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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059C7361993-08-24024 August 1993 Intervenor Exhibit I-MFP-88,consisting of NRC Insp of Diablo Canyon Units 1 & 2 IR 05000275/19920161993-08-24024 August 1993 Intervenor Exhibit I-MFP-137,consisting of Insp Rept Re Dockets 50-275/92-16 & 50-323/92-16,dtd 920707 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059M5041993-08-24024 August 1993 Staff Exhibit S-2,consisting of Re Notice of Violation ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 1999-09-20
[Table view] Category:PLEADINGS
MONTHYEARML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20056E8951993-08-17017 August 1993 Motion to Amend Protective Order (Governing non-disclosure of INPO Rept).* NRC Moves That Board Add Footnote to Paragraph 3.Certificate of Svc Encl ML20056E8021993-08-12012 August 1993 NRC Staff Opposition to San Luis Obispo Mothers for Peace Leave to Conduct Discovery on NRC Inquiry Into Allegations Re Pressure to Falsify Fire Watch Logs Motion for Postponement of Hearing....* W/Certificate of Svc ML20056E7371993-08-12012 August 1993 PG&E Response to San Luis Obispo Mothers for Peace Motion for Further Discovery & for Delay in Hearing Thermo-Lag Contention.* W/Certificate of Svc ML20046D1091993-08-11011 August 1993 San Luis Obispo Mothers for Peace Request for Leave to Conduct Discovery on NRC Inquiry Into Allegations Re Pressure to Falsify Fire Watch Logs,Motion for Postponement of Hearing on thermo-lag Contention.* ML20046B9181993-07-22022 July 1993 PG&E Request to Defer Briefing Schedule on Ref Ruling Re INPO Documents.* Board Erred as Matter of Law in Ordering Release of INPO Evaluation & Ref Ruling Should Be Reversed by Commission.* W/Certificate of Svc ML20046B9531993-07-22022 July 1993 Pacific Gas & Electric Co Motion to Require cross-exam Plans.* Requests That Board Require cross-examination Plans from Parties That Intend to Conduct cross-examination. W/Certificate of Svc ML20056C8721993-07-16016 July 1993 Pacific Gas & Electric Co Response to 930701 Motion to Compel.* Concludes That Motion to Compel Moot & Should Be Denied.W/Certificate of Svc ML20045G9691993-07-0202 July 1993 PG&E Response to Licensing Board Questions Re INPO Documents.* ML20045G9561993-07-0101 July 1993 Intervenor San Luis Obispo Mothers for Peace Motion to Compel PG&E to Respond to Third Set of Supplemental Interrogatories & Requests for Document Production,Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc ML20045G9431993-07-0101 July 1993 Intervenor San Luis Obispo Mothers for Peace (Slomfp) Response to Prehearing Conference Order Re INPO Documents.* Slomfp Cannot Provide Info by Affidavit Due to Lack of Info Re Content of INPO Documents.W/Certificate of Svc ML20045D7341993-06-21021 June 1993 Pge Motion for Schedule Change.* Util Moves That Licensing Board Adopt Listed Revised Schedule.W/Certificate of Svc ML20128P1821993-02-12012 February 1993 PG&E Preliminary Response to Discovery Request Filed Per 10CFR2.741(a)(2) & Motion for Protective Order.* Util Agrees to & Will Support Reasonable Discovery Into Issues within Scope of Contentions Admitted by Aslb.W/Certificate of Svc ML20128D8661993-02-0303 February 1993 Intervenor San Luis Obispo Mothers for Peace Request to PG&E for Entry Upon Facility,Per 10CFR2.741(a)(2) for Purposes of Insp,Measuring & Photographing.* W/Certificate of Svc.Related Correspondence ML20127D5461992-09-0808 September 1992 NRC Staff Response to San Luis Obispo Mothers for Peace Ltr Request for Hearing.* Presiding Officer Should Defer Ruling on Standing Pending Receipt of Any Amend Petitioners May File.W/Certificate of Svc & Notice of Appearance ML20006D7721990-02-0808 February 1990 PG&E Response in Opposition to Application for Stay.* Stay of Random Drug Testing Under NRC Fitness for Duty Rule Should Be Denied on Basis of Untimeliness & Challenge Having No Merit.W/Proof of Svc ML20247Q1531989-07-24024 July 1989 Sierra Club Request to Withdraw Contentions.* Requests That All Outstanding Contentions in Current Proceedings Be Withdrawn W/Understanding That Further Discussion Will Occur Between Sierra Club & NRC Re Nepa.W/Certificate of Svc ML20154E4281988-05-11011 May 1988 Motion to Terminate Proceeding.* Requests Termination of Pending Proceedings on Grounds of Mootness.Supporting Documentation & Certificate of Svc Encl ML20148L9531988-03-31031 March 1988 Response to NRC Staff to Petition for Leave to Intervene Filed by San Luis Obispo Mothers for Peace.* Notice of Appearance & Certificate of Svc Encl ML20148L9301988-03-29029 March 1988 Answer of PG&E to Petition to Intervene in License Amend Proceedings of San Luis Obispo Mothers for Peace.* San Luis Obispo Mothers for Peace Failed to Satisfy Technical Standing Requirements of 10CFR2.714.W/Certificate of Svc ML20237E5071987-12-15015 December 1987 Motion for Leave to File Response of NRC Staff to Appeal of Sierra Club from ASLB Memorandum & Order of 870902 & Initial Decision of 870911,1 Day Late.* W/Certificate of Svc ML20237E6891987-12-15015 December 1987 Motion for Leave to File Response of NRC Staff to Appeal of Sierra Club from Licensing Board Memorandum & Order of 870902 & Initial Decision of 870911,1 Day Late.* Motion Should Be Granted.Certificate of Svc Encl ML20237E8191987-12-11011 December 1987 Response of NRC Staff to Appeal of Sierra Club from Licensing Board Memorandum & Order of 870902 & Initial Decision of 870911.* Staff Opposes Sierra Club Appeal & Urges That Board Decisions Be Affirmed.W/Certificate of Svc ML20236E0031987-10-21021 October 1987 PG&E Answer in Opposition to Sierra Club Request for Stay.* Util Lists Four Arguments Opposing Request for Stay,Issued by ASLB on 870911,re Util Amends to Increase Spent Fuel Storage Capacity.Affidavit & Certificate of Svc Encl ML20236C1831987-10-20020 October 1987 Intervenor Request for Stay.* Sierra Club Requests NRC to Stay Effectiveness of 870902 Order & 870911 Initial Decision of Licensing Board Until Sierra Club Has Had Opportunity to Participate in Proceeding Re Reracking.W/Proof of Svc ML20235T4071987-10-0505 October 1987 Response of NRC Staff to Intervenor Sierra Club Request for Stay.* Sierra Club Failed to Satisfy Requirements of 10CFR2.788 & Request for Stay Should Be Denied.W/Certificate of Svc ML20235R9611987-10-0202 October 1987 PG&E Answer in Opposition to Sierra Club Request for Stay.* Sierra Club 870924 Request for Stay of 870911 ASLB Initial Decision (LBP-87-25) Authorizing Spent Fuel Pool Reracking Amends Should Be Denied ML20235F2951987-09-24024 September 1987 Intevenors Request for Stay.* Seeks Stay of ASLB 870911 Initial Decision Authorizing NRR to Issue OL Amends, Permitting Reracking of Spent Fuel Storage Pools.W/Proof of Svc ML20234D3021987-09-16016 September 1987 Sierra Club Brief in Support of Appeal of ASLB 870902 Order.* Contention Contains Requisite Specificity to Be Admitted to Proceeding.Criteria for late-filed Contention Met.Proof of Svc Encl ML20238A5771987-08-14014 August 1987 Supplemental Brief Re Applicability of ALAB-869 to Inclusion of Zircalloy Cladding Fire Contention.* Sierra Club Believes Focus for Admission of Contentions Must Be Requirements of Atomic Energy Act & Nepa.Proof of Svc Encl ML20238A6521987-08-14014 August 1987 PG&E Supplemental Answer in Opposition to Intervenor Motion to Admit Late Filed Contention.* Sierra Club Motion to Admit Late Filed Contention & Direct Preparation of EIS Should Be Denied.Certificate of Svc Encl ML20238A6001987-08-13013 August 1987 Response of NRC Staff to ASLB Order of 870731 (Directing Parties to File Comments on Applicability of Aslab Decision in Vermont Yankee Nuclear Power Corp,ALAB-869,to Proposed Contentions at Issue in Matter).* Certificate of Svc Encl ML20236B8541987-07-21021 July 1987 Motion on Notification of Meetings,Establishment of Seismic Review Committee & Govt Exam of Design Calculations.* Motion Undated ML20235J1541987-07-10010 July 1987 PG&E Answer in Opposition to Intervenor Motion to Admit late-filed Contention.* Board Requested to Direct NRC Staff to Prepare EIS Re Issues Discussed in Generic Issue 82. Certificate of Svc Encl ML20235J1791987-07-10010 July 1987 NRC Staff Answer to Sierra Club Motion to Admit Contention Re Generic Issue 82 & to Direct Preparation of an Eis.* Denial Urged.Certificate of Svc Encl ML20216J7911987-06-29029 June 1987 Motion to Include Issues Raised in Generic Issue 82 as Contentions in Proceeding & to Direct Preparation of Eis.* Board Requested to Direct Preparation of EIS Re Possibility & Impact of Zircalloy Cladding Fires ML20214A9391987-05-13013 May 1987 NRC Staff Comments on Proposed Order Re Electronic Storage & Retrieval.* ASLB Proposed Order Should Not Be Adopted.If ASLB Agrees,Staff & Parties Could Supply ASLB w/MS-DOS Disks of Prefiled Testimony.Certificate of Svc Encl ML20207P7081987-01-15015 January 1987 NRC Staff Answer in Opposition to Sierra Club/Mothers for Peace Motion for Summary Disposition.* Motion Devoid of Any Factual Support Which Warrants Granting of Summary Disposition Re Environ Claims.W/Certificate of Svc 1998-11-24
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Text
. p 00CKETED U #'
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIg I9NR -7 A10 :45 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
)
JOINT INTERVENORS' SUPPLEMENT TO FEBRUARY 14, 1984 MOTION TO AUGMENT-OR, IN THE ALTERNATIVE, TO REOPEN THE RECORD Pursuant to the February 23, 1984 Order of this Appeal Board, the Joint Intervenors hereby supplement their 4
February 14, 1984 Motion to Augment or, in the Alternative, to Reopen the Record. Specifically, this supplement relates to the l- recently released transcript of the January 25, 1984 meeting i
between former Diablo Canyon engineer Charles Stokes and j
representatives of the NRC Staff.
Previously incorporated by reference in the Joint Intervenors' February 14th motion, the transcript reveals a l
number of new and highly significant allegations of design and I design quality assurance deficiencies at Diablo Canyon. In l-addition, it provides further support for and explanation of some of the allegations contained in Mr. Stokes' two affidavits 8403080118 840301 $DRADOCK 05000275 PDR -
()/I) i j
- l submitted as attachments to the Joint Intervenors' motion.
Simply stated, the January 25, 1984 transcript contains 1
additional significant new information that undermines still j
!' . I further the confidence in the design of Diablo Canyon that is an j essential precondition to issuance of an operating license.1/
Given the bulk of the transcript and the extensive l I
amount of evidence contained in it, a reiteration here of_all of j
- the significant information is neither possible nor necessary. ;
+ ,
As with each of.the attachments to the motion, the transcript
- must be viewed in its entirety as documentation in support of dugmentation and reopening of the record, rather than selecting only discrete portions for consideration. However, some of the principal quality assurance-related deficiencies described by Mr. Stokes are included below to illustrate the nature and significance of the problems remaining at Diablo Canyon, both in the design process and in'the design product. Among the L deficiencies alleged by Mr. Stokes are the following:
I
-- In 1983 a management representative from San
- Francisco, Mr. Dan Curtis, refused to answer numerota A! The questionable practices described by Mr. Stokes in his Janua.y 25th meeting with the NRC Staff include noncompli-ance with applicable codes, deliberate destruction of documents
' in violation of normal industry practices, intentional nondis-
. closure and cover-up of design deficiencies, manipulation of calculations (i.e., elimination'of eccentricities), excessive work hours, retaliatory tranLfers of engineers, excessive-
_ production pressure, unavailability or lack of access to necessary documentation and manuals, inadequate training, improper or misleading' test procedures, disregard and exceedence of vendor load ratings for bolts, intimidation of engineers to i discourage questioning of design practices,'and misrepresenta-
- j. tions!to the NRC.
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questions and challenges from site engineers who believed that Document 049243 was not a conservative basis for the seismic redesign program. Management's inability to defend its program internally suggests that the licensee may have deliberately misinformed the NRC staff on Eecember 15, 1983 that Document 049243 is conservative under professional engineering standards. (Tr. 13-14.)
-- Management did not freely distribute professional codes that supposedly paralleled computer analyses relied on by engineers in the seismic dem review. In some cases the only reference materials t 'ide the engineers were the computer analyses. That is improper, as management effectively conceded in the fall of 1983 tnrough instructions that the computer analysis was merely a guide and not meant to replace the professional codes.
Unfortunately, the program had officially been completed when management disclosed the non-binding nature of the l computer analysis. (Tr . 16-17, 120-21.)
-- The M-9 computer analysis for angles omitted the relevant provision of the American Institute of Steel Construction ("AISC") code for allowable bending stress, l contrary to licensing commitments. Management officials stopped engineers from using that section of the code, because compliance required angles to be cut out and replaced with tube steel, or at least reinforced through braces. (Tr. 15-21.)
i l
r l t-
-- Management imposed inconsistent standards for modifications in the seismic design review: as the number of modifications approached the Ifmits beyond which PGandE had committed to expand the sample, management refused to fix deficiencies, even if obvious and more severe than those previously corrected. Instead, engineers conducting the first round of calculations were told to make assumptions contrary to fact, such as restraints that did not exist. (Tr. 23-24.)
-- Bechtel issued out-of-date computer STRUDL manuals to engineers in the seismic design review. Inexplicably, the office at Diablo Canyon was not on the route slip for updated materials on the computer, and even after that defic:lency was corrected the materials consistently were outdated. The manual provides backup information to engineers who wanted to check or go beyond the program.
(Tr. 27, 29.)
-- Engineers in the stress group relied on outdated seismic data that was necessary for their calculations. It took up to six months to receive updates, by which time the newly-arriving material was out-of-date. (Tr. 29.)
-- Bechtel's computer program did not have an adequate
" memory" for engineers to conduct full analyses of complex hangers. As a result, engineers had to ignore relevant factors as the worst case scenarios for force on the support frame. (Tr. 27, 29, 38-39.)
L
+
-- There was no consistent procedure or criterion to guide engineers who checked calculations in the seismic design review: they could check whatever they wanted through any method. (Tr . 31-3 2. )
-- After the NRC obtained certain work packages at Mr. Stokes' suggestion on December 8, 1983, management directed a purge of relevant files to remove any evidence of previously destroyed or censored work by engineers who failed hangers but were later overruled. (Tr. 41, 81-82.)
-- When assumptions or loads were changed for preliminary calculations on pipe supports that previously had failed, typically no one redid or checked the entire calculation. This step was necessary to determine that the new combination of variables in its entirety would support a conclusion to pass the pipe support. In Mr. Stokes' judgment, this allowed hangers to pass which should have failed. '(Tr. 50-51.)
-- Mr. Leo Mangoba, the Bechtel official who supervised engineers in the pipe support group, approved the seismic review calculations en masse over several days l without studying and properly reviewing the work.
l Mr. Mangoba did not even get to the calculations until a few days before the end of the program. Supposedly Mr. Mangoba's approval was one of the checks and balances on the quality of the calculations, but it was pro forma.
(Tr. 52.)
-- Management did not have necessary documents from vendors and manufacturers to guide calculations on required supports for vendor purchases such as valves. The omission helps to explain why engineers based their analysis on "past experience" at other plants brought in from previous jobs. (Tr. 54-55.)
-- Management at Diablo Canyon did not send drawing details and support conditions to valve manufacturers and other vendors for approval. The vendor's review and approval is necessary to assure that the component is being used as intended. This omission was unique in Mr. Stokes' experience in the nuclear industry. It represents more necessary information that was missing from the seismic design review program. (Tr. 55.)
-- Management's production schedule for the seismic design review made it impossible for engineers to think clearly, let alone produce consistently high-quality calculations. For extended periods, they were instructed to complete 1.5 hangers per day on a schedule of seven days
.and 84-120 hours per week. (Tr. 62-63, 89-91.)
t
-- In some instances engineers approved hangers solely on the basis of conclusions in file 049243 for similar pipe supports, without any independent evaluation. This was known as the " cookbook" approach. (Tr. 75-76, 91.)
-- Early in the seismic design review, management instructed engineers to check a blank on the form that the calculation results would not affect the Final Safety L1
Analysis Report ("FSAR"), despite the engineers' protests that they did not know what was in the FSAR. Eventually, blank forms were just xeroxed with the "X" filled in and distributed to the engineers for their calculations. The only way the engineer could ensure accuracy was by whiting-out what was already there. (Tr. 96-97.)
-- Engineering calculations that called for field modifications were altered after cc,mplaints from construction, without the knowledge or approval of the originator. Tampering with calculations in this manner was highly improper. (Tr. 98A. ) The significance is that in an unknown number of cases, corrective action required on the basis of documented engineering analysis was informally circumvented. The basis for revising the modifications is unknown.
-- Multiple. engineers independently produced preliminary calculations on the same hangers. Besides being wasteful, this practice gave management the option to throw out the calculations that-failed hangers and keep those that passed. (Tr.99-100.)
-- Management officials overruled engineers who attempted to calculate the effects and stresses of torsional loads, created when pipe supports were twisted to tighten them during installation. This is an obsolete technique in the nuclear industry, and according to a former engineer in the seismic design review, it is hardly ever used unless totally qualified by structural
calculations. Engineers were told not to calculate for torsion and were overruled when they did. The stated reason was that "the hanger wou a fail." (Tr. 103-04, 123.)
-- Engineers on-site had to wait up to a week to obtain information on the telephone from San Francisco that normally would be on the drawings and was necessary to draw engineering conclusions. (Tr . 110-11. ) Combined with scheduling requirements, this system created pressure on engineers without the benefit of data on which they normally would rely.
-- There was no system or procedure to verify the accuracy of design information received on the telephone from the San Francisco offices. In the absence of any such procedures, the data was unverifiable despite engineers' doubts about its accuracy in some cases. (TR. 111-12.)
-- The initial records for hanger calculations later l covered by the seismic design review are totally unprofessional and unacceptable due to the~ inadequate
! underlying documentation, as well as the lack of signatures and evidence of a checker or other approval for the great majority of calculations. The records are so deficient that the seismic design review must be expanded from a sample to cover 100% of relevant hardware. Reliance on a sample assumed the existence of a comprehensive, if questionable, base of professional engineering calculations. In Mr. Stokes' professional judgment, such a t
base did.not exist. The plant cannot be licensed on the basis of a sample base of minimally-acceptable engineering calculations. Crr. 113-15.)
--- At the time of Mr. Stokes' departure, plant operators did not have access to a centralized document center with all information necessary to respond to conditions in the plant. This could compromise operators' ability to make all decisions from the control room in an emergency. CTr. 115-16.)
-- Mr. Stokes reported errors in the M-9 computer analysis, which incorrectly instructed engineers to consider small-bore baseplates and non-computer analysed piping lines.as rigid. In fact, the baseplates and lines are flexible. The assumption was inconsistent with other
' instructions to calculate displacement for the bolts on the baseplate. Crr. 138-41.)
-- Engineers in the seismic design review did not have I written procedures to guide their use of the STRUDL computer program. As Mr. Stokes explained, "All we had was the form handbook of a STRUDEL [ sic] program minus the pertinent information such as the model load points." Crr .
146-47.)
-- Similar to the experience of Mr. Stokes and others in the pipe support group, engineers in the stress trailer were transferred after challenging suspect changes -- such as eliminating eccentricities -- in the models for the seismic design review calculations. The reluctant g
engineers were replaced by personnel who cooperated with questionable manipulation of models. In fact, there were considerably more personnel shifts in the stress group than the pipe support group. (Tr . 151. )
-- Contrary to management assertions at the December 15, 1983 meeting with NRC staff, the calculations that replaced those rejecting pipe supports were not more refined and sophisticated. In fact, the opposite was true:
less sophisticated analysis was used. The models for subsequent calculations eliminated the unique eccentricities relevant for particular pipe supports.
Tr 85-86, 152-53.)
These allegations cannot be reconciled with the testimony offered to this Board in Nov' ember 1983 by PGandE, the NRC Staff, and the IDVP. Nor can they be reconciled with a finding of reasonable assurance that Diablo Canyon has been designed in compliance with the Commission's regulations. The i
design practices described by Mr. Stokes are not only unprofessional, but highly questionable in terms of reliability or acceptability under the various design codes. Moreover, they are practices apparently adopted and imposed with the knowledge and sanction of PGandE management in an effort to expedite the redesign process and minimize the disclosure of errors.
Many of Mr. Stokes' allegations of deficient design i
practices have already been verified by the NRC Staff and, in some instances, confirmed by PGandE. Further, his charge of l
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retaliation by PGandE for his attempts to document nonconfor-mances has been investigated and confirmed by the U.S.
Department of Labor. His testimony as a whole must, therefore, be given considerable weight by this Board in its review of Joint Intervenors' motion and the extensive documentation upon which it is based. Because of the implications of his charges for the entire design process and for the completely unacceptable attitude of PGandE management and supervisors, his testimony must not be viewed in its narrowest sense, but with due consideration for the generic significance of the deficiencies described. If Mr. Stokes' statements at the January 25, 1984 meeting with the Staff are as accurate as his earlier allegations have proven to be, then PGandE has a lot of explaining to do.
The only adequate forum in which that explanation can be adequately tested is the hearing process reopened by this l
Board last year on the issue of design. Discovery and cross-examination provide the only means to explore disputed matters of fact. Because the evidence submitted to this Board on l February 14th and supplemented with the January 25, 1984 L transcript undermines much of the testimony received by the Board last November, further hearings are plainly required.
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Accordingly, for the reasons stated above and in the Joint Intervenors' February 14th motion and attached exhibits (including the January 25th transcript), Joint Intervenors respectfully request that this motion be granted.
Dated: March 1, 1984 Respectfully submitted, JOEL R. REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
ERIC HAVIAN, ESQ.
Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.
P. O. Box 1178 Oklahoma City, OK 73101 By e EL R. RjE?dLDS Attorneys for Joint Inter-venors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APPELBERG JOHN J. FORSTER i
3 e
- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 1st day of March, 1984, I have served copies of the foregoing JOINT INTERVENORS' SUPPLEMENT TO FEBRUARY 14, 1984 MOTION TO AUGMENT OR, IN THE ALTERNATIVE, TO REOPEN THE RECORD, mailing them through the U.S. mails, first class, postage prepaid.
- Thomas S. Moore, Chairman *Dr. W. Reed Johnson Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission. Commission Washington, D.C. 20555 Washington, D.C. 20555
- Dr. John H. Buck Docket and Service Branch Atomic Safety & Licensing Office of the Secretary Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
Office of the Executive Legal Director - BETH 042 U.S. Nuclear. Regulatory Commission Washington, D.C. 20555 L
Vice' President & General Counsel Philip A. Crane, Esq.
Pacific Gas & Electric Company 77 Beale Street, Room 3135 San Francisco, CA 94120 Mr. Fredrick Eissler.
Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara,,CA 93105 Janic'e E. Kerr, Esq.
Lawrence Q. Garcia, Esq.
J. Calvin Simpson, Esq.
California Public Utilities Commission 5246 McAllister Jtreet San Francisco, CA 94102 John Van de Kamp, Attorney General Andrea Sheridan Ordin, Chief Attorney General Michael J. Strumwasser, Special Counsel to the
' Attorney General -
State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, CA 90010 David S. Fle~1schaker, Esq.
Post Office Box 1178 Oklahoma. City, 0,K 73101 E' chard Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San:JocQ,CA'.95125 Arthur:C. Gehr, Esq. '
Snell'& Wilmer 3100 Valley Center 1 Phoenix,-AZ' 85073 )
Norton,cBurke,sBerry & French, P.C.
2002 E..Osborn -
Phoenix, AZ 85064 Maurice Axelrad, Esq.
Lowenstein, Newman, Reis,&'Axelraa, P.C.
1025 Connecticut. Avenue,-N.W.
Washington, D.C.;[20036
~
Virginia and Gordon Bruno I Pecho: Ranch ' -
-Post Office Box 6289 Los-Osos, CA ,.93402
~ ,
L.' ..
Sandra and Gordon Silver 1760 Alisal Street San Luis Obispo, CA 93401 Hancy Culver 192 Luneta San Luis Obispo, CA 93402 Carl Neiburger Telegram Tribune Post Office Box 112 San Luis Obispo, CA 93402 Betsy Umhoffer 1493 Southwood San Luis Obispo, CA 93401 t$$d 17C40C/b q Christina Concepcion
- Delivered via Express Mail.
"- . _1