ML20077Q347
| ML20077Q347 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/09/1983 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | CALIFORNIA, STATE OF |
| References | |
| NUDOCS 8309160070 | |
| Download: ML20077Q347 (29) | |
Text
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@ R 18 " N k L .gyo 1 UNITED STATES OF AMERICA SEP 15 Ali:03 2 NUCLEAR REGULATORY COMMISSrION 3 -
4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5
6 7
.In the Matter of )
8 ) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) 50-323
- 9 )
(Diablo Canyon Nuclear Power ) (Reopened Hearing --
10 Plant, Units No. 1 and 2) ) Design Quality
) Assurance) 11 12
, 13 14 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S
> FOURTH SET OF INTERROGATORIES TO GOVERNOR DEUKMEJIAN
. 15 16 17 18 INSTRUCTIONS 19 Instructions given for prior sets of interroga-20 tories shall apply. Unless otherwise specified,' references 21 herein to an interrogatory by number shall refer to Licensee's 22 Second Set of Interrogatories to Governor Deukmejian; reference 23 by contention number shall refer to the contentions as set 24 'forth in the Board Order dated August 26, 1983.
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i 8309160070 830909 gDRADOCK05000
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1 INTERROGATORY NO. 1:
2 Please update all answers to all interrogatories 3 heretofore propounded to you (Sets 1 through 3) to which you 4 have indicated that your review, study, or investigation was 5 not then complete.
6 INTERROGATORY NO. 2:
7 Do you consider that the application of engineering 8 judgment by the IDVP which is different from judgment by the 9 DCP in the development of models or the conduct of analyses 10 or the interpretation of criteria n'ecessarily indicates a 11 " quality assurance breakdown" (as previously defined by you) 12 by the DCP?
13 (a) Do you consider that such application of engineering 14 judgment by the IDVP in such circumstances indicates a 15 design error?
16 INTERROGATORY NO. 3:
17 In your opinion does the application or development 18 of a model or the conduct of an analysis according to state-19 of-the-art practices at the time of the original design of 20 Diablo Canyon Nuclear Power Plant or the Hosgri " reevaluation 21 constitute a design error where the state of the art for 22 such model or analysis has advanced today?
23 (a) If your answer is affirmative, identify who has rendered 24 this opinion.
25 (b) State each and every fact which forms the basis of the 26 opinion.
I 1 (c) ' Identify each document relied upon to form the basis of 2 the opinion with specific reference to the section and ,
3 page of the document.
4 INTERROGATORY NO. 4:
5 In your opinion, does the existence of each and 6 every single design. error establish that a "q'uality assurance 7 breakdown" has occurred?
8 '(a) If so, identify who has rendered this opinion.
9 (b) State each and every fact which ' forms the basis of the 10 opinion.
11 (c) Identify each document relied upon to form the basis of 12 the opinion with specific refe.ence to the section and 13 page of the document.
14 INTERROGATORY NO. 5:
15 As used by you, is there any difference between 16 the terms " licensing criteria" and " licensing commitment?"
17 (a) If so, explain fully the difference or distinction.
18 INTERROGATORY NO. 6:
! 19 Is it your opinion that any deviation from a 20 licensing criteria or commitment necessarily makes the 21 Diablo Canyon Power Plant unsafe?
22 (a) If so, state the name of each such person who has 23 rendered such opinion.
24 '(b ) State each and every fact which forms the basis of the 25 opinion.
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1 (c) Identify each document relied upon to form the basis of j 2 the opinion with-specific reference to the section and 3 Page of the document.
4 INTERROGATORY NO. 7:
5 In your answer to Interrogatory 50, you stated 6 "the IDVP did not verify samples from each seismic design 7 activity or from each seismic design group."
8 (a) As used in such response, define the term " verify. "
9 (b) Define the term " samples" and give a typical example 10 thereof.
11 (c) Define " seismic design activity" and give a typical 12 example thereof.
13 (d) Define " seismic design group" and give a typical example 14 thereof.
15 INTERROGATORY NO. 8:
16 In your answer to Interrogatory 50, you presented 17 an example "of a design group and activities not fully 18 reviewed by the IDVP and the ITP."
19 (a) As here used, explain the phrase, "not fully reviewed."
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20 INTERROGATORY NO. 9:
21 In your answer to Interrogatory 62, you stated 22 that your there-referenced contention was " based on the lack 23 of documentation by the IDVP of a ful} verification by it."
24 (a) As there used, define " full verification."
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1 INTER'ROGATORY NO. 10:
2 In your answer to Interrogatory 63, you stated 3 that "a complete verification is not documented by the 4 IDVP."
5 (a) As there used, define "a complete verification."
6 (b) Does this definition apply to all instan'ces wherein you 7 have used this term in your answers to interrogatories?
8 '(c) Give an example of what constitutes a " complete
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9 verification" as opposed to just a " verification."
10 INTERROGATORY NO. 11:
11 In your answer to Interrogatory 66, you identify 12 " cases where the IDVP failed to ascertain the root cause of 13 the identified discrepancy."
14 (a) As there used, define " root cause."
, 15 (b) Do you consider " root cause" to mean the same as the 16 term " basic cause" in Appendix B to 10 C.F.R. part 50?
17 (1) If not, please explain the difference between the 18 two terms.
19 INTERROGATORY NO. 12:
20 In your answer to Interrogatory 68, you state that 21 your review indicated to you that "the IDVP has failed to 22 verify independently" that all safety-related SS&C meet
- 23 licensing requirements.
24 '(a) As there used, define " verify independently."
25 (b) Do you mean that the IDVP " verified," but that the 26 verification was not " independent?"
1 1 INTERROGATORY NO. 13:
2 Do you have knowledge of facts that indicate the 3 IDVP was required by the Commission, the Staff, or otherwise 4 to do anything more than " consider" the use of statistical 5 techniques? If so:
6 (a) Identify each such fact.
7 (b) Identify the source of the fact.
8 (c) Identify each document by page and paragraph where the 9 fact is contained or even arguably inferred.
10 INTERROGATORY NO. 14:
11 In Interrogatory 70, you were asked to provide 12 each and every fact upon which you base your contention that 13 the IDVP has performed no independent verifications, but has 14 merely checked data inputs to models used by PGandE. In 15 your response, you indicated that your contention was based 16 on the " lack of complete, independent analyses."
17 (a) Define the term " independent verification" as used in 18 your' contention.
19 (b) Define the term " independent analyses" as used in your 20 answer.
21 (c) Define and give an example of what is a " complete, 22 independent analysis."
23 (d) Do you consider that the term " complete, independent 24 analyses" means the same as " independent verifications?"
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l 1 (e) ' Identify each analysis in your answer to Interrogatory l
2 70 which you consider to have been limited by either a 3 lack of independence and/or completeness.
4 (1) Explain specifically how each was limited.
5 INTERROGATORY NO. 15:
6 Do you have knowledge of facts tha't the IDVP is 7 required by the Commission, Staff, or otherwise to conduct ~a 8 " full, independent analysis" of the seismic design of all 9 structures? If so:
10 (a) Identify each such fact.
11 (b) Identify the source of the fact.
12 (c) Identify each document ny page and paragraph where the 13 fact is contained or even arguably inferred.
14 INTERROGATORY NO. 16:
15 Do you have knowledge of facts that the IDVP is 16 required by the Commission, Staff, or otherwise to conduct 17 "an independent verification of the correctness and reasonable-18 ness of PGandE's modeling of soil properties and soil structure 19 interaction for the Containment Building?" If so:
20 (a) Identify each such fact.
21 (b) Identify the source of the fact.
22 (c) Identify each document by page and paragraph where the 23 fact is contained or even arguably inferred.
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1 INTERROGATORY NO. 17:
-2 What facts or opinions do you have that indicate 3 to you that PGandE's modeling of soils properties and soils 4 structure interaction for the containment building are 5 incorrect or are unreasonable?
6 (a) Identify each person who has rendered such an opinion.
7 (b) State each and every fact which forms the basis of the 8 opinion. .
9 (c) Identify each document relied upbn to form the basis of 10 the opinion with specific reference to the section and 11 page of the document.
12 INTERROGATORY NO. 18:
13 If you consider that any model or method of analysis 14 utilized by DCP is inappropriate, do you have any analysis 15 to indicate to you that such model or method of analysis 16 employed is incorrect?
17 (a) What models do you consider to be incorrect and/or 18 inappropriate?
19 (b) In what way is each incorrect and/or inappropriate?
20 (c) What analysis do you consider to be incorr'ect and/or 21 inappropriate?
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22 (d) In what way is each analysis incorrect and/or inappropriate?
23 (e) What analyses, studies, or calculations are you aware 24 of that show any of the models or analyses you have set 25 forth in your answer to 18(a)-(d) are incorrect and/or 26 inappropriate?
1 (f) ' Identify each document where each analysis, study, or 2 calculation set forth in your answer tc 18(e) may be 3 found.
4 INTERROGATORY NO. 19:
5 Do you consider that hand calculations are not 6 formal calculations?
7 (a) Do you consider that hand calculations are inferior to 8 computer outputs as a general principle?
9 INTERROGATORY NO. 20:
10 Identify each and every document that Dr. Roesett 11 has reviewed or utilized in preparation of answers to 12 interrogatories propounded by PGandE to Governor Deukmejian 13 (Sets 1 through 4).
14 INTERROGATORY NO. 21:
15 Identify each and every document that Dr. Roesett 16 has as of September 26, 1983, reviewed or utilized in prepar-17 ation of his written testimony to be filed October 8, 1983.
18 INTERROGATORY NO. 22:
19 Identify each and every document that Dr. Roesett 20 has reviewed or utilized in preparation for his ' deposition.
21 INTERROGATORY NO. 23:
22 Contention 3 provides that in some instances where 23 it is contended that the ITP used improper engineering 24 ' standards, the IDVP either uced or approved the use of such 25 improper standards.
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1 (a) Define precisely what you mean by " engineering standard."
2 (b) Identify specifically each and every engineering standard 3 the use of which is considered to be improper.
4 (c) Identify specifically each and every instance where you 5 contend that the IDVP approved the use of each such 6 standard set forth in your response to Interrogatory 7 23(b).
8 (d) Identify specifically each and every instance where you 9 contend that the IDVP failed to verify use of any 10 engineering standard, and stat'e whether you believe 11 each such engineering standard was used properly or 12 improperly by the ITP.
13 (e) For each answer to 23(b), (c), and (d), specify the 14 full factual basis for your answer, and identify each 15 document by page and line on which you rely for each 16 such answer.
I 17 INTERROGATORY NO. 24:
18 Contention 4 contends that the IDVP accepted 19 deviations from the licensing criteria without adequate
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20 engineering justification.
21 (a) List each and every criteria from which there was a 22 deviation.
23 (b) List each and every licensing commitment from which there 24 was a deviation.
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1 (c) What, in your opinion, would constitute " adequate 2 engineering justification" for acceptance of each such 3 deviation from licensing criteria?
4 (d) What, in your opinion, would constitute " adequate 5 engineering justification" for acceptance of each such 6 deviation from a licensing commitment?
7 (e) Identify each document by precise page number where 8 each and every " licensing criteria" and " licensing 9 commitment" which you claim was deviated from may be 10 found.
11 INTERROGATORY NO. 25:
12 Explain in detail what actions you consider necessary 13 for the verification program to " verify" that Units 1 and 2 14 "as built" conform to the design drawings and analyses.
, 15 INTERROGATORY NO. 26:
16 Identify specifically each and every action by the 17 verification program, not already being performed, which you 18 consider to be necessary in order to " verify" that the 19 design of safety-related equipment supplied to PGandE by 20 Westinghouse meets licensing criteria.
i 21 INTERROGATORY NO. 27:
22 Contention 1 contends, in part, that the IDVP was 23 too narrow in that in the design activities it did review, 24 it did not verify samples from each of the design groups in 25 the design chain performing the design activity.
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1 (a) Define " design group."
2 (b) Define " design activity."
3 (c) Define "the design chain," and give a typical example 4 thereof.
5 (d) Define " samples."
6 INTERROGATORY NO. 28:
7 Explain fully why you consider that the use of the 8 mean-measured performance of structures and materials in 9 lieu of code-specified minima is an' improper engineering 10 practice.
13 INTERROGATORY NO. 29:
12 Explain fully why you consider that the failure to 13 specify all damping values in various seismic modes in the 14 containment building and auxiliary building constitutes an 15 improper engineering practice.
16 INTERROGATORY NO. 30:
17 Explain fully why you consider that use of the 18 double algebraic-sum method of calculation (rather than the 19 sum-of-the-squares method) constitutes an improper engineering
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20 practice.
21 INTERROGATORY NO. 31:
22 Explain fully why you consider that the ITP's use 23 of time-history modeling techniques for some accelerations, 24 displacements, and shell forces in the containment structure 25 and Blume response spectra for other accelerations, 26 ///
1 displ'a cements, and shell forces in the same structure 2 constitutes an improper engineering practice.
3 INTERROGATORY NO. 32:
4 Indicate those portions of the ITP's modeling of ,
5 the soil properties for both the containment and auxiliary 6 buildings you consider to be improper, and ex' p lain fully the 7 . reasons for such opinion.
8 '(a) Was the modeling employed by the ITP an improper 9 engineering practice?
10 (b) If yes, explain fully why you consider it to be an 11 improper practice?
12 INTERROGATORY NO. 33:
13 Indicate those portions of the ITP's modeling of 14 the crane in the turbine building you consider to be improper,
. 15 and explain fully the reason for such opinion.
16 (a) Was the modeling employed by the ITP an improper 17 engineering practice?
18 (b) If yes, explain fully why you consider it to be an 19 improper practice?
, 20 INTERROGATORY NO. 34:
21 Explain fully why you consider that the use of 22 different techniques for modeling of torsion factors for 23 different buildings is an improper engineering practice.
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1 INTERROGATORY NO. 35:
2 Explain fully why you consider that the ITP's 3 modeling of hydrodynamic forces for the intake structure was 4 an improper engineering practice.
5 INTERROGATORY NO. 36:
6 Explain fully why you consider that the ITP's 7 modeling of the intake structure was improper.
8 INTERROGATORY NO. 37: .
9 Explain fully why you consider that the absence of 10 use of two horizontal components for the DE and DDE was 11 improper.
12 INTERROGATORY NO. 38:
13 Explain fully why you consider that the ITP's 14 stress values for concrete in shear walls used in modeling 15 the auxiliary building were improper or incorrect.
16 INTERROGATORY NO. 39:
17 For each of the interrogatories numbered 28 through le 38 above, do you have knowledge of any facts which indicate 19 to you that the practice or activity you consider to be 20 improper renders the structure, material, or component 21 involved to be unsafe?
22 (a) If so, state fully what those facts are.
23 (b) List what studies you have conducted or have reviewed 24 which support such conclusion, and identify the author 25 of each such study.
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1 INTEPAOGATORY NO. 40:
2 For each of the interrogatories numbered 28 3 through 38 above, do you have knowledge of any facts which 4 indicate to you that the practice or activity you consider 5 to be improper has resulted in a failure to meet a licensing 6 criteria or licensing commitment.
7 (a) If so, state fully what those facts are.
8 '(b) If so, identify which licensing criteria or licensing
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9 commitment you consider have not been met.
10 (c) List what studies you have conducted or have reviewed 11 which support such conclusions and identify the author 12 of each such study.
13 INTERROGATORY NO. 41:
14 For each interrogatory in the Licensee's Second 15 Set of Interrogatories to Governor Deukmejian to which you 16 previously responded that the absence of documentation 17 indicates to you a failure to fully verify or completely 18 verify an'act, a judgment, a decision, an analysis, a model, 19 or the correctness or appropriateness of such, list all the
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20 documents you reviewed in order to reach each such conclusion.
21 INTERROGATORY NO. 42:
22 In your response to Interrogatory 68, define the 23 "certain specific conditions" that you consider to be valid 24 'for extension of the IDVP conclusions to unreviewed portions 25 of the plant.
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1 INTERROGATORY NO. 43:
2 Contentions -1(c) and 2(c) alleged that the IDVP 3 and ITP, respectively, did not have " statistically valid 4 samples from which to draw conclusions." Define what you 5 consider to be a " statistically valid sample" from which to 6 draw conclusions and give an example thereof.
7 INTERROGATORY NO. 44:
8 Define what you consider to be " statistically 9 valid sampling technicques" as used' in your answer to 10 Interrogatory 68.
11 (a) Explain and give examples of the techniques you consider 12 would be statistically valid.
13 INTERROGATORY NO. 45:
14 Define what you consider should be the criteria 15 for the selection of samples.
16 INTERROGATORY NO. 46:
17 Define what you consider should be the criteria 18 for the acceptable degree of confidence.
19 INTERROGATORY NO. 47:
20 Define what you consider should be' th'e criteria 21 for the review or verification of the sample.
22 INTERROGATORY NO. 48:
23 Define what you consider should be an acceptable 24 sample size.
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1 INTERh0GATORY NO. 49:
i 2 Define what you consider should be the criteria 3 for additional sampling.
4 INTERROGATORY NO. 50:
5 With regard to your response to Interrogatory 76, 6 please provide the following:
7 (a) Indicate in detail references to PGandE documentation 8 that substantiates the factual nature of the alle-9 gation.
10 (b) Indicate in detail references to PGandE documentation 11 showing what, if any, licensing criteria or commitments 12 have been violated by the use of the two different 13 analyses of the containment building.
14 INTERROGATORY NO. 51:
15 In regards to your response to Interrogatory 78, 16 please indicate in detail references to PGandE documentation 17 showing what, if any, licensing criteria or commitments have 18 been violated by the use of somewhat different seismic 19 analyses for the containment building for Hosgri vs. DE and
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20 DDE.
21 INTERROGATORY NO. 52:
22 In regards to your response to Interrogatory 86, 23 please indicate in detail references to PGandE documentation 24 showing what, if any, licensing criteria or commitments have 25 been violated by the use of 4% damping values for the DE and 26 DDE in modeling of the auxiliary building.
1 INTERROGATORY NO. 53:
2 In regards to your response to Interrogatory 88, 3 indicate in detail references to PGandE documentation 4 showing what, if any, licensing criteria or commitments have 5 been violated by the use of less conservative value, than 6 that of ACI 318-77, . for the concrete in the shear walls of 7 the aAuxiliary building.
8 INTERROGATORY NO. 54: .
9 In response to Interrogato'y r 92, indicate what 10 licensing criteria or commitments have been violated by the 11 use of the two different methods of summing member forces 12 for the Hosgri.
13 INTERROGATORY NO. 55:
14 In response to Interrogatory 94, indicate what 15 licensing criteria or commitments have been violated by 16 increasing horizontal motion by 10% to account for accidental 17 eccentricity in the turbine building and intake structure.
18 INTERROGATORY NO. 56:
19 In response to Interrogatory 98, indicate what 20 licensing criteria or commitments have been viol'ated by the 21 use of different analyses for the loaded and unloaded case 22 and by use of the SRSS method to combine the three directions 23 of earthquake motion.
24 INTERROGATORY NO. 57:
25 In response to Interrogatory 100, indicate what 26 licensing criteria or commitments have been violated by use
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l 1 of du'ctility factors of 1.3 for concrete and 3 for steel 2 combined with 7% damping for the Hosgri event.
3 INTERROGATORY NO. 58:
4 Define the following terms as referenced in response 5 to Interrogatory 60:
6 (a) " expect statistical assistance" 7 (b) " rigorous statistical technique" 8 '(c) " sampling procedure" 9 (d) " sampling criteria" 10 (e) " sampling acceptance criteria" 11 (f) " valid random samples" 12 (g) " subjective engineering judgment" 13 (h) " representative of the populations to which conclusions 14 were extrapolated" 15 INTERROGATORY NO. 59:
16 As referenced in your response to Interrogatory 64, 17 for each claimed deviation listed in Table 64, list what you 18 consider 'to be the criteria or commitments deviated from.
19 INTERROGATORY NO. 60:
20 As referenced in your response to I'terrogatory n 66, 21 identify each valid EOI. For each, identify and list what 22 you consider to be the two errors associated with each valid 23 EOI. Identify and list what you consider to be the error 24 'itself and the associated error or errors in the QA program 25 or the implementation thereof.
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1 SUPPLEMENTAL INSTRUCTIONS 2 The following questions relate to the contentions 3 of the Governor and the Joint Intervenors as particularized 4 and set forth in the document dated and signed September 8, 5 1983, by couhlsel for such parties.
6 INTERROGATORY NO. 61:
7 In Contention 3(f)(i), you contend that use of 8 boundary motion inputs to the model for the soil structure 9 interaction analysis of the containment for the DE and DDE 10 was improper.
11 (a) Explain in detail why you consider the use to be improper.
12 INTERROGATORY NO. 62:
13 In Contention 3(f)(ii), you contend that a 7%
14 damping value for rock is unconservative and especially so 15 for the DE.
16 (a) Explain in detail how you think the 7% damping figure 17 was used in the ITP's modeling of soil properties for 18 the containment building and for the auxiliary building.
19 (b) Explain what you consider to be a conservative value 20 for damping?
21 (1) for rock 22 _(2) for soil 23 (3) for each for the DE 24 (c) Were the values employed by the ITP not conservative in r 25 your opinion?
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1 '(1) If yes, specify which damping values you consider 2 not to be conservative.
3 INTERROGATORY NO. 63:
4 Do you consider that an omission of analysis of 5 the containment for uplifting of the foundation mat renders 6 the containment unsafe? -
7 (a) If so, what studies, calculations, or analyses have you 8 conducted or reviewed which supports this conclusion?
(1) State in detail the results of each such study, -
9 10 calculation, or analysis.
11 (b) List all licensing criteria or commitments which, in your 12 opinion, the absence of an analysis for uplifting violates:
13 (')
l Explain fully how each criterion or commitment is 14 violated.
15 INTERROGATORY NO. 64:
16 Explain fully why you consider the lack of specifica-17 tion of soil properties in the modeling of soil springs for 18 the auxiliary building to be improper.
19 INTERROGATORY NO. 65:
20 In Contention 3(f)(v), you contend ~ th'at, in the 21 ITP's modeling of the soil springs for the auxiliary building, 22 the motion inputs to the lower ends of the springs do not 23 account for all soil structure interaction phenomena that 24 'could be expected.
25 (a) How should the motion inputs to the lower ends of the 26 springs be modeled in your opinion?
1 (b) Do you have any analysis, calculation, or study which 2 indicates or quantifies the change in soil structure 3 interaction which would result from the application of 4 the manner of modeling which you prefer?
5 (1) If so, state in detail the results of each such 6 analysis,. calculation, or study.
7 (c) Do you consider that the effect any difference in soil 8 structure interaction which you may have found in any 9 such analysis, calculation, or study listed in (b) renders 10 the auxiliary building unsafe?
11 (1) If so, explain fully.
12 (d) Do you consider the modeling approach of the ITP to be 13 a deviation from standard industry practice?
14 (1) If so, explain fully the reason for such conclusion.
15 (2) List each and every document you rely upon to reach 16 such conclusion.
17 INTERROGATORY NO. 66:
18 How should the crane in the turbine building have 19 been modeled in your opinion?
20 INTERROGATORY NO. 67:
21 In Contention 3(h), you contend that PGandE's 22 modeling of torsion factors is not shown to be conservative 23 and is unconservative in at least one case.
24 (a) In the context used, define " conservative" and quantify.
25 (b) Specify the particular case which you consider to be 26 "unconservative."
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1 (c) What studies, analyses, or calculations do you have 2 knowledge of that indicate PGandE's modeling results in i
3 an unsafe structure or component?
4 INTERROGATORY NO. 68:
5 Explain in detail how, in your opinion, the sloshing
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6 effects for inside water and hydrodynamic pressure on the 7 outside of intake structure should have been included in the 8 'modeling.
9 (a) Define "not considered" as used in the contention.
10 (b) What is the significance from the standpoint of safety 11 of a failure to consider such factors?
12 INTERROGATORY NO. 69:
13 Etplain fully why you consider that the combination 14 of linear and nonlinear analyses for different loads in the 15 modeling of the crane at the intake structure is improper.
16 (a) Do you have any study, calculation, or analysis which 17 indicates that such combination renders the intake 18 stru'cture unsafe?
19 (1) If so, describe fully the results of such study, 20 calculation, and analysis.
21 (b) What licensing criteria or licensing commitment is 22 violated by such combination.
23 (c) Do you consider that such combination would be proper 24 with justification?
25 (1) If so, what do you consider to be " adequate 26 justification?"
1 INTERROGATORY NO. 70:
2 Do you have knowledge of any facts or opinion 3 which would lead you to conclude that the ductility estimates 4 utilized in the ITP's modeling of the intake structure are 5 incorrect?
6 (a) If so, identify and list each and every such fact.
7 (b) Identify the source of any such opinion and state in 8 detail what that opinion holds. .
9 INTERROGATORY NO. 71:
10 In Contention 3(1), you contend, in the computations 11 of modes in the containment building having frequencies 12 between 20 and 30 Hz, that it is not clear that criteria 13 were correctly applied.
14 (a) List each criterion to which the contention refers.
15 (b) Explain fully in what way or manner it is not clear to 16 you whether each such criterion was correctly applied.
17 (c) How, in your opinion, should each of the criterion 18 identified be applied.
19 INTERROGATORY NO. 72:
20 In Contention 3(m), you contend that 'it is not 21 clear whether in the ITP's modeling of the containment 22 building for the DE and DDE criteria were correctly applied.
23 (a) List each criterion to which the contention refers.
24 (b) Explain fully in what way or manner it is not clear to 25 you whether each such criterion was correctly applied.
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1 INTERROGATORY NO. 73:
2 In Contention 3(n), you contend that the stress 3 value for concrete used by the ITP in modeling shear walls 4 in the auxiliary building was improper.
5 (a) Do you consider that the stress value used by the ITP 6 is not conservative?
7 (b) If not, what value do you consider to be conservative?
8 (1) Identify each and every study or analysis that you 9 rely upon for such conclusi' on.
10 (c) Identify each and every fact, study, calculation, and 11 analysis you rely upon to support your contention that 12 the values used "may cause wide cracks."
13 (1) Define what you consider to be a " wide crack."
14 (2) How wide, in your opinion, would a crack need to 15 be before it became significant for the auxiliary 16 building?
17 INTERROGATORY NO. 74:
18 In Contention 4, you contend that the IDVP has 19 accepted deviations from the licensing criteria without 20 adequate engineering justification.
21 (a) As used in this contention, define " accepted."
22 (b) Ddfine " adequate engineering justification."
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1 (c) List each and every fact upon which you rely to support 2 the contention that the IDVP " accepted deviations from 3 the licensing criteria."
4 INTERROGATORY NO. 75:
, 5 For each answer to these interrogatories and all 6 sub-parts thereto, identify each person who participated in 7 the preparation of your answers pursuant to 10 C.F.R. section 8 2.740(b). .
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1 - Respectfully submitSt?d , _
3 ' ' '
2 ROBERT'OHLBACH PHILIP.A.. CRANE, JR . ,
3 RICHARD f. LOCKE t Pacific Gas and Electric Company-_
4 P. O. Box 7442 San Francisco, CA' 94120 ,
5 u (415) 781-4211 6 '
ARTHUR C. GEHR
-Snell & Wilmer .
-7 3100 Vcaley: Center + ,
Phoenix, AZ 85073 8 '
(602) 257-7288
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BRUCE NORTON ..
Norton, Burke, Berry & French ,, 'P.C. -
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P. O. Box 10569 ,
Phoenix, AZ 85064 11 (602) 955-2446 12 Attorneys for '
Pacific Gab and Electriq Company ' -
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16 Bruce Norton 4 ,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LnETE:
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In the Matter of - )
Docket No. 50-275 13 EP 15 21 :03 PACIFIC GAS AND ELECTRIC COMPANY
) Docket No. 50-323 I Dicblo Canyon Nuclear Power Plant, ) CFFICE 0r SECFt!O 00CKEIING & SE?vif.:
Units 1 and 2 )
BRANCH
)
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 Concnission Wanhington DC 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission
- John Phillips, Esq.
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 David F. Fleischaker, Esq.
~
Weahington DC 20555 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 Scn Francisco CA 94102 Phoenix AZ 85064 Mrs. Raye Fleming Chairman 1920 Mattie Road Atomic Safety and Licensing Shall Beach CA 93449 Board Panel US Nuclear Regulatory Commission Washington DC 20555 -
Mr. Frederick Eissler ^
Scenic Shoreline Preservation {
Conference, Inc.
4623 More Mesa Drive Scnta Barbara CA 93105
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Chairman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Washington DC 20555 US Nuclear Regulatory Commission Washington DC 20555 Sacretary US Nuclear Regulatory Commission Judge W. Reed Johnson Wochington DC 20555 -
Atomic Safety and Licensing Appeal Board Attn: Docketing and Service US Nuclear Regulatory Commission Section Washington DC '20555 Lcwrence J. Chandler, Esq. Judge John H. Buck Hanry J. Me,Gurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission WaDhington DC 20555 Washingt6n DC 20555
- Mr. Richard B. Hubbard
- Michael J. Strumwasser, Esq.
MHB Technical Associates Susan L. Durbin, Esq.
1723 Hamilton Avenue Suite K Peter H. Kaufman, Esq.
San Jose CA 95125 3580 Wilshire Blvd. Suite 800 Los Angeles CA 90010 Mr. Carl Neiberger Talegram Tribune Maurice Axelrad, Esq.
P. O. Box 112 Lowenstein, Newman, Reis, and San Luis Obispo CA 93402 Axelrad, P.C.
1025 Connecticut Ave NW Washington DC 20036 Date: September 12, 198~3 47 / DAN d G. c[b LUBBOCK
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