ML20080S283

Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20080S283
Person / Time
Site:	Diablo Canyon
Issue date:	10/14/1983
From:	Lubbock D PACIFIC GAS & ELECTRIC CO.
To:	Deukmejian CALIFORNIA, STATE OF
References
NUDOCS 8310180328
Download: ML20080S283 (14)

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' TUCMETED- f USNRC 1 UNITED STATES OF AMERICA

'83 00T 17 AH :55 2 NUCLEAR REGULATORY COMMISSION 3 - - h. . . U S.E. .

4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5

6 7 In the Matter of )

) Docket Nos. 50-275 8 PACIFIC GAS AND ELECTRIC COMPANY ) 50-323

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9 (Diablo Canyon Nuclear Power ) (Reopened Hearing --

Plant, Units No. 1 and 2) ) Design Quality 10 ) Assurance) 11 12 13 LICENSEE PACIFIC GAS AND ELECTRIC COMPANJ'S SECOND SUPPLEMENTAL RESPONSE TO 14 GOVERNOR DEUKMEJIAN'S THIRD SET OF INTERROGATORIES 15 16 17 RESPONSE TO INTERROGATORY 2:

18 Additional witness: E..Connell, III 19 20 RESPONSE TO INTERROGATORY 61:

21 1. E. Connell, III 22 (a) Yes 23 (b) Contention 9 ,

24 (c) See attached qualifications of E. Connell, III 25 (d) None 26 (e) To be provided during the testimony 8310180328 831014 PDR ADOCK 05000275 -

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4 1 (f) None 2 (g) i) N/A 3 ii) N/A 4 iii) N/A 5 iv) N/A 6 ///

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i 1 PROFESSIONAL QUALIFICATIONS OF EDWARD C. CONNELL, III 2

3 EDUCATION: B. S. Nuclear Engineering, University of Lowell, 1972 4

M. S. Nuclear Engineering, Purdue University, 5 1974. Teaching Fellow - Nuclear Engineering -

Thesis, Space Energy Synthesis for Fast Spectra 6

EXPERIENCE: 1982 - Present - Mechanical Group Supervisor 7 assigned to the Diablo Canyon Project.

Responsible for technical content and 8 direction, cost and schedule, and administration for project mechanical and 9 nuclear design.

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Bechtel Power Corporation, assigned to the Susquehanna Project. Succes-11 sive assignments of increasing responsibility as:

12 A. Systems Engineer - Overall design responsi-13 bility for a number of systems, ,e.g. , RHR, CS, MSIV-LCS. Performed design 14 calculations and procured equipment.

15 B. Project Licensing Engineer - Responsible for all licensing activities for all 16 disciplines, including pr,eparation of FSAR, ER, and Technical Specifications. Assured 17 all regulatory requirements were addressed in the Bechtel design. Responded to NRC 18 questions and represented the project in meetings with NRC and hearings before ACRS.

19 C. Nuclear Group Leader - Technical direction 20 and personnel actions for 16 engineers.

Overall responsibility for development of 21 design, procurement of equipment, and interface with client, start-up and 22 suppliers. . Group responsibilities included radwaste systems design, shielding, NSSS 23 interface, environmental and hazards studies, and licensi'ng.

24 D. Deputy Mechanical Group Supervisor - Assist 25 Group Supervisor and act in his absence.

Group of 45 engineers responsible for 26 nuclear, balance of plant, HVAC and L - _ -

O 1 plumbing design. Responsible for develop-ing yearly budget and scheduling major work 2 activities. Mechanical coordinator for Mark II seismic hydrodynamic loads program.

3 Review and sign-off on all drawings.

Trouble shoot and resolve special problems.

4 1974-1978 - Flour Pioneer Inc. -

Worked in 5 Standard Balance of Plant design for Westing-house and B & W standard plants. Prepared SAR, 6 coordinated with NSSS supplier, designed NSSS mechanical support facilities, performed 7 shielding and done cales, met with NRC and ACRS. As Project Regulatory Engineer, 8 coordinated all licensing activities and worked on design for nuclear and mechanical systems 9 for follow-on engineering for Kewaunee and Prairie Island plants after start-up. Senior 10 Project Nuclear Engineer for a systems inter-action study for Zion, responsible for review 11 of LER's from all plants, comparison with Zion design and made recommendations for hardware 12 and operational changes. Lead engineer in charge of a study to quantify the hazards and 13 assess the feasibility of siting gas turbines at Rancho Seco.

14 1972-1974 - Purdue University - Teaching Fellow 15 for Nuclear Engineering courses. Research in computational methods for solving core physics .

16 p'roblems for Liquid Metal Breeder Reactor.

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1 RESPONSE TO INTERROGATORY 61:

2 2. E. J. Kreh, Jr. (Previously designated in response 3 to Interrogatory 2(d) on 4 September 19, 1983.)

5 (a) Yes 6 (b) Nuclear plant quality assurance 7 (c) See attached qualifications of E. J. Kreh, Jr.

8 (d) Co-authored the ANSI /ASME NQA-1, " Quality 9 Assurance Program Requirements for Nuclear Power 10 Plants" 1979 and 1983 versions, as a member of the 11 main committee.

12 (e) If any, to be provided during testimony.

13 (f)- None ,

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24 25 26 1 PROFESSIONAL QUALIFICATION 2 OF 3 EDWARD J. KREH, JR.

4 5 My name is Edward Kreh. I am a Senior Consulting Engineer 6 with SMC O'Connell and Associates in Pittsburgh, PA. I am a 7 graduate of Carnegie Institute of Technology, now Carnegie 8 Mellon University of Pittsburgh, PA and hold a Bachelor's 9 Degree in Mechanical Engineering. I have been active in the 10 Nuclear Industry since January of 1951.

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11 12 Since my retirement in 1979, following over 33 years of 13 service with Westinghouse, -I have been consultipg in the 14 Nuclear Industry. The scope of my most recent involvement 15 'has included ' Management Evaluation, Product Assurance 16 Program Evaluation, Product Assurance Auditing, Training and 17 Design Review activities.

I 18 19 I am a registered Professional Engineer and an active member 20 of the ASME. In that capacity, I am a member of the ASME 21 Committee on Nuclear Quality Assurance, which is responsible i 22 for ANSI /ASME/NQA-1 Standards. Also, I am a member of the l 23 Executive Committee, as well as Chai,rman of the Design and 24 Procurement Subcommittee supporting the development of the 25 NQA-1 Standard for nuclear facilities.

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1 Before my retirement from Westinghouse, I was Manager, 2 Product Assurance for the Westinghouse Pressurized Water 3 Reactor Systems Division from 1972 to 1979.

4 5 Prior to 1972, I had various responsibilities at the Bettis 6 Atomic Power Laboratory, including, Manager of Bettis Atomic 7 Laboratory Operations; Manager, Nuclear Fuel and Plant 8 Material Development; Manager, Nuclear Fuel Development and 9 Quality Control. These were all assignments on the General 10 Manager's staff.

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1 RESPONSE TO INTERROGATORY 61:

2 2. R. A. Wiesemann (Previously designated in response 3 to Interrogatory 2(d) on 4 September 19, 1983.)

5 (a) Yes 6 (b) contention-6 7 (c) See attached qualifications of R. A. Weisemann 8 (d) None 9 (e) If any,-to be provided during testimony.

10 (f) and (g) Rec:;rds have not been maintained. How-11 ever, witness has testified at numerous 12 proceedings dating back to 1963. It 13 would require a tremendous effort to 14 review the records of all such proceed-15 ings involving Westinghouse-supplied 16 NSSS plants; this information is a 17 matter of public record.

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1 PROFESSIONAL QUALIFICATION 2 OF 3 ROBERT A. WEISEMANN 4

5 T.y name is Robert A. Weisemann. My business address is P.O.

6 Box 355, Pittsburgh, Pennsylvania 15230. I am employed by 7 Westinghouse Electric Corporation as Manager of Regulatory 8 and Legislative Affairs in the Nuclear Safety Department of 9 the Nuclear Technology Division (NTD). I have served in 10 this capacity since August, 1978 and, in this capacity, I am 11 one of the individuals responsible for reviewing the safety 12 of design, construction and operation in connection with 13' licensing nuclear power generating plants being d,esigned and 14 built by Westinghouse; Secretary of the WRD Safety Review 15 Committee; and responsible for directing the Westinghouse 16 participation in public hearings.

17 18 I was graduated from Case Institute of Technology in 1949 19 with a B.S. degree in Mechanical Engineering having majored 20 in Heat-Power and completed advanced studies in Mathematics, 21 Gas Dynamics and Heat Transfer and Business Administration 22' E :--; bu . h liy of Pennsylvania and the University of

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23 Missouri. I was graduated from Duquesne University School 24 of Law in 1982 with a J.D. degree and am currently an active 25 member of the Pennsylvania Bar.

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4 1 I have a total of over 34 years of engineering experience 2 with the Westinghouse Electric Corporation. The 28 years 3 prior to being assigned to my present position were spent in 4 the field of nuclear engineering as applied to reactor 5 systems for generation of electricity. The last 25 of these 6 28 years were devoted to nuclear safety; establishing safety 7 criteria and standards; directing safety assessments of 8 design, consti.uction and operation of nuclear plants and 9 preparation of safety analysis reports and testimony for 10 public hearings in support of applications for construction 11 permits and operating licenses for nuclear plants.

. 12 13 I am a registered professional engineer in the Commonwealth 14 of Pennsylvania, a member of the American Nuclear Society, 15 and a member of the American Bar Association. I am also an 16 associate member of Sigma XI.

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i I 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, California 94120 6 (415) 781-4211 7 ARTHUR C. GEHR Snell & Wilmer 8 3100 Valley Center Phoenix, Arizona 85073 9 (602) 257-7288 10 BRUCE NORTON Norton, Burke, Berry & French, P.C.

11 P.O. Box 10569 Phoenix, Arizona 85064 12 (602) 955-2446 13 Attorneys for Pacific Gas and Electric' Company 14 15 16 By W V

1. Dan G.'141bbock 17 18 DATED: October 14, 1983.

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00LKETEC USNRC 1 UNITED STATES OF AMERICA 53 00T 17 A11:55 2 NUCLEAR REGULATORY COMMISSION LFFICE 3 SEL:itiM 3 BEFORE THE ATOMIC SAFETY AND LICENSING APPEALU $id jhC 4

In the Matter of )

5 ) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 6 )

(Diablo Canyon Nuclear Power ) (Reopened Hearing --

7 Plant, Units No. 1 and 2) ) Design Quality

) Assurance) 8 9 CERTIFICATION 10 I, Dan G. Lubbock, hereby certify:

11 1. I am one of the attorneys for Licensee 12 Pacific Gas and Electric Company in the above-entitled 13 matter and, as such, am authorized to execut9 this 14 certification.

15 2. I have read the foregoing Second Supplemental 16 Response to

• Governor Deukmejian's Third Set of 17 Interrogatories, and know the contents thereof.

18 3. I am informed and believe the answers to said 19 interrogatories to be true and correct.

20 I certify under penalty of perjury that the 21 foregoing is true and correct.

22 Executed at San Francisco, California, on 23 October 14, 1983. ,

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AuW<d4G&

DAN G.' LUBBOCK I

s. .

U NITED STATES OF AMERICA , . . -

NUCLEAR REGULATORY COMMISSION [

'83 ggi 17 g1 :55 In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275

) Docket No. 50-323 [Ck...NI. . _ N\} J Dichlo Canyon Nuclear Power Plant, ) SRANCH Units 1 and 2 )

)

CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (hnve) been served today on the following by deposit in the United States mail, properly stamped and addressed:

Judge John F. Wolf '

Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety and Licensing Board San Luis Obispo CA 93401 US Nuclear Regulatory Commission Washington DC 20555 Mr. Gordon Silver 1760 Alisal Street San Luis Obispo CA 93401 Judge Glenn O. Bright Atomic Safety and Licensing Board US Nuclear Regulatory Commission , John Phillips, Esq.

Washington DC 20555 Joel Reynolds, Esq. ,

Center for Law in the Public Interest Judge Jerry R. Kline 10951 W. Pico Blvd. - Suite 300 Atomic Safety and Licensing Board Los Angeles CA 90064 US Nuclear Regulatory Commission David F. Fleischaker, Esq.

Washington DC 20555 P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer Arthur C. Gehr, Esq.

l 1493 Southwood Snell & Wilmer l San Luis Obispo CA 93401 3100 Valley Bank Center Jcnice E. Kerr, Esq. Phoenix AZ 85073 t

l Public Utilities Commission Bruce Norton, Esq.

State of California Ncrton, Burke, Berry & French, P.C.

5246 State Building 350 McAllister Street P. O. Box 10569 San Francisco CA 94102 Phoenix AZ 85064 Mrs. Rayo Fleming Chairman Atomic Safety and Licensing 1920 Mattie Road Board Panel Shell Beach CA 93449 US Nuclear Regulatory Commission 20555 Washington DC Mr. Frederick Eissler [

Sennic Shoreline Preservation Conference, Inc.

I 4623 More Mesa Drive Senta Barbara CA 93105

• Sent by Express Mail

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Chairman

• Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Washington DC 20555 US Nuclear Regulatory Commission Washington DC 20555

• Secretary US Nuclear Regulatory Commission

• Judge W. Reed Johnson Washington DC 20555 Atomic Safety and Licensing Appeal Board Attn: Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555

• Lawrence J. Chandler, Esq.

• Judge John H. Buck Henry J. McGurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission Washington DC 20555 Washington DC 20555 Mr. Richard B. Hubbard

• Michael J. Strumwasser, Esq.

MHB Technical Associates Susan L. Durbin, Esq.

1723 Hamilton Avenue Suite K Peter H. Kaufman, Esq.

San Jose CA 95125 3580 Wilshire Blvd. Suite 800 Los Angeles CA 90010 Mr. Carl Neiberger Telegram Tribune

• Maurice Axelrad, Esq.

P. O. Box 112 Lowenstein, Newman, Tseis, and San Luis Obispo CA 93402 Axelrad, P.C.

1025 Connecticut Ave NW Washington DC 20036 l

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Dr.te : October 14, 1983

• Sent by Express Mail l

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