ML20045A640

PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence

ML20045A640
Person / Time
Site:	Diablo Canyon
Issue date:	05/26/1993
From:	Locke R PACIFIC GAS & ELECTRIC CO., WINSTON & STRAWN
To:	Atomic Safety and Licensing Board Panel
References
CON-#293-14005 OLA-2, NUDOCS 9306110143
Download: ML20045A640 (8)

Text

g /9'M5 RELATED CORI.ESPONDENCE

'93 JP -1 n? :C5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

)

)

Docket Nos. 50-275-OLA_2; Pacific Gas and Electric Company

)

50-323-OLA

)

(Construction Period (Diablo Canyon Nuclear Power

)

Recovery)

Plant, Units 1 and 2)

)

)

PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO SUPPLEMENTAL INTERROGATORIES RELATED TO FIRST SET OF INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS (CABLE FAILURES) FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE Pacific Gas and Electric Company ("PG&E") herein responds to "Intervenor San Luis Obispo Mothers for Peace Supplemental Interrogatories Related to San Luis Obispo Mothers for Peace First Set of Written Interrogatories and Requests for Production of Documents to Pacific Gas and Electric Company," dated April 2, 1993

("MFP's Supplemental Interrogatories (Cable Failures)").

In accordance with the agreement entered into by PG&E and MFP concerning the scope of discovery at the May 12, 1993, prehearing conference,.

this response is limited to responses to Interrogatories 1-7 on the third page of Attachment 1 to MFP's Supplemental Interrogatories (Cable Failures), Copies of documents identified in Attachments 1

-5 are being provided to the representatives of the San Luis Obispo Mothers for Peace ("MFP")

herewith.

A facsimile copy of the affidavit required by 10 C.F.R.

l 9306110143 930526 PDR ADOCK 05000275 f r {}

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4 S 2.740b(b) for the answers to the discovery requests is included in this response; due to logistical difficulties, the original will v

follow within the next several days.

II.

ANSWERS TO INTERROGATORIES Please answer the following question with respect to the applications of the type of cable insulation that was discussed in the February 17, 1993, NRC Region V Morning Report:

Interrocatory 1:

Describe all maintenance and surveillance procedures applicable to this type of cable.

Answer to Interroaatory 1:

Electrical Maintenance activities for this cable are conducted in accordance with PG&E Maintenance procedure MP-E-54.2, a copy of which is attached to this Response. (Attachment 1).

Interroaatory 2:

Please provide records of all inspections and tests performed on this type of cable since DCNPP began operation.

Answer to Interroaatory 2:

Copies of inspections and tests for this type of cable are provided at Attachment 2 to this Response..

Interroaatory 3:

For each cable identified in response to interrogatory 1E, are temperature and radiation conditions monitored in the cables's location? How frequently are they monitored? How, if at all, is the effect of these conditions on qualified life of the cable evaluated?

Please document any such evaluations.

Answer to Interrocatory 3:

This Interrogatory refers to Question 1E which concerns environmental qualification of equipment.

Temperature and radiation monitoring are not conducted since this cable does not fall within the requirements of 10 CFR 50.49 relating to qualification of electrical equipment which is subjected to a harsh environment after a

postulated design basis accident.

See Responses to Interrogatories 1 and 2 regarding maintenance and inspections related to the cables.

Interroaatory 4:

Please provide a description of the " analysis" of the cable that is now being performed by PG&E and a private licensee contractor.

Answer to Interroaatorv 4:

See LER 1-93-005-00, April 27, 1993, a copy of which is provided at Attachment 3.

Extensive root cause investigation is continuing regarding the 12 kv cable failures, but has not yet been completed.

The LER will be supplemented to the extent necessary following completion of the root cause investigation.

Interroaatory 5:

k Please identify the private licensee contractor which is performing the analysis.

Answer to Interroaatory 5:

The primary contractor laboratory supporting our investigation is Altran Materials Engineering Incorporated, 200 High Street, Boston MA.

Interroaatorv 6:

Please provide documentation of the contract between PG&E and the private licensee contractor regarding the analysis.

Please provide copies of any correspondence, memoranda, or notes regarding the contract, and any documents discussing the analysis or its results.

Please include all drafts and final versions of documents prepared in the course of this analysis.

Answer to Interrocatorv 6:

The contract between PG&E and Altran Materials Laboratories and related materials are provided at Attachment 4 to this Response.

Interroaatorv 7:

Please provide copies of all " licensee evaluations," as described in Region V Morning Report at 3 (February 17, 1993).

f.

Answer to Interrocatorv 7:

The current Non-Conformance Report DCl-93-EM-N010 for'the 12 kv cable failures is provided at Attachment 5 to this Response.

Respectfully submitted, Joseph B. Knotts, Jr.

David A. Repka Kathryn M. Kalowsky WINSTON & STRAWN 1400 L Street, N.W.

Washington, DC 20005-3502 (202)' 71-5726

//

A Christopher J. Warner Richard F.

Locke PACIFIC GAS AND ELECTRIC COMPANY 77 Beale Street San Francisco, CA 94106 Attorneys for Pacific Gas and Electric Company Dated in San Francisco, CA this 26th day of May, 1993 RELATED CORRESPONDENCE l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j

BEFORE THE ATOMIC SAFETY AND LICENSINd9bOAND-1 R2 :05 In the Matter of:

)

)

Docket Nos. 50-275-OLA Pacific Gas and Electric Company

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50-323-OLA

)

(Construction Period (Diablo Canyon Power

)

Recapture)

Plant, Units 1 and 2)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO SUPPLEMENTAL INTERROGATORIES RELATED TO FIRST SET OF INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS (CABLE FAILURES) FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE" 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 26th day of May,1993.

Copies of documents being provided, as referenced in the discovery response, are being provided only to parties indicated by the (t) symbol.

Charles Bechhoefer, Chairman Frederick J.

Shon Administrative 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 1 White Flint North Section 11555 Rockville Pike (original + two copies)

Rockville, MD 20852

.. =

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 Nancy Culver, President Truman Burns Board of Directors California Public Utilities San Luis Obispo Mothers for Peace Commission P.O.

Box 164 505 Van Ness, Rm. 4103 Pismo Beach, CA 93448 San Francisco, CA 94102 Robert R. Wellington, Esq.

Joseph B. Knotts, Jr., Esq.

Diablo Canyon Independent Safety David A. Repka, Esq.

Committee Winston & Strawn 857 Cass Street, Suite D 1400 L Street, N.W.

Monterey, CA 93940 Washington, DC 20005-3502 Robert ninosian Jill ZamEk*

California Public Utilities 1123 Flora Road Commission Arroyo Grande, CA 93420 505 Van Ness, Rm. 4102 San Francisco, CA 94102 Mr. Gregory Minor *(t)

MHB Technical Associates 1723 Hamilton Ave., Suite K San Jose, CA 95125

)

/./

Hichard F. Locke Counsel for Pacific Gas &

Electric Company i

l i i

l UNITED STATES OF A!GRICA i'

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICNNSING BOARD In the Matter of:

)

)

Docket Nos. 50-275-OLA Pacific Gas and Bicetric Company

)

8io - 323 -OLA

)

(Construction Period (Diablo Canyon Nuclear Power

)

Recovery)

Plant, Unite 1 and 2)

)

)

AFFIDAVIT I, James E. Molden, being duly sworn, hereby state as follows.

I am en: ployed by Pacific Gas and Electric Company as Director, 1.

Instrumentation and Controls.

2.

My business address and phone number are:

Diablo Canyon Power Plant 104/5/521 P. O. Box 56 Avila Beach, CA 93424 (805) 545-4336 3.

I have provided the information which forms the basis for the answers to Interrogatories 1, 2, 3, 4, 5, 6, and 7 included in the attached "Facific Gas and Electric Cucipany's Response to Supplemental Interrogatories Related to First Set of Interrogatories and Requests for the Production of Documents (CaDie Failures) Filed by San Luis Obispo Mothers for Peace.'

4.

The information contained in the referenced interrogatory answers and responses to requests for documents is true and correct to the best of my knowledge and belief.

ames E. Molden 3,,,,., g g.

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Oeldtraf~.5;4dLW/J 08dfb Sworn and subscribed to before me this 26th day of May, 1993 op,casscna m s -

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sanom sa7Meay fuery haas-Qasema a

"'_lo sanwsomosocoum 6% Comm W Aa4WI,

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i Notary Public

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