ML20036A427

Informs Licensing Board of Communications Between Parties That Should Moot at Least One Motion.Concludes That Util Is Voluntarily Including First Set Responses within Scope of Visit in Order to Complete Discovery

ML20036A427
Person / Time
Site:	Diablo Canyon
Issue date:	05/03/1993
From:	Repka D PACIFIC GAS & ELECTRIC CO., WINSTON & STRAWN
To:	Bechhoefer C, Kline J, Shon F Atomic Safety and Licensing Board Panel
References
CON-#293-13932 OLA-2, NUDOCS 9305110205
Download: ML20036A427 (15)

Text

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2?2i 269 2500 (202) 371-5726 May 3, 1993 BY HAND DELIVERY Charles Bechhoefer, Chairman Frederick J.

Shon Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S.

Nuclear Regulatory U.S.

Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Jerry R. Kline Administrative Judge Atomic Safety and Licensing Board U.S.

Nuclear Regulatory Commission Washington, DC 20555 Re:

Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Docket Nos. 50-275-OLA. 50-323-OLA1(Construction Period Recapture) b

Dear Administrative Judges:

On April 26, 1993, the San Luis Obispo Mothers for Peace

("MFP") filed several motions in this proceeding.

This letter is to inform the Licensing Board of communications between the parties that should moot at least one of the motions.

In its " Motion for Extension of Time to Examine Documents at Diablo Canyon Nuclear Power Plant"

(" Motion"), MFP seeks time beyond the April 12,

1993, discovery completion date in this proceeding in order to complete its document discovery at the Diablo Canyon Power Plant ("DCPP").

MFP states that it needs the time to inspect / copy documents previously identified by Pacific Gas

& Electric Company ("PG&E") as responsive to MFP's First, Second, and Third Sets of discovery requests.

MFP, in its Motion, proposes a site visit on May 4, 5 and/or 6.

9305110205 930503 PDR ADOCK 050002 5 3

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WINSTON & STILuYN May 3, 1993 Page 2 PG&E has agreed to this proposal, as documented in the attached letter to Ms. ZamEk of MFP.

As stated therein, PG&E will make available documents previously identified by PG&E as responsive to MFP's First, Second, and Third Sets of requests.

Note that with respect to the First set, PG&E continues to believe that MFP has shown no good cause for the additional opportunity for

]

document discovery, given the time available previously to schedule this visit.

Nonetheless, PG&E is voluntarily including First set j

responses within the scope of the visit in order to complete the discovery.

Also, as stated in the letter to Ms. ZamEk, the document production will not include any documents for which discovery objections are pending.

Objectionable requests were not included i

i in the scope of MFP's Motion.

Assuming MFP arrives for document production as proposed, the Motion should be treated as moot.

PG&E wishes also to highlight a matter addressed by MFP in its filings of April 26, 1993.

MFP takes issue at several places in its filings with PG&E's production of documents at DCPP on March 16, 1993.

Given the limited time MFP stayed at the site and the scope of the document production involved, PG&E believes its production of documents was reasonable.

Moreover, PG&E, in good faith, provided those LERs and NCRs which it believed MFP had requested (as shown by the documents attached to the letter to i

Ms. ZamEk).

PG&E has been willing throughout this proceeding to make specific documents available to MFP, and remains willing to accommodate MFP at the site this week.

We do not understand MFP's reluctance to communicate with PG&E before now regarding discovery and its unwillingness to get on with the task.

With respect to MFP's other filings of April 26, 1993, PG&E notes that the normal response date for motions filed on that date would be May 11, 1993 -- the date of the scheduled prehearing conference.

Therefore, PG&E proposes to defer its responses to the following MFP filings until the oral presentation at the conference:

1)

MFP's " Motion to Compel Pacific Gas and Electric Company to Respond to the Second and Third Sets of Interrogatories and Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace;"

2)

MFP's " Motion for Leave to Reply to Pacific Gas and Electric Company's Opposition to Additional Discovery Re:

Cables" (as well as the Reply included therein).

1 l

i WINSTON & STRAWN May 3, 1993 i

Page 3 1

MFP's other filings'of April 26, 1993 require no ' response from PG&E.

Very truly yours, David A.

R pka Counsel for Pacific Gas &

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NEW YORK hiY $0038 4961 2921 269 2500 (202) 371-5726 April 30, 1993 l

BY FEDERAL EXPRESS Ms. Jill ZamEk San Luis Obispo Mothers for Peace 1123 Flora Road Arroyo Grande, CA 93420 Re:

Document Production at Diablo Canyon

Dear Ms. ZamEk:

This letter is a follow-up to Chris Warner's telephone call to you yesterday, and responds to the San Luis Obispo Mothers for Peace (MFP) request of April 26, 1993 for further document discovery at Diablo Canyon Power Plant (DCPP).

i As you know, PG&E has previously offered MFP, on numerous l

occasions, the opportunity to review documents at DCPP pursuant to l

discovery requests.

Therefore, as Chris Warner mentioned to you yesterday, we would be happy to accept your request for further document prod ction at DCPP on May 4, 5 and/or 6, as suggested in l

MFP's Motion for Extension of Time to Examine Documents at DCPP.

)

During this time we would make available any of the documents we have previously identified as-subject to production in our responses to MFP's First, Second, and Third sets of discovery requests filed in the license amendment proceeding. To enhance the efficiency of the effort, we also accept MFP's commitment that you provide us, prior to May 4, a list of those documents MFP wishes to copy at DCPP.

To'the extent possible, we'will then have those documents ready when MFP's_ representatives ~ arrive at the site.

~

Although we do not'believe.MFP has demonstrated good cause-fo extending the April 12 deadline for document review in connection with the First set of requests, PG&E, in good faith, is willing to voluntarily include documents in response to the First set of requests in the documen~ production next week.

Also,'during the site visit, PG&E will not waive any objections it has made to specific document. requests to 'date.

. - -... ~ -..

i WINSTON & STRAWN Ms. Jill ZamEk l

April 30, 1993 Page 2 l

Accordingly, we will not make available documents subject to our previous objections, either in the First, Second or Third sets of l

requests, or in the request for supplemental discovery regarding cable matters.

The focus of the site visit should be to complete document production which is not in dispute.

Two additional points are in order.

First, in MFP's papers of April 26, MFP complains that we filed our responses to the second and Third sets on April 12, stating that documents would be made available at the site only through April 12.

Contrary to j

your reading, it was never our intent to limit this document j

production to April 12, if the request in the Second or Third set was a new request and PG&E identified specific documents to be made available.

With respect to these Second and Third set responses we j

anticipated follow-up production at the site.

In any event, we now i

welcome MFP's request to visit the site next week to complete document production where not in dispute.

i Second, MFP in two of its filings of April 26 takes issue with the fact that during the first site visit PG&E allegedly did not provide all of the LERs and NCRs identified in Attachments 2 and 3 to our response to the First set of discovery requests.

However, attached to this letter is the mark-up of the two attachments given to me on the day of the first site visit by l

Rochelle Becker.

The LERs and NCRs checked by Ms. Becker on that mark-up were those we understood to be requested, and those were the LERs and NCRs we indeed provided.

Obviously, if there are other LERs and NCRs from Attachments 2 and 3 that MFP still wants, we will be happy to provide them during the site visit next week.

l Please contact me or Chris Warner (415) 973-6695 no later than noon (PDT), Monday, May 3, 1993, to make final arrangements for your site visit.

Very truly yours, 4-P David A.

Repka Counsel for Pacific Gas

& Electric Company l

l l

Interrecaterv 12

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MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE

' SUBJECT-DCl-90-EM-NOO1 1-12-90' Dedication of elays V i

DC2-90-EM-N028 4-19-90 BTC 232/High charging l

current e

DC2-90-EM-N029 4-19-90 Valve 8805B failed to meet stroke'open time i

DC1-90-EM-N042 6-11-90 SI-1-8805A Failed to cycle on' actuation signal 6

DC2-90-EM-N044 6-11-90 Main generator load j

rejection i

DCO-90-EM-N070 10-17-90 RHR motor 1-2 work not done in accordance with work l

order OCO-90-EM-N081 12-4-90 Uninterruptible power supply for Units 1 and 2 AMSAC (ATWS mitigation' system and circuitry) failed' j

DC1-90-MM-N002 1-15-90 Failure sleeves on-condenser DCO-90-MM-N013 3-16-90 Crosby relief. valves f

r DC2-90-MM-N016 3-28-90 Snubbers found locked j

DC2-90-MM-NO23 4-17-90 Check valve MS-2-5166 was found stuck open DC2-90-MM-N055 8-28-90 Snubber pin missing i

DC2-90-MM-N071 10-25-90 FW-2-LCV-106 and 107 actuators installed DC2-90-MM-N078 11-16-90 FCV-152 leakoff line supports not per design-DCO-90-MM-N089 12-21-90 Mechanical maintenance METE DCO-91-EM-N009 1-21-91 FCV-495/496 corrosion prevented manual valve operation. March 11, 1993 J

l

t MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE SUBJECT DC1-91-EM-N027 3-6-91 RHR pump motor screws missing from bearing housing cap DCl-91-EM-N041 2-5-92 ESF actuation - CVI-

-DCl-91-EM-NO46 4-29-91 Unit 1 trip, 4-24-91 manual i

t trip of Unit 1 due to power increase

% DC2-91-EM-N077 9-12-91 MOV 9001B motor leads not

/#

L joined with Raychem splices DC2-91-EM-N084 10-3-91 Bus 2-G fire in'480v motor control centerrafter start of diesel engine 2-1 DC2-91-EM-N086 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-j i

transformer-3 l

DC1-91-MM-N015 2-13-91 ASW pipe support 286-72R l

unable to perform desi'gn i

t function i

DCl-91-MM-N018 2-19-91 pipe support stud found not welded to containment liner DC1-91-MM-N028 3-B-91 Loss of off-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 DCO-91-MM-NO37 3-22-91 Weld filler material not controlled in accordance with nuclear weld control manual March 11, 1993 i

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i MAINTENANCE AND SURVEILLANCE NCRs 5

i NCR NUMBERL INITIATE DATE SUBJECT DCO-91-MM-N042

.4-3-91.

. Foreign material exclusion 1

area control less than I

adequate DCO-91-MM-NO49 6-6-91 DEG 1-3 test cock valve broke when tightened DCO-90-MM-N057 8-31-90 Fire pump 0-2 maint deficiencies' DCO-91-MM-N061 7-12-91

' Lubrication storage and l

handling discrepancies f

DC1-91-MM-N066 8-6-91 Component cooling water heat exchanger 1-1 flooding DCl-91-MM-N067 8-13-91 Auxillary salt water pump vault drain.

Check valves i

DC2-91-MM-N069 8-14-91 Leaking from charging.

'ubsystem of chemical and i

s volume control system DC2-91-MM-N072 8-27-91 MS-2-RV-225/60 relief valve i

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 i

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 cha'nnel adjusted DC2-92-T1-N062 7-16-91 CVI during. maintenance DCl-91-T1-N068 8-13-91 CVI curing maintenance DC2-91-T1-N088 10-7 Inadvertent SI due to personnel error March 11, 1993

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MAINTENANCE AND SURVEILLANCE NCRs t

NCR NUMBER INITIATE DATE SUBJECT DC1-91-T1-N096 10-25-91 Containment wide range ~ level i

failed low t

DC1-92-T1-NO39 9-6-92 FHB ventilation swap due to personnel error DC2-90-OP-N020 4-16-90 Inadvertent ESF ventilation systems mode transfer DC1-90-OP-N082 12-6-90 Unit 1 trip, 12-5-90, due to f

turbine runback failed to reduce generator level DC1-90-OP-N083 12-10-90 ESF actuation due to leaking feedwater.

Check valves Naintenance program DCO-92-QA-N003 1-31-92 commitment had not been met

)/DCO-91-MM-N079 9-18-91 Diesel generator.2.2 loose v[

camshaft dampener fastener DC2-91-MM-N094 10-21-91 STP V-3P3 failure /FW-2-532 l

) DCO-92-MM-N007 2-12-92 Containment fan coolers -

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counterweights on backdraft dampers missing or lacking i

locknuts DC1-92-MM-N021 5-15-92 1-171SL snubber damage DCO-92-MM-N022 5-26-92 HVAC maintenance practices -

are they sufficient to assure equipment reliability j

and safety l

DC1-92-MM-NO33 7-8-92 Centrifugal charging pump D-1-motorhold down bolts found unmarked and machined down to their root diameter V a l v e f a i l e d t o f u l l y o p e n,/

(DC2 EM-NO 2 6 6-3-92 DCl-92-T1-N020 4-29-92 CV1 RM-14B Spike

'( DC2-91-SS-N013 2-5-91 Fire protection (SSPS halon) g/

- damper failed to close March 11, 1993 I

f KAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE SUBJECT upon operation of the halon system NDCO-90-SE-N080 11-21-90 Fire in electrical panel V i

DCl-90-WP-N093 12-28-90 Inadvertent ground causes CV1'in Unit 1 h

4 DC1-91-WP-N012 2-1-91 Reactor trip - FW-1-530 &

540 closure resulting in a low steam generator level trip i

DC1-91-WP-N021 2-20-91 Quality-related maintenance l

work performed w/o a work i

order as required by APC-4053 DC2-91-WP-N097 10-25-91 Missed PMT (post maintenance test not performed following

-maintenance on a safety injection valve DC1-92-EM-N054 10-31-92 H0 POT on ASW PP motor 1-2 cable failed 1

'y(DCO-90-MM-N057 8-31-90 Fire pump 0-2. maintenance s/

deficiencies DCO-90-TN-N064 10-15-90 Numerous pump STPs do not strictly meet requirements of ASME Code section XI DCO-91-TN-NO26 3-5-91 Various check valves not verified stroked closed as part of IST testing program DCD-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

^

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i MAINTENANCE AND SURVEILLANCE NCRs NCR NUMBER INITIATE DATE SUBJECT DC2-90-T1-NO31 5-18-90 Steam flow transmitter reinstalled with sensing lines crossed DC092-MF-N025 5-29-92 Design life / shelf life limitations for non-EQ equipment not adequately implemented DCO-91-TR-N044 4-4-91 Maintenance Department's implementation of program requirements regarding personnel qualifications DCO-92-TN-N004 1-28-92 Long term cooling water hoses hydo tested, failed and were not replaced, other LTCW hose were not tested DCl-92-TC-N041 Time limit for surveillance required by Tech Specs including extension exceeded when a technician to perform gas decap tank surveillance DCO-91-EN-N024 6-14-91 Safety related solenoid valve with unidentified electrical splice DC1-91-EN-N019 5-6-91 Dielectric material in a connector different than specified in the environmental qualification report DC2-91-TN-N023 2-21-91 Undersized welds installed in plant during work for the CVCS letdown line repair DC1-92-TP-N052 10-12-92 Failed to recognize ASW pump I

was in alert range.

Therefore, tests were not performed on an accelerated frequency l

l l

, March 11, 1993 l

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j MAINTENANCE AND SURVEILLANCE NCRs 1

SUBJECT INITIATE DATE NCR NUMBER One damper failed during the 11-26-91 cable spreading room cardox DC2-91-SS-N101 surveillance test l

Work controls not effective 12-5-91 in controlling accumulation DC2-91-TN-N102 I

of unsecured loose material j

in containment t

Spurious discharge of cardox 9-21-90 DCD-90-SS-N063 system during diesel

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generator cardox system testing Certain check valves are not j

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5-28-91 verified for full stroking l

DCD-91-TN-N048 as per IST Program

open, l

.NRC violation for not having l

7-31-91 DCO-91-TN-N065 appropriate acceptance criteria for diesel l

generator starting air j

compressor l

l Boric acid heat tracing l

1-17-90 functional test not l

DC1-90-WP-N003 performed on schedule Newly installed RHR' valve 6-11-91 DC1-91-EN-N016 failed to close during surveillance test-During STP M-16E operator DC1-91-OP-N059 error caused an inadvertent 7-5-91 actuation of ESF During performance of 3-25-91 DC1-91-OP-NO3B surveillance test an inadvertent ESF occurred Fuel handling building 1-18-91 ventilation system failed DCl-91-TN-N 007 tech spec requirement Boric acid transfer pump was 1-23-92 DC1-92-TN-N003 not performed on an March 11, 1993...

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t MAINTENANCE AND SURVEILLANCE NCRs i

NCR NUMBER INITIATE DATE SUBJECT j

accelerated frequency as required l

DC2-92-OP-NO32 7-2-92 Missed step in STP I-1B performance j

DC1-92-EN-NO31 11-19-92 Recovery time determined i'i during STP did not meet-DCPP commitments for the diesel generator i

DC1-91-TN-N002 1-3-91 Back leakage through main feedwater check valve may impact AFW system flow operability j

l l

P1/NCRs2. dis I

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. March 11, 1993-

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.j Attachment':

--a*-meaterv 19 i

acen_socq ree tATED TO VAINTENANCE/ SURVEILLANCE 004-00 Co.

inment V gtilation Isolation and FHB ventilation _'f tem Shift to ine Rembatal Mode Due to Personnel Error During Tro.leshootinct

-005-01 "losu N of the Main Steamline Bypass Valves 2.

Due to Inadequa Backf1_ ling w_ Transmitter Sensing Lines 2-A-006-01 ' olati of Technical Specification Because of Inoperable S % m Flow *ransm' ters Due to Personnel Error

-007-OhissMurveillasnce of Sealed Sources Due to 1.

Personnel Error v 2-90-009-01 Inoperable Room Temperature Monitor'Due to Personnel Error

/ 1-90-014-00 Reactor Trip.on Turbine Trip Due to

nadequate Evaluation of Runback Limit Setpoint i

)

1-90-015-0CT IST Actuation, P-14 (High-High Steam Generator Water Level) Due to Feedwater R lating and Bypass Valves Leakage "M 4 x W.

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/ 1-90-017.Ger~ Reactor Trip Resulting from Failed Pressurizer Spray Valve Due to Incorrect Screw Installation OM w. ct 4". i 1-90-018-00 Fire Damper Cardox Actu tion Fusible Link Asse ly Incorrectly Installed for Indeterminate Reason 2-91-001-00 Centainment Ventilation Isolation Resulting From a Voltage Transient Due to Personnel Error i

/

01

/

1-91-002-po' Reactor Trip on Steam Generator Low Level with Steam Flow /Feedwater Mismatch due to Personnel Error 2-91-002-00 Potential Missetting of Main Steam Line Code Safety Valve due to Failure of Test Equipment 6

/1-91-004-9tf 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 Manual Reactor Trip Caused by Rod Control Power Supply Fuse Failure Due to Personnel Error

/ 1-91-009-00 Injection Due to Leaking Steam Dump ValveReactor Trip Due to Personnel Error on 1

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/ 2-91-009-01 10 CFR 100 Dose Limits Potentially Exceeded in Event of Design Basis Loss of Coolant Accident Recovery as a i

Result of Valve Leakage 2-91-011-00 Failure to Test Valve Following Maintenance Due to/ Personnel Error

/

1-91-012-00 Emergency Diesel Fuel Oil Inventory j

Surveillance Missed Due to Personnel Error 2-91-012-00 Debris in Containment, Lack of. Visual Inspections i

l j 1-91-013-00 Containment Ventilation Isolation During Maintenance due to Personnel Error 1 % 01 M CIN::Qs Ptsdq}tenance A 005-01 Containment Ventilation Isolation Due to l

Spurious High Radiation Signal l

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t ? -005 ;0 Di;;:1 ?"al Oil As ansIer sy.u==

vorzuston M 2-010 CC "C" F:il:

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f 1- 0 2-m 7-00 FMB Tv m rt Err- _

1 1 0 0 h -v u disseu C;.crie try Cm ;;ill:.r i

fr-92-024-00 Missed Accelerated Surveillance 4-93-002-00 Containment Isolation Valve Not Isolated in Accordance with Technical Specifications I

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