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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20045D8561993-06-21021 June 1993 San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related Correspondence ML20045D8291993-06-18018 June 1993 Response to Third Set of Suppl Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6751993-06-0404 June 1993 Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence ML20045A6401993-05-26026 May 1993 PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence ML20044F7701993-05-21021 May 1993 Intervenor San Luis Obispo Mothers for Peace Second Set of Supplemental Interrogatories & Requests for Production of Documents to Pge Cable Failures at Diablo Canyon Nuclear Power Plant.* W/Certificate of Svc.Related Correspondence ML20056C1891993-03-10010 March 1993 Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence ML20128P2251993-02-16016 February 1993 Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories & Requests for Production of Documents to Pg&E.* PG&E Should Answer Interrogatories within 14 Days.W/Certificate of Svc.Related Correspondence ML20213E5791986-11-0606 November 1986 Response to Util Second Set of Interrogatories Re Reracking of Spent Fuel Pools.Equations of Motion Appear in Encl Computer Program.W/Proof of Svc ML20213E6091986-11-0606 November 1986 Response to NRC Second Set of Inerrogatories Re Proposed Reracking of Spent Fuel Pools.Not Possible to Either Identify or Supply All Ref Documentation Supporting Contentions.W/Proof of Svc.Related Correspondence ML20213E6201986-11-0606 November 1986 Response to NRC Second Set of Interrogatories.Contentions Re Proposed Reracking & Alternatives Based on Understanding of Existing Industry Practice & Currently Available Technology. W/Proof of Svc.Related Correspondence ML20213F5851986-11-0505 November 1986 Suppl to 861003 Response to Intervenors 860916 First Set of Interrogatories Re Metals Used in Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20213F5011986-11-0505 November 1986 Response to 861017 Second Set of Interrogatories Re Seismic Analysis of High Density Fuel Racks for PG&E for Diablo Canyon Nuclear Power Station & Request for Production of Documents.W/Certificate of Svc.Related Correspondence ML20211E2121986-10-20020 October 1986 Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence ML20215H6691986-10-20020 October 1986 Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence ML20211E1721986-10-20020 October 1986 Second Set of Interrogatories Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses on Spent Fuel Pool.Related Correspondence ML20211E1871986-10-20020 October 1986 Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence ML20210S8921986-10-0606 October 1986 Response to Util Interrogatories Re Preparation for Upcoming Safety Hearings on Reracking of Spent Fuel Pools.Safety Issues Should Be Considered Before Amend Accepted.W/ Certificate of Svc.Related Correspondence ML20210S9651986-10-0606 October 1986 Answers to Sierra Club 860915 First Set of Interrogatories Re Reracking of Spent Fuel Pools.W/Certificate of Svc. Related Correspondence ML20210T2611986-10-0606 October 1986 Response to NRC Interrogatories on Contention 1 Re Util Responsibility to Demonstrate Safety of High Density Reracking.Intervenors Not Responsible for Solving Waste Storage Problem.W/Certificate of Svc.Related Correspondence ML20210S9711986-10-0303 October 1986 Response to Util & NRC First Set of Interrogatories & Request for Production of Documents.Interrogatories Opposed for Reasons Indicated.Certificate of Svc Encl.Related Correspondence ML20210T0731986-10-0303 October 1986 Response to Interrogatories & Request for Production of Documents Re Alternatives to High Density Reracking of Spent Fuel Pool at Facilities.Certificate of Svc Encl.Related Correspondence ML20210T0221986-10-0303 October 1986 Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence ML20210S9241986-10-0303 October 1986 Response to San Luis Obispo Mothers for Peace First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20206U7481986-10-0303 October 1986 Response to 860916 Interrogatories & Request for Production of Documents Re Licensing Proceedings.Certificate of Svc Encl.Related Correspondence ML20210S9931986-10-0303 October 1986 Response to Consumers Organized for Defense of Environ Safety First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20210T0541986-10-0303 October 1986 Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20210B7341986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc ML20214P8291986-09-16016 September 1986 Requests Response to Listed Interrogatories Re Design & Const of Fuel Ponds.Certificate of Svc Encl.Related Correspondence ML20214Q3521986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210B6321986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds ML20214Q3781986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions I & II Concerning Reracking of Spent Fuel Pools.Notice of Change of B Norton Address & Certificate of Svc Encl.Related Correspondence ML20210B6701986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools ML20214Q2981986-09-16016 September 1986 First Round of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20214Q3621986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210E1781986-09-15015 September 1986 Interrogatories & Request for Production of Documents Re Theoretical Work Concerning Displacement of High Density Spent Fuel Racks Due to Hypothetical Seismic Excitation. W/Certificate of Svc.Related Correspondence ML20214R1401986-09-15015 September 1986 Interrogatories Requesting All Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools, Dry Cask Onsite Storage & Cost/Benefit Assessment on Reracking.Certificate of Svc Encl.Related Correspondence ML20214R2341986-09-15015 September 1986 Interrogatories Requesting Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools & Dry Cask Onsite Storage as Alternative to High Density Reracking.Certificate of Svc Encl.Related Correspondence ML20081D7851983-10-26026 October 1983 Request for Production of Documents by NRC at 831107 Hearing in Avila Beach,Ca.Certificate of Svc Encl ML20080S2831983-10-14014 October 1983 Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20080Q3741983-10-0707 October 1983 Second Supplemental Answers to First Set of Interrogatories. Certification of Counsel & Prof Qualifications Encl ML20080Q3851983-10-0707 October 1983 First Supplemental Answers to Second Set of Interrogatories. Certification of Counsel Encl ML20080Q3951983-10-0707 October 1983 First Supplemental Answers to Fourth Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl ML20085J5951983-10-0707 October 1983 Fifth Supplemental Response to First Set of Interrogatories. Portions of RB Hubbard & Fj Samaniego 821221 Direct Testimony & Certificate of Svc Encl ML20080Q4441983-10-0505 October 1983 Response of Idvp to Interrogatory 57 in Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20078E1861983-10-0303 October 1983 Fourth Supplemental Response to First Set of Interrogatories.Certificate of Svc Encl ML20078D5091983-09-29029 September 1983 Supplemental Response to Second Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl.Related Correspondence ML20080M8521983-09-28028 September 1983 First Supplemental Answers to Third Set of Interrogatories. Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20078E1331983-09-28028 September 1983 First Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20080L5721983-09-26026 September 1983 Response to Fourth Set of Interrogatories.Certification of Counsel & Certificate of Svc Encl ML20078B8021983-09-23023 September 1983 Idvp Answers to First Set of Interrogatories.Certificate of Svc Encl 1993-06-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference ML20059D2071993-08-24024 August 1993 Intervenor Exhibit I-MFP-193,consisting of Review of LER 1-90-015-00,re Docket 50-275,dtd 910118 ML20059D2241993-08-24024 August 1993 Intervenor Exhibit I-MFP-220,consisting of Protest of Util ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 IR 05000275/19910061993-08-24024 August 1993 Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 1999-09-20
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. H M' iTEn r.1)nal34'(bNI1FNCH UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION 23 Am 23 A11:35 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD ,"D CFFi2 C- x DCC'riI]",';
nn . k. j,[ ,
In the Matter of ) Docket No. 50-275
) Docket No. 50-32 3 PACIFIC GAS AND ELECTRIC COMPANY )
) (Reopened Hearing --
Diablo Canyon Nuclear Power ) Design Quality Assurance)
Plan t Units Nos. 1 and 2 )
)
GOVERNOR DEUKMEJIAN' S FIRST SUPPLEMENTAL RESPONSE TO APPLICANT'S FIRST DOCUMENT PRODUCTION REQUEST Governor George Deukmeji an hereby provides this first supplement to his response to the first document production request 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 9,198 3, l
l order. Further supplemental answers are contemplated, as i
l provided by 10 C.F.R. section 2.740 (e) .
l REQUEST NO. 2:
All documents relating to Diablo Canyon design or design quality assurance prepared by PG&E, the IDVP, or the NRC, having commen ts , no tes, or the like on them and any writings prepared by or for you discussing, commenting on or otherwise referring to those documents.
RESPONSE TO REQUEST NO. 2:
The board's order divided the documents sought by this request into two categories. The first category consists of 1.
Sa8SRD8!!ol888hig G
l
_. _ ~.
all documents relating to Diablo Canyon design or design quality assurance prepared by PG&E, the IDVP, or the NRC, having notes or comments made on them. An index of such documents in the possession of the Governor, his counsel, or consultants to counsel is attached hereto as Exhibit 2-A-1.
The second category of documents consists of writings i
discussing or commenting on documents dealing with Diablo Canyon design or design quality assurance, prepared by PG&E, the IDVP-, or the NRC. The board's order limited the documents in this category to be produced to those created prior to
! October 1, 198 1. The only such documents are in the possession i
of MHB Technical Associates and consist of documents pertaining to past hearings in this case, dealing principally with seismic criteria and other previously litigated subjects. Should PG&E desire production of these documents, they will be produced at the MHB offices in San Jose at a time mutually convenient to the parties.
l REQUEST NO. 3:
l All other documents relating to Diablo Canyon design i
or design quality assurance not produced in response to Request No. 2 which have been prepared or reviewed by or for you.
l l RESPONSE TO REQUEST NO. 3:
I l
Pursuant to an August 17, 198 3, telephone conversation between Mr. Nor ton and Mr. Strumwasser, this request has been i clarified to exclude all documents prepared by the applicant, the IDVP, or the NRC not having comments, no te s , or the like on
- them.
i 2.
,, , , -,.. - , - - - - - , - - . . ~ . , - . . - . - . . - - , - - - - - + ----a ..,-,----s-----,------e - - * - - - - - - - -
Pursuant to the same telephone conversation, documen ts having the following characteristics have also been excluded:
documents prepared by the personnel of the Office of the Attorney General or the Office of the Governor, which have been seen only by some or all of the following people: George Deukmejian, Governor; S teven A. Merksamer, Chief-of-S taff to the Governor; Vance W. Raye, Legal Aff airs Secretary to the Governor; John K. Van de Kamp, Attorney General; Nelson Kempsky, Chief Deputy Attorney General; Andrea Sheridan Ordin, Chief Assistant Attorney General; Michael J. S trumwas se r, Special Counsel to the Attorney General; Susan L. Durbin and Peter H. Kaufman, Deputy Attorneys General; Christina Neal, Analyst; and support staff of the Governor 's Office and the Office of the Attorney General. (The term " support staff" excludes consultants and all other person retained by cont rac t. ) This response constitutes certification of the foregoing characteristics of the documents thus excluded.
Pursuant to the same conversation, counsel f or PG&E is being sen t under separate cover a copy of the file consisting of all press clippings in the Office of the Attorney General concerning Diablo Canyon.
As to all remaining documents responsive to the request, an index of the documents requested is attached hereto as Exhibit 3-1. For the applicant's convenience this list includes documents already on file in this case.
3.
REQUEST NO. 4:
All documents that contain calculations ~, analyses or' computer programs performed by or for you regarding -the design of Diablo Canyon structures, systems or components.
RMSPONSE TO REQUEST NO. 4:
Other than those documents listed in the response to Request No. 3, above, no such documents exist.
REQUEST NO. 6: -
All cor respondence or records of meetings' or telephone , ..
conversations between Mr. Hubbard (or his associates) and Dr. .
t Rosette [ sic.] (or his associates) related in any way to design -
of structures, systems, or components at Diablo Canyon.
RESPONSE TO REQUEST NO. 6: .
All documents have been indexed, produced, proferred, or excused from production in prior requests.
t REQUEST NO. 7: ,
All notes, calculations, meeting minutes, computer outputs, drawings or other writings prepared by MHB Technical Associates or Dr. Rosette [ sic.] or any otherhof your technical consultants related in any way to design or. design quality assurance at Diablo Canyon. -
4 4.
RESPONSE TO REQUEST NO. 7:
All documents have been indexed, produced, proferred, or excused from pr oduction in prior requests.
DATED: August 19, 1983 JOHN K. VAN DE KAMP, Attorney General of the 'S tate 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, Deputy Attorneys General By -
SUSAN L. DURBIN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2105 l
l l 5.
Exhibit 2-A-1 DOCLPDTIS PREPARED BY PG&E, 'I1E IINP, CR 'HE NRC HAVING bnRGINAL POIYS BY 'I1E OCNERtIR'S REPRESENmTIVES DOCLNENT MARGIN 4LIA AITH OR T TITLE T DA'IE DATE MARGINALIA 000MNr n 18 81 MB Preliminary Report, Seismic Reverification Program, R.L. Cloud Assoc. (Draft) 11 19 81 MB Statement of George Maneatiu before the House Subcomittee on Energy ard the Environment 11 19 81 MB Statemcnt of Richard Eckert befae the House Subcmmittee on Energy ard the Envirorincnt 12 4 81 MB PG&E letter to NRC regarding qualifications of R.L. Cloud Associates to corduct design verification 1 8 82 ME NBC rotice of meeting with PG&E 1 13 82 MB PG&E submittal of prcposed Phase II program to NRC 1 28 82 MB NRC letter to PG&E regarding acceptability of proposed review plan 3 15 82 MB NRC Information Items: cover letter fewarding four R.F. Reedy letters 3 15 82 ME NRC Information Items: cover 1atter fawarding four R.L. Cloud letters 4 15 82 MB PG&E letter to NRC regarding PG&E ocxnments on Mardi 8,1982 R.F. Reedy repat 6 18 82 MB IINP Phase II Program Management Plan 7 16 82 ME NRC rotice of meeting with PG&E, Brookhavel National Laboratory, ard the IINP 72182 MB Internal NRC letter regarding Diablo Canyon Seismic Reverification Program Inspections:
May 26-28,1982 t 71482 MB PG&E letter to NRC respording to Violation
! rotice from Inspection Repat 50-323/82-09 l 7 27 82 MB IINP (Teledyne) July Semi 4bnthly Report 7 1 82 ME NRC Board Notification: Brookhavcn Repat I of its Irdeperdent Evaluation of Diablo I
Canyon Design Verification l 8 16 82 MB Response of PG&E to Governor Brown's Motion to Reopcn the Recad 8 23 82 MB NRC Staff's Response to Governor Brown's Motion to Reopcn the Proceeding...
10 13 82 MB NRC SECY-82-414: Diablo Canyon Design Verification Program - Phase II l
Recxxnmerdations 11 10 82 MB Sumary of November 10, 198 2 Comission Meeting, PG&E presentation of ocxnments on October 20, 198 2 NRC Staff Briefing 11 12 82 MB Stone ard Webster November Semi 4bnthly Repa t i
l Exhibit 2-A-1 Page 1
D00JMFNF MARGINALIA Atm 0R OF TITLE T TATE IA'IE MGGINALIA DoctMNP 1 28 83 MB January 28-29 Presentation regarding Diablo Canyon Unit 1 Conpanent Cooling Water System 2 17 83 MB NRC (Chairman Palladiro) letter to Horocable Marris Ikhll, U.S. House of Representatives 3 11 83 MB IDVP 2rd Fri&y of Mardi Seml-Monthly Repcrt 32583 MB IDVP Erd of March Semi-mnthly Report 3 14 83 MHB NRC Conmission Meeting: Interim IINP 32583 MB NRC Interview of Virgil Tennymn 4 S 83 MB Staterrets of Virgil Tmnyson and Richard Roam 5 27 83 MB IDVP letter forward Preliminary Draft of ITR's No. 36 ard 38 5 17 83 5/3V83 MB Motion of Governor George Deukmejian to Reopen the Record on Construction Quality Assurance 6 6 83 Kaufman NBC Staff Response to Joint Intervenor's and Govenur's 2 tion to Reope) on Constrtrtion Quality Assurance 6 10 83 6/15/83 Durbin First Docummt Production Request by Applicant Pacific Gas ard Electric Cmpany to Governor Deukmejian 6 6 83 Durbin NRC Staff Response to Joint Intervenor's and Governor's Motion to Reops on Construction Quality Assurance l
l Exhibit 2-A-1 Page 2 l
t
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.
l -
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.
I 11/16/81 Letter from Herb Brown to Chairman Palladino further elucidating on Gov. Brown's verification proposal, and i
further outlining PG&E/Blume QA deficiencies.
11/19/81 Statement of Richard Hubbard before House Subcommittee on Energy and the Environment summarizing deficiencies 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.
l 2/25/82 Letter from Herb Brown to NRC Commissioners and enclosure presen ting Governor Brown's technical comments on the proposed seismic design verification pr og ram.
1 5/24/82 Affidavit of Richard Hubbard concerning breakdowns in the Diablo Canyon Quality Assurance Program.
8/ 2/82 Letter from Alan Dynner to Harold Denton enclosing technical comments from counsel to Governor Drown 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, 1982 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 for NRC Commissioners re: IDVP Diablo P roceed ing 8/18/83 Dr. Jose Roesset - Comments on ITR's Exhibit 3-1 Page 2
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)
~.
Exhibit 3-1 Page 3
o e- n~ -
UNITED STATES OF AMERICA 00LMETED NUCLEAR REGULATORY COMMISSION USVC BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL. gag
) CFTjg 0F ggggt g, In the Matter of ) GCunerma a sgpyt,
) BRANCH 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) )
)
CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing GOVERNOR DEUKMEJI AN' S FIRST SUPPLEMENTAL ANSWERS TO APPLICANT'S FIRST SET OF INTERROGATORIES AND GOVERNOR DEUKMEJIAN' S FIRST SUPPLEMENTAL RESPONSE TO APPLICANT' S FIRST DOCUMENT PRODUCTION REQUEST served on the following by U.S-Mail, first class (except for those persons marked with an as ter isk ("*"), to whom the envelope was posted Express Mail),
pos': age prepaid.
Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H S tree t, N.W.
Washing ton, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washing ton, D.C. 20555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washing ton, D.C. 20555 1.
Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washingbon, D.C. 20555 Hon. John Ahearne, commissioner U.S. Nuclear Regulatory Commission 1717 H Stree t, N.W.
Washing ton, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. Thomas S. Moore, Chairman
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .
Hon. W. Reed Johnson
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. John H. Buck
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 j Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Judge Jerry R. Kline Atomic Safety and Licensing Board l U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 l
! Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
]
. Leonard Bickwit, Esq.
! Office of the General Counsel i
U.S. Nuclear Regulatory Commission Washington, D.C. 20555
, 2.
i t
Lawrence Chandler, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Secretary U.'S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Atten tion: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E. Kerr, Esq.
Public Utilities Commission 5246 State Building 350 McAllister Street San Francisco, CA 94102 l
Mrs. Raye Fleming 1920 Mattie Road Shell Beach , CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 Gordon Silver i
Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 934 01 l Joel R. Reynolds, Esq.
Eric Havian, Esq.
John Phillips, Esq.
Cen ter for Law in the Public Interest 10951 West Pico Boulevard, Third Floor Los Angeles, CA 90064 B ruce Nor ton, Esq.
- Nor ton, Burke, Berry & French 2002 East Osborn Phoenix, AZ 85064 Philip A. C rane , J r. , Esq. * .
Richard F. Locke, Esq.
Pacific Gas and Electric Company San Francisco, CA 94120 3.
David S. Fleischaker, Esq.
P. O. Box 1178 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 Telegram 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 Conn ecticut Avenue, N.W.
Washington, D.C. 20036 I
DATED: August 19, 1983 JOHN K. VAN DE KAMP, Attorney General of the State of Calif ornia ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, l PETER H. KAUFMAN, Deputy Attorneys General By ,
l SUSAN L. D RBIN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 l Los Angeles, California 90010 (213) 736-2105 1.
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