ML20027A140
| ML20027A140 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/27/1978 |
| From: | Fleischaker D, Phillips J CENTER FOR LAW IN THE PUBLIC INTEREST |
| To: | |
| References | |
| NUDOCS 7810160155 | |
| Download: ML20027A140 (19) | |
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UNITED STATES OF AMERICA 8/7 Y
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h Before The Atomic Safety & bicensingBoah- '".9.. ... fQ 6 w 1 ?
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PACIFIC GAS & ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant,) ,
Units 1-& 2) )
INTERVENORS' Rs6 DEST TO THE STAFF FOR PRODUCTION OF DOCUMENTS, DATED SEPTEMBER 27, 1978 Pursuant to 10 CFR S2.744 (a) , Intervenors, SCENIC SHORE-LINE PRESERVATION CONFERENCE, INC., SAN LUIS OBISPO MOTHERS FOR PEACE, SANDRA SILVER, ECOLOGY ACTION CLUB, and JOHN J.
FORSTER, request the Staff to produce all documents identified in response to Interrogatories number 2b, 2c, 2f, 3d, 3g, 4, 5, 6, 7, 8, 9, 10, 11, 12, and 13, in INTERVENORS' INTERROGATORIES TO THE STAFF, DATED SEPTEMBER 27, 1978 which have not previously been made available to Intervenors or filed in the public documents room. These documents are relevant to the issues raised in the contentions relating to the adequacy of Diablo Canyon's seismic design.
Respectfully submitted, John Phillips, Esq.
7 Il0/ b Dl 6 h David S. Fleischaker, Esq.
Attorneys For Center For Law In The Public Interest September 27, 1978 -
By: M4((d (2 k (dtM N DAVID S. FLEISCHAKER, ESQ.
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UNITED STATES OF AMERICA-pf ,9 /,
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PACIFIC GAS & ELECTRIC COMPANY ) Docket Mos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant,)
Units 1 & 2) )
INTERVENORS' REQUEST TO THE APPLICANT FOR PRODUCTION OF DOCUMENTS, DATED SEPTEMBER 27, 1978 Pursuant to 10 CFR S2.741, Intervenors, SCENIC SHORE-LINE PRESERVATION CONFERENCE, INC., SAN LUIS OBSIPO MOTHERS FOR PEACE, SANDRA SILVER, ECOLOGY ACTION CLUB and JOHN J.
FORSTER request that Pacific Gas & Electric Company produce all documents identified in response to Interrogatories number 2b, 2c, 2f, 3d, 3g, 3h, 4, 5, 6, 7, 8, and 9 in INTERVENORS' INTERROGATORIES TO THE APPLICANT, DATED SEPTEMBER 27, 1978 which have not previously been made available to Intervenors or filed in the public documents room.
Respectfully submitted, John Phillips, Esq.
David S. Fleischaker, Esq.
Attorneys For Center For Law In The Public Interest September 27, 1978 David S. Fleischaker, Esq.
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UNITED STATES OF AMERICA ,o NUCLEAR REGULATORY COMMISSION gg'gG 7 Before The Atomic Safety & Licensing Board il g " gj$
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PACIFIC GAS & ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant,)
Units 1 & 2) )
INTERVENORS' REQUEST FOR ENLARGEMENT OF TIME TO FILE INTERROGATORIES
/
The Licensing Board established September 27, 1978 as the cutoff date for filing Interrogatories.
Intervenors hereby request an enlargement of time of one week, until October 3, 1973, in which to submit their final set of Interrogatories.
- 1. On September 21, 1978, Intervenors received copies of 12 memorandum from Dennis P. Allison to John F. Stolt:
describing data submitted informally to the Staff by the Applicant last spring announcing that the data was now avail-able in the public documents room. Intervenors have yet to complete their review of this data. Additional interroga-tories may be required upon completion of that review.
- 2. The Intervenors are preparing a final set of Inter-rogatories for both the Staff and Applicant, but due to conflicting obligations, Intervenors' counsel has not been i
2.
able to complete those Interrogatories. These obligations include completion of depositions under order.from the Federal District Court and recent arguments before State Courts.
- 3. Answers to Interrogatories would be due October 24, 1978. Intervenors do not anticipate that this enlargement of time would result in any further disruption of the hearing schedule established in the Licensing Board's Order, dated August 8, 1978.
Wherefore, Intervenors request an enlargement of time of one week, until October 3, 1978, in which to submit their final set of Interrogatories.
Respectfully submitted, John Phillips, Esq. '
David S. Fleischaker, Esq.
Attorneys For Center For Law In The Public Interest By: _
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David S. Fleischaker, Esq.
September 27, 1973
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UNITED STATES OF AMERICA
-!g NUCLEAR REGULATORY COMMISSION ,!d[ h . f-}, p Before The Atomic Safety & Licensing Board '.'. -
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PACIFIC GAS & ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant,)
Units 1 & 2) )
INTERVENORS' INTERROGATORIES TO THE APPLICANT, DATED SEPTEMBER 27, 1978
/
Pursuant to 10 C.F.R. 52. 74 0 (b) , Intervenors SCENIC SHORELINE PRESERVATION CONFERENCE, INC., SAN LUIS OBISPO MOTHERS FOR PEACE, SANDRA SILVER, ECOLOGY ACTION CLUB and JOHN J. FORSTER request Pacific Gas & Electric Company (Applicant) to answer the interrogatorie. set out below.
Instructions
- 1. Each interrogatory'is to be answered separately and fully in writhig under oath or affirmation by the officer of, employee of, or consultant to the Applicant who has personal knowledge thereof.
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- 2. In case of an objection, the reasons for the objec-tion shall be stated in full.
- 3. Answers to these interrogatories are due October 17, 197L l
2.
- 1. For each of the contentions relating to the adequacy of the seismic design of the Diablo Canyon Nuclear Power Plant, identify each witness the Applicant intends to call in the licensing hearing.
- 2. For each and every person identified in response to interrogatory number (1) above, identify the following:
a) the substance of the facts and opinions to which the witness is expected to testify; b) the grounds for each opinion; c) all documents, and porti'ons thereof, to which each expert will refer or upon which he will rely in the licensing hearing. If reference is made to the SER or FSAR and any amendments thereof, identify the specific section upon which each witness will rely; d) each witnesses' educational background; e) any professional employment or other work experience >
relating to the area of expertise upon which each witness will rely; f) all articles, books, scientific papers or abstracts, studies, analysis authored by the witnesses and relating to the area of expertise upon which each witness will rely.
- 3. a) Does the Applicant know what a three dimensional soil structure interaction analysis is?
b) Describe a three dimensional soil structure inter-action analysis.
3.
c) Has the Applicant or any of its consultants per-formed a.three dimensional soil structure interaction analysis on the Diablo Canyon Nuclear Power Plant?
d) If so, please describe the results of that analy' sis and identify all documents that contain the results of such analysis.
e) If the Applicant has not performed such analysis, state why they have not.
f) To'the Applicant's knowledge, has the Staff or any of its consultants performed a three dimensional soil structure interaction analysis on the Diablo Canyon Nuclear Power Plant?
g) If so, has the Applicant had the opportunity to review the results of that analysis? If the Applicant has reviewed the results of such analysis, summarize those results. Identify any documents that contain the ,
results of such analysis.
h) Has the Applicant ever discussed with the Staff the need to perform a three dimensional soil structure i interaction analysis on the Diablo Canyon Nuclear Power Plant? If so, please summarize those discussions. '
Identify any rules or memorandum relating to such l
discussions.
- 1) Is the Applicant aware of any person who has performed or has allegedly performed a three dimensional i
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, Nuclear Power Plan't? If so, please identify each t ,
p,erson.
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4." Identify all documents upon which the Applicant will
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rely for estimating peak, parameters of a 7.5; magnitude earth-s' e quake at short distances. If the bER or FSAR is cite'd, please provide the sectl'on ncmber.
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- 5. Identify all do'enments upon which the Applicant will rely tofsu'pport the reduction of the pet &. acceleration as
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measured in the free field to an " effective acceleration."
If the SER or FSAR is'ci'ted, please provide the section number.
- 6. Identify,all documents upon which the Applicant will '
rely to support use of a. tau effect to reduce by varying amounts the design response spectra for those structures of s
the Diablo Canyon Nuclear Power Plant having foundations ,
I e extending over large areas. If the SER or FSAR is cited,
. ' please provide the section number.
/
- 7. Identify all documents apon which the Applicant will rely fo'r the selection of peak acceleration, velocity, dura- /
tion and disple ;ementE parameters that descrise the safe 1
. shutdown earthquake for the' Diab.lo Canyon Nuclear Power
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Plant. If the SER or FSAR is~ cited, please provide the section number. >
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- 8. Id'entify any documents, including notes, lett,ers and s
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memorandum, that describe, summarize or report any meetings
.? between Staff consultant, Dr. Nathan Newmark, and Applicant
- employees or consultants during the course of reanalysis.
I Reference is made to the meeting of. March 13, 1978, as well i
as any other' meeting.
- 9. Idencify all documents, notes, memorandum and reports ,i
'0' relhting td or reporting on, or issuing from the Diablo Canyon Seismic Research Program (SRP) . See Attachment 1.
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Respectfully submitted, e
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,.. i John Phillips, Esq.
, David S. Fleischaker, Esq.
Attorneys For
, a Center For Law In The Public Interest By:
i h David S. Fleischaker, Esq.
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ATT ACHMEl'7 1.
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Az Dr. 3. Bolt .
Dr. A. Cornell Mr. D. u,.-41 con .
Dr. H. Seed Dr. S. S=1th Diablo Canven Seis=1e Research Proers= (52b Coordi=ation The purpose of the Diablo Canyon SEP is to reappraise the ground nation characteristics and the Eosgri Fault's pota=.ial on the site, and to refine the dyWc a=alysis of de pla=rto provide realistic assess =ents of the effect of the reappraised ground :aotion.
The Di.iblo Ca= yon SRP will be coordi= aced by a team. The co= position of this team and the flow of i=for=stics :o PG&I and to consultas:s is shown es the at:sched organizatio=al char.:.
The SRP coord1=stor will issue bi-weekly and bi-mondly 4 reports. The first bi-veekly repor: vas se== to you, as an exa=ple, on Septe=ber 16,377. The bi-weekly repor.s vill prd '-ily deal with routine =a::ers of the research, and v41' no at c=pc to report on cr1*d M assu=ptions and sig=ifica= results. In the future, therefore, only the bi-monthly repor:s, which vill report on the findings of the
, resear d in greater detail, vill be sent to veu. It is hoped that these bi-mondly reports vill kaep you adequately infor=ed. Eevever, should you need additional informatics, please call us. .
Please ccesider all =a :ers of the Diablo Ca= yon SEP confidential.
l The firs: bi-monthly progress report will be issued by the SRP coordinator shor-J.y.
l l Sincerely, l
R. V. BETnNGER .
l S 1. 7. 3ettinger l h
/HJHovland/j=c-Chief Civil E35 13eer cc: Mr. C. Cangloff Mr. C. C. Lenfestey .
l Dr. T. Essel an Mr. E. P. o.11ak/Mr. 7. J. Chio
! Dr. M. Keaton Mr. P . A. Crane
! Dr. C. Fra:1er Mr. M. Furbush l Dr. J. Blu=e Mr. J. 3. Hoch
! Dr. D. Jhaveri Mr. J. O. Schuyler u.r. A. B. Schuur=as P D OM64 l
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caran ,z, NONG Da*?Ag MNT NUMAR PROJICTS PROJECT ENGINF.ZR-DIABLO CANYON g-
_Diablo Canvet Seismic Researen Progran August 29, 1977 HESSES. H. J. GO:C"Y .
D. NIEMT E. P. WOLIAK
, 'Ihis is to conft m that Mr. George C. Ianfestey is -
responsible for ccordinating the Diablo Canyon Seismic Research Program (for= ally called Iong Ter= Studies) and. will report to c:a for project direc ion. He vill be assisced in this effort by }t: . John H. Hovland.
J. 3. HOCH
. Approved: R. V. Br. uNGER R. V. Bettinger JOS (3d96):dap cc: CEister RV3e c:inger PACrane
)GFurbush WEJohnson DVKelly ,
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JHHovland CCLenfescey P D 03368 ,
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UNITED STATES OF AMERICA , ~
i NUCLEAR REGULATORY COMMISSION :%,- -
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Before The Atomic Safety & Licensing Board Di., ,
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In The Matter Of )
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PACIFIC GAS & ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant,)
Units 1 & 2) )
INTERVENORS' INTERROGATORIES TO TIIE STAFF, DATED SEPTEMBER 27, 1978 Pursuant to 10 CRF S2.720 (h) (2) (ii) , Intervenors hereby file written interrogatories to be answered by NRC personnel with knowledge of the facts designated by the Executive Director for Operations. Answers to the interrogatories are necessary for a proper decision in this proceeding and are not rcisonably obtainable from any other sources.
- 1. For each of the contentions relating to the adequacy of the seismic design of the Diablo Canyon Nuclear Power Plant, identify each witness the Staff intends to call in the licensing hearing.
- 2. For each and every person identified in response to interrogatory number (1) above, identify the following:
a) the substance of the facts and opinions to which the witness is expected to testify; b) the grounds for each opinion; c) all documents, and portions thereof, to which
2.
each expert will refer or upon which he will rely.in the licensing. hearing. If reference is made to the SER or FSAR and any amendments thereof, identify the specific section upon which each witness will rely; d) each witnesses' educational background; e) any professional employment or other work experience relating to the area of expertise upon which each witness will rely; f) all articles, books, scientific papers or abstracts, studies, analysis authored by the witnesses and relating to the area of expertise upon which each witness will rely.
- 3. a) Does the Staff know what a three dimensional soil structure interaction analysis is?
b) Describe a three dimensional soil structure inter-action analysis, c) Has the Staff or any of its consultants performed a three dimensional soil structure interaction analysis on I the Diablo Canyon Nuclear Power Plant?
d) If so, please describe the results of that analysis and identify all documents that contain the results of such analysis, e) If the Staff has not performed such analysis, state why they have not.
f) To the Staff's knowledge, has the Applicant or any of its consultants performed a three dimensional soil l
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structure interaction analysis on the Diablo Canyon Nuclear Power Plant?
g) If so, has the Staff had the opportunity to review the results of that analysis? If the Staff has reviewed the results of such analysis, summarize those results.
Identify any documents that contain the results of such analysis.
h) Has the Staff ever discussed with.the Applicant the need to perform a three dimensional soil structure interaction analysis on the Diablo Canyon Nuclear Power Plant? If so, please summarize those discussions.
Identify any notes or memorandum relating to such discus-i sions.
i) Is the Staff aware of any perton who has performed or has allegedly performed a three dimensional soil structure interaction analysis on the Diablo Canyon Nuclear Power Plant? If so, please identify each person.
- 4. Has the USGS provided the NRC with any opinion regarding the selection of 0.75g as the zero period limit for design response spectra used in the reanalysis of the.Diablo Canyon Nuclear Power Plant? If so, please identify all documents containing those opinions.
- 5. Has the USGS provided the NRC with any opinion on the use of the Tau effect to reduce by varying amounts the design
4.
response spectra for those structures of the Diablo Canyon Nuclear Power Plant having foundations extending over large areas? If-so, please identify all documents containing those opinions.
- 6. Has the USGS provided the NRC with any opinions on the damping factors used to reduce the design response spectra for the structures of the Diablo Canyon Nuclear Power Plant?
If so, please identify all documents containing those opinions.
- 7. Identify all documents upon.which the Staff will rely for estimating peak parameters of 7.5 nagnitaib earthquake at at sirrt distances. If the SER or FSAR is cited, please provide the section number.
- 8. Identify all documents upon which the Staff will rely to support the reduction of the peak accelerations as measured in the free field to an " effective acceleration." If the SER or FSAR is cited, please provide the section number,
- 9. Identify all documents upon which the Staff will rely to support use of a tau ef.'fect to reduce by varying amounts the design response spectra for those structures of the I
i Diablo Canyon Nuclear Power Plant having foundations extending over large areas. If the SER or FSAR is cited, please p ovide l
the section number.
t j 10. Identify all documents upon which the Staff will rely
! for the selection of peak acceleration, velocity, duration I
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and displacement parameters that describe the safe shutdown earthquake for the Diablo Canyon Nuclear Power Plant. If the SER or FSAR is cited, please provide the section-number.
- 11. Identify any documents, including notes, letters and memorandum, that describe, summarize or report any meetings between Staff consultant, Dr. Nathan Newmark, and Applicant employees or consultants during the course of the reanalysis.
Reference is made to a meeting on March 13, 1978, as well as any other meeting.
- 12. a) Describe the data that has become available from the Fugro studies?
b) What conclusic as,. if any, has the Staff drawn from the Fugro data?
c) If the data has not yet become available, when does the Staff expect it to become available?
- 13. a) Describe the steps.taken, in the presentation of Staff testimony in this proceeding, to assure implementation of the Commission's open door policy about differing profes-sional opinion.
b) Identify those witnesses who will differ signifi-cantly in testimony related to the same subject matter. For such witnesses, briefly summarize their testimony and iden-tify each document upon which they will rely or to which they will refer.
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2.
Respectfully submitted, John Phillips, Esq.
David S. Fleischaker, Esq.
Attorneys For Center For Law In The Public Interest By: (4/46 $
David S. Fl'eischaker, Esq..
September 27, 1978 i
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UNITED STATES OF AMERICA 1./ ~
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NUCLEAR REGULATORY COMMISSION
[ . y Before The Atomic Safety & Licensing Board gjh B
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In The Matter Of ) Ni ~
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PACIFIC GAS & ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power Plant,)
Units 1 & 2) )
CERTIFICATE OF SERVICE I hereby certify that I have this 27th day of September 1978 served copies of the foregoing INTERVENORS' INTERROGA-TORIES TO THE APPLICANT, DATED SEPTEMBER 27,'1978, INTERVENORS' REQUEST TO THE APPLICANT FOR PRODUCTION OF DOCUMENTS, DATED SEPTEMBER 27, 1978, INTERVENORS'-INTERROGATORIES TO THE STAFF, DATED SEPTEMBER 27, 1978, INTERVENORS' REQUEST TO THE STAFF FOR PRODUCTION OF DOCUMENTS and INTERVENORS' REQUEST FOR ENLARGEMENT OF TIME TO FILE INTERROGATORIES by depositing
- copies thereof in the U.S. Mails, first class, postage pre-paid to the following parties:
Elizabeth S. Bowers, Esq. Docket & Service Section Chairman Office of the Secretary Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Mail Drop East West 450 Dr. William E. Martin Washington, D.C. 20555 Battelle Memorial Institute Columbus, Ohio 43201 Mr. Glenn Bright Atomic Safety & Licensing James R. Tourtellotte, Esq.
Board Panel L. Dow Davis, Esq.
U.S. Nuclear Regulatory Richard Goddard, Esq.
Commission Lawrence Brenner, Esq.
Mail Drop East West 450 Office of Executive Washington, D.C. 20555 Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 w -
2.
Mrs. Elizabeth Apfelberg John C. Morrissey, Esq.
1415 Cozadero Philip A. Crane, Esq.
San Luis Obispo, CA 93401 James O. Schuyler, Nuclear Projects Engineer Mr. Frederick Eissler Pacific Gas & Electric Company Scenic Shoreline Preserva- 77 Beale Street, Room 3127 tion Conference, Inc. San Francisco, CA 94106 4623 More Mesa Drive Santa Barbara, CA 93105 Arthur C. Gehr, Esq.
Snell & Wilmer Sandra A. & Gordon Silver 3100 Valley Center 1792 Conejo Avenue Phoenix, Arizona 85073 San Luis Obispo, CA 93401 Bruce Norton, Esq.
John Phillips, Esq. 3216 N. Third Street Center For Law In The Suite 202 Public Interest Phoenix, Arizona 85012 10203 Santa Monica Drive Los Angeles, CA 90067 Mr. Yale I. Jones, Esq.
100 Van Ness Avenue Paul C. Valentine, Esq. 19th Floor 321 Lytton Avenue San Francisco, CA 94102 Palo Alto, CA 94302 Mrs. Raye Fleming Janice E. Kerr, Esq. 1920 Mattie Road Lawrence Q. Garcia, Esq. Shell Beach, CA 93449 J. Calvin Simpson, Esq.
California Public Utilities MHB Technical Associates Commission 366 California Avenue 5246 State Building Suite 6 350 McAllister Street Palo Alto, CA 94306 San Francisco, CA 94102 k
DAVID S. FLEISCHAKER, ESQ.
1025 Fifteenth Street, N.W.
Suite 602 Washington, D.C. 20005
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