ML20071P296
| ML20071P296 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/31/1983 |
| From: | Reynolds J JOINT INTERVENORS - DIABLO CANYON |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-OL, NUDOCS 8306070406 | |
| Download: ML20071P296 (5) | |
Text
00tKETED tsnRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMINI0d -6 P t el BEFORE THE ATOMIC SAFETY AND LICENSING" APPEAL BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY )
Docket Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
)
JOINT INTERVENORS' RESPONSE'TO MOTION OF GOVERNOR DEUKMEJIAN TO REOPEN THE RECORD ON CONSTRUCTION QUALITY ASSURANCE On May 18, 1983, Governor Deukmejian moved this Appeal-Board for an order reopening the record in the Diablo Canyon Nuclear Power Plant ("Diablo Canyon) licensing proceeding on the issue of construction quality assurance
("CQA/QC").
The Governor based his. motion on the disclosure of thousands of deficiencies in the Diablo Canyon facility, as documented in various affidavits, sworn statements, and other recent documents.
The Joint Intervenors support the Governor's motion.
It supplies additional evidence regarding the breakdown in CQA/QC at Diablo Canyon on which the Joint Intervenors based their May 10, 1983 Motion to Reopen the Record on the Issue of Construction Quality Assurance.
In'particular, the Governor relies upon a May 6, 1983 Declaration of Richard B. Hubbard on Breakdowns in Construction Quality Assurance at Diablo Canyon, 8306070406 830531
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PDR ADDCK 05000275
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o PDR
which analyzes (a) the CQA/QC deficiencies outlined by former quality control personnel for Diablo Canyon contractor H.P.
Foley Company, (b) the CQA/QC deficiencies identified as part of the Independent Design Verification Program ("IDVP") based on the limited review conducted by Teledyne Engineering Services ("TES") and Stone and Webster Engineering Company
("SWEC"), and (c) the limitations in the TES/SWEC review itself.
This most recent declaration confirms the evidence and conclusions outlined in affidavits submitted previously by the Joint Intervenors in support of their motions to reopen the record on quality assurance.
Because of its obvious relevance to their pending motion, the Joint Intervenors hereby incorporate by reference the May 6, 1983 Declaration of Richard B. Hubbard as further support for reopening the record.
In addition, on May 10 and 11, 1983, the NRC issued two Preliminary Notices of Violation, both of which constitute additional direct evidence of CQA/QC deficiencies at Diablo Canyon not detected by the IDVP.
The first -- PNO 5-83-21 --
describes the discovery of faulty welds in the component cooling water system.
The second -- PNO 5-83-22 -- describes the discovery on May 9, 1983 that certain piping in the primary reactor coolant system fails to meet NRC standards for minimum wall thickness.
Both discoveries are currently being investigated by PGandE and the NRC.
These notices, which will be submitted to the Board when copies have been obtained
. ~
by counsel, are also incorporated by reference as further support for the Joint Intervenors' May 10th motion.
For the reasons stated by the Governor and by the Joint Intervenors in their respective motions, we urge this Board to reopen the record to take further evidence on the issue of CQA/QC.
DATED: May 31, 1983 Respectfully submitted, JOEL R.
REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
KENNETH GOLDENBERG, ESQ.
Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.
P. O. Box 1178 Oklahoma City, OK 73101 b
By (
CELR.dET{pLDS Attor eys for Joint Inter-venors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J.
FORSTER L.
.~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY )
Docket Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 31st day of May, 1983, I have served copies of the foregoing JOINT INTERVENORS' RESPONSE TO MOTION OF GOVERNOR DEUKMEJIAN TO REOPEN THE RECORD ON CONSTRUCTION QUALITY ASSURANCE, mailing them through the U.S.
mails, first class, postage prepaid.
Thomas S. Mcore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Commission Conference, Inc.
Washington, D.C.
20555 4623 More Mesa Drive Santa Barbara, CA 93105 Dr. W.
Reed Johnson Atomic Safety & Licensing Malcolm H. Furbush, Esq.
Appeal Board Vice President & General U.S.
Nuclear Regulatory Counsel Commission Philip A. Crane, Esq.
Washington, D.C.
20555 Pacific Gas & Electric Company Post Office Box 7442 Dr. John H. Buck San Francisco, CA 94106 Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20$55
o Docket & Service Branch David S. Fleischaker Office of the Secretary Post Office Box 1178 U.S. Nuclear Regulatory Oklahoma City, OK 73101 Commission Washington, D.C.
20555 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95725 Lawrence Chandler, Esq.
Office of the Executive Legal Arthur C. Gehr, Esq.
Director - BETH 042 Snell & Wilmer U.S. Nuclear Regulatory 3100 Valley Center Commission Phoenix, AZ 85073 Washington, D.C.
20555 Virginia and Gordon Bruno Herbert Brown, Esq.
Pecho Ranch Lawrence Coe Lanpher, Esq.
Post Office Box 6289 Alan Dynner, Esq.
Los Osos, CA 93402 Kirkpatrick, Lockhart, Hill, Christopher, et al.
Sandra and Gordon Silver 1900 M Street, N.W.
1760 Alisal Street Washington, D.C.
20036 San Luis Obispo, CA 93401 Nancy Culver Jance E.
Kerr, Esq.
192 Luneta Lawrence Q. Garcia, Esq.
San Luis Obispo, CA 93401 J. Calvin Simpson, Esq.
California public Utilities Carl Neiburger Commission Telegram Tribune 5246 McAllister Street Post Office Box 112 San Francisco, CA 94102 San Luis Obispo, CA 93402 John Van de Kamp, Attorney Bruce Norton General Norton, Burke, et al.
Andrea Sheridan Ordin, Chief 2002 E. Osborn Attorney General Phoenix, AZ 85016 Michael J.
Strumwasser, Special Counsel to the Attorney General State of California 3580 Wilshire Boulevard Suite 800 Los Angeles, CA 90010 Mckt Mt AMANDA VARONA