ML20072L175

Second Set of Interrogatories.Certificate of Svc Encl

ML20072L175
Person / Time
Site:	Diablo Canyon
Issue date:	07/08/1983
From:	Kaufman P CALIFORNIA, STATE OF
To:	PACIFIC GAS & ELECTRIC CO.
Shared Package
ML20072L173	List: ML20072L170 ML20072L175
References
ISSUANCES-OL, NUDOCS 8307130074
Download: ML20072L175 (19)

Text

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. UNITED STATES OF AMERICA l 'N/ t:.. - T--

NUCLEAR REGULATORY COMMISSION ([D DOL ; 9 ,983 y --

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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL] BOARD q l p,:ek

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) igt' In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Poker )

Plant, Units 1 and 2) ~ ) ,

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SECOND SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN

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Governor George Deukmejian hereby propounds to applicant Pacific Gas and Electric Company (PG&E ) this Second Set of Interrogatories, to be answered under oath within fourteen days, pursuant to 10 C.F R. sec tion 2.740b.

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. INSTRUCTIONS

! A. Where you have incomplete information that i precludes your fully answering an interrogatory, give such information as you have and state what information you do not h av e . If you are unable to give the information in the form sought but have the information agg regated dif ferently, give the information in the form in which you have it and explain.

E B. Wh'en asked in the interrogatories below to l identify or to give the identity of a person, please give the l

following information about him or her:

_ .. _ .. .. 1. full name; r -

2. present job title and employer;

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PDR ADOCK 05000275 9 PDR

C. When asked in the in te r r o(a tor ies below to identify or to give the identity of a document, please give ~ the

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follow ing information about the document:

1. its title, if any; chart,

2. its nature ( e. g . , le t te r , memorandum, computer printout, ledg er) ;

3. the da te , if any, stated on the document;

4. the identity of each. person who signed it; e

5. the identity of each person to whom it is add re ssed.

D. As used herein, the singular form of a noun or

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its meaning the pronoun shall be considered to include within and vice versa; plural form of the noun or pronoun so used, k

similarly, the use of the masculine form of a pronoun shall be

' considered to include also within 4its meaning the feminine form 9

of the pronoun so used, and vice versa; and in a similar

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fashion any tense of any verb used herein shall be considered I

also to include within its meaning all other tenses of the verb h'

g so used.

• E. The use of the word "or" is the inclusive form of conjunction, implicitly including within its meaning the

's" that

" word "and."

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F. Should you, have any questions regarding the fi'l meaning of any term or interpretation of any interrogatory, you are encouraged to consult with counsel regarding such questions.

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, DEFINITIONS

~ (1) " ANSI" means American National Standards Institute. I I

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" Appendix A" means Appendix A to par t 50 of 10 C.F.R.

(3) " Appendix B" means Appendix B to part 50 of 10 C.F.R.

(4 ) "B ech tel" means the Bech tel -Power Corporation.

(5) "Diablo Canyon" means units 1 and 2 of the Diablo Canyon Nuclear Power Plant, including all structures, sys tems,

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and components at the site.

(6) "Diablo Canyon Projec t" (DCP) means PG&E , B echtel, all .

joint projects of PG&E and Bech tel concerning Diablo Canyon, and all contrac tor s, subcon trac tor s, consultants, and agents of ,

the foregoing, excluding the IDVP.

(7) " Document" means any and all things that constitutg

" writings" pursuant to rule 1001 of the Federal Rules of Evidence. '4 (8) -" Important to safety" means SS&Cs that provide reasonable assu rance that the facility can be operated without i

undue risk to the health and safety of the public.

(9 ) " Independent Design Verification Program" (IDVP) means i

the program established by the November 19, 1981, order of the Nuclear Regulatory Commission (NRC), the November 19, 1981, letter f rom Harold Denton to Malcolm Furbush, and implementing l directives of the NRC staf f, as that prog r'am may have been i

modified since tha t da te.

(10) "P e r so n" includes natural persons, corpora tions, partnerships, other business entities, and public - agencies.

(11) "PG&E" means the Pacific Gas and Electric Company and

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its agents, employees, contrac tor s, subcontractors, affiliates, departments, divisions, units, subunits, and attorneys, exclud ing the IDVP .

(12) " Procured components" are components that were purchased by PG&E, ra ther than designed by employees of PG&E or PG&E design contractors.

(13) " Quality assurance" means all those planned and systematic actions necessary to providi adequate confidence that a structure, system, or component will. perform ,

satisfactorily in service. Quality assurance includes quality control.

(14) " Quality control" means those quality assurance actions related to the physi. cal characteristics of a material, structure, component, or system, which provide a means to control the quality of the materia [g structure, compon en t, or system to .prede termined requirements.

I (15) " Reg. Guide" means a Regulatory Guide of the Nuclear i

Regulatory Commission.

(16) " Safety-rela ted" means those SS&Cs necessary to assure: (1) the integrity of the reactor coolant pressure boundary; (2) the' capability to shut down the reactor and maintain it in a safe shutdown condition; or (3 ) the capability v -

to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the guide,line exposures of 10 C.F.R. part 100.

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(17 ) '"SS&C" mea'ns structu re s, sys tem s , and components.

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(18) " WASH-1283" means the document' issued by the Atomic ,

m. Energy Commission on or about May 24, 1974, entitled " Guidance on Quality Assurance Requirements During Design and Procurement-Phase of Nuclear Powe r Plan ts -- Revis ion 1. " ,

(19) "You " and "you r " refer to PG&E.

INTERROGATORIES

1. When did PG&E first commit itself to comply with

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Appendix B in the design of Di'ablo Canyon?

2. In what form was the commitment to . comply with 7 Appendix B made?

3. To what extent did the commitment apply to work .

performed bef ore the date of the commitment?

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4. If the commitment identified in your answer to .,

Interroga tory No. I was other than an unconditional commitment to comply fully with all terns of- Appendix B for design of, D'i ablo Canyon, ~

(a) What was the extent-of the commitment made at i

that time?

(b) Was that commitment ever enlarged' by PG&E? '

(c) If it was ever enlarged, identify each, and every

, commitment by PG&E to enlarged compliance, specifying .

( i) when the commitment was made, . - -

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(ii) what the exten t of th'e enla rged commitment -

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wa s , and- '

l l (iii) the form in which the commitment was made.

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,, ~5~.' When did P'd&E first commit ~itself 'to comply with the quality assurance requirements of Appendix _ A . i'n the design of

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Diablo Canyon?

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4 .' ' In what f orm was the con mitment to comply with the quality assurance requirements' of Appendix A made?

7. To what ex tent did the commitment apply to work performed before the date of the commitment?

r, 8. If the commitment identified in your answer to

~ Interrogatory No. 5 was other than an unconditional commitment to- comply fully with all terms of the quality assurance

, , - requirements of Appendix A for' design oI Diablo Canyon,

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(a) What was the extent of the commitment made at

that time?

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(b) Was that commitment ever enlarged by PG&E? -

(c) If it was ever enlarged, identify each and every

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commitment by PG&E to enlarged compliance, specif ying (i) when the commitment was made, (ii) what the extent jgf the enlarged commitment wa s , and (iii) the form in which the commitment was made.

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9. When did PG&E first commit itself to comply with the quality assurance requirements of Appendix A in the design of Diablo Canyon SS'&Cs that are' important to safety but not

. , sa fe ty-rela ted?

. 10. In what form was the commitment made to comply with the quality assurance requirements of Appendix A in the design of Diablo Canyon SS&Cs that are important to safety but not

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sa fe ty-rela ted?

c ~~ <- ~11; To what extent did the commitment apply to work per formed before the date of the commitment?

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12. If the commitment identified in your answer to

._ Interrogatory No. 9 was other than an unconditional commitment to comply fully with all terms of the quality assurance requirements of Appendix A for design of Diablo Canyon SS&Cs that are impor tant to safety but not sa f e ty-rela ted ,

(a) What was the extent of the commitment made at that time?

(b) Was that commitm6nt ever bnlarged by PG&E7 (c) If it was ever enlarged, identify each and every commitment by PG&E to enlarged compliance, specifying (i) when the commitment was made, ,

(ii) what the extent of the enlarged commitment wa s , and (iii) the form in which the commitment was made.

13. When did PG&E first comml46itself to comply with WASH-1283 in the design of Diablo Canyon?

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14. In what form was the commitment to comply with I

WASH-1283 made?

15. To what extent did the commitment apply to work performed before the date of the commitment?

16. If the commitment' identified in your answer to x

s In te rro'g a tory No. 13 was other than an unconditional commitment 3

l to comply fully with all terms of WASH-1283 for design of-Diablo Canyon, (a) What was the extent of the commitment made at

., that time?

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(b) To what extent did the commitment apply to work

._ performed before the date of the commitment?

(c) Was that commitment ever enlarged by PG&E? f (d) If it was ever enlarged, identify each and every commitment by PG&E to enlarged compliance, specifying  ;

4 (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and '

i (iii) the form in which the commitment was made. '

l 17 . With respect to each of the ANSI standards specified below in , items A through G, state separately:

(a) When did PG&E first commit itself to comply with l the standard in the design of Diablo Canyon?

I In what form was the commitment to comply with I

( b) the standard made? N

,5 (c) With which revision of the standard did PG&E

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commit itself to comply, and to what extent did PG&E I

subsequently c'ommit itself to comply with later revisions?

(d) To what extent did the commitment apply to work per formed before the date of the commitment?

(e) If the commitment identified in your answer to item (b), above, was other than an unconditional commitment x .

to comply fully with all terms of the standard for the design of Diablo Canyon:

(1) What was the extent of the commitment made

, at that time?

(2) Was that commitment ever enlarged by PG&E ?

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, (3) If it was ever enlarged, identify each and m every commitment by PG&E to enlarged compliance, speci fying (1) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the f orm in which the commitment was

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made.

The standards to which this interrogatory refers are: ,

(A) ANSI N45.2 (B ) ANSI N45.2.9 (C) ANSI N45.2.10 (D) ANSI N45.2.ll (E) ANSI N45.2.12 (F) ANSI N45.2.13 *

,3 (G) ANSI N45.2.23.

18. With respect to each of the Reg. Guides specified i

below in items A through G, state separately:

(a) When did PG&E first commit itself to comply with the Reg. Guide in the design of Diablo Canyon?

(b) In what form was the commitment to comply with the Reg. Guide made?

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(c) With which revision of the Reg. Guide did PG&E commit itself to comply, and to what extent did PG&E subsequently commit itself to comply with later revisions?

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. "(d) To what extent did the commitment apply to work performed before th'e date of the commitment?

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(e) If the commitment identified in your answer to item (b) , above, was other than an unconditional commitment to comply fully with all terms of the Reg. Guide for the design of Diablo Canyon:

(1) What was the extent of the commitment made at that time?

(2) Was that commitment ev,er enlarged by PG&E ?

(3) If it was ever enlarged, identify each and every commitment by PG&E to enlarged compliance, sp ecifying (i) when the commitment was made, (ii) what the extent of the enlarged commitmen t was, and (iii) the form in which the commitment was made. s The Reg. Guides to which this interrogatory refers are:

I (A) 1.28 i

(B) 1.88' (C) 1.74 (D) 1.64 (E ) 1.144 (F) 1.123 s, .

(G) 1.146

19. For each and every criterion contained in Appendix B, l during what period, if any, do you contend that the quality

, assurance prog ram f'or the design of Diablo Canyon Units 1 and 2 i

j met the requirements of that criterion?

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20. Has the seismic design work of each and every design

m. group in the design chain for each and every safety-related SS&C been reviewed by the DCP since November 19, 1981?

21. If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that have not been so reviewed state:

(a) the identity and locations. of the SS&Cs, and the identity of the design gro'ups whosI work was not reviewed;

( b) the reason for their exclusion from review; (c) the identity of the person responsible for the dec ision to exclude them.

22. Has the seismic qualification of all procured components that are safety-related been reviewed by the DCP since November 19, 19817

23. If your answer to the preggeding interrogatory is other than an unqualified "yes," for all such components thst have not been so reviewed state:

i (a) their identity and locations; (b) the vendor or vendors; (c) the reason for their exclusion from review; (d) the identity of the person responsible for the de' cision to exclude them.

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24. Has the seismic design work of each and every design group in the design chain for each and every safety-related SS&C that was reviewed by the DCP been reviewed for the DE, I

, . DDE, and Hosgri earthquake since November 19, 1981?

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, 25 . If your answer to the preceding interrogatory is other

- than an unqualified "yes," for each safety-related SS&C that was not reviewed for all three earthquakes state:

(a) the identity and locations of the SS&Cs, and the identity of the design groups whose work was not reviewed; (b) for which of the three earthquakes it was not reviewed;

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(c) the reason for fts exclusion from review for that earthquake;

(d) the identity of the person responsible for the decision to exclude it. .

26. Has the seismic qualification of all safety-related procured components that were reviewed by the DCP been reviewed for the DE, DDE, and Hosgri earthquake?

27 . If your answer to the preqeding interrogatory is other than an unqualified "yes," for all such components that have not been so reviewed state:

i (a) their identity and locations; (b) the vendor or vendors; (c) for which of the three earthquakes they were not reviewed; (d) ,

the reason for their exclusion from review for that earthquake; (e) the identity of the person responsible for the decision to exclude them.

28. Has the nonseismic design work of each and every design group in the design chain for each and every t, o .

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safety-related SS&C been reviewed by the DCP since November 19,

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29. If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that

have not been so reviewed state

(a) the identity and locations of the SS&Cs, and the identity of the design groups whose work was not reviewed;

( b) the reason for their excl'usion from review; (c) the identity of the person responsible for the '

decision to exclude them.

30. How did Westinghouse define " safety-related" for i

purposes of compliance with Appendix B to Part 50 of 10 C.F.R.

for all SS&Cs supplied by Westinghouse and used at Diablo Canyon.

31. How did Westinghouse defige "important to safety" for p'urposes of compliance with General Design Criterion 1 of

Appendix A to Part 50 of 10 C.F.R. for all SS&Cs supplied by 1 Westinghouse and used at Diablo' Canyon.

32. If your answer to any of the preceding interrogatories applies differently to unit 1 and unit 2 of Diablo Canyon, identify the interrogatory and explain how the answer differs f or unit 1 and unit 2.

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l 33. Identify each and every person on whom you relied for l

the rendition of expert advice on matters pertaining to l

statistics and probability theory and give the qualifications

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34. Identify the person or persons referred to at page

m. 3.5-8 of the IDVP Final Report as having been retained by the DCP to conduct a statistical evaluation, and provide the qualifications of each.

35. With respect to the statistical evaluation described l

1 in the preceding interrogatory, state:

(a) The scope of the evaluation.

(b) The schedule for" the conduct of the evaluation.

1 (c) The results of the evaluation .to date.

(d) The nature of all work remaining to be done in '

connection with the evaluation.

(e) The identity of each and every person, excluding clerical personnel, who participated in the evaluation and the nature of the work each performed.

36. For each of the preceding ,fnterrogatories, state separately for each interroga tory:

I (a) the identity of each and every person who i

participated in its answer; 8

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, (b) the identity of each and every document relied

a. upon in preparing the answe r.

DATED: July 8, 1983 JOHN K. VAN DE KAMP , Attorney Gene ral of the State of California ANDREA SHERIDAN ORDIN, . Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN PETTER H. KAUF ,

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ep ty A or ys General

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/ 18ET II . KAUFMAN Attorneys for Governor George Deukmejian

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3580 Wilshire Boulevard Suite 800 Los Angeles, California 9 0010 (213) 736-2130

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UNITED STATES OF AMERICA (. r NUCLEAR REGULATORY COMMISSION ~_.

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c.. I ' I 993 ", I BEFORE THE ATOMIC SAFETY AND LICENSING APPENF;BOAP& ,., 7 /

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I l In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

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CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing "Second Set of Interrogatories Propounded to .

Pacific Gas and Electric Company by Governor Deukmejian" and "Second Set of Interrogatories Propounded to the Independent Design Verification Program Contractors by Governor Deukmejian" served on the following by U.S. Mafl, first class, postage prepaid.

I Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H Stree t, N.W.

Wa sh ing. ton, D. C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission 1717 H Stree t, N.W.

t Wa sh ing ton, D.C. 20,555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regula tory Commission 1717 H Street, N.W.

Wa sh ing ton, D.C. 20555 Y l- ,

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Hon. James Asselstine, Commissioner c U..S. Nuclear Regulatory Commission j 1717 H S treet, N.W.

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Washing ton, D.C. 20555 Hon. John Ahearne, Commissioner U.S . Nuclear Regulatory Commiss ion 1717 H S treet, N.W.

Wa sh ing ton, D.C. 20555 Atomic Saf ety and Licensing Appeal Board U.S . Nuclear Regulatory Commiss ion Wa shing ton, D.C. 20555 Hon. Thomas S. Moore, Chairman .

Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 -

Hon. W. Reed Johnson Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission ,

Wash ing ton, D.C. 20555 Hon. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Judge John F. Wolf, Chairman ' as Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission

! Washing ton, D.C. 20555.

I Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Judge Jerry R. Kline Atomi*c Safety and Licensing Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Harold Den ton ' '

Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Leonard Bickwit, Esq.

- -- Off kee of- the General Counsel U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 D l- .

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Lawrence Chandler, Esq. C Office of Executive Legal Direc tor BETH 042

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U.S . Nuclear Regula tory Commiss ion Wa shing ton, D.C. 20555 Sec re ta ry U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Attention: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 l

, e Janice E. Kerr, Esq.

Public Utilities Commission 5246 State Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 19 20 Mattie Road Shell Beach, CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Confe rence, Inc.

4623 More Mesa Drive s Santa Barbara, CA 93105 d5 Gordon Silver

! Sandra A. Silver 1760 Alisal Street I

San Luis Obispo, CA 93401 Joel R. Reynolds, Esq.

John Phillips, Esq.

Center for Law in the Public Interest 10951 West Pico Boulevard, Third Floor Los Angeles, CA 90064 -

B ruce Nor ton, Esq.

g' Norton, Burke, Berry & Junck 2002 East Osborn P .O. Box 10569 .

Phoenix, AZ 85064 Philip A. Crane, Jr. , Esq.

Richard F. Locke, Esq.

Pacif4c Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120 o o ,

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David S . Fle ischake r , Esq. t P . . O . B ox 117 8 Oklahoma City, OK 73101

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Arthur C. Gehr, Esq.

Snell & Wilmer 3100 Valley Bank Center Phoenix, AZ 85073 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, CA 95125 Mr. Carl Neiberger . .

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Teleg ram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Virginia and Gordon Bruno Pecho Ranch P.O. Box 6289 .

Los Osos, CA 93402 Nancy Culver 192 Luneta San Luis Obispo, CA 93401 Maurice Axelrad, Esq.

Lowenstein, Newman, Reis, & Axelrd,d6 10 25 Connecticut Avenue, N.W.

Wash ing ton', D.C. 20036 DATED: July 8, 1983 JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUS AN L . DURB IN ,

PETER H. KAUFMAN, 62pu y Attor eys General T

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By / f/

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/' p W H. KAUFMAN Attorneys for Governor George Deukmejian

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