ML20215H669

Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence

ML20215H669
Person / Time
Site:	Diablo Canyon
Issue date:	10/20/1986
From:	Norton B PACIFIC GAS & ELECTRIC CO.
To:	Sierra Club
References
CON-#486-1227 OLA, NUDOCS 8610240082
Download: ML20215H669 (6)

Text

? h NELATED CORRESPONDD?CP DOCKETED USNPC 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 '86 0CT 23 Pl2:32 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 '

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00CMEiltu . 1 4 BRid.; '

) Docket Nos. 50-275 5 In the Matter of ) 50-323 0/J

)

6 PACIFIC GAS AND ELECTRIC COMPANY ) (Reracking of Spent Fuel Pools)

)

7 (Diablo Canyon Nuclear Power )

Plant Units I and 2) )

8 )

9 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S 10 SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SIERRA CLUB 11

> 12 Pursuant to 10 CFR 2.740b, Licensee PACIFIC GAS AND ELECTRIC COMPANY 13 hereby propounds the following interrogatories and document requests to Sierra 14 Club on its Contentions I and II.

15 INSTRUCTIONS 16 1. All information is to be divulged which is in the possession of 17 the individual, association, or corporate party, their attorneys, consultants, 18 investigators, agents, employees, witnesses or other representatives of the 19 named party.

20 2. Where you have incomplete information that precludes your fully 21 answering an interrogatory, give such information as you have and state what 22 information you do not have. If you are unable to give the information in the 23 form sought but have the information aggregated differently, give the 24 information in the form in which you have it and explain the reason for the 25 deviation.

26 3. When asked in the interrogatories below to identify or to give 8610240082 861020 DR ADOCK 0500 5 0

6 1 the identity of a person, please give the following information about him or 2 her:

3 (a) full name; 4 (b) present job title, employer, and telephone number.

5 4. When asked in the interrogatories below to identify or to give 6 the identity'of a document or writing, please give the following information 7 about the document:

8 (a) its title, if any;

'9 (b) its nature (e.g., letter, memorandum, chart, computer 10 printout, ledger, notes, etc.);

11 (c) the date, if any, stated on the document; 12 (d) the identity of each person who signed it; 13 (e) the identity of each person to whom it is addressed; 14 (f) the present location of the document.

15 . 5. Where an individual interrogatory calls for an answer which 16 involves more than one part, each part of the answer should be clearly set out 17 so that it is understandable.

18 6. These interrogatories are intended as continuing interrogatories, 19 requiring you to answer by supplemental answer, setting forth any information 20 within the scope of the interrogatories as may be acquired by you, your 21 agents, attorneys or representatives following your original answers up to the 22 time of hearing.

23 7. " Documents" include printed material, writings, calculations, 24 worksheets, handwritten notes, photographs, xerox reproductions, and audio or 25 video recordings. " Writings" and " recordings" consist of letters, words, or 26 numbers, or their equivalent, set down by handwriting, typewriting, printing, 5

1 photostating, photographing, magnetic impulse, mechanical or electronic 2 recording, or other form of data compilation, as defined in Rule 1001 of the 3 Federal Rules of Evidence, 28 U.S.C. ,

4 INTERROGATORIES 5 1. Please provide the freebody diagram and equations of motion used 6 in developing the computer program presented in Appendix A (pp. 32, 33, and 7 34) to your Response dated October 3, 1986 (" Response") to PGandE's First Set 8 of Interrogatories dated September 16, 1986.

9 2. In his time-history model (THM) (Response, p. 12), Dr. Ferguson ,

10 assumes that " half the mass of fuel moves separately" from the rack. Please 11 state each and every fact upon which that assumption is based.

12 3. Please provide initial velocities and displacements used in 13 developing the plots shown on Figure 1 and Figure 2 (pp. 29 and 30) of your 14 Response.

15 4. Dr. Ferguson asserts (Response, p. 16) that "He have constructed 16 a simple model which also results in rack displacements of several inches and 17 which predict the maximum speed for a free rack to be of the order of 24 18 inches /second" (Page 16). Please provide plots of the displacement and 19 velocity time-histories.

20 5. Dr. Ferguson asserts (Response, p.19) that "A different 21 expression for predicting fluid coupling forces between racks is currently 22 being investigated" using Bernoulli's law. Please provide the assumptions and 23 the form of Bernoulli's equation that are being used by Dr. Ferguson to 24 develop hydraulic coupling effects.

25 ///

26 ///

1 6. Please provide a diskette of Dr. Ferguson's cortputer program 2 presented in Appendix A (pp. 32, 33, and 34) of your Response.

3 -

4 Respectfully submitted, 5 BRUCE NORTON c/o P. A. Crane 6

7 ROBERT OHLBACH PHILIP A. CRANE, JR.

8 RICHARD F. LOCKE Pacific Gas and Electric Company ~

9 P. O. Box 7442 San Francisco, California 94120 10 (415) 781-4211 11 Attorneys for Pacific Gas and Electric Company 13 i 14 By Bruce Norton-15 16 DATED: October 20, 1986 18 19 20 21 22 23 24 25 26 e

+

kr.1AIED COH 3LSPONDENCE

.[

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 86 0CT 23 P4 ;52 GFFK.L - -

) Docket Nos. 09032754 -- "-

In the Matter of ) 50-32#bM

)

PACIFIC GAS AND ELECTRIC COMPANY ) (Reracking of Spent Fuel Pools)

)

(Diablo Canyon W clear Power )

Plant Units 1 ar.J 2) )

)

l CERTIFICATE OF SERVICE

~'

I hereby certify that on October 20, 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 SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SIERRA CLUB.

B. Paul Cotter, Jr., Chairman Docketing and Service Branch Administrative Judge Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington DC 20555 l U.S. Nuclear Regulatory Commission l 4350 East West Highway 4th Floor I Bethesda MD 20814 Glenn 0. Bright Lawrence Chandler, Esq.

Administrative Judge Henry J. McGurren, Esq.

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 Hest Highway 4th Floor Room 9604 Bethesda MD 20814 7735 Old Georgetown Road Bethesda MD 20814 Dr. Jerry Harbour Lewis Shollenberger i 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 Atomic Safety and Licensing Diane M. Grueneich Board Panel Grueneich & Lowry U.S. Nuclear Regulatory Commission 345 Franklin Street Washington DC 20555 San Francisco CA 94102

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Diablo Canyon Service List Atomic Safety and Licensing Jacquelyn Wheeler Appeal Board Panel 2455 Leona Street U.S. Nuclear Regulatory Commission San Luis Obispo CA 93401 Hashington DC 20555 Mr. Lee M. Gustafson Laurie McDermott, Coordinator Pacific Gas and Electric Company C.O.D.E.S.

731 Pacific Street Suite #42 1726 M Street NH Suite 1100 Hashington DC 20036-4502 San Luis Obispo CA 93401 -

Janice E. Kerr, Esq. Managing Editor Public Utilities Commission San Luis Obisco County 5246 State Building Telearam-Tribune 350 McAllister Street 1321 Johnson Avenue San Francisco CA 94102 San Luis Obispo CA 93406 Nancy Culver Richard E. Blankenburg 192 Luneta Street Co-publisher San Luis Obispo CA 93401 Wayne A. Soroyan, News Reporter South County Publishing Company P. O. Box 460 Arroyo Grande CA 93420 Dr. Richard Ferguson Dr. Howard M. Fishman

-Vice-Chairman Franklin Research Center Sierra Club 20th & Race Street Rocky Canyon Star Route Philadg1phia, PA 19103 Creston CA 93432 /l

[,' .

ejr ' . , ' /

(ljj k Richard F. Locke

.YI kOff Pacific Gas and Electric Company 77 Beale Street. 31st Floor San Francisco, CA 94106 Dated at San Francisco, California, this 20th day of October,1986.

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