ML20076E169
| ML20076E169 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/19/1983 |
| From: | Durbin S CALIFORNIA, STATE OF |
| To: | PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML20076E171 | List: |
| References | |
| NUDOCS 8308240194 | |
| Download: ML20076E169 (23) | |
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e g.yo commsrox*Nc8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .g3 g 23 M
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD ,
In the Matter of ) Docket No. 50-275
) Docket No. 50 -323 PACIFIC GAS AND ELECTRIC COMPANY )
)
Diablo Canyon Nuclear Power )
Plant Units Nos. 1 and 2 )
)
GOVERNOR DEUKMEJI AN' S FIRST SUPPLEMENTAL ANSWERS TO APPLICANT'S FIRST SET OF INTERROGATORIES Governor George Deukmejian hereby provides this first supplement to his answers to the first set of interrogatories propounded to him by Applicant Pacific Gas and Electric Company. This supplement provides the answers specified by the Atomic Safety and Licensing Appeal Board in its August 9,1983, order. Further supplemental answers are contemplated, as provided by 10 C.F.R. section 2.740 (e) .
, INTERROGATORY NO. 3:
Iden tif y all examinations, reviews, studies, analyses, or the like, conducted, initiated, or anticipated to be conducted by or for you since September 1981 relating in whole or part to design quality assurance or design activities at Diablo Canyon. As to each such study, analysis, or the like, state:
(a) The date of preparation or anticipated p repa ration.
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8308240194 830819 PDR ADOCK 05000275 O PDR
e (b) The name of each and every person who has or will contribute to the effort.
(c) The contribution of each person identified in your answer to 3 (b) .
ANSWER TO INTERROGATORY NO. 3:
An index of those examinations, reviews, studies, analyses, or the like that are in the possession of the Governor, his attorneys, or consultants is attached hereto as Exhibit 3-1.
INTERROGATORY NO. 5:
Identify each and every structure at Diablo Canyon that you believe to be "important-to-safety", but which is not classified as design Class I. As to each such structure identified, state:
,' a ) The bases for your opinion that the structure should be conside red "impor tant-to-safety".
(b) Each regulation which, in your opinion, requires each such structure to be classified as "important-to-safety".
(c) The date upon which each such regulation required each such structure to be so classified.
ANSWER TO INTERROGATORY NO. 5:
A list of structures, buildings and facilities considered to be important to safety, but which are not within PG&E's design Class I, is attached hereto as Exhibit 5-1.
(a) The basis for this categor ization is tha t, upon evaluation of all criteria set forth in the previous answer to this in te rr oga tor y, it is concluded that the listed 2.
structures, buildings, and facilities function during plant operation to provide reasonable assurance that Diablo Canyon can be operated without undue risk to the health and safety of the public.
(b) 10 C.F.R. part 50, Appendix A, GDC-1.
(c) February 1971.
Supplements to this answer are contemplated, pursuant to 10 C. F . R. section 2.740 (e) .
INTERROGATORY NO. 6:
Identify specifically each and every system at Diablo Canyon that you believe to be "important-to-safety", but which is not classified as design Class I. As to each such system identified, state:
(a) The bases for your opinion that each such system should be considered "important-to-safety".
(b) Each regulation which, in your opinion, requires each such system to be classified as "important-to-safety".
(c) The date upon which each such regulation required each such system to be so classified.
ANSWER TO INTERROGATORIES NO. 6:
A list of systems and components which the Governor considers to be important to safety but which are not within PG&E's design Class I is attached hereto as Exhibit 6/7-1. The terns " systems" and " components" are used inte rchangeably -
j because the terminology conforms to that of PG&E.
(a) The basis for this categorization is that, upon evaluation of all criteria set forth in the previous answer 3.
to this interrogatory, it is concluded that the listed systems and components function during plant operation to provide reasonable assurance that Diablo Canyon can be operated without undue risk to the health and safety of the public.
(b) 10 C.F.R. part 50, Appendix A, GDC-1.
(c) February 1971.
INTERROGATORY NO. 7 :
Identify specifically each and every component at Diablo Canyon that you believe to be "important-to-safety", but which is not classified as design Class I. As to each such component identified, state:
(a) The bases for your opinion that each such component should be considered "important-to-safety".
(b) Each regulation which, in your opinion, requires each such component to be classified as "important-to-safety".
(c) The date upon which each such regulation required e ach s uch compon ent to bb so classified.
j ANSWER TO INTERROGATORY NO. 7:
See answer to Interrogatory No. 6.
INTERROGATORY NO. 14:
List each ITR, with revision number, that you have reviewed to date. As to e ach ITR, state specifically:
l (a) Each fact stated therein with which you disagree.
1 e i (b) The specific page(s) of each ITR where the l fact (s) set forth in your answer to 14 (a) is located.
1 (c) Each conclusion or opinion stated therein with
, 4.
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which you disagree.
(d) The specific page(s) of each ITR where the co nclusion (s) or opinion (s) set forth in your answer to 14 (c) is located.
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(e) The specific bases for your disagreement with each such f act, conclusion or opinion.
ANSWER TO INTERROGATORY NO. 14:
The Governor's review of the ITR's is not yet complete. This answer is current as of the date of this filing, and will be supplemented as provided by 10 CFR 2.740 (e) and the board's order.
The Governor does not know of any factual statements in any ITR thus far reviewed with which he disagrees. However, he disagrees with certain opinions and conclusions expressed in the ITRs. The conclusions and statements of opinion in each ITR reviewed to date with which there is disagreement are listed in Exhibit 14-1, attached hereto, l
The answer does not specify pages and paragraphs of e ach ITR, since that information is as readily available to PG&E as to the Governor.
INTERROGATORY NO. 15:
For each answer to these interrogatories, and all subparts thereto, identify each person who participated in the l
preparation of your answers pursuant to 10 C.F.R. S 2.740b(b).
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ANSWER TO INTERROGATORY NO. 15:
All answers partially prepared by Michael J.
l Strumwasser, Special Counsel to the Attorney General; Susan L.
l 5.
Durbin, Deputy Attorney General; Christina Neal, Analyst. All have the address 3580 Wilshire Blvd. , Los Angeles, CA 90010.
'MHB Associates, under the direction of Richard Hubbard, partially prepared the answers to Interrogatories 3, 5,' 6 , 7 and 14 . Dr. Jose Roesset partially prepared the answers to Interrogatory 3 and 14.
DATED: August 19, 1983 JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General l
MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURB IN ,
PETER H. KAUFMAN, Deputy Attorneys General By 21,ff SUSAN L. DURHIN Attorneys for Governor George Deukmejian
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3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2105 6.
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I Exhibit 3-1 10/30/81 Letter from Gov. Brown to Palladino with memo to Denton outlining California's proposal for an independent quality verification program.
11/07/81 Letter from Byron Georgiou to Chairman Palladino listing 13 seismic design errors, and reiterating request for an independent verification program.
Attached is a description of each of the 13 errors, 11/16/81 Letter from Herb Brown to Chairman Palladino further elucidating on Gov. Brown's verification proposal, and further outlining PG&E/Blume QA de ficiencies, 11/19/81 Statement of Richard Hubbard before House Subcommittee on Energy and the Environmen t summarizing de ficiencies in PG&E's Diablo QA program.
12/14/81 Letter from Richard Hubbard to Lawrence Lanpher, containing comments on the 11-12-81 R.L. Cloud report.
1/15/82 Letter from Herb Brown to the NRC Commissioners transmitting attached comments by Governor Brown on the proposed seismic design verification program.
2/17/82 Presenation of Richard Hubbard for Governor Brown concerning PG&E's proposed seismic design verification pr og ram. Presentation given at February 17, 1982 meeting with NRC staff.
2/25/82 Letter from Herb Brown to NRC Commissioners and enclosure presenting Governor Brown's technical
- comments on the proposed seismic design verification program, i
l 5/24/82 Affidavit of Richard Hubbard concerning breakdowns in the Diablo Canyon Quality Assurance Program.
8/ 2/81 Letter from Alan Dynner to Harold Denton enclosing technical comments from counsel to Governor Brown on the proposed phase II Diablo Canyon design verification program.
Exhibit 3-1 Page 1 l
9/ 9/82 Presentation of Richard Hubbard on the proposed Diablo Canyon verification program, presented at September 9, 198 2 meeting with NRC staff.
11/10/82 Presentation of Richard Hubbard concerning proposed phase II Diablo Canyon design verification program, presentation made before the NRC Commissioners.
3/ 7/83 Dr. Jose Roesset to Michael J. Strumwasser - Lists questions regarding the seismic analyses conducted for Diablo 3/25/83 Richard B. Hubbard to Michael J. Strumwasser -
Encloses Summary of Anonymous Allegations regarding Diablo 3/31/83 Supplemental affidavit of Richard Hubbard concerning breakdowns in theDiablo Canyon Quality Assurance p rogram.
4/26/83 Dr. Jose Roesset to Michael J. Strumwasser - Comments on the review of the seismic design of Diablo 5 / 2/83 Curran Roller to Michael J. Strumwasser - Encloses Information Concerning Bechtel/PG&E Schedule Incentives at Diablo 5/ 3/83 Dr. Jose Roesset to Michael J. Strumwasser - Comments on the open items and errors reported by the IDVP 6/17/83 Richard B. Hubbard to Michael J. Strumwasser -
Summaries of ITRs 18, 20, 21, 22, 23, and 24 7/28/83 Richard B. Hubbard to Michael J. Strumwasser -
Encloses Summaries of ITRs 25, 26, 27, and 28 8/ 8/83 Richard B. Hubbard to Michael J. Strumwasser -
Comments f or NRC Commissioners re: IDVP Diablo l P roceed ing 8/18/83 Dr. Jose Roesset - Commen ts on ITR's Exhibit 3-1 Page 2
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Unknown Richard Hubbard, Dr. Jose Roesset - Summaries of and comments on remaining ITR's, SER, IDVP Final Report, ITP Phase I Final Report (dates of completion unknown) 2 J
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Exhibit 3-1 Page 3
Exhibit 5-1 to Governor Deukmejian's First Supplemental Response to Applicant's First Set of Interrogatories I. STRUCTURES, BUILDINGS, AND FACILITIES A. Containment Building Structures and Components Reactor Cavity Liner Radiation Shielding (Permanently Installed)
Ventilation and Air Cleaning Systems, Dwg 102023 Containmen t Fan Cooling System Annular CRDM Ventilation System Incore Instrument Room Air Conditioning Iodine Removal System Containment Purge Supply and Exhaust Fans B. Auxiliary and Fuel Handling Building and Facilities, RMS
, 22000 Buildings and Components Pipe Rupture Restraints Radiation Shielding (Permanently Installed)
Spent Fuel Pool Liner Safety Related Masonry Walls i Ventilation, DWG 102023 High Radioactivity Sampling Station Interim High Radioactivity Sampling Station Fuel Handling Facilities New Fuel S torage Racks C. Turbine Building and Facilities, RMS 24000 Building and Components Turbine Building 480 V Switchgear Rooms Diesel Generator Rooms S tructu res Component Cooling Water Heat Exchanger Pipe Whip Shield Pipe Rupture Restraints Ven tilation Tech nical Support Cen ter Normal Heating and Ventilation System D. Intake and Discharge Structures and Facilities, RMS 26000 Structures and Components Intake Structure Pipe Rupture Restraints Exhibit 5-1 Page 1
Exhibit 6/7-1 to Governor Deukmejian's First Supplemental Response to Applicant's First Set of Interrogatories II. NUCLEAR STEAM SUPPLY - MECHANICAL SYSTEMS A. Reactor Coolant System, DWG 102007, RMS 31000 Reactor Coolant Pump Reactor Coolant Pump Motor Tanks Reactor Vessel and Associated Items Vessel Insulation Pressurizer Relief Tank Heat Exchangers and Heaters Pressurizer Heaters Other Components Control Rod Drive Mechanism (CRDM) and Ventilation Shrouds, RMS 31100 Fuel and Rod Control Cluster Assemblies Flux Thimble Isolation Valves B. Chemical and Volume Control System - DWG 102008, RMS 32000 Tanks and Demineralizers Boric Acid Batch Tank Heat Exchangers and Heaters Boric Acide Batch Tank Primary Preheater C. Safety Iniection System, DWG 102009, RMS 33000 Piping and Valves Accumulator Nitrogen Supply Line, except for protion that penetrates Containment and connects Accumulator Nozzles.
G. Spen t Fuel Pool Cooling System - DWG 102013, RMS 37110 Pumps Spent Fuel Pool Pump Demineralizers Spent Fuel Pool Demineralizer Heat Exchangers Spent Fuel Pool Heat Exchanger Piping and Valves Spent Fuel Pool Cooling System Piping Spent Fuel Pool Cooling System Valves Other Components Spent Fuel Pool Leak Detection System Exhibit 6/7-1 Page 1
H. Componen t Cooling Water System - DWG 102014, RMS 52100 Served Components (CCW Side)
Spent Fuel Pool Heat Exchanger NSSS Sample Heat Exchangers (Secondary Side)
I. Liquiq Radwaste Systems - DWG 102019, RMS 35000 Pumps Reactor Coolant Drain Tank Pump Tanks Reactor Coolant Drain Tank Piping an Valves Portions of System Piping from Reactor Coolant Drain Tank and Pumps to Chemical and Volume Control system (Liquid Holdup Tanks), to Safety Injection System (Refueling Water S torage Tank), and to Equipment Drain Receivers; Piping from Miscellaneous Equipment Drain Tank and Pumps to Equipment Drain Receivers; Piping from Equipment Drain Receivers and Pumps to Waste Concen trator ; Piping from Waste Concentrator through Waste Concentrates Holding Tank and Pumps to Drumming Station, and Radioactive Resins Removal System Piping.
Valves for above portions of System.
J. Gaseous Radwaste System - DWG 102024, RMS 36000 Pumps, Etc.
Waste Gas Compressor s Tanks Waste Gas Decay Tanks Piping and Valves Gaseous Radwaste Piping Gaseous Radwaste Valves O. Post Loca High Radiation Samplying System III. BALANCE OF PLANT - MECHANICAL SYSTEMS B. Feedwater System - DWG 102003, RMS 45000 Pumps and Turbines Steam Generator Feedwater Pump Heat Exchangers and Heaters Feedwater Heaters I. Fire Protection System - DWG 102018, RMS 55000 Pumps Gasoline Driven Fire Pumps with 300 Gallon Water Tank Exhibit 6/7-1 Page 2
Tanks Raw Water Storage Reservoir CO2 Storage Tank K. Diesel Engine Generating System - DWG 102021, RMS 47000 Piping and Valves
- Engine Combustion Air Intake and Exhaust Piping (Air Dryer)
Piping.
Engine Combustion Air Intake and Exhaust Piping (Air Dryer)
Valves.
Other Components Fuel Oil System Diesel Fuel Oil L. Turbine and Generator Associated System - DWG 102022, RMS 41000 Other Componen ts Electrohydraulic Control Unit S. Emergency Assessment and Response System T. Compressed Breathable Air System IV. ELECTRICAL SYSTEMS AND EQUIPMENT D. 480 V Systems and Equipmen t, RMS 63400 480 V Systems - Vital Ground Detection System - Vital F. 120 V Security System Uninterruptible AC Power Supply, RMS 63800, 66500 G. 125 and 250 VDC Systems and Equipmen t, RMS 63900 125 VDC System - Vital DC Ground Detection System H. Lighting Systems and Equipment, RMS 68600 Lighting System - Vital AC Lighting Transformers Vital (llE, 13E, 15E, 16E)
Lighting and Power Panels Vital AC (111, 131, 132, 151, 161)
Exhibit 6/7-1 Page 3 i /
L. Other Systems and Equipmen t Site Emergency and Containment Evacuation Signals, RMS 66300 Heat Tracing Systems, RMS 68110 Boric Acide - Nonvital (Traces 22, 23, 27, 182 anmd 183)
Post LOCA Sampling system Interim Post LOCA Sampling System V. INSTRUMENTATION AND CONTROLS C. Rod Control Systems, RMS 31100 D. Solid State Protection Systems, RMS 31200 Computer Demultiplexer E. Piping Systems Instrumen tation and Controls, DWG 102001 Condensate System Instrumentation and Controls, DWG 102002, RMS 44000 Radiation, Instrumen t Systems, DWG 102931 Nuclear S team S upply Sampling System Instrumentation and Controls, DWG 102011, RMS 37200 Radiation Instrument Systems, DWG 102012, RMS 38000 Gross Failed Fuel Detector System, RMS 31300 Spent Fuel Pool Cooling System Instrumentation and Controls, DWG 102013, RMS 37110 G. Loose Parts Monitor System, RMS 39000 I. Control Boards, RMS 70000 Dedicated Shutdown Panel O. Fire Detections System, RMS 55300 Smoke and Flame Detector s Fire Detection Control Cabinet P. Reactor Containmen t, System, RMS 21000 Polar Crane Seismic Lock Control Containment Leak Rate Test Facilities Q. Seismic Monitoring System, RMS 70000 S. Plan t Security System, RMS 66500 Exhibit 6/7-1 Page 4
Exhibit 14-1 ITR 6 Area of Disagreement: Definition of acceptance criteria.
Basis for Disagreement: Definitions of acceptance criteria are
, unclear. For example, the tolerance within which agreement must occur is not specified.
ITR 6 Area of Disagreement: Adequacy of IDVP verification of seismic qualification of auxiliary building.
Basis for Disagreement: The selection of work reviewed is not sufficien tly complete.
ITR 6 Area of Disagreement: Adequacy of soil springs analysis.
Basis for Disagreement: The soil prine analysis is unclear as to its consideration of soil mass, embvedment, radiation damping and bounda ries, j ITR 13 Area of Disagreement: Adequacy of IDVP verification of HLA soils work.
Basis of Diagreement: An inadequate verification of the HLA soils work was done, in that: 1) no l independent measurements of the depth to bedrock or the properties of the
! backfill soil were done; and 2) no l
check was performed of the bearing l capacity or lateral earth pressures.
I ITR 13 Area of Disagreement: Accuracy of IDVP verification of HLA soils work.
Basis for Disagreement: The check of blow count data used approximate corection f actors which are known to be inaccurate.
Exhibit 14-1 Page 1
ITR 13 Area of Disagreement: Adequacy of IDVP verification of HLA soils work.
Basis for Disagreement: In assessing the reasonableness of the materials properties definition, an inadequate range of factor s was conside red. No consideration was given to variation of soil properties with varying levels of strain due to an earthquake.
- ITR 16 Area of Disagreement
- Adequacy of IDVP verification of HLA soils work.
Basis for Disagreement: As in ITR 13, no consideration was given to verification of soil
, properties with varying levels of l strain due to earthquake. Also, an inadequate sample of wor k was checked
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in this ITR.
ITR 18 Area of Disagreement: Resolution of EOI's 8019, 8020, 8021, 8035, 8036, 8038, and 8039 Basis for Disagreement: Resolutions do not address root causes of EOI's, or ensure that similar problems do not exist in unreviewed portions of the plant ITR 21 Area of Disagreement: Resolution of EOI's 8028, 8029, 8030, and 8031 l
l Basis for Disagreemen t: Resolutions do not address root causes l
of EOI's, or ensure that similar
! problems do not exist in unreviewed j portions of the plant
- Exhibit 14-1 Page 2
ITR 21 Area of Disagreement: Resolution of EOI 8014 Basis for Disagreement: Resolution of this EOI mentions only one of six level control valves, provides no resolution as to remaining
, five valves. Also, root cause of EOI was not addressed ITR 22 Area of Disagreement: Resolution of EOI 8027 Basis for Disagreement: The reason for the original problem has not been ascertained, ano there is, therefore, no assurance that the problem has been solved ITR 22 Area of Disagreement: Resolution of EOI 8015 Basis for Disagreement: The resolution of this EOI does not resolve concerns raised in ITR 22, Rev.
O as to possible negative results of not requiring flaw testing ITR 23 Area of Disagreement: Resolution of EOI 6049 Basis for Disagreement: The resolution of this EOI does not address generic implications of overlooking vital equipment in the original review, and provides no assurance that similar problems do not exist elsewhere in the plant ITR 24 Area of Disagreement: Resolution of EOI's 8023, 8024, 8025, and 8026 i Basis for Disagreemen t: Resolutions of these EOI's do not l address the generic implications of the EOI's l
j Exhibit 14-1 Page 3 i
l i
ITR 24 Area of Disagreement: Resolution of EOI 8022 Basis for Disagreement: Resolution of this EOI does not explain why the interrupting current required for buses F, G, and H
- changed between Rev. O and Rev. 1, nor does it address the generic implications of the EOI ITR 24 Area of Disagreement: Resolution of EOI 8022 Basis for Disagreement: Resolution of this EOI does not discuss the significance, in terms of reduced safety margin, of using manufacturer tests to establish interrupting capacity, rather than
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using nameplate rating ITR 24 Area of Disagreement: Resolution of EOI 8045 Basis for Disagreement: The resolution of this EOI does not address the potential for common-mode failure in the 125V dc diesel engine starting circuits. Neither does it address the potential generic implications of this EOI ITR 25 Area of Disagreement: Resolution of EOI's 8063, 8011, and 8044 Basis for Disagreement: Resolution of these EOI's does not address their potential generic implications, or why such implications should be conside red resolved Exhibit 14-1 Page 4
ITR 26 Area of Disagreement: Resolution of EOI 8041 Basis for Disagreement: Resolution of this EOI fails to address the root cause and the generic implications of the undetected error ITR 27 Area of Disagreement: Resolution of EOI's 8051 and 8059 Basis for Disagreement: The resolution of these EOI's fails to address the root causes of the EOI's and their generic implications ITR 28 Area of Disagreement: Resolution of EOI 8053 Basis for Disagreement: Resolution of this EOI does not show that other such errors could not affect the quality standards applied to other equipment in other systems ITR 28 Area of Disagreement: Resolution of EOI 8056 Basis for Disagreement: Resolution of this EOI fails to show that the CRVP system was the only system for which Class lE equipment was omitted from the EQ report ITR 28 Area of Disagreement: Resolution of EOI 8059 Basis f or Disagreement: Resolution of this EOI fails to verify that the as-built wiring is in accordance with PG&E's wiring sys tem Exhibit 14-1 Page 5
ITR 50
- Area of Disagreement: Analysis of seventh item of PG&E/BNL d isag reement.
Basis for Disagreement: The ITR fails to indicate or specify which spectra are correct, or why.
ITR 50 Area of Disagreement: Resolution of PG&E/BNL disagreements.
Basis for Disagreement: The ITR does not consider or resolve the generic implications of the differences between the BNL and Blume spectra.
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Exhibit 14-1 Page 6 i
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 O.L.
) 50 -32 3 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) '
CERTIFICATION I, Susan L. Durbin, hereby certify:
- 1. I am one of the attorneys for Governor George Deukmejian in the above-entitled matter and, as such, am authorized to execute this certification.
- 2. I have read the foregoing Governor Deukmejian's First Supplemental Answers to Applicant's First Set of Interrogatories and know the contents thereof.
3.
I am informed and believe said answers to be true and correct.
I certify under penalty of perjury that the foregoing is true and correct.
Executed at Los Angeles, California, on August 19.
1983.
/1 l SUSAN L. DURBIN ;
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PACIFIC GAS AND ELECTRIC CO. ) Docket Nos. 50-275 0.L.
) 50-323 0.L.
l (Diablo Canyon Nuclear Power )
Plant, Unit Nos. 1 and 2 )
AFFIDAVIT OF RICHARD B. HUBBARD FOR GOVERNOR GEORGE DEUKMEJIAN RIChRD B. HUBBARD, being duly sworn, do say under oath that I, the undersigned have assisted in preparing and reviewing supplemental responses number 3, 5, 6, 7, and 14 of Governor Deukmejian to Pacific Gas and Electric Company's First Set of Interrogatories, dated June 10, 1983. Said answers are true and correct to the best of my knowledge and belief.
/
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,hk '
f RICHARD B. HUBBARD b&
Subscribed and sworn to before
-me this /g day of k WI', 1983. I'~'
b'AW ,k . NOTARY PU L C.CA NOTARY PUBLIC w, CENs SANTA ctA#A COUNTY My Commission expires: [At4 b, fi[9 ^
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I O
I 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
) 50-323 (Diablo Canyon Nuclear Power Plant, Units 1 and 2) )
)
)
i I have assisted in preparing the answer to interrogatory
- 14. I declare under the penalty of perjury that said answer is true and correct to the best of my knowledge and belief.
Executed this 17th day of August,1983, in Austin, Texas.
l" f" '
1 Signed: Jose M. Roesset l
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