ML20236C347

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Responses of PG&E to Interrogatories Filed by San Luis Obispo Mothers for Peace Dtd 750911.* Certificate of Svc Encl
ML20236C347
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 09/26/1975
From: Carroll J, Crane P, Lindblad W
PACIFIC GAS & ELECTRIC CO.
To:
SAN LUIS OBISPO MOTHERS FOR PEACE
Shared Package
ML20236A877 List: ... further results
References
FOIA-87-214 OL, NUDOCS 8707300023
Download: ML20236C347 (4)
v • d • e


Text

1

~., k . l&, *lf JNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of ) I

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50 275 OL

) 50-3 3-OL Units 1 and 2 )

)

Diiblo Canyon Site )

)

l RESPONSES OF PACIFIC GAS AND ELECTRIC COMPANY TO INTERROGATORIES FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE DATED SEPTEMBER 11, 1975

1. Please specifically identify by title and brief summary of contents, all manuals, guides, procedures, plans, and other documents and texts l which will be required to be in the control room (and/or associated l offices) for the use of senior control operators during l A. Initial fuel loading B. Startup and power ascension C. Commercial operation

RESPONSE

See PGandE's response dated November 8, 1974 to Interrogatory 21.

2. Please answer interrogatory no. 1 for the case of the chief

' Startup Engineer.

RESPONSE

I See PGandE's response dated November 8, 1974 to Interrogatory 21 which is also appropriate for the Chief Startup Engineer.

3. Please answer interrogatory no. 1 for the case of Plant Superintendent.

RESPONSE

See PGandE's response dated November 8, 1974 to Interrogatory 22.

B707300023 870721 #

Q PDR FOIA PDR CONNORB7-214 L_

4. Please provide accurate response without errors to question nos.

24 and 25 of J. J. Forster's Interrogatories, 6-27-75

RESPONSE

In our response, dated June 27, 1975, to these interrogatories the numerator was inadvertently omitted in the right-hand side of the second equation given. For corrected response see attachment dated 9/26/75.

5. Provide response to Interrogatory 47 and 48 of JJF dated 6-27-75. i Note that question i's no less relevant to this proceeding than Diablo FSAR to which the interrogatory is addressed. Note also that the Presiding Board has admitted for purposes of discovery contentions related to high-dose producing incidents as well as low-level situations.

RESPONSE ,

PGandE submits that experience at the Humboldt Bay Power Plant is not relevant to the Diablo Canyon licensing proceeding. In ,

addition, PGandE submits that the Interrogatories do not present issues within the MFP contentions accepted for purposes of dis-covery. j l

6. Please provide Intervenor with a copy of WCAP 8362 (17 X 17  !

I

. verification).

RESPONSE

A copy of WCAP 8362 is attached.

7. Reference response to MFP Interrogatory 14E, June 19, 1975 [ sic)

(6/27/7 5) . Under what circumstances would PG&E allow other nuclear units with storage racks similar to Diablo, to use Diablo's storage facilities for storing spent fuel?

RESPONSE

There is no Interrogatory 14E in the June 19, 1975 interrogatories, to which PGandE responded on July 18, 1975. However, the inter-rogatories filed on behalf of John J. Forster dated May 13, 1975, to which PGandE responded June 27, 1975, do contain an Interrogatory 14E which appears to relate to Interrogatory 7.

2

ATTACHMENT TO RESPONSE TO INTERROGATORY 4 DATED 9/11/75

.- l

_ i log a o = -

(b + 3 ) + 0.OlM - 0.027M ,

do a =

,t Y '

where: ao = peak circund acceleration at the epicenter in gravity units a = peak ground accoloration at the site in gravity units

! E = site factor froia Figure 1-M = carthquake magnitude on the Richter scalc s' . .

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(No change)

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FIG. / -

DETERMINATION OF SITE FACTOR, b 2-a (Dated 9/26/75)

PGandE is not in the fuel storage business, and it is difficult- i to visualize the circumstances under which PGandE would store fuel- of others at Diablo Canyon.- However, it is conceivable ,

l that in a storage emergency, such as presently exists with '

respect to. PGandE's Unit 1 fuel, PGandE would store another utility's fuel at Diablo Canyon provided, of course, that space was available. Any such storage would be in accordance with:

PGandE's license and applicable regulations.

We' declare under penalty of perjury that the foregoing Responses To Interrogatories are true and correct to the best of our knowledge, information, and belief.

kW -

~~jndblad n en James C. . Carroll riv;ecc Engineer Supe [rvisingSteamGeneration Units 1 and 2 Engineer-Diablo Canyon Site Pacific Gas and Electric Company Respectfully submitted,

. JOHN C. MORRISSEY PHILIP A. CRANE, JR.

DENNIS C. SULLIVAN BRUCE R. WORTHINGTON ,

By b /1/t%:4# ,

Philip /A . Crane, Ur.

Attorneys for Pacific Gas and Electric Company-77 Beale Street San' Francisco, California 94106 415-781-4211 Dated: September 26, 1975 3

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