ML20210S993
| ML20210S993 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/03/1986 |
| From: | Connell E PACIFIC GAS & ELECTRIC CO. |
| To: | CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL |
| References | |
| CON-#486-0980, CON-#486-980 OLA, NUDOCS 8610080278 | |
| Download: ML20210S993 (12) | |
Text
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ge ATO 00CMETED USNRC 1
_ U'NITED STATES OF AMERICA NUCLEARREGULATORYCOMMISgN OCT -6 PS :08 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
Omi.i :_;
4
)
Docket Nos. 50-275 5
In the Matter of
)
50-323 - BM
)
6 PACIFIC GAS AND ELECTRIC COMPANY )
(Reracking of Spent Fuel Pools)
)
7 (Diablo Canyon Nuclear Power
)
Plant Units 1 and 2)
)
8
)
9 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S 10 ANSHERS TO FIRST SET OF INTERROGATORIES OF CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY, 11 DATED SEPTEMBER 16. 1986 12 13 INTERROGATORY NO. 1:
14 15 Provid'e beginning, ending and all other significant construction 16 dates for the fuel ponds and if constructicn stopped before completion, please 17 indicate date and reason for the interruption and justification and date for 18 resumption and provide dates and reasons for any alteration or repair to the 19 fuel ponds.
20 21 RESPONSE TO INTERROGATORY NO. 1:
22 23 Pursuant to 10 CFR 2.740(b), a party may obtain discovery regarding 24 non-priveleged matters that are relevant to the subject matter in the 25 proceeding as it relates to the claim or defense of ADy party. This 26 interrogatory, and several others of C.0.D.E.S., are not relevant, nor are 8610080278 861003 DR ADOCK 0500 5
DSo3
1 they designed to lead to the' discovery of relevant or material evidence, 2
relative to C.O.D.E.S. Contention 14 or the contentions of any of the othar 3
parties.
4 5
6 INTERROGATORY NO. 2:
7 8
Provide a list of companies who worked on the fuel ponds for both 9
design and construction, when the work was performed by each, and what the 10 work consisted of that each company did.
11 12 RESPONSE TO INTERROGATORY NO. 2:
13 14 See objection to Interrogatory No. 1.
15 16 17 INTERROGATORY NO. 3:
18 i
19 Describe how many and the location of all dissimilar metal contacts 20 in the' fuel ponds.
21 22 RESPONSE TO INTERROGATORY NO. 3:
23 24 The only dissimilar metal contact in the spent fuel pools is between 25 the carbon steel studs and the stainless steel liner, embedded plates, and 26 angles. There are numerous locations of this type of dissimilar metal
1 contact, as shown in PGandE Drawing Nos. 439501-439504 (attached).
2 3
4 INTERROGATORY NO. 4:
5 6
List the various metals and representative items of each metal used 7
in the construction of the fuel ponds.
8 9
RESPONSE TO INTERROGATORY NO. 4:
10 11 The metals and representative items of the spent fuel racks are:
i 12 13 Stainicss Steels Reoresentative Items 14 15 ASTM 240-304 Pool Liner, Embedded Plates and Angles,
'l 16 Tool and Light Brackets 17 18 ASTM 240-304L Rack Body, Rack Fixed Support Legs 19 20 ASTM 240-XM29 Rack Girdle Bars, Bridge Plates 21 22 ASTM 276-S21800 Rack Adjustable Legs (Upper Portion) 23 24 ASTM 564-630 Rack Adjustable Legs (Lower Portion) 25 26 E/ER-308L(si)
Filler Metal._,
1 ASTN 193, B8 Original Anchor Bolts (cutoff) 2 3
Carbon Steels 4
5 ASTM 615 Grades 40 and 60 Reinforcing Steel 6
7 ASTM 108 Studs on Embedded Plates and Angles 8
9 10 INTERROGATORY NO. 5:
11 12 Are manufacturer certifications (mill certs) for chemical analysis of 13 all metals used in the fuel ponds available?
14 15 (a) Here they required by any code or procedure?
16 (b) State which code or procedure required the mill certs.
17 (c) List all of the codes or procedures in (b) with their 18 appropriate dates, revisions, and revision dates.
19 (d) Did all metals used in the fuel ponds meet the required 20 specifications?
21 (e)
If (d) is yes, how do you know they met the specifications?
22 23 RESPONSE TO INTERROGATORY NO. 5:
24 25 See objection to Interrogatory No.1.
26
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1 INTERROGATORY NO. 6:
2 3
List all welding procedures, their revisions and revision dates 4
relevant to the fuel ponds.
5 6
RESPONSE TO INTERROGATORY NO. 6:.
7 8
See objection.to Interrogatory No. 1.
9 10 11 INTERROGATORY NO. 7:
12 13 Are qualification records available for all weldors used in 14 construction, alteration or repair of the fuel ponds?
15 i
16 (a) Here these records required by code or procedure?
17 (b) If the answer to 6(b) is yes, state which code or procedure and 18 list applicable dates, revisions, and revision dates.
19 20 RESPONSE TO INTERROGATORY NO. 7:
21 22 See objection to Interrogatory No. 1.
23
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1 INTERROGATORY NO. 8:
2 3
Are qualification and training records available for all quality 4
control personnel who were involved with inspections of the fuel pond work 5
from initial construction to present?
6 7
(a) Here these records required by code or procedure?
8 (b)
If answer to 8(a) is yes, state which code or procedure and list 9
applicable dates, revisions, and revision dates.
10 11 RESPONSE TO INTERROGATORY NO. 8:
12 13 See objection to Interrogatory No. 1.
14 15 16 INTERROGATORY NO. 9:
17 18 Does 10 CFR 50 Appendix B apply to work on the fuel ponds that is now 19 being done?
~
20 21 (a)
If answer to 9 is yes, at what point in time did it become a 1
22 criterion and for which units?
23 24 RESPONSE TO INTERROGATORY NO. 9:
25
)
l 26 See objection to Interrogatory No. 1..
1 INTERROGATORY NO. 10:
2 3
Have all pour cards been maintained for all concrete work on the 4
foundation for the fuel ponds?
5 6
(a) If answer is no, explain their disposition.
7 (b) Here these records required by code or procedure?
8 (c)
If answer to 10 (') is yes, state which code or procedure and o
9 list applicable dates, revisions, and revision dates.
10 11 RESPONSE TO INTERROGATORY NO. 10:
12 13 See objection-to Interrogatory No. 1.
14 i
15 16 INTERROGATORY NO. 11:
17 18 Have all results of cylinder samples of the concrete for the fuel 19 pond foundation been maintained?
20 21 (a) Here they required by any code or procedure?
22 (b)
If answer to ll(a) is yes, state which code or procedure and 23 list applicable dates, revisions, and revision dates.
24 (c) Here any results of concrete testing outside of acceptable norms.
25 (d)
If answer te ll(c) is yes, describe the disposition of each 26 instance.
1 RESPONSE TO INTERROGATORY NO. 11:
2 3
See objection to Interrogatory No. 1.
4 5
6 INTERROGATORY NO. 12:
7 8
Please list and provide copies of all documents that reflect 9
proposed, planned and/or real time activities and schedules during the current 10 refueling outage in this matter.
11 12 RESPONSE TO INTERROGATORY NO. 12:
13 14 See objection to Interrogatory No. 1.
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l 26 L
e 1
Attachments (Interroaatory No. 3) 2 3
4 Drawina No.
I1111 5
6 439501 Plan and Details - Spent Fuel Pool 7
Liner, Auxiliary Building, Area J 8
9 439502 Sections and Details - Spent Fuel Pool
~
10 Liner, Auxiliary Building 11 12 439503 Sections and Details - Spent Fuel Pool 13 Liner, Auxiliary Building, Area J 14 15 439504 Spent Fuel Pool Gate Details, Auxiliary 16 Building, Area J 17 l
18 19 20 21 22 23 4
24 25 26
1 FIRST SET OF INTERROGATORIES PROPOUNDED TO PACIFIC GAS AND ELECTRIC COMPANY 2
BY CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY 3
4 5
I have assisted in preparing the answers to Interrogatory Nos. 1 6
through 12. Said answers are true and correct to the best of my knowledge 7
and bttlef.
8 9
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10 y/ww[
11 vri G
c m n.,
12 EDHARD C. CONNELL III '
13 14 15 16 17 18 Subscribed and sworn to I
19 before me this 3rd day 20 of October,1986 21 22 23 Nancy J. Lemaster, Notary Public in and for the City and County 24 of San Francisco, State of California 25 26 Hy Commission expires April 27, 1990
{t'lilitt'Ut!!uttITilillimt'It'It*ttitttittlitnitivittcilismilmmi'.my OI-FICIAL SEAL rs
!'hp NANCY J. LEMASTER NOTAitf 908LIC.CAltFORMI4 5 ;j
city 4 COUNIV OF SAN FRANCISCO 10 -
f My Cornm ssen Empires April 27,19%
hh e.iis.u.'.16ai.hise:.;.!!tttialliittRillillellulit:lTil
,, are, romap.pONOWNW DOLHEiEP UiNRC UNITED STATES OF AMERICA 86 ET -6 P5 :08 NUCLEAR REGULATORY COMMISSION
[0CkTfdd[dh5d Docket Nos. 50-275 f
50-323 In the Matter of
)
i PACIFIC GAS AND ELECTRIC COMPANY )
(Reracking of Spent Fuel Pools)
)
(Diablo Canyon Nuclear Power
)
i Plant Units 1 and 2)
)
)
CERTIFICATE OF SERVICE l
I hereby certify that on October 3,1986, copies of the following documents in the above-captioned proceeding have been served on the following i
by deposit in the United States mail, first class:
(1) LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSWERS TO FIRST SET OF INTERROGATORIES OF THE SAN LUIS I
OBISP0 MOTHERS FOR PEACE, DATED SEPTEMBER 15, 1986; (2) LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S ANSHERS TO FIRST SET OF INTERROGATORIES OF CONSUMERS 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 served on only those indicated by an asterisk.
B. Paul Cotter, Jr., Chairman Docketing and Service Branch i
Administrative Judge Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington DC 20555 U.S. Nuclear Regulatory Commission i
4350 East West Highway 4th Floor Bethesda MD 20814 1
i Glenn O. Bright Lawrence Chandler, Esq.*
Administrative Judge Henry J. McGurren, Esq.
i Atomic Safety and Licensing Office of Executive Legal Director Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Maryland National Bank Building 4350 East West Highway 4th Floor Room 9604 Bethesda HD 20814 7735 Old Georgetown Road Bethesda MD 20814 l
Dr. Jerry Harbour Lewis Shollenberger i
Administrative Judge Regional Counsel i
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission i
Board Panel Region V i
U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 l
4350 East West Highway 4th Floor Halnut Creek CA 94596 i
Bethesda MD 20814 l
1 4
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Diablo Canyon Service List Atomic Safety and Licensing Diane M. Grueneich' Board Panel Grueneich & Lowry U.S. Nuclear Regulatory Commission 345 Franklin Street Nashington 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.0.D.E.S.
Pacific Gas and Electric Company 731 Pacific Street Suite #42 1726 M Street NH Suite 1100 San Luis Obispo CA 93401 Hashington DC 20036-4502 Managing Editor Janice E. Kerr, Esq.
San Luis Obisoo County Public Utilities Commission Telegram-Trib.Une 5246 State Building 1321 Johnson Avenue 350 McAllister Street San Luis Obispo CA 93406 San Francis'co CA 94102 Richard E. Blankenburg Nancy Culver, Co-publisher 192 Luneta Street Hayne 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 M/
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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