ML20076H464

First Document Production Request.Related Correspondence

ML20076H464
Person / Time
Site:	Diablo Canyon
Issue date:	06/10/1983
From:	Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO.
To:	CALIFORNIA, STATE OF, JOINT INTERVENORS - DIABLO CANYON
Shared Package
ML20076H466	List: ML20076H464 ML20076H478 ML20076H503
References
NUDOCS 8306160579
Download: ML20076H464 (6)

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CKE CO.pnTED 1 UNITED STATES OF AMERIGg3 $$ 14 mi'.07 2 NUCLEAR REGULATORY COMMISSION.. _

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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5

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In the Matter of )

8 ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 9 )

Diablo Canyon Nuclear Power Plant ) (Reopened Hearing --

10 Units Nos. 1 and 2 ) Design Quality

) Assurance) 11 12 13 14 FIRST DOCUMENT PRODUCTION REQUEST BY PACIFIC GAS AND ELECTRIC COMPANY 15 TO JOINT INTERVENORS AND GOVERNOR DEUKMEJIAN 16 .

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18 Licensee PACIFIC GAS AND ELECTRIC COMPANY hereby 19 requests JOINT INTERVENORS (jointly and severally) and i

20 GOVERNOR DEUKMEJIAN to produce the following documents 21 pursuant to 10 C.F.R. $ 2.741.

22 INSTRkJCTIONS 23 A. The documents produced shall be produced at 24 the 31st floor conference room of PG&E, 77 Beale Street, San 25 Francisco, California on Friday, July 15, 1983, at 9:00 a.m.

26 for inspection and/or copying.

8306160579 830610 PDR ADOCK 05000275

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1 B. If any documents called for herein are 2 withheld from production by reason of any assertion of 3 privilege, identify each such document, giving the following 4 information about it:

S 1. its title, if any; 6

2. its nature (e.g., letter, memorandum, 7 chart, computer printout, ledger);

8 3. the date, if any, stated on the 9 document, and the dates on which it was written, 10 signed, and distributed; 11 4. the identity of its author or authors; 12 5. the identity of each person wlio signed 13 it;

- 14 6. the identity of each person to whom it l

15 is addressed; 16 7. the identity of each person known to you 17 or believed by you to have received a copy; 18 8. the identity of the present custodian of 19 every copy known to you or believed by you to exist; 20 9. each and every ground upon which you 21 base your claim of right to withhold the document from l

22 production, including all facts necessary to evaluate 23 the merits of the claim.

24 C. " Documents" include printed material, l 25 writings, handwritten notes, photographs, xerox 26 repoductions, and audio or video recordings. " Writings" and

'e e 1 " recordings" consist of letters, words, or numbers, or their 2 equivalent, set down by handwriting, typewriting, printing, 3 photostating, photographing, magnetic impulse, mechanical or 4 electronic recording, or other form of data compilation, as 5 defined in Rule 1001 of the Federal Rules of Evidence.

6 D. ,

Documents produced shall be segregated 7 according to each specific category of request listed below.

8 E. Documents produced shall be the most legible 9 copy available. Illegible copies may be replaced by the 10 best available copy upon the request of the propounding 11 parties.

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F. As used herein, the singular form of a noun 13 or pronoun shall be considered to include within its meaning 14 the plural form of the noun or pronoun so used, and vice 15 versa; 'similarly, the use of the masculine form of a pronoun 16 shall be considered to- include also within its meaning the 17 feminine form of the pronoun so used, and vice versa; and in 18 a similar fashion any tense of any verb used herein shall be 19 considered also to include within its meaning all other 1

20 tenses of the verb so used.

21 G. All documents are to be produced which are, 22 or have been, in your possession as of the date of receipt 23 of this request through and including July 10, 1983.

24 H. "You" or "your" means the individual, 25 association, or corporate party, their attorneys, l

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= 1

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1 consultants, investigators, agents, employees or other

2 representatives of the named party and their attorneys.

3 I. "NRC" includes the Nuclear Regulatory 4 Commission and the Nuclear Regulatory Commission staff.

5 DOCUMENTS REQUESTED 6 REQUEST # 1. All writings you have taken at all meetings 7 between the NRC and/or PG&E and/or companies involved in the 8 Independent Design Verification Program (IDVP) from 9 October 1, 1981 to the present.

10 REQUEST # 2. All documents relating to Diablo Canyon design 11 or design quality assurance prepared by PGandE, the IDVP, or 12 the NRC, having comments, notes, or the like on them and any 13 Uritings prepared by or for you discussing, commenting on or 14 otherwise referring to those documents.

15 REQUEST # 3. All other documents relating to Diablo Canyon 16 design or design quality assurance not produced in response 17 to request # 2 which have been prepared or reviewed by or 18 for you.

19 REQUEST # 4. All documents that contain calculations, 20 analyses or computer programs performed by or for you l

21 regarding the design of Diablo Canyon structures, systems or t

22 components.

23 REQUEST # 5. All correspondence between you and the NRC or l

24 its contractors related in any way to design or design i

25 quality assurance at Diablo Canyon.

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l l l l . . _ - - .- --. . . _ - .---- . .

1 REQUEST # 6. All correspondence or records of meetings or 2 telephone conversations between Mr. Hubbard (or his 3 associates) and Dr. Rosette (or his associates) related in

, 4 any way to design of structures, systems, or components at 5 Diablo Canyon.

6 REQUEST # 7. All notes, calculations, meeting minutes, 7 computer outputs, drawings or other writings prepared by MHB 8 Technical Associates or Dr. Rosette or any other of your 9 technical consultants related in.any way to design or design 10 quality assurance at Diablo Canyon.

11 REQUEST # 8. All quality assurance manuals and procedures 12 (including quality control procedures) governing the work of 13 MHB Technical Associates since January 1, 1977, including 14 all amendments or revisions thereto.

15 REQUEST # 9. Copies of all documentation showing adherence 16 to MHB Technical Associates' quality assurance / quality 17 control procedures for MHB Technical Associates' work 18 relating to Diablo Canyon.

19 REQUEST # 10. All quality assurance manuals and procedures 20 (including quality control procedures) governing the work of 21 Dr. Rosette since January 1, 1982, including all amendments 22 or revisions thereto.

23 REQUEST # 11. Copies of all documentation showing adherence l 24 by Dr. Rosette to quality assurance / quality control 25 procedures for Dr. Rosette's work relating to Diablo Canyon.

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O 1 REQUEST # 12. All documents identified in your answers to 2 PG&E's first set of interrogatories served the same date as 3 this request.

4 REQUEST # 13. All exhibits you intend to mark for 5 identification at_the hearing of this matter.

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7 Respectfully submitted, 8 ROBERT OHLBACH PHILIP A. CRANE, JR.

9 RICHARD F. LOCKE Pacific Gas and Electric Company 10 P.O. Box 7442 San Francisco, California 94120 11 (415) 781-4211 12 ARTHUR C. GEHR

, Snell & Wilmer 13 3100 Valley Center Phoenix, Arizona 85073 14 (602) 257-7288 15 BRUCE NORTON Norton, Burke, Berry & French, P.C.

16 P.O. Box 10569 Phoen'x, Arizona 85064 17 (602) 955-2446 18 Attorneys for Pacific Gas and Electric Company 19 20 21 By Q Bruce Norton 23 DATED: June 10, 1983.

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