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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20045D8561993-06-21021 June 1993 San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related Correspondence ML20045D8291993-06-18018 June 1993 Response to Third Set of Suppl Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6751993-06-0404 June 1993 Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence ML20045A6401993-05-26026 May 1993 PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence ML20044F7701993-05-21021 May 1993 Intervenor San Luis Obispo Mothers for Peace Second Set of Supplemental Interrogatories & Requests for Production of Documents to Pge Cable Failures at Diablo Canyon Nuclear Power Plant.* W/Certificate of Svc.Related Correspondence ML20056C1891993-03-10010 March 1993 Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence ML20128P2251993-02-16016 February 1993 Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories & Requests for Production of Documents to Pg&E.* PG&E Should Answer Interrogatories within 14 Days.W/Certificate of Svc.Related Correspondence ML20213E5791986-11-0606 November 1986 Response to Util Second Set of Interrogatories Re Reracking of Spent Fuel Pools.Equations of Motion Appear in Encl Computer Program.W/Proof of Svc ML20213E6091986-11-0606 November 1986 Response to NRC Second Set of Inerrogatories Re Proposed Reracking of Spent Fuel Pools.Not Possible to Either Identify or Supply All Ref Documentation Supporting Contentions.W/Proof of Svc.Related Correspondence ML20213E6201986-11-0606 November 1986 Response to NRC Second Set of Interrogatories.Contentions Re Proposed Reracking & Alternatives Based on Understanding of Existing Industry Practice & Currently Available Technology. W/Proof of Svc.Related Correspondence ML20213F5851986-11-0505 November 1986 Suppl to 861003 Response to Intervenors 860916 First Set of Interrogatories Re Metals Used in Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20213F5011986-11-0505 November 1986 Response to 861017 Second Set of Interrogatories Re Seismic Analysis of High Density Fuel Racks for PG&E for Diablo Canyon Nuclear Power Station & Request for Production of Documents.W/Certificate of Svc.Related Correspondence ML20211E2121986-10-20020 October 1986 Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence ML20215H6691986-10-20020 October 1986 Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence ML20211E1721986-10-20020 October 1986 Second Set of Interrogatories Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses on Spent Fuel Pool.Related Correspondence ML20211E1871986-10-20020 October 1986 Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence ML20210S8921986-10-0606 October 1986 Response to Util Interrogatories Re Preparation for Upcoming Safety Hearings on Reracking of Spent Fuel Pools.Safety Issues Should Be Considered Before Amend Accepted.W/ Certificate of Svc.Related Correspondence ML20210S9651986-10-0606 October 1986 Answers to Sierra Club 860915 First Set of Interrogatories Re Reracking of Spent Fuel Pools.W/Certificate of Svc. Related Correspondence ML20210T2611986-10-0606 October 1986 Response to NRC Interrogatories on Contention 1 Re Util Responsibility to Demonstrate Safety of High Density Reracking.Intervenors Not Responsible for Solving Waste Storage Problem.W/Certificate of Svc.Related Correspondence ML20210S9711986-10-0303 October 1986 Response to Util & NRC First Set of Interrogatories & Request for Production of Documents.Interrogatories Opposed for Reasons Indicated.Certificate of Svc Encl.Related Correspondence ML20210T0731986-10-0303 October 1986 Response to Interrogatories & Request for Production of Documents Re Alternatives to High Density Reracking of Spent Fuel Pool at Facilities.Certificate of Svc Encl.Related Correspondence ML20210T0221986-10-0303 October 1986 Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence ML20210S9241986-10-0303 October 1986 Response to San Luis Obispo Mothers for Peace First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20206U7481986-10-0303 October 1986 Response to 860916 Interrogatories & Request for Production of Documents Re Licensing Proceedings.Certificate of Svc Encl.Related Correspondence ML20210S9931986-10-0303 October 1986 Response to Consumers Organized for Defense of Environ Safety First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20210T0541986-10-0303 October 1986 Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20210B7341986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc ML20214P8291986-09-16016 September 1986 Requests Response to Listed Interrogatories Re Design & Const of Fuel Ponds.Certificate of Svc Encl.Related Correspondence ML20214Q3521986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210B6321986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds ML20214Q3781986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions I & II Concerning Reracking of Spent Fuel Pools.Notice of Change of B Norton Address & Certificate of Svc Encl.Related Correspondence ML20210B6701986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools ML20214Q2981986-09-16016 September 1986 First Round of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20214Q3621986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210E1781986-09-15015 September 1986 Interrogatories & Request for Production of Documents Re Theoretical Work Concerning Displacement of High Density Spent Fuel Racks Due to Hypothetical Seismic Excitation. W/Certificate of Svc.Related Correspondence ML20214R1401986-09-15015 September 1986 Interrogatories Requesting All Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools, Dry Cask Onsite Storage & Cost/Benefit Assessment on Reracking.Certificate of Svc Encl.Related Correspondence ML20214R2341986-09-15015 September 1986 Interrogatories Requesting Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools & Dry Cask Onsite Storage as Alternative to High Density Reracking.Certificate of Svc Encl.Related Correspondence ML20081D7851983-10-26026 October 1983 Request for Production of Documents by NRC at 831107 Hearing in Avila Beach,Ca.Certificate of Svc Encl ML20080S2831983-10-14014 October 1983 Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20080Q3741983-10-0707 October 1983 Second Supplemental Answers to First Set of Interrogatories. Certification of Counsel & Prof Qualifications Encl ML20080Q3851983-10-0707 October 1983 First Supplemental Answers to Second Set of Interrogatories. Certification of Counsel Encl ML20080Q3951983-10-0707 October 1983 First Supplemental Answers to Fourth Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl ML20085J5951983-10-0707 October 1983 Fifth Supplemental Response to First Set of Interrogatories. Portions of RB Hubbard & Fj Samaniego 821221 Direct Testimony & Certificate of Svc Encl ML20080Q4441983-10-0505 October 1983 Response of Idvp to Interrogatory 57 in Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20078E1861983-10-0303 October 1983 Fourth Supplemental Response to First Set of Interrogatories.Certificate of Svc Encl ML20078D5091983-09-29029 September 1983 Supplemental Response to Second Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl.Related Correspondence ML20080M8521983-09-28028 September 1983 First Supplemental Answers to Third Set of Interrogatories. Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20078E1331983-09-28028 September 1983 First Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20080L5721983-09-26026 September 1983 Response to Fourth Set of Interrogatories.Certification of Counsel & Certificate of Svc Encl ML20078B8021983-09-23023 September 1983 Idvp Answers to First Set of Interrogatories.Certificate of Svc Encl 1993-06-04
[Table view] 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] |
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g,,,cne *4M a 00LKETED usHRC 1
UNITED STATES OF AMERICA 86 0CT -6 P5:08 2 NUCLEAR REGULATORY COMMISSION 3 0FFKE 0 BEFORE THE ATOMIC S$FETY AND LICENSING 4
5 ) Docket Nos. 50-275 In the Matter of ) 50-323 -dM 6 -)
PACIFIC GAS AND ELECTRIC COMPANY ) (Reracking of Spent Fuel Pools) 7 )
(Diablo Canyon Nuclear Power )
8 Plant Units 1 and 2) )
)
9 10 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO FIRST SET OF INTERROGATORIES 11 0F THE SAN LUIS OBISPO MOTHERS FOR PEACE, DATED SEPTEMBER 15. 1986 12 33 14 INTERROGATORY NO. 1:
15
- 16 Identify and supply all documents, including but not limited to 17 reports, analyses, meeting summaries, memorandums, and portions thereof, 18 relied upon to evaluate the alternatives to high density re-racking of the 19 spent fuel pools at Diablo Canyon nuclear plant.
20 21 RESPONSE TO INTERROGATORY NO. 1:
22 23 PGandE's evaluation of alternatives was based on an understanding of i
24 the existing industry practice and, in general, the currently available 25 technology for the storage of spent fuel. This understanding was derived from 26 a review of the existing literature on reracking amendments submitted by other 8610080258 861003 PDR ADOCK 05000275
- O PDR
1 utilities which had been previously filed with and issued by the NRC, generic 2 research documentation generated by the federal government pursuant to the l 3 Nuclear Maste Policy Act of 1982, and other industry sources discussing spent 4 fuel storage alternatives. These sources also included periodicals of the 5 nuclear industry, technical reports issued by the NRC, and other documents 6 related to storage of spent fuel. While these sources provided a general 7 understanding of the available alternatives, PGandE performed a specific 8 review of alternatives for Diablo Canyon. Since the evaluation was performed 9 with this basic understanding, it was deemed not necessary to document each -
10 aspect of the evaluation; therefore, it is not possible to either identify or 11 supply all of the reference documentation. However, specific documents that 12 are available and which are directly related to the evaluation of alternatives 13 at Diablo Canyon are listed on page 4 and attached to this response.
14 15 16 INTERROGATORY NO. 2:
17 18 Identify and supply all information and documents relied upon to 19 evaluate dry cask on-site storage as an alternativo to high density
! 20 re-racking.
21 22 RESPONFE TO INTERROGATORY NO. 2:
23
- 24 See response to Interrogatory No. 1.
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- 1 1 INTERROGATORY NO. 3:
2 3 Supply the cost-benefit assessment done by PGandE on re-racking and 4 alternatives to it. (referred to in Rerackina of Soent Fuel Pools. Diablo 5 Canyon Units 1 and 2. Seotember.1985) 6 -
7 RESPONSE TO INTERROGATORY NO. 3:
8 9 See response to Interrogatory No. 1. '
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.e 1 Documents Produced for Interroaatories 1. 2 and 3 i 2
- 1. Distribution of Job Estimate, PGandE NPG-041, February 14, 1984 3
4 2. PGandE Memorandum, J. D. Shiffer to J. O. Schuyler, " Question on Dry Cask Storage," Letter No. 83/21-14; May 21, 1983, 2 pages 5
6 3. Draft PGandE Report on Spent Fuel Rack Addition Description and Safety Analysis, November 1979; with markups 7
8 4. PGandE Memorandum on Vendor Presentation on Spent Fuel Storage and Transport, August 4, 1981 9
10 5. Job Estimate, Replace Spent Fuel Storage Racks with High Density Racks, PGandE NPG-041, 1982; with draft 11
, 12 6. PGandE Project / Activity Justification for Spent Fuel Modification,
- October 6, 1983.
13 14 7. Draft Proposal for Spent Fuel Modifications, PGandE, October 6,1983.
15
- 8. Economics of At-Reactor Spent Fuel Storage Alternatives, E. T. Merrill 16 and J. F. Fletcher, April 1983 17
- 9. PGandE Memorandum on Spent Fuel Rack Modification, High-Density Racks, GM Cost Estimate NPG-041, October 21, 1983 18 19
- 10. PGandE Job Estimates submitted to the Board of Directors for review, l 20 Spent Fuel Rack Modifications, February 15, 1984 ,
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1 FIRST SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY 2 BY SAN LUIS OBISP0 MOTHERS FOR PEACE 3
4 5 I have assisted in preparing the answers to Interrogatory Nos. 1, 2, 6 and 3. Said answers are true and' correct to the best of my 7 knowledge and belief.
8 9
10
/4Y 12 S /RYANT H. GIFFIN W 13 14 15 16 17 18 Subscribed and sworn to 19 before me this 3rd day 20 of October, 1986 21 22 =&7/0 C
23 Nancy J. Lemaster, Notary Public SEAL in and for the City and County 24 of San Francisco, State of California 25 26 My Commission expires April 27, 1990 PjrtitintinteWIu'titttlittlilitettlitittittitinlitIHit!!Jftllfill!!!!..ll!
5 -
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5 .4 NANCY J. LEMASTER NOTARt PUBUC CAltf0dNIA y a
3 de/ CITY 4 COUNTY OF SAN FRANCliC0g
- ~
l My Commession Empires Apnl 27,1990 $
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1 FIRST SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY 2 BY SAN LUIS OBISPO NOTHERS FOR PEACE 3
4 5 I have assisted in preparing the answers to Interrogatory Nos. 1, 2, 6 and 3. Said answers are true and. correct to the best of my 7 knowledge and belief.
8 9 -
10 t ;1X&Os 12 E0HARD C. CONNELL III 13 14 15 16 17 18 Subscribed and sworn to 19 before me this 3rd day 20 of October, 1986 21 22 .
23 Na y J. Lemaster, Tdfary PubH c in and for the City and County 24 of San Francisco, State of SEAL California 25 26 My Commission expires April 27, 1990 (mtlNttittl!!!!!!!IlittiliitttttfitglinHINI, E OFFICIAL SEAL M M4 NANCY J. LEMASTER l j7t<j'4 NOTARY PUBUC.CAUFORNIA CITY & COUNTY OF SAN f RANCISCO g _ _
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, UNITED STATES OF AMERICA '86 (ET -6 P5.08 NUCLEAR REGULATORY COMISSION f
I
{0CET !$ib BRANCH
) Docket Nos. 50-275 In the Matter of ) 50-323
)
PACIFIC GAS AND ELECTRIC COMPANY ) (Reracking of Spent Fuel Pools)
)
j (Diablo Canyon Nuclear Power )
Plant Units 1 and 2) )
)
1 CERTIFICATE OF SERVICE I I hereby certify that on October 3,1986, copies of the following documents in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class: (1) LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSHERS TO FIRST SET OF INTERROGATORIES OF THE SAN LUIS i OBISPO MOTHERS FOR PEACE, DATED SEPTEMBER 15, 1986; (2) LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSHERS TO FIRST SET OF INTERROGATORIES OF CONSlI1ERS
, ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY, DATED SEPTEMBER 16, 1986; and (3) LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSHERS TO FIRST SET OF INTERROGATORIES OF THE SIERRA CLUB, DATED SEPTEMBER 15, 1986. The production of documents associated with the interrogatories have been serveo on only those indicated by an asterisk.
j 4
! B. Paul Cotter, Jr., Chairman Docketing and Service Branch t Administrative Judge Office of the Secretary i Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Hashington DC 20555 U.S. Nuclear Regulatory Commission 4350 East West Highway 4th Floor Bethesda MD 20814 Glenn 0. Bright Lawrence Chandler, Esq.*
l l Administrative Judge Henry J. McGurren, Esq.
l Atomic Safety and Licensing Office of Executive Legal Director Board Panel r U.S. Nuclear egulatory Commission U.S. Nuclear Regulatory Commission Maryland National Bank Building 4350 East West Highway 4th Flocr Room 9604 Bethesda MD 20814 7735 Old Georgetown Road Bethesda MD 20814 Dr. Jerry Harbour Lewis Shollenberger Administrative Judge Regional Counsel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 4350 East West Highway 4th Floor Halnut Creek CA 94596 Bethesda MD 20814
a Diablo Canyon Service List Atomic Safety and Licensing Diane M. Grueneich*
Board Panel Grueneich & Lowry U.S. Nuclear Regulatory Commission . 345 Franklin Street Hashington DC _20555 - San Francisco CA 94102 Atomic Safety and Licensing Jacquelyn Wheeler Appeal Board Panel 2455 Leona Street U.S. Nuclear Regulatory Commission San Luis Obispo CA 93401 Washington DC 20555 ,
Mr. Lee M. Gustafson C.O.D.E.S.
Pacific Gas and Electric Company 731 Pacific Street Suite #42 1726 M Street NH Suite 1100 San Luis Obispo CA 93401 Washington DC 20036-4502 Managing Editor Janice E. Kerr, Esq. San Luis Obisoo County Public Utilities Commission Telearam-Tribune 5246 State Building 1321 Johnson Avenue 350 McAllister Street San Luis Obispo CA 93406 San Francisco CA 94102 Richard E. Blankenburg Nancy Culver, Co-publisher 192 Luneta Street Wayne A. Soroyan, News Reporter San Luis Obispo CA 93401 South County Publishing Company P. O. Box 460 Arroyo Grande CA 93420 Dr. Richard Ferguson*
Vice-Chairman Sierra Club Rocky Canyon Star Route Creston CA 93432 kA - . V i Richard F. Locke
- Pacific Gas and Electric Company 77 Beale Street. 31st Floor San Francisco, CA 94106 Dated at San Francisco, California, this 3rd day of October,1986.
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