ML20076H478

First Set of Interrogatories.Related Correspondence

ML20076H478
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
Shared Package
ML20076H466	List: ML20076H464 ML20076H478 ML20076H503
References
NUDOCS 8306160584
Download: ML20076H478 (17)

Text

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- gni,nED C01mmesDEF,E I.~f.Sc 1 UNITED STATES OF AMERICA 'g J,"i M IU '-

2 ' NUCLEAR REGULATORY COMMIS'SION 3

4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5

6 7

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 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES 15 TO GOVERNOR DEUKMEJIAN 16 .

17 18 Pursuant to 10 C.F.R. $ 2.740b, Licensee PACIFIC 19 GAS AND ELECTRIC COMPANY hereby propounds the following 20 Interrogatories to GOVERNOR DEUKMEJIAN.

21 INSTRUCTIONS 22 1. All informatio is to be divulged which is in 23 the possession of the individual, association, or corporate 24 party, their attorneys, consultants, investigators, agents, 25 employees, witnesses or other representatives of the named 3

26 party.

8306160584 830610 P PDR ADOCK 05000275 G PDR

1 2. Where you have incomplete info'rmation that 2 precludes your fully answering an inter' rogatory, give such 3 information as you have and state what information you do 4 not have. If you are unable to give the information in the 5 form sought but have the information aggregated differently, 6 give the information in the form in which you have it and 7 explain the reason for the deviation.

8 3. When asked in the interrogatories below to 9 identify or to give the identity of a person, please give 10 the following information cbout him or her:

11 (a) full name; 12 (b) present job title, employer,- and 13 telephone number.

. 14 4. When asked in the interrogatories below to 15 identify or to give the identity of a document or writing, 16 please give the following information about the document:

l 17 (a) its title, if any; 1

l 18 (b) its nature (e.g., letter, memorandum, 19 chart, computer printout, ledger);

l 20 (c) the date, if any, stated on the 1

21 document; 22 (d) the ident$ity of each person who signed 23 it; i 24 (e) the identity of each person to whom it 25 is addressed; 1

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1 5. Where an individual Interrogatory calls for i

2 an answer which involves more than one part, each part of 3 the - answer should be clearly set out so that it is 4 understandable. ,

5 6. These Interrogatories are intended as 6 continuing Interrogatories, requiring you to ' answer by 7 supplemental answer, setting forth any information within 8 the scope of the Interrogatories as may be acquired by you, 9 your agents, attorneys or representatives following your 10 original answers up to the time of hearing.

11 7. " Documents" include printed material, writ-12 ings, handwritten notes, photographs, xerox repoductions, 13 and audio or video recordings. " Writings" and " recordings" 14 consist of letters, words, or numbers, or their equivalent, 15 set down by handwriting, typewriting, printing, 16 photostating, photographing, magnetic impulse, mechanical or 17 electronic recording, or other form of data compilation, as 18 defined in Rule 100.1 of the Federal Rules of Evidence, 28 '

19 U.S.C. - i 20 INTERROGATORIES (

21 1. As to each person employed by PG&E, Bechtel, 22 the PG&E/Bechtel " Project", or any of those entities' 23 subcontractors working on Diablo Canyon that you have had 24 communication with since November 21, 1981, regarding Diablo 25 Canyon, state:

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• 1 (a) The name of each employee or representa-

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2 tive with whom you have communicated. -(This interrogatory l 3 is not intended to cover any administrative communications j t

4 regarding announced meetings between the NRC Staff and/or 5 the IDVP and/or PG&E).

6 (b) The.name of each person involved on your

, 7 behalf in eacl$ communication.

s (c) The date of each such communication.

9 (d) How the communication was made, i.e.,

l 10 whether by telephone, written instrument, personal meeting, 11 or otherwise. I 12 (e) Who initiated each such communication.

i 13 (f) The substance of information exchanged l

14 during each such communication.

15 2. Identify each and every person you intend to 16 call as a witness during these proceedings. As to each such 17 witness, state:

18 (a) Name, occupation, occupational address 19 and telephone number.

20 (b) Whether the witness will render expert 21 testimony.

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1 (c) If the witness will render expert 2 testimony, please list each specific subject matter about 3 which the witness will be expected to testify.

4 (d) If the witness will be called to give 5 expert testimony, please list the specific qualifications of 6 the witness that you contend would qualify the witness to 7 give opinion testimony on each specific subject matter about 8 which the witness will testify.

9 (e) List each and every professional 10 article, book, or the like, if any, the witness has authored 11 or co-authored concerning each specific subject matter set 12 forth in your answer to 2(c).

13 (f) Identify each and every dccument the 14 witness will rely on to reach any opinion testimony and 15 corollate each such document to each specific subject matter 16 on which the witness will render an opinion.

17 (g) As to each specific subject matter 18 identified in your answer to 2(c), identify by docket number 19 and case name each Nuclear Regulatory Commission licensing 20 proceeding where the witness has previously given expert 21 testimony concerning each specific subject matter.

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22 (h) As to each proceeding identified in your 23 answer to 2(g), please state:

24 (i) The date(s) the expert testimony 25 was given.

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i t-l 1 (ii) Whether you have a copy of the 2 testimony given.

3 (iii) Whether you have a copy of the 4 transcript covering any or all of the 5 witness' examination and/or cross-examination 6 for each such proceeding.

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(iv) Whether you have a copy of the 8 notes which the witness made in preparation 9 for, or utilized during, the witness' 10 examination or cross-examination in each such 11 proceeding.

12 (i) As to each specific subject matter 13 identified in your answer to 2(c), identify by docket number 14 and court name each legal proceeding where the witness has 15 previously given expert testimony concerning each specific 16 subject matter.

17 (j) As to each proceeding identified in your 18 answer to 2(i), please state:

19 (i) The date(s) the exper' testimony 20 was given.

21 (ii) Whether you have a copy of the 22 transcript covering any or all of the 23 witness' examination and/or cross-examination 24 for each such proceeding.

25 (iii) Whether you have a copy of the 26 notes which the witness made in preparation

1 for, or utilized during, the witness' 2 examination or cross-examination in each such 3 ,

proceeding.

4 (k) As to each specific subject matter 5 ' identified in your answer to 2(c), identify committees and 6 organizations where the witness has previously given 7 testimony concerning each specific subject matter.

8 (1) As to each committee or organization 9 identified in 2(k), please state:

10 (i) The date(s) the testimony was 11 given.

12 (ii) Whether you have a copy of the 4

13 testimony given.

14 (iii) Whether you have a copy of the 15 transcript covering any or all of the 16 witness', examination and/or cross-examination 17 for each such proceeding.

18 (iv) Whether you have a copy of the 19 notes which the witness made in preparation 20 for, or utilized during, the witness' 21 testimony and/or examination and/or 22 cross-examinati$n in each such proceeding.

23 3. Identify all examinations, reviews, studies, 24 analyses, or the like, conducted, initiated, or anticipated 25 to be conducted by or for you since September 1981 relating 26 in whole or part to design quality assurance or design

1 activities at Diablo Canyon. As to each such study, 2 analysis, or the like, state:

3 (a) The date of preparation or anticipated 4 preparation.

5 (b) The name of each and every person who 6 has or will contribute to the effort.

7 (c) The ' contribution of each person 8 identified in your answer to 3(b).

9 4. As to the terms "important-to-safety" and 10 " safety-related", please:

11 (a) Give your definition for each term for 12 the following periods:

13 (i) January 1, 1968 to November 20, 14 1981.

15 (ii) November 21, 1981 to the present.

16 (b) State the bases for each definition 17 given in your answers to 4(a)(i) and 4(a)(ii).

18 5. Identify each and every structure at Diablo 19 Canyon c. hat you believe to be "important-to-safety", but 20 which is not classified as design Class I. As to each such 21 structure identified, state:

22 (a) The bases ~ for your opinion that the 23 structure should be considered "important-to-safety".

24 (b) Each regulation which, in your opinion, 25 requires each such structure to be classified as 26 "important-to-safety".

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1 (c) The date upon which each such regulation 2 required each such structure to be so classified.

3 6. Identify specifically each and every system 4 at Diablo Canyon that you believe to be 5 "important-to-safety", but which is not classified as design 6 ' Class I. As to each such system identified, state:

7 ' (a) The bases for your opinion that each

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8 _such system should be considered "important-to-safety".

9 (b) Each regulation which, in your opinion, 10 requires each such system to be classified as 11 "important-to-safety".

12 (c) The date upon which each such regulation 13 requir'ed each such system to be so classified.

14 7. Identify specifically each and every

'15 component at Diablo Canyon that you believe to be 16 "important-to-safety", but which is not classified as design 17 Class I. As to each such component identified, state:

l 18 (a) The bases for your opinion that each 19 such component should be considered "important-to-safety".

20 (b) Each regulation which, in your opinion, 4 21 requires each such component to be classified as 22 "important-to-safety".

i 23 (c) The date upon which each such regulation i 24 required each such component to be so classified.

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1 8. Identify the person (s) upon whom you rely for 2 the answers given to 5, 6 and 7 above and for each such 3 person (s), state:

4 (a) The person's name.

5 (b) The specific experience and qualifica-6 tions of the person which qualify the person to make the 7 analyses necessary to answer interrogatories 5 (structures),

8 6 (systems) and 7 (components).

9 9. Identify each and every design quality assur-10 ance/ control program you have written or been responsible 11 for. As to each such quality assurance program, state:

12 (a) The date of initial preparation.

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(b) The name of the company or entity who 14 used or is using the program.

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15 (c) Whether you wrote all or portions of the 16 program and, if portions, which portions.

17 (d) Whether you were responsible for execut-18 ing all or portions of the program and, if portions, which 19 portions.

20 (e) Whether the program was ever audited, 21 and, if so, when and by whom.

22 (f) The present. location of all audits 23 identified in your answer to 9(e).

24 10. Identify each and every other quality assur-25 ance/ control program you have written or been responsible l

26 for. As to each such quality assurance program, state:

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1 (a) The date of initial preparation.

2 (b) The name of the company or entity who

.3 used or is using the program.

4 (c) Whether you wrote all or portions of the 5 program and, if portions, which portions.

6 (d) Whether you were responsible for exe-7 cuting all or portions of the program and, if portions, ,

8 which portions.

9 (e) Whether the program was ever audited, 10 and, if so, when and by whom. -

11 (f) The present location of all audits 12 identified in your answer to 10(e). .

13 11. Identify each and every design quality 4

14 assurance / quality control procedure you have written or been 15 responsible for. As to each such procedure, state:

16 (a) The,date of initial preparation.

17 (b) The name of the company or entity who 18 used or is using the procedure.

19 (c) Whether you wrote all or portions of the 20 procedure and, if portions, which portions.

21 (d) Whether you were responsible for 22 executing all or portions of Ihe procedure and, if portions, 23 which portions.

24 (e) Whether the procedure was ever audited, 25 and, if so, when and by whom.

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1 (f) The present location of all audits 2 identified-in your response to 11(e).

3 12. Identify each and every other quality assur-4 ance procedure / quality control procedure you have written or 5 been responsible for. As to each such procedure, state:

6 (a) The date of initial preparation.

7 - (b) The name of the company or entity who 8 used or is using the procedure.

9 (c) Whether you wrote all or portions of the 10 procedure and, if portions, which portions.

11 (d) Whether you were responsible for 12 executing all or portions of the procedures and, if 13 portions, which portions.

14 (e) Whether the procedure was ever audited, 15 and, if so, when and by whom.

16 (f) The present location of all audits 17 identified in your response to 12(e).

18 13. Mr. Hubbard, in his affidavits and/or his 19 declaration uses the following terms:

20 (a) " safety-significance" (b) " errors" 21 (c) " deficiencies" (d) " safety implications" 22 (e) " design QA8' (f) " safety hazard" i 23 (g) " quality control" l (h) " root cause" 24 (i) " basic cause" l (j) "QA breakdown" 25 (k) " extreme likelihood" (1) " major errors" 26 (m) " rigorous and thorough design verification program" l

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1 (n) " design product" (o) " minor QA breakdown" 2 (p) "QA finding"

( ;) "QA observation" 3

4 As to each term, please:

5 (a) Give your definition of the term.

6 (b) Identify the regulation or other source 7 upon which you base your definition.

8 (c) Give your explanation of the difference 9 between " safety-significance" and the terms 10 "important-to-safety" and " safety-related".

11 (d) Give your explanation of the difference 12 between " major errors" and " errors". -

13 (e) Give your explanation of the difference 14 between " deficiencies" and " errors".

15 (f) Give your explanation of the difference 16 between a "QA breakdown',' and a " major QA breakdown".

17 (g) Give your explanation of the difference l 18 between a "QA breakdown" and a "QA finding".

19 (h) Give,your explanation of the difference 20 between a "QA breakdown" and a "QA observation".

21 14. List each ITR, with revision number, that you l 22 have reviewed to date. As to each ITR, state specifically:

l 23 (a) Each fact stated therein with which you l

24 disagree.

l l 25 (b) The specific page(s) of each ITR where

! 26 the fact (s) set forth in your answer to 14(a) is located.

1 (c) Each conclusion or opinion stated 2 therein with which you disagree.

3 (d) The specific page(s) of each ITR where 4 the conclusion (s) or' opinion (s) set forth in your answer to 5 14(c) is located.

6 (e) The specific . bases for your disagreement 7 with eaich such fact, conclusion or opinion.

8 15. With respect to the PG&E Phase I Final 9 Report, identify:

10 (a) Each fact stated therein with which you 11 disagree.

12 (b) The specific page(s) of the Report where 13 the fa'ct(s) set forth in your answer to 15(a) is located.

14 (c) Each conclusion or opinion stated 15 therein with which you disagree.

16 (d) The specific page(s) of the Report where 17 the conclusion (s) or opinion (s) set forth in your answer to 18 15(c) is located.

4 19 (e) The specific bases for your disagreement 20 with each such fact, conclusion or opinion.

! 21 16. State specifically all direct personal 22 knowledge that you have regarding:

23 (a) The design of Diablo Canyon.

24 (b) The design quality assurance programs 25 for Diablo Canyon.

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1 (c) How such direct personal knowledge was 2 acquired.

3 17. Mr. Hubbard has alleged in an affidavit that 4 Diablo Canyon design errors " reflected significant QA 5 breakdowns", and that "those breakdowns led the Commission 6 to suspend the low power license".

7 (a) Explain how Mr. Hubbard arrived at this 8 conclusion.

9 (b) Identify what access Mr. Hubbard had to 10 the Commission's decision-making process.

11 (c) Identify specifically each and every 12 document or communication you relied on that describes the 13 reason the Commission reached its decision to suspend the 14 low power license.

15 18. In paragraph 9 of the Hubbard affidavit 16 attached to Joint Intervenors' Motion to Reopen of June 7, '

17 1982, Mr. Hubbard lists categories of items that he 18 reviewed. Identify specifically:

19 (a) The industry QA/QC standards prior to 20 1970 that Mr. Hubbard reviewed.

21 (b) The " regulatory developments" examined.

22 (c) All documents examined by Mr. Hubbard in 23 his examination of the NRC's implementation of QA/QC 24 regulations.

25 19. Identify specifically any and all PG&E, NRC, 26 and/or ACRS documents that you allege stand for the propo-

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4 1 sition that PG&E and/or the NRC and/or the ACRS relied upon 2 superior QA/QC at Diablo Canyon to compensate for reduced

3 conservatism.

4 20. Do you admit that superior QA/QC at Diablo

5 Canyon would compensate for reduced conservatism?

i 6 Explain the bases for your answer to this 7 interrogatoiy.'

8 21. In paragraph 12 of the Hubbard affidavit

, 9 identified in ' Interrogatory No. 18, the term " basis for

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10 confidence" is used. -Define the term and explain, in 11 context, what constitutes a " basis for confidence".

12 22. In paragraph 13 of the Hubbard affidavit 13 identified in Interrogatory No. 18, Mr. Hubbard alleges a 14 number of " errors and discrepancies" at Diablo Canyon and 15 states that they involved a failure by PG&E to properly 16 implement the QA requirements of Appendix B. ,

Identify each 17 such alleged error and discrepancy. As to each alleged 18 error and discrepancy:

i 19 (a) State specifically the significance of 20 each alleged error or discrepancy.

, 21 (b) State specifically how each alleged 22 ' error or discrepancy was cause'd'by PG&E's alleged failure to 23 properly implement the QA requirements of Appendix B.

24 23. Identify specifically each document upon 25 which you rely as support for your contentions or positions 26 as . stated in your answers to these interrogatories. As to i

1 each such document, identify the precise portion relied upon 2 as to each such contention or position.

3 24. For each answer to these interrogatories, and 4 all subparts thereto, identify each person who participated 5 in the preparation of your answers pursuant to 10 C.F.R. 6 5 2.740b(b).

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8 Respectfully submitted, 9 ROBERT OHLBACH PHILIP A. CRANE, JR.

10 RICHARD F. LOCKE Pacific Gas and Electric Company 11 P.O. Box 7442 San Francisco, California 94120 12 (415) 781-4211 13 ARTHUR C. GEHR Snell & Wilmer 14 3100 Valley Center Phoenix, Arizona 85073 15 (602) 257-7288 16 BRUCE NORTON

- Norton, Burke, Berry & French, P.C.

17 P.O. Box 10569 i

Phoenix, Arizona 85064 18 (602) 955-2446

! 19 Attorneys for

. Pacific Gas and Electric Company 20 21 ,

22 By -

we Bruce' No'rton 23 24 DATED: June 10, 1983.

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