ML20079Q174
| ML20079Q174 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/06/1983 |
| From: | Reynolds J, Strumwasser M CALIFORNIA, STATE OF, JOINT INTERVENORS - DIABLO CANYON |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8305110383 | |
| Download: ML20079Q174 (26) | |
Text
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.N UNITED STATES OF AMERTCA NUCLEAR REGULATORY .C IS93ON (%
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BEFORE THE ATOMIC SAFETY AND LICENSING EAL RD
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In the Matter of ) n'~ '
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PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
FIRST SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY BY GOVERNOR DEUKMEJIAN AND JOINT INTERVENORS Governor George Deukmejian and Joint Intervenorsl/
hereby propound to applicant Pacific Gas and Electric Company (PG&E) this First Set of Interrogatories, to be answered under oath within fourteen days, pursuant to 10 C.F.R. section 2.740b.
INSTRUCTIONS A. Where you have incomplete information that precludes your fully answering an interrogatory, give such information as you have and state what information you do not have. If you are unable to give the information in the form sought but have the information aggregated differently, give the information in the form in which you have it and explain.
B. When asked in the interrogatories below to 408 88' oo 1/ Joint Intervenors are San Luis Obispo Mothers for
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{ g Action Club, Sandra Silver, Gordon Silver, Elizabeth Apfelberg, gg and John J . Forster.
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identify or to give the identity of a person, please give the following information about him or her:
- 1. full name;
- 2. present job title and employer; C. When asked in the interrogatories below to identify or to give the identity of a document, please give the following information about the document:
- 1. its title, if any;
- 2. its nature (e.g., letter, memorandum, chart, computer printout, ledger);
- 3. the date, if any, stated on the document;
- 4. the identity of each person who signed it;
- 5. the identity of each person to whom it is addressed.
D. As used herein, the singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun so used, and vice verso, similarly, the use of the masculine form of a pronoun shall be considered to include also within its meaning the feminine form of the pronoun so used, and vice versa; and in a similar fashion any tense of any verb used herein shall be considered also to include within its meaning all other tenses of the verb so used.
E. The use of the word "or" is the inclusive form of that conjunction, implicitly including within its meaning the word "and."
F. Should you have any questions regarding the 2.
meaning of any term or interpretation of any interrogatory, you are encouraged to consult with counsel regarding such questions.
DEFINITIONS (1) " Analysis" means analysis, methodology, model, compu tation, run of a computer model, study, and review.
(2) "Bechtel" means the Bechtel Power Corporation.
(3) " Computer model" means a program used with a digital computer to predict, estimate, evaluate, or assess selected a t tr ibu te s, including behavior, of a physical process or entity.
(4) " Data collection" means the gathering of information for analysis, including physical testing, measurement, sampling, and extraction of information from documents.
(5) "Diablo Canyon" means units 1 and 2 of the Diablo Canyon Nuclear Power Plant, including all structures, systems, and components at the site.
(6) "Diablo Canyon Project" (DCP) means PG&E, Bechtel, all joint projects of PG&E and Bechtel concerning Diablo Canyon, and all contractors, subcontractors, consultants, and agents of the foregoing, excluding the IDVP.
(7) " Document" means any and all things that constitute
" writings" pursuant to rule 1001 of the Federal Rules of Evidence.
, (8) " Document control" means the process of maintaining an inventory of documents, the process of maintaining a summary of documents, the process of determining a document's circulation, 4, the process of determining access to a document, and the j process of filing, storing, or disposing of a document or a i 3.
i
record pertaining thereto.
, (9) " Documentation" means the process of writing or otherwise producing documents and document control.
(10) " Independent Design Verification Program" (IDVP) means the program established by the November 19, 1981, order of the Nuclear Regulatory Commission (NRC), the Ncvember 19, 1981, letter from Harold Denton to Malcolm Furbush, and implementing directives of the NRC staff, as that program may have been modified since that date.
(11) " Interim Technical Report" (ITR) means a report in the l series of Interim Technical Reports by the IDVP.
i '
(12) " Person" includes natural persons, corporations, partnerships, other business entities, and public agencies.
(13) "PGLE" means the Pacific Gas and Electric Company and its agents, employees, contractors, subcontractors, af filiates, departments, divisions, units, subunits, and attorneys, 1 including the IDVP.
(14) " Reassessment" means analysis, engineering, and
- modification of design performed since the record last closed
- in this docket.
(15) " Report" means a document describing an analysis, results, or both.
(16) "Results" means the interpretation of an analysis and the conclusions, determinations, and recommendations of an i
analysis.
I (17) "You" and "your" refer to PG&E.
4.
INTERROGATORIES
- 1. With respect to each ITR, including all revisions, except ITR 36 and ITR 38, state:
(a) What contractors and subcontractors to the IDVP worked on the ITR.
(b) The person employed or retained by the IDVP or its subcontractors most knowledgeable about the ITR.
s (c) The person employed or retained by the IDVP or its subcontractors most knowledgeable about:
(i) data collection for the ITR; (ii) analyses performed for the ITR; (iii) the conclusions of the ITR; (iv) documentation of the ITR.
(d) What reports the IDVP received from the DCP in connection with the ITR and, with respect to each, whether the IDVP relied upon it.
- (e) In categorical terms, what other information the l IDVP received from the DCP in connection with the ITR, and, with respect to each category
(i) whether the IDVP independently verified the information received; (ii) if it did, how it verified the information.
(f) What computer models were employed in performing analyses in connection with the ITR, stating as to each:
l i
(i) If the model was obtained from an outside 1
- source,
- the identity of that source, l
5.
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- the name or names by which the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer prog ram) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the ITR; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the nodel,
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model, 6.
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- the manuf acturer and model number of the computer or computers on which the computer model was run in connection with the ITR.
- 2. With respect to the reassessment of the containment building of Diablo Canyon unit 1, state:
(a) What contractors and subcontractors to the DCP
, worked on the reassessment.
4 l
i (b) The person employed or retained by the DCP or its subcontractors most knowledgeable about the reassessment. ,
< (c) The person employed or retained by the DCP or its subcontractors most knowledgeable about:
(i) data collection for the reassessment; (ii) analyses performed for the reassessment; (iii) conclusions of the DCP in connection with the reassessment; (iv) documentation of the reassessment.
(d) What computer models were employed in performing analyses in connection with the reassessment, stating as to
- each
f (i) If the model was obtained from an outside source,
- the identity of that source,
- the name or names by which the model is known, l - the general function of the model, i
i
- whether the model was received in source code or object code, I 7.
i L.-.._.-__.--.. _ _ _ _ _ _ . _ - . . _ . _ . . . _ _ . _ _ . . _ . ,
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i. e. , the computer prog ram) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the nodel,
- the name or names by which the model is known,
- the general function of the model, l
1 - the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model, i
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment.
4 8.
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- 3. With respect to the reassessment of the containment building of Diablo Canyon unit 2, state:
(a) What contrac tors and subcontractors to the DCP worked on the reassessment.
(b) The person employed or retained by the DCP or its subcontractors most knowledgeable about the reassessment.
(c) The person employed or retained by the DCP or its subcontractors most knowledgeable about:
(i) data collection for the reassessment; (ii) analyses performed for the reassessment; (iii) conclusions of the DCP in connection with the reassessment; (iv) documentation of the reassessment.
(d) What computer models were employed in performing analyses in connection with the reassessment, stating as to each:
(i) If the model was obtained from an outside source, l
- the identity of that source,
- the name or names by which the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification, 9.
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- whether the model (i.e., the computer program) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) af ter receipt and, if so, the nature of all such modifications, 1
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the model,
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment.
- 4. With respect to the reassessment of the fuel handling building of Diablo Canyon, state:
(a) What contractors and subcontractors to the DCP worked on the reassessment.
10.
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(b) The person employed or retained by the DCP or its subcontractors most knowledgeable about the reassessment.
(c) The person employed or retained by the DCP or its subcontractors most knowledgeable about:
(i) data collection for the reassessment; (ii) analyses performed for the reassessment; (iii) conclusions of the DCP in connection with the reassessment; (iv) documentation of the reassessment.
(d) What computer models were employed in performing analyses in connection with the reassessment, stating as to each:
(i) If the model was obtained from an outside source,
- the identity of that source,
- the name or names by which the model is l known,
- the general function of the model,
- whether the model was received in source code or object code, i
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer program) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, l
if so, the nature of all such modifications, 1
11.
_. . . -. . . = - __- - _____ . - _ _ __ .- _ . . .
- the manuf acturer and model number of the computer or computers on which the computer model was run in connection with the reassessment; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the model,
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment.
- 5. With respect to the reassessment of the auxiliary building of Diablo Canyon, state:
(a) What contractors and subcontractors to the DCP vorked on the reassessment.
(b) The person employed or retained by the DCP or its subcontractors most knowledgeable about the reassessment.
(c) The person employed or retained by the DCP or its subcontractors most knowledgeable about:
(i) data collection for the reassessment; 12.
(ii) analyses performed for the reassessment; (iii) conclusions of the DCP in connection with the reassessment; (iv) documentation of the reassessment.
(d) What computer models were employed in performing analyses in connection with the reassessment, stating as to each:
(i) If the model was obtained from an outside source,
- the identity of that source,
- the name or names by which the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer prog ram) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
)
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment; 1 k 1 l
! 13.
(ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the model,
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment.
- 6. With respect to the reassessment of the turbine building of Diablo Canyon, state:
(a) What contractors and subcontractors to the DCP worked on the reassessment.
(b) The person empicyed or retained by the DCP or its subcontractors most knowledgaable about the reassessment.
(c) The person employed or retained by the DCP or its subcontractors most knowledgeable about:
(i) data collection for the reassessment; (ii) analyses performed for the reassessment; (iii) conclusions of the DCP in connection with the reassessment; (iv) documentation of the reassessment.
14.
i.
(d) What computer models were employed in performing analyses in connection with the reassessment, stating as to each:
(i) If the model was obtained from an outside source,
- the identity of that source, t
- the name or names by which'the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer prog ram) was modified in any way (excluding t
modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the model, 15.
_ -~- , . , ,_ _ _ _ . . _ . . _ _ , _ . , - _ .
. , , . . . ~ , , - .
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment.
- 7. With respect to the reassessment of the intake structure of Diablo Canyon, state:
(a) What contractors and subcontractors to the DCP worked on the reassessment.
(b) The person employed or retained by the DCP or its subcontractors most knowledgeable about the reassessment.
(c) The person employed or retained.by the DCP or its subcontractors most knowledgeable about:
(i) data collection for the reassessment; (ii) analyses performed for the reassessment; (iii) conclusions of the DCP in connection with the reassessment; (iv) documentation of the reassessment.
(d) What computer models were employed in performing analyses in connection with the reassessment, stating as to each:
16.
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(i) If the model was obtained f rom an outside source, t
- the identity of that source,
- the name or names by which the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of j the certification,
- whether the model (i.e., the computer 1
prog ram) was modified in any way (excluding modifications solely to alter the format in which l 1
data were read or displayed) after receipt and, if so, the nature of all such modifications, l
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the model,
- the name or names by which the model is j known,
- the general function of the model, 17.
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the reassessment.
- 8. With respect to the IDVP Phase I Final Report, state:
(a) The person employed or retained by the IDVP or its subcontractors most knowledgeable about the Final Report.
(c) The person employed or retained by the IDVP or its subcontractors most knowledgeable about:
(i) data collection for the Final Report (as opposed to data collected for the ITRs);
(ii) analyses performed for the Final Report (independent f rom the data collected for the ITRs);
(iii) conclusions of the Final Report; (iv) documentation of the Final Report.
(d) What computer models were employed in performing analyses in connection with the Final Report (excluding nodels employed in connection with the ITRs), stating as to each:
(i) If the model was obtained from an outside source,
- the identity of that source, 18.
1
- the name or names by which the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer prog ram) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report; (ii) If the model was not obtained from an outside source, l
l - the identity of the person or persons 1
having overall responsibility for developing the
, model, l - the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written, 19 .
l
. . ___ = .- -_.
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report.
- 9. With respect to the IDVP Phase II Final Report, state:
(a) The person employed or retained by the IDVP or its subcontractors most knowledgeable about the Final Report.
(c) The person employed or retained by the IDVP or its subcontractors most knowledgeable about:
(i) data collection for the Final Report (as opposed to data collected for the ITRs);
(ii) analyses performed for the Final Report (independent from the data collected for the ITRs);
(iii) conclusions of the Final Report; (iv) documentation of the Final Report.
(d) What computer models were employed in performing analyses in connection with the Final Report (excluding models employed in connection with the ITRs), stating as to each:
(i) If the model was obtained from an outside source,
- the identity of that source,
- the name or names by which the model is known,
- the general function of the model, 20.
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer program) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report; (ii) If the model was not obtained from an i
outside source,
- the identity of the person or persons having overall responsibility for developing the i model, l
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report.
21.
- 10. With respect to the DCP Phase I Final Report, state:
(a) The person employed or retained by the IDVP or its subcontractors most knowledgeable about the Final Report.
(c) The person employed or retained by the IDVP or its subcontractors most knowledgeable about:
(i) data collection for the Final Report (as opposed to data collected for the ITRs);
(ii) analyses performed for the Final Report (independent f rom the data collected for the ITRs);
(iii) conclusions of the Final Report; (iv) documentation of the Final Report.
(d) What computer models were employed in performing analyses in connection with the Final Report (excluding models employed in connection with the ITRs), stating as to each:
(i) If the model was obtained from an outside source,
- the identity of that source,
- the name or names by which the model is known,
- the general function of the model,
- whether the model was received in source code or object code,
- whether the version received had been certified for accuracy and, if so, the nature of the certification, 22.
- whether the model (i.e., the computer program) was modified in any way (excluding modifications solely to alter the format in which data were read or displayed) after receipt and, if so, the nature of all such modifications,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the nodel, 1
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model l was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report.
- 11. With respect to the DCP Phase II Final Report, state:
(a) The porson employed or rotainnd by tho TDVP or Ita sutcoattnetots most k n. swledg ea t> le dbout the Final Report.
23.
l
4 (c) The person employed or retained by the IDVP or i
its subcontractors most knowledgeable about:
(i) data collection for the Final Report (as opposed to data collected for the ITRs);
(ii) analyses performed for the Final Report (independent from the data collected for the ITRs);
(iii) conclusions of the Final Report; (iv) documentation of the Final Report.
(d) What computer models were einployed in performing analyses in connection with the Final Report (excluding models employed in connection with the ITRs), stating as to each:
(i) If the model was obtained from an outside source,
- - the identity of that source, 4
- the name or names by which the model is
} known,
- the general function of the model,
- whether the model was received in source l
code or object code, l
- whether the version received had been certified for accuracy and, if so, the nature of the certification,
- whether the model (i.e., the computer i
i prog ram) was modified in any way (excluding modifications solely to alter the format in which i
data were read or displayed) after receipt and, if so, the nature of all such modifications, 24.
- - - - ---- , - - . , . . - , , , , - - , --.-,v,-,- - - , - . , _ - . _ , - - - . . _ . , _ _ . . . . . . . . - . - , , . - , , , . --
- the manufacturer and model number of the computer or computers on which the computer model was run in connection with the Final Report; (ii) If the model was not obtained from an outside source,
- the identity of the person or persons having overall responsibility for developing the model,
- the name or names by which the model is known,
- the general function of the model,
- the computer language in which the model was written,
- in general, what measures were taken to verify the accuracy of the model,
- the manufacturer and model number of the compoter or computers on which the computer model was run in connection with the Final Report.
- 12. Ilow do you define " safety-related" for purposes of compliance with appendix B to part 50 of 10 C.F.R.?
- 13. How do you define "important to safety" for purposes of compliance with General Design Criterion 1 of appendix A to l
! 25.
}
L-
part 50 of 10 C.F.R.?
DATED: May 6, 1983.
JOHN K. VAN DE KAMP, Attorney General of the S tate of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General
}
By /
HICHAE J. STRUMWASSER Attorneys for Intervenor Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2102 JOHN R. PHILLIPS, ESQ.
JOEL R. REYNOLDS, ESQ.
Center for Law in the Public Interest 10203 Santa Monica Boulevard Fifth Floor Los Angeles, California 90067 (2 13) 470-3000 DAVID S. FLEISCHAKER, ESQ.
JOEG R,.(AEYNOLDS Attorneys for Intervenors San Luis Obispo Mothers for Peace, Secnic Shoreline Preservation Conference, Inc. , Ecology Action Club, Sandra Silver, Gordon Silver, Elizabeth Apfelberg, and John J. Forster 26.