ML20045D829
| ML20045D829 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/18/1993 |
| From: | Warner C PACIFIC GAS & ELECTRIC CO., WINSTON & STRAWN |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-14057 OLA-2, NUDOCS 9306300103 | |
| Download: ML20045D829 (26) | |
Text
.
]V057 gTED CopRESPO@EW June 18, 1993 g
UNITED STATES OF AMERICA
'93 JUN 21 il9 :39 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
{j.Ml 4 Q,.,
In the Matter of:
)
)
Docket Nos. 50-275-OLA 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 THIRD SET OF SUPPLEMENTAL INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS ~(AGING)
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 Third Set of Supplemental Interrogatories and Requests for-Production of-Documents to Pacific Gas and Electric Company Re: Aging," dated June 4, 1993 ("MFP's Supplemental Interrogatories (Aging)").
Interrocatory 1:
Answer interrogatories 1 through 9 below with respect to the following important-to-safety components located in a harsh environment:
check valves Limitorque valve operators cables with bonded Hypalon jackets cableslistedinAttachment1toInformation Notice 93-33 [ April 28, 1993]1 1/ nformation Notice 93-33, re: Potential Deficiency of Certain I
Class IE Instrumentation and Control Cables, was served on the Licensing Board and parties by Board Notification 93-11 (May 5, 1993).
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a)
Describe the method [s), if any, used by PG&E to determine whether the actual operating environment is bounded by the conditions to which the component was aged during environmental qualification testing, or which were assumed for purposes of environmental qualification.
In addition, please provide the results of such method [s] as they have been applied to each component.
b)
Provide the equipment qualification files for these components.
Answer to Interroaatory 1:
a)
General The components listed in these interrogatories (check valves, Limitorque motor operators, electrical cables) are specified, designed and fabricated for nuclear power plant service.
Applications at numerous power plants over extended periods of operation demonstrate that this type of equipment is fully satisfactory for typical power plant environmental conditions, including temperature, vibration,
- humidity, radiation, erosion / corrosion and submergence.
Required periodic inspection, testing and surveillance provide assurance of continued equipment performance within these typical power plant environments.
Changes to environmental conditions which might have adverse effects on these components are monitored as a function of normal surveillance testing and periodic checks during routine t
preventive maintenance.
Examples of procedures for both environmentally-qualified and non-environmentally-qualified equipment include:
Procedure CF3.ID1, Maintenance and Surveillance of Environmentally Qualified Electrical Equipment l l
t
Procedure AP C-761, Condition Monitoring of Environmentally Qualified Electrical Equipment l.
i Procedure MP E-53.10A, Preventative Maintenance of Limitorque Motor Operators Procedure MP E-57.4, Environmental Qualification Maintenance and Survey of Containment Penetrations, Cables and Splices Procedure AP D-760, Check Valve Predictive Maintenance and Inspection Program Procedure PD TS5, Engineering Support Functions l
Check Valves Check valves are not subject to environmental qualification under 10 CFR 50.49, because they are l
mechanical
- devices, not electrical equipment.
In addition, safety-related check valves are designed for i
normal operating conditions of high flow velocity, high i
pressure and high temperature.
Therefore, the environmental parameters listed in Interrogatories 2-9, i
below, are not expected to adversely affect the service life of the valves.
Any degradation of safety-related check valves resulting l
from environmental conditions or other causes is detected i
through the DCPP Check Valve Predictive Maintenance and l
l Inspection
- Prograla, AP D-760, and the DCPP preventive maintenance program, AP C-750, both of which previously have been described.
See Answers to Requests 3-6, PG&E's " Response to Second Set of Written Interrogatories and Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace," April 12, 1993. l l
l
-~_.
t i
Limitorcue Motor Operators Limitorque motor operators are environmentally qualified where they are subject to a harsh environment from postulated accident-conditions..
Therefore, the answers to Interrogatories 2-9 regarding specific environmental parameters apply to these operators to the extent that the parameters themselves are required to be monitored in connection with the maintenance and surveillance of environmentally-qualified equipment.
In addition, such operators, whether environmentally qualified or not, are also subject to routine preventive maintenance and periodic inspection and surveillance.
The maintenance and surveillance program. for Limitorque motor operators previously has been provided.
See Procedure MP E-53.10A (provided following the May 6, 1993 plant site visit);
Answers to Requests 7-9, PG&E's " Response to Second Set of Written Interrogatories and Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace," April 12, 1993.
Environmentally Oualified Electrical Cables Electrical cables with bonded Hypalon jackets and electrical cables listed in NRC Information Notice 93-33 at DCPP are generally Instrumentation and Control (I&C) cables j
i and low power voltage cables.
Variations in environmental parameters during normal ope ~ rating conditions are unlikely to -
.= -
affect the ability of the cables to perform their safety-related function.
J The cables cited in Interrogatory 1 are subject to environmental qualification and, therefore, the answers to Interrogatories 2-9,
- below, apply to the extent the parameters are required to be monitored in connection with the maintenance of environmentally-qualified equipment.
PG&E previously has provided MFP with a description of the 4
temperature monitoring program for these cables.
See Answers to Interrogatories 32 and 33, PG&E's " Response to Second Set of Supplemental Interrogatories and Requests for Production of Documents Re: Cable Failures at Diablo Canyon Nuclear Power Plant Filed by San Luis Obispo Mothers for Peace," May 28, 1993. (Due to an inadvertent error, the temperature monitoring program was referenced as Maintenance Procedure (MP) E-57.4.
The correct reference is MP E-57.8A.)
b)
PG&E objects to this interrogatory, because it relates to the environmental qualification of equipment, not to the maintenance of already qualified equipment.
See Answer to Document Request 27, PG&E's
" Response to First Set of Interrogatories and Request for Production of Documents Filed by San Luis obispo Mothers for Peace (Re: Contention I),"
March 12, 1993; see also "Prehearing Conference Order (Late-filed Contentions and Discovery)," LBP-93-9, June 17,1993, at.
29 (Denial of late-filed contention on environmental qualification issue).
t.
l l
Interroaatory 2:
In NRC Information Notice No. 89-30 [ March 15, 1989], the NRC alerted licensees to " potential problems resulting from high temperature environments in areas that contain safety-related equipment or electrical cables." Idz at 1.2/
The NRC noted that "It is important for licensees to be aware that there are areas within the plant where the local temperature may exceed equipment qualification specifications even when the bulk temperature, as measured by a limited number of sencors, is indicating that it is lower than the qualification temperature. " Idz at 3. SLOMFP seeks to determine the methods, accuracy and situations under which PG&E measures local temperatures to which important-to-safety equipment is subjected.
a)
Provide a description of the method for measuring the j
temperature inside containment and a description of the method for measuring the temperature in other areas where important-to-safety equipment is located.
Into what zones, if any, is the containment broken for purposes of temperature measurement?
Please provide:
[i]
the results of all such temperature measurements;
[11] the results of any comparison betweers these temperature measurements and environmental qualification specifications for important-to-safety equipment in each zone.
b)
Provide copies of any documents generated in response to Temporary Instruction 2515/88, "Information on High Temperature Inside Containment /Drywell in PWR and BWR Plants;
[ June 30, 1988].
[This document is referenced in Information Notice 88-30 at page 1.]
j c)
Information Notice 89-30 states that: "It is expected that recipients will review the information [provided in the Information Notice] for applicability to their facilities and consider actions, as appropriate, to avoid similar problems."
Describe your evaluation of the applicability of this l
2/A copy of NRC Information Notice No. 89-30 [ March 15, 1989] is attached to SLOMFP Second Set of Supplemental Interrogatories Re:
Cables [May 21, 1993)..-
information Notice to Diablo Canyon Nuclear Power Plant
("DCNPP"] and discuss any actions that have been taken or considered to avoid similar problems.
In addition, please provide copies of any documents that discuss your analysis well as any changes that have been made or contemplated.I/as Answer to Interrocatory 2:
4 a) and c)
PG&E previously has provided MFP with a
description of the temperature monitoring program for environmentally-qualified equipment, including cables and Limitorque motor operators. See Answers to Interrogdtories 32 and 33, PG&E's " Response to Second Set of Supplemental 4
Interrogatories and Requests for Production of Documents Re:
Cable Failures at Diablo Canyon Nuclear Power Plant Filed by San Luis Obispo Mothers for Peace," May 28, 1993.
Standard Test Procedure (STP) I-1A, ROUTINE SHIFT CHECKS REOUIRED BY LICENSES, AND STP I-1B, ROUTINE DAILY CHECKS REOUIRED BY LICENSES, provide requirements for the monitoring of outside, and inside containment temperatures respectively.
These temperature measurements assure that technical specifications which provide for containment average air temperature monitoring (T.S. 3/4.6.1.5) and important outside containment area temperature monitoring (T.S. 3/4.7.11) are met during plant operation.
In addition, Maintenance Procedure MP E-57.8A establishes PG&E's program for temperature monitoring in connection with maintenance of such environmentally-qualified 2/SLOMFP acknowledges receipt of Memorandum dated June 14, 1989 regarding NRC IE Notice 89-30 and Memoraridum dated February 13, 1989 regarding NRC Information Notice 87-65.,
~
equipment.
The results of these tempsrature monitoring activities are available for inspection at DCPP.
l b)
PG&E has no record of any documentation pertaining to Temporary Instruction 2515/88, "Information on High Temperature Inside Containment /Drywell in PWR and BWR Plants;
[ June 30, 1988).
NRC Temporary Instructions probably are applicable to inspections conducted by NRC staff, not to activities by licensees.
Interroaatory 3:
In NRC Information Notice No. 89-30, Supp. 1 [ November 1,
1990)
[ attached),
the NRC describes instances in which j
elevated temperatures had adverse effects on operability of emergency diesel generators and solid state protection system alarms.
The Information Notice states that: "It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems."
In addition, please provide copies
.of any documents that discuss your analysis, as well as any changes that have been made or contemplated.
Answer to Interrocatory 3:
Issues identified in NRC Information Notice No. 89-30, Supp.
1, are not applicable to the check valves, Limitorque motor operators or cables that are subject to this set of interrogatories.
Interrocatory 4:
SLOMFP seeks to determine the methods, accuracy and situations under which PG&E measures vibration to which important-to-safety equipment is subjected.
Provide A description of the method for measuring vibration inside containment and a..
description of the method for measuring vibration in other areas where important-to-safety equipment is located.
Into what zones, if any, is the containment broken for purposes of vibration measurement ?
Please provide:
[i]
the results of all such vibration measurements; (ii) the results of any comparison between these vibrations measurements and environmental qualification specifications for important-to-safety equipment in each zone.
Answer to Interrocatory 4:
Limitorque motor operators, check valves and cables are specified, designed and built to accommodate vibration conditions normally experienced during plant operation.
Specific environmental qualification testing criteria for vibration, except for seismic, are therefore not normally included in the equipment specification.
During normal plant walkdowns by engineering, operations and maintenance personnel, any unusual vibration conditions are reported to engineering for evaluation.
If any unusual vibration is
- detected, vibration measurements of piping systems (including associated equipment / components)'are made using velocity probes. Occasionally, other diagnostic devices are used, e.g.,
proximity probes, strain gages, fast Fourier Transform analyzers.
The major source of vibration for the equipment under review is rotating equipment.
Periodic surveillance testing l
of critical rotating equipment is performed to assure that the equipment is functioning within acceptable ranges.
Any unacceptable conditions are corrected and documented, with the.
.-_.-r-
results trended to assure continued equipment performance.
Certain rotating equipment (e.g., reactor coolant pumps, main feedwater pumps, main generator) has continuous vibration monitoring devices (proximity probes) permanently installed to trend and rapidly detect any unusual conditions.
i check valves are generally not a source of vibration.
If l
any leakage problems are observed, the valves are inspected l
l and repaired as required.
Limitorque motor operators are normally mounted on valves in piping systems.
As such, they would only be subjected to vibration if the piping system itself vibrates.
- However, piping system vibration is controlled as described above.
To the extent Limitorque motor operators are located in proximity l
to rotating equipment which is subject to periodic or continuous vibration monitoring, maintenance and surveillance records relevant to such vibration monitoring are available at DCPP for inspection.
In addition, these motor operators are i
designed and tested for dynamic seismic loads, which are typically far more severe than vibrations in piping systems l
during normal plant operation.
Cables are normally not subjected to vibration, unless they are attached to rotating equipment.
In those cases, the connections to the equipment are designed to accommodate l
anticipated levels of vibration.
- Finally, it should be' noted that 10CFR50. 49 (b) (3) (c) specifically excludes dynamic qualification from the l
environmental qualification process.
Vibration as an l
environmental parameter is not specifically measured within the scope of current EQ maintenance activities for Limitorque motor operators or cables subject to EQ requirements.
- However, if any problems are encountered due to device vibration, the methods and procedures, as discussed in the l
response to Interrogatory la, would provide assurance that the problem would be promptly reviewed and resolved.
i l
1 Interrocatory 5:
SLOMFP seeks to determine the methods, accuracy and situations i
under which PG&E measures humidity to which important-to-safety equipment is subjected.
Provide a description of the method for measuring humidity inside containment and a
description of the method for measuring humidity in other areas where important-to-safety equipment is located.
Into what zones, if any, is the containment broken for purposes of humidity measurement?
Please provide.
[i]
the results of all such humidity measurements; (ii) the results of any comparison between these humidity i
measurements and environmental qualification specifications for important-to-safety equipment in each zone.
Answer to Interroaatory 5:
Any adverse effects of humidity are monitored as a function of normal STP and periodic functional checks.
Nonetheless, humidity effects involving Limitorque motor operators, environmentally qualified cables, and check valves are considered in the original equipment design.
Measurement of humidity conditions in-containment is not l
required by 10 CFR 50.49 because EQ components are designed
- - m.
M
for usage in harsh environmental conditions, including usage in saturated steam conditions (100 % Relative Humidity).
Furthermore, with respect to eleccrical cable, NUREG 0588 states that the effects of relative humidity need not be considered in the test aging process.
Per the requirements of 10CFR50.49(e) (2) humidity is only d
required to be considered for design basis accidents.
In l
situations outside containment where small leaks in system
)
piping might create localized, high humidity conditions, current methods and procedures, as discussed in the response to Interrogatory la, provide assurance that the problem would 4
be promptly reviewed and resolved.
Interroaatorv 6:
SLOMFP seeks to determine the methods, accuracy and situations under which PG&E measures radiation exposure to which important-to-safety equipment is subjected.
Provide a
description of the method for measuring radiation exposure inside containment and a description of the method for measuring radiation exposure in other areas where important-to-safety equipment is located.
Into what zones, if any, is the containment broken for purposes of radiation exposure measurement?
Please provide:
4
[1]
the results of all such radiation exposure measurements;
[11] the results of any comparison between these radiation exposure measurements and environmental qualification specifications for important-to-safety equipment in each zone.
Answer to Interroaatorv 6:
Limitorque motor operators and EQ cables located both inside and outside containment, which may be exposed to.
significant radiation doses have been environmentally qualified to very conservative dose estimates, using worst case assumptions.
These qualification margins are sufficient to assure that all EQ radiation qualification doses exceed any possible plant dose during normal operations by a large margin.
Interroaatorv 7:
SLOMFP seeks to determine the methods, accuracy and situations under which PG&E measures corrosion to which important-tn-safety equipment is subjected.
Provide a description of the method for measuring corrosion inside containment and a description of the method for measuring corrosion in other areas where important-to-safety equipment is located.
Into what zones, if any, is the containment broken for purposes of corrosion measurement?
Please provide:
j
[1]
the results of all such corrosion measurements;
{ii] the results of any comparison between these corrosion measurements and environmental qualification specifications for important-to-safety equipmat in each l
zone.
Answer to Interroaatorv 7:
Corrosion effects involving Limitorque motor operators, environmentally qualified
- cables, and check valves are considered in the original equipment design. These components are constructed with significant design margin with respect to environmental parameters expected in normal nuclear power plant service.
Per the requirements of 10CFR50.49, corrosion is not required to be included in the parameters to be considered during environmental qualification of equipment.
However,,
t i
l PG&E's Erosion / Corrosion Monitoring Program identifies, monitors and mitigates erosion / corrosion degradation in susceptible plant piping and components. (PG&E previously has-described this program.
See Answer to Interrogatory 14, 4
PG&E's " Response Third - Set of Written Interrogatories and-l
]
Requests for Production of Documents by San Luis. Obispo Mothers for Peace," dated April 12, 1993.
If problems are j
encountered due to the effects of corrosion, current methods j
and procedures, as discussed in the response to Interrogatory l
la, provide assurance that the problem would be promptly
}
reviewed and resolved.
l Interroaatorv 8:
I SLOMFP seeks to determine the methods, accuracy and situations under which PG&E measures submergence to which important-to-
}
safety equipment is subjected.
Provide a description of the j
method for measuring submergence inside containment and a j'
description of the method for measuring submergence in other j
' areas where important-to-safety equipment is located.
Into what zones, if any, is the containrent broken for purposes of j
submergence measurement?
Please provide:
[i]
the results of all such submergence measurements;
)
[11] the results of any comparison between these submergence measurements and environmental qualification specifications for important-to-safety equipment in each
{
zone.
l.
Answer to Interrocatorv 8:
No EQ Limitorque motor operators or cables, which could be exposed to a postulated harsh environment, are subjected to submergence during normal plant operation.
Submergence is postulated to occur after a design basis accident when large,
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volumes of coolant cro released due to failures in the primary i
LOCA inside coolant piping (Loss Of Coolant Accident containment) or a secondary coolant piping (High Energy Line HELB outside containment).
Where applicable, the Break equipment is qualified for these design basis conditions.
In situations where small leaks in system piping night occur, some localized flooding may be possible.
- However, normal plant monitoring and in-service maintenance would promptly identify and remedy the problem.
- However, if problems are encountered due to device localized flooding, current methods and procedures, as discussed in the Answer to Interrogatory la, provide assurance that the problem would be promptly reviewed and resolved.
Interroaatorv 9:
SLOMFP seeks to determine the methods, accuracy and situations under which PG&E measures a combination of factors (such as vibration and corrosion) to which important-to-safety equipment is subjected.
Provide a description of the method for measuring a combination of factors inside containment and a description of the j
method for measuring a combination of factors in other areas where important-to-safety equipment is located.
Into what zones, if any, is the containment broken for purposes of combination of factors measurement?
Please provide:
[i]
the results of all such combination of factors measurements;
[11] the results of any comparison between these combination of factors measurements and environmental qualification specifications for important-to-safety equipment in each zone..
Answer to Interroaatorv 9:
Combinations of environmental factors involving Limitorque motor operators, environmentally qualified cables, and check valves are inherently considered in the original equipment design.
These components are constructed with significant design margin with respect to environmental parameters expected in nuclear power plant service. Industry codes and standards recognize installed conditions and provide design margin to account for any expected degradation.
Per the requirements of 10CFR50.49, synergistic effects, where significant, were considered in the environmental qualification of this equipment.
10CFR50.49 endorsed IEEE Standard 323.
IEEE Standard 323 defines the methodology for type testing of components.
This methodology is based upon sequential testing of aging parameters, not simultaneous testing.
Because synergistic effects were conservatively considered in the original environmental qualification of the equipment, combination of factors as an environmental parameter is not specifically measured within the scope of current EQ maintenance activities. If problems are encountered due to the effects of various factors on any of these components, current methods and procedures, as discussed in the response to Interrogatory la, provide assurance that the problem would be promptly reviewed and tracked to completion. ^
r e
Interrocatory 10:
When DCPP was first constructed, what. was the expected i
qualified, life of the steam generator tubes which constitute part of the primary pressure boundary?
l
)
1 Answer to Interrocatory 10:
It was originally expected that the Model 51 steam i
generators installed at DCPP could remain in operation for the l
plant's 40-year ' design life.
However, the _ plant's design basis does not rely on the 40-year _ qualified life for the steam generators.
Provisions for steam generator removal and replacement were designed into the plant, and extensive t
maintenance and surveillance programs were established to monitor conditions, plug tubes if necessary and predict remaining tube life as appropriate.
See Answers to Interrogatories 11 and 12 below.
Interrocatory 11:
How has your maintenance program measured the environment of the tubes to see if they are within their quality environment?
j i
Answer to Interroaatory 11:
j During plant operation, chemistry conditions in the condensate, feedwater, steam, makeup water, and other process streams are managed in accordance with the chemistry guidelines published by the Electric Power Research Institutes (PWR Secondary Water Chemistry Guidelines - Revision 3, May 1993).
These guidelines, which were developed by a committee of industry experts (including utility specialists, nuclear !
1
steam system supplier vendor representatives, Institute of Nuclear Plant Operations representatives, consrltants, and EPRI staff),
are intended to reflect the industry state-of-the-art with respect to measures for reducing corrosion so as to enhance steam generator reliability.
l Each refueling outage, the condition of the steam generator tubes is measured via eddy current techniques in accordance with the requirements in DCPP's Technical Specification, the examination guidelines published by EPRI l
l (PWR steam generator Examination Guidelines: Revision 3), and the recommendation of the Westinghouse WEXTEX Owners Group.
These guidelines were specifically designed to avoid forced i
outages due to steam generator tube leakage.
l Interroaatorv.12:
What has been the experience with steam generator tube failures in terms of the mean time to degrade or fail?
Answer to Interrocatory 12:
By definition (Technical Specifications) a defective steam generator tube is a tube having an imperfection that is equal to or greater than 40% of the nominal tube wall thickness.
PG&E has used industry steam generator tube degradation data and statistical models to benchmark DCPP's current steam generator tube degradation performance and to predict DCPP's future steam generator tube plugging requirements for each steam generator tube degradation mechanism present or expected at DCPP.
For most damage,
4 mechanisms, once a defect has initiated, the mean time to maximum allowable deflect depth is less than 10 years.
However, few (if any), defects initiate immediately upon plant start-up.
We conclude, therefore, that it is possible to maintain DCPP's steam generators serviceable (by plugging and sleeving) for the duration of plant life is both.
Interroaatory 13:
As of this date, for each of the steam generators, what number of tubes out of the total have been plugged?
Give the answer in number and percent.
Answer to Interroaatory 13:
The data presented below reflects the total number of tubes plugged as of the end of each unit's fifth fuel cycle (i.e., 1R5/2R5):
S/G #
- of Defective S/G Tubes
% of Total S/G Tubes l
1-1 11 0.3%
1-2 20 0.6%
1-3 8
0.2%
1-4 4
0.1%
Unit 1 Total n
M 2-1 13 0.4%
2-2 33 1.0%
2-3 19 0.6%
l 2-4 11 0.3%
l Unit 2 Total 2_6 0.6%
6 Interroaatory 14:
How does the failure rate experienced to date on steam generator tubes compare to the estimated qualified life.
j i
.=. - _ -
Answer to Interroaatory 14:
Based on the results of the benchmarking study discussed in Answer to Interrogatory 12,
- above, DCPP Unit l's performance places it in the 20th percentile (i.e.,
80% of plants have higher steam generator tube degradation rates than those reported by DCPP Unit 1) while DCPP Unit 2's performance places it just above the 50th percentile. As such, if this level of performance continues, we would predict that fewer than 10% of the steam generator tubes in each Unit would experience the maximum allowable deflect depth before the end of plant life (i.e.,
through 2021, for Unit 1 and 2025, for Unit 2 - both based on license re-capture).
However, if steam generator tube degradation is higher than predicted, the steam
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generators could be replaced as has already been done on l
l-nuclear units at other utilities.
l Respectfully submitted, Joseph B. Knotts, Jr.
David A. Repka Kathryn M. Kalowsky WINSTON & STRAWN 1400 L Street, N.W.
Washington, DC 20005-3502 (202) 371-5726 M
Christoplfer JVWarner Richard F. Locke PACIFIC GAS AND ELECTRIC COMPANY 77 Beale StrAet San Francisco, CA 94106 Attorneys for Pacific Gas and Electric Company Dated in San Francisco, CA this 18th day of June, 1993 i
l
! l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
AFFIDAVIT I,
Richard B.
Clark, being duly sworn, hereby state as follows.
1.
I am employed by Pacific Gas and Electric Company as Director, Nuclear Engineering Services 2.
My business address and phone number are:
333 Market Street, Room A1414 San Francisco, CA 94105
]
(415) 973-1503 l
3.
I have provided the information which forms the basis for the answers to Interrogatories 10 through 14 included in the attached
" Pacific Gas and Electric Company's Response to Third Set of l
Supplemental Interrogatories and Requests for the Production of Documents (Aging) 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.
l Richard B.
Clark i
Sworn and subscribed to before me this I b day of June, 1993 k
%b nunnmnnimumanmusmannrannumnannuun g
OFFJCIAL SLAL Notarp Public
/
gyg AMY EMIKO DONG l
l 4it NOTARY PUBi!C.CAllFORNIA j
/
Cm & COUNTY OF SAN FRANCISCOI
/ ((ff}t}jp [k j hh My Commission Expires Dec. 23,1994 l
mmummunannumunmumanumanamiimi My commission expires:
w UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA i
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
I, WellM D. Fargo, being duly sworn, hereby state as follows.
1.
I am employed by Pacific Gas and Electric Company as Group Leader, Environmental Qualification.
2.
My business address and phone number are:
1 l
333 Market Street, Room A2043 San Francisco, CA 94105 (415) 973-9112 3.
I have provided the information which forms the basis for the answers to Interrogatories 1 through 9 included in the attached
" Pacific Gas and Electric Company's Response to Third Set of Supplemental Interrogatories and Requests for the Production of Documents (Aging) 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.
M Wells D. Fargo V Sworn and ubscribed to before me this /-
day of June, 1993 RnumimmmWimmmmuumuipmnmitunutmmuhmmut ml fgf3 h ryt h
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Ol'FICIAL SLAL 4
AMY EMIKO DONG Notarp Public
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
~
BEFORE TEE ATOMIC SAFETY AND LICENSING BOARD.
In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
I AFFIDAVIT I, Bryant W. Giffin, being duly sworn, hereby state as follows.
1 1.
I am employed by Pacific Gas and Electric Company as Manager, Maintenance Services.
2.
My business address and phone number are:
Diablo Canyon Power Plant 104/5/505 P. O. Box 56 Avila Beach, CA 93424 (805) 545-4168 3.
I have provided the information which forms the basis for the answers to Interrogatories 1 through 9 included in the attached
" Pacific Gas and Electric Company's Response to Third Set of Supplemental Interrogatories and Requests for the Production of i
Documents (Aging) 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.
M Bryan W. Giffin
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My c6:=ti'ssion expires:
100*3D6d 80073 HIS DHin 33X3 WOWd 40 21 CG. 81 Hnr
' (( U UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '93 WN 21 A9 :39 Docket Nos.-50-275 Oli;M,f'M//".
I'Hl In the Matter of:
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A
)
Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Power
)
Recapture)
I Plant, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE l
I hereby certify that copies of " PACIFIC GAS AND ELECTRIC COMPANY'S RESPONSE TO THIRD SET OF SUPPLEMENTAL INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS (AGING) FILED BY SAN.LUIS OBISPO MOTHERS i
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, J
this 18th day of June, 1993.
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.
U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission l
Attn:
Docketing and Service 1 White Flint North Section 11555 Rockville Pike (original + two copies)
Rockville, MD 20852 -,
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t Adjudicatory File Peter Arth, Jr.
Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G.
Fairchild i
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. 41n3 Pismo Beach, CA 93448 San Francisco, CA 02 Robert R. Wellington, Esq.
Joseph B.-Knotts, J.
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 Kinosian 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
- MHB Technical Associates 1723 Hamilton Ave., Suite K l
San Jose, CA 95125 l
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Christoph6r J./ Warner j
Counsel for Pacific Gas &
Electric Company 1
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