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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20045D8561993-06-21021 June 1993 San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related Correspondence ML20045D8291993-06-18018 June 1993 Response to Third Set of Suppl Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6751993-06-0404 June 1993 Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence ML20045A6401993-05-26026 May 1993 PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence ML20044F7701993-05-21021 May 1993 Intervenor San Luis Obispo Mothers for Peace Second Set of Supplemental Interrogatories & Requests for Production of Documents to Pge Cable Failures at Diablo Canyon Nuclear Power Plant.* W/Certificate of Svc.Related Correspondence ML20056C1891993-03-10010 March 1993 Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence ML20128P2251993-02-16016 February 1993 Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories & Requests for Production of Documents to Pg&E.* PG&E Should Answer Interrogatories within 14 Days.W/Certificate of Svc.Related Correspondence ML20213E5791986-11-0606 November 1986 Response to Util Second Set of Interrogatories Re Reracking of Spent Fuel Pools.Equations of Motion Appear in Encl Computer Program.W/Proof of Svc ML20213E6091986-11-0606 November 1986 Response to NRC Second Set of Inerrogatories Re Proposed Reracking of Spent Fuel Pools.Not Possible to Either Identify or Supply All Ref Documentation Supporting Contentions.W/Proof of Svc.Related Correspondence ML20213E6201986-11-0606 November 1986 Response to NRC Second Set of Interrogatories.Contentions Re Proposed Reracking & Alternatives Based on Understanding of Existing Industry Practice & Currently Available Technology. W/Proof of Svc.Related Correspondence ML20213F5851986-11-0505 November 1986 Suppl to 861003 Response to Intervenors 860916 First Set of Interrogatories Re Metals Used in Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20213F5011986-11-0505 November 1986 Response to 861017 Second Set of Interrogatories Re Seismic Analysis of High Density Fuel Racks for PG&E for Diablo Canyon Nuclear Power Station & Request for Production of Documents.W/Certificate of Svc.Related Correspondence ML20211E2121986-10-20020 October 1986 Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence ML20215H6691986-10-20020 October 1986 Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence ML20211E1721986-10-20020 October 1986 Second Set of Interrogatories Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses on Spent Fuel Pool.Related Correspondence ML20211E1871986-10-20020 October 1986 Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence ML20210S8921986-10-0606 October 1986 Response to Util Interrogatories Re Preparation for Upcoming Safety Hearings on Reracking of Spent Fuel Pools.Safety Issues Should Be Considered Before Amend Accepted.W/ Certificate of Svc.Related Correspondence ML20210S9651986-10-0606 October 1986 Answers to Sierra Club 860915 First Set of Interrogatories Re Reracking of Spent Fuel Pools.W/Certificate of Svc. Related Correspondence ML20210T2611986-10-0606 October 1986 Response to NRC Interrogatories on Contention 1 Re Util Responsibility to Demonstrate Safety of High Density Reracking.Intervenors Not Responsible for Solving Waste Storage Problem.W/Certificate of Svc.Related Correspondence ML20210S9711986-10-0303 October 1986 Response to Util & NRC First Set of Interrogatories & Request for Production of Documents.Interrogatories Opposed for Reasons Indicated.Certificate of Svc Encl.Related Correspondence ML20210T0731986-10-0303 October 1986 Response to Interrogatories & Request for Production of Documents Re Alternatives to High Density Reracking of Spent Fuel Pool at Facilities.Certificate of Svc Encl.Related Correspondence ML20210T0221986-10-0303 October 1986 Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence ML20210S9241986-10-0303 October 1986 Response to San Luis Obispo Mothers for Peace First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20206U7481986-10-0303 October 1986 Response to 860916 Interrogatories & Request for Production of Documents Re Licensing Proceedings.Certificate of Svc Encl.Related Correspondence ML20210S9931986-10-0303 October 1986 Response to Consumers Organized for Defense of Environ Safety First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20210T0541986-10-0303 October 1986 Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20210B7341986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc ML20214P8291986-09-16016 September 1986 Requests Response to Listed Interrogatories Re Design & Const of Fuel Ponds.Certificate of Svc Encl.Related Correspondence ML20214Q3521986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210B6321986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds ML20214Q3781986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions I & II Concerning Reracking of Spent Fuel Pools.Notice of Change of B Norton Address & Certificate of Svc Encl.Related Correspondence ML20210B6701986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools ML20214Q2981986-09-16016 September 1986 First Round of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20214Q3621986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210E1781986-09-15015 September 1986 Interrogatories & Request for Production of Documents Re Theoretical Work Concerning Displacement of High Density Spent Fuel Racks Due to Hypothetical Seismic Excitation. W/Certificate of Svc.Related Correspondence ML20214R1401986-09-15015 September 1986 Interrogatories Requesting All Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools, Dry Cask Onsite Storage & Cost/Benefit Assessment on Reracking.Certificate of Svc Encl.Related Correspondence ML20214R2341986-09-15015 September 1986 Interrogatories Requesting Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools & Dry Cask Onsite Storage as Alternative to High Density Reracking.Certificate of Svc Encl.Related Correspondence ML20081D7851983-10-26026 October 1983 Request for Production of Documents by NRC at 831107 Hearing in Avila Beach,Ca.Certificate of Svc Encl ML20080S2831983-10-14014 October 1983 Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20080Q3741983-10-0707 October 1983 Second Supplemental Answers to First Set of Interrogatories. Certification of Counsel & Prof Qualifications Encl ML20080Q3851983-10-0707 October 1983 First Supplemental Answers to Second Set of Interrogatories. Certification of Counsel Encl ML20080Q3951983-10-0707 October 1983 First Supplemental Answers to Fourth Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl ML20085J5951983-10-0707 October 1983 Fifth Supplemental Response to First Set of Interrogatories. Portions of RB Hubbard & Fj Samaniego 821221 Direct Testimony & Certificate of Svc Encl ML20080Q4441983-10-0505 October 1983 Response of Idvp to Interrogatory 57 in Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20078E1861983-10-0303 October 1983 Fourth Supplemental Response to First Set of Interrogatories.Certificate of Svc Encl ML20078D5091983-09-29029 September 1983 Supplemental Response to Second Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl.Related Correspondence ML20080M8521983-09-28028 September 1983 First Supplemental Answers to Third Set of Interrogatories. Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20078E1331983-09-28028 September 1983 First Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20080L5721983-09-26026 September 1983 Response to Fourth Set of Interrogatories.Certification of Counsel & Certificate of Svc Encl ML20078B8021983-09-23023 September 1983 Idvp Answers to First Set of Interrogatories.Certificate of Svc Encl 1993-06-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059C7361993-08-24024 August 1993 Intervenor Exhibit I-MFP-88,consisting of NRC Insp of Diablo Canyon Units 1 & 2 IR 05000275/19920161993-08-24024 August 1993 Intervenor Exhibit I-MFP-137,consisting of Insp Rept Re Dockets 50-275/92-16 & 50-323/92-16,dtd 920707 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059M5041993-08-24024 August 1993 Staff Exhibit S-2,consisting of Re Notice of Violation ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 1999-09-20
[Table view] |
Text
IUL*.TE COEIPc.EPONDEMI; law CFFsCES IDWENSTEIN, NzwxAN, REIS & AxzLnAn, P. C.
1025 CONNECTICUT AVENUE, N. W.
WAS Hi rd GTON, D. C. 20036 JACm n, newesan samoLo r.mais "o' " '-**
"J"J'."O" J. A. 90W KneGMT, JR.
eseCuagL A.SAUStm -
oogskas 0,onttu postRTLDwtusTtsu DAYIO G. PowtLL OF CoweestL ALVIN M. GUTTEWesaN
- e. c.c.o.T e u.. .
JangT t.a.ECasa CTEvCN P. FRaNTE JsLL E.0mawT July 15, 1983 mouk, ..r ..c L.. ..
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0)
- N5w Michael J. Strumwasser, Esquire W W 3580 Wilshire Boulevard $-
Suite 600 Los Angeles, CA 90010 t N 131983 5 ) y / ,
C&ccr rwg Joel R. Reynolds, Esquire 'N ', d Center for Law in the Public ')J G'<
Interest
_f 10951 West Pico Boulevard Third Floor Los Angeles, CA 90064 Re: Pacific Gas and Electric Company (Diablo Canyon Nuclear Project, Units 1 and 2), Docket Nos.
50-275 OL, 50-323 OL
Dear Mr. Strumwasser and Mr. Reynolds:
The enclosed interrogatory responses supplement the
' Independent Design Verification Program's initial responses to your first set of interrogatories, which were filed by PGandE on May- 23, 1983. The enclosed responses answer Inter-rogatory One with respect to the three ITR's (46, 47 and 49) which have been issued since that date.
Sincerely, 4E David B. Paskin Attorney for the Independent Design Verification Program Enclosures cc: Service list B307190153 830715 PDR ADOCK 05000275 O PDR
- 1-46-1 ITR-46 Additional Verification of Selection of System Design Pressure and Temperature and Differential Pressure Across Power - Operated Valves
- 1. With respect to each ITR, including all revisions, except ITR 36 and 38, state:
- a. What contractors and subcontractors to the IDVP worked on the ITR?
Answer:
Teledyne Engineering Services Stone & Webster Engineering Corporation (SWEC)
- b. The person employed or retained by the IDVP or its subcon-tractors most knowledgeable about the ITR.
Answer:
John Edward Krechting, Project Engineer, SWEC
- c. The person employed or retained by the IDVP or its subcon-tractors most knowledgeable about:
(i) data collection for the ITR; Answer:
Karl Andrew Swenson, Lead Power Engineer, SWEC (ii) analyses performed for the ITR; Answer:
! Karl Andrew Swenson l
(iii) the conclusions of the ITR;
! . Answer:
John Edward Krechting I
+ ~ - -
. ~ . .. - - .
a 2 1. - 1-46-2 p
(iv) documentation of the ITR.
Answer:
Karl Andrew Swenson
- d. What reports the IDVP received from the DCP in connection l
-with the ITR - and, with respect to each, whether the IDVP b relied upon it.
! Answer:-
Relied Report On o FSAR Yes.
o Westinghouse System Description from Steam Systems Yes.
Design Manual-o Identification of revision dates to the applicable Yes.
i design codes for piping, valves, flanges, and equipment o DCNPP-1 Technical Specifications- Yes.
l o Basis for design pressure and temper,ature selection Yes.
including calculations o Minimum wall calculation for 24" safety valve headers Yes.
(Line numbers 1065,1066)
I o Main Steam Pressure vs. Plant Load Curve Yes.
I o- Information provided by Design Criteria Memorandum Yes.
M46 as it applies to-the CCW and MS Systems fo: Index for Design Criteria Memoranda No.
o Checklist of'all mechanical equipment, piping Yes.
fittings and components reviewed o Checklist of power - operated valves Yes.
l i
.c !. ,
. . . ~ . , - _ , . . . . - -. . - , , . _ - -. .-
1-46-3
- e. In categorical terms, what other information the IDVP received from the DCP in connection with the ITR, and with respect to each category:
(i) whether the IDVP independently verified the information received; (ii) if it did, how it verified the information.
Answer:
Information Verification o Specifications or Specification No.
Data Sheets for all system equip-ment that includes rated tempera-ture and pressure o Set points and size of all pressure No.
or thermal relief valves o Specification Data Sheets for all No.
regulating valves, including infor-mation on maximum differential pressure for actuator sizing o All piping drawing showing equip- Yes; various components were ment and piping elevations field verified for elevation o' Notification to the IDVP that the No.
systems identified in section 4.2 of ITR 34 have been reviewed by the DCP and the results of that review are final l
0 Component cooling water pump curves No.
l
- f. What computer models were employed in performing analyses in con-l.
! nection with the ITR:
Answer:
None. ,
l l
1-47-1 ITR-47 Additional Verification of Environmental Consequences of Postulated Pipe Ruptures Outside of Containment
- 1. With respect to each'ITR, including all revisions, except ITR-36 and ITR-38, state:
- a. What contractors and subcontractors to the IDVP worked on the ITR?
Answer: .
Teledyne Engineering Services Stone & Webster Engineering Corporation (SWEC)
- b. The person employed or retained by the IDVP or its subcon-tractors most knowledgeable about the ITR.
Answer:
John Edward Krechting, Project Engineer, SWEC 4
- c. The person employed o'r retained by the IDVP or its. subcon-tractors most knowledgeable about:
(i) data collection for-the ITR; Answer:
Charles Frances Bergeron, Lead Nuclear Engineer, SWEC (ii) analyses performed for the ITR; j Answer:
Charles Frances Bergeron (iii) the conclusions.of the ITR; Answer:
! John Edward Krechting (iv) documentaticn of the ITR; 1
O n - r --
e
- - 1-47-2 Answer:
Charles Frances Bergeron
- d. What reports the IDVP received from the DCP in connection with- the ITR and, with respect to each, whether the IDVP relied upon it.
Answer:
Relied Report On o PGandE completion package for E01 File 8001 Yes.
o ' Letter from AEC to PGandE, " General Information Yes. -
Required for Consideration of the Effects of a Piping System Break Outside Co'ntainment", 12-18-72 o Letter from AEC to PGandE, " General Information Yes.
Required for Consideration of the Effects of a Piping System Break Outside Containment",1-29-73 o Computer Program FLUD Description Yes.
o DCP calculation PT-2.1: Area GE/GW-Elevation 115', Yes.
Elevation 100', and Elevation 85', Pressure and Temperature Analysis in Compartments Due To Pipe Break Outside Containment o DCP calculation M-222: Compartment Characteristics Yes, for GE and GW Areas o DCP calculation M-287: GE/GW, Building Structural Yes.
Characterization i
o DCP Calculation M-221: Compartment Characteristics Yes.
for Turbine Building f
L o DCP calculation PT-1.1: Pressure and Temperature Yes.
AnalysisforTurbineBuilding(As-BuiltConditions)-
Computer Model, Echo Input, and Blowdown Data; Com-l partment Peak Pressure and Temperature Results -
l 0 DCP Calculation M-297 (sections 1, 2, & 3): Physical Yes.
Characteristics of Compartments.in the Auxiliary Building - Unit 1
l 1-47-3 Relied Report On o DCP calculation No. 2202: Circumferential Pipe Yes.
Break in Steam Supply Line to Auxiliary Feedwater Turbine o DCP calculation No. 2205: Flow Rates Through Pipe Yes.
Breaks in Lines; 112, 113, 1663, 26, 1749, 1750, and 593 o DCP calculation M-355: Pressure - Temperature Yes.
Analysis for the Auxiliary Building-(H, K, J, L) -
Assumptions on worst pipe and worst break in each compartment and deletions of vent paths o DCP calculation No. 2207: Auxiliary Building Yes.
Pressure / Temperature Transient (Area L) o DCP calculation No. 2206: Pressure and Temperature Yes.
in Auxiliary Building Compartments Due to Pipe Break o PGandE letter to NRC, dated 1/28/80, re: auxiliary Yes.
feedwater flow rate o Information from PGandE providing tu'rbine building Yes.
galbestos siding data o Information from PGandE providing data on bird Yes.
screen located in turbine building roof monitor l
o Information from PGandE that provided data on Yes.
blowout panel in area GW
- e. In categorical terms, what other information the IDVP l
received from the DCP in connection with the ITR, and with respect to each category:-
(i) whether the IDVP independently verified the infor-l mation received; l
(ii)' if it did, how it verified the information.
l L
i
I I
1-47-4 Answer:
Information Verification o Equipment Location Yes; general locations of equipment, compartment ar-rangements, and compartment openings in areas GE, GW, and the turbine building (el 140') were field verified for development of geometric models.
o Concrete drawings Yes; same.
o Drawings which show building Yes; same.
penetrations o Main steam Yes; general location of main piping schematic steam system in areas GE, GW, and the turbine building were field verified for develop-m,ent of geometric models, o Piping and mechanical Yes; same.
drawings o Structural steel drawings Yes; general locations of steel and siding in areas GE, GW, and the turbine building (el 140') were field verified for development of geometric models, o Turbine building siding Yes; same.
drawings o PGandE Drawing No. 049021-18 No.
Piping Specification Index o Drawing No. 69-XA-25-9 No.
assembly of 28-inch x 24-inch x 28-inch Main Steam Line Valve i
1-47-5 Verification Information o PGandE Drawing No. 102040-9 No.
.Line Designation Table o CRVP system duct drawings Yes; field verified for general location of equipment ducts.
o PGandE Drawing No. 59650 Yes; field verified general Roof Access Details-Turbine location of opening in roof Building o Air Conditioning Control Room Yes; field verified general Pressurization System Ducting location in turbine building Details Drawings for development of geometric nodalization,
- f. What computer models were employed in performing analyses in connection with the ITR:
(1) if the model was obtained from an outside source, Answer: .
None f.(ii) if the model was not obtained from an outside source,
- the identity of the person or persons having over-all responsibility for_ developing the model,
- the name or names by which the model is known, the general function of the model,
- the computer language in which the model was
. written, .
in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of - the computer or computers on -which the computer model was run in connection with the ITR.
l i
l
"Y
-*- 1-47-6 .
Answer:
- SWEC
- Version 12, Level 03, NU-092, Subcompartment Transient Response (THREED)
- The program calculates the transient pressure, temperature, and humidity in subcompartments following a postulated rupture in a moderate or high energy pipeline.
- FORTRAN IV - 98 percent ,
BAL - 2 percent
- Benchmarked with industry codes RELAP 4 Mod 5 and COMPARE Mod 0 and manual verification of various phenomena.
IBM 370/3033 t
4
,-o , - , - , - - - -
1-49-1 ITR-49 Additional Verification Circuit Separation and Single Failure Review of Safety-Related Electrical Equipment
- 1. With respect to each ITR, including all revisions, except ITR 36 and 38, state:
- a. What contractors and subcontractors to the IDVP worked on the ITR7 Answer:
Teledyne Engineering Services Stone & Webster Engineering Corporation (SWEC)
- b. The person employed or retained by the IDVP or its subcon-tractors most knowledgeable about the ITR.
Answer:
John Edward Krechting, Project Engineer, SWEC
- c. The person employed or retained by the IDVP or its subcon-tractors most knowledgeable about:
-(i) data collection for the ITR; Answer:
Frank James Rezendes, Lead I&C Engineer, SWEC (ii) analyses performed for the ITR; Answer:
Frank James Rezendes (iii) the conclusions of the ITR; Answer:
John Edward Krechting
I .
1-49-2 (iv) documentation of the ITR.
Answer:
Frank James Rezendes 1
- d. What reports the IDVP received from the DCP in connection with the ITR and, with respect to each, whether the IDVP relied upon it.
Answer:
Relied Report On o FSAR Yes.
o PGandE Resolution packages for E0I Files 8017 Yes.
and 8057.
- e. In categorical terms, what other information the IDVP received from the DCP in connection with the ITR, and with respect to each category:
(i) whether the IDVP independently verified the information received; (ii) if it did, how it verified the information.
Answer:
Information Verification o Electrical schematics Yes; for selected sample sys-tems mutually redundant cir-cuits identified by DCP analy-sis o Electrical connection diagrams Yes; field verified separation for selected sample systems o Letter from PGandE. Yes; verified DCP circuit separation review for selected sample systems verified DCP performed o' DCP failure analysis Yes; single failure analysis
e 1-49-3
~ ,
i f. What computer models were employed in performing analyses in con-nection with the ITR:
Answer:
None.
4 2
1 4
0 3
0'
~
3 D
STATE OF MASSACHUSETTS SS:
COUNTY OF MIDDLESEX l
The undersigned, William E. Cooper, being duly sworn this 13th day of July,1983, upon his oath states that he is employed by Teledyne Engineering Services (TES) as a Consulting Engineer and is assigned as Project Manager for the DCNPP-1 IDVP for which Teledyne Engineering Services is the Program Manager, that he is informed en the matters of inquiry of Interrogatory 1 (a) through (f) of the First Set of Interrogatories Propounded to Pacific Gas and Electric Company by Governor Deuksejian and Joint Intervenors; that in answering the above and foregoing Interrogatory with respect to ITR's 46, 47 and 49, he has personally revicwed or caused others to review the files and records of Teltdyne Engineering Services and Stone & Webster Engineering Corporation; has caused information to be gathered from employees and of ficers of the above; and that the answers to the above and foregoing interrogatory are true and correct as he has been informed and verily believes.
$~ %
William E. Cooper July 13, 1983 f]maswt'/h . Z5m L -
c % miss&., Eryires
- kvetry ? 3, / 9f?
l'
3 UNITED STATES OF AMERICA s
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of- )
)
PACIFIC' GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant ) i Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of the Independent Design Verification Program's supplemental answers to Governor George Deukmejian's
' First Set of Interrogatories have been served on the following 4 by deposit in the United States mail, first class, postage pre-7 paid, this 15th day of July 1983: >
Dr. John H. Buck Dr. Jerry Kline i Atomic Safety and Licensing Appeal Administrative Judge Board Atomic Safety and Licensing U.S.. Nuclear Regulatory Commission Board Washington, D.C. ~20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I 'Dr.=W. Reed Johnson
. Atomic Safety and Licensing Appeal Philip A. Crane., Jr., Esq.
Pacific Gas and Electric Company Board U.S. Nuclear Regulatory Commission P.O.. Box ~7442 Washington, D.C. 20555 San Francisco, CA 94120 Thomas S. Moore, Esq., Chairman Mr.. Frederick Eissler Atomic Safety and Licensing Appeal Scenic Shoreline Preservation Conference, Inc.
Board (U.S. Nuclear Regulatory Commission 4623 More Mesa Drive l
Washingtoni D.C. 20555 Santa Barbara, CA 93105 L
John F.' Wolf, Esq. Mrs. Raye Fleming
' Administrative Judge 1920 Mattie Road l
Atomic-Safety"and Licensing Board Shell Beach, CA 93449
'U.S. Nuclear Regulatory Commission Richard E. Blankenburg, p
Washington,.D.C. '20555 Co-publisher-I 1Mr. Glenn O. Bright Wayne:A. Soroyan, News' Reporter.
Administrative Judge South County Publishing Company
.P.O.-Box 460 Atomic Safety.and Licensing Board.' -Arroyo. Grande, CA 93420 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael J.:Strumwasser,-Esq.
- Lawrence J.LChandler
. Susan L.'Durbin, Esq..
, Peter H.>Kaufman, Esq.
- Office of Executive Legal Director ~3580 Wilshire. Blvd., Suite'600
BETH 042 Los Anaeles, CA 90010
'U.S. Nuclear Regulatory;Ccamission-zwashington,.D;C. '20555
_u__._a-______2 ___.s - . . . . . _ . - . . , , . , , . . . , _ . _ , v.m ..,y ., y p... , .,,4, _-
3 y., ,w,
Elizabeth Apfelberg Harry M. Willis
- 1415 Cozadero Seymour & Willis San Luis Obispo, CA 93401 601 California St., Suite 2100
- San Francisco, CA 94108 Mr. Gordon Silver Mrs. Sandra A. Silver Janice E. Kerr, Esq.
1760 Alisal Street Lawrence Q. Garcia, Esq.
San Luis Obispo, CA 93401 350 McAllister Street San Francisco, CA 94102 Joel R. Reynolds, Esq.
John R. Phillips, Esq. Mr. James O. Schuyler Center for Law in the Public Nuclear Projects Engineer Interest Pacific Gas and Electric Company 10951 West Pico Boulevard 77 Beale Street Third Floor San Francisco, CA 94106 Los Angeles, CA 90064 Paul C. Valentine, Esq.
Arthur C. Gehr, Esq. 321 Lytton Avenue Snell & Wilmer Palo Alto, CA 94302 3100 Valley Center Phoenix, AZ 85073 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mark Gottlieb Washington, D.C. 20555 California Energy Commission MS-18 Atomic Safety and Licensing Appeal 1111 Howe Avenue Board Sacramento, CA 95825 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Bruce Norton, Esq.
Norton, Burke, Berry & French, Docketing and Service Section P.C. U.S. Nuclear Regulatory Commission 2002 E. Osborn Road Washington, D.C. 20555 P.O. Bcx 10569 Phoenix, AZ 85064 Mr. Thomas H. Harris, Energy Writer San Jose Mercury News David S. Fleischaker, Esq. 750 Ridder Park Drive P.O. Box 1178 San Jose, CA 95190 Oklahoma City, OK 73101 John Marrs, Managing Editor Richard B. Hubbard San Luis Obispo County MHB Technical Associates Telegram-Tribune 1723 Hamilton Avenue - Suite K 1321 Johnson Avenue San Jose, CA 95125 P.O. Box 112 San Luis Obispo, CA 93406 lh $ Aw'
~ '
David'B. Raskih Attorney For The Independent Design Verification Program