ML20076H651
| ML20076H651 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/31/1983 |
| From: | Durbin S CALIFORNIA, STATE OF |
| To: | PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML20076H654 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309060106 | |
| Download: ML20076H651 (92) | |
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UN5TED STATES OF AMERICA DOCKETED ,
USNRC NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL B@SID8ED -2 A10:29 0FFICE OF SECRtiM,
) 00CKETING & SERVla In the Matter of .
) 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) )
)
ANSWERS OF GOVERNOR DEUKMEJIAN TO APPLICANT'S SECOND SET OF INTERROGATORIES Governor George Deukmejian hereby responds to the second set of interrogatories propounded to him by applicant Pacific Gas and Electric Company. The answers provided herein are current as of the date of this filing and will be supplemen ted as provided by 10 C.F.R. S 2.740(e).
INTERRC"ATORY NO. 1:
1, tate each and every f act upon which you base your contention that the licensee has failed to timely develop and implemen t a systematic quality assurance / quality control l program for the design of safety related structures, sys tems and componen ts for design wor k at Diablo Canyon Units 1 and 2 since November 1, 1981.
ANSWER TO INTERROGATORY NO. 1:
The Governor's review of the development and implemen tation of a systematic quality assurance / quality i
- control proqram for the design, since November 1, 1981, of Diablo Canyon safety-related structures, systems and componen ts 1*
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f 8 .I (SSC's) is not yet complete. Further,'the IDVP review of the
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post November 1,1981 design activities is not yet complete, nor have all EOI's addressing design matters concerning this time period been resolved by the IDVP and the resolution documented in an appropriate ITR. Furthermore, the IDVP in general has not specifically set forth either its conclusions regarding whether the identified errors were caused by the applican t (PG&E) or its major subcontractor s or its identification of the deficiency in the QA/QC process which allowed the iden tified errors to occur and to remain undetected prior to the IDVP review (see Answer to Interrogatory No. 2).
The Governor's review to date of the FSAR, the IDVP Report, the ITP Report, the SER S upplement #18, and the QA policies, procedures and instructions set forth in the PG&E/Bechtel Diablo Canyon Project QA Manual and the PG&E Engineering Department Procedures Manual has disclosed the examples as tabulated in Table 1 herein which indicate that the applicant has f ailed to timely develop and implemen t a systematic quality assurance / quality control program for the design modifications to SS&Cs which have occurred since November 1, 1981. The Governor's review of PG&E's design QA commitments provided in chapter 17 of the FSAR, including PG&E's proposals of June 10 and August 8,1983 to the NRC to replace the FSAR chapter in its entirety, have also not yet been completed. The answer does not specify pages and paragraphs of referenced documents since that information is as readily available to PG&E as it is to the Governor.
2.
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0 J TABLE 1 Deficiencies in OA Program Development & Implemen tation (Design Modifications Since November 1,1981)
Description Appendix B of Deficiency Criteria
- Refe rence
- 1. Lind tations of Appendix B All FSAR, S 17.0 commitment to "the extent possible" considering the status of design.
- 2. Limitations of Appendix B All Transcript commitment to "as of the ASLAB practicable" as elicited Hearing on before ASLAB during July Construction 198 3 Hearing. Quality Assu rance, pp. 465-466.
- 3. Exclusion of Unit 1 at All QA Pr og ram Diablo Canyon as Described Author ization in the QA Program PG&E QA Manual Author ization of PG&E's for Design and '
QA Manual for the Design Constr uction and Construction of of Nuclear Nuclear Power Plants. Power
- 4. BNL discovered discrepan- 2, 3, 16, 18 SER, Supp. 18, cies in the design SS 3.6.2, reanalyses and its design 3.6.3 and verification regarding the 3.6.4 response of the annulus structure and the evaluation of two piping systems.
- 5. BNL discovered discrepan- 4, 7, 18 SER, S upp. 18, cies in the design verification SS 3.6.5 and of piping by Westinghouse and 3.6.6.
Luried diesel tanks by Harding and Lawson.
- The designation of Appendix B criteria relevant to the identified deficiencies is intended to highlight the major criteria violated and, as such, is not intended to be an exhaustive list. The preceding limitation is necessary also because of the high degree of interrelationship between a number of the criteria of Appendix B.
3.
e _p TABLE 1 Deficiencies in OA Program Development & Implemen tation (Design Modifications Since November 1,1981)
Description Appendix B of Deficiency Criteria Refe rence
- 6. The IDVP design control 1,2,3,4,5 ITR 4 audit disclosed 24 6, 7, 16, 17- (Appendix E deficiencies in the and 18 particularly)
IXP quality assurance program developmen t and implementation including incomplete records documentation, lack of procedures, procedures not being followed, inadequate training, failure to implement commitmen ts in a timely manner, inadequate docu-men t control, deviations in design control activities, and failure to control pro-curement activities.
Procedure 3.1 regarding Department classification of SS&Cs P rocedures (the Q-list) is deficient 3.1, in that classification Rev. 1, 2 & 3 responsibility is not un- dated 3/1/82, ambiguously assigned, the 4/5/82, and applicable revisions to 6/30/82.
references including Regulatory Guides is not provided, and no regular time interval for distribution of the Q-list is specified.
- 8. Differences were disclosed 3, 6, 10, 16 EOI 1123 between "as-built" and "as-analyzed" instrument tubing support.
4.
TABLE 1 Deficiencies in OA Program Development & Implementation (Design Modifications Since November 1, 1981)
Description Appendix B of Deficiency Criteria Refe rence
- 9. The design analysis 3, 6, 10, 16 EOI 1124 finite element model of the control room slab used to generate Hosgri spectra does not agree with the field verified location of the supporting wall.
- 10. Revision 1 of the HVAC 3, 6, 16 EOI 1125 compressor seismic calculaton used incorrect and unconservative spectra.
- 12. Deficiencies in ITP 3, 6, 10, 16 EOI 1128 reanalyses of station battery racks regarding bolt diameter and re-solved shear force.
- 14. Reanalyses of large bore 3, 6, 16 EOI 1131 pipe supports not evaluated as required by the DCP pr oce du re.
- 15. Failure to perform an 3, 6, 16 EOI 1132 evaluation of auxillary building slabs for in-plane loadings contrary to the PG&E Final Report dated May 18, 1983.
5.
TABLE 1 Deficiencies in QA Program Development & Implemen ta tion (Design Modifications Since November 1, 1981)
Description Appendix B of Deficiency Criteria Refe rence
- 17. Discrepancies in the 3, 6, 16 EOI 113 4 DCP calculation of first mode frequency for HVAC duc t and duct supports.
- 19. E rr or in the design 3, 6, 16 EOI 1139 analysis calculation of f requency of a small bore pipe support.
- 21. DCP f ailed to iden tify 3, 6, 16 EOI 1141 all high energy lines inside and outside co ntainmen t.
2? Pipe support loads due 3, 6, 16 EOI 1142 to the effects of various loading combina-tions were not considered in the design analysis contrary to the DCP design criteria procedure.
6.
INTERROGATORY NO. 2:
State each and every fact upon which you base your contention that the licensee's major subcontractors at Diablo Canyon Units 1 and 2 have failed to timely develop and implement a systematic quality assurance / quality control program for the design of safety related structures, systems and components for design work at Diablo Canyon Units 1 and 2 since November 1,1981. .
ANSWER TO INTERROGATORY NO. 2:
The Governor 's review of the development and implementation of a systematic quality assurance / quality control program by the applicant's major subcontractor s for the design efforts conducted on SS&Cs since November 1,1981 is not yet complete. Further, as noted in the answer to Interrogatory No. 1 herein, the IDVP in general did not identify who (PG&E or a major subcontractor) was responsible for the error s disclosed in the review of the ITP's corrective action. Furthermore, the IDVP review of the ITP corrective action is not yet complete.
In addition, as prescribed in Criterion 1 of Appendix B, while PG&E may delegate to others, such as major subcontractor s, the work of establishing and executing the quality assurance programs, or any part thereof, PG&E still retains responsibility for the delegated activities since the applicant has ultimate responsibility for the establishment and execution of the quality assurance program.
The Governor's review to date of the IDVP Report, the DCP Report, Supplement #18 of the SER, and the QA/QC policies, 7.
procedures and instructions set forth in the Bechtel Project Engineer's Instruction Manual for the Die.blo Canyon Project, Bechtel Topical Report BQ-TOP-lj Rev. 3A as modified by PG&E's letter of June 18, 198 2, and the Bechtel _ Quality Assurance Department Procedures Manual, while not yet complete, has disclosed the examples tabulated herein in Table 2 which indicate that PG&E's major subcontractors have failed to timely develop and implemen t a systematic quality assurance / quality control program for the design modifications to SS&Cs which have occurred since November 1,1981.
The answer does not specify pages and paragraphs of referenced documents since that information is as readily available to PG&E as to the Governor.
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TABLE 2 Deficiencies in Maior Subcontractors' Oh Program Developmen t & Implemen tation u.-
1 (Design Modifications Since November 1,1981)
Description Appendix B of Deficiency Criteria
- Refe rence
- 1. BNL discovered discrepan- 2, 3, 16, 18 SER, S upp. 18, cies in the design S 3.6.6, reanalyses and design verification of buried diesel tanks conducted by Harding and Lawson including the reanalyses and reverification conducted in 198 2.
- 2. BNL discovered deficiencies 2, 3, 6,18 SER, S upp. 18, and omissions noted in PG&E S 3.6.6 Westinghouse piping models and their design verification
- The designation of Appendix B criteria relevant to the identified deficiencies is intended to highlight the major criteria violated and as such, is not intended to be an exhaustive list. The preceding limitation is also necessary because of the high degree of interrelationship between a number of the criteria of Appendix B.
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TABLE 2 .
Deficiencies in Maior Subcontractors' QA Program Developmen t & Implemen tation (Design Modifications Since November 1,1981)
Description Appendix E of Deficiency Criterij Refe rence
- 3. The internal design 1,2,3,4 Bech tel interf aces and 5, 7, 16, 18 Instr uction responsibilities for No. 5 Unit 1, as documented in Attachmen t A of Bechtel Diablo Canyon Instruction No. 5, were not included in the pro-cedure until Rev. 2 dated March 11, 1983.
- 4. The design interfaces for 1,2,3,4 Bech tel Unit 2 design as required 5, 7, 16, 18 Instruction by Attachment B of Bechtel No. 5.
Diablo Canyon Instruction No. 5, Rev. 2, da ted March 11, 1983 is listed as "Later."
10.
INTERROGATORY NO. 3:
Please list each and every major subcontractor for Dia61o Canyon Units 1 and 2 who has been involved in the design of safety related structures and/or systems and/or components.
(a) For each such major subcontractor state:
' (i) the time period when tne subcontractor did design of safety related structures, systems and components f or Diablo Canyon Units 1 and 2.
(ii) the time period you allege when the subcontractor did not develop and implemen t a systematic quality assurance / quality control program.
ANSWER TO INTERROGATORY NO. 3:
The list of major subcontractor s for Diablo Canyon Units 1 and 2 who had an ef fect on the final design of the non-seismic safety-related structures, systems and componen ts is identified in ITR-9. Similarly, the list of seismic safety related design contractor s is described in ITR-5 and the documents referenced therein. Further, the list and involvement of seismic safety related design contractor s are set forth in the following:
(a) " Preliminary Repor t, Seismic Verification Program," by Robert L. Cloud Associates, dated November 12, 1981.
(b) Phase I Program submitted by PG&E dated December 4, 1981.
(c) Phase II Program submitted by PG&E dated January 13, 1982.
11.
In addition, the list of service-relate'd design subcontractors is described by the IDVP in Section 4.1.4 of its Final Report including a listing of responsible safety related design subcontractor s who were not included in the IDVP verification efforts. The Governor is not aware of any subcontractors other than Bechtel who have participated in the ITP's design modification program since November 1981, who did not participate in the original design of Diablo Canyon. -
(1) The Governor has not yet determined the exact time period when the subcontractor s did design of safety related structures, systems and components f or Diablo Canyon Units 1 and 2. Further, the Governor attempted to obtain this timing information from the IDVP regarding the iden tified EOI's. However, in the Response of the IDVP to Governor Deukmejian's Second Set of Interrogator ies, the IDVP stated in response to Interrogatory No. 39 that "the IDVP generally did not, even when applicable, attempt to determine the exact date of an ' event' giving rise to the EOI." Finally, as set for th at. pages 16 and 17 of the Supplemen tal affidavit of Richard B. Hubbard dated March 26, 1983, the Governor believes that the majority of the original safety related design activities occurred prior to the 1978/79 time period. In addition, the Governor believes that the majority of the design modifications resulting from the IDVP/ITP verification program have occurred since November 1,1981.
12.
(ii) Pursuant to the recent ASLAB's instructions as set forth in answer to ' Interrogatory No. 4 herein, the issue of design QA compliance with the regulations and licensing criteria prior to November 1,1981 is now moot. For the period between November 1981 and the current date, the Governor 's review of PG&E and its major subcontractors QA program and its implementation is still in progress (see answers to Interrogatories Nos. 1 and 2).
INTERROGATORY NO. 4:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 1 of Appendix B to 10 C.F.R. part 50 prior to November 1,1981.
ANSWER TO INTERROGATORY NO. 4:
Based on the ASLAB's August 16, 198 3, or de r, and the Board's further elucidation of its order during the pre-hearing conference on August 23 and 24, it was established that the reopened proceeding would focus on whether the IDVP and the ITP verify the correctness of the Diablo Canyon Unit 1 and 2 design rather than on whether PG&E complied with the commission's design quality assurance regulations in the period prior to November 1, 1981. Thus, the subject area addressed by this interrogatory is now moot.
13.
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INTERROGATORY NO. 5: . .
1 For each and every major fsubcontractor for Diablo Canyon Units 1 and 2, state specidically each and every f act you rely on as a basis for your ' allegation that each such subcontractor's design quality assurance program failed to comply with criterion 2 of Appendix'B to 10 C.F.R. part 50 prior to November 1, 1981.
ANSWER TO INTERROGATORY NO. 5:
See Answer to Interrogatory No. 4.
INTERROGATORY NO. 6:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 3 of Appendix B to 10 C.F.R. part 50 prior to November 1, 1981.
ANSWER TO INTERROGATORY NO. 6:
Sec Answer to Interrogatory No. 4.
INTERROGATORY NO. 7 :
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 4 of Appendix B to 10 C . F . R. part 50 prior to November 1,1981.
ANSWER TO INTERROGATORY NO. 7:
See Answer to Interrogatory No. 4.
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INTERROGATORY NO. 8: ;
1 For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every fact .
you rely on as a basis for your allegation that each such j subcontractor's design quality assurance program failed to comply with criterion 5 of Appendix B to 10 C.F.R. part 50 prior to November 1,1981.
ANSWER TO INTERROGATORY NO. 8: .
See Answer to Interrogatory No. 4.
INTERROGATORY NO. 9 :
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically e ach and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program f ailed to comply with criterion 6 of Appendix B to 10 C.F.R. part 50 prior to November 1, 1981.
ANSWER TO INTERROGATORY NO. 9 :
See Answer to Interrogatory No. 4.
INTERROGATORY NO. 10:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 7 of Appendix B to 10 C.F.R. part 50 prior to November 1, 1981.
ANSWER TO INTERROGATORY NO. 10:
See Answer to Interrogatory No. 4.
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r INTERROGATORY NO. 11:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every fact you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 10 of Appendix B to 10 C.F.R. part 50 prior to November 1, 1981.
ANSWER TO INTERROGATORY NO. 11:
See Answer to Interrogatory No. 4.
D4TERROGATORY NO. 12:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 16 of Appendix B to 10 C.F.R. part 50 prior to November 1,1981.
ANSWER TO INTERROGATORY NO. 12:
See Answer to Interrogatory No. 4.
INTERROGATORY NO. 13:
For cach and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 17 of Appendix B to 10 C.F.R. part 50 l
prior to November 1, 1981. '
ANSWER TO INTERROGATORY NO. 13:
See Answer to Interrogatory No. 4.
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a o INTERROGATORY NO. 14:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that. each such subcontractor's design quality assurance program failed to comply with criterion 18 of Appendix B to 10 C.F.R. part 50 prior to November 1,1981.
ANSWER TO INTERROGATORY NO. 14:
See Answer to Interrogatory No. 4.
INTERROGATORY NO. 15:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every fact you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 1 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 15:
See Answer to Interrogatory No. 2.
D4TERROGATORY NO. 16:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 2 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 16:
See Answer to Interrogatory No. 2.
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INTERROGATORY NO. 17:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act
-you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 3 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 17:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 18:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program f ailed to comply with criterion 4 of Appendix B to 10 C.F,R. part 50 since to November 1, 1981.
ANSWER TO INTERROGATORY NO. 18:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 19:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 5 of Appendix B to 10 C. F . R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 19:
See Answer to Interrogatory No. 2.
18.
INTERROGATORY NO. 20:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 6 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY 110. 20:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 21:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 7 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 21:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 22:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 10 of Appendix B to 10 C . F . R. part 50 since to November 1, 1981.
ANSWER TO INTERROGATORY NO. 22:
See Answer to Interrogatory No. 2.
19.
INTERROGATORY NO. 2 3 :
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 16 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 23:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 24:
For each and every major subcontractor for Diablo Canyon Units 1 and 2, state specifically each and every f act ,
you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 17 of Appendix B to 10 C.F.R. part 50 since to November 1, 1981.
ANSWER TO INTERROGATORY NO. 24:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 25:
For each and every major subcontractor for Diablo l
Canyon Units 1 and 2, state specifically each and every f act you rely on as a basis for your allegation that each such subcontractor's design quality assurance program failed to comply with criterion 17 of Appendix B to 10 C.F.R. part 50 since to November 1,1981.
ANSWER TO INTERROGATORY NO. 25:
See Answer to Interrogatory No. 2.
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INTERROGATORY NO. 26:
State 'specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 f ailed to comply with criterion 1 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 26:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 27:
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 failed to ,
comply with criterion 2 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 27:
See Answer to Interrogatory No. 1.
INTERROGATORY NO. 28:
State specifically each and every f act you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 failed to comply with criterion 3 of Appendix B to 10 C.F.R. part 50 since November 1,1931.
ANSWER TO INTERROGATORY NO. 28:
See Answer to Interrogatory No. 1.
INTERROGATORY NO. 29:
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality 21.
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assurance program for Diablo Canyon Units 1 and 2 failed to comply with criterion 4 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 29:
See Answer to Interrogatory No. 1.
INTERROGATORY NO. 30:
State specifically each and every f act you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 failed to comply with criterion 5 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 30:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 31:
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 f ailed to comply with criterion 6 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 31:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 32:
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 failed to comply with criterion 7 of Appendix B to 10 C.F . R. part 50 since November 1,1981.
22.
O O ANSWER TO INTERROGATORY NO. 32:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 33:
State specifier).ly each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 f ailed to comply with criterion 7 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 33:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 3 4 :
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 failed to comply with criterion 16 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 34:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 35:
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 failed to comply with criterion 17 of Appendix B to 10 C.F.R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 35:
See Answer to Interrogatory No.1.
23.
. e INTERROGATORY NO. 36:
State specifically each and every fact you rely on as a basis for your allegation that the licensee's design quality assurance program for Diablo Canyon Units 1 and 2 f ailed to complyfwith criterion 18 of Appendix B to 10 C.F . R. part 50 since November 1,1981.
ANSWER TO INTERROGATORY NO. 36:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 37:
List specifically each and every license commitment set forth in the Diablo Canyon FSAR which you allege has not been achieved as a result of the licensee's design quality assurance program since November 1,1981.
ANSWER TO INTERROGATORY NO. 37:
Each valid Error which addresses activities accomplished by the ITP represents an example of a licensing commitment (including a QA program commitment) which has not been achieved during the design modifications which have occurred since November 1,1981. Two examples of such an Error are set f orth in EOI's 1138 and 1139. Further, a number of the ITR's which will address the adequacy of the ITP's design modifications, and particularly the seismic design modifications, have not yet been issued for review by the IDVP. Also see responses to Interrogatories Nos. 1 and 2.
Thus, the Governor's review of the IDVP's iden tification and resolution of EOI's, as well as the ITP's corrective action measures, is of necessity not yet complete.
24.
e o IffrERROGATORY NO. 38:
State specifically each and every fact upon which you base your allegation that' the licensee's design quality assurance program since. November 1,1981 has caused commitments in the Diablo Canyon FSAR not to be achieved.
ANSWER TO INTERROGATORY NO. 38:
See Answer to Interrogatory No. 37 and Interrogatory No. 1.
INTERROGATORY NO. 39:
List specifically each and every license commitment set forth in the Diablo Canyon FSAR which you allege has not been achievej as a result of major subcontractor s' design quality assurance program since November 1,1981.
ANSWER TO INTERROGATORY NO. 39:
See Answer to Interrogatory No. 37 and Interrogatory No. 2.
INTERROGATORY NO. 40:
List specifically each and every portion of the licensee's design quality assurance program from November 1, 1981 to the present which you believe is deficient.
ANSWER TO INTERROGATORY NO. 4 0 :
See Answer to Interrogatory No.1.
INTERROGATORY NO. 41:
State each and every fact upon which you base your judgment regarding deficiency as to each such portion of licensee's design quality assurance program.
25.
. s ANSWER TO INTERROGATORY- NO. 41:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 42:
List specifically each and every implemen ting procedure of the licensee's design quality assurance program from November 1,1981 to the present which you believe to be deficient.
ANSWER TO INTERROGATORY NO. 42:
See Answer to Interrogatory No.1.
INTERROGATORY NO. 43:
State each and every f act upon which you base your judgment regarding each such deficiency for each such implemen ting procedure of the licensee's design quality assurance program.
ANSWER TO INTERROGATORY NO. 43:
See Answer to Interrogatory No. 1.
INTERROGATORY NO. 44:
For each and every major subcontractor for Diablo Canyon Units 1 and 2 since November 1,1981, list specifically each and every portion of each such subcontractor 's design quality assurance program for which you believe to be deficient.
ANSWER TO INTERROGATORY NO. 44:
l See Answer to Interroga tory No. 2.
INTERROGATORY NO. 45:
State each and every f act upon which you base your l
judgment regarding each such deficiency for each such portion of each such subcontractor 's design quality assurance program.
26.
ANSWER TO INTERROGATORY NO. 45:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 46:
For each and every major subcontractor for Diablo Canyon Units 1 and 2 since November 1,1981, list specifically each and every implemen ting procedure of each such subcontractor's design quality assurance program for which you believe to be deficien t.
ANSWER TO INTERROGATORY NO. 46:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 47:
State each and every fact upon which you base your judgment regarding each such deficiency for each such implemen ting procedure of each such subcontractor 's design quality assurance program.
ANSWER TO INTERROGATORY NO. 47:
See Answer to Interrogatory No. 2.
INTERROGATORY NO. 48:
Do you believe there are any of the 18 criteria of Appendix B to 10 C.F.R. part 50 which the licensee's design quality assurance program does not address?
ANSWER TO INTERROGATORY NO. 48:
The Governor 's review to date of the PG&E quality assurance program in ef f ect since November 1, 1981 indicates that the PG&E QA manual addresses each of tha 18 criteria of Appendix B. However, the adequacy of the QA program is still 27.
_ . . . _ . ~ . . _ _ . . _ _ _ .
under review, and deficiencies have been identified as described in answer to Interrogatory No.1.
INTERROGATORY NO. 49:
Dc you believe there are any of the 18 criteria of Appendix B to 10 C. F . R. part 50 which any of the major subcontractor 's design quality assurance program do not address?
ANSWER TO INTERROGATORY NO. 49:
At this time, the Governor has only reveiwed the QA program description for one of the major design subcontractors (Bech tel) . The Bech tel QA program in effect since mid-198 2 appears to address each of the 18 criteria of Appendix B.
However, the adequacy of the Bechtel QA program is still under review, and deficiencies have been identified as described in answers to Interrogator ies Nos.1 and 2.
INTERROGATORY NO. 50:
State each and every fact upon which you base your allegation that the scope of the IDVP's review of the seismic design of safety related SS&Cs is too narrow.
ANSWER TO INTERROGATORY NO. 50:
The Governor's review of the seismic portion of the IDVP is not complete at this time, in part because the IDVP has not yet documen ted the completion of all seismic Interim Technical Reports (ITR ' s ) , of all EOI's resolutions in the ITR's, or of the IDVP 's Final Repor t.
The Governor's review to date indicates that the scope of the IDVP review of seismic design is too narrow for several reasons as identified below.
28.
First, the IDVP did not verify samples from each seismic design activity, or from each seismic design group within each seismic design activity, which it did review.
The IDVP states in their Final Report that firms were excluded from IDVP review on the following bases:
- 1. Involved in licensing only.
- 2. Involved in design studies, or provided minor design input.
- 3. Performing NDE.
- 4. Provided design input which was not used in final designs.
- 5. Providing designs or design reviews which were not used.
The IDVP iden tified the following firms as being excluded from IDVP review:
- 1. R. L. Cloud Associates
- 2. Teledyne Engineering Services
- 3. Westinghouse (NSSS Supplier)
- 4. James Engineering Company.
- 5. Kaiser Engineers
- 6. Mark C. Jones
- 7. Nu Tech Incorporated S. Western Canada Hydraulic Laboratories
- 9. G. E. Company (See IDVP Report, pp. 4.1.4-2 and 4.1.4-3)
The Governor is particularly concerned with the exclusion of Westinghouse NSSS design work from IDVP review, 29.
. o since NSSS design is a critical and major aspect of plant de sign.
The above list may not be an exhaustive list of design groups whose design activities were not reviewed by the IDVP.
However, it is clear that PG&E has direct access to data underlying the IDVP and ITP efforts unavailable to the Governor , and can more readily compile a complete list than can the Governor.
Further, the IDVP did not select statistically valid samples from which to draw conclusions, as set forth in the Answer to Interrogatory No. 68.
Third, the IDVP failed to verify independently the analyses, but merely checked data of inputs to models used by PG&E, or performed limited analysis as set forth in the Answer to Interrogatory No. 70.
Finally, the IDVP review was limited to Diablo Canyon Unit 1 (see NEUREG - 0675, SUPPLEMENT NO. 18, Diablo Canyon SER, p. C.1-4); Unit 2 was excluded from the scope of review.
For the above reasons, the Governor's review indicates that the scope of seismic review of the IDVP is too narrow to provide assurance of the seismic design adequacy of structures, systems and componen ts at Diablo Canyon.
INTERROGATORY NO. 51:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
30.
ANSWER TO INTERROGhTORY NO. 51: -
The references which apply to Interrogatory No. 51 are given in the body of the A'nswer to Interrogatory No. 50.
Paragraph and page information are not always supplied in every case since this information is as readily available to PG&E as to the Governor .
INTERROGLTORY NO. 52:
State each and every fact upon which you base your allegation that the IDVP did not verify samples from each of the seismic design activities.
ANSWER TO INTERROGATORY NO. 52:
See the Answer to Interrogatory No. 50.
INTERROGATORY NO. 53:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 53:
See the Answer to Interrogatory No. 50.
INTERROGATORY NO. 54:
State each and every fact upon which you base your allegation that the IDVP did not verify samples from e ach of the design groups in the design chain performing the seismic design activities it did review.
ANSWER TO INTERROGATORY NO. 54:
See the Answer to Interrogatory No. 50.
31.
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INTERROGATORY NO. 55: g Please iden tify each and everh documen t which you claim supports each f act set forth inithe preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach'such f act.
ANSWER TO INTERROGATORY NO. 55:
See the Answer to Interrogatory No. 50.
INTERROGATORY NO. 56:
State each and every fact upon which you base your allegation that the IDVP did not verify samples from each of the non-seismic design activities it did review.
ANSWER TO INTERROGATORY NO. 56:
PG&E, in its Answers to Governor's Second Set of Interrogatories, stated on page 20 that the DCP had not reviewed the non-seismic design wor k for each and every design group in the design chain for each and every safety related str uc ture , system and componen t modified since November 1, 1981. PG&E further stated that the reason for this was that the November 19 , 198 1 NRC letter f rom Harold Den ton required the review of non-seismic design activities by an independent contractor.
In addition, the IDVP in its Response to Governor 's Second Set of Interrogatories states on pages 15-16 that it had not reviewed the non-seismic design work of each and every design group in the design chain for each and every safety related system, struc ture and componen t at Diablo Canyon. The IDVP Phase II review consisted of (a) a fluid system, (b) an 32.
air system, and (c) an electrical system associated with one of the above. Design work outside the above three systems was reviewed only in special instances, such as additional verification for generic EOI's, and review of certain cases in ,
the ITP Corrective Action Program. The IDVP further stated that iden tification of every design group whose wor k was not reviewed was not part of the IDVP ef fort, and that any design groups not reviewed by the IDVP were either beyond the scope of the IDVP program or outside the sample selected by the IDVP.
The re for e , there appears to be little disagreement that some design activities performed by some design groups in the design chain were not verified by IDVP samples. The Governor is attempting to ascertain exactly which activities by which groups were not reviewed. Neither PG&E nor the IDVP were able to provide a listing of unreviewed design activities or design groups in response to the Governor's Interrogatories No. 29 (a) and No. 38 (a) respectively. Therefore, the Governor will continue the review of the scope of the Diablo Canyon non-seismic design verification activities and will supplement this Response if and when a more definitive listing of unreviewed design activities is developed.
INTERROGATORY NO. 57:
Please iden tify each and every documen t which you claim supports e ach f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
l l
33.
. _ - - - ~ _ - - - - - -
ANSWER TO INTERROGATORY NO. 57:
The references to the Response to Interrogatory No. 57 are provided in the body of the Response to Interrogatory No. 56.
INTERROGATORY NO. 58:
, State each and every f act upon which you base your allegation that the IDVP did not verify samples from each of the design groups in the design chain that performed the non-seismic design activities it did review.
ANSWER TO INTERROGATORY NO. 58:
The facts which support the Governor 's conclusion that the IDVP has not reviewed samples from each non-seismic design group in the design chain are stated in the Response to Interrogatory No. 56. As stated in the Response to Interrogator y No. 56, the Governor was not provided with the specific identification of each unreviewed design group in the answers to the Governor 's Interrogatories supplied by PG&E and the IDVP. An example of a design group and activities not fully reviewed by the IDVP and the ITP are the Westinghouse NSSS design. Westinghouse provided major and critical design e f for t to Diablo Canyon but the Westinghouse NSSS was excluded from the scope of the design verification program because of the interpretation of Westinghouse's activities as " design wc'r k done by a vendor in support of the sale and licensing of their equipmen t" (see the IDVP Final Repor t, SS 1.3.2 and 4.1.4).
The Governor believes that PG&E, which has direct access to data underlying the IDVP and ITP effor ts unavailable 34.
-. .- _- 1
. e to the Governor, can more readily compile a list of the design groups whose wor k was not reviewed than can the Governor.
INTERROGATORY NO. 59:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 59:
The references to the Response to Interrogatory No. 59 are provided in the body of the Response to Interrogatory No. 58.
INTERROGATORY NO. 60:
State each and every f act upon which you base your allegation that the number of samples obtained for the non-seismic design activities the IDVP did verify are insufficient to provide mathematically verifiable conclusions about even those activities.
ANSWER TO INTERROGATORY NO. 60:
The Governor 's review to date indicates that the IDVP's sampling program was deficient for the reasons set forth in the Response to Interrogatory No. 68. The portion of the Response to Interrogatory No. 68 pertinent to Interrogatory No. 60 include the following:
- 1. The sampling program was not conceived or executed using expert statistical assistance or rigorous statistical techniques.
35.
- 2. The sampling procedures, criteria and acceptance criteria were not set forth beforehand.
- 3. The samples selected were not valid random samples. Rather, a number of samples were based solely on subjective engineering judgment.
- 4. The samples selected were not represen tative of the populations to which conclusions were extrapolated.
INTERROGATORY NO. 61:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 61:
See Answer to Interrogatory No. 69.
INTERROGATORY NO. 62:
State each and every f act upon which you base your allegation that the IDVP has accepted substitution of mean measured performance of structures and materials in lieu of code-specified minima.
ANSWER TO INTERROGATORY NO. 62:
This conten tion is based on the lack of documentation I
by the IDVP of a full verification by it of use in the PG&E Phase I Final Report of material properties based on test values rather than specified minimum value.
36.
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INTERROGATORY NO. 63:
Please identify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible 1 (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 63:
No specific page and paragraph of IDVP materials can be cited, since a complete verification is not documented by 1 IDVP.
INTERROGATORY NO. 64:
State each and every f act upon which you base your allegation that the IDVP has accepted deviations from the equipmen t standa rds set for th in PG&E's license commitments without providing an adequate engineering justification for the ch ange.
ANSWER TO INTERROGATORY NO. 64:
The Governor's review of the IDVP's resolution of EOI's is not yet complete. Further, all EOI's have not yet been resolved by the IDVP, nor have the resolution of all EOI's yet been documen ted in ITRs.
The Governor 's review to date has iden tified the following examples, summarized in Table 64, of EOI's where the IDVP accepted deviations f rom the Diablo Canyon licensing
! commitments without providing an adequate engineering justification.
l 37.
The answer does not specify pages and paragraphs'of each EOI since that information is as readily available to PG&E as it is to the Governor.
TABLE 64 IDVP ACCEPTED DEVIATIONS FROM DIABLO CANYON LICENSING CRITERIA Description of Deviation EOI Nos.
- 1. Contrary to the requirements of FSAR 8027, 8048 Section 17.1 regarding compliance of the as-built installation with the design documen ts, the IDVP review of the AFWS disclosed that the as-built installa-tion failed to meet the design drawings in that (i) a steam trap on the turbine-driven AFW pump steam supply line was not provided and (ii) there were discrepancies in the arrangement of the long-term cooling water supply line.
- 2. Contrary to FSAR Section 8.3.3., the 8055, 8059 electrical design did not fully comply with commitments regarding separation and color coding .
- 3. Contrary to the single failure criterion 8041 of Appendix A to 10 CFR Part 50, a single f ailure may cause loss of redundant power divisions because redundant electric power division trains were electrically inter-connected through the circuit breakers and a single power transfer switch.
- 4. Contrary to GDC 57 of Appendix A, valve 8018 operator s for the isolation valves which provide the steam supply to the turbine-driven auxiliary feed pump from two of the main s team generators were not classified and procurred as safety related components.
38.
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TABLE 64 IDVP ACCEPTED DEVIATIONS FROM DIABLO CANYON LICENSING CRITERIA Description of Deviation EOI Nos.
- 5. The single failure of an auxiliary relay 8052 would prevent automatic closure of the redundant steam generator blowdown isolation i
valves on automatic initiation of the AFWS contrary to a Westinghouse interface require-ment and FSAR Figure 7.2-1.
- 6. Flow transmitter FT-78 and flow control 8052 valve FCV-95 are located in a harsh environ-men t but where not listed as such in the PG&E 4
environmental qualification report and are
- not yet environmen tally qualified.
- 7. Portions of the CRVPS were omitted from 8056 PG&E's environmen tal qualification report.
- 8. CRVPS equipment identified in the FSAR 80 50 as necessary to maintain control room habitability during safe shutdown were not evaluated regarding the effects of a moderate energy pipe break.
- 9. The fire zone separation for the motor 8038, 8037 drivec AFW pump room was not consistent 8019, 8021 with licensing document descriptions with regard to a large grated ventilation opening in the ceiling as well as dis-crepancies in the PG&E fire review noted in EOI's 8037, 8019, and 8021 which results in an inadequate margin of safety.
- 10. Contrary to licensing document descriptions, 8039 each of the three 4160 volt cable spreading rooms has a ventilation opening leading up to the 4160 volt switchgear rooms which results in an inadequate margin of fire safety.
- 11. Verification of system design pressures and 8009, 8010 temperatures for safety related systems 8062 including its use in equipment specification were not included in the IDVP's additional
- verification program for items within the t
Westinghouse design scope, but rather were improperly limited by the IDVP to PG&E design scope systems.
39.
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TABLE 64 IDVP ACCEPTED DEVIATIONS FROM DIABLO CANYON LICENSING CRITERIA .
Description of Deviation EOI Nos.
- 12. Contrary to FSAR Section 3.6, possible jet 7002 impingement loads were not considered in the design and qualification of safety related piping and equipment inside containment.
- 13. Contrary to QA program commitments in FSAR 6002 Section 17.1, documented evidence was inadequate to demonstrate that rupture restraints outside and inside containment '
have been properly designed and installed to provide protection against rupture in high pressure piping.
- 14. For the containmen t exterior shell review SER, Supp.18 the ITP review used the AISC Code rather at p. C.3-17 than Section III of the ASME Code contrary to the commitment in Table 3.2-4 of the FSAR.
1 4
40.
~ e IlffERROGATORY NO. 65:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response-and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 65:
See Answer to Interrogatory No. 64.
INTERROGATORY NO. 66:
State each and every fact upon which you base your allegation that the IDVP has failed to ascertain the root cause of the deviation from PG&E's license commitments and the regulatory requirements that it was and is discovering.
ANSWER TO INTERROGATORY NO. 66:
In many cases, the IDVP has resolved EOI's as specific problems, rather than attempting to find out what f actors or even ts led to the discrepancy's existence. Examples of such resolutions are cases where EOI's were resolved by analysis or modifications which resolved the specific concern iden tified, without giving any indication as to how the concern arose. In fact, the Governor 's review could not iden tify a single EOI for which the underlying cause, or series of events leading to the error was iden tified in the IDVP documen ta tion. Each valid EOI represents at least two errors: the error itself, and the accompanying error or error s in the QA program or its implementation which allowed the original error to remain unde tec ted . In no case did the IDVP specifically iden tify the second error or errors in quality assurance.
41.
Table 66.1 provides a listing of the EOI's which the Governor's review to date has identified as cases where the IDVP failed to ascertain the root cause of the identified discrepancy. Table 66.2 summarizes the categorles of deficiencies in disposition of EOI's identified in Table 66.1. (The use of the term " generic" in these answers is intended to conform to the PG&E terminology and implies no agreemen t with PG&E's or the IDVP 's cha racterization.)
42.
TABLE 66.1 LISTING OF EOI RESOLUTIONS WHERE ROOT CAUSE WAS NOT ADDRESSED EOI ITR _ COMMENTS 7004 47 Closed by IDVP; concern proved ~ to exist 7005 generically, but safety significance was not 8001 addressed in ITR, nor was root cause of err or s. PGsE is now resolving any design implications in its Iterative Design Proce'ss.
8003 47 (Same as for 7004, 7005 and 8001 above) .
8005 14 Closed by IDVP; root cause of error was not a dd ressed. Rather, the adequacy was justified by analysis.
8006 47 (Same as for 7004, 7005 and 8001 above) .
8009 46 Closed by IDVP; concern proved to exist 8010 generically. The IDVP did not address the safety significance in ITR, or the root cause of the errors. PG&E is now performing a general reanalysis.
t 8011 21 Closed by IDVP; r oot cause o f err or was not addressed.
8014 21 Closed by IDVP; resolution omitted mention of four out of six components identified in or iginal EOI. Root cause of error was not addressed, nor were potential generic implications.
8015 22 Closed by IDVP; root cause of the error was not addressed, .or were the possible negative effects of not requiring flow testing which the IDVP it self iden tified.
' 8017 49 Closed by IDVP; concern proved to exist gen erically. The IDVP did not address the safety significance in the ITR, or the root '
cause of the error. PG&E is per for ming a general review and making modifications as necess a ry.
43.
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TABLE 66.1 LISTING OF EOI RESOLUTIONS WHERE ROOT CAUSE WAS NOT ADDRESSED 8019 18 Closed by IDVP; root cause of the error was 8020 not addressed.- Rather, the adequacy was 8021 justified by analysis.
8022 24 Closed by IDVP; root cause of the error was not addressed. Rather, the adequacy was justified by analysis.
8023 24 Closed by IDVP; root cause of the error was 8024 not addressed, nor were the potential 8025 generic implications. The error was resolved 8026 by modifications.
8027 22 Closed by IDVP; root cause of the error was not addressed.
8031 21 Closed by IDVP; root cause of the error was not addressed. Rather, the adequacy was justified by analysis. Some of the aff ected equipment was transferred to EOI file 8064.
8032 27 Closed by IDVP; root cause of the error was not addressed, nor were the potential generic implications. The error was resolved by modifications.
8033 47 (Same as for 7004, 7005, and 8001 above) .
8034 8035 18 Closed by IDVP; root cause of the error was 8036 not addressed.
8038 18 Closed by IDVP; root cause of the error was 8039 not addressed. Rather, the adequacy was justified by analysis.
8040 14 (Same as for 8005 above) .
8041 26 Closed by IDVP; root cause of the error was not addressed.
8044 26 (Same as for 8041 above) .
8045 24 (Same as for 8022 above) .
44.
- - . . - - ~ . .
TABLE 66.1 LISTING OF EOI RESO.SUTIONS WHERE ROOT CAUSE WAS NOT ADDRESSED 8048 22 Closed by IDVP; root cause of the error was not addressed.
8049 23 Closed by IDVP; root cause of the erroc was not addressed. Rather, the adequacy was justified by analysis.
8050 21 Closed by IDVP; root cause of the error was not addressed. Rather, the adequacy was justified by a,nalysis.
8051 27 Closed by IDVP; root cause of the error was not addressed.
8053 28 Closed by IDVP; root cause of the error was not addressed.
8055 27 (Same as for 8051 above) .
8056 28 (Same as for 8053 above) .
8057 49 (Same as for 8017 above) .
8060 22 Closed by IDVP; root cause of the error was not addressed. The error was resolved by modifications.
8062 22 (Same as for 8009 and 8010 above) .
8063 25 Closed by IDVP; root cause of the error was not addressed. The errac was resolved by modifications.
8065 48 Closed by IDVP; root cause of the error was not addressed. Rather, the adequacy was justified by analysis.
45.
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TABLE 66.2
SUMMARY
OF TABLE 66.1 Root Cause of Error Not Addressed Generic Resolved by Resolved by Concern Modif ication Analysis Other TOTAL 12 7 13 13
_E OI ' s 7004 8023 8005 8011 7005 8024 8019 8014 8001 8025 8020 8015 8003 8026 8021 8027 8006 8032 8022 8035 8009 8060 8031 8036 8010 8063 8038 8041 8017 8039 8044 8033 8040 8048 8034 '8045 8051 8057 8049 8053 8062 8050 8055 8065 8056 INTERROGATORY NO. 67:
Please iden tify each and avery documen t which you claim supports e ach f act set forth in the preceding response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 67:
Table 66.1 identifies the EOI's and the Interim Tech nical Repor ts in which they are discussed. Table 66.1 does not specify pages and paragraphs within ITR's since that information is as readily available to PG&E as to the Governor.
INTERROGATORY NO. 68:
State each and every f act upon which you base your allegation that the IDVP has f ailed to verify independently 46.
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that all safety related structures, systems, and components at 2 g
. Diablo Canyon meet PG&E's licensing commitments. --_
ANSWER TO INTERROGhTORY NO. G8: '
The Governor's review to date indicates that the ID P -
has failed to verify independently that all safety related structur.es, systems and components of Diablo Canyon meet PGh5's licensing commitments.
The IDVP reviewed a sample of struc tures, systems and components at Diablo Canyon. For example,. the IDVP review of non-seismic design focused on the Auxiliary Feedwater System, the Control Room Ventilation and Pressurization System, and the 4160-volt Electrical Distribution System. To claim that the IDVP had verified the non-seismic design of other safety related systems, structures and componenets would require the extrapolation of the IDVP's conclusions to the unreviewed safety systems. While the extension of analytical conclusions is a vali'd exercise under certain specific conditions, the IDVP review has not met those conditions and therefore conclusions cannot be drawn as to the adequacy of design activities in the unreviewed portion of the plant, for the reasons set forth below.
The extrapolation of conclusions from a sample to a population is a statistical exercise and requires expert knowledge and use of statistical principles. Howev er, the IDVP committed only to " consider" the use of statistical techniques to "augmen t the program" in the Phase I and II Pr ogram Management Plans (see Appendix C to both the Phase I and II 47.
. . I Program Management Plans) . Later, the IDVP determined that
" rigorous statistical techniques are largely inappropriate for a design verification program," and decided not to retain a statistical expert as consultant to the IDVP (see the IDVP Final Report, pp. 3.5-7 and 3.5.-8). Therefore the IDVP did not have the expert assistance necessary to establish a valid sampling program.
The IDVP samples provide inadequate bases for the extrapolation of results to the unreviewed population of safety related systems, structures and componen ts of Diablo Canyon.
Deficiencies in the IDVP's samples are set forth below as follows:
- 1. The samples are not represen tative of the en tire ,
population. Conclusions based on a sample can only be extrapolated to a population similar to the sample. Work performed in one design activity cannot represen t wor k performed in a different design activity. Therefore, the IDVP should have reviewed samples of all of the design activities. As set forth in the Response to Interrogatory No. 56, the IDVP did nat. The wor k product of one design subcontractor cannot represen t the wor k produc t of a dif feren t design subcont rac tor . Therefore, for a given design activitiy, the IDVP should have campled wor k for every subcontractor. As set forth in the Response to Interrogatory No. 58, the IDVP did 48.
o a not. Further, the Governor's continuing review has f ailed to identify any IDVP analysis which purports to justify the safety systems from which review samples were taken as being representative of all other safety related systems, structures and componen ts of Diablo Canyon.
- 2. The samples are not random. The IDVP sampling program relied on subjective engineering judgments rather than statistically valid sampling techniques. (See Supplemen tal Af fidavit of Richard Hubbard Concerning Breakdowns in the Diablo Canyon Quality Assurance Program, pp.
33-34).
- 3. The sampling criteria are not explicit. The IDVP has failed to set forth its criteria for the selection of samples, such as desired degree of con fid ence, acceptance criteria of the review, sample size, or criteria for additional sampling. Therefore, the IDVP has failed to provide any documen ted basis that they conceived and executed a valid sampling program.
In summary, the Governor concludes that the extrapolation of the areas reviewed by the IDVP to the unreviewed portions of Diablo Canyon is inappropriate, based on the above deficiencies in the IDVP's sampling program.
Further, the Governor believes that deficiencies exist in the IDVP's disposition of identified non-compliances in the 49.
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areas sampled. As set forth in the Responses to Interrogatories No. 66 and 124, the IDVP did nat address the root cause and generic implications of many identified discrepancies. between PGEE's licensing commitments and the actual design of Diablo Canyon.
The Governor's review of the Interim Technical Reports (ITR's) in which the IDVP's review samples are discussed is not yet complete. The Governor is also waiting for further information from PG&E and the IDVP (such as ITR's and updates of the IDVP Final Repor t) .
INTERROGATORY NO. 69:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as poossible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 69:
4 The references used in the Answer to Interrogatory No. 68 are iden tified in the body of the Answer to Interrogatory No. 68.
INTERROGATORY NO. 70:
State each and every fact upon which you base your allegation that the IDVP has performed no independent verifications, but has merely checked data inputs to models used by PG&E.
ANSWER TO INTERROGATORY NO. 70:
This contention is based on the lack of complete, independent analyses, similar to the anlyses done by Brookhaven 50.
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y , . , _ . , _ , , . _ ___% p ._ _-,, - p ,_ , , ,_ ,_ , , , , , , _ . . , _ .__
' 7" I o . .; -
National Laboratories,; y the IDVP for the Containment Auxiliary Building, Fuel Handling Building, Turbine Building or Intake Structure. Whi e _ some independence analyses have been !
done they are highly limited, and do not verify the seismic design of all structures.
INTERROGATORY NO. 71:
1 Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 71:
ITR 6, the first ITR dealing with the seismic analysis of a structure, contains only an analysis for natural f requencies and modal shapes rather than an analysis to obtain the complete dynamic response of the structure (ITR 6, Scope, p.8). Page 35 of ITR 6 recommends an examination of the seismic analysis of the remaining structures, to review design and field changes, and to review the new Auxiliary Building analysis, but the re is no discussion or recommendations of a full, independen t analysis by the IDVP .
The document entitled Verification Program for PG&E Corrective Action, which appears to be ITR 8, sets forth the IDVP plan of action for the Containment Structure, Auxiliary Building, Fuel Handling Building and Intake Structure at Tables 1, 2, 3 and 5, and at pages 5, 9,13, and 19, respectively.
Neither these tables nor the referencing texts state tha t f ull, independent analyses of these structures will be done by the 51.
~
IDVP. Table 4, on page 17, dealing with the Turbine Building was not completed at the time of review.
ITR 50 states that the IDVP has conducted independent analyses of two piping models in the containmen t annulus but indicates no other independent review of this structure.
INTERROGATORY NO. 72:
State each and every fact upon which you base your allegation that the IDVP has failed to verify that modeling by PG&E of soils properties for the containmen t building is justified and proper.
ANSWER TO INTERROGATORY NO. 72:
This contention is based on the lack of documentation by the IDVP of an independent verification by it of the correctness and reasonableness of PG&E's modeling of the soils properties ara soils structure interaction for the Containment Building.
INTERROGATORY NO. 73:
Please identify each and every document which you claim supports each f act set forth in the preceding response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 73:
No ITR page or paragraph of IDVP material can be cited, since a complete, independen t analysis is not documen ted by the IDVP.
INTERROGATORY NO. 74:
State each and every fact upon which you base your 52.
.- ... .. . - . r . .. . . , , . . . . . , _ . , _ . - - _ . - _ _ - - -
allegation that the IDVP has failed to verify PG&E's computations for modes in the containmen t building having frequencies between 20 and 33 HZ.
ANSWER TO INTERROGATORY NO. 74:
This conten tion is based on the absence from any ITR of a documented verification of the correctness and appropriateness of PG&E's seismic analysis of the Containment Building for the DE and the DDE for modes with f requencies greater than 20 HZ.
INTERROGATORY NO. 75:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 75:
No specific IDVP materials page or paragraph can be cited, since a complete verification of this modeling approach is not documented by the IDVP.
INTERROGATORY NO. 76:
State each and every f act upon which you base your allegation that the IDVP has failed to verify that use of inconsisten t seismic techniques of modeling of accelerations, displacements, and shell forces in the containment building is justifiable and proper.
ANSWER TO INTERROGATORY NO. 76:
- This conten tion is based on the absence of documented verification by the IDVP of the correctness and appropriateness 53.
of the use by PG&E of a time history modal superposition analysis to determine accelerations and displacements in its seismic analysis of the Containment Building, while using a response spectra analysis to determine shell forces in the same building.
INTERROGATORY NO. 77:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 77:
No specific IDVP materials, page and paragraph can be cited, since a complete verification of the use of this modeling approach has not been documen ted by the IDVP.
IN".ERROGATORY NO. 7 8 :
State each and every f act upon which you base your allegation that the IDVP has failed to verify that failure by PG&E to use two hor izontal componen ts in its seismic modeling of the containment building for the DE and DDE, as it did for the Hosgri, is justifiable and proper.
ANSWER TO INTERROGATORY NO. 7 8:
This conten tion is based on the absence of documentation by the IDVP that it has fully verified the correctness and appropriateness of the use by PG&E of a seismic analysis for the Containment Building that uses only one hor izontal componen t of motion for the DE and the DDE, but uses two horizontal components of motion for the Hosgri.
54.
INTERROGATORY NO. 79:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 79:
No specific IDVP materials, page and paragraph can be cited, since a complete verification of the use of this modeling approach has not been documen ted by the IDVP.
INTERROGATORY NO. 80:
State each and every fact upon which you base your allegation that the IDVP failed to verify that use by PG&E of inappropriate and poten tially dangerous stress f actor s and load f actors for steel still used in the containment building, is justifiable and proper.
ANSWER TO INTERROGATORY NO. 80:
This conten tion is based on the absence of documentation by the IDVP that it has adequately verified the ~
correctness and appropriateness of the stress f actor s and load f actors for steel used in PG&E's analysis of the Containment Building, and of PG&E's application of relevant seismic criteria in that analysis.
INTERROGATORY NO. 81:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and cor relate each such documen t as specifically as possible (page and parag raph number) with e ach such f act.
55.
e .
ANSWER TO INTERROGATORY NO. 81:
No specific page and paragraph of IDVP materials can be cited, since a complete verification of the relevant f actors has no t been documen ted by the IDVP .
INTERROGATORY NO. 82: '
State each and every fact upon which you base your allegation that the IDVP has failed to verify that PG&E's failure to specify all damping values used in modeling of each mode in the containment building, is justifiable and proper.
ANSWER TO INTERROGATORY NO. 82:
The contention is based on the absence from the PG&E Phase I Final Report of a full listing of modal damping values used in the horizontal analysis of the Containment Building for the DE and the DDE, and the lack of documentation by the IDVP that it has fully verified Building the correctness and appropriateness of modal damping valves in that analysis.
INTERROGATORY NO. 83:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 83:
No specific page and paragraph of IDVP materials can be cited, since a complete verification of PG&E's use of correct and proper damping values has not been documented by I DV P .
56.
INTERROGATORY NO. 84:
State each and every fact upon which you base your allegation that the IDVP has failed to verify that the values used by PGsE in modeling soils properties for the auxiliary building are correct and properly used.
ANSWER TO INTERROGATORY NO. 84:
This conten tion is based on the lack of documentation by the IDVP that it has fully verified the correctness and appropriateness of PG&E's use of soils springs in its modeling of the Auxiliary Building, including the physical meaning and intended purpose of the soil springs, the bounda ry conditions at the ends of the springs, and the way in which the springs account for soil mass.D4TERROGATORY NO. 85:
Please identify each and every document which you claim supports each fact set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
ANSWER TO INTERROGATORY NO. 85:
The discussion in ITR 6, section 5.1.1, page 11, is incomplete and fails to describe a full verification of the factor s listed in the answer to the preceding interrogatory.
INTERROGATORY NO. 86:
( State each and every fact upon which you base your allegation that the IDVP has failed to verify that all damping factor s used by PG&E in modeling of the DE for auxiliary buildings are conservative and proper.
57.
o e ANSWER TO INTERROGATORY NO. 86:
This conten tion is based on the lack of documentation by the IDVP that it has fully verified the correctness and !
l appropriateness of the use by PG&E of 4% damping values for the DE and the DDE in its modeling of the Auxiliary Building including the cor rectness of PG&E's iden tification and application of relevant seismic criteria.
INTERROGATORY NO. 87 :
Please identify each and every document which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 87 :
No specific page and paragraph of IDVP material can be cited, since a complete verification of the use of correct and proper damping values has not been documented.
INTERROGATORY NO. 88:
State each and every fact upon which you base your allegation that the IDVP has failed to verify that all stress values for concrete in shear walls used by PG&E in modeling the auxiliary building are conservative and proper.
ANSWER TO INTERROGATORY NO. 88:
This conten tion is based on the lack of documentation by the IDVP that it has fully verified the appropriateness of use by PG&E of allowable shear stress for the concrete in the shear walls of the Auxiliary Building of 10 (sqrt(f'c)), a less conservative value than that of ACI 318-77.
58.
< r INTERROGkTORY NO. 89:
Please identify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act. .
ANSWER TO INTERROGATORY NO. 89:
No specific page and paragraph of IDVP materials can be cited, since a complete verification of the use of this value has not been documen ted by the IDVP.
INTERROGATORY NO. 90:
State each and every f act upon which you base your allegation that the IDVP has failed to verify that PGEE's modeling of the crane in the turbine building at full load is complete, covers all cases, and is conservative and proper.
ANSWER TO INTERROGATORY NO. 90:
This conten tion is based on the lack of documentation by the IDVP that it has fully verified that PG&E's modeling of the crane at fuel load has been done for all cases, with the crane loaded or unloaded and parked at various locations, and not solely for the crane unloaded and parked at column line 9.
INTERROGATORY NO. 91:
Please identify each and every document which you i
claim supports each f act set forth in the preceding response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
59.
i e- -3,- - - , _ . ,,ww a .- , ...n .,g- ,,-.---e - - . -
- r. ._._-.-.---,,,w.,...,,-e-,,m ,--.--.4,- , m-,,-, m.- - . - ,.- e.. - , , - . - - - + , .. = - - . - - , - , . - , , .
. . cr ANSWER TO INTERROGATORY NO. 91:
No specific page and paragraph of IDVP materials can be cited, since a complete verification of this modeling analysis has not been documen ted by IDVP.
INTERROGATORY NO. 92:
State each and every f act upon which you base your allegation that the IDVP has failed to verify that PG&E's use of the double algebraic sum method of calculation, rather than the square root of the sum of the squares method, is justifiable and properly done.
ANSWER TO INTERROGATORY NO. 92:
This conten tion is based on the lack of documentation by the IDVP that it has fully verified the correctness and appropriateness of use by PG&E of the response spectra modal superposition method with modal responses combined by the square root sum of the squares method in calculating member forces for the Hosgri, except for closely spaced modes, which were combined using the double algebraic sum method.
INTERROGATORY NO. 93:
Please identify each and every document which you claim supports each f act set forth in the preceding response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 93:
No specific page and paragraph of IDVP materials can be cited, since a complete verification of this technique has not been documen ted by the IDVP.
60.
, ?- -
e r IlfrERROGATORY NO. 94:
State each and every f act upon which you base your allegation that the IDVP has failed to ver'ify that PG&E's modeling of tor sion factor s by dif fering techniques for different buildings is conservative and properly done.
ANSWER TO INTERROGATORY NO. 94:
This conten tion is based on the lack of documentation by the IDVP that it has fully verified the correctness and appropriateness of the modeling methods by which PG&E has accounted for torsional motion in all structures, including accounting for acciden tal eccen tricity in the Turbine Building and the Intake Structure by increasing horizontal motion by 10%.
INTERROGATORY NO. 9 5:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 9 5:
No specific page and paragraph of IDVP materials can be cited, since a complete verification of the relevant modeling tech niques has no t been documen ted by the IDVP.
INTERROGATORY NO. 96 :
State each and every f act upon which you base your allegation that the IDVP has failed to verify how hydr odynamic forces were computed by PG&E in its modeling of the intake structure, and that such computation was properly and correctly done.
61.
- ~
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ANSWER TO IBFFERROGATORY NO. 96:
This contention is based on the lack of explanation in the PG&E Phase I Final Report of how the hydrodynamic forces in the Intake Structure were modeled, and on the lack of documentation by the IDVP that it has fully verified the correctness and appropriateness of such modeling.
INTERROGATORY NO. 97:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 97:
No specific page and paragraph of PG&E or IDVP materials can be cited, since a complete explanation or verification of this modeling has not been documented by either.
INTERROGATORY NO. 98 :
State each and every f act upon which you base your allegation that the IDVP has failed to verify that PG&E's use in modeling the intake structure of dif feren t models for non-linear vertical dynamic amplification and for horizontal seismic loading, and PG&E's method of combining their responses, are justifiable and properly done.
ANSWER TO INTERROGATORY NO. 98:
This conten tion is based on the lack of documentation by IDVP that it has fully verified correctness and appropriateness of the use by PG&E of a linear elastic analysis of the horizontal and vertical response for the unloaded case, 62.
, . . , _ , c. . - , , , ~ , , . -- _ _ _ _ _ _ _ . _ _ -_ - -
. e a nonlinear time history analysis for the vertical response for the loaded case, and use of the SRSS method to combine the three directions of earthquake motion.
INTERROGATORY NO. 99:
Please identify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 99 :
No specific page or paragraph of IDVP materials can be cited, since a complete explanation and verification of this modeling technique has not been documented by the IDVP.
INTERROGATORY NO. 100:
State each and every fact upon which you base your allegation that the IDVP has failed to verify that PG&E's use of duc tility f actor s for steel and concrete in modeling the intake structure is conservative and properly done.
ANSWER TO INTERROGATORY NO. 100:
This contention is based on the lack of documentation by the IDVP that it has fully verified the correctness and j appropriateness of the use by PG&E of ductility f actors of 1.3 for concrete, 3 for steel, and imprecisely specified local f ac tor s (identified only as being required to demonstrate that the function of design Class I equipment will not be adversely a f f ec ted) , combined with 7% damping for the Hosgri event.
63.
- ,- , . ~ . , - - -- , . . - _ _ . . . - _ - _ _ - . . - ,
. r INTERROGATORY NO. 101:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 101: ,
No specific page or paragraph of IDVP materials can be cited, since a complete explanation and verification of this modeling tech nique has not been documented by the IDVP.
ITR 58, Rev. O, has a brief comment on ductilities at page 17, but this is a conclusory statement that provides no explanation, documentation or verification.
INTERROGATORY NO. 102:
State each and every fact upon which you base your allegation that the standards which the IDVP utilized to determine whether the non-seismic design activities it reviewed met PG&E's license commitments were improper.
ANSWER TO INTERROGATORY NO. 102:
See Answer to Interrogatory No. 64.
RITERROGATORY NO. 103:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 103:
See Answer to Interrogatory No. 64.
64.
< r INTERROGATORY NO. 104:
State each and every fact. upon which you base your allegation that the IDVP has acgepted deviations from the equipmen t standa rds set forth in PGEE's license commitaents without providing an adequate engineering justification for the changes ANSWER TO INTERROGATORY NO. 104 :
See Answer to Interrogatory No. 64.
INTERROGATORY NO. 105:
Please identify each and every document which you claim supports each f act set forth in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 105:
See Answer to Interrogatory No. 64.
INTERROGATORY NO. 106:
i State each and every fact upon which you base your allegation that the IDVP has f ailed to ascertain the root cause of the deviations from PG&E's license commitments that it was and is discovering.
ANSWER TO INTERROGATORY NO. 106:
Interrogatory No.106 appears to be similar to i Interrogatory No. 66, except more limited in wording.
Therefore, the response to Interrogatory No. 66 also addresses the response to Interrogatory No.106.
65.
i
.--...__#-, ____l' . f. l __ ,J. _ _. . _._-.__.._.___,J.Z"'? .u,,___...-. _ . _ . . . - . - , , _ - _ _ _ - . _ _ , . _ . - . - . - .
INTERROGATORY NO. 107:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 107:
See Answer to Interrocatory No. 67.
INTERROGATORY NO. 108:
State each and every f act upon which you base your allegation that the IDVP has no systematic program for verifying that the design of equipmen t supplied to PG&E from its subcontractors met PG&E's license commitments for such equipmelt.
ANSWER TO INTERROGATORY NO. 108:
During the ASLAB pre-hearing conference on August 23 and 24, 198 3, counsel for PG&E acknowledged that the IDVP had no systematic program for verifying that the design of equipmen t and componen ts supplied to PG&E by its contractor s met the license application criteria. A major example is Westinghouse supplied equipmen t. While the IDVP/ITP program did identify errors in the Westinghouse equipment such as the accumulator cabinets and the main control boards, in gen eral, the IDVP limited its review to the PG&E/ Westinghouse seismic in ter f ace a s se t f or th in ITR-ll . Further, not even all safety-related design subcontractors were reviewed by IDVP.
For example, Section 4.1.4 of the IDVP Final Report provides a list of safety-related design subcontractors who were not 66.
. e included in the IDVP verification efforts. Thus, the Governor's review to date indicates that the apparent weakness of PG&E's design quality assurance program has rendered the design of all the plant's structures, systems, and componen ts suspect (also see the ASLAB's Order of August 16, 1983).
The Governor's review of this matter is not yet complete. The answer does not specify pages and paragraphs of each referenced document since that information is as readily available to PG&E as it is to the Governor.'
INTERROGATORY NO. 109:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 109:
See Answer to Interrogatory No. 108.
INTERROGATORY NO. 110:
State each and every fact upon which you base your allegation that the IDVP has failed to verify whether equipment and componen ts supplied to PG&E by PG&E's subcontractor s met all seismic design requirements.
ANSWER TO INTERROGATORY NO. 110:
See Answer to Interrogatory No.108.
INTERROGATORY NO. 111:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response 67.
~ ._. -
and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
ANSWER TO INTERROMTORY NO. 111:
See Answer to Interrogatory No.108.
INTERROGATORY NO. 112:
State each and every fact upon which you base your allegation that the IDVP has failed to verify whether equipment supplied to PG&E by PG&E's subcontractor s met all non-seismic design requirements.
ANSWER TO INTERROGATORY NO. 112:
See Answer to Interrogatory No.108.
INTERROGATORY NO. 113:
Please iden tify each and every documen t which you claim supports e ach f act set for th in the preceding response and correlate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 113:
See Answer to Interrogatory No.108.
D4TERROGATORY NO. 114:
State each and every f act upon which you base your allegation that the IDVP has failed to require PG&E to implemen t a cor rective and preven tative action program that is sufficient to assure that the seismic design deficiencies that have been uncovered do not exist in other unexamined portions of the plant or will not be repeated in future design documents.
68.
ANSWER TO INTERROGPLTORY NO. 114:
i As stated in Answers to Interrogatories No. 66 and 124, the Governor's review of the IDVP's Interim Technical Repor ts (ITR's) has led to the conclusion that the root causes and generic implications of EOI's were not adequately addressed by the IDVP . The Governor believes that adequate consideration of the root causes and generic implications of identified deficiencies is essential to assure that similar problems will not occur in future design documents. The above discussion applies to seismic as well as non-seismic design deficiencies.
Examples identified in the Governor's review to date of EOI's for which the root causes and generic implications of the discovered deficiencies have not been adequately addressed may be found in Tables 66.1 and 124. Also see responses to Interrogatory No. 68 regarding inadequacies in the IDVP sampling of ITP activities.
The Governor's review of the ITP programs corrective and preventative action program is ongoing. Further, the j major ity of the IDVP ITR's regarding its review of this subject l
l have not yet been issued.
INTERROGATORY NO. 115:
Please iden tify each and every documen t which you claim supports each f act set forth in the preceding response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
i 69.
ANSWER TO INTERROGATORY nom 1158 Tables 66.1 and 124, referred to in the Response to Interrogator y No. 114, iden tify EOI's and the Interim Technical Reports in which the EOI's are discussed. Page and paragraph information is not given since that information is as .readily available to PG&E as it is to the Governor.
INTERROGATORY NO. I16:
State each and every fact upon which you base your allegation that the IDVP has failed to look for the root cause of the discrepancies it has found in the seismic design.
ANSWER TO INTERROGATORY NO. 116:
This conten tion is based on the absence of documentation by the IDVP of an eff ective pursuit of the root cause or causes of the discrepancies found in the seismic design of Diablo Canyon.
INTERROGATORY NO. 117:
Please iden tif y each and every document which you claim supports each f act set f orth in the preceding response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 117:
The specific IDVP materials page and paragraph can be cited. since the IDVP has f ailed to provide any documen tation l
of a thorough or eff ective pursuit of root causes.
INTERROGATORY NO. 118:
State each and every f act upon which you base your allegation that the IDVP has failed to recognize the generic l
70.
l
.-y - -
, - _ , . - ~ . ___ _ - _ _ . - . .-- _ _ _ -
nature of a numbar of ths caisnic dasign diccrcpancice uncovered.
ANSWER TO INTERROGATORY NO. 118:
This contention is based on the absence of documen tation by the IDVP of an effective pursuit of the generic, implications of the discrepancies uncovered on the seismic design of Diablo Canyon.
INTERROGATORY NO. 119:
Please identify each and every document which you claim supports e ach f act set forth in the preceding' response and cor relate each such documen t as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 119:
No specific IDVP materials, page and paragraph number can be cited, since the IDVP has failed to provide any documentation of a thorough or ef f ective pursuit of generic implications.
INTERROGATORY NO. 120:
State each and every fact upon which you base your allegation that the IDVP has failed to require PG&E to implemen t a cor rective and preven tative action program that is sufficient to assure that the non-seismic design deficiencies that have been uncovered do not exist in other, unexami ned portions of the plant or will not be repeated in future design documen ts .
71.
ANSWER TO INTERROGATORY NO. 120:
The Answer to Interrogatory No.114 addresses both seismic and non-seismic design deficiencies regarding a corrective and preventative action program review of the IDVP and therefore addresses Interrogatory No.120.
INTERROGATOR Y NO. 121:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 121:
See Answer to Interrogatory No. 115.
INTERROGATORY NO. 122:
State each and every fact upon which you base your allegation that the IDVP has failed to look for the root cause of the discrepancies it has found in the non-seismic design.
ANSWER TO INTERROGATORY NO. 122:
Interrogarory No.122 appears to be similar to Interrogatory No. 66, except in No.122 the Governor is asked to iden tify cases where the IDVP failed to "look for" root causes, whereas Interrogatory No. 66 asks for cases where the IDVP f ailed to " ascertain" root causes.
The Governor is unable to distinguish, based on the available documen tation, whether the IDVP f ailed to look for root causes, or looked for root causes but failed to ascertain 72.
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1 j
thca. Thorafero, tha rOsponca to Intarrcgatory No.122 iG tha same as the response to Interrogatory No. 66.
INTERROGATORY NO. 123:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO D9TERROGATORY NO. 123: i See Answer to Interrogatory No. 67.
INTERROGATORY NO. 124:
State each and every fact upon which you base your allegation that the IDVP has failed to recognize the generic nature of a number of the non-seismic design discrepancies uncove red.
ANSWER TO INTERROGATORY NO. 124:
The Governor's review of the IDVP's Interim Technical Repor ts (ITR's) is not yet complete.
There are essentially two ways to consider the generic nature of an iden tified deficiency in a plant system. The first is to actually search throughout other plant systems for similar problems (i.e. additional verification) . The second is to determine the root cause of the deficiency, or the sequence of events which led to the deficiency, and assess the potential for that root cause or series of events to impact other activities involving other plant systems (see answer no. 66).
As stated in the response to Interrogatory No. 66, the Governor 's review to da te has iden tified no instance in which 73.
the IDUP ascartoined tha root ccuco or ccquenco cf eventa which led to a1 discrepancy between the Diablo Canyon design and PG&E's licensing commitmen ts. Therefore, even in those cases where some additional verification was performed, the IDVP failhd'do iden tify the root cause of the discrepancy.
~
- I >
Table 124 sets forth those EOI's identified to date far~ which the Governor concludes that the IDVP has f aiJ ed to recognize the generic nature of the identified deficiencies.
TABLE 124 LISTING OF EOI RESOLUTIONS WHERE GENERIC NATURE WAS NOT ADDRESSED Resolved by Resolved by Mod if ication Analysis Other TOTAL 7 13 13 EOI's (ITR f) 8023 (24) 8005 (14) 8011 (21) 8024 (24) 8019 (18) 8014 (21) 8025 (24) 8020 (18) 8015 (22) 8026 (24) 8021 (18) 8027 (22) 8032 (18) 8022 (24) 8035 (18) 8060 (22) 8031 (21) 8036 (18) 8063 (25) 8038 (18) 8041 (26) 8039 (18) 8044 (25) 8040 (14) 8048 (22) 8045 (24) 8051 (27) 8049 (;2 3) 8053 (28) 8050 (21) 8055 (27) 8065 (48) 8056 '28) 74.
e *
- ge. > em we> y
INTERROGLTORY NO- 125:
Please iden tify 'each and every documen t which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 125:
Table 124 identifies the Interim Technical Reports in which the referenced EOI's are discussed. Page and paragraph information is not given since that information is as readily available to PG&E as it is to the Governor..
INTERROGATORY NO. 126:
State each and every fact upon which you base your allegation that the IDVP has failed to require PG&E to implemen t a corrective and preven tative action program that is sufficient to assure that the deficiencies in the design documsa ts of its equipment subcontractor s do not exist in the design documents of contractors whose work was not examined and will not occur in the design wor k of future subcontractor s.
ANSWER TO INTERROGATORY NO. 126:
The Governor believes that unless the root causes and generic implications of identified deficiencies are addressed, the deficiencies could exist in unreviewed portions of the plant. This includes portions where design was the responsibility of various subcontractor s (particularly since all would have had design interfaces with PG&E). Therr? ore, the considerations iden tified in response to Interrogatory No. 114 address this Interrogatory as well.
75.
. . I INTERROGhTORY NO. 127:
Please iden tify each and every document which you claim supporta each f act set forth in the preceding response
, and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act. ,
l ANSWER TO ENTERROGATORY NO. 127: 1 i
See Answer to Interrogatory No.115. j INTERROGATORY NO. 128:
State each and every fact upon which you base your allegation that the IDVP has no systematic program for reviewing whether the seismic design modifications it has requested that PGsE perform have occurred.
ANSWER TO INTERROGATORY NO. 128:
The Governor's review to date of Interim Technical Reports indicates that the IDVP did not verify that each and every design modification requested by the IDVP was performed by PG&E. Rather, the IDVP utilized samples to verify PG&E's performance of the modifications. The above applies both to seismic and no.'.-seismic modifications.
The Governor's review to date indicates that the IDVP's use of samples was generally deficien t as set forth in i the response to Interrogatories No. 60 and 68. The Governor believes that the IDVP has not utilized sampling techniques
- adequate to support the extrapolation of conclusions to entire plant populations. Therefore the Governor does not believe that the IDVP has developed and implemented a systematic 76 .
- , . .:r : . - :: . - ~ . . _ _ = _ . . - - _ - - - .- - . . - -_ _ _--_
- _ . - - _ _ - _ _ _ _ _ . = _ .-. -- .
progrca cufficicnt to ccours thst acch cnd svary rcquasted design modification has been implemen ted by PGsE.
I!ffERROGATORY NO. 129:
4 Please iden tify each and every document which you claim supports each f act set forth in the preceding response j and correlate each such document as specifically as possible (page and paragraph number) with e ach auch f act.
- ANSWER TO INTERROGATORY NO. 129:
! See Answer to Interrogatory No. 69.
1 INTERROGATORY NO. 130:
State each and every f act upon which you base your allegation that the IDVP has no systematic program for 1
reviewing whether the non-seismic design modifications it has I requested that PG&E perform have occurred.
j ANSWER TO INTERROGATORY NO. 130:
, Since the response to Interrogatory No.128 addresses this question for both seismic and non-seismic design modifications, see the response to Interrogatory No.128.
INTERROGATORY NO. 131:
Please iden tify each and every document which you
, claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
l ANSWER TO INTERROGATORY NO. 131:
See Answer to Interrogatory No. 69.
, 77.
, . - - --__ L . . ,l' . . , _ . ._ _ - :.-- - . , _ . - - -_.._ J - .-.,- '--- . . - -
h_ . .
INTERROGATORY NO., 132:
State each and every fact upon which you base your allegation that PG&E's Internal Technical Program ("ITP") does not provide assurance, equivalent to Appendix B compliance, that PGsE has and will meet its license commitments for the seismic design of SS&C's at Diablo Canyon.
ANSWER TO INTERROGATORY NO. 132:
The Governor 's response to this interrogatory is set forth in the responses to the preceding Answer to Interrogarory No. 131. Major su'b ject areas regarding the insufficient assurance relative to seismic design of SS&Cs provided by the ITP are set forth herein in Table 132.
The Governor's review of the ITP is not yet complete as described in detail in the referenced interrogatory responses. The answer does not specify pages and paragraphs of each referenced documen t since that information is as readily available to PG&E as it is to the Governor.
/
/
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78.
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TABLE 132 INSUFFICIENT ASSURANCE BY ITP SEISMIC DESIGN OF DIABLO CANYON SS&Cs
- 1. 1, 2, 3 Timely development and implemen tation of QA/QC program for design modifications since November 1,1981.
- 2. 62, 63 Mean values of structures and materials.
- 3. 70 to 101 Seismic design modeling.
- 4. 50 to 55 Scope of ITP seismic corrective action program.
- 5. 116 to 119, 66 Ascertainment of root causes and generic nature of design errors.
- 6. 69 Analysis of deviations from licen sing commi tmen ts.
- 7. 108 to 113 Review of equipment.
- 8. 114 Initiation of preven tative and corrective actions.
INTERROGATORY NO. 133:
Please identify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 133:
See Answer to Interrogatory No. 132.
INTERROGATORY NO. 134:
State each and every f act upon which you base your allegation that PG&E and its major subcontractors failed to develop and implemen t in a timely fashion a QA/QC program for the design of important to safety but not safety related SS&C's 79.
~
ct Dicblo C:nyon which met (cnd c20t) tho rcquir;ncnta of GDC-1 of Appendix A Jto 10 C.F.R. part 50 (" Appendix A") .
ANSWER TO INTERROETORY NO. 13 4 :
Pursuant to the ASLAB's oral ruling during the pre-hearing conference on August 23 - 29, 1983, the Board determined that Diablo Canyon's compliance with GDC-1 of Appendix A, and the IDVP review of such compliance, was an issue that will not be examined in the reopened hearing. Thus, the subject area addressed by this interrogatory is no longer relevant to the proceeding before the Board.
INTERROGATORY NO. 135:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 135:
See Answer to Interrogatory No. 13 4.
INTERROGATORY NO. 136:
State each and every f act upon which you base your allegation that the IDVP has not and will not provide any assurance, equivalent to Appendix A compliance that the design of important to safety but not safety related SS&C's at Diablo Canyon meets the regulatory requiremen ts for the design of such equipment.
ANSWER TO INTERROGATORY NO. 136:
l See Answer to Interrogatory No.134. {
l
- 80. '
, ~ . . . - . _ - .
l
INTERROGATORY NO. 137:
Please iden tify each and every document which you claim supports each f act set forth in the preceding response and correlate each such document as specifically as possible (page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. '137 :
See Answer to Interrogatory No.134.
INTERROGATORY NO. 138:
For each even numbered interrogatory from number 50 through number 130, state specifically (section I, page and line, etc.) where in the regulations, the Commission order of November 19, 1981, the Denton letter of November 19, 1981, or the IDVP's Phase I and II program plans that the activity (or lack thereof) by the IDVP you allege did (or did not) take place is required to take (or not take) place.
ANSWER TO INTERROGATORY NO. 138:
The Governor has not completeJ ane determination of where in the regulations, the Commission's order of November 19, 198 1, the Den ton letter of November 19, 1981, or the IDVP Phase I and Phase II program plans that the activities addressed by the design QA/QC contentions adopted by the Board, and described in PG&E interrogatories 50 through 130 herein, are set forth. In general, the Governor believes tha t Criterion III of Appendix B to 10 CFR 50 requires that measures be established by PG&E to assure that regulatory requirements as specified in the license application are correctly translated into specifications, procedures and inst r uc tions.
81.
e o Tha requir:ncnt fcr complicnca with th2 lic;nca cpplication commitmen ts is also provided in 10 CFR Sections 50.34(b) and 50.57 (a) . The requirement to determine the cause of conditions adverse to quality including " basic causes" is set forth in the Commission's November 19, 1981 order as well as in Criterion XVI of Appendix B. Further, as set forth in Criterion XVI, the corrective action measures shall be adequate to preclude repetition.
Criterion XVIII of Appendix B requires that PG&E carry out planned and periodic audits to verify compliance with all aspects of the quality assurance program and to determine the ef fectiveness of the program. In addition, as specified in Section 10 of ANSI /ASME Standa rd NOA-1-Pl79 en titled " Quality Assurance Program Requirements for Nuclear Power Plants" where sampling is used to verify acceptability of a group of items, the sampling procedure shall be based on recognized standard practices.
The Governor has provided a number of references to specific requirements of the regulations, Commission Order and Den ton letter in the body of the responses to Interrogatories 50 to 132. Furthermore, the Governor's review of the IDVP is not yet complete (nor is the IDVP complete as well documented in Supplement 18 of the Diablo Canyon SER) .
The answer does not specif y section number, page and line, etc. , of the referenced documents since that information is as readily available to PG&E as it is to the Governor.
82.
INTERROGPLTORY NO. 139:
Define " root cause" as used in your proposed contention II A 1 (c) .
ANSWER TO INTERROGATORY NO. 139:
See answer 13 (h) to PG&E's First Set of Interrogator ies to the Governor .
INTERROGATORY NO. 14 0:
Define "equipmen t standa rds" as used in your proposed contention II B 1 (b).
ANSWER TO INTERROGATORY NO. 140:
Pursuant to the discussions at the pre-hearing conference on August 23 and 29,198 3, the "equipmen t standa rds" used in the Governor's proposed contention refer to the licen sing commi tmen ts (criteria) set forth in the Diablo Canyon PSAR, FSAR, Hosgri Report, SER, SER Supplements, and other licensing documen ts relied upon by the NRC including letters to the NRC from PG&E.
INTERROGATORY NO. 141:
Please list each and every "equipmen t standard" set forth in PG&E's license commitments which you believe the IDVP has accepted deviations from.
ANSWER TO INTERROGATORY NO. 141:
See Answer to Interrogatory No. 64.
INTERROGATORY NO. 142:
Define " tor sion factor s" as used in your proposed contention II B 1 (q).
- 83. l
~ ~ ' ~ -
e D ANSWER TO INTERROGATORY NO. 142:
In its approach to accounting for accidental eccentricity in the Turbine Building and Intake Structure, PG&E takes into account the tor sion generated by accidental eccentricity by multiplying the horizontal motion by a f actor of 1.1. This is the factor referred to in the cited contention as " torsion f actor. "
INTERROGATORY NO. 143 :
Define " hydrodynamic forces" as used in your proposed contention II B 1 (r) .
ANSWER TO INTERROGATORY NO. 143 :
The term " hydrodynamic forces" is a well established one. It refers to forces exerted on a structure by fluids (predominantly water) due to the motion of one or the other. A typical example is wave forces when waves are generated by winds or tsunamis. Hydrodynamic forces are also generated by vibrations of the structure during an earthquake if the structure contains a fluid (i.e., sloshing in tanks) or if it is adjacent to a fluid (as in a dam) . The Intake Structure is subjected to both conditions, and it is to this type of force that the term refers.
INTERROGATORY NO. 144:
Define " generic nature" as used in your proposed contention II C 1 (b).
ANSWER TO INTERROGATORY NO. 144:
" Generic natu re" is the potential that an identified deficiency belongs to a larger group of deficiencies which may 84.
- ~: T:: ,__: . _ - - _ _ . _ _ _ - _ _ _ _ _ .
- o be charact:rized by c common typa, c common root cture, or c common series of events which led to their existence.
The generic nature of an identified deficiency (for instance, an EOI) is the potential for similar deficiencies to exist in other systems, structures or components of the plant, or for other deficiencies to exist due to similar causes or due to a similar series of events. See also response to Interrogatory No.124.
INTERROGATORY NO. 142 (sic) 145:
Please list each regulation, or regulatory guide, by specific section and/or subsection, which requires the iden tification of a " root" cause when a deviation occurs, or at any time, or which defines " root cause."
ANSWER TO INTERROGATORY NO. 145:
The Governor is not aware of any regulation or regulatory guide which defines " root cause." However, paragraph 5 (b) of Attachment 1 to the Commission's November 19, 1981 order states that the IDVP shall assess "to basic cause of all design errors identified." Further, in testimony by William Dircks, Executive Director for Operations of the NRC, to the U.S. House Subcommittee on Energy and the Environment, and to the Commission on November 19, 198 1, Mr. Dircks stated that in cases such as Diablo Canyon where QA/QC problems had been iden tified "the cor rective action taken was not suf ficiently br oad" and " too f requently, the response was one of treating the symptom, rather than finding the basic cause and correcting it."
85.
_)
e e Also, see answer to Interrogatory No.138 regarding the requirements for corrective action, and Interrogatory No.139 for the definition of " root cause."
INTERROGATORY NO. 143 (sic)146:
For each answer to these interrogatories, and all
' subparts thereto, identify each person who participated in the preparation of your answers pursuant to 10 C.F.R.
Section 2.740 (b)
ANSWER TO INTERROGATORY NO. 146:
Richard B. Hubbard assisted in the preparation of the Governor 's response to PG&E interrogator ies 1 to 49, 56 to 61, 64 to 69, 102 to 115, 120 to 141, and 144 to 146. Dr. Jose M.
Roesset assisted in the preparation of the Govern.t 's response to PG&E interrogatories 50 to 55, 62 to 63, 70 to 101,116 to 119, and 142 to 143 .
DATED: August 31, 1983 JOHN K. VAN DE KAMP, Attor ney General of the State of Calif ornia ANDREA SHERIDAN ORDIN, Chief Assistan t Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURB IN, PETER H. KAUFMAN, Deputy Attor neys General By '
SUSAN L. DURBM Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, Calif or nia 90010 (213) 736-2105 86.
9a9 - r ae- , - - . - . , . - , , - -,, . - ,. - -,,
e -o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PACIFIC GAS AND ELECTRIC CO. ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Unit Nos. 1 and 2 )
AFFIDAVIT OF RICHARD B. HUBBARD FOR GOVERNOR GEORGE DEUKMEJIAN RICHARD B. HUBBARD, being duly sworn, do say under oath that I, the undersigned have assisted in preparing and reviewing responses number 1 to 61, 64 to 69, 102 to 115, 120 to 141, and 144 to 146 of Governor Deukmejian to Pacific Gas and Electric Company's Second Set of Interrogatories, dated July 27, 1983. Said answers are true and correct to the best of my knowledge and belief.
/8 '
RICHARD B. HUBBARD Subscribed and sworn to before me this day /fpst)ff,1983.
N TA Y PUBLIC 9 e "m.cm r M mmission expires: O J/ / OFFICIAL SEAL i --
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3 JAMES F LEHMAN
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/ NOTARY puBLIC CAllF02N:A j
,k !ANTA CLAM COUhiY i.
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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.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 Answers to Applicant's Second Set of Interrogatories and know the contents thereof.
- 3. I am informed and believe said answers to be true and correct.
I certify undar penalty of perjury that the foregoing is true and correct.
Executed at Los Angeles, Calif ornia, on August 31, 1983.
Am>/
SUSAN L. DURBIN
. _ - . _ . ~ ,___._____,_,____ _ _ _ _ _ _ _
e .=
UNITED STATES OF AMERICA NUCLEAR REGUIATORY 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 )
Plan t , Units 1 and 2) )
)
CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing ANSWERS OF GOVERNOR DEUKMEJIAN TO APPLICANT'S SECOND SET OF INTERROGATORIES AND ANSWERS OF GOVERNOR DEUKMEJIAN TO APPLICANT'S THIRD SET OF INTERROGATORIES served on the following by U.S. Mail, first class (except f or those persons marked with an asterisk ("*"), to whom the envelope was posted Express Mail), postage prepaid.
Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washing ton, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission 1717 H Stree t, N.W.
Washing ton, D.C. 20555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tre e t , N.W.
Washing ton, D.C. 20555 i
1.
o =
Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washing ton, D.C. 20555 Hon. John Ahearne, commissioner U.S. Nuclear Regulatory Commission 1717 H Street, 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 Washington, D.C. 20555 Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Leonard Bickwit, Esq.
Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 2.
- c. m Lawrence Chandler, Esq.
- Henry J. McGurren, Esc.
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 Mrs. Raye Fleming 1920 Mattie Road Shell Beach , CA 93449 Mr. Frederd Eiscler Scen ic Shoreline Preservation Confe rence, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 Gordon Silver Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401 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 Bruce Nor ton, Esq.
- Nor ton, Burke, Berry & French 2002 East Osborn Phoen ix, AZ 85064 Philip A. C rane, Jr. , Esq.
- Richa rd F. Locke, Esq.
Pacific Gas and Electric Company San Francisco, CA 94120 3.
c, we David S. Fleischaker, Esq.
P. O. Box 1178 Oklahoma City, OK 73101 Arthur C. Gehr, Esq.
Snell & Wilmer ,
3100 Valley Bank Center Phoen ix, AZ 8507 3 i Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilbon Avenue, Suite K San Jose, CA 95125 Mr. Carl Neiberger Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Virginia and Gordon Bruno P ech o 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 1025 Conn ecticut Avenue, N.W.
Washington, D.C. 20036 DATED: August 31, 198 3 JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMNASSER, Special Counsel to the Attorney General SUSAN L. DURB IN, PETER H. KAUFMAN, Deputy Attor neys General By /
SUSAN L. DURBIN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2105 4.
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