ML20072N546

Second Set of Interrogatories.Certificate of Svc Encl

ML20072N546
Person / Time
Site:	Diablo Canyon
Issue date:	07/08/1983
From:	Kaufman P CALIFORNIA, STATE OF
To:	PACIFIC GAS & ELECTRIC CO.
Shared Package
ML20072N538	List: ML20072N533 ML20072N546
References
ISSUANCES-OL, NUDOCS 8307150361
Download: ML20072N546 (19)

Text

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)s UNITED STATES OF AMERICA Y9 C

NUCLEAR REGULATORY COMMISSION 2 n !7!

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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 Power )

Plant, Units 1 and 2) )

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SECOND SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJI AN Governor George Deukmejian hereby propounds to applicant Pacific Gas and Electric Company (PG&E) this Second Set of In terrogator ies, to be answered under oath within fourteen days, pursuant to 10 C.F.R. sec tion 2.740b.

INSTRUCTIONS A. Where you have incomplete information that 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.

B. When asked in the interrogatories below to identify or to give the identity of a person, please give the following information about him or her:

1. full name;

2. present job title and employer; l[kpo OO l-Q

. C. When asked in the interrogatories below to identify or to give the identity of a document, please give the following information about the document:

1. its title, if any;

2. its nature (e.g., letter, memorandum, chart, computer printout, ledg er) ;

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

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

5. the identity of each person to whom it is I

addressed.

D. As used herein, the singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun so used, and vice versa; similarly, the use of the masculine form of a pronoun shall be considered to include also within its meaning the feminine form of the pronoun so -used, and vice versa; and in a similar fashion any tense of any verb used herein shall be considered

'T also to include within its meaning all other tenses of the verb so used.

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

F. Should you. have any questions regarding the

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.

(2) " Appendix A" means Appendix A to part 50 of 10 C.F.R.

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

(4) "Bech 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 tem s, and components at the site.

(6) "Diablo Canyon Projec t" (DCP) means PG&E, Bechtel, all joint projects of PG&E and Bech tel concerning Diablo Canyon, and all contractors, subcontrac tor s, consultan ts , and agents of the foregoing, excluding the IDVP.

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

" writings" pursuant to rule 1001 of the Federal Rules of Evidence.

(8) "Important to safety" means SS&Cs that provide reasonable assu rance that the facility can be operated without undue risk to the health and safety of the public.

(9 ) " Independent Design Verification Program" (IDVP) means the program established by the November 19, 1981, order of the Nuclear Regula tory Commission (NRC), the November 19, 1981, letter f rom Harold Denton to Malcolm Furbush, and implementing j directives of the NRC staf f, as that progr'am may have been l modified since that date.

(10) " Person" includes natural persons, corpora tions, par tnerships, other business entities, and public agencies.

(11) "PG&E" means the Pacific Gas and Electric Company and 3.

its agents, employees, contractors, subcontractors, af filiates, departments, div is ions, units, subunits, and attorneys, excluding the IDVP .

(12) " Procured components" are components that were pu rchased by PG&E, rather than designed by employees of PG&E or PG&E design contractors.

(13) " Quality assurance" means all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisf actorily in service. Quality assurance includes quality control.

(14) " Quality control" means those quality assurance

actions related to the physical characteristics of a material, i

i struc tu re , component, or system, which provide a means to control the quality of the material, structure, component, or i system to prede termined requirements.

, (15) " Reg. Guide" means a Regulatory Guide of the Nuclear Regulatory Commission.

(16) " Safety-related" means those SS&Cs necessary to assure: (1) the integrity of the reac tor coolant pressure boundary; (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the 4

guideline exposures of 10 C.F.R. part 100.

(17) "SS&C" means structu res, sys tems, and components.

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(18) " WASH-1283" means the document issued by the Atomic Energy Commission on or about May 24, 1974, entitled " Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants -- Revision 1. "

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

INTERROGATORIES

1. When did PG&E first commit itself to comply with Appendix B in the design of Diablo Canyon?

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

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

4. If the commitment identified in your answer to Interroga tory No. 1 was other than an unconditional commitment to comply fully with all terns of Appendix B for design of Diablo Canyon, (a) What was the extent of the commitment made at that time?

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

(c) If it was ever enlarged, identify each and every commitmen t by PG&E to enlarged compliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment l wa s , and r

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

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

! quality assurance requirements of Appendix A in the design of Diablo Canyon?

5.

6. In what form was the commitment 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?

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 of Diablo Canyon, (a) What wa s the extent of the commitment made at 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, specif ying (i) when the commitment was made, (ii) wha t the extent of the enlarged commitment wa s , and (iii) the form in which the commitment was made.

9. When did PG&E first commit itself to comply with the quality assurance- tequirements of Appendix A in the design of Diablo Canyon SS&Cs that are impor tant to safety but not sa fe ty-rela ted?

10. In what form was the commitment made to comply with the quality assu rance requirements of Appendix A in the design of Diablo Canyon SS&Cs that are important to safety but not sa fe ty-rela ted ?

11. To what extent did the commitment apply to work performed 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 important to safety but not safety-related, (a) What was the extent of the commitment made at 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 c$mpliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the form in which the commitment was made.

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

14. In what form was the commitment to comply with 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 Interroga tory No. 13 was other than an unconditional commitment to comply fully with all terms of WASH-1283 for design of Diablo Canyon, (a) What was the ex :ent of the commitment made at that time? l 7.

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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?

(d) 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.

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

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

(b) In what form was the commitment to comply with the standard made?

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

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

(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 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 every commitment by PG&E to enlarged compliance, sp ecifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the form in which the commitment was 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 N45.2.11 (E) ANSI N45.2.12 (F) ANSI N45.2.13 (G) ANSI N45.2.23.

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

(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?

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

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

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

(3) 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 was, and (iii) the form in which the commitment was made.

The Reg. Guides to which this interrogatory refers are:

(A) 1.28 (B) 1.88 (C) 1.74 (D) 1,64 (E) 1. 144 (F) 1.123 (G) 1. 146

19. For each and every criterion contained in Appendix B, during what period, if any, do you contend that the quality assurance program for the design of Diablo Canyon Units 1 and 2 met the requirements of that criterion?

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20. Has the seismic design work of each and every design group in the design chain for each and every safety-related SS&C been reviewed b1 the DCP since November 19, 1981?

21. I f you r answe r 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 rea son f or their exclusion from review; (c) the identity of the person responsible for the decision to exclude them.

22. Has the seismic qualification of all procured components that are safety-rela ted been reviewed by the DCP since November 19, 1981?

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

( 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 decision to exclude them.

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, 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; (c) the reason for its 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 revieNed by the DCP been reviewed for the DE, DDE, and Hosgri earthquake?

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

(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 12.

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• safety-related SS&C been reviewed by the DCP since November 19, 1981?

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 exclusion from review; (c) the identity of the person responsible for the decision to exclude them.

30. How did Westinghouse define " safety-related" for 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 define "important to safety" for purposes of compliance with General Design Criterion 1 of Appendix A to Part 50 of 10 C.F.R. for all SS&Cs supplied by Westinghouse and used at Diablo Canyon.

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

33. Identify each and every person on whom you relied for the rendition of expert advice on matters pertaining to statistics and probability theory and give the qualifications j of each.

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34. Identify the person or persons referred to at page 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 in the preceding interrogatory, s ta te :

(a) The scope of the evaluation.

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

(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 interrogatories, state separately for each interrogatory:

(a) the identity of each and every person who participated in its answer; 1

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i (b) the identity of each and every document relied upon in preparing the answe r.

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 SUSAN L. DURBIN PETER H. KAUFM ,

p ty A or ys General

^

By ,

" PET 'TI . KAUFMAN

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Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2130

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, UNITED STATES OF AMERICA ,

l NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 1 . j

)

\- \ jf 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 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 Deuksejian" served on the following by U.S. Mail, first class, postage p repa id.

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

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

Wa sh ing ton, D.C. 20555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tree t, N .W.

Wa sh ing ton, D.C. 20555 1.

Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H S t ree t , N .W.

Wash ing ton, D.C. 20555 Hon. John Ahearne, Commicsioner U.S. Nuclear Regulatory Commission 1717 H S treet, N.W.

Washing ton, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Wa sh ing ton, D.C. 20555 Hon. Thomas S . Moore , Cha irman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Wash ing ton, D.C. 20555 Hon. W. Reed Johnson Atomic Safety and Licensing Appeal Boaid 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 Wash ing ton, D.C. 20555 Judge John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Wash ing ton, D.C. 20555 Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Wash ing ton, D.C. 20555 Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Wash ing ton, D.C. - 20555 Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Wash ing ton, D.C. 20555 Leonard Bickwit, Esq..

Of fice of the General Counsel U.S. Nuclear Regulatory Commission l Wash ing ton, D.C. 20555 l 2.

l

i Lawrence Chandler, Esq.

Of fice of Executive Legal Direc tor BETII 042 U.S . Nuclear Regulatory Commiss ion Washing ton, D.C. 20555 Sec re ta ry U.S . Nuclear Regulatory Commiss ion Washing ton, D.C. 20555 Attention: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E. Kerr, Esq.

Public Utilities Commission 5246 S tate Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Beach, CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Confe rence, Inc.

46 23 More Mesa Drive Santa Barbara, CA 93105 Gordon Silver Sandra A. Silver 1760 Alisal Street 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 Bruce Nor ton, Esq.

Norton, Burke, Berry & Junck 2002 East Osborn P.O. Box 10569 Phoen ix, AZ 85064 Philip A. Crane, Jr., Esq.

Richard F. Locke, Esq.

Pacific Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120 3.

David S . Fle ischaker, Esq.

P . O . B ox 117 8 Oklahoma City, OK 73101 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 Teleg ram Tribune P . O . B ox 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, & Axelrad 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 SUSAN L. DURB IN ,

PETER H. KAUFMAN d2pu y Attor eys General

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By /J / /

/ f p W H. KAUFMAN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2102 4.

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