ML20056C872
| ML20056C872 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/16/1993 |
| From: | Repka D FRIENDS PEACE EXCHANGE (FORMERLY MOTHERS FOR PEACE), PORTLAND GENERAL ELECTRIC CO., WINSTON & STRAWN |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#393-14130 OLA, OLA-2, NUDOCS 9307260058 | |
| Download: ML20056C872 (10) | |
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July 16, 1993 93 JUL 19 p,' 56 UNITEDSTATESOSAME$1ICA' NUCLEAR REGULATORY' COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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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 AND ELECTRIC COMPANY'S RESPONSE TO JULY 1, 1993 MOTION TO COMPEL I.
INTRODUCTION On July 1,1993, the San Luis Obispo Mothers for Peace ("MFP")
filed a
Motion to Compel' further discovery responses.1' Specifically, MFP seeks more documents and clarifications related to Pacific Gas and Electric Company's ("PG&E") response,2/ to MFP's Third Set of Supplemental Interrogatories and Requests for the e
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"Intervenor San Luis Obispo Mothers for Peace Motion to Compel Pacific Gas and Electric Company to Respond to Third Set of Supplemental Interrogatories and Requests for the Production of Documents Filed by San Luis Obispo Mothers for Peace",
dated July 1, 1993
(" Motion to Compel").
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" 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", dated June 18, 1993
(" Response").
9307260058 930716 PDR ADOCK 05000275 C
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Production of Documents (Aging).I' PG&E herein responds to the Motion to Compel.
II.
DISCUSSION A.
Interrocatorv lb This Interrogatory requested equipment qualification ("EQ")
files for:
the following important-to-safety components located in a harsh environment:
check valves Limitorque valve operators cables with bonded Hypalon jackets cables listed in Attachment 1 to Information Notice 93-33, April 28, 1993."
PG&E objected to the request for EQ files, as it has in the past.
A request for EQ files is overbroad and insufficiently focused on maintenance information.
MFP continues to misunderstand the difference between EQ issues and maintenance issues.
EQ is a design. consideration related to performance of equipment in a
harsh accident environment.
Maintenance relates, at most, to preserving the functional capability of equipment during normal operating conditions.
EQ files are focused on the former rather than the latter issue.
However, as PG&E has stated before, to the extent EQ requirements dictate particular maintenance requirements (e.g., to -
2' "Intervenor San Luis Obispo Mothers for Peace Third Set of Supplemental Interrogatories and Requests for the Production of Documents to Pacific Gas and Electric Company Re:
Aging,"
dated June 4, 1993.
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preserve qualified life under normal conditions),
those requirements are incorporated into the maintenance procedures and practices for the specific equipment. Heg Administrative Procedure D-7.56 (a copy of which was provided to MFP on March 16, 1993).
In this light, PG&E previously stated that it would make
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available for inspection and copying by MFP, any specific component maintenance procedures and histories for EQ equipment.
- Likewise, PG&E offered to make available records of ambient conditions for specified equipment.f' MFP has not availed itself of this opportunity in any systematic way.
However, PG&E has in fact previously provided MFP with copies of the specific maintenance procedures applicable to Limitorque motor operators.
These procedures, along with the Recurring Task Activities scheduler and Electric Work Orders (also provided previously), incorporate the maintenance requirements associated with environmental qualification of Limitorque motor operators.
This request for EQ files extends also to check valves.
Check valves, however, as stated in the Response, are not subject to the EQ program, so the request is meaningless.
i
- Finally, this discovery request also extends to certain electrical cables.
The types of cables listed are, in some i
s' See " Pacific Gas and Electric Company's Response to San Luis Obispo Mothers for Peace Motion to Compel Re:
Contention I,"
dated April 8, 1993, at 9-10; see also Response at 7-8.
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i instances, used in EQ applications.
With one exception, the electrical cables cited in the interrogatory that are within the scope of the EQ program are qualified for at least a 40-year life.
l Therefore, other than any monitoring of the normal installed, operating environment, they are not subject to specific maintenance requirements.
PG&E's methods to monitor the normal operating environment for this EQ equipment weridescribed in PG&E's Response to the June 18, 1993 MFP discovery requests.
3,gg, e.g.,
Response
at 5.
In one case of cables within the scope of the request (Raychem Flametrol cable), the qualified life is under current review for potential revision to less than 40 years.
- However, pending completion of this review, PG&E has determined that no changes in maintenance procedures are required, since the actual
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age of the cable in question is still within any reduced qualified life likely to result from the review.
B.
Interrocatory 2a j
This Interrogatory related to Information Notice (IN) 89-30 (March 15, 1989), which in turn related to potential issues due to i
I high temperature environments that contain safety-related electrical cables.
Interrogatory 2a, the subject of the Motion to compel, specifically sought a description of PG&E's methods for measuring temperatures in areas where important to safety equipment is located.
In addition, MFP sought "[i] the results of all such temperature measurements; [and] [ii) the results of any comparison between these temperature measurements and environmental u
f-qualification specifications for important-to-safety equipment in each zone."
MFP now complains that PG&E did not respond to these 1
latter two document requests.
In response to Interrogatory 2, PG&E referenced and clarified earlier responses describing PG&E's temperature monitoring program for EQ equipment.
PG&E stated that "The results of these i
temperature monitoring activities are available for inspection at DCPP."
Response at 8.
PG&E believes that this was fully responsive to MFP's initial request.
C.
Interrocatorv 6 In this Interrogatory, MFP sought information on any PG&E programs for measuring / monitoring radiation exposure to important to safety equipment.
(PG&E assumes that MFP was referring here to normal operating conditions.)
MFP further sought "[i] the results of all such radiation exposure measurements; [and) [11] the results of any comparisons between these radiation exposure measurements and environmental' qualification specifications for important-to-safety equipment in each zone.
PG&E reads this Interrogatory as related to equipment within the scope of the EQ program (based on the reference to comparisons of radiation measurements to EQ specifications).
PG&E explained that, in these cases, any radiation exposure under normal operating conditions is not a significant concern -- given that EQ equipment t
is qualified to the harsh radiation conditions of an accident environment.
MFP apparently is unsatisfied with this response.
MFP would like to know expressly whether PG&E " measure [s] radiation exposure to important-to-safety equipment in containment."
Accordingly, PG&E provides the following clarification.
PG&E does not monitor normal rad [ation exposure to Limitorque motor operators or to the cited electrical cables that are subject to EQ requirements.
This is because the normal expected radiation doses (under normal operating conditions) that EQ Limitorque motor operators and the subject EQ electrical cables will see in their installed lifetimes is a small percentage of the normal operating lifetime dose plus postulated accident dose for which this equipment is qualified.
(The normal operating dose to this equipment is less than 1% of the total lifetime normal operating dose plus postulated accident dose.)
III.
CONCLUSION Based on PG&E's previous responses, supplemented by information provided above, PG&E concludes that the Motion to
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t Compel is noot.
To the extent the Motion to Compel is not moot, it should be denied.
Respectfully submitted, b-David A. Repka.
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WINSTON &'STRAWN 1400 L Street, N.W.
Washington, DC 20005-3502 (202) 371-5726 Christopher J. Warner Richard F. Locke PACIFIC GAS AND ELECTRIC COMPANY 77 Beale Street San Francisco, CA 94106 Attorneys for Pacific Gas and Electric Company Dated in Washington, DC this 16th day of July,'1993 T ;-~
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b F-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 l'and 2)
)
)
AEEIDAVIT I, Wells 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:
333 Market Street, Room A2043
. San Francisco, CA 94105 I
(415) 973-9112.
3.
I have provided the information_which forms the basis for the-answers to Interrogatories ib,.2, and 6 included'in the attached
" Pacific Gas and Electric Company's Response to July 1, 1993 Motion.to Compel."
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.
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Sworn and subscribed to.before me this #6A d of July, 1993
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Notary Public /
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.My commission expires:
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yi*,G' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'93 JL 19 P3 56 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3,c 3, ya uut In the Matter of:
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.; i
)
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-AND ELECTRIC COMPANY'S RESPONSE TO JULY 1,
1993 MOTION TO COMPEL" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 16th day of July, 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 Regule. tory 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 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 U.S. Nuclear Regulatory Commission California Public Utilities Washington, DC 20555 Commission 505 Van Ness Avenue San Francisco, CA 94102
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,0-q Nancy Culver, President Truman Burns Board of Directors California Public Utilities San Luis obispo Mothers for Peace Commission P.O. Box 164 505 Van Ness, Rm. 4103 Pismo Beach, CA 93448 San Francisco, CA 94102 Robert R. Wellington, Esq.
Christopher J. Warner, Esq.
.Diablo Canyon Independent Safety Richard F.
Locke, Esq.
Committee Pacific Gas & Electric Company.
857 Cass Street, Suite D 77 Beale Street Monterey, CA 93940 San Francisco, CA 94106 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 San Jose, CA 95125 David A. Repka Counsel for Pacific Gas &
Electric Company l
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