC 2C555 Edward O'Neill i
Arn F.
Mcdgdon, Esq.
Peter Arth, Jr.
I Cffice of the General Econsel Trumon Burns
_.5.
Nuclecr Regulatory Commission Robert Kinesian s
Ucshington, DC 20555 Peter G.
Fairchild. Esq.
Californic Public Utilities Commission I
Jcseph E.
- Knotts, Jr.,
Esq.
5C5 Ucn Ness Avenue l
Uanston & Strawn Son Frcncisco. CA 99102 i
1900 L Street, N.U.
Ucsbington, DC 20C05 Adjudicatory File Secretary cf
",e Commission L.E.
Nuclecr Pegulatcry Commission DccLeting cnd Eervice Ercnch i
l Ucshington. DC E0555 U.S.
Nuclecr Regulctoru Ccmmiss1cn
[
Ucsbington. CC 20555
-"=
- R
- 111rgtcn, Esc.
I D;cblo Canycn Indeperdent Safety Committee j
DE~ Cass Street. Suite D l
Ec-terey, CA S359C Christcpher Ucrner, Esq.
i Pic"crd Lccke, Esq.
p Pccaf ic Jos crd Electric Cc.
f Q h' k g /
7 Eecle Street l
San =ronc1 scc, CA es1C5
.;.2 2cmEk i
Octed Opri. 25, ISS3, Sun t ;s Obispo Ccunt CO 3,
-.