ML20077S691
| ML20077S691 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/19/1983 |
| From: | Crane P PACIFIC GAS & ELECTRIC CO. |
| To: | CALIFORNIA, STATE OF |
| References | |
| NUDOCS 8309220179 | |
| Download: ML20077S691 (140) | |
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00CXETED USNR0 1
UNITED STATES OF AMERICA
'83 SEP 21 F12:21 2
NUCLEAR REGULATORY COMMISSION 3
4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARL 5
6 7
8 In the Matter of
)
)
Docket Nos. 50-275 9
PACIFIC GAS AND ELECTRIC COMPANY
)
50-323
)
10 (Diablo Canyon Nuclear Power
)
(Reopened Hearing --
Plant, Units No. 1 and 2)
)
Design Quality 11
)
Assurance) 12 13 14 15 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO 16 GOVERNOR DEUKMEJIAN'S THIRD SET OF INTERROGATORIES AND SECOND DOCUMENT PRODUCTION REQUEST 17 18 19 4
20 INTERROGATORY NO. 1:
21 With respect to contention 1(a), do you deny that 22 the scope of the IDVP review of both the seismic and 23 non-seismic aspects of the designs of safety-related 24 systems, structures and components was too narrow in that 25 the IDVP did not verify samples from each design activity 26 (seismic and non-seismic)?
8309220179 830919 PDR ADOCK 05000275 G
PDR 2 -.. -. -
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RESPONSE TO INTERROGATORY NO. 1:
2 While it is unclear what the Governor or Joint 3
Intervenors mean by " design activity," it is Licensee's 4
opinion that the IDVP's review was not too narrow in any 5
sense.
6 INTERROGATORY NO. 2:
7 If your answer to the preceding interrogatory is a 8
denial of the contention stated therein:
9 (a)
Please state each and every fact on which you rely in 10 support of your denial.
11 (b)
Please identify each and every document on which you 12 rely in support of your denial.
13 (c)
Please identify each and every document known to you or 14 believed by you to contain facts or allegations that 15 contradict, are inconsistent with, or tend to cast 16 doubt upon the validity of your denial or upon those 17 facts on which you base your denial.
18 (d)
Please identify each and every person you intend to 19 call as a witness whom you expect to testify concerning 20 your denial of this contention or the facts on which l
21 you rely in support of the denial of this contention.
22 RESPONSE TO INTERROGATORY NO. 2 23 (a)
The scope of the IDVP review was adequate to give 24 reasonable assurances that the design of the Diablo 25 Canyon Nuclear Power Plant meets licensing criteria and 26 licensing commitments...
1 (b)
All of our exhibits.
2 (c)
Other than the contentions of the Governor and the 3
Joint Intervenors, none.
4 (d)
Potential PGandE witnesses:
5 Richard C. Anderson Dr. William H. White 6
Gary H. Moore Larry E. Shipley 7
Steve M. Skidmore Richard D. Etzler 8
John B. Hoch Michael R. Tresler 9
Greg V. Cranston Charles W. Dick 10 Mike J. Jacobson Thomas G. De Uriarte 11 John M. Amaral Dr Harry Seed 12 Dr. Lincoln E. Malik Bimal~Sarkar 13 John K. McCall Pat Chang-Lo 14 Neil J. Tuholski Ed R. Kahler 15 Dr. Stanley Kaplan 16 Other potential witnesses:
17 Westinghouse:
Ed Kregh, Bob Wiseman IDVP witnesses 18 19 INTERROGATORY NO. 3:
20 With respect to contention 1(b), do you deny that 21 the scope of the IDVP review of both the seismic and 22 non-seismic aspects of the designs
'o f safety-related 23 systems, structures and components was too narrow in that 24 the IDVP did not verify samples from each of the design
.i 25 groups in the design chain performing the design activity?
26 fff -
3.
a.
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1 RESPONSE TO INTERROGATORY NO. 3:
2 While it is unclear what the Governor or Joint 3
Intervenors mean by " design chain" or " design group," it is 4
the opinion of Licensee that the scope of the IDVP's review 5
was not too narrow in any sense.
6 INTERROGATORY NO. 4:
7 If your answer to the preceding interrogatory is a 8
denial of the contention stated therein:
9 (a)
Please state each and every fact on which you rely in 10 support of your denial.
11 (b)
Please identify each and every document on which you 12 rely in support of your denial.
13 (c)
Please identify each and every document known to you or 14 believed by you to contain facts or allegations that 15 contradict, are inconsistent with, or tend to cast 16 doubt upon the validity of your denial or upon those 17 facts on which you base your denial.
18 (d)
Please identify each and every perscn you intend to 19 call as a witness whom you expect to testify concerning 20 your denial of this contention or the facts on which
'21 you rely in support of the denial of this contention.
22 RESPONSE TO INTERROGATORY NO. 4:
23 (a)
See answer to 2(a).
24 (b)
All of our exhibits.
25 (c)
See answer to 2(c).
26 (d)
See answer to 2(d).
-+
1 INTERROGATORY NO. 5:
2 With respect to contention 1(c), do you deny that 3
the scope of the IDVP review of both the seismic and 4
non-seismic aspects of the designs of safety-related 5
systems, structures and components was too narrow in that 6
the IDVP did not have statistically valid samples from which 7
to draw conclusions?
8 RESPONSE TO INTERROGATORY NO. 5:
9 Yes.
10 INTERROGATORY NO. 6:
11 If your answer to the preceding interrogatory is a 12 denial of the contention stated therein:
13 (a)
Please state each and every fact on which you rely in 14 support of your denial.
15 (b)
Please identify each and every document on which you 16 rely in support of your denial.
17 (c)
Please identify each and every document known to you or 18 believed by you to contain facts or allegations that i
19 contradict, are inconsistent with, or tend to cast 20 doubt upon the validity of your denial or upon those 21 facts on which you base your denial.
22 (d)
Please identify each and every person you intend to 23 call as a witness whom you expect to testify concerning 24 your denial of this contention or the facts on which 25 you rely in support of the denial of this contention.
26 fff -
a 1
RESPONSE TO INTERROGATORY NO. 6:
2 (a)
The selection of samples is discussed in the IDVP 3
Program Management plans for Phase I and Phase II and 4
in the IDVP Final Report.
The samples for review were 5
selected using engineering judgment based on detailed 6
knowledge of the systems, structures, and components 7
along with an understanding of interfaces between 8
disciplines and contractors.
This approach to sample 9
selection is more appropriate and more effective than a 10 purely statistical sample selection.
Further dis-4 11 cussion on the applicability of statistics will be 12 given in the Testimony of Dr. Stanley Kaplan to be 13 filed on October 8.
Dr. Kaplan's testimony will 14 discuss the inappropriateness of a statistical approach 15 to the sample selection as well as some discussion on 16 possible use of statistics in evaluating the present 17 verification program results.
Dr. Kaplan's work in 18 preparation of testimony has not been completed at this 19 time.
20 (b)
Program Management Plans for Phase I and Phase II; IDVP Final Report.
21 t
22 (c)
See answers to 2(c).
23 (d)
Stanley Kaplan 24 R. C. Anderson 25 W. H. White 26
///.
1
\\
1 INTERROGATORY NO. 7:
2 With respect to contention 1(d), do you deny that 3
the scope of the IDVP review of both the seismic and 4
non-seismic aspects of the designs of safety-related 5
systems, structures and components was too narrow in that 6
the IDVP failed to verify independently the analyses but 7
merely checked data of inputs to models used by PGandE?
8 RESPONSE TO INTERROGATORY NO. 7:
9 Yes.
10 INTERROGATORY NO. 8:
11 If your answer to the preceding interrogatory is a 12 denial of the' contention stated therein:
13 (a)
Please state each and every fact on which you rely in 14 support of your denial.
15 (b)
Please identify each and every document on w. _ch you 16 rely in support of your denial.
17 (c)
Please identify each and every document known to you or 18 believed by you to contain facts or allegations that 19 contradict, are inconsistent with, or tend to cast 20 l
doubt upon the validity of your denial or upon those 21 facts on which you base your denial.
22 (d)
Please identify each and every person you intend to 23 call as a witness whom you expect to testify concerning 24 your denial of this contention or the facts on which 25 you rely in support of the denial of this contention.
26
/// -.
~
N 1
RESPONSE TO INTERROGATORY NO. 8:
2 (a)
The IDVP did independently verify analyses, models and 3
the like.
Therefore, the premise of the. contention is 4
false.
5 (b)
See answer to 2(b).
6 (c)
See answer to 2(c).
7 (d)
See answer to 2(d).
8 INTERROGATORY NO. 9:
9 With respect to contention 1(e), do you deny that 10 the scope of the IDVP review of both the seismic and 11 non-seismic aspects of the designs of safety-related 12 systems, structures and components was too narrow in that 13 the IDVP failed to verify the design of Unit 2?
14 RESPONSE TO INTERROGATORY NO. 9:
15 Yes.
16 INTERROGATORY NO. 10:
i 17 If your answer to the preceding interrogatory is a 18 denial of the contention stated therein:
19 (a)
Please state each and every fact on which you rely in 20 support of your denial.
l 21 (b)
Please identify each and every document on which you 22 rely in support of your denial.
23
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24
///
25
///
)
26 i
i '
1 (c)
Please identify each and every document known to you or 2
believed by you to contain facts or allegations that 3
contradict, are inconsistent with, or tend to cast 4
doubt upon the validity of your denial or upon those 5
facts on which you base your denial.
6 (d)
Please identify each and every person you intend to 7
call as a witness whom you expect to testify concerning 8
your denial of this contention or the facts on which 9
you rely in support of the denial of this contention.
10 RESPONSE TO' INTERROGATORY NO. 10:
11 (a)
The scope of ~ the IDVP is consistent with the orders of 12 the Commission.
13 (b)
All our exhibits, Commission order (CLI-81-30),
14 Secy-82-89; Memorandum of Commission Secretary dated 15 March 8, 1982 (M820304A); Secy 82-414; and Memorandum 16 of Commission Secretary dated December 9, 1982 17 (M821208A).
4 18 (c)
See answer to 2(c).
19 (d)
See answer to 2(d).
20 INTERROGATORY NO. 11:
21 With respect to contention 2(a), do you deny that 22 the scope of the ITP review of both the seismic and 23 non-seismic aspects of the designs of safety-related 24 systems, structures and components was too narrow in that 25 the ITP did not verify samples from each design activity 26 (seismic and non-seismic)?
{ -
'l RESPONSE TO INTERROGATORY NO. 11:
2 Yes.
3 INTERROGATORY NO. 12:
4 If your answer to the preceding interrogatory is a 5
denial of the contention stated therein:
6 (a)
Please state each and every fact on which you rely in 7
support of your denial.
8 (b)
Please identify each and every document on which you 9
rely in support of your denial.
10 (c)
Please identify each and every document known to you or 11 believed by you to contain facts or allegations that 12 contradict, are inconsistent with, or tend to cast 13 doubt upon the validity of your denial or upon those 14 facts on which you base your denial.
15 (d)
Please identify each and every person you intend to 16 call as a witness whom you expect to testify concerning 17 your denial of this contention or the facts on which 18 you rely in support of the denial of this contention.
19 RESPONSE TO INTERROGATORY NO. 12:
20 (a)
The scope of the ITP review was adequate to give 21 reasonable assurances that the design of Diablo Canyon 22 Nuclear Power Plant meets the licensing criteria and 23 licensing commitments.
24 (b)
DCP final report and all documents referenced therein; 25 reference 6, Attachment A.
26 (c)
See answer to 2(c)... _.
1 (d)
See answer to 2(d).
2 INTERROGATORY NO. 13:
3 With respect to contention 2(b), do you deny that 4
the scope of the ITP review of-both the seismic and 5
non-seismic aspects of the designs of safety-related 6
systems, structures and components was too narrow in that 7
the design activities the ITP did review, it did not verify 8
. samples from each of the design groups in the design chain 9
performing the design activity?
10 RESPONSE TO INTERROGATORY NO. 13:
11 While the Licensee is unsure what the Governor or 12 Joint Intervenors mean by " sample from.
." design groups 13 in the design chain," it is Licensee's opinion that the 14 review by the ITP was not too narrow in any sense.
15 INTERROGATORY NO. 14:
16 If your answer to the preceding interrogatory is a 17 denial'of the contention stated'therein:
18 (a)
Please state each and every fact on which you rely in 19 support of your denial.
20 (b)
Please identify each and every document on which you f
l 21 rely in support of your denial.
22 (c)
Please identify each and every document known to you or l
23
' believed by ycu to contain facts or allegations that 1
24 contradict, are inconsistent with, or tend to cast j
doubt upon the validity of your denial or upon those 25 f
26 facts on which you base your denial.
l
i i
1 (d)
Please identify each and every person you intend to 2
call as a witness whom you expect to testify concerning 3
your denial of this contention or the facts on which 4
you rely in support of the denial of this contention.
5 RESPONSE TO INTERROGATORY NO. 14:
6 (a)
The review of the ITP provides reasonable assurances 7
that the Diablo Canyon Nuclear Power Plant meets 8
licensing criteria and licensing commitments.
9 (b)
See answer to 12(b).
10 (c)
See answer to 12(c).
11 (d)
See answer to 12(d).
12 INTERROG3 TORY NO. 15:
13 With respect to contention 2(c), do you deny that 14 the scope of the ITP review of both the seismic and 15 non-seismic aspects of the designs of safety-related 16 systems, structures and components was too narrow in that 17 the ITP did not have statistically valid samples from which i
18 to draw conclusions?
19 RESPONSE TO INTERROGATORY NO. 15:
20 Yes.
l 21 INTERROGATORY NO. 16:
22 If your answer to the preceding interrogatory is a 23 denial of the contention stated therein:
24 (a)
Please state each and every fact on which you rely in 25 support of your denial.
26
///.--
1 (b)
Please identify each and every document on which you 2
rely in support of your denial.
3 (c)
Please identify each and every document known to you or 4
believed by you to contain facts or allegatians that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your denial or upon those 7
facts on which you base your denial.
8 (d)
Please identify each and every person you intend to 9
call as a witness whom you expect to testify concerning 10 your denial of this contention or the facts on which 11 you rely in support of the denial of this contention.
12 RESPONSE TO INTERROGATORY NO. 16:
13 (a)
The scope of the ITP is clearly defined in PGandE's 14 Phase I Final Report and the Phase II Final Report.
15 The extensive program described in these reports was 16 developed based on engineering judgment and detailed 17 knowledge of the systems, structures, and components 18 being reviewed.
The program was not developed based on 19 statistical sampling.
20 (b)
See answer to (a) above; see answer to 12(b).
21 (c)
Other than contentions of Governor and Joint 22 Intervenors, none.
23 (d)
Stanley Kaplan 24 R. C. Anderson 25 W. H. White 26
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,,,,. ~ _ _. _ _ _, _, _ _ _
_._,.---7,,-
1 INTERROGATORY NO. 17:
2 With respect to contention 2(d), do you deny that 3
the scope of the ITP review of both the seismic and 4
non-seismic aspects of the designs of safety-related 5
systems, structures and components was too narrow in that 6
the ITP has failed systematically to verify the adequacy of 7
the design of Unit 2?
8 RESPONSE TO INTERROGATORY NO. 17:
9 While it is unclear what the Governor or Joint 10 Intervenors mean by
" systematically verify,"
it is 11 Licensee's opinion that the ITP's review was not too narrow 12 in any sense.
13 INTERROGATORY NO. 18:
14 If your answer to the preceding interrogatory is a 15 denial of the contention stated therein:
16 (a)
Please state each and every fact on which you rely in l
17 support of your denial.
18 (b)
Please identify each and every document on which you i
l 19 rely in support of your denial.
l 1
20 (c)
Please identify each and every document known to you or I
21 believed by you to contain facts or allegations that 22 contradict, are inconsistent with, or tend to cast 23 doubt upon the validity of your denial or upon those l
24 facts on which you base your denial.
25
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26
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p 1
(d)
Please identify each and every person you intend to 2
call as a witness whom you expect to testify concerning 3
your denial of this contention or the facts on which 4
you rely in support of the denial of this-contention.
5
. RESPONSE TO INTERROGATORY NO. 18:
6 (a)
See answer to 14(a).
7 (b)'. See answer to 12(b).
8 (c)
See answer to 12(c).
9 (d)
See answer to 12(d).
10 INTERROGATORY NO. 19:
11
. ith respect to contention 3(a), do you deny that W
12 the ITP used improper engineering standards to determine 13 whether design activities met license criteria in that it
[
14 accepted the mean measured performance of structures and l-15 materials in lieu of code-specified minima and that the l
16 IDVP either used or approved the use of such an improper 17 standard or did not verify it at all?
18 RESPONSE TO INTERROGATORY NO. 19:
1 19 Objection.
This interrogatory exceeds the scope 20 of the Board's order of August 26, 1983, in that.the ITP 21 applied licensing criteria previously litigated and approved 1
22 in NRC proceedings.
Licensee is of the opinion that the ITP
(
23 used proper engineering standards which give reasonable 24
. assurance that the Diablo Canyon Nuclear Power Plant meets 25 licensing criteria.
26 fjj -
i 1
INTERROGATORY NO. 20:
2 If your answer to the preceding interrogatory is a 3
denial of the contention stated therein:
4 (a)
Please state each and every fact on which you rely in 5
support of your denial.
6 (b)
Please identify each and every document on which you 7
rely in support of your denial.
8 (c)
Please identify each and every document known to you or 9
believed by you to contain facts or allegations that 10 contradict, are inconsistent with, or tend to cast 11 doubt upon the validity of your denial or upon those 12 facts on which you base your denial.
13 (d)
Please identify each and every person you intend to 14 call as a witness whom you expect to testify concerning 15 your denial of this contention or the facts on which 16 you rely in support of the denial of this contention.
17 RESPONSE TO INTERROGATORY NO. 20:
18 Not applicable.
19 INTERROGATORY NO. 21:
20 With respect to contention 3(b), do you deny that l
21 the ITP used improper engineering standards to determine 22 whether design activities met license criteria in that it 23 failed to verify that the stress and load factors for steel 24 used in the containment building were within code values 25 and that the IDVP either used or approved the use of such an 26 improper standard or did not verify it at all?. _.
1 RESPONSE TO INTERROGATORY NO 21:
2 Yes.
3 INTERROGATORY NO. 22:
4 If your answer to the preceding interrogatory is a 5
denial of the contention stated therein:
6 (a)
Please state each and every fact on which you rely in 7
support of your denial.
8 (b)
Please identify each and every document on which you 9
rely in support of your denial.
10 (c)
Please identify each and every document known to you or 11 believed by you to contain facts or allegations that 12 contradict, are inconsistent with, or tend to cast 13 doubt upon the validity of your denial or upon those 14 facts on which you base your denial.
15 (d)
Please identify each and every person you intend to 16 call as a witness whom you expect to testify concerning 17 your denial of this contention or the facts on which 18 you rely in support of the denial of this contention.
19 RESPONSE TO INTERROGATORY NO. 22:
l 20 (a)
No improper engineering standards are used to determine 21 that design activities met licensing criteria since the 22 stress allowables are in accordance with the Code and 23 the load factors used to calculate stresses are so l
24 stated in the Hosgri Report and the FSAR.
l 25 (b)
References 1, 4,
and 5 in Attachment A to these
[
26 responses.
l l
1 l L
m l
1 (c)
Other than the contentions of the Governor and the 2
Joint Intervenors, none.
3 (d)
Dr. W. H. White.
'4 INTERROGATORY NO. 23:
5 With respect to contention 3(c), do you deny that 6
the ITP used improper engineering standards to determine 7
whether design activities met license criteria in that it 8
failed to specify all damping values used in various seismic 9
modes in the containment and auxiliary buildings and that
]
10 the IDVP either used or approved the use of such an improper 11 standard or did not verify it at all?
s 12 RESPONSE TO INTERROGATORY NO. 23:
13 Yes.
14 INTERROGATORY NO. 24:
15 If your answer to the preceding interrogatory is a I
16 denial of the contention stated therein:
17 (a)
Please ' state each and every fact on which you rely in 18 support of your denial.
19 (b)
Please identify each and every document on which you 20 rely in support of your denial.
l 21 (c)
Please identify each and every document known to you or 22 believed by you to contain facts or allegations that 23 contradict, are inconsistent with, or tend to cast 24 doubt upon the validity of your denial or upon those 25 facts on which you base your denial.
26
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1
-(d)
Please identify each and every person you intend to 2
call as a witness whom you expect to testify concerning 3
your denial of this contention or the facts on which 4
you rely in support of the denial of this contention.
5 RESPONSE TO INTERROGATORY NO. 24:
6 (a)
No improper engineerins standards are used to determine 7
that design activities meet licensing criteria.
For 8
containment for the DE and DDE, the resulting values of 9
damping for each mode in the model analysis are 10 specified in " Report by John A.
Blume and Associates, 11 Engineers, Diablo Canyon Nuclear Power Plant Unit No.
12 1,
Containment Structure Finite Element Model, 13 Dynamic Seismic Analysis, July 1970, JABE-PGE-DC-1."
14 For the auxiliary building, values of damping for each 15 mode in the modal analysis are not individually 16 specified since they are identical.
Damping values 17 associated with soil spring are conservatively ignored.
18 (b)
See (a) above; also references 1, 2,
3, 4 and 5 in 19 Attachment A to these responses.
20 (c)
See answer to 2(c).
21 (d)
Dr. W. H. White.
22 INTERROGATORY NO. 25:
23 With respect to contention 3(d), do you deny that i
24 the ITP used improper engineering standards to determine 25 whether design activities met license criteria in that it 26 failed to verify that PGandE's use of the double algebraic l
a B
1 sum method of calculation (rather than *he sum of the 2
squares method) was acceptable as a substitution and that 3
the IDVP either used or approved the use of such an improper 4
standard or did not verify it at all?
5 RESPONSE TO INTERROGATORY NO. 25:
6 Yes.
7 INTERROGATORY NO. 26:
8 If your answer to the preceding interrogatory is a 9
denial of the contention stated therein:
10 (a)
Please state each and every fact on which you rely in 11 support of your denial.
- o 12 (b)
Please identify each and every document on which you 13 rely in support of your denial.
14 (c)
Please identify each and every document known to you or 15 believed by you to contain facts or allegations that 16 contradict, are inconsistent with, or tend to cast 17 doubt upon the validity of your denial or upon those 18 facts on which you base your denial.
19 (d)
Please identify each and every person you intend to 20 call as a witness whom you expect to testify concerning i
21 your denial of this contention or the facts on which 22 you rely in support of the denial of this contention.
l l
23
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24
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25
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26 l
i s
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1 RESPONSE TO INTERROCATORY NO. 26:
T 2
(a)
No improper engineering standards are use'd to determine' 3
.that design activities meet licensing criteria.
In 4
accordance with the Hosgri criteria the individual 5
modal responses are combined by the square root of the
[
t 6
sum of squares (SRSS) method; hpvever, in case cf the t 7
turbine building, for some principal. load carrying a
members, a more conservative approach of use of' the 9
double algebraic sum (DAS) method was also applied.
10 (b)
References 1 and 4 in Attachment A.
11 (c)
See answer to 2(c).
12 (d)
Dr. W. H. White.
13 INTERROGATORY NO. 27:
14 With respect to contention 3(e), do you deny that 15 the ITP used improper engineering standards to determine 16 whether design activities met license criteria in that it 17 used time-history modeling techniques ' for some accelera-l 18 tions, displacements and shell forces in the containment 19 structure and Blume response spectra for other 20 accelerations, displacements and shell forces in the same_ y-
'21 structure and that the IDVP either used or approved the use 22 of such an improper standard or did not verify it at all?
j l
23 RESPONSE TO INTERROGATORY NO. 27:
24 Yes.
25
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26 fff l
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i I
E y
~
1 INTERROGATORY NO. 28:
s
[4 2
If your answer to the preceding interrogatory is a f~
3 denial of the contention stated therein:
4 (a)
Please state each and every fact on which you rely in 25 support of your denial.
g 1
6 (b).Please identify each and every document on which you 7
rely in support of your denial.
, ~-
8 (c)
Please identify each and every document known to you or 9
believed by you to contain facts or allegations that
_. contradict, are inconsistent with, or tend to cast 10
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11
.. doubt upon the validity of your denial or upon those s
haqtsonwhichyoubaseyourdenial.
12 s
U 's 13 (d)
Please identify each and every person you' intend to E
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w 14 call as a witness whom you expect to testify concerning x'~'(
15 your denial of this contention or the facts on which
~
,., yoil rely in support of the denial of this contention.
16 C
~
17 iRESPONSE TO INTERROGATORY NO. 28:
18 (a)
No improper engineering standards are used to determine 19 that design activities meet licensing criteria.
The 20 licensing criteria as stated in the licensing documents 21 listed under (b) below allow the use of both sthe time 22 history and the response spectra methods of dynamic 23 analyses. k s
N 24 (b)
References 1, 2, 4, and 5, of Attachment A.
25 (c)
See answer to 2(c).
't(h)
S'ee answer to 26(d).
26 g
1w-
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1 INTERROGATORY NO. 29:
2 With respect to contention 3(f), do you deny that 3
the ITP used improper engineering standards to determine 4
whether design activities met license criteria with respect 5
to its modeling of the soil properties for the containment 6
and auxiliary buildings and that the IDVP either used or 7
approved the use of such an improper standard or did not 8
verify it at all?
9 RESPONSE TO INTERROGATORY NO. 29:
10 Yes.
11 INTERROGATORY NO. 30:
12 If your answer to the preceding interrogatory is a 13 denial of the contention stated therein:
14 (a)
Please state each and every fact on which you rely in
~15 support of your denial.
16
~(b)
Please identify each and every document on which you 17 l
rely in support of your denial.
l 18 (c)
Please identify each and every document known to you or 19 believed by you to contain facts or allegations that f
l 20 contradict, are inconsistent with, or tend to cast 21 doubt upon the validity of your denial or upon those 22 facts on which-you base your denial.
I 23 (d)
Please identify each and every person you intend to l
i 24 call as a witness whom you expect to testify concerning-25 your denial of this contention or the facts on which 26 you rely in. support of the denial of this contention.,
J
1 RESPONSE TO INTERROGATORY NO. 30:
2 (a)
No improper engineering standards are used to determine 3
that design activities meet licensing criteria.
4 (i)
(a)
In the soil structure interaction analysis of 5
containment for the DE and the DDE, use of 6
boundary motion to the model were used 7
properly and appropriately.
The entire 8
proced.are of developing these boundary 9
motions is explained in detail in " Report by 10 John A.
Blume and Associates, Engineers, 11 Diablo Canyon Nuclear Power Plant Unit No. 1, 12 Containment Structure - Finite Element Model, 13 Dynamic Seismic
- Analysis, July
- 1970, 14 JABE-PGE-DC-1," and FSAR.
15 (b)
See (i)(a) above.
16 (c)
See answer to 2(c).
17 (d)
See answer to 24(d).
18 (ii)
(a)
The soil structure interaction analysis for 19 containment for the DE and the DDE uses a 7 20 percent damping value for rock in accordance 21 with the licensing criteria as specified in 22 the FSAR.
23 (b)
See (ii)(a) above.
I 24 (c)
See answer to 2(c).
25 (d)
See anarer to 24(d).
26
///
- t
1 (iii)
(a)
The dynamic analyses of the containment for 2
the DE and DDE consider the flexibilities of 3
both the foundation mat and the underlying 4
rock.
For the Hosgri event, however, the 5
dynamic analysis is based on fixed base model 6
in accordance with the licensing criteria.
7 (b)
References 1, 2,
3, 4 and 5 of Attachment A.
8 (c)
See answer to 2(c).
9 (d)
Dr. W. H. White.
10 (iv)
(a)
The soil properties are specified in the 11 FSAR.
12 (b)
See (iv)(a) above.
13 (c)- See answer to 2(c).
14 (d)
Dr. W. H. White.
15 (v)
(a)
In the seismic analysis of the auxiliary 16 building the input motion applied to the end 17 of the soil spring is in accordance with the 18 accepted licensing provisions.
19 (b)
References 1, 2,
4, and 5 of Attachment A.
20 (c)
See answer to 2(c).
21 (d)
Dr. W. H. White.
22
///
23
///
24
///
25 26 i
1 INTERROGATORY NO. 31:
2 With respect to contention 3(g), do you deny that 3
the ITP used improper engineering standards to determine 4
whether design activities met license criteria with respect 5
to its modeling of the crane in the turbine building and 6
that the IDVP either used or approved the use of such an 7
improper standard or did not verify it at all?
8 ANSWER TO INTERROGATORY NO. 31:
9 Yes.
10 INTERROGATORY NO. 32:
11 If your answer to the preceding interrogatory is a 12 denial of the contention stated therein:
13 (a)
Please state each and every fact on which you rely in 14 support of your denial.
15 (b)
Please identify each and every document on which you 16 rely in support of your denial.
17 (c)
Please identify each and every document known to you or 18 believed by you to contain facts or allegations that 19 contradict, are inconsistent with, or tend to cast 20 doubt upon the validity of your denial or upon those 21 facts on which you base your denial.
22 (d)
Please identify each and every person you intend to 23 call as a witness whom you expect to testify concerning 24 your denial of this contention or the facts on which 25 you rely in support of the denial of this contention.
26
/// -.
0 8
1 ANSWER TO INTERROGATORY NO. 32:
2 (a)
The initial seismic qualification of the turbine 3
building considered the crane parked in a single 4
location.
This analysis is proper as long as the crane 5
remains parked and unloaded.
PGandE has committed to 6
leave the crane parked and unloaded until the turbine 7
building has been qualified for a loaded crane in all 8
anticipated locations.
9 (b)
Reference 4 in Attachment A.
10 (c)
See response to 2(c).
11 (d)
Dr. W. H. White 12 INTERROGATORY NO. 33:
13 With respect to contention 3(h), do you deny that 14 the ITP used improper engineering standards to determine 15 whether design _ activities met license criteria by virtue of 16 its modeling of the torsion factors for different buildings 17 by differing techniques and that the IDVP either used or 18 approved the use of such an improper standard or did not 19 verify it at all?
20 RESPONSE TO INTERROGATORY NO. 33:
21 Yes.
22 INTERROGATORY NO. 34:
23 If your answer to the preceding interrogatory is a 24 denial of the contention stated therein:
25 (a)
Please state each and every fact on which you rely in 26 support of your denial.
1 (b)
Please identify each and every document on which you 2
rely in support of your denial.
3 (c)
Please identify each and every document known to you or 4
believed by you to contain facts or allegations that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your denial or upon those 7
facts on which you base your denial.
8 (d)
Please identify each and every person you intend to 9
call as a witness whom you expect to testify concerning 10 your denial of this contention or the facts on which 11 you rely in support of the denial of this contention.
12 RESPONSE TO INTERROGATORY NO. 34:
13 (a)
No improper engineering standards are used to determine 14 that design activities meet licensing criteria in 15 application of the effect of accidental torsion in the 16 seismic analyses of the different buildings.
The 17 methods used are in accordance with the provisions of 18 the Hosgri criteria.
19 (b)
References 1, 2, and 5 of Attachment A.
20 (c)
See answer to 2(c).
21 (d)
Dr. W. H. White.
22
///
23
///
24
///
25 26 1
INTERROGATORY NO. 35:
2 With respect to contention 3(i), do you deny that 3
the ITP used improper engineering standards to determine 4
whether design activities met license criteria with respect 5
to its modeling of hydrodynamic forces for the intake 6
structure and that the IDVP either used or approved the use 7
of such an improper standard or did not verify it at all?
8 RESPONSE TO INTERROGATORY NO. 35:
9 Yes.
10 INTERROGATORY NO. 36:
11 If your answer to the preceding interrogatory is a 12 denial of the contention stated therein:
13 (a)
Please state each and every fact on which you rely in 14 support of your denial.
15 (b)
Please identify each and every document on which you 15 rely in support of your denial.
17 (c)
Please identify each and every document known to you or 18 believed by you to contain facts or allegations that 19 contradict, are inconsistent with, or tend to cast 20 doubt upon the validity of your denial or upon those 21 facts on which you base your denial.
22 (d)
Please identify each and every person you intend to 23 call as a witness whom you expect to testify concerning 24 your denial of this contention or the facts on which 25 you rely in. support of the denial of this contention.
26
///
i 1
RESPONSE TO INTERROGATORY NO. 36:
2 (a)
No improper engineering standards are used to determine 3
that design activities meet licensing criteria.
In the 4
evaluation of the intake structure no sloshing effect 5
was considered since sloshing cannot take place in the 6
open ended compartments between the flow straightners 7
which are deep and narrow.
The hydrodynamic pressures 8
on the outside of the structure are considered as 9
described in the Phase I Final Report.
10 (b)
See (a) above.
11 (c)
See answer to 2(c).
i 12 (d)
Dr. W. H. White.
13 INTERROGATORY NO. 37:
14 With respect to contention 3(j ), do you deny that 15 the ITP used improper engineering standards to determine 16 whether design activities met license criteria in that for 17 its modeling of the intake structure it used different 18 models for horizontal and vertical seismic loadings and 19 combined the results of these different models for vertical 20 and horizontal responses and that the IDVP either used or 21 approved the use of such an improper standard or did not 22 verify it at all?
23 RESPONSE TO INTERROGATORY NO. 37:
24 Yes.
25
///
26
/// -.
1 INTERROGATORY NO. 38:
2 If your answer to the preceding interrogatory is a 3
denial of the contention stated therein:
4 (a)
Please state each and every fact on which you rely in 5
support of your denial.
6 (b)
Please identify each and every document on which you 7
rely in support of your denial.
8 (c)
Please identify each and every document known to you or 9
believed by you to contain facts or allegations that 10 contradict, are inconsistent with, or tend to cast 11 doubt upon the validity of your denial or upon those 12 facts'on which you base your denial.
13 (d)
Please identify each and every person you intend to 14 call as a witness whom you expect to testify concerning 15 your denial of this contention or the facts on which 16 you rely in support of the denial of this contention.
17
///
18
///
19
///
20 21 22 23 24 25 26.
- ~_ -
6 1
RESPONSE TO INTERROGATORY NO. 38:
2 (a)
No improper engineering standards are used to detertaine 3
that design activities meet licensing criteria.
There 4
is no basic difference in the horizontal and vertical 5
seismic models, except that in modeling the intake 6
crane in the vertical direction proper consideration is 7
given to the fact that during vertical upward motion 8
the cable holding the lifted weight is slack which 9
introduces the so-called non-linear effect.
It is 10 perfectly justifiable to combine the responses obtained 11 from the different seismic analyses which include this 12 effect.
13 (b)
Reference 4 of Attachment A.
14 (c)
See answer to 2(c).
15 (d)
Dr. W. H. White.
16 INTERROGATORY NO. 39:
l 17 With respect to contention 3(k), do you deny that 18 the ITP used improper engineering standards to determine 19 whether design activities met license criteria in that for 20 its modeling of the intake structure it used improper 21 ductility factors for steel and concrete and that the IDVP 22 either used or approved the use of such an improper standard 23 or did not verify it at all?
i 24 RESPONSE TO INTERROGATORY NO. 39:
l 25 Yes.
l 26
///
l i
_ _..,_ = _ -- - _ - -.
J 1
INTERROGATORY NO. 40:
2 If your answer to the preceding interrogatory is a 3
denial of the contention stated therein:
4 (a)
Please state each and every fact on which you rely in 5
support of your denial.
6 (b)
Please identify each and every document on which you 7
rely in support of your denial.
8 (c)
Please identify each and every document known to you or 9
believed by you to contain facts or allegations that l
10 contradict, are inconsistent with, or tend to cast 11 doubt upon the validity of your denial or upon those 12 facts on which you base your. denial.
13 (d)
Please identify each and every person you intend to 14 call as a witness whom you expect to testify concerning 15 your denial of this contention or the facts on which 1
16 you rely in support of the denial of this contention.
l 17 RESPONSE TO INTERROGATORY NO. 40:
18 (a)
No improper engineering standards are used to determine 19 that design activities meet licensing criteria.
The 20 ductility factors used in evaluation of certion local 21
- structural elements during the Hosgri evo:nt are within 22 the specified allowables of the Hosgri criteria.
l 23
-(b)
References 1, 2 and 4 of Attachment A.
l I
24 (c)
See answer to 2(c).
l 25 (d)
Dr. W. H. White.
l 26
///
i i
--n-,-
--,,e-e,-
,, ~ -, -..,,,.,.,,,
,,n,.n.,--_,---.-,,,-rnn,,,,
,,w w.
1 INTERROGATORY NO. 41:
2 With respect to contention 3(1), do you deny that 3
the ITP used improper engineering standards to determine 4
whether design activities met license criteria with respect 5
to its computations of modes in the containment building 6
having frequencies between 20 and 33 HZ and that the IDVP 7
either used or approved the use of such an improper standard 8
or did not verify it at all?
9 RESPONSE TO INTERROGATORY NO. 41:
10 Yes.
11 INTERROGATORY NO. 42:
12 If your answer to the preceding interrogatory is a 13 denial of the contention stated therein:
14 (a)
Please state each and every fact on which you rely in 15 support of your denial.
16 (b)
Please identify each and every document on which you 17 rely in support of your denial.
18 (c)
Please identify each and every document known to you or 19 believed by you to contain facts or allegations that 20 contradict, are inconsistent with, or tend to cast 21 doubt upon the validity of your denial or upon those 22 facts on which you base your denial.
23 (d)
Please identify each and every person you intend to 24 call as a witness whom you expect to testify concerning 25 your denial of this contention or the facts on which 26 you rely in support of the denial of this contention..
1 RESPONSE TO INTERROGATORY NO. 42:
2 (a)
The Project's response to the NRC question regarding 3
the 20 Hz criteria was included in the September 9, 4
1983 submittal to the NRC as Enclosure 2, Attachment 1, 5
which is attached hereafter as Attachment B.
6 (b)
In addition to the reference given above, this subject 7
is addressed in the FSAR and the Hosgri Report.
8 (c)
Other than the contentions of the Governor and the 9
Joint Intervenors, none.
10 (d)
Dr. W. H. White 11 Larry Shipley 12 INTERROGATORY NO. 43:
13 With respect to contention 3(m), do you deny that 14 the ITP used improper engineering standards to determine 15 whether design activities met license criteria in that in 16 modeling the containment building it failed to use two 17 horizontal components for the DE and DDE and that the IDVP 18 either used or approved the use of such an improper standard 19 or did not verify it at all?
20 RESPONSE TO INTERROGATORY NO. 43:
21 Yes.
22 INTERROGATORY NO. 44:
23 If your answer to the preceding interrogatory is a 24 denial of the contention stated therein:
25 (a)
Please state each and every fact on which you rely in l
26 support of your denial.
O s
1 (b)
Please identify each and every document on which you 2
rely in support of your' denial.
3 (c)
Please identify each and every document known to you or 4
believed by you to contain facts or allegations that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your denial or upon those 7
facts on which you base your denial.
8 (d). Please identify each and every person you intend to 9
call as a witness whom you expect to testify concerning 10 your denial of this contention or the facts on which 11 you rely in support of the denial of this contention.
12 RESPONSE TO INTERROGATORY NO. 44:
13 (a)
No improper engineering standards are used to determine 14 that design activities meet licensing criteria.
The 15 original licensing criterion with regards to the DE and 16 the DDE was to combine the responses due to one 17 horizontal excitation to the responses due to the-1 18 vertical excitation by the absolute sum method and not 19 to consider the effects of the three components of 20 earthquake simultaneously.
This criterion was 21 correctly applied.
22 (b)
NRC's SER, Supplement 7, dated May 26, 1978.
23 (c)
See answer to 2(c).
I I
24 (d)
Dr. W. H. White.
25
///
l.
26
///
! L
1 INTERROGATORY NO. 45:
2 With respect to contention 3(n), do you deny that 3
the ITP used improper engineering standards to determine 4
whether design activities met license criteria by virtue of 5
the stress values it used for concrete in shear walls in 6
modeling the auxiliary building and that the IDVP either 7
used or approved the use of such an improper standard or did 8
.not verify it at all?
9 RESPONSE TO INTERROGATORY NO. 45:
10 Yes.
11 INTERROGATORY NO. 46:
i
~
12 If your answer to the preceding interrogatory is a i
13 denial of the contention stated therein:
I 14 (a)
Please state each and every fact on which you rely in 15 support of your denial.
16 (b)
Please identify each and every document on which you 17 rely in support of your denial.
18 (c)
Please identify each and every document known to you or 19 believed by you to contain facts.or allegations that 20 contradict, are inconsistent with, or tend to cast 21 doubt upon the validity of your denial or upon those 22 facts on which you base your denial.
23 (d)
Please identify-each and every person you intend to 24 call as a witness whom you expect to testify concerning 25 your denial of this contention or the facts on which 26 you rely in support of the denial of this contention. - -
1 RESPONSE TO INTERROGATORY NO. 46:
2 (a)
No improper engineering standards are used to determine 3
that design activities meet licensing criteria.
The 4
stress value (allowable) used for concrete in shear 5
walls is not applied in modeling the auxiliary 6
building.
Furthermore, the stress allowables are in 7
accordance with the criteria of Appendix 2A of Phase I 8
Final Report.
These criteria are based on test reshlts 9
which are acceptable in accordance with the provisions 10 of ACI Code.
11 (b)
See (a) above.
12 (c)
Other than the contentions of the Governor and Joint 13 Intervenors, none.
14 (d)
Dr. W. H. White.
15 INTERROGATORY NO. 47:
16 With respect to contention 4, do you deny that the 17 IDVP has accepted deviations from the licensing criteria 18 without providing adequate engineering justification?
19 RESPONSE-TO INTERROGATORY NO. 47:
20 While contention No. 4 is not clear as to what is 21 meant by " accepted," Licensee believes that all actions of 22 the DCP are consistent with licensing criteria and can be 23 supported by engineering justification or judgment.
24 INTERROGATORY FO. 48:
25 If your answer to the preceding interrogatory is a 26 denial of the contention stated therein: -._
1 (a)
Please state each and every fact on which you rely in 2
support of your denial.
3 (b)
Please identify each and every document on which you 4
rely in support of your denial.
5 (c)
Please identify each and every document-known to you or 6
believed by you to contain facts or allegations that 7
contradict, are inconsistent with, or tend to cast 8
doubt upon the validity of your denial or upon those 9
facts on which you base your denial.
10 (d)
Please identify each and every person you intend to 11 call as a witness whom you expect to testify concerning 12 your denial of this contention or the facts on which 13 you rely in support of the denial of this contention.
14 RESPONSE TO INTERROGATORY NO. 48:
15 (a)
The IDVP has received full and complete responses to 16 questions and concerns they have raised concerning 17 their review of selected DCNPP-1 Unit 1 systems.
18 Licensing criteria have been met in all cases, and 19 adequate engineering justification has been provided.
l 20 The nature and extent of this engineering justification 21 with particular reference to contention 4_ is provided 22 below.
23
///
24
///
25
///
l 26 l
t i l
l
=.
o 1
Contention 4(a):
2 Contrary to the requirements of FSAR Section 17.1 re-3 garding compliance of the as-built installation with 4
the design documents, the IDVP review of the AFWS dis-5 closed that the as-built installation failed to meet 6
the design drawings in that (i) a steam trap on the 7
turbine-driven AFW pump steam supply line is not pro-8
- vided and (ii) there are discrepancies in the arrange-9 ment of the long-term cooling water supply line.
10
Response
11 For this issue, complete engineering justification is 12 provided in the DCP Resolution and/or Completion 13 Packages for EOI file 8027 for item (a)(i), and the DCP 14 Resolution and Completion Packages for EOI file 8048 15 for item (a)(ii).
The IDVP has fully addressed these 16 matters in ITR No. 22, Rev. 1, on page 4-9.
17 Contention 4(b):
18 Contrary to FSAR Section 8.3.3., the electrical design 19 does not fully comply with the commitments regarding 20 separation and color coding.
21
Response
22 For this issue, complete engineering justification is 23 provided in the DCP Resolution and/or Completion 24 Packages for EOI files 8055 and 8059.
The IDVP has 25 fully addressed these matters in ITR No. 27, Rev. 2, on 26 pages 5-3 and 5-4.
. ~
1 Contention 4(c):
2 contrary to the single failure criterion on Appendix A 3
to 10 CFR Part 50, a single failure may cause loss of 4
redundant power divisions because redundant electric 5
power division trains are electrically interconnected 6
through two circuit breakers and a single power 7
transfer switch.
8
Response
9 For this issue, complete engineering justification is 10 provided in the DCP Resolution and/or Completion 11 Packages for EOI file 8041.
The IDVP has fully 12 addressed these matters in ITR No. 26, Rev. 1, on pages 13 5-1.
14 Contention 4(d):
15 Contrary to GCD 57 of Appendix A, valve operators for 16 the isolation valves which provide the steam supply to 17 the turbine-driven auxiliary feed pump from two of the 18 main steam generators have not been classified and 19 procured as safety related components.
20
Response
21 For this issue, complete engineering justification is 22 provided in the DCP Resolution and/or Completion 23 Packages for EOI file 8018.
The IDVP has fully 24 addressed these matters in ITR No. 27, Rev. 2, on page 25 5-1.
26
///
1 Contention 4(e):
2 The single failure of an auxiliary relay would prevent 3
automatic closure of the redundant steam generator 4
blow-down isolation valves on automatic initiation of 5
the AFWS contrary to a Westinghouse interface 6
requirement and FSAR Figure 7.2-1.
7
Response
8 For this issue, complete engineering justification is 9
provided in the DCP Resolution and/or Completion 10 Packages for EOI file 8047.
The IDVP has fully 11 addressed these matters in ITR No. 27, Rev. 2, on page s
12 5-1.
13 Contention 4(f):
14 Contrary to NUREG 0588 regarding environmental qualifi-15 cations, flow transmitter FT-78 and flow control valve 16 FCV-05 are located in a harsh environment but were not 17 listed as such in the PG&E Environmental Qualification 18 Report dated September 1981, and are not yet 19 environmentally qualified.
20
Response
21 For this issue, complete engineering justification is 22 provided in the DCP Resolution and/or Completion 23 Packages for EOI file 8052.
The IDVP has fully 24 addressed these matters in ITR No. 27, Rev. 2, on page 25 5-2.
26
///.-. -
1 Contention 4(g):
2 Contrary to the requirements of NUREG 0588 regarding 3
environmental qualifications, portions of the CRVPS 4
were omitted from PG&E's Environmental Qualification 5
report.
6
Response
7 For this issue, complete engineering justification is 8
provided in the DCP Resolution and/or Completion 9
Packages for EOI file 8056.
The IDVP has fully 10 addressed these matters in ITR No. 28, Rev. 2, on page 11 5-2.
4 12 Contention 4(h):
13 Contrary to PG&E's September 14 and December 28, 1978 14 licensing commitments, CRVPS equipment identified in 15 the FSAR as necessary to maintain control room 16 habitability during safe shutdown has not been 17 evaluated regarding the effects of a moderate energy 18 pipe break.
- 19
Response
20 For this issue, complete engineering justification is 21 provided in the DCP Resolution and/or Completion 22 Packages for EOI file 8050.
The IDVP has fully 23 addressed these matters in ITR No. 21, Rev.1, on page 24 4-2.
25
///
26
/// -
,,e--.
-ey-r-
a.
~ - - - - -
,,,,, - ~,
1 Contention 4(i):
2 The fire protection for the motor driven AFW pump room 3
is not consistent with the PG&E licensing commitment 4
for fire zone separation as stated in its November 13, 5
1978 Supplemental Information for Fire Protection 6
Review ("SIFPR") in that:
7 1) there is a large grated ventilation opening in the 8
ceiling of the room; 9
2) a fire damper has gaps when it is closed.
10
Response
11 For these issues, complete engineering justification is s
12 provided in the DCP Resolution and/or Completion 13 Packages for EOI files 8038 and 8037.
The IDVP has 14 fully addressed these matters in ITR No. 18, Rev. 1, on 15 page 5-3.
16 Contention 4(j):
17 The fire protection for the AFW pump room is not 18 consistent with the PG&E licensing commitment for cable 19 separation as stated in its SIFPR of November 13, 1978 l
20 in that:
21 1) the pumps for the motor driven AFW pumps and the 22 control circuitry for a flow control valve nec-23 essary for operation of the turbine driven AFW 24 pump are located in a single fire zone.
25
///
26
///
1
Response
2 For this issue, complete engineering justification is 3
provided in the DCP Resolution and/or Completion 4
Packages for EOI file 8019.
The IDVP has fully 5
addressed these matters in ITR No.18, Rev.1, on page 6
5-1.
7 Contention 4(j):
8 2) cables for some AFW circuits are not routed in 9
accord with descriptions in the SIFPR and four AFW 10 circuits PG&E committed to identify and review in 11 the, SIFPR were not included in that document.
12
Response
13 For this issue, complete engineering justification is 14 provided in the DCP Resolution and/or Completion 15 Packages for EOI file 8021.
The IDVP has fully 16 addressed these matters in ITR No. 18, Rev. 1, on page 17 5-2.
l l
18 Contention 4(k):
I 19 Contrary to the licensing commitment set forth in its 20 SIFPR of November 13, 1978, each of the three 4160 volt 21 cable spreading rooms has a ventilation opening leading 22 up to the 4160 volt switchgear rooms.
23
///
24
///
l 25
///
26,
1
Response
2 For this issue, complete engineering justification is 3
provided in the DCP Resolution and/or Completion 4
Packages for EOI file 8039.
The IDVP has fully 5
addressed these matters in ITR No.18, Rev.1, on page 6
5-3.
7 Contention 4(1):
8 Contrary to FSAR Section 3.6, possible jet impingement 9
loads have not been considered in the design and 10 qualification of safety related piping and equipment 11 inside containment.
12 Sesponse:
13 For this issue, complete engineering justification is 14 provided in the DCP Resolution and/or Completion 15 Packages for EOI files 7002 and 8065.
The ICVP has 16 fully addressed these matters in ITR No. 48, Rev. D, on 17 pages 7-1 and 7-2.
i 18 Contention 4(m):
19 Contrary to QA program commitments in FSAR Section 20 17.1, documented evidence is inadequate to demonstrate l
21 that rupture restraints outside and inside containment 22 have been properly designed and installed to provide 23 protection against rupture in high pressure piping.
l 24
///
25
///
l 26
///
1
Response
2 Section 17.1 of the FSAR discusses only QA programs and 3
is silent on the topic of rupture restraints.
This 4
contention in unclear.
5 Contention 4(n):
4 6
For the containment exterior shell review the ITP 7
review used the AISC Code rather than Section III of 8
the ASME Code contrary to the commitment in Table 3.2-4 9
of the FSAR.
10
Response
11 This issue is fully addressed in SER, Supplement 18 on 12 page C.3-17.
13 Contention 4(o):
14 Contrary to the requirements of NUREG-0588 regarding 15 environmental qualifications, safety-related cables and 16 cable splices which could be subject to a harsh 17 environment during a high energy line break are not 18 identified in the PG&E Environmental Qualification 19 Report.
20
Response
21 For this-issue, complete engineering justification is 22 provided in the DCP Resolution and/or Completion 23 Packages for EOI file 8044.
The IDVP has fully 24 addressed these matters in ITR No. 25, Rev.1, on page 25 5-2.
4 26
///...
1 Contention 4(p):
2 The NSC pipe break analysis, which is Appendix A to 3
FSAR Section 3.6, did not include all likely sources of 4
water in the calculation of flooding levels.
5
Response
6 For this issue, complete engineering justification is 7
provided in the DCP Resolution and/or Completion 8
Packages for E0I file 8005.
The IDVP has fully 9
addressed these matters in ITR No.14, Rev 2., on page 10 5-4.
11 Contention 4(q):
12 Contrary to PG&E's December 28, 1979 licensing commit-13 ment letter to the NRC, modifications to protect two 14 Auxiliary Feedwater valves from the effects of moderate 15 energy line breaks were not implemented.
16
Response
17 For this issue, complete engineering justification is 18 provided in the DCP Resolution and/or Completion Pack-19 ages for EOI file 8014.
The IDVP has fully addressed 20 these matters in ITR No. 21, Rev 1.,
on page 4-1.
21
///
22
///
23
///
24 25 26 _
1 Contention 4(r):
2 Centrary to the licensing commitment to maintain 3
minimum system redundancy'as stated in FSAR Section 4
3.6A (NSC evaluation of pipe break outside 5
containment), four components were identified for which 6
high energy line cracks could cause temperatures in 7
excess of the specification temperahures of the 8
components.
9
Response
x 10 For this issue, complete engineering justification is 11 provided in the DCP Resolution and/or Completion 12 Packages for EOI file 8058.
The 'IDVP has fully 13 addressed these matters in ITR1No. 27', Rev 2., on page 14 5-3.
8 15 Contention 4(s):
16 Contrary to the licensing commitment to maintain g
l 17 minimum system redundancy as -stated in FSAR, 'section'.
18 3.6A (NSC evaluation of pipe break outside 19 containment), a conduit was identified whose failure 20 due to a high energy line crack could eliminate 21 redundant Auxiliary Feedwater system flow.
f.
22
///
23
///
l 24
///
i
.25 s
26
. ~-.
\\
1
Response
__ k, 2
(for this issue, complete engineering justification is s
3 3
' provided i.in the DCP Resolution and/or Completion 4
Pa'cka'ges for EOI files 8028, 8029, and 8030.
The IDVP
\\
5 has fully ' addressed these matters in ITR No. 21, Rev.
6
'1,.on'page 4-2.
7 Contention 4(t):
8 Contrary to the FSAR Section 8.3 commitment to provide 9
switchgear buses with adequate short circuit inter-lo rupting capability, the calculated duties for circuit u
'J
'11 breakers on 4160 V. buses F, G,
and H were above the
.\\
12 nameplate ratings fer those buses.
s 13 Response _:
14 For this issue, complete engineering justification is 15 pr,ovided in the DCP Resolution and/or Completion 16 Packages for EOI file 8022.
The IDVP has fully i
17 addressed these matters in ITR No. 24, Rev.1, on page 18 5-1.
19 Contiention 4(u):
20 Contrary to single failure criteria stated in FSAR e2,1 Section 3.1.1, reviews of the Auxiliary Feedwater and g...,
22 Control Room Ventilation and Pressurization systems 23 identified circuit separation and single failure
(
~
24 deficiencies.
Similar deficiencies were identified in r
additional verification reviews, which included other 25 26 safety-related systems.
S N
( '3 -[
o 1
Response
2 For this issue, colaplete engineering justification is 3
provided in the DCP Resolution and/or Completion y
~'
4 Packages for EOI files 8017 and 8057.
The IDVP has 5
fully addressed these matters in ITR No. 28, Rev. 2, on 6
pages 5-1 and 5-2, and ITR No. 49, Rev. O, on pages 4-1 7
and 5-1.
8 (b)
The documents pertinent' to this matter are identified 9
in our response to Number 48(a) above.
10 (c)
Other than the contentions of the Governor and the 11 Joint Intervenors, none.
-12 (d)
See answer to Interrogatory No. 2(d).
13 INTERROGATORY NO. 49:
14 With respect to contention 5, do you deny that the 15 verification program' has not verified that Diablo Canyon 16 Units 1 and 2 "ahbuilt"conformtothedesigndrawingsand 17 analyses?
18 RESPONSE TO INTERROGATORY NO. 49:
19 As of the time of these answers, the "as built" 20 conformance process is not-ye. complete, but will be 21 completed as set forth 1v M a ee.
22 INTERROGATORY NO. 50:
j 23 If your answer to the preceding interrogatory is a 24 denial of tlie contention stated therein:
25 (a),Please state each and every fact on which you rely in 26 support of your denial.
=
=4
]
1 (b)
Please identify each and every document on which you 2
rely in support of your denial.
3 (c)
Please identify each and every document known to you or 4
believed by you to contain facts or allegations that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your denial or upon those 7
facts on which you base your denial.
8 (d)
Please identify each and every person you intend to 9
call as a witness whom you expect to testify concerning 10 your denial of this contention or the facts on which 11 you rely in support of the denial of this contention.
12 RESPONSE TO INTERROGATORY NO. 50 13 (a)
Unit 1:
The engineering review of plant modifications 14 resulting from IDVP EOI, have been performed in i
15 accordance with Engineering Manual Procedue 3.60N for 16 Unit 1.
These procedures require that engineering 17 review the results of construction efforts which differ 18 from the design change notice.
This review also 19 includes a comparison of these results with the design 20 used in the analyses performed prior to release of the 21 design.
r 22 Unit 2 :
The Unit 2 Internal Review Program, which was 23 issued March 1983 to address the verification program, 24 requires that as-built modifications be reviewed to 25 confirm acceptability.
26
/// -
e 1
(b)
PGandE Engineering Manual Procedure No. 3.60N; PGandE 2
Engineering Manual Procedure No.
3.7, Rev. 5; PGandE 3
Engineering Manual Procedure No. 3.7, Rev. TR-9; Diablo 4
Canyon Project Engineer's Instruction No. 13, Rev. 0; 5
Diablo Canyon Project Engineer's Instruction No. -13, 6
Rev. 1; previously furnished in discovery.
7 (c)
See answer to 48(c).
8
(,1)
See answer to 48(d).
9 INTERROGATORY NO. 51:
10 With respect to contention 6, do you deny that the 11 verification program failed to verify that the design of 12 safety related equipment supplied to PGandE by Westinghouse 13 met licensing criteria?
14 RESPONSE'TO INTERROGATORY NO. 51:
15 No.
The seismic design of all safety-related 16 equipment furnished by Westinghouse was not reanalyzed.
17 Whenever findings of the verification program altered the i
18 input to specific pieces of safety-related equipment, that 19 equipment was requalified by Westinghouse and reviewed by 20
.the DCP.
21 INTERROGATORY NO. 52:
22 If your answer to the preceding interrogatory is a l
' 23 denial of the contention stated therein:
l 24 (a)
Please state each and every fact on which you rely in 25 support of your denial.
26 fy.-
i 1
(b)
Please identify each and every document on which you 2
rely in support of your denial.
3 (c)
Please identify each and every document known'to you or 4
believed by you to contain facts or allegations that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your denial or upon those 7
facts on which you base your denial.
8 (d)
Please identify each and every person you intend to 9
call as a witness whom you expect to testify concerning 10 your denial of this contention or the facts on which 11 you rely in support of the denial of this contention.
12 RESPONSE TO INTERROGATORY NO. 52:
13 Not applicable.
14 INTERROGATORY NO. 53:
15 With respect to contention 7, do you deny that the 16 verification program failed to identify the root causes for 17 the failures in the PGandE design quality assurance program 18 and failed to determine if such failures raise generic 19 concerns?
20 RESPONSE TO INTERROGATORY NO. 53:
21 Yes.
.22 INTERROGATORY NO. 54:
23 If your answer to the preceding interrogatory is a 24 denial of the contention stated therein:
25 (a)
Please state each and every fact on which you rely in 26 support of your denial.
1 (b)
Please identify each and every document on which you 2
rely in support of your denial.
3 (c)
Please identify each and every document known to you or 4
believed by you to contain facts or allegations that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your denial or upon those 7
facts on which you base your denial.
8 (d)
Please identify each and every person you intend to 9
call as a witness whom you expect to testify concerning 10 your denial of this contention or the facts on which 11 you rely in support of the denial of this contention.
s 12 RESPONS$ TO INTERROGATORY NO. 54:
13 (a)
The cause of the deficiencies is clearly addressed in 14 Section 1.8 of PGandE's Phase I Final Report, in 15 Section 3.0 of PGandE's Phase II Final Report and in 16 Section 6.0 of the IDVP Final Report.
The development l
17 of the program to address generic concerns is described i
l 18 in the above referenced Final Reports as well as in the i
l 19 IDVP Phase I and Phase II management plans.
These 20 documents show that both causes of deficiencies and 21 possible generic concerns were adequately addressed by l
l 22 the verification program.
23 (b)
See above paragraph.
i l
24 (c)
See answer to 42(c).
25 fff 26 f//,
1 (d)
R. C. Anderson 2
H. B. Friend 3
G. H. Moore 4
C. W. Dick 5
INTERROGATORY NO. 55:
6 With respect to contention 8, do you deny that the 7
ITP failed to develop and implement in a timely manner a 8
design quality assurance program in accordance with 10 C.F.R 9
Part 50, Appendix B to assure the quality of the recent 10 design modifications to the Diablo Canyon facility and 'that 11 the IDVP failed to ensure that the corrective and 12 preventative action programs implemented by the ITP are 13 sufficient to assure that the Diablo Canyon facilities will 14 meet licensing criteria?
15 RESPONSE TO INTERROGATORY NO. 55:
16 Yes.
17 INTERROGATORY NO. 56:
18 If your answer to the preceding interrogatory is a 19 denial of the contention stated therein:
20 (a)
Please state each and every fact on which you rely in 21 support of your denial.
22 (b)
Please identify each and every document on which you 23 rely in support of your denial.
24
///
25
///
i 26
/// -. -
1 (c)
Please identify each and every document known to you or 2
believed by you to contain facts or allegations that 3
contradict, are inconsistent with, or tend to cast 4
doubt upon the validity of your denial or upon those 5
facts on which you base your denial.
6 (d)
Please identify each and every person you intend to 7
call as a witness whom you expect to testify concerning 8
your denial of this contention or the facts on which 9
you rely in support of the denial of this contention.
10 RESPONSE TO INTERROGATORY NO. 56:
11 (a)
The PGandE Quality Assurance Program complies with 12 10CFR50 Appendix B and has been approved by NRC.
The 13 DCP Quality Assurance Program complies with 10CFR50 14 Appendix B and has been approved by NRC.
A QA Program 15 that complies with 10CFR50 Appendix B has been in force 16 since the inception of the ITP.
Audit programs have 17 been implemented in a timely manner to assure 18 continuing effective implementation of the quality 19 assurance program, and to provide resolution and 20 corrective action for any deficiencies identified.
The 21 IDVP has performed QA audits and design reviews of DCP 22 activities, as required by the NRC Commission Order and 23 Staff Letter.
The IDVP Audit included assessment of 24 DCP corrective action design activities related to 25 Error or Open item (EOI) Reports and DCP Open Items 26 (o1),.-
1 (b) 1.
Bechtel Power Corpor& tion Topical Report BQ-TOP-1 2
Revision 3A "Bechtel Quality Assurance Program for 3
Nuclear Power Plants"; dated October, 1980; signed 4
by S. D. Bechtel, Jr.
5 2.
" Quality Assurance
- Program, Bechtel Power 6
Corporation, Diablo Canyon Project, Revision 1";
7 report 8
3.
Letter dated June 12, 1981, from Karl V.
Seyfrit 9
to Mr. C. D. Statton 10 4.
Letter dated October 16,
- 1980, from Walter P.
11 Haass to Mr. R. M. Collins 12 5.
Letter dated August 2, 1982, from D. G. Eisenhut 13 to Philip A. Crane, Jr., Esq.
14 6.
Letter dated August 13,
- 1982, from Philip A.
15 Crane, Jr. to Frank J. Miraglia, Jr.
16 7.
Letter dated September 22, 1982, from H. R. Denton 17 to Mr. Joel Reynolds (previously provided to all 18 parties) 19 8.
Diablo Canyon FSAR Section 17 (available to all 4
20 parties) 21 9.
" Pacific Gas and. Electric Company Quality 22 Assurance Manual for Nuclear Power Plants"; signed 23 by Barton W.
Shackelford (provided in Governor's 24 First Document Production Request) 25
///
26
///.-.
1 10.
"Diablo Canyon Project Nuclear Quality Assurance 2
Manual" Revision 4; dated August 15, 1983; signed 3
by R. D.
- Allen, W. T.
Kellerman, H. B.
Friend 4
(Revisions 0, 1,
and 2 provided in Governor's 5
First Document Production Request) 6 11.
"Bechtel Power Corporation, San Francisco Power 7
Division, Quality Assurance Department Manual";
8 Revision 35 dated Dcember 27, 1982; individual 9
procedures signed by H. F.
- Lilligh, W. T.
10 Kellerman, and others (provided in Governor's 11 first Document Production Request) 12 12.
"Diablo Canyon
- Project, Pro' ject Engineer's 13 Instruction," Revision 9 dated August 5, 1983; 14 signed by G. H. Moore, G. V.
Cranston and M. J.
15 Jacobson (provided in Governor's first Document 16 Production Request) 17 13.
" Pacific Gas and Electric Company, Engineering 18 Manual";
dated August 15, 1983; individual 19 procedures signed by D. A.
Brand and others 20 (provided in Governor's First Document Production 21 Request) l 22 14.
Letter dated August 20, 1982 from J. O.
Schuyler 23 to Howard B. Friend 24 15.
NRC Inspection Report 50-275/81-29, 50-323/81-18 25 dated November 6, 1981; signed by J. L. Crews and l
26 others (available to all parties) l l
1 16.
NUREG-0675 Supplement No. 18 dated August 1983 2
(available to all parties) 3 17.
Project Audit Reports and Management QA Audits 4
(provided in Governor's First Document Request and 5
to be provided in JIs' Second Set of 6
Interrogatories and Request for Production of 7
Documents excepts as follows:
8 (a)
Project Audit 10.1-1; memorandum; May 23, 9
1983; signed by M. J.
Jacobson; to G. H.
10 Moore /G. V. Cranston 11 (b)
Project Audit 15.1-1; memorandum; May 13, 12 1983; signed by M. J.
Jacobson; to G. H.
13 Moore /G. V. Cranston 14 (c)
Project Audit 2.1-4; memorandum; 15 September 12, 1983; signed by M. J. Jacobson; 16 to G. V. Cranston 17 (d)
Project Audit 3.14.-2; memorandum; August 31, 18 1983; signed by M. J.
Jacobson; to G. V.
19 Cranston 20 (e)
Project Audit 13-1; memorandum; August 24, 21 1983; signed by M. J.
Jacobson; to G. V.
22 Cranston) 23 18.
NRC Inspection Report 50-275/82-31, dated 24 November 15, 1982; signed by D. F.
Kirsch 25 (available to all parties) 26
///
i
,c.
e
'l 19.
Letter dated January 26,. 1983, from Darrell G.
2
-Eisenhut to Philip A. Crane, Jr., Esq.
3 20.
IDVP Final Report (available to all parties) 4 21.
All ITR's (available to all parties) 5 22.
ITP Final Reports (available to all parties) 6 (c)
Other than contentions advanced by the Governor and 7
Joint Intervenors, none.
8 (d)
H. B. Friend 9
C. W. Dick 10 M. J. Jacobson 11 INTERROGATORY NO. 57:
12 Do you contend that the design quality of all the 13 safety related equipment supplied to PGandE by Westinghouse 14 was assured by a quality assurance program or programs which
'15 met each and every requirement of each and every criterion 16 of Appendix B to 10 C.F.R. Part 50?
17 RESPONSE TO INTERROGATORY NO. 57:
i 18 No.
The Westinghouse program fully complied with 19 applicable' Commission quality assurance requirements at the 20 time of design.
- 21 INTERROGATORY NO. 58:
22 If your answer to the preceding interrogatory is 23 in the affirmative:
24 (a)
Please state each and every fact on which you rely in 25 support of your answer.
26
///
~
1 1
(b)
Please identify each and every document on which you 2
rely in support of your answer.
3 (c)
Please identify each and every document known to you or 4
believed by you to contain facts or allegations that 5
contradict, are inconsistent with, or tend to cast 6
doubt upon the validity of your answer or upon those 7
facts on which you base your answer.
8 RESPONSE TO INTERROGATORY NO. 58:
9 Not applicable.
10 INTERROGATORY NO. 59:
11 Do you contend that the design quality of all the 12 safety related equipment supplied to PGandE by Westinghouse 13 was assured by a quality assurance program or programs whose 14 implementation met each and every requirement of each and 15 every criterion of Appendix B to 10 C.F.R. Part 50?
16 RESPONSE TO INTERROGATORY NO. 59:
17 No.
The Westinghouse program fully complied with 18 applicable Commission quality assurance requirements at the 19 time of design.
20 INTERROGATORY NO. 60:
l-21 If your answer to the preceding interrogatory is 22 in the affirmative:
23 (a)
Please state each and every fact on which you rely in 24 support of your answer.
25 (b)
Please identify each and every document on which you 26 rely in support of your answer..
9 6
1 (c)
Please identify each and every document known to you or 2
believed by you to contain facts or allegations that 3
contradict, are inconsistent with, or tend to cast 4
doubt upon the validity of your answer or upon those 5
facts on which you base your answer.
6 RESPONSE TO INTERROGATORY NO. 60:
7 Not applicable.
8 INTERROGATORY NO. 61:
9 For each and every person identified in your 10 answers to the preceding interrogatories as a prospective 11 witness in these proceedings, please state:
12 (a)
Whether he or she will be offered as an expert witness.
13
'(b)
If the witness will be offered as an expert, the 14 specific subject matter about which the witness will be 15 expected to tesk fy.
l 16 (c)
If the witness will be offered as an expert, the l
17 specific qualifications of the witness that you contend 18 would qualify the witness to give opinion testimony on 19 each specific subject matter about which the witness 20 will testify.
21 (d)
Each and every professional article, book, or the like, 22 if any,.the witness has authored or co-authored l
l 23 concerning each specific subject matter set forth in 24 your answer to subpart (b), above.
25
///
l 26
///
j i
1 (e)
The identity of each and every document the witness 2
will rely on to reach any opinion testimony and 3
specifically correlate each such document (by page and 4
paragraph number) to each specific subject matter on 5
which the witness will render an opinion.
6 (f)
As to each specific subject matter identified in your 7
answer to subpart (b), above, the identity by docket 8
number and case name of each case (court or administra-9 tive agency) where the witness has previously given 10 expert testimony concerning each specific subject 11 matter.
12 (g)
As to each such case, 13 (i) the date(s) the expert estimony was given; 14 (ii) whether yc,u have a copy of the testimony given; 15 (iii) whether you have a copy of the transcript covering 16 any or all of the witness's examination or 17 cross-examination for each such proceeding; 18 (iv) whether you have a copy of any notes which the 19 witness made in preparation for, or utilized 20
- during, the witness's examination or 21 cross-examination in each such proceeding.
22 RESPONSE TO INTERROGATORY NO. 61:
23 See Attachment C.
l 24
///
25
///
26
///
l.
,--w 4
l o
1 INTERROGATORY NO. 62:
2 Please identify each and every document 3
excluding the IDVP and DCP Final Reports, the Interim 4
Technical Reports, and Supplement 18 to the Safety 5
Evaluation Report -- that:
6 (a)
Describes how the DCP, the IDVP, or the staff drew 7
inferences from sample observations of design 8
activities and products concerning the quality of 9
design of Diablo Canyon.
10 (b)
Discusses the validity of the methods used to drav 11 inferences about the quality of design of Diablo Canyon 12 from sample observations.
13 (c)
Discusses the validity of the inferences about the 14 quality of design of Diablo Canyon drawn from sample 15 observations.
16 (d)
Discusses the method by which any one or more sample 17 was drawn for the purpose of assessing the quality of 18 design of Diablo Canyon.
19 (e)
Discusses the validity of the sampling methods used.
j 20 RESPONSE TO INTERROG\\ TORY NO. 62:
21 There are 1.o documents responding to items a, b, 22 or c.
The list below responds to items d and e:
23 1.
IDVP Phase I Program Plan, TES; April 2, 24 1982.
25 2.
IDVP Phase II Program Plan, TES; June 18, 26 1982. _
e 1
3.
SECY-82-89, NRC; March 1, 1982.
2 4.
SECY-82-414, NRC; October 13, 1982.
3 5.
Public Meeting, February 3, 1982, NRC Staff, 4
IDVP, PGandE; Bethesda, Maryland.
5 6.
Public Meeting, March 4, 1982; NRC Commis-6 sioners, NRC Staff; Washington, D.C.
7
///
8
///
9
///
10 11 s
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 1.
- _ - _ - ~ _ _ - ~. _ _ _ _ _. _ _.. _ _
1 2
Respectfully submitted, 3
ROBERT OHLBACH PHILIP A. CRANE, JR.
4 RICHARD F. LOCKE Pacific Gas and Electric Company 5
P. O. Box 7442 San Francisco, CA 94120 6
(415) 781-4211 7
ARTHUR C. GEHR Snell & Wilmer 8
3100 Valley Center Phoenix, AZ 85073 9
(602) 257-7288 10 BRUCE NORTON Norton, Burke, Berry & French, P.C.
11 P. O. Box 10569 Phoenix, AZ 85064 12 (602) 955-2446 13 Attorneys for Pacific Gas and Electric Company 15 16 j
M
' P11fli V Cranef, Jr.
17
(
18 DATED:
September 19, 1983.
20 21 22 23 24 25 26.
~.
ATTACHMENT A I
s-i LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO GOVERNOR DEUKMEJIAN'S THIRD SET OF INTERROGATORIES 1
1 e
4 1
5 4
4 3
4 b
i 4
k tr a
i
!l
Attachment A References (Supplement to Response to Interrogatory No. 24(b))
(1)
Seismic Evaluation for Postulated 7.5M Hosgri Earthquake, Units 1 and 2, Diablo Canyon Site, PGandE, U.S. NRC Docket Nos. 50-275 and 50-323.
(2)
Specification for Seismic Review of Major Structures for 7.5M Hosgri Earthquake, February.8, 1977.
(3)
Report by John A. Blume and Associates, Engineers, Diablo Canyon Nuclear Power Plant Unit No.
1, Contain-ment Structure-Finite Element Model, Dynamic Seismic Analysis, July 1970, JABE-PGE-DC-1.
(4)
Pacific Gas and Electric Company, Phase I Final Report, Design Verification Program, Diablo Canyon Power Plant, 1982, Docket No. 50-275, OL-DPR-76.
(5)
Final Safety Analysis Report, Units 1 and 2, Diablo Canyon Site, PGandE, U.S. AEC Docket Nos. 50-275, 50-323.
(6)
ITP working papers, calculation packages, and all pertinent EOIs.
I i
l
[
i...
i
.t.
ATTACHMENT B J
i i
i LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO GOVERNOR DEUKMEJIAN'S THIRD SET OF. INTERROGATORIES l
1 r
i
i ATTACHMENT B
~.
INCIDSURE 2 mis enclosure contains information which addresses potential unresolved items extracted fra SSER No.18. S e information provided is considered by PGandE to resolve these items and is provided for review, as appropriate.
Information for each item is provided on an individual attachnent. Each attachment contains a reference, the identification of the unresolved item, and a response to the identified item. No further action on these issues is contenplated by the Project at this time, with the exception of 1) revising or supplementing the Phase I and II Final Reports at a future date, if appropriate, or 2) conpletion of evaluations and/or modification work, and documentation of said work.
4174a/naw i
V
INCIDSURE 2 CONTAIl@ TENT AIOULUS suUCavg2 20 H2 cutoff frequency A.
REFERDICE Cbntainment Annulus Structure SER Section 3.2.1.6, p. C.3-9 B.
POTENTIAL UNRESOLVED ITDt "It is noted, however, that a frequency of 20 Hz should not be considered as a frequency in the rigid range without verification.
S e Netnark Hosgri spectra approach ZPA at 33 Hz. It is the staff's position that use of the 20 Hz cutoff frequency for generation of floor response spectra should be verified and/or justified. With the exception noted, the results should lead to the acceptance of the annulus steel structure if the the program was carried out properly.
S e IDVP review will verify the accuracy of the DCP program."
- 2e staff considers the 20 Hz cutoff frequency for generation of floor response spectra an open issue and will require that the IDVP review verifications and/or justifications provided by the DCP and include the results of review in future reports."
C.
DCP RESPONSE Horizontal stiffness of the annulus steel being considered rigid by having a frequency beyond 20 Hz is based on the following rationale:
i (1) At the time of the Hosgri evaluation, the NRC Staff and its consultants, and PGandE and their consultants agreed the evaluation would be based on the same mathematical models and l
analytical procedures as were used for the DDE with certain specific exceptions. Since no exception was given in the Hosgri report, the Hosgri evaluation of the annulus steel was performed to the same criteria and using the same mathematical models and analytical procedures as for the DDE evaluation. For the annulus structure, this DDE analysis, as described in the FSAR, was based on the motions of the interior concrete crane wall without additional anplification. R us, the horizontal stiffness of the annulus was considered rigid, i.e., transmit motion without anplification. mis degree of rigidity, as j
i defined in the FSAR for pipe support structures, systems, and-ccuponents is 20 Hz. mis same set of assumptions and considerations was carried forward for the Hosgri evaluation as l
permitted by the Hosgri report.
4174a I i
l l
l r
i C.
DCP RESPCtEE (continued) l (2) S e annulus steel is a structure specifically designed to l
support piping. De stiffness requirements for pipe support I
structures for the DDE analysis as well as the Hosgri analysis is clearly defined in the FSAR and Hoegri Rsports as 20 Hz.
B is agreed upon criteria, i.e., being considered rigid by having a fundamental frequency greater than 20 Hz, is e tirely reasonable and appropriate for the safety evaluation of the supported systems and ccaponents for the following reasons:
o D ainant modes of piping and raceways generally have frequencies I
in the 5 to 15 Hz range. D ese modes are dcninant for either or both of the following reasons. First, the highest anplification i
in the horizontal floor response spectra occurs in this range.
Second, the participation factor of the modes in the 5 to 15 Hz range are normally higher than those of the higher
- modes. In the cases where modes with frequencies g5 eater can 15 Hz have i
i larger participation factors than those of lower modes, the system is quite stiff which results in considerable inherent structural capacity.
l o
D e strain associated with modes having frequencies higher than 20 Hz is quite small. For exanple, the natura] freqJency of a single mass oscillator is f = 3.13/fD, where D is the static deflection in inches of the mass subjected to a 1.0 g loading and f is in cycles per second. S e deflection of a 20 Hz oscillator to a 1.0 g load is 0.0245 inches, which for the span and size of piping and raceways considered results is a small strain. A conservative estimate of the acceleration fr a a coupled analysis of the annulus steel'and the piping or raceway for nodes having a frequency greater than 20 Hz is 3.0 g.
'the deflection associated with a 20 Hz mode experiencing 3.0 g would be approximately 0.064 inches. Such a deflection could not cause serious problems for raceways or piping and these are the items supported by the annulus steel, o
For conduits or piping where the modes having frequencies greater than 20 Hz are ccabined with lower modes, the effects are ccabined by the SRSS. Ris tends to reduce the significance of a nondominant mode. If, for exanple, there is one dominant mode below 20 Hz which produces a stress of 20 ksi and a mode above 20 Hz which produces a stress of 5 ksi, the ccabined stress is 20.6 ksi. Further, if there are four modes below 20 Hz and all are producing 5 ksi individually, the ccrnbined stress, excluding the higher mode, would be 10 ksi. Se contined stress, including the higher : rode, would be 11.2 ksi.
B is indicates the increase in stress due to inclusion of the higher modes causes only a small increase in the combined seisnic stress.
4174a -
1
)
C.
DCP RESPONSE (continued)
Piping supports for Diablo Canyon have a stiffness of 20 Hz o
which results in a certain amount of toughness above that of supports designed on the basis of strength only. A ntaber of plants designed in the late 60's and early 70's did not have any specific stiffness requirement for pipe supports. S us, the design of Diablo Canyon's pipe supports is already more conservative than typical industry practice for this vintage plant.
2e piping and raceway analysis is based on an uncoupled linear o
elastic analysis. hats have demonstrated behavior to be nonlinear and designs based on linear analysis with traditional low danping values to be quite conservative. For piping, if the actual behavior of the supports are taken into consideration, it is apparent that the linear elastic analysis is a conservative idealization of the actual behavior, n e actual gaps that exist at scune supports are neglected. 2is results in more of the actual building motion being transmitted to the pipe than actually takes place. In reality, the pipe will tend to have relative movement between the pipe and supports where the gaps exist, which tends to reduce the input motion into the piping system and also tends to prevent a resonant condition from developing. In addition, s ee suports allow sliding to take place between the support and the pipe. Se frictional behavior is also neglected, which, if included, would tend to reduce resonant conditions. Se uncoupled analysis using response spectra as irput has been recognized as a conservative approach when the weight of the supported items is above a few percent of the supporting structure. In the case of the piping and raceway systems, the percentage is high, relative to the annulus steel.
Berefore some unquantified margin exists.
When the Hoagri criteria were developed fran many and lengthy discussions between the NRC Staff, PGandE and its respective consultants, the above considerations, and perhaps others not explicitly mentioned, influenced the collective engineering l
judgment. Engineering judgment is, in fact, necessary in such a process due to the nature of seismic design. Based on all of the considerations outlined above, it is concluded that the 20 Hz criteria for definitions of rigid range for the horizontal response of the annulus structure is a reasonable ard appropriate basis for evaluation of the piping, systems, and emponents supported by the annulus steel.
4174a,
. _ =. _.
i s
. ATTACHfiENT C 1
LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO GOVERNOR DEUKMEJIAN'S THIRD SET OF INTERROGATORIES i
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ATTACHMENT C
!WiE:
LINCOLN E. MALIK RESPONSE 10 IITr. 61:
(a). Yes (b) Seismic (c) See attached resume.
(d)
Publications:
1.
" Evaluation of Contribution of Floor Systen to Dynamic Characteristics of Moment-Resisting Space Frames," with V. V.
Bertero, Proceedings, Sixth World Conference on Earthquake Engineering, New Delhi, India (January, 1977) 2.
" Contribution of a Floor System to the Dynamic Characteristics of R/C Buildings," with V. V. Bertero, Earthquake Engineering Research Center, Report No. EERC 76-30, University of California, Berkeley (1976) l 3.
" Preliminary Dynamic Analysis of the Main Building of the Olive View Hospital," with A. K. Chopra, V. V. Bertero, and S. A. Mahin, l
Proceedings, National Conference on Earthquake Engineering, I
l Investigation of the San Fernando Eartixpake, Ios Angeles, California (February, 1972) i 4248a..
s s.
't 4.
" Propagation of Entropy Through Systems of Mathematical Equations,",,
Engineer 'Ihesis, Stanford University (1970)
(e) To be provided at the time of the testir.ony.
1
?
Pu (f) i)
Docket i
~ ~
ii)
Case #
Diablo Canyon License Unit 1 Testimony Before ASLB
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(g) i)
Date:
1979 ii)
No 4
iii)
No iv)
No i
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Lincoln E. Malik structura2 engineering earthquake engineering probability analysis soils engineering
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EDUCATION University of California, Berkeley:
Ph.D. Structural Engineering, 1976 Stanford University:
Degree of Engineer, 1970 Stanford University:
M.S. Civil Engineering, 1969 University of California, Berkeley:
B.S. Civil Engineering, 1964 PROFESSIONAL HISTORY y
URS/ John A. Blume & Associates, Engineers, San Francisco, California, Man-g' ager of Structures Department, 1979 present; Project Engineer, 1976-1979 University of California, Berkeley, Department of Civil Engineering, Re-search Assistant, 1971-1976 Sargent and Lundy Consulting Engineers, Chicago, Illinois, Design Engi-neer, 1965-1968
~,
Westenhoff and Novak Consulting Engineers, Chicago, Illinois, Design Engi-neer, 1964
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t PROFESSIONAL EXPERIENCE Dr. Malik has had extensive experience in structural engineering, risk l
analysis, and soils engineering.s His experience includes the seismic anal-i ysis of nuclear power plants, high-rise buildings, and buried structures; design of' reinforced concrete and steel structures; assessment of earth-
, quake damage; risk analysis of nuc ear-related equipment and structures; l
foundation design; and slope-stability analysis.
He is also a member of selected professional committees engaged in establishing state-of-the-art procedures for the seismic analysis of nuclear facilities.
Among other major projects, Dr. Malik supervised the seismic reanalysis and design of ~ modifications for the Connecticut Yankee nuclear power plant in response to the' Systematic Evaluation Program (SEP) initiatad by the Nuclear Regulat'ory Commission (NRC).
Mc cirected the effort to develop the struc-tural criteria and the technical approach to modal, analyze, and design the modifications for the entire plant.
He also supervised the development of project-specific computer programs and preliminary parametric studies and l
the preparation of responses to NRC staff questions.
l Dr. Malik was also responsible for supervising the analysis, evaluation, and design of modifications of safety-related masonry walls in response to l
lE Bulletin 80-11.
For this project, criteria documents were developed for l
three nuclear plants, and a fbil evaluation and design of modifications was I
completed for the masonry walls at the Connecticut Yankee plant.
He also i
participated in the owners group that developed generic criteria for use in all plants.q
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LINCOLN E. MAllK
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PROFESSIONAZa EXPERIENCE (Continued)
His supervision of'the seismic evaluation and risk analysis of the Purex facility structures at.the Hanford reservation in Washington included over-seeing the nonlinear analyses of several structures.
Also involved, in essociation with a subcontractor, was a risk analysis to develop fragility curves for the structures at the facility.
in connection with the seismic review of the Diablo Canyon Nuclear Power Plant for a postulated earthquake on the Hosgri fault, Dr. Malik supervised the reevaluation of the containment and auxiliary structures, providing such work as dev'elopment of seismic criteria, mathematical modeling, soil-
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structure' interaction analysis, dynamic analysis, and assistance in the development of the seismic sections of the PSAR and FSAR documents.
In this work, he ofte, met with NRC staff and clients to resolve problems and of-fered. expert. testimony at hearings before the Advisory Connittee on Reactor Safeguards and,the Atomic Safety and Licensing Board.
He also coordinated a seismic research program for Pacific Gas and Electric Company involving several engineering and scientific firms.
. 7r His nuclear experience has also included structural analyses and design of structures at the Quad Citi,es Nuclear Power Plant, seismic analysis of buried nuclear waste storage tanks at the Hanford facility, and SEP work for the Dresden 2 and Oyster Creek nuclear power plants.
Dr. Malik's probability analysis experience includes supervision of a proJ-ect to assess both -the reliability of industrial cranes and added rella-bility resulting from redundancies along the crane's loading path, r
Soils engineering, which was one of Dr. Malik's minors in his doctoral studies, is another area of his professional expertise.
He was responsible for the analysis and design of'the crusher building at the River Rouge Plant in Michigan, which was surk as a caisson in very soft clay.
He also directed projects requiring the ' design of foundations at several power plants and slope-stability analyses' under gravity and seismic loads.
i in addition, Dr. Malik has perforned static and dynamic analyses to inves-t j
tigate the response of the Olive View Medical Center in Los Angeles to the 1971 San Fernando earthquake.- He also investigated the contribution of j
floor systems to the dynamic characteristics of buildings.
AFFIIaIATIONS ASCE Seismic Analysis of Safety Class Structures Standards Committee, Nuclear Standards Committee m-
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NAME:
JOHN M. AMARAL RESPONSE E Ilfr. 61:
(a) Yes (b) Quality Assurance (c) See attached professional qualifications for J. M. Amaral.
(d) Author of numerous papers and reports that have contributed to the overall effectiveness of quality programs:
Papers 1.
" Approach to the Acceptance of Concrete Requirements," presented at AIF Forum on Reactor Construction and Operation, Boston (1977) 2.
" Interfacing With Project Management," given during the Ninth Annual s
National Energy Division Conference, Orlando (1982) 3.
" Control of Quality for the 260-In-Dia Sold Rocket Motors," presented at ICRPG/AIAA Solid Propulsion Conference, Washington, D.C. (1966) 4.
" Quality Assurance & Reliability of the Aerojet 260-Inch Motor,"
presented to the Panel on Reliability of Large Solid-Propellant Motors, JPL (1965) 4248a 4.
5.
" Observations on the Practical Approach to the Acceptance of Concrete Requirements," presented at Atomic International Forum on Reactor Construction and Operation, Boston (1977)
Reports 1.
"260-Inch Motor Reliability Study, Final Report."
(1968) 2.
" Development of Non-Destructive Test Techniques for Large Solid Propellant Grains, Final Report," J. M. Amaral and B. L. Lamb (1971)
Contractural Reports, Plans, Proposals and Procedures 1.
" Cost Effectiveness of Radiographic Examination of 156-In-Dia Rocket Motors."
2.
" Microwave Inspection Technique Development for the 260-In-Dia Motor Grain."
3.
"NDT Plan for TPA Titanium Forgings, ANSC QA-261-13-121."
4.
" Nozzle Extension NDT Plan for Fibrous Graphite - Composite Nozzle Components, ANSC QA-261-13-143."
4248a 5.
" Reliability and Quality Control Plan for Design, Fabrication, and Test of Omnidirectional Flexible Seals for 21 rust Vector Control of Large Solid Rocket Motors."
(e)
To be provided during the testimony.
(f) 1.1)
Docket l's 50-498 Operating License, 50-499 Operating License Houston Lighting & Power, et al 11)
Case i South Texas Project Units 1 and 2 ASLB Hearing 2.1)
Docket l's 50-275, 50-323 11)
Case i PGandE OQA ASLB Hearing (g) 1.
Refer to the Docket.
2.
Refer to the Docket.
11)1 No
)2 No 4248a iii)1 tb l
)2 tb iv)1 No
)2 No 4248a '
e.
PROFESSIONAL QUALIFICATIONS OF JOHN M. AMARAL My name is John M. Amaral.
I am the Manager of Quality Assurance for the Bechtel Power Corporation.
In this capacity I have responsibility for advancing the effectiveness of the corporate program and directing its inplementation in all four divisions of Bechtel Power Corporation. This covers quality control and related activities for engineering, construction, and procurement. As part of this, I have provided special assistance to several projects, including non-Bechtel projects, where quality problems haw.,
developed, in which I directed investigations, furnished consulting services, and developed reccanendations for corrective action.
I have 30 years of industry experience, including 11 years with Bechtel.
Previously, my responsibilities included Manager of Quality Assurance for the Gaithersburg Power Division, Deputy Manager of Division Quality Assurance in Bechtel's San Francisco Power Division, and Quality Assurance Manager for the LMBR Fast Flux Test Facility.
Prior to joining Bechtel, I was Manager of Quality Systems for Aeroject Nuclear Systems Ccupany, and served as a consultant on reliability, quality systems, and non-destructive testing and developed the quality system for Aerojet's portion of a major nuclear program.
Earlier, I was program manager 4248a s
of advanced technology, responsible for conducting research and developraent programs in nondestructive testing and reliability. Before that, I held successive positions as Quality Engineer, Manager of Quality Engineering, and Associate Manager, and later, Manager of Reliability and Quality Assurance.
I have also been Chief Engineer at Burnd) Corporation, responsible for supervising production engineering and control and quality control.
I hold a Bachelor of Science degree from the University of Southern California, where I majored in Industrial Management / Engineering.
I am a Registered Professional Engineer in California and a Certified Reliability Engineer by the American Society for Quality Control (ASQC,). I am a Senior Member of the ASQC; Junior Past Chairman of the ASQC Energy Division; Member of the Atcznic Industrial Forum Subccanittee on Quality Apsurance; and Member of the General Requirements Subcomnittee of the ASME Conmittee onNuclear Quality Assurance.
I was selected as ASQC Energy Division QA Person of the Year for 1962, and received the 1983 American Nuclear Society (ANS) Special Award for distinctive quality assurance achievernent in the nuclear energy field.
4248a NAME:
R. D. ETZLER RES FNSE TO INT. 61:
(a) Yes (b) General (c) See attached professional qualifications of R. D. Etzler.
(d) None (e) To be provided during testimony.
(f) i)
Docket i Diablo Canyon Unit il ii)
Case #
OQA Hearing before ASLB (g) i)
Date: July 19-22, 1983 l
11)
Yes iii)
Yes i
iv)
No 4248a........ - -.
PROFESSIONAL QUALIFICATIONS OF RICHARD D. ETZLER My name is Richard D. Etzler.
I am Project Superintendent at Diablo Canyon.
I have held this position since September, 1978.
I am responsible for managing the on-site construction and startup activities at Diablo Canyon.
Prior to my duties as Project Superintendent, I was Resident Mechanical Engineer.
I held that position from March, 1977 to September, 1978. As Resident Mechanical Engineer, I was responsible for managing the mechanical type of construction activities such as installation of piping, ventilation systems, turbine / generator components, and nuclear steam supply system s
i ccznponents.
Prior to my duties as Resident Mechanical Engineer, I was a Field Engineer and Group Imader, reporting to the Mechanical Resident Engineer.
I held this type of position and level of responsibilities from 1971 to 1977. My responsibilities included supervising installation of the nuclear steam supply and turbine generator systems.
l l
Prior to my duties as a Group Leader for the Mechanical Resident Engineer, I was a Startup Field Engineer, beginning in December, 1969. My duties as a Startup Engineer included preparing preoperational startup testing procedures and scheduling tests, l
4248a,
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Prior to my assignment to Diablo Canyon, I was in training to be a Startup Engineer since October, 1968. This training included approximately nine months' startup experience at the Robert E. Ginna nuclear power plant near Rochester, New York, and six weeks' reactor operator training at Westinghouse's Waltz Mill facility near Pittsburg, Pennsylvania.
Prior to October, 1968, I was a Field Engineer at PGandE's Round Mountain 500 kv Substation for three months. Duties included planning construction activities, "as-built" drawings, and assisting in testing components.
My first assignment with PGandE was as a Field Engineer on the construction of the Moss Landing Power Plant Units 6 and 7.
'Ihis assignment started in June, 1967 and continued to July, 1968. My duties included assuring installation of piping systems was in accordance with engineering specifications and drawings.
I graduated from California Polytechnic College, San Luis Obispo, in June, 1967 with a BS degree in Mechanical Engineering.
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4248a...
NAME:
H. B. FRIEtE)
/
RESPONSE ' 0 INT. 61:
(a) Yes (b) General (c) See attached resume.
(d) None te) To be provided during testimony (f) None i
(9) i)
Not Applicable 11)
Not Applicable lii)
Not Applicable iv)
Not Applicable 4248a.i
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PROFESSIONAL QUALIFICATIONS OF HOWARD B. FRIEND EDUCATION:
BS, Mechanical Engineering, Heald Engineering College PROFESSIONAL DATA:
Member, American Society of Mechanical Engineers (Nuclear Power Group) -
Special task force for the design of prestressed concrete containment vessels.
SUMMARY
OF EXPERIENCE:
1 year:
Manager of Projects 2 years: Manager of Division Engineering 5 years: Engineering Manager 2 years: Project Manager i
7 years:
Project Engineer 4 years: Senior Engineer i
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l 4248a EXPERIENCE:
Currently, Mr. Friend is the Completion Manager on Diablo Canyon for PGandE. Mr. Friend was previously Manager of Projects for the San Francisco Power Division. As Project Manager for the South Texas project (two 1250 MW pressurized water reactor (PWR) units), Mr. Friend was responsible for the takeover of engineering, procurement, and construction management, and related services. Takeover activities included reviewing and establishing the status of design, procurement, quality assurance, construction, and related activities; preparation of total cost estimate and schedule; preparation and implementation of a transition program to transfer the responsibilities from he existing engineer and construction manager to Bechtel; preparation of licensing information for the Nuclear Regulatory Comission (NRC); and explanation of the transition program to the NRC, Public Utilities Comission, partners, and other interested parties.
Prior to the above assignment, Mr Triend was the Manager of Division Engineering, responsible for directing all engineering of the San Francisco Power Division, including the design of both fossil-fuel and nuclear power plants. His department was responsible for more than 22 major design l
projects, including development of the Bechtel generic coal-fired power plant.
4248a.. - -.
Previously, as Engineering Manager, Mr. Friend had been responsible for Bowline Point Units 1 and 2 (two 600 W oil-fired units); Skagit Unit 1 (a 1336 W boiling water reactor (BWR) unit); Syncrude utility plant (an approximately 300 W plant that furnishes steam, electricity, and other utilities for the Syncrude Tar Sands project in northern Alberta); and for a power plant that furnishes steam, electricity, and other utilities for the Badak liquid natural gas facility.
Mr. Friend was also Engineering Manager for the Susquehanna' Steam Electric Station Units 1 and 2 (two 1086 E B W units) and for the studies and a task force responsible for analyzing the response of several Mark I and Mark II BRR containment structures to newly identified loading criteria.
Mr. Friend also acted as Project Engineer on other major projects, including Peach Bottom Units 1, 2, and 3 (one 40 W high-tenperture gas reactor, and two 1108 MW BWR units) and Limerick Units 1 and 2 (two 1090 MW BWR units).
Earlier assignments covered a variety of fossil-fired and nuclear power plants in supervisory and technical capabilities and in field assignments.
4248a,
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NAME:
R. C. ANDERSON u--
RESPONSE TO INT. 61:
(.)
Yes (b) General, Statistics and Seismic (c) See attached professional qualifications of R. C. Anderson.
(d) None (e) Tb be provided during the testimony.
(f) i)
Docket i 1.
50-323, 50-275 2.
50-344 3.
50-263 11)
Case #
1.
Diablo Canyon CQA Hearing before the ASLB 2.
Trojan 3.
Monticello 4248a,
{
(g) i)
Date:
1.
July 19-22, 1983 j
2.
ii) iii) iv) 1 J
i i
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1 4248a !
. o PROFESSIONAL QUALIFICATICNS OF RICHARD C. ANDERSON My name is Richard C. Anderson.
I am the Engineering Manager in the Diablo Canyon integrated project organization consisting of Pacific Gas and Electric Canpany and Bechtel Power Corporation employees.
I am a Registered Mechanical and Nuclear Engineer in the State of California.
I hold a BS l
degree in Mechanical Engineering from the University of California at Berkeley.
I have been with Bechtel for more than 24 years and for the past five years have been assigned as an Engineering Manager in Bechtel's San Francisco Division, responsible for all engineering work in the Pacific Northwest and Japan.
I have been assigned since March, 1982, specifically to the Diablo Canyon Project to act as Project Engineering Manager. Prior to these Engineering Manager assignments, I was the Q11ef Nuclear /Envirorsnental Engineer for Bechtel's San Francisco Power Division, involved in nuclear power plant design, safety, and operation.
Prior to that, I was assigned as an Assistant Project Engineer on a proposed nuclear power plant project for PGandE and as Mechanical Supervisor and later Project Engineer on another large nuclear power plant project in the United States. These assignments included supervision and coordination of design, specification, procurement and quality control activities, t
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4248a. - --.
2.
I also served as Senior Mechanical Engineer for various other nuclear power facility projects in the United States and abroad, which included work in systems, safety and equipnent engineering.
I have been an instructor in Bechtel's power plant courses for over 10 years and have given numerous talks and lectures in California on nuclear power and energy issues.
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NAME:
W. H. WHITE RESPONSE E INE. 61:
(a) Yes (b) General, Statistics and Seismic (c)
See attached professional qualifications of W. H. White.
(d)
Inplane Shear Capacity of Reinforced Ccunposite Masonry Block Walls, by W. H. White, W. S. Tseng, Transactions of 6th SMIRT Conference, 1981.
Free Vibration and Buckling of Edge Stiffened Square flates, Ph. D.
'Ihesis.
(e) To be provided during the testimony.
(f) i)
Docket #
1.
50-323, 50-275 2.
50-344 ii)
Case i 1.
Diablo Canyon CQA Hearing 2.
Trojan 4248a.
(9) i)
Date:
1.
July 19-22, 1983 2.
ii) iii) iv 4248a N
l PROFESSIONAL QUALIFICATIONS OF DR. WILLIAM H. WHITE My name is William H. White.
I am an Assistant Project Engineer in the Diablo Canyon integrated organization consisting of Pacific Gas and Electric Company and Bechtel Power Corporation employees. My responsibilities include supervision and direction of seismic-related engineering analyses for the Diablo Canyon Unit 1 Project Engineering Organization.
I am a Registered Professional Engineer and member of the American Society of Civil Engineers.
My educational background ir.cludes:
BS, Civil Engineering, University of Idaho; MS, Civil Engineering, University of Golerado; PhD, Civil Engineering, University of Colorado.
For the past five years, I have been an engineering specialist with Bechtel's San Francisco Power Division working with the Chief Civil Engineer's staff in the area of seismic analysis for several Bechtel projects.
Earlier, I was a Structural Engineer with the Tennessee Valley Authority where I was responsible for seismic analysis of all Category I structures for a twin-unit nuclear power plant, including seismic input for the design of the nuclear steam supply system.
4248a _
9 o.-
I was an Assistant Professor at Oregon State University where I taught undergraduate and graduate courses in structural mechanics and analysis and ccanputer applications.
I performed a special study for Bechtel on soil-structure interaction for the proposed Mendocir.o nuclear power plant while teaching at Oregon State University.
While enployed at the Bettis Atomic Power Laboratory, I was a Senior Engineer working on shock analysis of nuclear reactors aboard sutznarines and was invc'*/ed in programs to assess the shock resistance of reactor internals subjected to long-term irradiation damage, f
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4248a.
1 NAME:
S. M. SKIDMORE i
i RESPONSE 'IO Ilc. 61:
(a) Yes (b) General and Quality Assurance (c) See attached professional qualifications of S. M. Skidmore.
(d) None (e)
'Ib be provided during testimony.
(f) i)
Docket # 50-323, 50-275 11)
Case i Diablo Canyon CQA Hearing 1
(g) i)
Date: July 19-22, 1983 ii) iii) iv) 4248a 24-7
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6 PROFESSIONAL QUALIFICATIONS OF STEVEN M. SKIDMORE
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My name is Steven M. Skidmore.
I have been the Manager of Quality Assurance in the Nuclear Power Generation Department in the Pacific Gas and
[
Electric Company since May, 1983. I am responsible for tne quality assurance of Diablo Canyon Power Plant construction and engineering. Prior to that, I was the Assistant Project Manager to the Diablo Canyon Project, between February, 1982 and May, 1983, where I was responsible for management of the Diablo Canyon Construction Quality Assurance Evaluation, as well as other functions.
Between 1972 and 1982, I was employed by Pacific Gas and Electric Company as an engineer in various capacities, including engineer in the Mechanical and Nuclear Engineering Department, Assistant to the Nuclear Projects Engineer, Technical Assistant to the Vice President of Nuclear Power Generation, and Supervising Personnel and Environmental Safety Engineer.
In these positions, my responsibilities included analyses of reactor physics and fuel cycle evaluations for Diablo Canyon, and the management and coordination of development of the emergency plans for Diablo Canyon.
Between 1967 and 1971, I was employed as a Research Assistant in the Department of Mechanical Engineering at Stanford University, where I was enrolled as a graduate student of nuclear engineering.
- 4248a Between 1962 and 1967, I was e@ loyed by the General Electric Co@ any, both at the Hanford Atomic Products Operations Office and at the Nuclear Energy Division. My responsibilities included engineering work in pile physics, and the analyses of reactor physics for reactor fuel manu#acturers and a plutoniun production laboratory.
I am a Registered Professional Nuclear Engineer in the State of California.
I have a MS degree in Nuclear Engineering from Stanford University in 1969, and a BS degree in Physics from Oregon State University in 1962.
4 i
4248a. -
NAME:
M. J. JACOBSON RESPONSE 'IO INT. 61:
(a) Yes 4
(b) Quality Assurance (c) See Attached professional qualifications of M. J. Jacobson (d) None (e)
'Ib be provided during testimony.
(f) i)
Docket i 1.
50-323, 50-275 2.
50-471 11)
Case #
1.
Diablo Canyon CQA Mini-Hearing 2.
Pilgrim Station Unit 2 Construction Permit Hearing 4248a f
- (9) i)
Date:
'1.
July 20-21,'1983 i
a i
2.
2 1
4 i
a ii) 1.
Yes (Affidavit of Warren A. Raymond, et al, July 2, 1
1982) i i-4 2.
No i
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Yes s
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2.
No Q i,
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PROFESSIONAL QUALIFICATIONS OF MICHAEL J. JACDBSON My name is Michael J. Jacobson..I am the Project Quality Assurance (QA)
Engineer for the Diablo Canyon Project consisting of the integrated organization of Bechtel Power Corporation and Pacific Gas and Electric Company.
I am a Registered Professional Quality Engineer in the State of
~
My educational background is as follows: BS in Civil Engineering, Sacramento State Oo11ege,--1970: Business Management Certificate in Management, Golden Gate University, 1979.
o I joined Bechtel Power Corporation in^1970.as a Quality Assurance Engineer
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responsible for various aspects of design phase quality assurance on a nuclear power plant project. I was subsequently responsible for performing structural design and seismic analysis activities on the project. Later, I was assigned as Project Quality Assurance Engineer responsible for supervising project QA activities, including direction of quality audits of construction activities.
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subsequently, I was assigned Project QA Engineer on various other nuclear power plants, where I was responsible for directing project QA programs.
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.was responsible for ensuring that project construction and site activities, as well as quality control aspects, met applicable QA and regulatory requirements.
I was assigned to the Diablo Canyon project in 1982 to direct and control the QA program for this project.
4248a.
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,/
NAME:
C. W. DICK RESPONSE 'IO Ilff. 61:
(a)
Yes s
(b) ObalityAssurance
.(c) See attached professional qualifications of C. W. Dick.
.a k-g (d)
Paper on Design Control Requirements (ANSI N45.2.ll) pesented at the Nuclear Quality Assurance Seminar, Knoxville, Tenn. on Maren 9, 1978.
(e)
'Ib be provided during testimony.
B (f) i)'
Docket i 50-323, 50-275 5
11)
Case i Diablo Canyon CQA Hearing (g) i)
Date: July 19-22, 1983 l
l-ii) iii)
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iv)
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PROFESSIONAL QUALIFICATIOfLS OF CHARLES W. DICK My name is Charles W. Dick.
I am a Project Manager and a member of the project management team of the Diablo Canyon Project consisting of the integrated organization of Bechtel Power Corporation and Pacific Gas and Electric Conpany, and with responsibilities which include quality assurance.
I am a Licensed Professional Engineer in the states of California, New York, and Pennsylvania.
My educational background is as follows: BS in Electrical Engineering, California Institute of Technology, 1946; MS in Electrical Engineering, Stanford University, 1948.
I have also had additional training through Advanced Engineering Programs in Business Administration and from various technical and business courses.
Prior to my recent assignment to the Diablo Canyon Project, I was Manager of Division Quality Assurance Division at the Bechtel Power Corporation from 1980 to 1982. My responsibilities included formulating the QA programs for 1
inplementing such programs, and training QA personnel for some 14 nuclear projects.
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4248a !
- o I joined Bechtel Power Corporation in 1965 and worked as a Project Engineer'on various nuclear and fossil-fuel projects.
I was responsible for project engineering work for a number of different types of power projects and studies, for nuclear standards development and for licensing. Beginning in 1973, I became an Engineering Manager and subsequently Manager of Engineering, with overall management responsibility for the project engineering work on more than 20 power plant projects.
Prior to my employment at Bechtel, I was engaged as an engineer with the General Electric Conpany beginning in 1948.
During that time, I was involved in marketing and application engineering related to nuclear power facilities.
Prior to that I was assigned as an electric utility g>plications engineer and provided consultation services involving heavy electrical apparatus.
I am a senior member of IEEE and a member of the American Society for Quality Control.
I was also a member of the industry working group for development of ANSI Standard N45.2.ll (Quality Assurance Standards for Design of Nuclear Power Plants).
4248a NAME:
G. H. MOORE RESPONSE TO INT 61:
(a) Yes (b) General, Statistics and Seismic (c) See attached professional qualifications of G. H. Moore.
(d)
(e) ib be provided during the testimony.
-(f) i)
Docket # 50-323, 50-275
.ii)
Case i Diablo Canyon CQA Hearing (g) i)
Date: July 19-22, 1983 ii) iii) iv) 4
- 4248a,,
PROFESSIONAL QUALIFICATIONS OF GARY H. MOORE i
My name is Gary H. Moore.
I am the Unit 1 Project Engineer of the Diablo Canyon Project consisting of the integrated organization of Pacific Gas and Electric Company and Bechtel Power Corporation.
I have held this position since January, 1982.
I am responsible for the project engineering work related to the design and analysis of Diablo Canyon Power Plant Unit 1.
I am a Registered Professional Engineer in Mechanical and Control Systems in the State of California.
My educational background is as follows: BS in Mechanical Engineering, s
San Jose State University, 1968; MS in Mechanical Engineering, Saif Jose State University, 1969.
I joined PGand E in 1969 as a Mechanical Engineer in the Mechanical and Nuclear Engineering Department, designing instrumentation and control (I&C) systens for conventional fossil plants.
In 1977, I was named a Senior Mechanical Engineer supervising the I&C Group assigned to the Potrero Unit 7 Project.
In 1979, I was named Supervising Mechanical Engineer, supervising the Mechanical and Nuclear Engineering Department's entire I&C Group, including responsibility for the IEC design of the Diablo Canyon Power Plant.
4248a -.
I have coupleted the following formal training courses: Simulator Training, Westinghouse Nuclear Training Center, Zion, Illinois; Westinghouse PWR Information Course.
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I 4248a -- -
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NAME:
DR. S. KAPLAN RESPONSE 'ID INI. 61:
(a) Yes (b) Statistics (c) See attached professional qualifications of Dr. S. Kaplan.
(d) See attached list of publications.
(e)
'Ib be provided during the testimony.
(f) i)
Docket i 11)
Case #
l (g) i)
Date:
ii) lii) iv 4248a _-. _ _.
I PROFESSIONAL QUALIFICATIONS OF DR. STANLEY KAPLAN EDUCATION:
Senior Post-Doctoral Fellowship, University of Southern California, 1967-1969.
Ph.D., Mechanical Engineering and Applied Mathematics, University of Pittsburgh, 1960. Post-doctoral courses in mathenatics at the University of Pittsburgh and Carnegie Institute of Technology, 1960-1965.
M.S., Mechanical Engineering, University of Pittsburgh, 1958.
Graduate of the Oak Ridge School of Reactor Technology, 1955.
B.S., Civil Engineering, City College of New York, 1954.
PROFESSIONAL EXPERIEtCE:
General Summary Mathematician and engineer well known for contributions to risk analysis and reliability theory, reactor physics, kinetics, and conputational 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 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 drill (environmental risk), underground oil storage, pipelines, and tarsands 4248a --
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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 h eory of Event Trees and DPD approach to seismic risk analysis.
Chronological Sungnary 1977 - Present President, Kaplan & Associates, Inc., a consulting firm specializing in risk analysis and applied decision theory.
Concurrently Adjunct Professor, Department of Chemical, Nuclear and 'Ihermal Engineering, University of California, Los Angeles, and Associate Consultant, Pickard, Iowe and Garrick, Inc.
1975-1977 Private consultant specializing in risk analysis and decision theory.
1972-1975 Holmes & Narver, Inc., Anaheim, California l
Director, Advanced Technology Division; Director, Systems Sciences Division l
l Technical Director, Nuclear & Systems Science Group l
1971-1972 Director of Software Development, COMARC Design Systems, l
1 Inc., San Francisco, California, i
I 4248a 1
1969-1971 Product Manager and Senior Staff Member, Computer Sciences Corporation, Iras Angeles, California.
1967-1969 Special Research Fellow, U.S. Mblic 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.
1962-1967 Concurrently Adjunct Professor of Mechanical Engineering, University of Pittsburgh; Lecturer, Department of Mathematics, Carnegie Institute of Technology.
MEMEERSHIPS, PAST OR PRESENT:
American Society of Civil Engineers American Nuclear Society Society of Industrial and Applied Mathematics New York Academy of Sciences 4248a l
LIST OF PUBLICATIONS OF DR. STANLEY KAPLAN Kaplan, S., "On a 'Two-Stage' Bayesian Procedure for Determining Failure Rates from Experiential Data," PLG-0191, IEEE Transactions on Power Apparatus and Systems, Vol PAS-102, No.1, January 1983.
I Garrick, B.
J., and S. Kaplan, Chapter 2.7, " Electric Power," High Risk Safety Technology, A.E. Green, Editory, John Wiley & Sons, Ltd., 1982.
Kaplan, S., "On Safety Goals and Related Questions," Reliability Engineering, 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. Bieniarz, "On the Use of Bayes' Theorem in Assessing the Frequency of Anticipated Transients," Nuclear Engineering and Design, Vol. 065, ISS., 23-32 (1981).
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Kaplan, S., "On the !!ethod of Discrete Probability Distributions in Risk and Reliability Calculations - Application to Seismic Risk Assessment,"
Risk Analysis, Vol. I, No. 3, September 1981.
Kaplan, S., and B. J. Garrick, "On the Quantitative Definition of Risk,"
Risk Analysis, 1, 1, May 1981.
Apostolakis, G., and S. Kaplan, " Pitfalls of Risk Calculations,"
Reliability Engineering, 2_, 2, 135-145, April 1981.
Kaplan, S., B. J. Garrick, and G. Apostolakis, " Advances in Quantitative Risk Assessment - The Maturing'of a Discipline," IEEE Transactions on Nuclear Science, NS-28, No.1, February 1981.
Kaplan, S., and B. J. Garrick, "Some Misconceptions 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, March 1980.
Kaplan, S., and B. J. Garrick, "On the Use of Bayesian Reasoning in l
Safety and Reliability Decisions - Three Examples," Nuclear Technology, H,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.
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- Kaplan, S., "On a Probabilistic Approach to Project Cost Estimating,"
Consulting Engineer, February 1976.
Garrick, B. J., and S. Kaplan, " Reliability Technology and Nuclear Power," IEEE Transactions on Reliability, Saecial Issue on Nuclear Systems Reliability and Safety, Vol. R-25, No. 3, August 1976.
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Kaplan, S., "On a Bayesian Type Methodology for 11aking Accept / Reject Decisions on Offshore i. ease Bids," Journal of Petroleum Technology, March 1976.
Kaplan, S., and D. Trujillo, " Numerical Studies of the Partial Differential Equations Governing Nerve Impulse Conduction-I, the Significance of Lieber! stein's Inductance Term," Journal of Mathematical Biosciences, 7,, 379-404 (1970).
Kaplan, S., " Variational Methods in Nuclear Engineering," Advances _in Nuclear Science and Technology, Vol. V, P. R. Greebler, editor, Academic Press (1969).
Kaplan, S., A. J. McNabb, J. K. Siemsen, and 0. Trujillo, "The Inverse Problem of Radioisotope Diagnosis - A Computational Model for Determining the Size and Location 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, 31, 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," Nuclear Science and Engineering, 31_, 2, 354 (1968).
Kaplan, S., A. J. McNabb, and M. B. Wolf, " Input-Output Relations for a Counter Current Dialyzer by the liethod of Invariant Imbedding," Journal l
of Mathematical Biosciences, 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 l-the Variational Principles of Transport Theo:y," Nuclear Science and Engineering, 28, 2, 166-176 (1967).
Kaplan, S., J. A. Davis, and M. Natelson, " Space-Angle Synthesis - An l
, Approach to Transport Approximations," Nuclear Science and Engineering, 28,364-375,(1967).
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Kaplan, S., " Properties of the Relaxation Lengths in P1-Double-P1 and Angle-Space Synthesis Type Approximations," Nuclear Science and i
Engineering, 2_8,, 450-463 (1967).
8 Kaplan, S., and J. B. Yasinsky, " Natural Modes of the Xenon Problem with Flow Feedback - An Example," Nuclear Science and Engineering, 25, 430-438 (1966).
1-Gelbard, E. M., and S. Kaplan, " Reality of Relaxation Lengths in Various 4
Approximate Forms of the Slab Transport Equation," Nuclear Science and Engineering, 26, 4, 569 (1966).
- Kaplan, S., " Synthesis Methods in Reactor Theory," Advances in Nuclear Science, Vol.111, Academic Press, June 1966.
i Kaplan, S., "An Analogy Between the Variational Principles of Reactor Theory and Those of Classical Mechanics," Nuclear Science and Engineering, 2_3_, 3, 234 (1965).
Kaplan, S., E. M. Gelbard, " Invariant Imbedding and the Integration s
Techniques of Reactor Theory," Journal of Mathematical Analysis and '
Applications, H, No. 1-3, 538-547, (1965).
Henry, A. F., and S. Kaplan, "Some Applications of a Multimode Generalization of the Inhour Fonnula," Nuclear Science and Engineering, E,4,479-486,(1965).
Kaplan, S., O. J. Marlowe, and'J. A. Bewick, " Application of Synthesis Techniques to Problems Involving Time Dependence," Nuclear Science and i
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 of Atomic Energy, Geneva (196A).
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'Kaplan, S., "Some New Methods of Flux Synthesis," Nuclear Science and
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Engineering, 13,, 1, 22-31 (1962).
Kaplan, S., "The Property of Finality and the Analysis of Problems in Reactor Space-Time Kinetics by Yarious Model Expansions," Nuclear Science and Engineering, 9_, 3, 375 (1961).
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s 4 e-Kaplan, S., and G.'Sonnemann, "The Methods of Finite Integral Transforms in Heat Transfer Problems," Fenceedings of the International Heat Transfer Conference, Boulder 3olorado (1961).
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Kaplan, S., and S. G. Margolis, " Delayed Neutron Effects During Flux Tilt Transients," Nuclear Science and Engineering, 7_, 3, 276 (1960).
Kaplan, S., and G. Sonnemann, "A Generalization of the Finite Integral Transform Technique and Tables of Special Cases," Proceedings of Mid-Western Conference on Solid and Fluid Mechanics, Austin, Texas (1959).
3 Goldsmith, 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 United Nations International Conference on the Peaceful Uses of Atomic Energy, Pager P/2376 (1958).
REPORTS 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 Ass 9ssment," 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 Decision 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.
l Bley, D. C., S. Kaplan, and B. J. Garrick, " Assembling and Decomposing PRA Results: A Matrix Formalisu," presented at the International Meeting on Thermal 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.
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" 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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Lin, J. C., and S. Kaplan, "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 Risk 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.
Kaplan, S., G. Apostolakis, B. J. Garrick, D. C. Bley, and K. Woodard,
" 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 Intemountain 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.
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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, l-Methods of Analysis - Program Planning - Applications," 2 Yols.,
PLG-0148. October 1980.
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, 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.
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Garrick, B. J., S. Kaplan, G. Apostolakis, D. C. Iden, K. Woodard, and T. E. Potter, " Seminar: Probabilistic Risk Assessment of Nuclear Power P1 ants " 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.
Garrick, B. J., and S. Kaplan, "A Conceptual Plan for a National Data System for Electric Power Plants," PLG-0131, April 1980.
Garrick, B. J., and -S. Kaplan, "0yster Creek Probabilistic Safety Anal-ysis (OPSA)," 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. Garrick, 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, B. J., S. Kaplan, P. P. Bieniarz, 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 Battelle Northwest Laboratory, June 1979.
Garrick, B. J., P. P. Bieniarz, and S. Kaplan, " Risk Analysis of Transporting Oconee Spent Nuclear Fuel to the McGuire 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 Industry, Proceedings, Miami Beach, Florida, April 19-20,1979.
7
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Kaplan, S., J. M. Vallance, and C. L. Cate, " Prediction of Fraquency 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 P. elates to Uranium Procurenient 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. Baldonado, "On a Decison Theory Formalism for Nuclear Power Plant Siting," presented to the Conference on
' Unique Siting Concepts for Nuclear Power Plants, Joint Connittee on l
Atomic Development and Space, Sacramento, California, May 9,1972.
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NAME:
TfiOMAS G. DeURIARTE RESPONSE TO INT. 61:
(a) Yes (b) Quality Assurance-(c) See attached Professional Qualifications of T. G. DeUriarte (d) None (e) To be provided at the time of the testimony.
(f) None (9) i)
Not applicable ii)
Not applicable lii)
Not applicable iv)
Not applicable 4248a..
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Rtzume T. G. de Uriarte, Senior Engineer Quality Assurance Department Pacific Gas and Electric Company 77 Beale St., San Francisco, California 94106 EDUCATION B.S. Civil Engineering, University of California, Berkeley,1967 PROFESSIONAL REGISTRATION Certificate No. 25196, Civil Engineering, California Certificate No. 874, Quality Engineering, California EXPERIENCE 7/67 TO PRESENT:
Pacific Gas and Electric Company, 77 Beale St.,
San Francisco, CA 94106 7/77 TO PRESENT:
Senior Engineer, Quality Assurance Department Primary responsibilities include:
(a) administration of audit program, schedule audits and assign personnel to perform audits of Company and Supplier activities to verify compli-ance with applicable Nuclear Regulatory Commission regulations and other requirements such as nuclear industry guides and standards, and corporate procedures and specifications.
(b) supervision of department personnel for the timely completion of special projects.
(c) supervision of departmental participation in review of discrepancies.
(d) supervision of development of departmental training program.
(e) participation in licensing hearings as QA department representative.
2/72 to 7/77:
Engineer, Quality Assurance Department.
Primary responsibilities were to (a) perform audits of Company and Supplier activities; (b) develop procedures for the corporate quality program; (c) review and approve, if appropriate, suppliers quality assurance / control l
programs; (d) develop the corporate specifications for suppliers quality assurance programs; (e) provide interface with regional NRC inspectors.
4/70 to 2/72:
Scheduling Engineer, Station Construction Department at Pittsburg Power Plant.
Primary responsibilities were to (a) develop, layout, and maintain overall project schedule and schedules for the various contractors and the various systems; (b) analyze layouts and budgeting for future plant sites; (c) investigate equipment delivery dates and forecast the consequences of delays to the project schedule; (d) prepare weekly and bi-monthly progress reports; (e) initiate and process claims against contractors, carriers, and suppliers.
.' 10/68 to 4/70:
Field Engineer, Civil Department at Pittsburg Power Plant.
Primary responsibilities were to (a) perform field inspection of specific contracts; (b) provide office supervision of specific contracts; (c) estimate quantities for contract administration; (d) verify contractors' billings for unit price and cost plus change orders; (e) analyze job progress and provide suggestions for improvements; (f) participate in Company program for safety, first aid, and jobsite surveillance of safety infractions.
The above duties were performed for pile driving, subfoundations and foundations, underground piping systems, structural steel erection, and superstructure erection.
7/67 to 10/68:
Field Engineer, Substation Construction. General Construction Department.
Primary responsibilities were to (a) supervise contractors in excavating, grading, fencing, and surfacing Company substations; (b) provide job progress reports; (c) perform surveying for verification of property lines and acceptance of final grades; (d) perform drafting, job layouts, and quantity takeoffs for job estimates.
SOCIETIES American Society for Quality Control; American Society for Nondestructive Testing; California Association of Professional Engineers.
--i.-r vm
Name:
L.E. SHIPLEY Position:
Assistant Chief Engineer (Plant Design)
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Technical Consultant to Diablo Canyon Education:
BS, Mechanical Engineering, US Merchant Marine Academy, Kings Point, NY Professional Data:
o Registered Professional Mechanical Engineer in California o Member of ASME o Member of ASME/ ANSI Task Force t.o Define Vibration Monitoring Requirements for Piping (Past) o Member ANS Committee for Protection Against Postu-laced Effects of Pipe Rupture.
Member of Industry Advisory Committee to a DOE pro-o gram for Structural Energy Absorbing Restrainers.
o Chairman on several ASME Technical Sessions at the ASME Piping and Pressure Vessel Conferences.
Su==ary:
o Present - Assistant Chief Engineer 1 year Technical Consultant to Diablo Canyon o
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o 1 years Assistant Project Engineer (Nuclear Plant) 4 years Supervisor of Piping Stress Analysis for o
San Francisco Power Division.
o 9 years various positions of increasing responsi-bility in Engineering o 2 years Engineering Officer, U3 Merchant Marines.
Experience:
Mr. Shipley has recently assumed the position of Assis-tant Chief Engineer for Plant Design in the San Francisco Power Division. The scope of responsibility i
of-the Chief's office requires technical direction of L
over 900 professional engineers and draf tsmen working on 15 projects worldwide.
Scope of services includes equipment location, piping-layout, piping stress analy-sis, pipe support design, material specification, welding and NDE.
Projects include nuclear, fossil and co-generation power plants. He is the chairman of an interdivisional technical steering committee for com-puter program applications.
In addition, he is the corporate sponsor for over 10 computer programs includ-ing the most widely used piping program.
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Experience For over a year, Mr. Shipley has been assigned to the (continued):
Diablo Canyon Nuclear Power Plant in San Luis Obispo, Ca. as a Technical Consultant to the piping program.
i He was instrumental in the development and review of the Corrective Action Program whose intent was to re-view all piping systems to licensing commitments and newly developed seismic criteria. During the course of the assignment, constant communication was required with the independent verification team and the con-struction forces at the jobsite.
Previously, he was Assistant Project Engineer on the Susquehanna Stems Electric Station in Berwick, Pennsylvania for th yrs. He was responsible for en-gineering in the civil-structural, architectural and piping / plant design areas. He directed the efforts of 350 engineers and draf tsmen in a variety of engineering tasks including:
structural analysis review of all seismic category o
1 buildings.
o Preparation of as-built response spectra curves.
o Piping / Stress analysis and pipe support design.
o Valve Qualification o Material Specification o Welding and NDE Ine final 2 months before fuel-load were spent at the jobsite coordinating the final as-built reconciliation for pipe hangers. This phase of the work required extensive construction / engineering interface for which l
he was the focal point. The job responsibilities also included budget, schedule and =anpower planning as-pects.
Technical direction was given in the areas of stress analysis, pipe support design, materials selection and qualification, valve qualification, welding and NDE.
Previously, Mr. Shipley worked in' the field of piping stress analysis for 13h years and was responsible for technical direction and personnel administration of 150 engineers and technicians.
Projects under his supervision include nuclear and fossil power plants, i
l as well as liquid-metal fast breeder plants.
i i
Experience Re has been directly involved in the design of the fol-(continued):
loving nuclear plants: Monticello, Pilgrim 1, Peach Bottom, and Duand Arnold. He has had supervisory re-
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sponsibilities for Arkansas Units 1 and 2, and Trojan, Limerick,1 & 2, Susquehanna,1 & 2, Pilgrim 2, Skagit.
Fossil plants include: Jim Bridger and Colstrip.
FFIF was the breeder plant.
Mr. Shipley was responsible for the dynamic analysis of piping as it relates to abnormal events, such as pipe rupture and building response to dynamic loads. Analy-sis includes 'uoth linear and non-linear, as well as elasto-plastic evaluations using time history and direct integration computer codes.. Mr. Shipley was also re-sponsible for ASME - required stress reports including life cycle evaluation of thermal transients as well as other cyclic phenomenon.
He was responsible for the analysis of piping on fossil projects, including cold springing of the major piping systems.
Corporate Standards and Guides were written under his supervision.
Mr. Shipley has visited all of the jobsites mentioned above, primarily in a trouble-shooting capacity, and has conducted the pipe support field review on Monti-cello.
He was responsible for the Bechtel Topical
- report,
" Seismic Analysis of Piping Systems." He has served on ASME Annual Meetings for Pressure Vessels and Piping as a session chairman for seismic analysis of piping and equipment.
Ee has testified at several hearings on various piping issues.
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Date of Testimony 7 TeoTAW sets. WeuAwArled fg._79
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Do you have a copy of the transcript of the witness's exa.aination or cros --examination?
XJO 5.
Do you have any notes for the preparation of the testicony?
Do 6.
Provide the document references you will rely on to reach any opinion l
testimony and specifically correlate ea;h document (by page and paragraph number) to each specific subject matter.
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THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 51 and 52 Said answers are true and correct to the best of my knowledge and belief.
5 Edward C.
Connell', TI Subscribed and sworn to before me this 19th day of September, 1983.
smannemuunnwanunnuninmannimme l @ NOI'RY P'J3LIC C. T. NEAL MADISON i
l Cl*Y AND COUNTY OF l
SAN FRANCISCO 3L.
b G [~ - M/M g""'"""""My Commission Empires On. 27,1985 C. T. Neal Madison, Notary Public in and for the City and County of San Francisco, State of California My Commission expires December 27, 1985
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. 4 THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 47, 48, 49, and 50 Said answers are true and correct to the best of my knowledge and belief.
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Peter F. Mason s
Subscribed and sworn to before me this 19th day of September, 1983.
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C. T. NEAL MADISON i
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My comminion hpim pec. 27,1985 g mununmemuumuuuuuummmuuuumne C. T. Neal Madison, Notary Public in and for the City and County of San Francisco, State of California s
My Commission expires December 27, 1985
THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 5,
6, 15, 16, 41, 42, 53, 54, 61, and 62 Said answers are true and correct to the best of my knowledge and belief.
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Richard C. Anderson Subscribed and sworn _to before me this 19th day of September, 1983.
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NOT/R'l PTJ.iC - CALIFORNIA I g
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WN2/fg My Comminion he Du Emsunununusunnununnunun. 27,it:5 unensuu a C. T. Neal Madison, Notary Public in and for the City and County of San Francisco, State of California My Commission expires December 27, 1985
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r THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to
-Interrogatories 1, 2,
3, 4,
7, 8,
9, 10, 11, 12, 13, 14, 17, 18, 19, 20, 57, 58, 59, and 60.
Said answers are true and correct to the best of my knowledge and belief.
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Dan G.
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/ Subscribed.and sworn to
,before me this 19th day of September, 19P3.
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NOPRY P'JT.lc -CAUFORNIA E ct;i M40 COUNTY OE I
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My Commission Empires On. 2T,1985 enesusanmuunna -
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Y My Commission expires December 27, 1985
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THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 33, 34.
35, 36, 37 38, 39, 40, 43, 44, 45, and 46.
Said answers are true and, correct to the best of my knowledge and belief.
y Bimal Sarkar Subscribed and sworn to before me this 19th day of September, 1983.
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C. T. PIEAL MADISON
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T. Neal Madison, Notary Public in and for the City and County of San Francisco, State of California My Commission expires December 27, 1985 l
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T!!IRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 55, 56, and 61 Said answers are true and correct to the best of my knowledge and belief.
W isebasA S. S e d m Michae1~'J. J&cobson Subscribed and sworn to before me this 19th day of September, 1983.
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..i C. T. NEAL MADISON
@ N37."!? 'MUC -CAUF Clh A.C COUNTY OF ghg SAN FRANCISCO Mr C==* rw tw. n, itss C.
T. Neal Madison, Notary Public in and for the City and County of San Francisco, State of California My Commission expires December 27, 1985 e
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THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 31, 12. a n ci g1 Said answers are true and correct to the best of my knowledge and belief.
hlme cm ry H. Moore Subscribed and sworn to before me this 19th day of September, 1983.
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. NOT3.T! :"C'JC - CAUFORNIA Clie AND COUNTY OF
,f fkYlfm SAN FRAT!CISCO Enmanonummunmmuneenasen. 27,1983 Mr Comnussion Espires Da C. T. Neal Madison, Notary Public ismumm.a.
in and for the City and County of San Francisco, State of California My Commission expires December 27, 1985
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.I THIRD SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN I have assisted in preparing the answers to Interrogatories 49 and 50 Said answers are true and correct to the best of my knowledge and belief.
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Han MG. 50mmer Subscribed and sworn to before me this 19th day of September, 1983.
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C. T. Neal Madison, Notary Public in and for the City and County of San Francisco, State of California My Commission expires December 27, 1985
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,e In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
)
Docket No. 50-275
)
Docket No. 50-323 Dichlo Canyon Nuclear Power Plant, )
)
Units 1 and 2
)
CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (hove) been served today on the following by deposit in the United States coil, 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 W2chington 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.
W3chington 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 Detsy Umhoffer 1493 Southwood Arthur C. Gehr, Esq.
Scn Luis Obispo CA 93401 Snell & Wilmer 3100 Valley Bank Center Jcnice E. Kerr, Esq.
Phoenix AZ 85073 Public Utilities Commission State of California Bruce Norton, Esq.
5246 State Building Norton, Burke, Berry & French, P.C.
i 350 McAllister Street P. O. Box 10569 San Francisco CA 94102 Phoenix AZ 85064 Mro. Raye Fleming Chairman 1920 Mattie Road Atomic Safety and Licensing Shall Beach CA 93449 Board Panel US Nuclear. Regulatory Commission Mr. Frederick Eissler Washington DC 20555 Scanic shoreline Preservation Ccnference, Inc.
4623 More Mesa Drive Santa Barbara CA 93105
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F Choirman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Wachington DC 20555 US Nuclear Regulatory Commission.
Washington DC 20555 S cretary US Nuclear Regulatory Commission Judge W. Reed Johnson W3chington DC 20555 Atomic Safety and Licensing Appeal Board Attn:
Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555 L wrence J. Chandler, Esq.
Judge John H. Buck H:nry J. McGurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission Washington DC 20555 Washingtot 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.
S n Jose CA 95125 3580 Wilshire Blvd.
Suite 800 Los Angeles CA 90010 Mr. Carl Neiberger Talcgram Tribune Maurice Axelrad, Esq.
P. O.
Box 112 Lowenstein, Newman, Reis, and Srn Luis Obispo CA 93402 Axelrad, P.C.
1025 Connecticut Ave NW Washington DC 20036 Dat0: September 19, 1983
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s' Dan G7 Lubbock
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