ML20024E805

Answers to Second Set of Interrogatories Re Design Qa. Certificate of Svc Encl

ML20024E805
Person / Time
Site:	Diablo Canyon
Issue date:	08/31/1983
From:	Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:	PACIFIC GAS & ELECTRIC CO.
References
ISSUANCES-OL, NUDOCS 8309070087
Download: ML20024E805 (25)

Text

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00CKCTED UNITED STATES OF AMERICA llSNRC NUCLEAR REGULATORY COMMISSION- _g BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD OChhT NG 3 RANCH hy['

)

In the Matter of )

) ,s PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) ) (Reopened Hearing --

) Design Quality

) Assurance)

JOINT INTERVENORS' RESPONSE TO PACIFIC GAS AND ELECTRIC COMPANY'S SECOND SET OF INTERROGATORIES Joint'Intervenors submit the following response to Pacific Gas and Electric Company's ("PGandE") Second Set of Interrogatories.

RESPONSE TO INTERROGATORY NOS. 1-70, 77, 78:

Based on the pre-hearing conference of August 23-24,

! 1983, and the August 16 and 26, 1983 orders of the Appeal Board, i

l these interrogatories have been rendered irrelevant in light of the concession by PGandE that it will not contest the existence of deficiencies in its design QA/QC programs. Instead, the work l

l of the IDVP and ITP will be offered as an " affirmative defense" to such deficiencies. Further, the Board ruled that the Joint l

l Intervenors' contention regarding nonsafety-grade SS&C's important to safety is outside the scope of the reopned proceeding; thus, interrogatories directed to that issue are also irrelevant.

8309070087 830831 gDRADOCK 05000275 l PDR

RESPONSE TO INTERROGATORY NO. 71:

.See response to Interrogatory No. 73. In addition, the ITP is a Diablo Canyon Project ("DCP") internal program. To-the extent that PGandE wishes to rely on its work to meet its burden in this proceeding'it is entitled to do so, but must demonstrate the accuracy, reliability,.and sufficiency of that effort to provide the requisite reasonable assurance. PGandE's past failures to comply with applicable regulatory standards provides reason.for concern that the ITP's activities may be similarly flawed. Further, the extent of the redesign, the large number of modifications, and the unprecedented number of workers on-site (in excess of 7,000) provide a reason'for-concern that the ITP may be sacrificing quality for speed in a manner similar to that demonstrated during the CQA mini-hearing.

i A number of the Joint Intervenors' concerns regarding the ITP are specified in the proposed contention set forth in the August 26, 1983 Order of the Appeal Board. Those, and further

inadequacies of the ITP, and the facts which establish those f inadequacies, have been outlined in many of the documents .

[

described in response to Interrogatory No. 73.

See also further answers infra. Final conclusions regarding the inadequacies of the ITP and IDVP will be stated once our review has been completed. We will supplement our l

l responses at that time.

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l RESPONSE TO INTERROGATORY NO. 72:

See responses to Interrogatory Nos. 71 and 73.

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r,y 8 s RESPONSE TO INTERROGATORY NO. 73:

The Joint Intervenors' review of the IDVP is continuing. However, based on our review to date, the inadequacies of the IDVP are set forth in the contention filed on July 19, 1983 and subsequently amended and proposed during the pre-hearing conference of August 23-24, 1983. Those and further inadequacies of the IDVP, and the facts which establish those inadequacies, have been outlined in:

(1) May 28, 1982 letter, Reynolds to Denton, regarding lack of independence, schedule pressure, document access by intervenors, meeting access by intervenors, reporting and recording of information, access to information, deviations from licensing criteria; (2) August 2, 1982 letter, Reynolds to Commissioners, regarding BNL findings and failure of IDVP to discover fundamental flaws in seismic design, access to information by intervenors, invalidity of Phase I and II dichotomy, failure to require DCP use of 3-D modelling techniques, need for CQA audit, need for physical inspection of "as-built" (redesigned and modified) facility, need for expansion of BNL role in audit; (3) June 23, 1983 and August 10, 1983 letters, Reynolds to Denton, regarding lack of independence between DCP and IDVP; (4) February 5, 1982 letter, Fleischaker to Commissioners, regarding lack of independence between RLCA (IDVP) and PGandE;

• ^ e (5) October 30, 1981 letter, Brown to Palladino, regarding selection of an independent auditor, scope of design review; (6)' January'15,'1982 letter, Brown to Commissioners, regarding scope of review, need for CQA review, need for specification of sampling criteria, specific comments re PGandE proposed design verification program; (7) February 25, 1982 letter, Brown to Commissioners, regarding scope of review, CQA review absence, inadequacy of sample size, lack of technical basis for acceptance criteria, inadequate extent and depth of program, inappropriateness of Phase I/ Phase II dichotomy.

(8) August 2, 1982 comments, Brown to Denton, regarding Phase II Management Plan, including errors disclosed, BNL findings, inappropriateness of Phase I/ Phase II dichotomy, need for CQA audit, expansion to include nonsafety-grade SS&C's important to safety; specific comments re representative sample, acceptance criteria, clarity of IDVP documents, statistical basis for sampling, access to documents; (9) Supplemental Affidavit of Richard B. Hubbard Concerning Breakdowns in Diablo Canyon Quality Assurance Program (March 26, 1983), regarding discovery of seismic design errors by BNL rather than IDVP (5-11), failure of PGandE to address root cause of errors (10-12), substantial modification of facility and resulting change in TES role

• ,o (13-14), limited Phase II verification effort and need to expand scope to include 100% verification'of non-seismic based on errors to date (21-24), need to address nonsafety-grade components important to safety (28-42), need for statistically valid sampling techniques (33-35);

(10) NRC Staff SSER 18, passim, regarding incomplete nature of the review (seismic and nonseismic);

(11) BNL July 1982 Report, passim, and July 27, 1982 meeting, regarding inaccuracies in PGandE calculation of vertical response spectra for annulus area, Unit 1 containment, not detected by IDVP; (12) February 15, 1983 Meeting regarding BNL findings on inaccurate PGandE calculation of horizontal response spectra for annulus area, Unit 1, not detected in IDVP; (13) April 1, 1982 Meeting regarding Reedy Review, and TES attempts to minimize significance of findings; (14) September 1, 1982 Meeting regarding status, including discussion regarding extent of nonseismic QA l deficiencies; (15) January 13, 1983 Meeting regarding status, including report on extent of modifications and IDVP comments minimizing significance of nonseismic design errors discovered; (16) Draft ITR -- Phase II, Additional Sample and Additional Verification (12/23/82), regarding extent and nature of nonseismic errors;

(17) ITR-34, Rev. O, Verification of Diablo Canyon Project Efforts by SWEC, regarding nonseismic review.

(18) July 6, 1983 Meeting regarding BNL findings on buried tanks, not detected by IDVP; (19) Governor Deukmejian's First Supplemental Answers to Applicant's First Set of Interrogatories, Exhibit 14-1, regarding disagreement with ITR's; (20) IDVP Final Report, S 7.1, regarding compliance with PGandE's schedule; S 2.0, regarding conclusions; passim, regarding incomplete status of review, adequacy of scope and extent of review, S 3.5, regarding verification of corrective action; (21) ITR's 8 and 35, regarding failure to specify sampling criteria and statistical basis for conclusions; (22) IDVP Program Plans, Phase I and Phase II, regarding failure to require adequate scope or to define sampling and acceptance criteria and justification for them; (23) November 10, 1982 Meeting with Commission, including presentations by Hubbard and Roesset regarding status, scope, content and implementation of audit, content and comprehensibility of ITR's, and appropriateness of DCP modelling and IDVP review of it; (24) Each of the EOI's issued 'y 3 the IDVP arising out of the CAP, each of which suggests a continuing failure by PGandE and the DCP to implement an adequate QA program, as well as a failure by the IDVP to review adequately the

-CAP QA program.

Although the Joint Intervenors have attempted to the extent possible to provide the information requested by this interrogatory, the list cannot be inclusive. Under the circumstances of this proceeding, it is simply impossible to list each and every fact (or document that contains such facts) upon which the Joint Intervenors intend to rely. The'IDVP has been in existence for almost two years and the ITP for a year and a half. There are numerous meeting transcripts, EOI's, IDVP and DCP reports, NRC inspection and trip reports, and correspondence which relate directly to the matters in issue.

PGandE has copies of each and every one of them and is equally able to ascertain what aspects of those documents and what specific facts suggest inadequacies in the IDVP and ITP and, further, which of those are relevant to the proposed contentions.

See also further answers infra. Final conclusions regarding the inadequacies of the IDVP review will be stated once our review has been completed. We will supplement our i responses at that time.

RESPONSE TO INTERROGATORY NO. 74:

See Response to Interrogatory No. 73.

RESPONSE TO INTERROGATORY NO. 75:

In addition to the allegations set forth in the D

contention outlined by the Board in its August 26, 1983 Order, the scope of the IDVP's review is inadequate most obviously in its failure to require 100% reverification of all structures, systems, and components important to safety. Even within the limited category of safety-related SS&C's, however, it fails to require 100% reverification of nonseismic SS&C's, a shortcoming not consistent with the extent and generic nature of the errors disclosed to date. Its scope is also inadequate in that it fails to require a sufficiently thorough and comprehensive verification of the design and installation of all modifications to the facility implemented by the ITP. Further, it fails to require completion, verification, and approval of all analyses related to SS&C's within its scope, as well as the installation, verification, and approval of all modifications to such SS&C's, prior to any recommendation regarding licensing. It fails to include a thorough examination of root causes and generic implications of all deficiencies in compliance with the regulations and licensing criteria, and it fails to verify independently, as has BNL, the accuracy of the redesign by the DCP. Further, its scope is inadequate in that it has failed to require use of statistically valid sampling techniques in its review, thereby undermining the validity of its conclusions. It has failed to include any review of the extent to which production and QA/QC are independent during the CAP, and the QA/QC review of that program failed to consider adequately the generic nature of its " observations." The recent EOI's issued by RLCA indicate potentially significant deficiencies in the CAP work.

The IDVP Program Plan, ITR-8, and the IDVP Final Report furnish further basis for the Joint Intervenors' contention regarding the manner in which the~ scope of the IDVP to verify certain design activities renders it an insufficient substitute for,-or supplement to, PGandE's admittedly deficient design quality assurance program. Given the failures described above, there can be no assurance, analogous to that provided by compliance with Appendix B, that the Diablo Canyon Nuclear Power Plant ("DCNPP") is designed in accordance with regulatory requirements and license commitments.

See also response to Interrogatory No. 73 supra and further answers infra. Final conclusions regarding the inadequacies of the IDVP scope will be stated once our review has been completed. We will supplement our responses at that time.

RESPONSE TO INTERROGATORY NO. 76:

See Response to Interrogatory Nos. 73 and 75.

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! RESPONSE TO INTERROGATORY NO. 79:

The fact that sampling is being used by the IDVP has l

been repeatedly stated in its Program Plans, its Final Report, ITR-8, ITR-35, virtually all of the ITR's issued, and at numerous meetings with the NRC, including the September 1, 1982, and January 13, 1983 meetings in San Francisco, That the IDVP -

is using sampling rather than 100% reverification of nonseismic SS&C's cannot reasonably be disputed.

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RESPONSE TO INTERROGATORY-NO. 80:

-See Response to Interrogatory Nos. 73 and 79, supra.

RESPONSE TO INTERROGATORY NO. 81:

This allegation is based on the absence of a sufficient description of the sampling criteria, and the statistical bases therefor, contained in the IDVP Program Plan, the ITR's-issued to date, the IDVP Final Report, and the various meetings at which IDVP representative have given presentations (i.e., 9/1/82; 1/13/83). The inadequacies in the descriptions given have been repeatedly stated by the Joint Intervenors and the Governor. See, e.g., the Hubbard Supplemental Affidavit, supra, at paragraphs 43-44; 8/11/82 Comments by Governor Brown, at 10.

! See also resonse to Interrogatory No. 73 supra and further answers infra. Final conclusions regarding the criteria i

( for sampling will be stated once our review has been completed.

We will supplement our responses at that time.

RESPONSE TO INTERROGATORY NO. 82:

See Response to Interrogatory No. 81.

RESPONSE TO INTERROGATORY NO. 83:

This contention is based on the fact that the IDVP did not independently devise models for certain SS&C's at Diablo Canyon to verify the models utilized by PGandE in the recalculation of the facility's seismic design. The only independent organization to do so has been BNL, and its results provide a clear factual basis to question _the' accuracy of PGandE's models. The IDVP failed to discover the inaccuracies.

Rather, the IDVP merely reviewed the data of PGandE's inputs to these models. Specific examples of this inadequacy and of certain invalid engineering assumptions that were used by the ITP without meaningful independent evaluation are specified in contentions 3 (a) through 3 (n) , as stated in the Board's August 26 Order. The specific boundaries of the IDVP review are still being reviewed. Because the IDVP review of key aspects of the redesign are not complete, the Joint Intervenors are unable to provide a complete answer at this time. This answer will be supplemented once further information is acquired. See also response to Interrogatory No. 73, supra.

RESPONSE TO INTERROGATORY NO. 84:

This allegation is based on the IDVP Program Plan, the ITR's issued to date, the IDVP Final Report, and discussions at various IDVP meetings, including the untranscribed meetings at Bechtel's offices in San Francisco in late April 1983.

i RESPONSE TO INTERROGATORY NO. 85:

The recent EOI's issued by RLCA indicate potentially significant deficiencies in the work done by the CAP, deficiencies not identified and remeaied by the CAP QA program.

Further, the 24 " observations" found by R.F. Reedy were not considered for their generic significance with regard to the

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adequacy of the QA/QC program, and hence there is:no confidence that more;significant yet undiscovered deficiencies in the-QA program -- and, as a result, in the facility - -do not.also exist. In addition, the extent of the CAP and the unprecedented number of workers -- many of whom have been working hours-substantially in excess of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week -- suggest the probability that deficiencies exist in the work that would not otherwise exist under normal conditions. A good example of the adverse effects of such production pressure was highlighted at the CQA mini-hearing with regard to H.P. Foley Company.

Further, the use of sampling by the IDVP, the failure to specify

. in detail the sampling criteria used, and failure to state the statistical bases, if any, for its findings, renders questionable the accuracy of the IDVP's findings regarding the CAP QA program.

See also response to Interrogatory No. 73 supra.

Final conclusions'regarding the inadequacies of the CAP will be stated once our review has been completed. We will supplement

,our responses at that time.

RESPOSNE TO INTERROGATORY NO. 86:

See Response to Interrogatory No. 8. See also ITR-41.

RESPONSE TO INTERROGATORY NO. 87:

The findings of BNL are summarized by the NRC Staff in SSER 18, at C-3-81 et seg. Its vertical seismic analysis and results nad its seismic analyses of PGandE's piping systems are

• O reported in NUREG/CR-7834. Its horizontal seismic analysis findings were discussed at a meeting in Bethesda on February 15, 1983, and its findings regarding buried tanks were discussed in a meeting in Bethesda on July 6, 1983. None of the documents issued to date specifies what aspects, !? any, of the BNL work have been incorporated by the DCP in its analyses, or even to what extent changes have resulted from the BNL work. At a deposition on August 26, 1983, Dr. William White testified that the DCP had made no attempt to apply the BNL findings generically to other SS&C's at Diablo Canyon. Although he was able to identify certain changes to the DCP models attributable at least in part to the BNL findings, he disagreed with a number of BNL's findings. The Joint Intervenors believe that all BNL findings which indicate that PGandE's models represent less conservative assumptions than those of BNL should be incorporated into the DCP models through revisions to ensure that the full measure of conservatism deemed appropriate by BNL is applied by the DCP in its models. It is difficult at this stage to specify precisely the extent to which the BNL work has been disregarded by the DCP.

See also response to Interrogatory No. 73 supra.

Final conclusions regarding the extent to which BNL's conclusions have been utilized will be stated once our review has been completed. We will supplement our responses at that time.

s RESPONSE TO INTERROGATORY NO. 88:

The redesign of the facility has been necessitated by a breakdown in the Diablo Canyon QA programs. BNL's work is a benchmark to determine the accuracy of the redesign. Thus, incorporation of BNL's findings into the models is required by the regulations in order to ensure that, notwithstanding such breakdown, an equivalent level of protection of the public and assurance of proper design exists.

RESPONSE TO INTERROGATORY NO. 89:

See Appeal Board orders dated August 16 and 26, 1983.

RESPONSE TO INTERROGATORY NO. 90 The IDVP has given no indication of the extent to which BNL's work has been incorporated into the Diablo Canyon design. Although the IDVP's review of most of the areas covered by the BNL work is incomplete, its initial comments following issuance of the BNL report in July 1982 attempted to minimize i

their significance and adopted essentially the position taken by l

PGandE in its response to the BNL report. See October 15, 1982 Letter, Cooper to Denton; July 8, 1982 Letter, Maneatis to Cooper.

See also responses to Interrogatory Nos. 73 and 87 supra. Final conclusions regarding the DCP use of BNL findings will be stated once our review has been completed. We will supplement our responses at that time.

I

RESPONSE TO INTERROGATORY NO. 91:

See Response to Interrogatory No. 90.

RESPONSE TO INTERROGATORY NO. 92:

The most recent of the IDVP semi-monthly status reports issued by TES (8/26/83) indicates at Table A-2 that a significant amount of design verification is incomplete and that no verification of modifications has been done. Further, the use of sampling in such verification, particularly in the use of nonstatistically based techniques, is inappropriate and insufficient to ensure that the redesign has in all respects actually been incorporated into the "as-built" facility.

Particularly in light of the extent of the design, the number of modifications, the unprecedented level of activity at the facility during the CAP, and the need to hire large numbers of new workers to implement the required changes, a full and complete verification prior to the issuance of final conclusions by the IDVP is necessary.

l See also response to Interrogatory No. 73 supra.

Final conclusions regarding the extent of as-built verification will be stated once our review has been completed. We will supplement our responses at that time.

l RESPONSE TO INTERROGATORY NO. 93.

j See Response to Interrogatory No. 92.

RESPONSE TO INTERROGATORY NO. 94:

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A reading of the IDVP Final Report indicates that, although root causes for design errors are purportedly addressed, in virtually every instance the causes identified are vague and. unspecific, indicating a superficial. examination of such causes by the IDVP. Of particular note is the' failure of the IDVP to attribute the blame (even in part) for the widespread QA/QC breakdown to failures of PGandE management,.a cause highlighted by R.F. Reedy'and cited as well by the NRC Staff in its SSER 18. The Joint Intervenors contend that the essence of an effective. reverification program is the identification of the root causes of design deficiencies. Only in this manner.can one determine with confidence that the errors discovered are not indicative of a wider, generic deficiency.

The IDVP's failure to-identify such causes with particularity as to each of the design errors and associated regulatory violations undermines the reliability of its results and conclusions and is inconsistent with the findings of reasonable assurance required for licensing.

RESPONSE TO INTERROGATORY NO, 95:

See Response to Interrogatory No. 94.

RESPONSE TO INTERROGATORY NO. 96:

The ITR's issued by the IDVP fail to document adequately the basis for the IDVP findings, recommendations, and/or conclusions in that the analysis relied upon -- to the extent it exists -- is not described sufficiently to permit an independent expert to assess the validity of the conclusions reached (i.e., ITR-6 -- use of soil springs in analysis not justified or explained). Further, the criteria for sampling are nowhere identified in ITR's 8 or 35, thereby precluding any effective analysis of the validity of the sampling techniques and conclusions derived from the sampling. Generally speaking, the ITR's do not explain the basis for resolution of EOI's, the root causes for the errors, the generic significance of the EOI's (and the reasons for concluding that they do or do not have such significance), and the type and extent of any action required to remedy a concern.

RESPONSE TO INTERROGATORY NO. 97:

See Response to Interrogatory No. 96.

RESPONSE TO INTERROGATORY NO. 98:

To date, the Joint Intervenors have not identified any specific tests. The contention arises out of the discussion at the May 4, 1983 meeting at PGandE's offices in San Francisco at which the NRC asked a series of questions regarding the extent to which PGandE intended to repeat, and was repeating, previously completed pre-op tests the results of which might have been affected by the redesign, the CAP, and/or any modifications. PGandE's response, through James Shiffer, was not sufficiently specific to provide an indication of what, if any, tests might be so affected, l

e .,

RESPONSE TO INTERROGATORY NO. 99:

NRC/IDVP/PGandE Meeting Transcript (May 4,1983) .

RESPONSE TO INTERROGATORY NO. 100:

The redesign program and any of the myriad modifications arising out of it undoubtedly will have an effect on a number of the SS&C's affected and hence upon the results of certain testing previously done for those SS&C's. Further, the presence of in excess of 7,000 workers on-site per day working on and around safety-related SS&C's poses a significant risk to the calibration, accuracy, or functionability of certain of the SS&C's.

RESPONSE TO INTERROGATORY NO. 101:

See Response to Interrogatory No. 99.

RESPONSE TO INTERROGATORY NO. 102:

See Response to Interrogatory No. 98. In addition, PGandE's past history of failing to " systematically" comply with the Commission's QA/QC regulations, one of which is Appendix B, Criterion ll, provides no basis for confidence that it is now in compliance.

RESPONSE TO INTERROGATORY NO. 103:

See Response to Interrogatory No. 99.

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RESPONSE TO INTERROGATORY NO. 104:

The Joint =Intervenors referred to such additional ~

testing as is necessary to ensure that the SS&C's affected will perform satisfactorily in service. Such testing has not as yet been identified.

RESPONSE TO INTERROGATORY NO. 105:

10 C.F.R. Part 50, Appendix B, Criterion 11.

RESPONSE TO INTERROGATORY NO. 106:

Criterion 11 requires that all testing required to demonstrate that SS&C's will perform satisfactorily in service be identified and performed in accordance with written test procedures which incorporate the requirements and acceptable limits contained in applicable design documents. The contention

! alleges a failure to comply with that requirement, and hence the non-existent written procedures cannot be identified.

RESPONSE TO INTERROGATORY NO. 107:

10 C.F.R. Part 50, Appendix B, Criterion 11.

RESPONSE TO INTERROGATORY NO. 108:

To the Joint Intervenors' knowledge and in light of the discussion referred to above at the May 4, 1983 meeting, PGandE has not identified and performed additional testing to verify that the affected SS&C's will perform satisfactorily in service.

o ..

RESPONSE TO INTERROGATORY NO. 109:

10 C.F.R. Part 50, Appendix B, Criterion 11.

RESPONSE TO INTERROGATORY NO. 110:

As was discussed at the Prehearing Conference of August 23 and 24, 1983, and as has been explained by the Appeal Board in its August 16 and 26, 1983 orders, there is no dispute in this proceeding that deficiencies existed in the various Diablo Canyon design QA programs. Therefore, PGandE has the burden, analogous to an' affirmative defense, to demonstrate that a level of confidence equivalent to compliance with the QA regulations and licensing commitments exists by virtue of some other means. Therefore, the IDVP and the manner in which it is designed, implemented, and executed are relevant to the extent that they may bear on the existence or absence of any such defense.

RESPONSE TO INTERROGATORY NO. 111:

" Root cause" means the basic or fundamental cause of an event or circumstance.

RESPONSE TO INTERROGATORY NO. 112:

No regulation or regulatory guide requires the identification of a " root cause" per se. However, to the extent that determination of a root cause is necessary to ensure that a deficiency will not recur or is not generic, the root cause determination is plainly required by the Commission's regulations.

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RESPONSE TO INTERROGATORY NO. 113:

Joel R. Reynolds and Eric R. Havian participated in the preparation of the answers to the above interrogatories.

DATED: August 31, 1983 Respectfully-submitted, JOEL R. REYNOLDS, ESQ.

> JOHN R. PHILLIPS, ESQ.

ERIC R. 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 -. -

{JOELREYNCLUS Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER i

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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.

(Diablo Canyon Nuclear Power ) 50-323 O.L.

Plant, Units 1 and 2) )

-)

- CERTIFICATION I, Joel R. Reynolds, hereby', certify-

1. I am one of the attorneys' for the Joint Intervenors in the above-entitl'ed proceeding and, as such, am authorized to execute this certification.

2. I have read the foregoing Joint Intervenors' Response to Pacific Gas and Electric Company's Second Set of Interrogatories'and know the contents thereof.

3. I am informed and believe said answers to be true and correct.

l I ce'rtify under penalty of perjury that the foregoing is ture and correct.

Executed at Los Angeles, California, on August 31, 1983, i

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I OEL R MREkNOLDS

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' UNITED STATES OF AMERICA

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+ NUCLEAR REGULATORY' COMMISSION

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' BEFORE THE ATOMIC SAFETY AND LICENSING' APPEAL BOARD k

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)

In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 O.L.

-(Diablo Canyon Nuclear Power- )

Plant, Units 1 and 2) )

) .

- , )

a - - . - CERTIFICATE OF SERVICE

- r I hereby certify that on this 31st day of August, 1983, I have served copies of the foregoing JOINT INTERVENORS' RESPONSE TO PACIFIC GAS AND ELECTRIC COMPANY'S SECOND SET OF INTERROGATORIES, mailing them through the U.S. mails, first class, postage prepaid.

• Thomas S Moore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Commission Conference, Inc.

Washington, D.C. 20555 4623 More Mesa Drive Santa Barbara, CA 93105

• Dr. W. Reed Johnson Atomic Safety & Licensing *Malcolm H. Furbush, Esq.

Appeal Board Vice President & General U.S. Nuclear Regulatory Counsel Commission Philip A. Crane, Esq.

Washington, D.C. 20555 Pacific Gas & Electric Company Post Office Box 7442

• Dr. John H. Buck San Francisco, CA 94120 Atomic Safety'& Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

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Docket and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commissior.

Washington, D.C. 20555 Lawrence Chandler, Esq.

Office of the Executive Legal Director - BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Janice E. Kerr, Esq.

Lawrence Q. Garcia, Esq.

J. Calvin Simpson, Esq.

California Public Utilities Commission 5246 McAllister Street 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. Fleischaker, Esq.

Post Office Box 1178 Oklahoma City, OK 73101 Richard Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, CA 95725 Arthur C. Gehr, Esq.

l Snell & Wilmer l 3100 Valley Center Phoenix, AZ 85073

• Bruce Norton, Esq.

Norton, Burke, Berry & French, P.C.

Post Office Box 10569 Phoenix, AZ 95064 Maurice Axelrad, Esq.

Lowenstein, Newman, Reis & Axelrad, P.C.

1023 Connecticut Avenue, N.W.

Washington, D.C. 20036 Virginia and Gordon Bruno Pecho Ranch Post Of fice Box 6289 Los Osos, CA 93402 l

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Sandra and Gordon Silver 1760 Alisal Street San Luis Obispo, CA 93401 Nancy 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 r C. N C_- _

AMANDA VARONA i

• Second Copy Delivered via Express Mail on September 1, 1983 T

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