ML20076H503
| ML20076H503 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/10/1983 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| Shared Package | |
| ML20076H466 | List: |
| References | |
| NUDOCS 8306160595 | |
| Download: ML20076H503 (19) | |
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1 UNITED STATES OF AMERICAU 2 NUCLEAR REGULATORY COMMISSION 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 JOINT INTERVENORS 16 ,
17 18 Pursuant to 10 C.F.R. 9 2.740b, Licensee PACIFIC 19 GAS AND ELECTRIC COMPANY hereby propounds the following 20 Interrogatories to the JOINT INTERVENORS.
21 INSTRUCTIONS 22 1. All informatioN 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 26 Party.
8306160595 830610 PDR ADOCK 05000275 C PDR
1 2. Where you have incomplete information that
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2 precludes your fully answering an interrogatory, 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 r
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 about him or her:
i 11 (a) full name; 12 (b) present job title, employer, - and 13 telephone number.
1 - 14 4. When asked in the interrogatories below to 15 identify or to give the identity of a document or writing, i
16 please give the following information about the document:
i 17 (a) its-title, if any; 1
f 18 (b) its nature (e.g., letter, memorandum, l 19 chart, computer printout, ledger);
20 (c) the date, if any, stated on the i
! 21 document;
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22 (d) the identity of each person who signed i
23 it; 24 (e) the identity of each person to whom it 25 is addressed; 26 ///
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1 5. Where an individual Interrogatory calls for 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 a 'nswer, 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. "You" or "your" means jointly and severally 12 each of the Joint Intervenors or any attorney, consultant, 13 invest'igator, agent, employee or other representative of the 14 collective or individual Joint Intervenors.
15 8. " Documents" include printed material, writ-16 ings, handwritten notes, photographs, xerox repoductions, 17 and audio or video recordings. " Writings" and " recordings" 18 consist of letters, words, or numbers, or their equivalent, 19 set down by handwriting, typewriting, printing, 20 photostating, photographing, magnetic impulse, mechanical or 21 electronic recording, or other form of data compilation, as 22 defined in Rule 1001 of the F5deral Rules of Evidence, 28 23 U.S.C.
24 INTERROGATORIES 25 1. As to each person employed by PG&E, Bechtel, 26 the PG&E/Bechtel " Project", or any of those entities' 1 subcontractors working on Diablo Canyon that you have had 2 communication with since November 21, 1981, regarding Diablo 3 Canyon, state:
4 (a) The name of each employee or representa-5 tive with whom you have communicated. (This interrogatory 6 is not intended to cover any administrative communications 7 regarding announced meetings between -the NRC Staff and/or 8 the IDVP and/or PG&E).
9 (b) The name of each person involved on your 10 behalf in each communication.
11 (c) The date of each such communication.
12 (d) How the communication was made, i.e.,
13 whether by telephone, written instrument, personal meeting, 14 or otherwise.
15 (e) Who initiated each such communication.
16 (f) The, substance of information exchanged 17 during each such communication.
18 2. Identify each and every person you intend to 19 call as a witness during these proceedings.
As to each such 20 witness, state:
21 (a) Name, occupation, occupational address
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i 22 and telephone number.
- 23 (b) Whether the witness will render expert l
24 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 document 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 l 18 identified in your answer to 2(c), identify by docket number 19 and case name each Nuclear Regulatory Commission licensing l
20 proceeding where the witness has previously given expert 21 testimony concerning each specific subject matter.
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.
l l 26 ///
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.
7 (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 expert 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 13 testimony given.
14 (iii) Whether you have a copy of the 15 transcript covering any or all of the l 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' l 21 testimony and/or examination and/or 22 cross-examination in each such proceeding.
23 3. Identify all examinations, reviews, studies, i analyses, or the like, conducted, initiated, or anticipated 24 25 to be conducted by or for you since September 1981 relating i
l in whole or part to design quality assurance or design 26
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 that 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".
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 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 required 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:
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, l 21 requires each such component to be classified as
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22 "important-to-safety".
23 (c) The date upon which each such regulation
. 24 required each such component to be so classified.
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4 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 (systiems) 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..
13 (b) The name of the company or entity who 14 used or is using the program.
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 presest~ 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 26 for. As to each such quality assurance program, state:
1 1
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, a 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 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.
l l 21 (d) Whether you were responsible for 22 executing all or portions of the 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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- j. 1 (f) The present location of all audits 3
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 2
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 pr.ocedures and, if 13 portio'ns, 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).
7 l 18 13. Mr. Hubbard, in his affidavits and/or his 19 declaration uses the following terms:
20 (a) " safety-significance" l
(b) " errors" 21 (c) " deficiencies" (d) " safety implications" 22 (e) " design QA" (f) " safety hazard" t 23 (g) " quality control"
, (h) " root cause" t
24 (i) " basic cause" (j) "QA breakdown" 25 (k) " extreme likelihood" (1) " major' errors" 26 (m) " rigorous and thorough design j verification program" l
I I
1 (n) " design product" (o) " minor QA breakdown" 2 (p) "QA finding" (q) "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".
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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 18 between a "QA breakdown" and a "QA finding".
i 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
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22 have reviewed to date. As to each ITR, state specifically:
23 (a) Each fact stated Enerein with which you 24 disagree.
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) ofeachIhRwhere 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 each such fact, conclusion or opinion.
8 15. With respect to the PG&E Phase I Final
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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 fact (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 i 18 15(c) is located. '
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19 (e) The specific base's for your disagreement l
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 1
l 25 for Diablo Canyon.
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1 1 (c) How such direct personal knowledge was il 2 acquired.
Pl[d ,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.
s 9 (b) Identify what access Mr. Hubbard had to
/ 10 the Commission's decision-making process.
l 11 (c) Identify specifically each and every 12 document or communication you relied on that describes the t .
f t
' 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 i
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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- ,
1 l
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I 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?
6 Explain the bases for your answer to this 7 interrogatory; 8 21. In paragraph 12 of the Hubbard affidavit 9 identified in Interrogatory No. 18, the term " basis for 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 identi'fied 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
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 caused 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 l
s a
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 i 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).
7 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 Phoenix, Arizona 85064 18 (602) 955-2446 19 Attorneys for Pacific Gas and Electric Company 20
- 21 l
l 22 By _W Bruce Norton 23 .
24 DATED: June 10, 1983.
25 l
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J L fj J .=
. UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION
- TJ.ElED In the Matter of ) JF ~
) i PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275 I
) Docket No. 5053233;14 kn:0g Diablo Canyon Nuclear Power Plant,-)
Units 1 and 2 )
)
CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company hno (have) been served today on the following by deposit in the United States mail, properly stamped and addressed:
Judge John F. Wolf Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety and' Licensing Board San Luis Obispo CA 93401 US Nuclear Regulatory Commission Washington DC 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission
- John Phillips, Esq.
Wochington DC 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest Judge Jerry R. Kline 10951 W. ~P ico Blvd. ' Suite 300 Atomic Safety and Licensing Board Los Angeles CA 90064 US Nuclear Regulatory Commission Washington DC 20555 David F. Fleischaker, Esq.
P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer
< 1493 Southwood Arthur C. Gehr, Esq.
San Luis Obispo CA 93401 -
Snell & Wilmer 3100 Valley Bank Center Janice E. Kerr, Esq. Phoenix AZ 85073 Public Utilities Commission State of California Philip A. Crane, Jr., Esq.
l 5246 State Building Pacific Gas and Electric Company 350 McAllister Street -
P. O. Box 7442 Scn Francisco CA 94102 San Francisco CA 94120 Mrs. Raye Fleming Chairman 1920 Mattie Road Atomic Safety and Licensing Shell Beach CA 93449 Board Panel US Nuclear Regulatory Commission Mr. Frederick Eissler Washington DC 20555 Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara CA 93105
- This copy sent by EXPRESS MAIL.
Chnirman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Weahington DC 20555 US Nuclear Regulatory Commission Washington DC 20555 Sncretary US Nuclear Regulatory Commission Judge W. Reed Johnson Wnchington DC 20555 Atomic Safety and Licensing Appeal Board Attn: Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555 Lawrence J. Chandler, Esq. Judge John H. Buck Jack R. Goldberg, Esq. Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission Wnshington DC 20555 Washington DC 20555 Mr. Richard B. Hubbard
- Michael J. Strumwasser MHB Technical Associates Susan L. Durbin 1723 Hamilton Avenue, Suite K Peter H. Kaufman San Jose CA 95125 3580 Wilshire Blvd. Suite 800 Los Angeles CA 90010 Mr. Carl Neibergsr Talegram Tribune P. O. Box 112 San Luis Obispo CA 93402 s -
Dnte: June 10, 1983 "1MJLE Bruce Norton Attorney for Pacific Gas and Electric Company ,
- This copy sent by EXPRESS MAIL.