ML20056C189

Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence

ML20056C189
Person / Time
Site:	Diablo Canyon
Issue date:	03/10/1993
From:	Repka D PACIFIC GAS & ELECTRIC CO., WINSTON & STRAWN
To:	SAN LUIS OBISPO MOTHERS FOR PEACE
References
CON-#193-13739 OLA-2, NUDOCS 9303300223
Download: ML20056C189 (51)

Text

b PRATED CORRESPONDENCE March 10, 1993

'93 P'

17 P' '3';

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' In the Matter of:

)

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Docket Nos. 50-275-OLA_ g Pacific Gas and Electric Company

)

50-323-OLA

)

(Construction Period (Diablo Canyon Nuclear Power

)

Recovery)

Plant, Units 1 and 2)

)

)

PACIFIC GAS & ELECTRIC COMPANY'S RESPONSE TO FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE (RE:

CONTENTION V)

Pacific Gas & Electric Company ("PG&E") herein responds in part to "Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories and Requests for Production of Documents to Pacific Gas & Electric Company," dated February 16, 1993 ("MFP's First Set").

This response includes answers and objections in accordance with 10 C.F.R.

S S 2.740b(b) and 2.741(d), and addresses in full the portions of MFP's First Set that relate to Contention V (Thermo-Lag).I' Facsimile copies of the affidavits required by 10 C.F.R. 5 2.740b(b) for the answers to the discovery requests are l'

This response is being timely filed in accordance with the schedule for discovery responses adopted by the Atomic Safety and Licensing Board in this proceeding.

See Memorandum and Order (Discovery and Hearing Schedules), February 9,

1993, at 4, T 2.

In

fact, in an effort to accommodate the intervenor by providing information in advance of a requested site visit (tentatively the week of March 15, 1993), these responses are being filed in advance of the due date of March 19, 1993, 9303300223 930310 90g PDR ADOCK 05000275 Q

PDR

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s included in this response; due to logistical difficulties, originals will follow within the next several days.

Copies of l

those documents identified in Attachment 1 related to Contention V i

are being provided to the Mothers for Peace herewith.

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GENERAL OBJECTION (Contention V:

Thermo-Laa) l As in its previous discovery request in this proceeding,l' the Intervenor San Luis Obispo Mothers for Peace ("MFP") fundamentally j

misperceive the scope of Contention V as admitted by the Atomic j

Safety and Licensing Board (" Licensing Board") in this proceeding.

The admitted contention, specifically narrowed and clarified by the i

Licensing

Board, concerns only the effectiveness of PG&E's implementation of interim compensatory measuras to address potentially degraded Thermo-Lag fire barriers.

The admitted contention does not permit inquiry into the generic issues of a) the ultimate resolution of the Thermo-Lag issue or b) the adequacy of fire protection provided by NRC-approved interim compensatory measures.

See Prehearina Conference Order (Ruling Upon Intervention Petition and Authorizing Hearing),

LBP-93-1, January 21, 1993, at 38, n.41 ("Prehearing Conference Order");

Memorandum and Order (Discovery and Hearing Schedules), February 9, 2/

"Intervenor San Luis Obispo Mothers for Peace Request to Pacific Gas and Electric Company for Entry Upon the Diablo Canyon Nuclear Power Plant, Units 1 and 2, Pursuant to 10 CFR dated February 1, 1993

("MFP Discovery

2. 741 (a) (2)

Request");

see also " Pacific Gas and Electric Company's Preliminary Response to Discovery Request Filed Pursuant to i

10 CFR 2.741(a) (2 ) and Motion for Protective Order," dated February 12, 1993.

("PG&E Preliminary Response").

2. _ _

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r 1993, at 2

(" Discovery and Scheduling Order").

Moreover, the j

t breadth of. the admitted contention was limited by MFP's own proffered basis for proposed contention V.

In. support of the assertion of deficiencies in implementation of Thermo-Lag compensatory measures at the Diablo Canyon Nuclear Power Plant, Units 1 and 2 ("the Diablo Canyon plant"), the basis statement addressed only a few specific matters such as missed fire watches j

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and the defeat of certain fire barriers.I' Other aspects of the f

basis and contention, addressing generic matters, were rejected by i

the Licensing Board.

Accordingly, discovery related to Contention V as admitted is i

L appropriate only to the extent it could lead to relevant l

i information regarding the effectiveness of PG&E's implementation of

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l Thermo-Lag compensatory measures.

Instead, MFP's First Set, as detailed more specifically below, seeks discovery on Contention V

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r in excess of the admitted contention in this proceeding.

For example, MFP seeks detailed physical and functional information.

concerning the Thorno-Lag installations; a matter germane only to j

the generic long-term issue. MFP also seeks information related to j

the effectiveness of fire watches as a generic matter, as opposed i

II See " San Luis Obispo Mothers for Peace Supplement to Petition 3

to Intervene," October 26, 1992, at 2 8-31.

Specifically, the basis asserted for the challenge to PG&E's implementation of interim compensatory measures consisted of isolated incidents of open fire doors, three missed fire watches, and one l

inoperable sprinkler system.

There was no correlation shown between any of these incidents and actual Thermo-Lag.

compensatory measures at Diablo Canyon.

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"s to information related to the effectiveness of PG&E's 6

implementation of fire watches.i' This includes information for 1

comparing effectiveness of fire watches relative to operable fire I

barriers.

MFP also seeks information related to equipment l

l protected by Thermo-Lag, a matter with no bearing on the issue of I

whether fire watches have been missed or other compensatory-i measures are being inadequately implemented at the Diablo Canyon i

plant.

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While PG&E desires to be cooperative on discovery in this prrceeding, it cannot do so if MFP refuses to recognize the legitimate scope of the admitted issues.

PG&E is simply not i

required to respond to open-ended, resource-intensive fishing I

exercises related to generic Thermo-Lag issues which are being i

separately and responsibly addressed by the nuclear industry and i

the Commission.

f i

F The interim compensatory measures implemented _by PG&E are not l

a basis for litigation in this proceeding. They are generally authorized by the Diablo Canyon operating licenses and have been approved by the Commission, in the specific context of the Thermo-Lag issue, as adequate throughout the industry.

See, e.o.,

Memorandum, S.J.

Chilk to J.M.

Taylor, "COMSECY-92-026 - Staff's Planned Actions to Address Issues Related to Thermo-Lag 330-1 Fire Barrier Material," dated September 21, 1992; see also Texas Utilities Electric Co.

(Comanche Peak Steam Electric Station, Units 1 and 2), et al.,

DD-93-03, _ NRC _, slip op. at 15-22 (February 1, 1993)

(rejecting a 10 C.F.R. 5 2.206 petition which requested, among other things, immediate plant shutdowns due to degraded Thermo-Lag barriers).

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ANSWERS TO INTERROGATORIES i

Interroaatory 1:

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1 Please identify each and every area (such as, for i

example, pump rooms, enclosures, pipe chases, cable i

chases, etc.) at the Diablo Canyon Nuclear Power Plant for which there are fire barriers containing or comprised of Thermo-Lag (if this listing of areas consists of f

Table 1 of PG&E's response to Supplement 1 to NRC i

Bulletin 92-1, it will be a sufficient response for PG&E to so note, and additionally to affirm that Thermo-Lag is not used in any other fire barriers at the Diablo Canyon l

Nuclear Power Plant and to provide the information l

requested below).

t I

Answer to Interrocatory 1.

The requested list is set forth in Table 1 of PG&E's response i

to Supplement 1 to NRC Bulletin 92-1.

PG&E affirns that Thermo-Lag

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is not used for any other Appendix R safe shutdown fire barriers at

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the Diablo Canyon plant.

Interrocatory 1(al:

A diagram showing the location and elevation l

of the area with respect to the remainder of j

the plant and which identifies the equipment

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and components (by train) which are located in each such area, i

f Answer to Interroaatory 1(a):

i General arrangement drawings of the location and elevation of fire areas in which Thermo-Lag is located are being provided in the Answer to Thermo-Lag Document Request 19, below.

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l PG&E objects to this interrogatory to the extent it seeks j

l information other than the location of the areas identified in l

response to Interrogatory 1.

Through this interrogatory, MFP seeks l

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information outside the scope of Contention V, as admitted by the Licensing Board in this proceeding.

An identification of equipment and components located in each fire area is also irrelevant to the issues in this proceeding.

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i Such information could be germane only to issues addressed to

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general fire protection adequacy or to the long-term Thermo-Lag j

i resolution.

See Discovery and Scheduling Order, at 2

("the l

1 adequacy of the Applicant's adherence to interim measures [is) all l

that [is) in issue").

i Interrocatory 1(b):

l An identification of each and every interim j

1 fire-protection measure upon which PG&E relics i

to provide compensatory actions to account for the presence of Thermo-Lag fire barriers, and the location of the fire protection measure l

with respect to the Thermo-Lag barriers and j

1 the equipment for which the barriers were i

intended to provide protection (provide j

diagrams if possible) (to the extent that this i

information is covered in PG&E's response to.

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Supplement 1 to NRC Bulletin 92-01, it will be sufficient-to make reference thereto);

j further, if one of the compensatory measures is a continuous or hourly fire watch, please indicate where in the area the fire watch personnel are stationed and what areas within l

the fire watch area are inspected and on what frequency.

Answer to Interrocatory 1(b):

To the extent this interrogatory seeks an identification of interim compensatory measures for each Thermo-Lag fire area, see PG&E's response to Supplement 1 to NRC Bulletin 92-1 (DCL-92-208,

)

i September 28, 1992).

All cited fire areas are inspected by roving fire watches on an hourly basis.

r PG&E objects to this interrogatory to the. extent that it requests the identification of equipment protected by Thermo-Lag f

fire barriers for the same reason as stated in response 'to i

Interrogatory 1(a) above.

The identification of.such equipment is

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not germane to the implementation of NRC-approved interim compensatory measures at the Diablo Canyon plant.

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Interroaatory 1(c):

j An identification of approximately how i

frequently hourly fire watches inspect each area and an identification of approximately how much time is spent on each inspection l

(note that it could be cresumed that the inspection frequency is " hourly" or at least once per 60 minutes, but it is possible that PG&E conservatively inspects the affected areas more frequently than this, or it is possible that under PG&E practices and procedures there is some leeway allowed such that the inspections could be done on, for example, and hourly +/- 15 minutes basis, thus there is a need for a response to this question even though the answer may appear to be superficially obvious).

Answer to Interrogatory 1(c):

i once per hour.

Each fire watch round requires approximately 45-60 minutes to complete.

Interroaatory ifd):

An estimate of the length of time. required from the time a fire is detected until the fact of the fire and its location can be reported by hourly fire watch personnel to the fire brigade. 2 I

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Answer to Interrocatory 1(d):

PG&E objects to this interrogatory. The information requested t

is pertinent only to assessing the adequacy of NRC-approved interim compensatory measures at the Diablo Canyon plant.

That issue is i

not included within the scope of Contention V.

Contention V addresses only PG&E's implementation of the approved compensatory measures.

Interroaatory 1(e):

An estimate of the length of time required I

from the time the fire brigade receives notice of the fact and location of a fire until the fire brigade can report to the fire location l

and begin to fight the fire.

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Answer to Interrocatory 1(e):

i PG&E objects to this interrogatory for the same reasons as stated above for Interrogatory 1(d).

The interrogatory seeks information pertinent.only to the adequacy of NRC-approved interim compensatory measures at the Diablo Canyon plant.

Interroaatory 1(f):

1 The distance from the fire location to the nearest fire hose station and/or portable fire extinguisher.

Answer to Interrogatory 1(f):

PG&E objects to this interrogatory for the same reasons as i

stated for Interrogatories 1(d) and 1(e) above. This interrogatory seeks information pertinent only to the adequacy of NRC-approved interim compensatory measures at the Diablo Canyon plant.

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i Interrocatory 2:

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Please describe the schedule for performing the hourly l

fire watches for each area for which Thermo-Lag is i

provided as a fire barrier.

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Answer to Interroaatory 2:

Each fire area is required to be inspected once per hour. The roving firewatch starts his or her hourly round at the " top" of i

each hour.

Each area is inspected in the same sequence along a designated route at about the same time each hour.

Along the i

route, key stations are passed and the fire watch logs each of

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these computerized watch stations using a "bar code" vand.

The i

watch remains in each area long enough to perform a reasonable assessment of the area prior to proceeding along the route to_the i

next area.

Interroaatory 3:

Please identify the maximum time period'that can elapse between " hourly" fire watches.

4 Answer to Interrocatory 3:

See Answer to Interrogatory 2 above.

Interroaatory 4:

3 Please describe the responsibilities of personnel assigned to fire watch duty.

In your description, please explain whether the fire watch personnel have any other duties and, if so, describe those duties in detail and j

provide an estimate of what percentage of their time is spent on fire watch and other duties.

Answer to Interrocatory 4:

The responsibilities of fire watch personnel are described in Nuclear Plant Administrative Procedure (NPAP)

A-13,

" PLANT i !

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ORGANIZATION FOR FIRE LOSS PREVENTION."

A copy of this procedure l

l is being provided.

Fire watch personnel have no other duties while l

performing fire watch duties.

1 Interroaatory 5:

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Please provide copies of the procedures which PG&E utilizes to inspect for the control of ignition sources and combustible materials at Diablo Canyon.

If the current procedures are different from those in effect l

before PG&E became aware of the Thermo-Lag issue, please l

provide copies of both the former and current procedures.

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Answer to Interroaatorv 5:

j Procedures for controlling combustibles and ignition sources f

are described in NPAP C-13, " FIRE LOSS PREVENTION," a copy of which t

is being provided.

These procedures have not been changed in l

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response to NRC Bulletin 92-1.

Interrocatorv 6:

Please compare the effectiveness of the fire detection l

capability which existed at Diablo Canyon prior to the j

declaration that Thermo-Lag fire barriers were inoperable with the fire detection capability that currently exists l

at Diablo Canyon.

Please limit your response to those j

plant areas affected by Therno-Lag-related fire barrier j

inadequacies.

I Answer to Interroaatorv 6:

PG&E objects to this interrogatory. The information MFP seeks (i.e.,

"the effectiveness of the fire detection capability which existed at Diablo Canyon prior to the declaration that Thermo-Lag fire barriers were inoperable") is not relevant to, nor could it I

lead to information relevant to, the implementation of Thermo-Lag compensatory measures at the Diablo Canyon plant.

Neither the comparative context in which MFP has couched this interrogatory nor j

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-i its limitation to " areas affected by Thermo-Lag-related fire barrier inadequacies" make the interrogatory relevant to Contention i

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as admitted by the Licensing Board.

Rather, the request for a f

l comparison quite clearly shows that MFP seeks information pertinent

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only to the adequacy of the interim compensatory measures -- an..

i issue not admitted in contention V.

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Interroaatorv 7:

i Please compare the effectiveness of the fire suppression capability which existed at Diablo Canyon prior to the declaration that Thermo-Lag fire barriers were inoperable l

l with the fire suppression capability that currently l

exists at Diablo Canyon.

Please limit your response to those plant areas affected by Thermo-Lag related fire barrier inadequacies.

I Answer to Interrocatorv 7:

PG&E objects to this interrogatory. The requested information

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(i.e.,

related to "the effectiveness of the fire suppression f

capability which existed at Diablo Canyon prior to the declaration I

that Thermo-Lag fire barriers were inoperable") is not relevant to, nor could it lead to information relevant to, the implementation of 7

i interim compensatory measures at the Diablo Canyon plant.

The i

request for a comparison in the interrogatory demonstrates that MFP t

seeks to address the adequacy of fire protection rather than PG&E's

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implementation of compensatory measures.

Moreover, fire

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suppression capability -- either before or after the advent of the i

compensatory measures -- is not an issue in this proceeding.

The l

limitation to "those plant areas affected by Thermo-Lag-related.

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fire barrier inadequacies" does not make this interrogatory relevant to Contention 7.

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Interroaatorv 8:

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For each of the Thermo-Lag-affected fire areas identified l

in PG&E's September 29, 1992, response to NRC Bulletin 92-01, Supplement 1, please indicate the distance (in i

feet or meters) from the fire area to the nearest plant communication system device (radio, paging system, etc. ).

i Answer to Interroaatorv 8:

PG&E objects to this interrogatory. The requested information

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pertains only to the adequacy, as opposed to the implementation, of l

NRC-approved interim compensatory measures at the Diablo Canyon i

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l plant.

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Interrocatorv 9:

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Please describe in detail the training which PG&E has l

provided to fire watch personnel (for both continuous and j

hourly fire watch personnel, responding separately if there is any difference) to inspect for control of i

I ignition sources and combustible materials.

Answer to Interroaatorv 9:

i All personnel assigned to perform fire watch duties are I

required to attend fire watch training classes.

They attend l

General Employee Training on fire protection, and also specific

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I Fire Watch Training.

The skills and knowledge required by fire 2

I watches and fire watch foremen are specified in NPAP B-13, d

" QUALIFICATION AND TRAINING REQUIREMENTS OF PIANT PERSONNEL I

l SPECIFICALLY CONCERNED WITH FIRE LOSS PREVENTION," a copy of which

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is being provided.

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Interroaatory 10:

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l Please describe in detail the training which PG&E has l

provided to fire watch personnel (for both continuous and hourly fire watch personnel, responding separately if j

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r there is any difference) to look for signs of incipient fires.

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i Answer to Interrocatory 10:

See Answer to Interrogatory 9.

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Interroaatory 11:

Please describe in detail the training which PG&E has provided to fire watch personnel (for both continuous and

'i hourly fire watch personnel, responding separately if there is any difference) to provide prompt notifications of fire hazards and fires.

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t Answer to Interroaatory 11:

i See Answer to Interrogatory 9.

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Interroaatory 12:

Please describe in detail the training which PG&E has provided to fire watch personnel (for both continuous and 4

hourly fire watch personnel, responding separately if there is any difference) to conduct fire suppression activities.

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Answer to Interrocatory 12:

i See Answer to Interrogatory 9.

Interroaatory 13:

Please describe in detail the training which PG&E has provided to fire watch personnel (for both continuous and j

hourly fire watch personnel, responding separately if j

there is any difference) to assure that they are capable of determining the size, actual location, source, and l

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type of fires which they observe.

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Answer to Interroaatory 13:

See Answer to Interrogatory 9.

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Interrocatory 14:

Consistent with PG&E's response to Supplement 1 of IGC j

Bulletin 92-01 (enclosure to PG&E Letter Nos. DCL-92-208 l

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and HBL-92-060, letter dated September 28, 1992), please state whether it its PG&E's position that fire barriers, consisting of either 1-hour or 3-hour pre-formed Thern-Lag 330 panels and conduit shapes are "non-functional" within the meaning of the Diablo Canyon plant Technical Specification 3.7.10, and, if not, please fully describe PG&E's position regarding the functionality and/or operability of these barriers and identify fully each and every basis upon which PG&E relies in reaching this position.

Answer to Interroaatory 14:

PG&E objects to this interrogatory.

MFP here seeks detailed information concerning Thermo-Lag installations.

However, the issues of the functionality and/or operability of the Thermo-Lag barriers that are the subject of the interrogatory have nothing to do with the implementation of interim compensatory measures at the Diablo Canyon plant.

Therefore, this interrogatory seeks information outside the scope of Contention V, as admitted by the Licensing Board in this proceeding.

Interroaatorv 15:

Consistent with PG&E's response to Supplement 1 of NRC Bulletin 92-01 (enclosure to PG&E Letter Nos. DCL-92-208 and HBL-92-060, letter dated September 28, 1992), please state whether it its PG&E's position that fire barriers, consisting of Thermo-Lag fire barriers used in raceways, walls, ceilings, equipment enclosures, or other areas. to protect cable trays, conduits or separate redundant safe shutdown functions, are "non-functional" within the meaning of the Diablo Canyon plant Technical Specification 3.7.10 and, if not, please fully describe PG&E's position regarding the functionality and/or operability of these barriers and each and every basis upon which PG&E relies in reaching this position.

Answer to Interrocatory 15:

Consistent with the response to Interrogatory 14, PG&E objects to this interrogatory.

MFP's request is improperly focused on the functionality and operability of Thermo-Lag barriers.

The l

information sought through this interrogatory is not relevant to, nor could it lead to the discovery of information relevant to, the effectiveness of PG&E's implementation of interim compensatory

measures, j

Interroaatory 16:

Please identify each and every instance in which i

redundant safety-related

power, control, or i

instrumentation cabling is separated oy less than twenty l

feet and for which fire protection is provided by fire barriers containing Thermo-Lag.

For each such instance identified, please indicate whether that location is provided with fixed automatic fire detection and/or suppression systems (and, if so, the nature of such detection and/or suppression systems; e.a.,

protection provided by smoke detectors and a wet-pipe suppression system).

If the requested information has not been previously identified by PG&E, please make available j

documentation sufficient to enable the identification of each such instance to be made independently of PG&E.

Answer to Interroaatory 16:

PG&E objects to this interrogatory.

Information regarding the separation of cabling for which fire-protection is provided by i

Thermo-Lag fire barriers is not relevant to, nor could it lead to the discovery of information relevant to, the implementation of interim compensatory measures at the Diablo Canyon plant.

The identification of such areas and discovery of information regarding the nature of fire detection and/or suppression systems applicable to such areas would go beyond the scope of the contention admitted in this proceeding.

Contention V does not provide an opportunity l

to reevaluate fire protection generally at the Diablo Canyon plant.

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Interroaatory 17:

t Please identify all Licensee Event Reports (LERs) issued by PG&E for Diablo Canyon Units 1 and/or 2 which l

addresses deficiencies in fire barriers.

Answer to Interrocatory 17:

PG&E objects to this interrogatory.

MFP seeks to discover information concerning all fire barriers, even those without Thermo-Lag, at the Diablo Canyon plant.

Even if the scope of the request is interpreted narrowly, however, to encompass only those LERs addressing deficiencies in Thermo-Lag fire barriers, it still i

seeks information outside the scope of Contention V; i.e.,

the i

adequacy of the barriers themselves, not the implementation of l

interim compensatory measures at the Diablo Canyon plant.

f i

Therefore, whether it is interpreted broadly or narrowly, PG&E objects to this interrogatory.

Interrocatory 18:

Please identify all Licensee Event Reports-(LERs) issued by PG&E for Diablo Canyon Units i

and/or 2 which addresses problems with hourly and/or continuous fire watches (e.a., missed fire watches or failure to set up a fire watch in a timely manner given-a known degraded fire barrier).

Answer to Interrocatory 18:

Since IEC Bulletin 92-01 was issued, PG&E has issued no Licensee Event Reports relating to missed or inadequate fire i

watches where the fire watches were implemented as an interim compensatory measure in Thermo-Lag affected areas.

PG&E objects to this interrogatory to the extent it seeks information unrelated to the implementation of hourly fire watches as an interim t

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compensatory measure in response the NRC Bulletin 92-1.

For example, failure to set up a fire watch in a timely manner given a l

t known degraded fire barrier is not germane to the issue of whether such fire watches are being implemented once the degraded fire barrier is known to exist.

Similarly, performance of fire watches in previous years is not germane to PG&E's current (i.e.,

post-Bulletin 92-1) performance of hourly fire watches in Thermo-Lag i

fire areas.

Interrocatory 19:

Please identify all Licensee Event Reports (LERs) issued by PG&E for Diablo Canyon Units 1 and/or 2 which note the occurrence of a fire within the protected area at the l

plant.

Answer to Interrogatory 19:

i Since the issuance of Bulletin 92-1, no LERs have been issued by PG&E which note the occurrence of a fire within fire areas in-which Thermo-lag is located.

PG&E objects to this interrogatory to l

the extent it might request information related to other fires at i

the Diablo Canyon

plant, which would be unrelated to the f

implementation of hourly fire watches as an interim compensatory f

measure in response to NRC Bulletin 92-1.

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Interroaatory 20:

'i Please identify all NRC meeting

minutes, meeting i

transcripts, meeting summaries, and other documents (including, without limitation, viewgraphs,

slides, i

handouts, etc.) which record or otherwise document the i

proceedings of NRC meetings attended by PG&E concerning

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Thermo-Lag fire barrier material and/or compensatory l

actions which can or should be taken as a result of any 7

deficiencies in such fire barrier material.

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Answer to Interrocatory 20:

i PG&E objects to this interrogatory for several reasons.

The i

interrogatory is generic in nature in that it seeks information I

that is not necessarily specific to the implementation of interim compensatory measures at the Diablo Canyon plant.

The requested information "concerning Thermo-Lag fire barrier material" is not relevant to Contention V,

as admitted by the Licensing Board, because it is not relevant to, nor could it lead to the discovery f

of information relevant to, the implementation of interim I

compensatory measures.

Rather, it is pertinent only to the j

adequacy of Thermo-Lag as a generic issue.

Furthermore, the

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i requested information concerning " compensatory actions which can or should be taken as a result of any deficiencies in such [Thermo-Lag) fire barrier material" is germane to the adequacy, rather than a

the implementation, of NRC-approved interim compensatory fire-f l

i protection measures as a generic matter.

This is not an issue in i

this proceeding.

See Discovery and Scheduling Order, at 2 - ("the i

adequacy of the Applicant's adherence to interim measures [is] all l

1 that [is) in issue").

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Interrocatory 21:

As part of its September 28,

1992, response to NRC

...in j

Bulletin 92-01, Supplement 1, PG&E stated that general, the combustible loadings for the Diablo Canyon j

plant fire areas with Thermo-Lag are relatively low" (see page 1 of the Enclosure to PG&E's response letter).

j Regarding this statement, please:

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Interroaatory 21(a):

Describe-in quantitative terms what PG&E means by "relatively low" in terms of combustible loadings.

Answer to Interroaatory 21(a):.

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.PG&E objects to this interrogatory.

"[T]he combustible loadings for the Diablo Canyon plant fire areas with Thermo-Lag" i

discussed as part of PG&E's response to NRC Bulletin 92-01,-

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Supplement 1,

is not relevant to Contention V.

The t

i characterization of those loadings by PG&E is not relevant to, nor i

i could it lead to the discovery of information relevant to, the implementation of interim compensatory measures at the Diablo l

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Canyon plant.

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Interrocatory 21(b):

l Identify those DCPP fire areas with Thermo-Lag

-l where the combustible loadings are other than "relatively I w" and provide PG&E's

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quantitative characterization

-of the combustible loading in such areas, comparing them in each case with the combustible loading l

which PG&E characterizes as "relatively low".

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Answer to Interroaatory 21(b):

Tor the same reason stated in response to Interrogatory 21(a),

I PG&E objects to this interrogatory.

Interrocatory 21(c):

1 Identify the fixed and transient combustible l

loadings present in each of the DCPP fire areas with Thermo-Lag barriers (please specify i

l the combustible materials present and their l

l quantities in the case of fixed materials, and specify the types and maximum quantities of transient combustibles permitted in each such area, accounting for all activities required j

i r l

and permitted under PG&E maintenance and surveillance procedures and for all modes of operation from refueling to full power operation).

Answer to Interrocatory 21(c):

PG&E objects to this interrogatory.

The requested identification of " fixed and transient combustible loadings present in each of the Diablo Canyon plant fire areas with Thermo-Lag barriers" would not, nor could it, lead to information relevant to Contention V,

as admitted by the Licensing Board in this proceeding.

Such information has nothing to do with the implementation of interim compensatory measures at the Diablo Canyon plant.

Such information could be pertinent only to fire protection generally, to the long-term resolution of generic issues concerning the adequacy of the Thermo-Lag installations, or to the generic adequacy of interin measures.

None of these issues are admitted in this proceeding.

Interroaatory 22:

For each fire area listed in Table 1 of PG&E's response to NRC Bulletin 92-01 (PG&E Letter Nos. DCL-92-173 and HBL-92-048, letter dated July 29, 1992), please identify (by component, system, and train) the safety-related and important-to-safety equipment located in each fire area.

Please also identify (by component, system, and train) the power, control, and/or instrumentation cables which terminate in or which pass through each fire area.

Answer to Interroaatory 22:

PG&E objects to this interrogatory.

An identification of the equipment of the type specified in the request would be irrelevant to the implementation of interin compensatory fire-protection measures at the Diablo Canyon plant.

In seeking information

^

i related to equipment protected by Thermo-Lag, MFP is inquiring into i

generic matters related to the present adequacy of Thermo-Lag, the i

long-term adequacy of Thermo-Lag, and/or the adequacy of the NRC-approved interim compensatory measures.

None of these matters is

-j

.s.

at issue in this proceeding.

j t

Interrocatory 23:

In PG&E's response to NRC Bulletin 92-01 (PG&E Letter Nos. DCL-92-173 and HBL-92-048, letter dated July 29, i

1992),

PG&E states in part, "As a.

result of the l

i uncertainties associated with qualification of Thermo-Lag fire barrier systems for small conduits between 1-inch and 4-inches o diameter, PG&E has verified that existing l

1 i

measures are sufficient to ensure that plant safety is not compromised."

Regarding this statement, please define what PG&E means by

" plant safety" and

" compromised" in this context, and describe each and every basis for PG&E's statement that " plant safety.is l'

not compromised."

Also, please indicate the meaning of the symbol "o" in PG&E's response to NRC Bulletin 92-01, as cited above.

j i

.i Answer to Interrocatory 23:

PG&E objects to this interrogatory. The information requested I

solely relates to the adequacy, as opposed to the implementation, i

i of interim compensatory measures at the Diablo Canyon plant.

Interrocatory 24:

PG&E's response to Supplement 1 to NRC Bulletin 92-01 l

(Table 1 in the enclosure to PG&E Letter Nos. DCL-92-208 and HBL-92-060, letter dated September 28, 1992) identifies as one column the heading " Fire Duration (minutes)".

Please fully explain the meaning and deriv 3 tion of " Fire Duration (minutes)" in each case in which an.

dry is made in that column.

Answer to Interroaatory 24:

PG&E objects to this interrogatory.

The information provided by PG&E in its response to Supplement 1 to NRC Bulletin 92-01 is >

1 y

w v

m.

not relevant to, nor could it lead to the identification of infornation relevant to, the implementation of interim compensatory measures at the Diablo Canyon plant.

Instead, the requested information regarding fire duration in Thermo-Lag fire areas could pertain only to the adequacy of Thermo-Lag, the adequacy of the NRC-approved interim compensatory measures, and/or the adequacy of the fire protection program generally.

These matters are not subject to litigation in this proceeding.

Interrocatory 25:

Please indicate whether PG&E has issued any contract (s)

(or any other document or documents which authorizes a vendor to perform work) to augment, modify, or replace the Thermo-Lag fire barriers in any or all of the arcas identified in PG&E's response tc-Supplement 1 to NRC Bulletin 92-01 as containing such fire barriers.

In addition, please identify the areas and specific barriers which are affected by these contract (s) or other authorizing documents.

Answer to Interrocatory 25:

PG&E objects to this interrogatory.

The existence of contracts or other authori::ing documents "tc augment, modify, or replace the Thermo-Lag barriers" is, quite clurly, unrelated to the implementation of interim compensatory measures.

Such information could pertain directly only to the adequacy of the Thermo-Lag material itself and the long-term resolution of the generic Thermo-Lag issue. MFP has again requested information that is clearly outside the scope of Contention V, as admitted by the Licensing Board in this proceeding. l

t Interrocatory 26:

For each fire area listed in Table 1 of PG&E's response j

to NRC Bulletin 92-01 (PG&E Letter Nos. DCL-92-173 and HBL-92-048, letter dated July 29, 1992), please identify whether a

fire in that area could disable the communications systems upon which PG&E relies to enable the fire watch personnel assigned to that fire area to communicate the occurrence of a fire to the fire brigade and other plant personnel (e.c., control room operators).

If a fire could disable the communications systems, please identify any alternate communications system upon which PG&E relies to provide the required notifications and if no such alternate system exists, please identify the travel time from the fire area to the nearest location at which the fire brigade could be notified in person of the existence of the fire.

Answer to Interrocatory 26:

A postulated fire in the fire areas noted in the referenced Table 1 could not disable the communications system upon which PG&E relies to enable fire watch personnel to communicate to the fire brigade and other plant personnel.

Interroaatory 27:

Please indicate whether PG&E considers its NRC-approved fire protection plan to be legally binding and, if so, by what mechanism is the plan made legally binding (e.c., by specific NEC regulation, by reference in the Updated FSAR, by license condition, etc.)

Answer to Interrocatory 27:

PG&E objects to this interrogatory. The requested information is not relevant to, nor could it lead to the identification of information relevant to, the implementation of NRC-approved interin.

compensatory measures at the Diablo Canyon plant.

Neither the j

legal stature nor the mechanisms by which the fire protection plan are made legally binding are encompassec by the scope of Contention l

V, as admitted by the Licensing Board in this proceeding. !

I

3

)

Interroaatory 28:

Please indicate whether PG&E considers itself legally

\\

required to comply with Appendix R to 10 CFR Part 50, for Diablo Canyon Units 1 and 2, and, if not, please explain in detail each and every basis for your conclusion.

l Answer to Interroaatory 28:

PG&E objects to this interrogatory.

The requested opinion is

[

i unrelated to the narrow issue posed by Contention V; i.e.,

the f

f implementation of NRC-approved interim compensatory measures. This l

interrogatory once again seeks information, or in this case an opinion, well beyond the scope of the contention admitted by the Licensing Board.

i Interrocatory 29:

Please identify, by manuf acturer, cable size, cable type, and insulation material, the cables terminating in or f

passing through all areas of the Diablo Canyon plant where Thermo-Lag is used.

Answer to Interrocatory 29.

PG&E objects to this interrogatory. The requested information

[

t cencerns cables protected by Thermo-Lag. However, this information has nothing to do with the implementation of-interim compensatory j

i measures at the Diablo Canyon plant.

As such, this interrogatory i

i inquires into generic issues pertinent to the adequacy of Thermo-j i

Lag and/or adequacy of the NRC-approved interim compensatory

}

l measures -- both of which are outside the scope of Contention V.

I Other cable issues, such as the ampacity derating issues related to j

4 Therno-Lag, are also outside the scope of this proceeding.

j i

i i

t i i 4

i s

l

?

Interroaatorv 30:

In environmentally qualifying each cable identified in response to the previous interrogatory, please identify the assumptions (in quantitative and qualitative terms) that were made regarding temperature, as required ' by 10 CFR 50.49(e).

l Answer to Interroaatorv 30:

I PG&E objects to.his interrogatory.

Infornation concerning l

l i

the environmental qualification of cables protected by Thermo-Lag is in no way related to the implementation of NRC-approved interim i

compensatory measures at the Diablo Canyon plant.

I l

Interroaatory 31:

Please describe your procedure, if any, for assuring that i

the ambient conditions of temperature to which the cables

~

identified in response to the two previous interrogatories are subjected remain within the temperature assumed for purposes of qualification testing.

l i

Answer to Interroaatory 31:

For the same reason stated in response to Interrogatory 30, PG&E objects to this interrogatory.

Information concerning the environmental qualification of equipment is totally unrelated to i

the implementation of NRC-approved interin compensatory measures at the Diablo Canyon plant.

Likewise, ambient conditions around i

installed cabla, cable ampacity considerations, and any other issues as might be revealed by the requested information, are all J

outside the scope of the present proceeding.

Interroaatory 32:

Please identify the fire protection standards that are applicable to the Diablo Canyon plant under IEC regulations (including regulations, regulatory guides, 1

i i

i i

l generic letters, bulletins, license conditions, FSAR commitments, and any other form of NRC-enforceable j

standards).

Answer to Interroaatory 32:

PG&E objects to this interrogatory. The identification of all fire protection standards applicable to the Diablo Canyon plant is l

overly broad and irrelevant to the implementation of NRC-approved j

f interim compensatory measures at the Diablo Canyon plant.

PG&E again reiterates the narrow scope of Contention V, as admitted by l

s the Licensing Board.

See Discovery and Scheduling Order, at 3.

l i

PG&E objects to interrogatories proffered by MFP, including Interrogatory 32, which are the product of a

fundamental misconception of that scope.

I 3

III.

REOUESTS FOR PRODUCTION OF DOCUMENTS l

l e

a Document Recuest 1:

Please provide a copy of the current, interfiled, controlled j

(i.e., a copy of which contains the most recent issued version of each page of the document) portions of the Diablo Canyon Nuclear Power Station, Units 1 and 2, Updated Safety Analysis l

Report which address fire protection issues.

{

v Answer to Document Reauest 1:

i i

This information is available to MFP in the Public Document i

S_ee 10 C.F.R. 5 2.740(b) (1) ("Where any book, document or

~

Room.

e other tangible thing sought is reasonably available from another i

source, such as from the Commission's Public Document Room, or local Public Document

Room, a

sufficient response to an interrogatory involving such materials would be the location, the I

title and a page reference to the relevant book, document, or 1

? !

l e

tangible thing.")

PG&E refers MFP to Chapter 9 of the Updated FSAR.

l Docurrent Recuest 2:

Please provide a copy of the current, interfiled, controlled copy of the Diablo Canyon Nuclear Power Station, Units 1 and 2,

" fire hazards analysis report" (i.e.,

the report which-documents the compliance of the plant to the U.S.

Nuclear Regulatory Commission's fire protection regulations).

Answer to Document Reauest 2:

PG&E objects to this request. There is no correlation between i

the fire hazards analysis and implementation of interim 1

compensatory actions to address Thermo-Lag at the Diablo Canyon plant.

The fire hazards analysis would be germane only to generic l

issues concerning adequacy of fire protection. Such issues are not admitted in this proceeding.

Document Recuest 3:

Please provide copies of all " Justification for Continued Operation" ("JCOs") which have been issued for Diablo Canyon Nuclear Power Plant, Units 1 and 2,

which concern fire barriers containing Thermo-Lag.

Answer to Document Reauest 3:

L PG&E objects to this request.

JCos and/or operability i

determinations concerning fire barriers with Thermo-Lag have no

.i bearing on this proceeding.

The NRC has generically required all l

licensees to treat Thermo-Lag barriers as if they were inoperable f

and to implement compensatory measures such as those set forth in the plant's technical specifications.

Only PG&E's implementation i

of compensatory measures -- not the operability of the barriers or 4 i

. ~..

b the adequacy of the approved compensatory measures -- is here at issue.

Document Recuest 4:

Please provide a copy of the current controlled version of the training manuals utilized to train personnel to perform in hourly fire watches and/or continuous fire watches at the Diablo Canyon Nuclear Power Plant, Units 1 and 2.

Answer to Document Reauest 4:

PG&E is providing a copy of DCPP Instructor Lesson Guide #

FEFA320, "FIREWATCH PREVENTION."

In addition, a video entitled

" Fire Protection" is used with this Lesson Guide.

The video will be available for viewing at the plant.

Document Recuest 5:

To the extent that any manual (s) provided in response to the' previous interrogatory make reference to standards (such as, for example, National Fire Protection Association standards or U.S. Nuclear Regulatory Commission Regulatory Guides) as part of the training manual and/or training program, please provide copies of the versions these standards which are so referenced.

t Answer to Document Recuest 5:

I PG&E is providing a copy of NFPA 51B, " Standard. for Fire j

)

Prevention in Use of Cutting and Welding Processes" (1989 Edition).

Document Recuest 6:

Please provide documents which describe the "NUMAI1C program" on Thermo-Lag 330 testing, as identified in PG&E's response to NRC Bulletin 92-01, Supplement 1 (PG&E Letter Nos. DCL-92-208 and HBL-92-060, dated September 28, 1992).

i Answer to Document Recuest 6:

I PG&E objects to this request.

The NUMARC testing program on Thermo-lag clearly addresses, by its very terms, the long term

! I i

i l

t resolution of the Thermo-Lag issue generic to the industry.

Such generic matters are not here at issue.

See Prehearing conference i

Order, at 37; Discovery and Scheduling Order, at 2.

i i

Document Reauest 7:

f Please provide copies of all procedures currently in use at i

the Diablo Canyon Nuclear Power Plant, Units 1 and 2, for the l

f purpose of controlling transient combustible materials.

J Answer to Document Recuest 7:

PG&E objects to this request.

Interim compensatory measures for inoperable fire barriers at the Diablo Canyon plant include only fire watches (hourly or continuous), supplemented in some cases by portable fire detection devices.

Control of combustibles l

is part of the Diablo Canyon fire protection program, but is not

~

part of the interim compensatory measures and is a facet of fire

[

protection unaffected by the Thermo-Lag issue.

Accordingly, i

procedures for control of combustible materials are not relevant to j

this proceeding and could not lead to relevant information.

Document Reauest 8.

Please provide copies of all procedures currently in use at the Diablo Canyon Nuclear Power Plant, Units 1 and 2, for the i

purpose of conducting and documenting the results of hourly and continuous fire watches.

Answer to Document Recuest 8:

PG&E is providing a

copy of NPAP C-113,

" FIRE SYSTEM IMPAIRMENT."

i Document Reauest 9:

Please provide copies of all procedures currently in use at the Diablo Canyon Nuclear Power Plant, Units 1 and 2, for the

i

i pu'. pose of implementing interim fire-protection measures apart from hourly and/or continuous fire watches.

Answer to Document Request 9:

With respect to interim compensatory measures, see Diablo j

Canyon Surveillance Test Procedure (STP) I-34J, " PORTABLE DETECTION L

SYSTEM INSTALLATION, TESTING AND OPERATION PROCEDURE," a copy of e

which is being provided.

PG&E objects to this document request to the extent it might request any procedures other than those which govern the implementation of interim compensatory measures in response to NRC Bulletin 92-1.

Fire protection procedures unrelated to those interim compensatory measures in place in fire areas where Thermo-Lag is located are not germane to the contention as admitted.

Document Recuest 10:

Please identify and provide copies of all Quality Assurance Department audits, inspections, surveillances, and any other form of review conducted by the Quality Assurance Department of the interim fire-protection measures being utilized to compensate for the use of fire barriers containing Thermo-Lag i

materials.

{

Answer to Document Recuest 102 There are no documents responsive to this request.

Document Recuest 11:

Please provide copies of all documents received from TSI (and/or all TSI documents in PG&E's possession, custody, or l

control) which discuss interim fire-protection measures.to be taken to compensate for fire barriers containing Thermo-Lag materials.

F k

8.

a.

--e r-r

i Answer to Document Recuest II:

PG&E objects to this request.

Although the request purperts to address interim compensatory measures, it in fact seeks information which, if any existed, would be germane only to the generic issue of the adequacy of the interim compensatory measures adopted at the Diablo Canyon plant.

This issue has been ruled by the Licensing Board to be outside the scope of this proceeding.

2 Discovery and Scheduling

Order, at 2.

There would be no correlation between any information TSI may have provided regarding interim compensatory measures and the efficacy of PG&E's implementation of those compensatory measures adopted for the Diablo Canyon plant and approved by the NRC.

Document Reauest 12:

Please provide copies of all documents received from NUMARC i

(and/or all NUMARC documents in PG&E's possession, custody, or '

control) which discuss interim fire-protection measures to be taken to compensate for fire barriers containing Thermo-Lag i

materials.

Answer to Document Recuest 12:

PG&E objects to this request for the same reasons articulated e

in response to Document Request 11 above.

Document Recuest 13:

Please provide a copy of the internal fire analysis portion of the report which PG&E has submitted or, if not yet submitted, the latest draft of the report which will eventually be submitted, to the U.S.

Nuclear Regulatory Commission in

[

response to Generic Letter No. 88-20, Supplement 4,

i

" Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities - 10CFR50.54(f)", June 28, 1991.

If no such report or draft exists, please provide a f'

copy of the fire analysis portion of the Diablo Canyon Long-Term Seismic Program probabilistic risk assessment, as well as

- 1 1

4

a description of any subsequent plant and/or procedural modifications which PG&E has made that would reduce the risk posed by fires.

Answer to Document Recuest 13:

PG&E objects to this request.

This request seeks information germane only to fire protection matters not at issue in the present i

proceeding.

The focus in this request on seismic vulnerabilities, in particular, apparently addresses an issue raised in proposed Contention V (regarding an alleged seismic vulnerability of Thermo-Lag), but specifically rejected by the Licensing Board.

Sag Prehearing Conference Order, at 37.

Document Request 14:

Please provide a copy of the internal fire analysis portion of the "second tier" documentation of the IPEEE examination required by Generic Letter No. 88-20, Supplement 4,

" Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities - 10CFR50.54 (f), June 28,1991 (see, in particular, page 9, Section 9, of the Generic Letter supplement, which states:

"The IPEEE should be conducted in a traceable manner to provide the basis for the findings.

l This can be dealt with most efficiently by a two-tier approach.

The first tier consists of the results of the examination, which will be reported to the NRC.

The second tier is the documentation of the examination itself, which should be retained by the licensee for. the duration of the l

license.")

Answer to Document Recuest 14:

J PG&E objects to this request for the same reasons articulated in response to Discovery Request 13 above.

Document Recuest 15:

Please provide copies of records documenting the conduct of calculations performed for the Diablo Canyon Nuclear Power

Plant, Units 1

and 2,

using any version of the fire propagation model known as COMPBRN, for configurations present in any of the fire areas identified in PG&E's response to i

1 l

a Supplement 1 to NRC Bulletin 92-01 as containing Thermo-Lag fire barrier material.

If no such calculations exist, please i

so state in writing.

(Note that the initial version of the j

code was documented in an NRC-sponsored report, NUREG/CR-3239, i

1 A Computer Code for Modelina Compartment Fires, COMPBRN November 1985; and that an additional version of the code is documented in UCLA-ENG-8524, COMPBRN III - A Computer code for Modelina Compartment Fires, November 1985.)

Answer to Document Recuest 15:

PG&E objects to this request.

Fire propagation calculations f

have no bearing on implementation of incerim compensatory measures i

for fire areas with Thermo-Lag.

The interim compensatory measures at the Diablo Canyon plant are what they are; they have been documented in correspondence to the NRC and they are consistent i

with the measures the Commission has expected and accepted generically.

The nature of those measures is not subject to litigation in this proceeding.

Likewise, the long-term adequacy of Thermo-Lag in the areas in which Thermo-Lag is used presently at

[

the Diablo Canyon plant is not here in issue.

The information requested by MFP would be of relevance only to issues regarding general adequacy of fire protection at the Diablo Canyon plant, r

long-term adequacy of Thermo-Lag in specific, applications, or the

{

adequacy of the accepted interim compensatory measures.

Document Recuest 16:

Please provide a copy of the current, interfiled, controlled

" fire protection plan" for the Diablo Canyon Nuclear Power Plant, Units 1 and 2.

(Note that the regulatory requirements for such a plan are addressed at 10 CFR 50.48(a).)

To the extent that this plan differs from what has been referred to as the " Fire Protection Appendix R Submittal" (see, for example, NUREG/CR-4840, page 2-8), please also provide a copy of the

current, interfiled, controlled

" Fire Protection Appendix.R Submittal"..

~,

l Answer to Document Reauest 16:

[

PG&E objects to th

.s request.

The " fire protection plan" for the Diablo Canyon plant has no relevance to PG&E's implementation of the accepted interim compensatory measures at Diablo Canyon.

The requested material would be relevant only to issues challenging i

aspects of the fire protection program at the Diablo Canyon plant not here at issue, to the long-term resolution of the Thermo-Lag issue for specific Diablo Canyon applications, or to the adequacy of the interim compensatory measures utilized at Diablo Canyon.

Contention V does not reach any of these matters.

i s

Document Recuest 17:

Please provide copies of the documentation describing all exemptions or applications for exemptions to the-requirements of 10 CFR 50.48 and/or 10 CFR 50, Appendix R, for the Diablo i

Canyon plant.

l t

I Answer to Document Recuest 17:

1 PG&E objects to this request.

Implementation of -interim compensatory measures for Thermo-Lag fire barriers does not involve any exemption applications. Such exemptions from 10 C.F.R. S 50.48 l

1 and/or Part 50, Appendix R, as PG&E might have received or might j

apply for, are irrelevant to this proceeding.

By definition, these exemptions and/or exemption requests would involve fire protection l

r matters not at issue in this-proceeding.

i Document Request-18:

l Please provide' a

copy of the

current, controlled, j

civil / structural drawing index for the Diablo Canyon Nuclear Power Plant, Units 1 and 2.

I

\\

1 4

1 I

Answer to Document Recuest 18:

PG&E objects to this request.

The civil / structural drawing

index, and the drawings themselves, are irrelevant to implementation of interim compensatory measures.

This is.not a proceeding to reassess fire protection generally at the Diablo Canyon plant or to reassess what compensatory measures ought to be taken in Thermo-Lag fire areas.

These drawings cannot lead to evidence relevant to whether PG&E has missed hourly or continuous fire

watches, or otherwise properly implemented interim cotJensatory measures.

Document Recuest 19:

Please provide a copy of the current, controlled, general arrangement drawings for Diablo Canyon, Units 1 and 2,

for areas of the plant in which fire barriers containing Thermo-Lag are located.

l Answer to Document Recuest 19:

1 PG&E is providing general arrangement drawings 515562,

-63,

-68,

-69,

-70,

-73,

-77,

-78, and -80 for fire areas in which Thermo-Lag is located as identified in Table 1 to PG&E's response l

to Supplement 1 of Bulletin 92-1.

Document Recuest 20:

Please provide a copy of the current, controlled Fire Brigade-

}

Procedures for Diablo Canyon Nuclear Power Plant, Units 1 and 2.

Answer to Document Recuest 20:

i PG&E objects-to this document request.

Fire Brigade Procedures, as well as the adequacy of other parts of Diablo Canyon's Fire Protection Program, are not germane to the contention f

l :,

..,_,~.,,.__,_,___.,,..,_._.:

as admitted.

The adequacy of PG&E's implementation of hourly fire watches in fire areas where Thermo-Lag is located is not dependent on the Fire Brigade Procedures included in the Fire Protection Program.

Document Recuest 21:

Please provide a copy of the current, controlled power and control cable routing diagrams for Diablo Canyon Nuclear Power Plant, Units 1 and 2.

Answer to Document Recuest 21:

PG&E objects to this request.

Cable routing diagrams, and cable routing generally, have no bearing on PG&E's implementation of interim compensatory measures.

This information might be related to fire protection issues unrelated to Thermo-Lag, to the i

long term resolution of the Thermo-Lag matter for the Diablo Canyon plant, or to an argument for different compensatory measures.

However, none of these matters are admitted in this proceeding.

Document Recuest 22:

Please provide copies of all reports submitted by PG&E to American Nuclear Insurers (ANI) concerning the occurrence of a fire at Diablo Canyon Nuclear Power Plant, Units 1 and 2.

Answer to Document Recuest 22:

No reports have been submitted to ANI concerning the occurrence of a fire at the Diablo Canyon plant in fire areas in which Thermo-Lag interim compensatory measures are being i

implemented.

PG&E objects to this document request to the extent 3

i it might request additional information for other areas.

Additional plant areas are unrelated to the implementation of i l i

interim compensatory measures in fire areas in which Thermo-Lag is located.

Document Recuest 23:

Please provide copies of all reports submitted by PG&E to MAELIU [ sic] concerning the occurrence of a fire at Diablo Canyon Nuclear Power Plant, Units 1 and 2.

Answer to Document Recuest 23:

No reports have been submitted to MAELU concerning the occurrence of a fire at the Diablo Canyon plant in fire areas in which Thermo-Lag interim compensatory measures are being implemented.

PG&E objects to this document request to the extent it might seek additional information for other plant areas for the l

same reasons stated in the Answer to Document Request 22.

Document Reauest 24:

Please provide copies of all PG&E notes, minutes, meeting transcripts, meeting summaries, and other documents (includi.ng, without limitation, viewgraphs, slides, handouts, etc.) which record or otherwise document the proceedings of NRC meetings attended by PG&E concerning Thermo-Lag fire barrier material and/or compensatory actions which can or should be taken as a result of any deficiencies in such fire barrier material.

Answer to Document Recuest 24:

PG&E objects to this document request to the extent it requests information unrelated to the implementation of interim compensatory measures in fire areas in which Thermo-Lag is located.

However, no documents exist which relate to PG&E meetings with NRC personnel concerning implementation of such interim _ compensatory measures.

l i 9 f

t f

i Document Recuest 25:

In PG&E's response to NRC Bulletin 92-01 (PG&E Letter Nos.

DCL-92-173 and HEL-92-048, letter dated July 29, 1992), PG&E states in part, "As a result of the uncertainties associated with qualification of Thermo-Lag fire barrier systems for small conduits between 1-inch and 4-inches o diameter, PG&E has verified that existing measures are sufficient to ensure that plant safety is not compromised."

Regarding this statement, please provide copies of records which document PG&E's verification that " existing measures are sufficient to ensure that plant safety is not compromised".

Answer to Document Reauest 25:

PG&E objects to this request.

This request is beyond the scope of admitted Contention V.

By its very terms, the request seeks the supporting bases for PG&E's prior conclusion that

" existing measures are sufficient to ensure that plant' safety is not compromised."

However, the issue of the sufficiency of existing measures (as opposed to implementation of those measures) has not been admitted for litigation in this proceeding.

See Discovery and Scheduling Order, at 2

("the adequacy of the Applicant's adherence to interim measures [is] all that [is) in issue").

Document Recuest 26:

In PG&E's response to NRC Bulletin 92-01 (PG&E Letter Nos.

DCL-92-173 and HBL-92-048, letter dated July 29, 1992), PG&E states in part, "As a conservative measure to augment the approved Appendix R Fire Protection Program, the Diablo Canyon plant has maintained hourly fire watches in effect since the beginning of commercial operation in all fire areas (except in the containment buildings and the Units 1 and 2 intake areas) where the Diablo Canyon plant credits Appendix R safe shutdown circuits." In addition, in PG&E's response to Supplerwent 1 to NRC Bulletin 92-01 (Table 1 in the enclosure to PG&E Letter Nos. DCL-92-208 and HBL-92-060, letter dated September 28,1 992), PG&E identifies eleven fire areas containing Thermo-Lag installations.

For each of these eleven fire areas, please provide copies of the records documenting the performance of the hourly and/or continuous fire watches for the past 30 days.

Answer to Document Recuest 26:

PG&E is providing the Fire Watch log sheets for the period i

f February 1, 1993 through February 28, 1993.

i l

Document Recuest 27:

PG&E's response to Supplement 1 to NRC Bulletin 92-01 (Table 1 in the enclosure to PG&E Letter Nos.

DCL-92-208 and HBL-92-060, letter dated September 28, 1992) identifies as one -

column the heading " Fire Duration (minutes)".

Please provide copies of the calculations and supporting reports which for the basis for these fire durations.

Answer to Document Recuest 27:

PG&E objects to this request.

The duration of the fire hypothesized for each Thermo-Lag fire area is of no relevance to implementation of compensatory measures (i.e.,

primarily fire watches).

The Licensing Board has previously rejected issues related to the long-term adequacy of Thermo-Lag or related to the adequacy of the previously accepted compensatory measures.

Accordingly, this discovery request goes beyond the scope of the proceeding.

Document Recuest 28:

Please provide any studies, evaluations, or reports conducted to confirm that all Thermo-Lag-affected areas can in fact be inspected by fire watches on an hourly basis, given the layout of the Diablo Canyon plant and the number of fire watch personnel assigned to such duties.

Answer to Document Recuest 28:

See Answer to Document Request 4 and Answer to Interrogatory 9.

Fire Watch Logs, coupled with training in accordance with _ _ _ _ _ - - _ _ _ _ _ _ - _ - _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ - - _ _ _ _ _ - - _ - _ - _ _ - _ _ _ _ -

I r

Instructor Lesson Guide FEFA320, assure that Thermo-Lag-affected fire areas can and are inspected by fire watches on an hourly basis, given the layout of the plant and the number of fire watch personnel.

The Fire Watch Logs and mandatory training provide confidence that plant personnel assigned to fire watch duties over I

long periods of time will maintain their effectiveness.

Document Recuest 29:

Please provide copies of any

studies, evaluations, t

assessments, or reports in PG&E's possession, custody, or control which discuss the effectiveness of training in obtaining procedural compliance involving repetitive tasks over long periods of time (i.e.,

months to years).

If PG&E has no such documents, please describe in detail the bases for PG&E having confidence that plant personnel arsigned to fire watch duties over long periods of time will maintain their effectiveness in terms of complying with procedures which

{

govern the conduct of their work.

Answer to Document Recuest 29:

See Answer to Document Request 28.

Document Recuest 30:

Please provide a copy of the latest version (interfiled and controlled) of the Technical Specifications for Diablo Canyon Units 1 and 2.

Answer to Document Recuest 30:

This document is available to MFP in the Public Document Room.

See 10 C.F.R. 5 2.740(b) (1) ; see also Discovery and Scheduling order, at 3.

Docurent Recuest 31:

Please provide a copy of the documents which constitute PG&E's review of the information contained in NRC Information Notice 92-82 ("Results of Thermo-Lag 330-1 Cortustibility Testing",

December 15, 1992) for applicability to the Diablo Canyon

plant, and, to the extent that such information is not reflected in those documents, please identify each and every instance in which Thermo-Lag fire barrier material is used at the Diablo Canyon plant to enclose intervening combustibles.

Answer to Document Recuest 31:

PG&E objects to this request.

NRC Information Notice 92-82 addresses combustibility of Thermo-Lag observed during ongoing Thermo-Lag testing. The Information Notice raises issues regarding use of Thermo-Lag to enclose intervening combustibles.1/

However, this issue is part of the generic Thermo-Lag issue ared has not been admitted for litigation in this proceeding.

The information requested has no bearing on the adequacy of PG&E's implementation of interim compensatory measures to address inoperable or degraded Thermo-Lag fire barriers.

Document Recuest 32:

Please provide the NRC safety evaluation performed pursuant to 10 CFR 50.48(b) for Diablo Canyon Power Plant.

Answer to Document Recuest 32:

PG&E objects to this request.

The NRC's safety evaluation report on fire protection at the Diablo Canyon plant is irrelevant to the issue admitted in this proceeding.

In any event, however, the requested document is available in the Public Document Room.

See 10 C.F.R. 5 2.740(b) (1).

1/

Use of Thermo-Lag to address intervening combustibles is a different application of Thermo-Lag than use as a fire barrier.

The compensatory measures required by the NRC for Thermo-Lag address only the fire barrier areas.

l Document Reauest 33:

Please provide a copy of the documents which constitute PG&E's response to NRC Generic Letter 86-10 (" Implementation of Fire Protection Requirements", April 24, 1986).

Answer to Document Recuest 33:

PG&E objects to this request.

PG&E's response to Generic I

Letter 86-10 addresses compliance with fire protection requirements generally.

However, such broad-based compliance issues are not i

admitted in Contention V.

Generic Letter 86-10, and the response, quite obviously pre-date the Thermo-Lag issue and have no bearing on the efficacy of PG&E's implementation of Thermo-Lag barrier interim compensatory measures.

Document Reauest 34:

Please provide copies of the program and procedures used at the Diablo Canyon plant for assuring that the ambient conditions of temperature to which the cables identified in response to the two previous interrogatories are subjected remain within the temperature assumed for purposes of qualification testing.

Answer to Document Recntest 34:

PG&E objects to this request.

Qualification testing of-l cables, ambient conditions around installed cables,- postulated aging of cables, cable ampacity considerations, and any other i

issues that might be revealed by the requested information, are all outside the scope of the present proceeding.-

This discovery request has no bearing on PG&E's implementation of interim i

compensatory measures in Thermo-Lag fire areas.

, i f

4 Document Recuest 35:

For each cable identified in response to Interrogatory #29 in Attachment B, please provide the environmental qualification file that is kept in accordance with 10 CFR 50.49(j).

Answer to Document Reauest 35:

PG&E objects to this request for the same reasons articulated in response to Interrogatory 29 and Document Request-34 above.

Document Request 36:

For each area of the Diablo Canyon plant where Thermo-Lag is used in the presence of cable that is important-to-safety, please provide all records of ambient temperature which have been collected during the operating life of the plant.

Answer to Document Reauest 36:

PG&E objects to this request for the same reasons articulated in response to Document Request 34 above.

Document Reauest 37; Please provide copies of any contract (s)

(or any other document or documents which authorizes a vendor to perform work) to augment, modify, or replace the Thermo-Lag fire barriers in any or all of the areas identified in PG&E's response to Supplement 1 to NRC Bulletin 92-01 as containing such fire barriers.

Answer to Document Reguest 37:

PG&E objects to this request.

It expressly addresses the long-term resolution of the Thermo-Lag issue at the Diablo Canyon

~

plant.

This -' issue has been rejected ' for litigation in this proceeding.

Respectfully submitted, k

b Joseph B.

Knottd, Jr.

David A. Repka Kathryn M.

Kalowsky WINSTON & STRAWN 1400 L Street, N.W.

Washington, DC 20005-3502 (202) 371-5726 i

Christopher J. Warner Richard F.

Locke PACIFIC GAS AND ELECTRIC COMPANY l

77 Beale Street San Francisco, CA 94106 Attorneys for Pacific Gas and Electric Company Dated in Washington, DC this 10th day of March, 1993 l

I I

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inp-10-199; 1-::05 FPOt1 DCPP-LEE G4 cut 4TPOL' IO EI20 E 15950 P 02 e

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION l

BEFORE_THE ATCMTC EAFF~T AND LICENSING "OARD i

t In the Matter of:

)

)

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

)

50-323-OLA i

)

(Construction Period I

(Diablo Canyon Nuclear Power

)

Recovery)

Plant, Units I and 2)

)

)

AFFIDAVTT I,

David K.

Cosgrove, being duly sworn, hereby state as follows.

i 1.

I am employed by Pacific Gas and Electric Company as Supervisor,

[

Safety and Fire Protection.

I 2.

My business address and phone number are:

Diablo Canyon Power Plant 104/4/28A P.

O.

Box 56 Avila Beach, CA 93424 (805) 545-4319 t

3.

I have provided the information which forms the basis for the f

answers to Interrogatories B-lb, B-1c, B-2, B-3, B-4, B-5, B-9, t

B-10, B-11, B-12, B-13 and Document Requests D-4, D-5, D-8, D-9, i

D-10, D-20, D-26, D-28, D-29 included in the attached " Pacific Gas and Electric Company's Response to First Set of Interrogatories and Request for Production of Documents 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 i

best of my knowledge and belief.

I t

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I 3rA;"E o F CALifese org DavidE!kodg[qfvt!I~[

do aur f of & D 2.oi.c & A 5Pb i

Sworn and subscribed to before me'this jpfEday of March, 1993 f

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U N WW g s=== um hm*7, a=umo

%.c Notary Public emeny m._

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r1AR 10 '93 14: 33 FROM TO EISHOPCOOK PAGE.002/004 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.BEFORE THE ATOMIC SAFFTY AND LICENSTNG BOARD In the Matter of:

)

i

)

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)

)

)

AFFTDAVIT I,

Alan L.

Nicholson, being duly sworn, hereby state as follows.

1.

I am e= ployed by Pacific Gas and Electric Company as a Nuclear Regulatory Engineer.

2.

My business address and phone number are:

333 Market Street, Room A6090 San Francisco, CA 94105 (415) 973-9654 3.

I have provided the information which forms the basis for the answers to Interrogatories B-18, B-19 and Document Requests D-24 included in the attached " Pacific Gas and Electric Company's Response to First Set of Interrogatories and Request for Production of Documents Filed by San Luis Obi' po Mot hers for Peace."

4.

The information contained in t_he ref erencer'. interrogatory answers and responses to requests for documents 3.s true and correct to the best of my knowledge and belief.

/

d24A,_

• J _/

A Alan L. Nicholson Sworn and subscribed to before ne this /0* day of March, 1993

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BIANCA E.ZELNIK y

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My cou:sission expires:

m;-lu-1992 :4:06 F;0'1 MPF-EEIGN C24TPOL TO 12023:5950 P.0; UNITED STATES OF AMERICA NUCLE 7Jt REGULATORY CO!GUSSICN E_E FC RE THE_.QOMTC F AFETY TG 1.!CENSI:G POAW In the Matter of:

)

}

Docket Nos 5 0 - 2 75 - OIA Facific Gas and Electric Company

)

50-323-OLA

)

(Construction Period iDiablo Canyon Nuclear Power

)

Recovery)

Plant. Units 1 and 2)

)

)

M.ELDjM I,

Usama A. Farrad-i, being duly sworn, hereby state as follows.

1.

1 am employed by Pacific Gas and Electric Company as Group Leader, Mechanical.

2.

My business address and phone number are:

333 Market Street, Room A7004 San Francisco, CA 94105 (414) 973-9726 3.

I have provided the infomation which f orms the basis f or the answers to Interrogatories B-26 and Document Requests D-19 included in the attached " Pacific Gas and Electric Ccepany's Response to First Set of Interrogatories and Request for Production of Documents Filed by San Luis Obispo Mothers for Peace."

4.

The informatien contained in the referenced interrogatory answers anc responses to recuests for documents is true and ccrrect to the best of my kncwledge and belief.

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Sworn and subscribed to before me this #ffd'.4y of March, 1993 C

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SAmota EADEEALY

= - -c SAM LU6 OIROPC COLMTV Wemmm.Dessen At ed eaM5 TOTi4L F.03

1 ATTACHMENT 1 CUMULATIVE INDEX CF DOCUMENTS PROVIDED TO MFP Starting Ending Document l

Bates No.

Batte No.

Date Document Deecrirtien I.

DOC"MENTS PREVIO" SLY PPOVIDED fBY LETTER DATrD 3/3/931 i

000001 000233 06/14/92 Report by PGEE titled " Classification of Structures, Systems, and Components for Diablo Canyon Units 1 and 2 (Q-List),"

Rev.

14; USNRC Docket Nos.

50-275 and 50-323.

l 000234 000249 02/10/S6 Diablo Canyon Plant Administrative l

Procedure, " General Requirements for Plant l

Maintenance Programs," NPAP C-40, Rev. 3.

000250 000271 09/01/92 Diablo Canyon Plant Administrative Procedure,

" Instrument and controls Preventive Maintenance Program," AP C-450, Rev.

9.

000272 000287 07/06/89 Diablo Canyon Plant Administrative Procedure,

" Maintenance Department Preventative Maintenance Program,"

AP C-750, Rev. 10.

II.

THEPRO-LAG (QQNTENU ON V) DOCUMENTS Interrocaterv 4 000288 000296 12/05/88 Diablo Canyon Plant Administrr.tive Precedure, " Plant organization for Fire Less Preventien," NFAP A-13, Rev.

7.

Interrocaterv 5 000297 000334 04/28/92 Diablo Canyon Plant Administrative Procedure " Fire Loss Prevention," AP C-13, Rev. 13.

Interrocatery o 000335 000340 09/11/90 Diablo Canyen Plant Administrative Procedure,

" Qualification and Training Requirements of Plant Personnel Specifically concerned with Fire Loss Prevention," NPAP B-13, Rev.

5.

Document Pecueet 4 C00341 000353 02/24/93 Diablo Canyon Plant Instructor Lesson Guide, Fire Prevention, FEFA320.

Document Pem:e et 5 000354 000364 1989 NFPA SIB, " Standard f or Fire Prevention in Use of Cutting and Welding Processes",

1989 Edition.

}

Starting Ending Document Bates No, Bates No.

Date Document Description Document Pecuest 9 000365 000373 12/11/91 Diablo Canyon Plant Administrative Procedure, " Fire System Impairment," NPAP C-113, Rev. 7.

Document Pecuest 9 000374 000390 10/8/92 Diablo Canyon Plant Surveillance Test Procedure,

" Portable Detection System Installation, Testing. and Ope. ration Procedure," STP I-34J, Rev. O.

Document Pecuest 19 6

Diablo Canyon Plant General Arrangement 000391 000399 Drawings 515562, -63,

-68,

-69,'-70,

-73,

-77,

-78, and -80.

l Document Recuest 26 t

Fire Watch Logs (February 1,1993, through 000400 001286 February 28, 1993).

A I

i 1 !

i i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '93 mr 17 p3 :3a

[

i In the Matter of:

)

e:

3,

)

Docket Nos. 50-275-OLA:

Pacific Gas and Electric Company

)

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 & ELECTRIC CC,MPANY ' S 1

RESPONSE TO FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE (RE:

CONTENTION V)" in the abc": -captioned proceeding have been served on the following by deposit in one United States mail, first class, or as indicated by an asterisk

(*),

by Federal Express overnight delivery, this loth day of March, 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 i

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 Washington, DC 20555 Section (original + two copies)

Adjudicatory File Peter Arth, Jr.

Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G.

Fairchild l

U.S. Nuclear Regulatory Commission California Public Utilities l

Washington, DC 20555 Commission 505 Van Ness Avenue San Francisco, CA 94102

7 l

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

P.O.

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

Wellington, Esq.

Christopher J. Warner, Esq.

l Diablo Canyon Independent Safety Richard F.

Locke, Esq.

Committee Pacific Gas & Electric Company 857 Cass Street, Suite D 77 Beale Street j

Monterey, CA 93940 San Francisco, CA 94106 j

Robert Kinosian Jill ZamEk*

l 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 l

San Jose, CA 95125 Q

David A.

Repka Counsel for Pacific Gas &

i Electric Company i

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.