ML20077P368

First Set of Interrogatories to Idvp.Certificate of Svc Encl

ML20077P368
Person / Time
Site:	Diablo Canyon
Issue date:	09/07/1983
From:	Havian E CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:
References
ISSUANCES-OL, NUDOCS 8309130354
Download: ML20077P368 (8)

Text

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i DOCK.ETED UNITED STATES OF AMERICA JSMC NUCLEAR REGULATORY COMMISSION g .

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD Yg'hf[TkSECRENp!

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In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) ) (Reopened Hearing --

) Design Quality

) Assurance)

JOINT INTERVENORS' FIRST SET OF INTERROGATORIES TO THE INDEPENDENT DESIGN VERIFICATION PROGRAM Please use the same instcuctions and definitions as those given in Governor Deukmejian's Third Set of Interrogatories to the Independent Design Verification Program.

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INTERROGATORY NO. 1:

For each Interim Technical Report ("ITR") issued or l

currently being prepared by the Independent Design Verification Program ("IDVP"), state whether sampling was used as part of the verification process, and, if so, described how sampling was l

l used.and the conclusions reached by the IDVP based on each instance of such sampling.

i INTERROGATORY NO. 2:

l For each ITR in which sampling was used as part of the verification process by the IDVP, state:

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(a) The size of each sample, and the basis for your determination of the size of each sample; (b) The confidence level that you obtained as a result of each sample, and the basis for your conclusion that the level of confidence is adequate.

(c) The size of the total population for each item being sampled, and the basis for your determination that each sample was representative of the total population of the item being sampled; (d) Your acceptance criteria with respect to items evaluated in each sample; (e) The factual basis for the criteria described in (d);

(f) The basis for your decision to expand the initial sample in those cases where the sample was expanded; (g) The basis for your decision not to expand the initial sample in those cases where the sample was not expanded; and (h) Every fact.upon which you based your decision to expand or not to expand the initial sample as described in (f) and (g).

INTERROGATORY NO. 3: ----

For each ITR in which sampling was the means of verification used by the IDVP, state each and every fact that supports.your. determination that the evaluation of the sample

items provides adequate assurance that items not sampled were satisfactory. -

INTERROGATORY NO. 4:

For each ITR in which sampling was the means of verification used by the IDVP, state:

(a) The criteria used to determine which items would be chosen for the initial sample; and (b) The basis for your decision to employ those criteria as opposed to other criteria.

INTERROGATORY NO. 5:

For each Error Open Item ("EOI") identified by the IDVP, state whether you ascertained the root cause of the EOI, and, if so, identify each such root cause.

INTERROGATORY NO. 6:

For each root cause identified in your response to

, Interrogatory No. 5, state the basis for your conclusion that such root cause was or was not indicative of a problem of generic i concern.

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INTERROGATORY NO. 7:

For each EOI in which the IDVP failed to ascertain the ~ --

root cause of the error, state the basis for your conclusion that such error was or was not indicative of a problem of generic concern.

INTERROGATORY NO. 8:

With respect to the analyses performed by Brookhaven National Laboratory ("BNL") , state:

(a) Whether the IDVP reviewed these analyses; (b) The manner in which the results of these analyses were utilized in the IDVP verification process; (c) Whether the IDVP verified that the results of these analyses were incorporated into the corrective action taken at Diablo Canyon, and if not, why not; and (d) Whether the IDVP agrees with the results of these analyses as interpreted and explained by BNL in NRC meetings.

(e) How, if at all, the results of these analyses were incorporated into the corrective action taken at Diablo Canyon by the DCP, and, if not, why not?

INTERROGATORY NO. 9:

With respect to the analyses performed by BNL that i

were found to be inconsistent with analyses done by PGandE or l the DCP, explain:

! (a) Your opinion of the reasons for each of the

( inconsistencies; and l

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(b) Why the IDVP failed to ascertain the inadequacies in the PGandE or DCP analyses prior to their disclosure by BNL. .

DATED: September 7, 1983 Respectfully submitted, JOEL R. REYNOLDS, ESQ.

JOHN R. PHILLIPS, ESQ.

ERIC R. HAVIAN, ESQ.

Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.

P. O. Box 1178 Oklahoma City, OK 73101' By U [

ERIC R. HAVIpH Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG l JOHN J. FORSTER i

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.- - . = . _ . . - . . . - . . . , - - -

P UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

) .

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L. l

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

)

CERTIFICATE OF SERVICE

, I hereby certify that on this 7th day of September, 1983, I

j. have served copies of the foregoing JOINT INTERVENORS' FIRST SET a

OF INTERROGATORIES TO THE INDEPENDENT DESIGN VERIFICATION *-

PROGRAM, mailing them through-the U.S. mails, first class, I

postage prepaid.

~

Thomas S. Moore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Commission Conference, Inc.

Washington, D.C. 20555'

4623 More Mesa Drive Santa Barbara, CA 93105 Dr. W. Reed Johnson .

l Atomic Safety & Licensing Malcolm H. Furbush, Esq.

Appeal Board _

Vice President & General U.S. Nuclear Regulatory Counsel Commission Philip A. Crane, Esq.

Washington, D.C. 20555 Pacific Gas & Electric Company 77 Beale Street, Room 3135 Dr. John H. Buck San Francisco, CA 94106 -- --

i - Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 9

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Docket and Service Branch

. Office of the Secretary U.S. Nuclear Regulatory Commission

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washington, D.C. 20555 -

Lawrence Chandler, Esq.

Office of the Executive Legal Director - BETH 042 U.S. Nuclear Regulatory Commission

, Washington, D.C. 20555 Janice E. Kerr, Esq.

Lawrence Q. Garcia, Esq.

J. Calvin Simpson, Esq.

California Public Utilities Commission 5246 McAllister Street San Francisco, CA 94102 John Van de Kamp, Attorney General Andrea Sheridan Ordin, Chief Attorney General ,

Michael J. Strumwasser, Special Counsel to the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, CA 90010

, David S. Fleischaker, Esq.

Post Office Box 1178 Oklahoma City, OK 73101 Richard Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, CA 95725

Arthur C. Gehr, Esq.

Snell & Wilmer j .

'3100 Valley Center

[ Phoenix, AZ 85073 j Bruce Norton, Esq.

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

l 2002 E. Osborn l Phoenix,.'AZ 85016

.* Maurice Axelrad, Esq..

Lowenstein, Newman, Reis & Axelrad, P.C. - --

1025 Connecticut Avenue,-N.W.

Washington,.D.C. 20036 Virginia and Gordon Bruno Pecho' Ranch' Post Office Box 6289 Los Osos,.CA 93402

_-. ~, _ ~ . , _- _ _ - . _ _ , _ _ _ . . . _ _ ~ , - . . . _ . _ . _ . _ . _ _ _ . _ , - - . , , . .

Sandra and Gordon Silver 1760 Alisal Street .

San Luis Obispo, CA 93401 Nancy Culver 192 Luneta San Luis Obispo, CA 93402 Carl Neiburger Telegram Tribune Post Office Box 112 San Luis Obispo, CA 93402 Betsy Umhoffer 1493 Southwood San Luis Obispo, CA 93401 CUL AMANDA VARONA l

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• Delivered via Express Mail

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