ML20077D747
| ML20077D747 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/25/1983 |
| From: | Locke R PACIFIC GAS & ELECTRIC CO. |
| To: | CALIFORNIA, STATE OF |
| References | |
| NUDOCS 8307270147 | |
| Download: ML20077D747 (66) | |
Text
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D UNITED STATES OF AMERIChr c)
NUCLEARREGULATORYCOMMIjSION [. -
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,p BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL._ BOARD-tr. Y )' .[T,!
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- In the Matter of )
. ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323
) [ Reopened Proceeding -
Diablo Canyon Nuclear Power Plant ) Design Quality Assurance)
Units Nos. 1 and 2 )
)
l APPLICANT PACIFIC GAS AND ELECTRIC COMPANY's ANSWERS TO GOVERNOR GEORGE DEUKMEJIAN's !
SECOND SET OF INTERROGATOR,IES INTERROGATORY NO. 1:
When did PG&E first commit itself to comply with Appendix B in the design of Diablo Canyon?
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RESPONSE TO INTERROGATORY NO. 1: l July 10, 1969 INTERROGATORY NO. 2:
In what form was the commitment to comply with Appendix B made?
4 RESPONSE TO INTERROGATORY NO. 2:
It was made in Amendment 4 to the Preliminary Safety Analysis Report (PSAR) for Unit 2, Diablo Canyon Power Plant.
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- 2 INTERROGATORY NO. 3:
To what extent did the commitment apply to work performed before the date of the commitment?
RESPONSE TO INTERROGATORY NO. 3:
The commitment was not applied to prior work.
INTERROGATORY NO. 4:
If the commitment identified in your answer to Interrogatory No. 1 was other than an unconditional commitment to comply fully with all terms of Appendix B for design of Diablo Canyon, (a) What was the extent of the commitment made at that time?
(b) Was that commitment ever enlarged by PG5E?
(c) If it was ever enlarged, identify each and every commitment by PG&E to enlarge compliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the form in which the commitment was made.
RESPONSE TO INTERROGATORY._NO. 4:
(a) PG&E committed to comply with Appendix B for Unit 1 to the extent possible considering the status of design and construction at that time.
(b) No.
(c) Not applicable.
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O r INTERROGATORY NO. 5:
When did PG&E first commit itself to comply with the quality assurance requirements of Appendix A in the design of ,
Diablo Canyon?
RESPONSE TO INTERROGATORY NO. 5:
Issuance of construction permits for both units and a substantial portion of the design of the Diablo Canyon Units predated the adoption of Appendix A to 10 CFR 50 (published by the Atomic Energy Commission (AEC) in February, 1971). As stated in Section 3.1 of the Diablo Canyon Final Safety Analysis Report (PSAR), the Diablo Canyon Units were designed to comply with the " General Design Criteria for Nuclear Power Plant Construction Permits" published by the AEC in July, 1967. The relationship of the plant design to the 1967 General Design Criteria was set forth in Chapter 1 of both the Unit 1 and Unit 2 PSARs. The Unit 1 and Unit 2 PSARs were submitted with the Construction Permit Applicationc on January 16, 1967 and June 28, 1970, for Units 1 and 2, respectively. Appendix 3.lA of the Diablo Canyon FSAR compares the plant design with the general design criteria contained in Appendix A to 10 CFR
- 50. With respect to the quality requirements of Design Criterion 1, this comparison concludes that "the Diablo Canyon Units 1 and 2 designs conform with the intent of Criterion 1".
INTERROGATORY NO. 6:
In what form was the commitment to comply with the quality assurance requirements of Appendix A made?
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' o RESPONSE TO_ INTERROGATORY NO. 6:
See response to Interrogatory 5.
INTERROGATORY NO. 7:
To what extent did the commitment apply to work performed before the date of the commitment?
RESPONSE TO INTERROGATORY NO. 7:
See response to Interrogatory 5. Quality requirements contained in Appendix A to 10 CFR 50 did not apply to design performed prior to its adoption.
INTERROGATORY NO. 8:
If the commitment identified in your answer to Interrogatory No. 5 was other than an unconditional commitment to comply fully with all terms of the quality assurance requirements of Appendix A for design of Diablo Canyon, (a) What was the extent of the commitment made at that time?
(b) Was that commitment ever enlarged by PG&E?
(c) If it was ever enlarged, identify each and every commitment by PG&E to enlarge compliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the form in which the commitment was made.
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o e RESPONSE TO INTERROGATORY NO. 8:
See response to Interrogatories 5 and 7. Design work which was begun after the adoption of Appendix A to 10 CPR 50 was based on the quality requirements contained in Criterion No. 1.
INTERROGATORY NO. 9:
When did PG&E first commit itself to comply with the quality assurance requirements of Appendix A in the design of Diablo Canyon SS&Cs that are important to safety but not safety-related?
RESPONSE TO INTERROGATORY NO. 9:
See response to Interrogatories 5 through 8. Also, refer to PG&E's response dated May 23, 1983 to Governor Deukmejian's First Set of Interrogatories. PG&E's answers to Interrogatories Nos. 12 and 13 clearly state PG&E's understanding of the meaning of the terms "important-to-safety" and " safety-related". The term "important to safety" was not used in the 1967 " General Desic1 Criteria for Nuclear Power Plant Construction Permits" but appeared in the final version of Appendix A to 10 CPR 50 published in February 1971. For purposes of its compliance with General Design Criterion 1, PG&E considers that the term "important-to-safety" as used in Appendix A to 10 CFR 50 is synonymous both with the term
" safety-related" as used in other sections of NRC rules and regulations and with "PGandE Design Class I "
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f C INTERROGATORY NO. 10:
In what form was the commitment made to comply with the quality assurance requirements of Appendix A in the design of Diablo Canyon SS&Cs that are important to safety but not safety-related?
RESPONSE TO INTERROGATORY NO. 10:
See response to Interrogatory 9.
INTERROGATORY NO. 11:
To what extent did the commitment apply to work performed before the date of the commitment?
RESPONSE TO INTERROGATORY NO. 11:
See response to Interrogatory 9.
INTERROGATORY NO. 12:
If the commitment identified in your answer to Interrogatory No. 9 was other than an unconditional commitment to comply fully with all terms of the quality assurance requirements of Appendix A for design of Diablo Canyon SS&Cs that are important to safety but not safety-related, (a) What was the extent of the commitment made at that time?
(b) Was that commitment ever enlarged by PG&E7 (c) If it was ever enlarged, identify each and every commitment by PG&E to enlarge compliance, specifying
, (i) when the commitment was made l
(ii) what the extent of the enlarged commitment was, and j l
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e a (iii) the form in which the commitment was made.
RESPONSE TO INTERROGATORY NO. 12:
See response to Interrogatory 9.
INTERROGATORY NO. 13:
When did PG&E first commit itself to comply with WAS!!-1283 in the design of Diablo Canyon?
RESPONSE TO INTERROGATORY NO. 13:
PGandE has never committed to comply with WASH-1283 for design of Diablo Canyon.
INTERROGATORY NO. 14:
In what form was the commitment to comply with WASil-1283 made?
RESPONSE TO INTERROGATORY NO. 14:
Not applicable, i
INTERROGATORY NO. 15:
To what extent did the commitment apply to work performed before the date of the commitment?
m RESPONSE TO INTERROGATORY NO. 15:
Not applicable.
INTERROGATORY NO. 16:
If the commitment identified in your answer to Interrogatory No. 13 was other than an unconditional commitment to comply fully with all terms of WASH-1283 for design of Diablo Canyon,
, (a) What was the extent of the commitment made at that time?
(b) To what extent did the commitment apply to work performed before the date of the commitment?
(c) Was that commitment ever enlarged by PG&E7 (d) If it was ever enlarged, identify each and every commitment by PG&E to enlarge compliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the form in which the commitment was made.
RESPONSE TO INTERROGATORY NO. 16:
Not applicable.
INTERROGATORY NO. 17:
With respect to each of the ANSI standards specified below in items A through G, state separately:
(a) When did PG&E first commit itself to comply with the standard in the design of Diablo Canyon?
(b) In what form was the commitment to comply with the standard made?
(c) With which revision of the standard did PG&E commit itself to comply, and to what extent did PG&E l
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e i subsequently commit itself to comply with later revisions?
(d) To what extent did the commitment apply to work performed before the date of the commitment?
(e) If the commitment identified in your answer to item (b),
above, was other than an unconditional commitment to comply fully with all terms of the standard for the design of Diablo Canyon:
(1) What was the extent of the commitment made at that time?
(2) Was that commitment ever enlarged by PG&E7 (3) If it was ever enlarged, identify each and every commitment by PG&E to enlarge compliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment was, and (iii) the form in which the commitment was made.
The stardards to which this interrogatory refers are:
(A) ANSI N45.2 (B) ANSI N45.2-9 .
(C) ANSI N45.2.10 (D) ANSI N45.2.11 (E) ANSI N45.2.12 (F) ANSI N45.2.13 (G) ANSI N45.2.23.
RESPONSE TO INTERROGATORY NO. 17:
ITEM (A) ANSI N45.2
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(a) September 28, 1973.
(b) PGSE committed to ANSI N45.2 in the original Diablo Canyon FSAR.
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(c) PG&E committed to ANSI N45.2-1971 and has not changed that commitment.
- (d) Not at all.
(e) The commitment to ANSI N45.2 was unconditional.
ITEM (B) ANSI N45.2.9 (a) September 28, 1973. ,
(b) PG&E committed to ANSI N45.2.9 in the original Diablo Canyon FSAR (c) PG&E committed to the rough draft of ANSI N45.2.9
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in existence in 1973. In a proposed FSAR revision submitted for approval on June 10, 1983, PG&E committed to ANSI N45.2.9-1974 with the exception that PG&E complies with the two-hour fire rating in Section 5.6 of ANSI N45.2.9-1979.
(d) Not at all.
(c) The commitment to ANSI N45.2.9. was unconditional.
ITEM (C) ANSI N45.2.10 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC for approval on June 10, 1983.
(c) ANSI N45.2.10-1973. l-(d) The commitment does not apply to prior work; ,
however, ANSI N45.2.10 contains definitions generally accepted throughout the nuclear
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industry and PG&E has been in compliance with the guidance of ANSI N45.2.10 since its issuance in 1973.
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(e) The proposed commitment is unconditional.
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ITEM (D) ANSI N45.2.11 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC I
for approval on June 10, 1983.
(c) ANSI N45.2.ll-1974.
(d) The commitment does not apply to prior work; however, the guidance contained in ANSI N45.2.11 was used in developing revisions to PG&E's. design procedures beginning in 1978 and ANSI N45.2.11 is referenced in those procedures as applicable.
(e) The proposed commitment is unconditional.
ITEM (E) ANSI N45.2.12 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC for approval on June 10, 1983.
(c) ANSI N45.2.12-1977.
(d) The commitment does not apply to prior work; however, the guidance contained in ANSI N45.2.12 has been followed by the PG&E Quality Assurance Department since the issuance of the Standard in 1977.
(e) The proposed commitment is unconditional.
ITEM (F) ANSI N45.2.13 -
(a) June 10, 1983.
(b) In a proposed.PSAR revision subn'tted i to the NP.C for approval on June 10, 1983.
. (c) ANSI N45.2.13-1976.
. (d) The commitment'does not apply to prior work; however, the guidance contained in ANSI N45.2.13 has been used by PG&E in procurement activities since the issuance of the Standard in 197E.
(e) The proposed commitment is unconditional.
ITEM (G) ANSI N45.2.23 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC i for approval on June 10, 1983.
(c) ANSI N45.2.23-1978.
(d) The commitment does not apply to prior work; however, PG&E's Quality Assurance Department internal procedure for qualification of auditors has complied with the guidance contained in ANSI N45.2.23 since August 15, 1977.
(e) The proposed commitment is unconditional.
INTERROGATORY NO. 18 With respect to each of the Reg. Guides specibied '-
below in items A through G, state separately:
(a) When did PG&E first commit itself to comply with the Reg. ,
4 Guide in the design of Diablo Canyon? s .
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(b) In what form was the commitment to comply with the Reg.
Guide made?
(c) With which revision of the Reg. Guide did PG&E commit itself to comply, and to what extent did PG&E subsequently commit itself to comply with later revisions?
(d) To what extent did the commitment apply to work performed l
before the date of the commitment?
(e) If the commitment identified in your answer to item (b),
above, was other than an unconditional commitment to l comply fully with all terms of the Reg. Guide for the design of Diablo Canyon:
(1) What was the extent of the commitment made at that time?
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(2) Was the comnitment ever enlarged by PG&E?
(3) If it was evr+r enlarged, identify each and every commitment by PG&E to enlarge compliance, specifying (i) when the commitment was made, (ii) what the extent of the enlarged commitment I
was, and (iii) the form in which the commitment was made, e
The Reg. Guides to which this interrogatory refers are:
(A) 1.28 (B) 1.88 (C) 1.74
.(D) 1.64 (E) 1.144 (F) 1.123 (G) 1.146 I. ,
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RESPONSE TO INTERROGATORY NO. 18:
ITEM (A) Reg. Guide 1.28 (Safety Guide 28)
(a) September 28, 1973.
(b) PG&E committed to Safety Guide 28 in the original Diablo Canyon FSAR.
(c) PG&E has committed to Reg. Guide 1.28 (Safety Guide 28 - June 7, 1972) and has not changed that commitment.
(d) The commitment does not apply to prior work.
(e) The commitment to Reg. Guide 1.28 was unconditional.
ITEM (B) Reg. Guide 1.88 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC for approval on June 10, 1983.
(c) Revision 2 of Reg. Guide 1.88 (October 1976).
(d) The commitment does not apply to prior work. 4 Reg. Guide 1.88 endorses ANSI N45.2.9 which PG&E committed to comply with in its draft form in
'1973. (See response to Interrogatory 17.)
(e) The proposed commitment is unconditional.
ITEM (C) Reg. Guide 1.74 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC for approval on June 10, 1983.
J (c) Reg. Guide 1,74 (February, 1974).
(d) The commitment does not apply to prior work.
Reg. Guide 1.74 endorses ANSI N45.2.10, the guidance of which PG&E has attempted to comply with since 1973. (See response to Interrogatory
. No. 17).
(e) The proposed commitment is unconditional.
ITEM (D) Reg. Guide 1.64 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC for approval on June 10, 1983.
(c) Revision 2 of Reg. Guide 1.64 (June, 1976).
(d) The commitment does not apply to prior work; however, Reg. Guide 1.64 endorses ANSI N45.2.11.
PG&E has used the guidance contained in ANSI l N45.2.11 since 1978. l (See response to Interrogatory No. 17).
(e) The proposed commitment is unconditional.
ITEM (E) Reg. Guide 1.144 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC for approval on June 10, 1983.
(c) Guide 1.144 (September 1980).
(d) The commitment does not apply to prior work; however, Reg. Guide 1.144 endorses ANSI N45.2.12 which PG&E has complied with since 1977. (See response to Interrogatory No. 17.)
(e) The proposed commitment is unconditional.
ITEM (F) Reg. Guide 1.123 (a) June 10, 1983.
(b) In a proposed FSAR revision submitted to the NRC
. for approval on June 10, 1983.
(c) Reg. Guide 1.123 (January 1977).
(d) The commitment does not apply to prior work; however, Reg. Guide 1.123 endorses ANSI N45.2.13. PG&E has used the guidance contained in ANSI N45.2.13 since 1976. (See response to Interrogatory No. 17).
(e) The proposed commitment is unconditional.
ITEM (G) Reg. Guide 1.146 (a) June 10, 1983.
(b) In a proposed PSAR revision submitted to the NRC for approval on June 10, 1983.
(c) Reg. Guide 1.146 (August, 1980).
(d) The commitment does not apply to prior work; however, Reg. Guide 1.146 endorses ANSI N45.2.23 which PG&E has co;mplied with since August, 1977.
(See response to Interrogatory No. 17).
(e) The proposed commitment is unconditional.
INTERROGATORY NO. 19:
For each and every criterion contained in Appendix p, during what period, if any, do you contend that the quality i
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l l l assurance program for the design of Diablo Canyon Units 1 and 2 l
met the requirements of that criterion?
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RESPONSE TO INTERROGATORY NO. 19:
July 10, 1969 to present.
INTERROGATORY NO. 20:
Has the seismic design worll of each and every design group in the design cnain for each and every safety-related SS&C been reviewed by the DCP since November 19, 19817 RESPONSE TO INTERROGATORY NO. 20:
Yes.
INTERROCATORY NO. 21:
If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that have not been so reviewed state:
(a) the identity and locations of the SS&Cs, and the identity of the design groups whose work was not reviewed; (b) the reason for their exclusion from review; (c) the identity of the person responsible for the decision to exclude them.
RESPONSE TO INTERROGATORY NO. 21:
Not applicable.
l INTERROGATORY NO. 22:
Has the seismic qualification of all procured l
components that are safety-related been reviewed by the DCP since November 19, 19817
. RESPONSE TO INTERROGATORY NO. 22:
Yes.
INTERROGATORY NO. 23:
If your answer to the preceding interrogatory is other than an unqualified "yes," for all such components that have not been so reviewed state:
(a) their identity and locations; (b) the vendor or vendors; (c) the reason for their exclusion from review; (d) the identity of the person responsible for the decision to exclude them.
RESPONSE TO INTERROGATORY NO. 23:
Not applicable.
INTERROGATORY NO. 24:
Has the seismic design work of each and every design group in the design chain for each and every safety-related SS&C that was reviewed by the DCP been reviewed for the DE, DDE, and Hosgri earthquake since November 19, 19817
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RESPONSE TO INTERROGATORY NO. 24:
No. i INTERROGATORY NO. 25:
If your answer to the preceding interrogatory is other th'an an unqualified "yes," for each safety-related SS&C that was not reviewed for all three earthquakes state:
(a) the identity and locations of the SS&Cs, and the identity of the design groups whose work was not reviewed; (b) for which of the three earthquakes it was not reviewed; (c) the reason for its exclusion from review for the decision to exclude it.
RESPONSE TO INTERROGATORY NO. 25:
(a) Electrical raceway supports.
(b) DE.
(c) This is consistent with the licensing commitments as stated in the Hosgri Report and the FSAR.
INTERROGATORY NO. 26:
Has the seismic qualification of all safety-related procured components that were reviewed by the DCP been reviewed for the DE, DDE, and Hosgri earthquake?
RESPONSE TO INTERROGATORY NO. 26:
Yes.
- O INTERROGATORY NO. 27:
If your answer to the preceding interrogatory is other than an unqualified "yes," for all such components that have not been so reviewed state:
(a) their identity and locations; (b) the vendor or vendors; (c) for which of the three earthquakes they were not reviewed; (d) the reason for their exclusion from review for that earthquake; (e) the identity of the person responsible for the decision to exclude them.
RESPONSE TO INTERROGATORY NO. 27:
Not applicable.
INTERROGATORY NO. 28:
Has the nonseismic design work of each and every design group in the design chain for each and every safety-related SS&C been reviewed by the DCP since November 19, 1981?
RESPONSE TO INTERROGATORY NO. 28:
No.
. INTERROGATORY NO. 29:
If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that have not been reviewed state:
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(a) the identity and locations of the SS&Cs, and the identity of the design groups whose work was not reviewed; (b) 'he t reason for their exclusion from review; (c) the identity of the person responsible for the decision to exclude them.
RESPONSE TO INTERROGATORY NO. 29:
(a) The work reviewed is identified in the PG&E Phase II l Final Report, Design Verification Program, June 1983, and in the IDVP's Final Report, 1983.
(b)&(c) The November 19, 1981 NRC letter from Harold Denton required review of non-seismic design activities by an l
independent contractor as part of an independent verification program.
INTERROGATORY NO. 30:
How did Westinghouse define " safety-rclated" for purposes of compliance with Appendix B to Part 50 of 10 C.F.R.
for all SS&Cs supplied by Westinghouse and used at Diablo Canyon?
RESPONSE TO INTERROGATORY NO. 30:
Westinghouse historically defined the term
" safety-related" with respect to Diablo Canyon in the same manner as PG&E. See response to Interrogatory No. 9.
INTERROGATORY NO. 31:
How did Westinghouse define "important-to-safety" for purposes of compliance with General Design Criterion 1 of
Appendix A to Part 50 of 10 C.F.R. for all SS&Cs supplied by Westinghouse and used at Diablo Canyon?
RESPONSE TO INTERROGATORY NO. 31:
- Westinghouse historically defined the term "important-to-safety" with respect to Diablo Canyon in the same manner as s
PG&E, See response to Interrogatory No. 9.
INTERROGATORY NO. 32:
If your answer to any of the preceding interrogatories applies differently to Unit 1 and Unit 2 of Diablo Canyon, identify the interrogatory and explain how the answer differs for Unit 1 and Unit 2.
RESPONSE TO INTERROGATORY NO. 32:
With the exception of Interrogatory No. 29, the answers tc the preceding interrogatories apply to Diablo Canyon Units 1 and 2 the IDVP program is not applied directly to Unit 2.
INTERROGATORY NO. 33:
Identify each and every person on whom you relied for the rendition of expert advice on matters pertaining to statistics and probability theory and give the qualifications of each.
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l RESPONSE TO INTERROGATORY NO. 33:
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PG&E objects to this interrogatory on the grounds that j i l
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< e the information it seeks is not relevant to and exceeds the limited scope of this proceeding, which, by Appeal Board order, is to inquire into design quality assurance at Diablo Canyon Power Plant. As a regulated public utility appearing before both federal and state rate-making bodies, PG&B, for years, has relied upon expert advice in matters pertaining to statistics and probability theory. For example, PG&E has engaged historically in such activities as load projections, growth projections, income projections, all of which are irrelevant to this proceeding. Thus it is impossible to comply with this request since this activity has been conducted for many years.
INTERROGATORY NO. 34:
Identify the person or persons referred to at page 3.5-8 of the IDVP Final Report as having been retained by the DCP to conduct a statistical evaluation, and provide the qualifications of each.
RESPONSE TO INTERROGATORY NO. 34:
Dr. Stanley Kaplan has been retained to evaluate the applicability of statistical sampling methods to the design verification process. Dr. Kaplan's resume is attached.
INTERROGATORY NO. 35:
With respect to the statistical evaluation described in the preceding interrcgatory, state:
(a) The scope of the evaluation.
(b) The schedule for the conduct of the evaluation.
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(c) The results of the evaluation to date. l (d) The nature of all work remaining to be done in connection with the evaluation.
(e) The identity of each and every person, excluding clerical personnel, who participated in the evaluation and the nature of the work each performed.
RESPONSE TO INTERROGATORY NO. 35:
(a) An evaluation is being made of the applicability of statistical sampling methods to the design verification process. It includes an attempt to apply the statistical method to the IDVP, thus bringing into focus the merits and limitations of this approach, and a clarification of what can and cannot be learned from the approach.
(b) The work is scheduled for completion in August 1983.
(c) A conceptual framework for the evaluation has been proposed through meetings and discussions between Dr. Kaplan and the Diablo Canyon Project. Dr. Kaplan has reviewed the DCP and IDVP Final Reports. No numerical work has been done at this time.
(d) The remaining work includes completion of the evaluation described in (a) above, including qualitative discussions and numerical calculations based on the results of the IDVP, as reported in the June 30, 1983, submittal of the IDVP Final Report and the PG&E Phase II Final Report, dated June, 1983.
(e) No additional consultation or participation is anticipated at this time.
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(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
! (i) Nuclear Unit 2 Diablo Canyan Site l Pacific Gas and Electric Company Preliminary Safety Analysis Report June 28, 1968 (ii) Amendment 4 to the above document dated July 10, 1969.
FOR INTERROGATORY NO. 3 (a) Response prepared by:
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Nuclear Unit 2 Diablo Canyon Site, Pacific Gas and Electric Company Preliminary Safety Analysis Report June 28, 1968 (ii) Amendment 4 to the above document dated July 10, 1969.
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INTERROGATORY NO. 36:
For each of the preceding interrogatories, state separately for each interrogatory:
(a) the identity of each and every person who participated in its answer, (b) the identity of each and every document relied upon in preparing the answer.
RESPONSE TO INTERROGATORY NO. 36:
FOR INTERROGATORY NO. 1 a) Response prepared by:
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company.
(b) Documents relied upon were:
(i) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report June 28, 1968 (ii) Amendment 4 to the above document dated July 10, 1969.
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FOR INTERROGATORY NO. 2 l (a) Response prepared by:
a .
(iii) Units 1 and 2 Diablo Canyon site Pacific Gas and Electric Company Final Safety Analysis Report September 28, 1973 FOR INTERROGATORY NO. 4 (a) Response prepared by:
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report June 28, 1968 (ii) Amendment 4 to the above document dated July 10, 1969.
(iii) Units 1 and 2 Diablo Canyon site Pacific Gas and Electric Company Final Safety Analysis Report September 28, 1973 l t
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FOR INTERROGATORY NO. 5 (a) Response prepared by:
t (i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Units 1 and 2 Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 l
Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CFR 50, Appendix A (vi) 10 CFR 50, Appendix B (vii) 10 CFR 100, Appendix A
FOR INTERROGATORY NO. 6 (a) Response prepared by:
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Units 1 and 2 Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CFR 50, Appendix A (vi) 10 CPR 50, Appendix B (vii) 10 CFR 100, Appendix A
__ ______________-_______________________________________n
. o FOR INTERROGATORY NO. 7 (a) Response prepared by:
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 pacific Gas and Electric Company (b) Documents relied upon were:
i (i) Units 1 and 2 1
Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report
{
(ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company l 1
Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CFR 50, Appendix A (vi) 10 CPR 50, Appendix B (vii) 10 CPR 100, Appendix A
__.; ._ __ . .._...a.._a_x..u _ _
FOR INTERROGATORY NO. 8 l (a) Response prepared by:
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Units 1 and 2 Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CPR 50, Appendix A (vi) 10 CFR 50, Appendix B (vii) 10 CPR 100, Appendix A FOR INTERROGATORY NO. 9 (a) Response prepared by:
l 1
, .,s (i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Units 1 and 2 Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CPR 50, Appendix A (vi) 10 CPR 50, Appendix B (vii) 10 CPR 100, Append.ix A POR INTERROGATORY NO. 10
. (a) Response prepared by:
I
,:- . - . w .- _ ..:a...:.. .: = - . . ..:: - -
l * .
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company
, (b) Documents relied upon were:
(i) Units 1 and 2 Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CFR 50, Appendix A (vi) 10 CFR 50, Appendix B (vii) 10 CFR 100, Appendix A FOR INTERROGATORY NO. 11 (a) Response prepared by:
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company
, ~ _ .
(b) Documents relied upon were:
(i) Units 1 and 2 Diablo Canyon Site l' %'ific Cas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant Construction Permits, AEC, 1967 (v) 10 CPR 50, Appendix A (vi) 10 CPR 50, Appendix B (vii) 10 CFR 100, Appendix A FOR INTERROCATORY NO. 12 (a) Response prepared by:
(i) John B. Hoch i
Project Manager Diablo Canyon Units 1 and 2 j ,
Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Units 1 and 2
- Diablo Canyon Site Pacific Gas and Electric Company Final Safety Analysis Report (ii) Nuclear Unit 1 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iii) Nuclear Unit 2 Diablo Canyon Site Pacific Gas and Electric Company Preliminary Safety Analysis Report (iv) General Design Criteria for Nuclear Power Plant l Construction Permits, AEC, 1967 (v) 10 CPR 50, Appendix A (vi) 10 CPR 50, Appendix B (vii) 10 CFR 100, Appendix A POR INTERROGATORY NO. 13 (a) Response prepared by
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR
(ii) Units 1 and 2 Diablo Canyon Site Final Safety Analysis Report September 28, 1973 (iii) Amendment 25, dated January 30, 1975, to the Diablo Canyon Site, Final Safety Analysis Report.
FOR INTERROGATORY NO. 14 (a) Response prepared by:
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR (ii) Units 1 and 2 Diablo Canyon Site l Final Safety Analysis Report l September 28, 1973 (iii) Amendment 25, dated January 30, 1975, to the Diablo Canyon Site, Final Safety Analysis Report.
FOR INTERROGATORY NO. 15
- (a) Response prepared by
(i) Thomas G. de Uriarte 1
Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company j (b) Documents relied upon were:
(i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR (ii) Units 1 and 2 Diablo Canyon Site Final Safety Analysis Report September 28, 1973 (iii) Amendment 25, dated January 30, 1975, to the Diablo Canyon Site, Final Safety Analysis Report.
FOR INTERROGATORY NO. 16 (a) Response prepared by:
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR (ii) Units 1 and 2 Diablo Canyon Site Final Safety Analysis Report i
September 28, 1973 I
l l l I l 1
(iii) Amendment 25, dated January 30, 1975, to the Diablo Canyon Site, Final Safety Analysis Report.
FOR INTERROGATORY NO. 17 (a) Response prepared by:
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR (ii) Units 1 and 2 Diablo Canyon Site Final Safety Analysis Report September 28, 1973 (iii) Amendment 25, dated January 30, 1975, to the Diablo Canyon Site, Final Safety Analysis Report.
(iv) Revision 1, dated August 15, 1977, to PG&E's Quality Assurance Department Procedure 17.1,
" Personnel Qualification Records", approved by the Director, Quality Assurance.
(v) Letter dated January 22, 1983, from P. A. Crane of PG&E to R. L. Tedesco of the USNRC.
i FOR INTERROGATORY NO. 18 (a) Response prepared by:
n.-____.--.-
._ . _. . _e w. _ ;.c.4 . . . . __
(i) Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
, (i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR (ii) Units 1 and 2 Diablo Canyon Site Final Safety Analysis Report September 28, 1973 (iii) Amendment 25, dated January 30, 1975, to the Diablo Canyon Site, Final Safety Analysis Report.
(iv) Revision 1, dated August 15, 1977, to PG&E's Quality Assurance Department Procedure 17.1,
" Personnel Qualification Records", approved by the i Director, Quality Assurance. ,
(v) Letter dated January 22, 1983, from P. A. Crane of PG&E to R. L. Tedesco of the USNRC.
FOR INTERROGATORY NO. 19 (a) Response prepared by:
(i) ,
Thomas G. de Uriarte Senior Engineer, Auditing Quality Assurance Department Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Amendment 4, dated July 10, 1969, to the Nuclear Unit 2, Diablo Canyon Site, PSAR i (ii) Units 1 and 2
[
Diablo Canyon Site Final Safety ann 1ysis Report
~
~
September 28,,19'73 (iii) Amendment 25, dated January 30, 1975, Lo the' Diablo Canyon Site, Final Safety Analysis Report.
(iv) Revision 1, dated August 15, 1977, to PG&E's Quality-Assurance Department Procedure'17.1,
" Personnel Qualification Records", approved by bhe Director, Quality Assurance.
~
(v) Letter dated January 22,'1983, from P. A. Crane of PG&E to R. L. Tedesco of the USNRC.
FOR INTERROGATORY NO 20 (a) Response prepared by:
(i) Richard C. Anderson ,
' ~
Engineering Manager ,
Diablo Canyon Project .
San Francisco Powed Division ,
Bechtel Power Corporation
~
(ii) Dr. William H. White
. Assistant Project Engineer, Seismic Diablo Canyon Project f
San Francisco Power Division
~
Bechtel Power Corporation
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(b) Documents relied upon were:
(i) Pacific Gas and Electric Company
. Phase I Final Report Design Verification Program
. FOR INTERROGATORY NO. 21 (a) Response prepared by:
( 1-) Not Applicable (b) Documents relied upon were:
(i) Not Applicable L
FOR INTERROGATORY NO. 22 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (ii) .Dr. William H. White Assistant Project Engineer, Seismic Diablo Canyon Project San Francisco Power Division l l
Bechtel Power Corporation (iii) Gary H. Moore
. Project Engineer Unit 1 Diablo Canyon Project 1
Pacific Gas and Electric Company
>/
/
_ _ _ . - . _ . _ _ _ _ _ _ _______m_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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f.
(b) Documents relied upon were:
1 (ii. Pacific Gas and Electric Company
' I Phase I Final Report Design Verification Program
. FOR INTERROGATORY NO. 23 (a) Response prepared by:
(i) Not Applicable (b) Documents relied upon were:
Not Applicable FOR INTERROGATORY NO. 24 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (ii) Dr. William H. White Assistant Project Engineer, Seismic Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (b) Documents relied upon were:
l (i) Pacific Gas and Electric Company Phase I Final Report Design Verification Program
~ . . .. . - . . ~ '. . it . . . .
. . l l
POR INTERROGATORY NO. 25 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project i San Francisco Power Division Bechtel Power Corporation (ii) Dr. William H. White Assistant Project Engineer, Seismic Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (b) Documents relied upon were:
None FOR INTERROGATORY NO. 26 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (ii) Gary H. Moore Project Engineer Unit 1 Diablo Canyon Project i Pacific Gas and Electric Company l
i l
)
, ,, . .A. ...,..., ..- . . . , ~ , . .
(iii) Dr. William H. White Assistant Project Engineer, Seismic Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation
,, (b) Documents relied upon were:
(i) Pacific Gas and Electric Company Phase I Final Report Design Verification Program INTERROGATORY NO. 27 (a) Response prepared by:
(i) Not Applicable.
(b) Documents relied upon were:
(i) Not Applicable.
FOR INTERROGATORY NO. 28 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Powe,r Division Bechtel Power Corporation (ii) Gary H. Moore Project Engineer Unit 1 Diablo Canyon Project Pacific Gas and Electric Company j l
- - . . . = - . . . , . . . .. : .. . ..; +.,
(b) Documents relied upon were:
(i) Pacific Gas and Electric Company Phase II Final Report Design Verification Program June, 1983
, (ii) Diablo Canyon Nuclear Power Plant - Unit 1 Final Report Independent Design Verification Program, 1983 FOR INTERROGATORY NO. 29 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (ii) Gary H. Moore Project Engineer Unit 1 Diablo Canyon Project Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Pacific Gas and Electric Company Phase II Final Report Design Verification Program June, 1983
.__...._.__......:z...u__ _ . . . . . _ _ _ _ . _ _ _ _ . . _ . . . _ _ . _ _ _ _
(ii) Diablo Canyon Nuclear Power Plant - Unit 1 Final Report Independent Design Verification Program, 1983 FOR INTERROGATORY NO. 30
, (a) Response prepared by:
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company (b) Documents relied upon were:
(i) DCPP Units 1 and 2 PSAR (ii) 10 CFR 50, Appendix A FOR INTERROGATORY NO. 31 (a) Response prepared by:
(i) John B. Hoch Project Manager Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company (b) Documents relied upon were:
(i) DCPP Units 1 and 2 PSAR (ii) 10 CFR 50, Appendix A i
? FOR INTERROGATORY NO. 32 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (ii) Gregory V. Cranston 4
Project Engineer Unit 2 Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (b) Documents relied upon were:
(i) None FOR INTERROGATORY NO. 33
, (a) Response prepared by:
(i) D. G. Lubbock Attorney Pacific Gas and Electric Company (b) Documents relied upon were:
(i) Memorandum and Order dated April 21, 1983 FOR INTERROGATORY NO. 34 (a) Response prepared by:
(i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation
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O O (b) Documents relied upon were:
(i) None FOR INTERROGATORY NO 35 (a) Response prepared by:
, (i) Richard C. Anderson Engineering Manager Diablo Canyon Project San Francisco Power Division Bechtel Power Corporation (b) Documents relied upon were:
(i) None Respectfully submitted, ROBERT OHLBACH PHILIP A. CRANE, JR.
RICHARD F. LOCKE Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94120 (415) 781-4211 ARTHUR C. GEHR Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073 (602) 257-7288 BRUCE NORTON
! Norton, Burke, Berry & French, P.C.
I P.O. Box 10569 l
Phoenix, Arizona 85064 (602) 955-2446
! . Attorneys ;
I Pacific Gas and Electric Company !
By: '}40 k E Richard F. Locke i
DATED: July 25, 1983.
l l
l l
NAE STANLEY KAPLAN EDUCATION Senior Post-Doctoral Fo11cuship, University of Soutfiern California, 1967-1909.
Ph.D., Mechanical Engineering and Applied Mathematics, University of Pittsburgh, 1960. Post-doctoral courses in mathematics at the University of Pittsburgh and Carnegie Institute of Technology, 1960-1965.
M.S., Mechanical Engideering, University of Pittsburgh,1958. l Graduate of the Oak Ridge School of Reactor Technology,1955. I B.S., Civil Engineering, City College of New York,1954.
PROFESSIONAL EXPERIENCE General Summary Mathematician and engineer well known for contributions to risk analysis and reliability theory, reactor physics, kinetics, and computational technique. Specializes in probabilistic methodology; decision theory; risk analysis; and, particularly, applications of Bayes' theorem. In this connection has worked specifically and recently on developing i probabilistic and decision theoretic treatments of various phases of the energy business. Included here are PRA analyses of several existing nuclear plants, hazardous material transportation and storage, spent fuel pools, aircraft impact, offshore oil drilling (environmental risk),
underground oil storage, pipelines, and tarsands projects (business and construction risk). Developer of the DPD method for probabilistic calculations, the two-stage Bayesian technique for data analysis, the
" set of triplets," " probability of frequency," "cause table," and
" environmental table" concepts in risk analysis. Originator of the Matrix Theory of Event Trees and DPD appreach to seismic risk analysis.
Chronological Summary 1977-Present President, Kaplan & Associates, Inc., a consulting firm specializing in risk analysis and applied decision theory.
Concurrently Adjunct Professor, Department of Chemical, Nucicar and Thermal Engineering, University of California, Los Angeles, and Associate Consultant, Pickard, Lowe and Garrick, Inc.
1975-1977 Private consultant specializing in risk analysis and decision theory.
1972-1975 Holmes & Narver, Inc., Anaheim, California.
Director, Advanced Technology Division; Director, Systems Sciences Division; Technical Director, Nuclear & Systems Sciences Group.
1 0759P052783
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1971-1972 Director of Software Development, COMARC Design Systems, Inc., San francisco, California. -
1969-1971 Product Manager and Senior Staff Member, Computer Sciences Corporation, Los Angeles, California.
1967-1969 Special Research Fellow, U.S. Public Health Service at University of Southern California, Los Angeles.
1955-1967 Westinghouse Bettis Atomic Power Laboratory, West Mifflin, Pennsylvania.
Experimentalist, Experimentalist in Charge, Scientist, Senior Scientist, Fellow Scientist, Advisory Scientist.
1954 Lecturer, Department of Civil Engineering, City College of New York.
1952-1967 Concurrently Adjunct Professor of Mechanical Engineering, University of Pittsburgh; Lecturer Department of Mathematics, Carnegie Institute of Technology.
MEMBERSHIPS._ PAST OR FRESENT American Society of Civil Engineers.
American Nuclear Society.
Society of Industrial and Applied Mathematics.
New York Academy of Sciences.
PUBLICATIONS Kaplan, S., "On a 'Two-Stage' Bayesian Procedure for Detennining Failure Rates from Experiential Data," PLG-0191, IEEE Transactions on Power Apy,ar_a_tus and Systems, Vol PAS-102, No.1, January 1983.
Garrick, B. J., and S. Kaplan, Chapter 2.7, " Electric Power," High Risk Safety Technology, A. E. Green, Editor, John Wiley & Sons, Ltd.,1982.
Kaplan, S., "On Safety Goals and Related Questions," Reliability E_ngineering, Vol. 3, No. 4, July 1982, 267-277.
Kaplan, S., "A Matrix Theory Formalism for Event Tree Analysis," Risk Analysis, Vol 2, No.1, March 1982.
Kaplan, S., B. J. Garrick, and P. P. Bientarz, "On the Use of Bayes' Theorem in Assessing the Frequency of Anticipated Transients," Nuclear Eg ineerin_g and Design, Vol. 065, ISS., 23-32 (1981).
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KAPLAN - 3 Kaplan, S., "On the tiethod of Discrete Probability Distributions in Risk and Reliability Calculations ' Application to Seistic Risk Assessment,"'
Risk Analysis, Vol. I, No. 3, September 1981.
Kaplan, S., and B. J. Garrick, "On the Quantitative Definition of Risk,"
R_isk Analysis,1,1, tiay 1981.
Apostolakis, G., and S. Kaplan, " Pitfalls of Risk Calculations," $
Reliability Engincering, 2,, 2,135-145, April 1981.
7 Kaplan, S., B. J. Garrick, and G. Apostolakis, " Advances in Quantitative '
Risk Assessment - The !4aturing of a Discipline," IEEE Transactions on Nuclear Science, NS-28, No.1, February 1981.
Kaplan, S., and B. J. Garrick, "Some flisconceptions About Misconceptions," Letter to the Editor, Risk Analysis, Vol.1, No. 4, December 1981.
Apostolakis, G., S. Kaplan, B. J. Garrick, and R. J. Duphily, " Data Specialization for Plant Specific Risk Studies," Nuclear Engineering and Design, Vol. 56, 321-239 (1980).
Kennedy, R. P. , A. C. Cornell, R. D. Campbell, S. Kaplan, and H. F. Perla, "Probabilistic Seismic Safety Study of an Existing Nuclear Power Plant," Nuclear Engineering and Design, 59, 2, August 1980.
Kaplan, S., and B. J. Garrick, "Try Probabilistic Thinking to Improve Power Plant Reliability," Power,11 arch 1980.
I Kaplan, S., and B. J. Garrick, "On the Use of Bayesian Reasoning in Safety and Reliability Decisions - Three Examples," Nuclear Technology, 44, 231-245 (1979).
Apostolakis, G., S. Kaplan, B. J. Garrick, and W. Dickter, " Assessment of the Frequency of Failure To Scram in Light Water Reactors," Nuclear Safety, Vol. 20, No. 6, November-December 1979.
Kaplan, S., "On a Probabilistic Approach to Project Cost Estimating," l Consulting Engineer, February 1976.
Garrick, B. J., and S. Kaplan, " Reliability Technology and Nuclear Power," IEEE Transactions on Reliability, S)ecial Issue on Nuclear Systems YelT5bmTty ;an_d sarety, V61. R-2T,70. 3, August 1976.
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o a KAPLAN - 4 Kaplan, S., "On a Bayesian Type Method)1ogy for Making Accept / Reject Decisions on Offshore lease Bids " Journal of Petroleum Technology, March 1976.
Kaplan, S., and D. Trujillo, " Numerical Studies of the Partial Differential Equations Governing Nerve Impulse Conduction-1, the Significance of Lieberstein's Inductance Term," Journal of Mathematical Biosciences, 7_, 379-404 (1970).
Kaplan S., Advances in Nuclear Science " Variational and Technology, Methods in Y, Vol. Nuclear Engineering,"
P. R. Greebler, ed it5r, Academic Fr~ess (1960.
Kaplan, S., A. J. McNabb, J. K. Siemsen, and D. Trujillo, "The Inverse Problem of Radioisotope Diagnosis - A Computational Model for Determining the Size and Lccation of Tumors," Journal of Mathematical Biosciences, 5, ~
29-35 (1969).
Yasinsky, J. B., and S. Kaplan, "On the Use of Dual Variational Principles for the Estimation of Error in Approximate Solutions of Diffusion of Problems," Nuclear Science and Engineering, 3 , 80-90 (1968).
Kaplan, S., " Canonical and Involutory Transformations of Variational Problems Involving Higher Derivatives," Journal of Mathematical Analysis and Applications, 22, 1, 45-53 (1968).
Yasinsky, J. B., and S. Kaplan, " Anomalies Arising from the Use of Adjoint Weighting in a Collapsed Group Space Synthesis Model," Nuc1 car Science and EnJineering, 31, 2, 354 (1968).
Kaplan, S., A. J. McNabb, and M. B. Wolf, " Input-Output Relations for a Counter Current Dialyzer by the Method of Invariant Imbedding," Journal of Mathematical B_fosciences, 3_, 3, 289-293 (1968).
Kaplan, S., "A New Derivation of Discrete Ordinate Approximations,"
Nuclear Science and Engineering, 34,, 1, 76 (1968).
Yasinsky, J. B., and S. Kaplan, " Synthesis of Three-Dimensional Flux Shapes Using Discontinuous Sets of Trail Functions," Nuclear Science and.
Engineering, 28_, 426-437 (1967).
Kaplan, S., and J. A. Davis, " Canonical and Involutory Transformations of the Variational Principles of Transport Theory," Nuclear Science and Engineering, 28, 2, 166-176 (1967).
Kaplan, S., J. A. Davis, and M. Natelson, " Space-Angle Synthesis - An ,
Approach to Transport Approximations," Nuclear Science and Engineering, l l 28,,364-375,(1967).
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KAPLAN - 5 l
Kaplan, S., " Properties of the Relaxation Lengths in PI-Double-P1 and Angle-Space Synthesis Type Approximations," Nuclear Sc,ience and Erigineering, 28_, 450-463 (1967).
Kaplan, S., and J. B. Yasinsky, " Natural Modes of the Xenon Problem with Flow Feedback - An Example," Nuclear Science and Engi_neering, -25, 430-438 (1966). .
Gelbard, E. M., and S. Kaplan, " Reality of Relaxation Lengths in Various Approximate Forms of the Slab Transport Equation," Nuclear Science and Engineering, 26,, 4, 569 (1966).
Kaplan, S., " Synthesis Methods in Reactor Theory," Advances in fluclear Science, Vol. 111, Academic Press, June 1966.
Kaplan, S., "An Analogy Between the Variational Principles of Reactor Theory and Those of Classical Mechanics," Nuclear Science and
,Engincering, 23, 3, 234 (1965).
Kaplan, S., E. M. Gelbard, " Invariant Imbedding and the Integration Techniques of Reactor Theory," Journal of Mathematical Analysis and Applications,11_, No.1-3, 538-T4U19T5i.
Henry, A. F., and S. Kaplan, "Some Applications of a lhltimode Generalization of the Inhour Fomula," Nuclear Science and Engineering, 22_, 4, 479-486, (1965).
Kaplan, S., O. J. Marlowe, and J. A. Bewick, " App 1fcation of Synthesis Techniques to Problems Involving Time Dependence," Nuclear Science and Engineering, ,18,, 163-176 (1964).
Kaplan, S., "The Use of the Rayleight-Ritz Method in Non-Self Adjoint Problems," IEEE Transactions, MIT-12, 2 (1964). ,
Kaplan, S., Editor and Contributor, Section 5.5, " Space-Time Kinetics,"
Naval Reactors Handbook, Vol. 1.
Kaplan, S., A. F. Henry, S. G. Margolis, and J. J. Taylor, " Space-Time Reactor Dynamics," Proceedings, Third United Nations International Conference on the Peaceful Uses oTTEmic_ Energy, Geneva (1Y64).
Kaplan, S., "Some New Methods of Flux Synthesis," Nuclear Science and
_ Engineering, 13_, 1, 22-31 (1962).
Kaplan, S., "The Property of Finality and the Analysis of Problems in Reactor Space-Time Kinetics by Various Model Expansions," Nuclear Science and Engineering, 9_, 3, 375 (1961). l l
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KAPLAN - 6 Kaplan, S., and G. Sonnemann, "The Methods of Finite Integral Transforms in Heat Transfer Problems," Proceedings o_f the Internation_al Heat Transfer Conference, Boulder 7 Colorado (1961).
Kaplan, S., and S. G. Margolis, " Delayed Neutron Effects During Flux Tilt
. Transients," Nuclear Science and Engineering, 7, 3, 276 (1960).
F Kaplan, S., and G. Sonnemann, "A Generalization of the Finite Integral Transfom Technique and Tables of Special Cases," P_ roc _e_e_d_ings of l Mid-Western Conference on Solid and Fluid Mechanics, Austin, Texas (1959).
l cadsmith, M., T. T. Jones, T. M. Ryan, S. Kaplan, and A. D. Vorhis,
" Theoretical Analysis of Highly Enriched Light Water Moderated Critical Assemblies," Proceedings, Second _U_nited Nations _Internatfonal Conference on the Peaceful Uses of Atomic Energy, Pager P/2376 (IM8).
REPOR1S AND PRESENTATIONS Kaplan, S., " Bayesian Methods in PRA," presented at the American Nuclear Society Topical Meeting: Advances in Reactor Computations, PLG-0265, March 28-31, 1983.
"Seabrook Probabilistic Safety Assessment," Public Service Company of New Hampshire, to be published in 1983.
Kaplan, S., M. T. L. Ma, J. C. Wang, and C. P. Purohit, "Probabilistic Risk and Decisicn Analysis of General Electric Turbine Cracking Problem,"
PLG-0246, September 1982.
Kaplan, S., H. F. Perla, and D. C. Bley, "A Methodology for Seismic Safety Analysis of Nuclear Power Plants," presented at the International Meeting on Thermal Nuclear Reactor Safety, Chicago, Illinois, August 29-September 2, 1982.
Bley, D. C., S. Kaplan, and B. J. Garrick, " Assembling and Decomposing PRA Results: A Matrix Formalism," presented at the International Meeting on Themal Nuclear Reactor Safety, Chicago, Illinois, August 29-September 2, 1982.
Fleming, K. N., S. Kaplan, and B. J. Garrick, "Seabrook Probabilistic Safety Assessment Management Plan,"PLG-0239, June 1982.
Garrick, B. J., S. Kaplan, D. C. Iden, E. B. Cleveland, H. F. Perla, D.
-C. Bley, D. W. Stillwell, H. V. Schneider, and G. Apostolakis, " Power Plant Availability Engineering: Methods of Analysis, Program Planning, and Applications," EPRI NP-2168, PLG-0165 May 1982.
" Indian Point 2 and 3 Probabilistic Safety Study." Power Authority of the State of New York and Consolidated Edison Company of New York, Inc.,
March 1982.
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. o KAPLAN - 7 Lin, J. C., and S. Kap'lan, "SEIS3: A Computer Program for Seismic and Wind Risk Assessment, PLG-0222, March 1982. *
" Zion Probabilistic Safety Study," Commonwealth Edison Company, September 1981, Kaplan, S., "The Bayesian Approach to Data Reduction in Probabilistic Risk Analysis," PLG-0205 prepared as input to the NRC/ANS Probabilistic
,P.f sk Assessment Procedures Guide, September 1981.
Stillwell, D. W., B. J. Garrick, D. R. Buttemer, G. Apostolakis, J. C. Lin, and S. Kaplan, " Analysis of the Pilgrim Nuclear Power Station Reactor Protection System," PLG-0195, July 1981.
Kaplan, S., " Matrix Format for PRA and Its Possible Usefulness in Licensing," presented to the ACRS Subcommittee on Reliability and Probabilistic Risk Assessment, Los Angeles, California, July 28, 1981. I Kaplan, S., G. Apostolakis, B. J. Garrick, D. C. Bley, and K. Woodard, l
" Methodology for Probabilistic Risk Assessment of Nuclear Power Plants,"
PLG-0209, June 1981.
Kaplan, S., " Scarce Data Analysis Techniques," ANS 1981 Annual Meeting, Transactions, Miami, Florida, June 7-11, 1981.
Mulvihill, R. J. , and B. J. Garrick, R. S. Hanson, S. Kaplan, Y. G. Mody, D. A. Reny, L. H. Riechers, and H. V. Schneider, " Comparative Evaluation of Boiler Availability for Intermountain Power Project," PLG-0169, April 1981.
Garrick, B. J., S. Kaplan, and N. O. Siu, " Definition of Bounding Physical Tests Representative of Transport Accidents - Rail and Truck,"
PLG-0164, March 1981.
Kaplan, S., L. H. Reichers, and B. J. Garrick, " Histogram Convolution Program (HICOP)," PLG-0157, December 1980.
Hanson. R. S., J. C. Lin, D. M. Wheeler, S. Kaplan, B. J. Garrick, D. C., Iden, W. B. Holder, and L. G. H. Sarmanian, "An Assessment of the Reliability of Turbine-Generators," PLG-0155, November 1980.
Garrick, B. J., S. Kaplan, D. C. Iden E. B. Cleveland, H. F. Perla, D. C. Bley, and D. W. Stillwell, " Power Plant Availability Engineering, Methods of Analysis - Program Planning - Applications," 2 Vols.,
PLG-0148. October 1980.
Kaplan, S., R. S. Hanson, B. J. Garrick, and J. W. Stetkar, "A Strategic Plan for a National Data System for Electric Power Plants," PLG-0144, July 1980.
7 0759P070783
KAPLAN - 8 Garrick, B. J., S. Kaplan, G. Apostolakis, D. C. Iden, K. Woodard, and T. E. Potter, " Seminar: Probabilistic Risk Assessment of Nuclear Power Plants," PLG-0141, July 1980.
Garrick, B. J. , S. Kaplan, and D. C. Bley, " Seminar: Power Plant Probabilistic Risk Assessment and Reliability," PLG-0127, May 1980, i
Garrick, B. J., and S. Kaplan, "A Conceptual Plan for a National Data System for Electric Poser Plants," PLG-0131, April 1980.
Garrick, B. J., and S. Kaplan, "0yster Creek Probabilistic Safety Anal-ysis (0PSA)," presented at the ANS-ENS Topical Meeting on Thermal Reactor Safety, Knoxville, Tennessee, April 8-11, 1980.
Kaplan, S., and B. J. Garrick, "A Strategic Plan for a National Reliability Data System," PLG-0125, March 1980.
Garrick, B. J., S. Kaplan, G. Apostolakis, D. C. Bley, and T. E. Potter,
" Seminar: Probabilistic Risk Assessment as Applied to Nuclear Power Plants," PLG-0124, March 1980.
Kaplan, S., B. J. Carrick, and D. C. Bley, " Notes on Risk, Probability, and Decision," PLG-0113, November 1979.
Garrick, B. J., S. Kaplan, and S. Ahmed, "A Reliability Prediction Technique for Selected Thermomechanical Components of Gas Turbine Combined Cycle Plants," PLG-0109, September 1979.
Garrick, 9. J. , S. Kaplan, P. P. Bientarz, K. Woodard, D. C. Iden, H. F. Perla, W. Dicter, C. L. Cate, T. E. Potter, R. J. Duphily, T. R. Robbins, D. C. Bley, and S. Ahmed, "0PSA, Oyster Creek Probabilistic Safety Analysis," (Executive Summary, Main Report, Appendixes), PLG-0100 DRAFT, August 1979.
Kaplan, S., and B. J. Garrick, " Notes on Prediction of Reliability,"
PLG-0117, June 1979.
Kaplan, S., and B. J. Garrick, " Notes for a Workshop on Risk, Reliability, and Decision Under Uncertainty," presented at Batte.lle Northwest Laboratory, June 1979.
Garrick, B. J., P. P. Bientarz, and S. Kaplan, " Risk Analysis of Transporting Oconce Spent Huclear Fuel to the 14cGuire Nuclear Station,"
.PLG-0102, June 1979.
Garrick, B. J., and S. Kaplan, " Training Engineers to be Reliability Practitioners," Sixth Annual Reliability Engineering Conference for the
~ _
Electric Power liidiistry, Proceediligs,141amt Feach,7Torida, April 1970,1979. ~
^ ~
8 0759P070783
KAPLAN - 9 Kaplan, S., J. M. Vallance, and C. L. Cate, " Prediction of Frequency of ,
Aircraft Crashes at the Three Mile Island Site," October 1978.
Kaplan, S., " Description of OPTSWU-1, a Program for Computing the Optimum ,
Amounts of Separative Work to be Contracted for," November 1976.
Kaplan, S., " Notes on Pooling, Meaning of, Types of, and Advantages of.
Also Hotes on a Bookkeeping Concept for Equitable and Visible Management of a Nuclear Pool," September 1976.
Kaplan, S., " Notes on the Concept of Inventory as it Relates to Uranium Procurement Planning," September 1976.
Kaplan, S., "UPLAN, A Decision Theoretic Tool for Uranium Procurement Planning," May 1976.
Kaplan, S., and J. M. Vallance, " Notes on a Model for Evaluation and Optimization of Uranium Procurement Strategies for the CAPC0 Companies,"
January 1976.
Garrick, B. J., and S. Kaplan, " Reliability Technology and Nuclear Power," 1975.
Garrick, B. J., S. Kaplan, "A Method for Evaluating Nuclear Plant Siting Concepts," presented before the Joint Committee on Atomic Development and Space, California Legislature, Sacramento, May 19, 1972.
Garrick, B. J., S. Kaplan, and O. C. Bald;1 ado, "On a Decison Theory Fonnalism for Nuclear Power Plant Siting," presented to the Conference on Unique Siting Concepts for Nuclear Power Plants, Joint Committee on Atomic Development and Space, Sacramento, California, May 9, 1972.
l 9
0759P070783
.-.-; . _ . - - . _ - - ~ . - - - - . - . . . - . . . - . ~ - . . . . . - - . . . . . . . . . .
SECOND SET OF IlffERROGA'IORIES PROPOUNDED TO PACIFIC GAS AND ELEC7MIC COMPANY BY GOVERNOR DEUKMFJIAN
)
~.
I have assisted in preparing the answers to Interrogatories 1 - 4 and_13 - 19 inclusive _.
Said answers are true and correct to the best of my knowledge and belief.
'~
g/lt.1td -
Thomas G. deUriarte Subscribed and sworn to before me this 25th day of July, 1983.
I.mmumumimiimm C. T.11EAL MADISON
!!3fiaW ?.':LIC - CALIFORN!A i mmmiim. i j
- Clf f NIO COUNTY OF i SAN IHAt CISCO i Mr Co.:in: An hires Dn. 27,1985 I
[ G J /[N .
485311500000053 B 88818848.8158 e s 4 E 6 a 48888834888831881830t 3 T. Neal Mad'ison, Notary Public i
/
i _C.
j in and for the City and County
! of San Francisco, State of California 1 1
4 My Comission expires December 27, 1985 l l
~ . - ~ . . , , . ,; u .. . . . . , ,
SFXDND SET OF IlffERROGNIORIES PROPOUNDED 'IO PACIFIC GAS AND EIEC'IMIC COFSANY BY 00VERIOR DEUW2JIAN I
I have assisted in preparing the answers to Interrogatories _ _5 through 12, 30, and 31 .
Said answers are true and correct to the best of my knowlc*3ge and belief.
John Hoch subscribed and sworn to before me this 25th day of July, 1983.
\
3 ~C. T. Ibal Madison, Notary Public i in and for the City and County i of San Francisco, State of California .
My Comission expires December 27, 1985 i
. . I I
SECOND SET OF IlffERROGNIORIES
- ,. PROPOUNDED 'IO PACIFIC GAS AND EIEC'rRIC COMPANY 7' _
BY GOVERNOR DWKMEJIAN d
- sy .
- f u
I have assisted in preparing the answers to Interrogatories _20, 22, 24, 25, 26, 28, 29, 32,34 and 35. l Said answers are true and correct to the best of my knowledge l
and belief. f l .
l xscw l '
Richard C. Anderson Subscribed and sworn to i l
before me this 25th day of July, 1983.
ItHittattultittllillf tttilitlitfl5ll180819101488009 C. T. NEAL MADISON NOT.'RY P'JXIC - CALIFORN!A OIT( AND COUNTY OF
}
[,7 [/fdfN C. T. Heal Madison, Notary Public Ia@nuusuinuninu SAN titANCISCO tir kmna tspiru De 27,1985 in and for the City and County f of San Francisco, State of California My Coianission expires December 27, 1985
s e SECOND SET OF INTfRROGA'IORIES PROK)UNDED 'IO PACIFIC GAS MO FLEC'IMIC COMPANY BY GCNERNOR DEUKMFJIAN s.
I have assisted in preparing the answers to Interrogatories 20, 22, 24, 25, and 26 .
l Said ancwers are true and correct to the best of ray knowledge and belief.
jL. 5 .
Dr. William H. White subscribed and sworn to before me this 25th day J of July, 1983.
13188888383458184111 f:51 B38446 tee eg g gg g ela g s s t a g ge e s g e gg C. T. NEl.L MADISON
! H3E?Y ?IllC - CAllFORNIA Cl; f A;iD COUNTY OF SAN FRANOISCO I 4 tifiltlllit e, c-+% tillilit <ms t ;88888 t g a l 3 d'. 7.'~
//a/Af.ade. r+= o . n.
C. T. Neal Madison, Notary Public__
in and for the City and County i of San Francisco, State of I california My Coitanission expires December 27, 1985
_ _______.___.._-___--______-__-__m
['* t e ,
SECOND SF7P OF INTERROGA'IORIES
,y PROPOUNDED 'IO PACIFIC GAS AND ELEC'1RIC COMPANY r BY 00VERNOR DFUKMEJIAN
.. -E
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. I, I have assisted in preparing the answers to Interrogatories 22, 26, 28, and 29 .
Said answere,are true and correct to the best of my knowledge and belief.
N1 -
A Gary H. re Subscrilxx] and sworn to before me this 25th day of July, 1983.
f Illlll8BIllllllistillF18tlHellsig33tgegesgesaggesspellt l C. T. NEAL MADISON CIT ( AND COUNTY OF
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MJ//ftw I@ N0ffRY ?JM C. T. Neal Midison, Nota ry PIiElic "*"*"""""""*"*""""""*"*""
SAN FRM6CtSCO ar cowen r@n on. 27,19ss i
[ in and for the City and County
- i of San Francisco, State of
~! California .
1 l
My.Coinnission expires December 27, 1985
e o SECOND Sict OF IND:RROGA'IONIES PROPOUNDED 'IO PACIPIC GAS AND ELEC'Dt1C COMPANY BY 00VERNOR DEUKMEJIAN 1
'i 4.
I have assisted in preparing the answers to Interrogatories 32 . i Said answers are true and correct to the best of my knowledge and belief.
Gregory V. Cranston Subscribed and sworn to before me this 25th day of July, 1983.
,I E T. Neal Madison, Notary Public in and for the City and County 3
i-of San Francisco, State of California ;.
My Comission expires December 27, 1985
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ee o e
SECOND SET OF INTERROCA'IORIES
' ,r -- PROPOUNDED 'IO PACIFIC GAS AND EIECTRIC COMPANY BY GOVERNOR DEUKMEJIAN
=
1
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I have assisted in preparing the answers to Interrojatories 33 .
Said answers are true and correct to the best of my knowledge and belief,
/ h /
c db V D. G. Lubbock Subscribed and sworn to before me this 25th day of July, 1983.
I m m u u uC.u T.miNEAL m ,i,,,,,,,,,,,n,,,,,,,,,,,,,,,n,,,,
MADISON l NOTt2/ P13tK - CAllf0RNIA cist A:D COUNTY OF
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- _ mmmum,n.r Co.n ai ,,,,anIni, ,,:ren Dec.
n u . a.,
T,1985
,,,, n ,, ,,, ,, , ,,,
i C. T. Heal Madison, Notary Public 3
in and for the City and Cour.ty i
of San Francisco, State of California My Commission expires December 27, 1985
. - .... n . at ..x . .- -. . - - - - - -
- " 6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
In the Matter of )
. I PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275
) Docket No. 50-323 Diablo Canyon Nuclear Power Plant, )
Unito 1 and 2 )
)
CERTIFICATE OF SERVICE -
The foregoing document (s) of Pacific Gas and Electric Company has (have) been served today on the following by deposit in the United States mail, properly stamped and addressed:
Judge John F. Wolf Mrs. Sandra A. Silver chairman 1760 Alisal Street Atomic Safety and Licensing Board ~ San Luis Obispo CA 93401 US Nuclear Regulatory Commission Washington 'DC 20555 Mr. Gordon Silver 1760 A11 sal Street Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission John Phillips, Esq.
- Washington DC 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest
, Judge Jerry R. Kline 10951 W. Pico Blvd. - Suite 300 Atomic Safety and Licensing Board Los Angeles CA 90064 -
US Nuclear Regulatory Commission Washington DC 20555 David F. Fleischaker, Esq.
P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer 1493 Southwood Arthur C. Gehr, Esq.
San Luis Obispo CA, 93401 Snell & Wilmer 3100 Valley Bank Center Janice E. Kerr, Esq. Phoenix AZ 85073 Public Utilities Commission
' State of California Bruce Norton, Esq.*
5246 State Building Norton, Burke, Berry & French, P.C.
350 McAllister Street P. O. Box 10569 l San Francisco CA 94102 Phoen,ix AZ 85064 Mrs. Raye Fleming Chairman t 1920 Mattic Road Atomic Safety and Licensing l Shell Beach CA 93449 Board Panel US Nuclear Regulatory Commission !
Mr. Frederick Eissler Washington DC 20555 Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara CA 93105 :
he o Chalunan Judge Thomas S. Moore
- Atomic Safety and Licensing Chainnan Appeal Panel Atomic Safety and Licensing US tluclear Regulatory Commission Appeal Board Washington DC 2p555 US Nucicar Regulatory Concission Washington DC 20555 Secretary.
US Nucicar Regulatory Commission Judge W. Reed Johnson
- Washington DC 20555 Atomic Safety and Licensing Appeal Board Attn:
Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555 Lawrence J. Chandler, Esq.*
Judge John H. Buck
- Jack R. Goldberg, Esq. Atomic Safety and Licensing US Nuclear Regulatory Commission . Appeal Board Of fice of Executive Legal Director US Nuclear Regulatory ConJnission Wa shi ng ton -- DC 20555 Washington DC 20555 Mr. Richard B. Hubbard Michael J. Strumwas swer, Esq.
- MllB Technical Associates Susan L. Durbin, Esq.
1723 Hamilton Avenue, Suite K Peter 11. Kaufman, Esq.
San Jose CA 95125 3580 Wilshire Blvd. Suite 800 Mr. Carl Neiberger L s Angeles, CA 90010 Maurice Axelrad, Esq.
- L w nstein, Newman, Reis, and Axelrad, P.C.
San Luis Obispo CA 93402 1025 Connecticut Ave, N.W.
Washington, D.C. 20036
- Sent by Courier on July 25, 1983.
- - h /
Pacific Gas and Electric Company Dator ' July 25, 1933 l .
O G 9