ML20024E844
| ML20024E844 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/02/1983 |
| From: | Durbin S CALIFORNIA, STATE OF |
| To: | |
| Shared Package | |
| ML20024E836 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309070130 | |
| Download: ML20024E844 (30) | |
Text
i l J .
s .
99CKETED UNITED S'DLTES OF AMERICA USNRC NUCLEAR REGUIATORY COMMISSION g7 ,
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.
) 50 -32 3 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
i GOVERNOR DEUKMEJIAN' S . THIRD SET I OF INTERROGATORIES AND SECOND DOCUMENT PRODUCTION REQUEST TO THE INDEPENDENT DESIGN VERIFICATION PROGRAM CONTRACTORS Pursuant to 10 C.F.R. section 2.740(b), Governor Deukmejian I
hereby propounds the following interrogator!es to the contractor s for the Independent Design Verification Program.
INSTRUCTIONS
- 1. All information is to be divulged which is in the possession of the individual, association, or corporate party, their attorneys, consultan ts, investigator s, agen ts, employees, witnesses or other representatives of the named party.
- 2. Where you have incomplete information that precludes your fully answering an interrogatory, give such information as you have and state what information you do not have. If you are unable to give the information in the form sought but have the information aggregated dif ferently, give the infor mation in the form in which you have it and explain the reason for the deviation.
- 3. When asked in the interrogatories below to iden tify or 8309070130 830902 1*
- . . - .. - ___. . - . .~ _ . . n -- - ~- . - - . , _ - - - , - , _ . . - , . - - . - .
to give the identity of a person, please give the following information about him or hers (a) full name; (b) present job title, employer, and telephone number.
- 4. When asked in the interrogatories below to identify or to give the identity of a document or writing, please give the following information about the document:
(a) its title, if any; (b) its nature (e.g., letter, memorandum, chart, computer printout, ledger);
(c) the date, if any, stated on the document; (d) the identity of each person who signed it; (e) the identity of each person to whom it is addressed;
- 5. Where an individual Interrogatory calls for an answer which invloves more than one part, eadi part of the answer should be clearly set out so that it is understandable.
- 6. These interrogatorles are intended as continuing interrogatories, requiring you to answer by supplemental t
answer, setting for th any infor mation within the scope of the interrogatories as may be acquired by you, your agents, attorneys or represen tatives following your original answers up to the time of hearing.
- 7. "Documen ts" include printed material, writings, handwritten notes, photographs, xerox reproductions, and audio at video recordings. " Writings" and " recordings" consist of 2.
t
- -- e.. . . . . . . . . .. .,_
....v ..._. ... ... . . . . .
l letters, words, or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostating, photographing, magnetic impulse, mechanical or electronic recording, or other form of data compilation, as defined in Rule 1001 of the Federal Rules of Evidence 28 U.S.C.
- 8. When asked in the interrogatorles below for your position with respect to a numbered contention; for the f acts, and documents which support that position; and for the witness or witnesses who will testify at the hearing on your behalf with respect to that position, the contentions referred to are i
those contentions and any subsequent amendments or additions :
thereto which are set forth in the Atomic Safety and Licensing Appeal Board's August 26, 1983 order at pages 4 through 7.
DEFIN ITIONS (1) " Appendix B" means Appenc.ix B to part 50 of 10 C.F.R.
- (2) "Dlablo Canyon" means units 1 and 2 of the Diablo Canyon Nuclear Power Plant, including all structures, systems, and componen ts at the site.
(3) "Diablo Canyon Project" (DCP) means PGEE, Bech tel, all joint projects of PG&E and Bechtel concerning Diablo Canyon, and all contractor s, subcontrac tor s, consultan ts , and agen ts of the foregoing, excluding the IDVP.
(4) " Internal Technical Program" means the activities of the DCP undertaken to verify the adequacy of design of Diablo Canyon.
(5) "Independen t Design Verification Program" (IDVP) means the program established by the November 19, 1981, order of the 3.
1 Nuclear -Regulatory Commission (NRC), the November 19, 1981, letter from Harold Denton to Malcolm Furbush, and implementing directives of the NRC staff, as that' program may have been modified since that date.
(6) " Person" includes natural persons, corporations, partnerships, other business entities, and public agencies.
(7) "PGt,E" means the Pacific Gas and Electric Company and its agents, employees, contractors, subcontractors, affiliates, departmen ts , divisions, units , subunits , and attor neys, excluding the IDVP.
i (8) " Quality assurance" means all those planned and l~ -
systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service. Quality assurance includes quality Control.
(9) " Quality control" means those quality assurance actions related to the physical characteristics of a material, struc ture, component, or system, which provide a means to control the quality of the material, etructure, component, or system to prede termined requirements.
! (10) " Safety-related" means those SS&Cs necessary to i
assure: (1) the integrity of the reactor coolant pressure boundary; (2) the capability to shut down the reactor and r.sintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the guideline exposures of 10 C.F.R. part 100.
4.
- - - - . , -----n--- ,__,.--,--,.-_-n,,,---..-~~-e . . . - - - - , - - -n,---
(11) " Verification Program" means all activities of the DCP and the IDVP.
(21) "You" and "your" refer to the IDVP.
INTERROGLTORIES
- 1. With respect to contention 1(a), do you deny that the scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures and components was too narrow in that the IU7P did not verify samples from each design activity (seismic and non-seismic)?
- 2. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state ead and every f act on whid you rely in support of your denial.
(b) Please identify each and every document on whis you rely in support of your denial.
i (c) Please identify each and every document known to you or believed by you to contain facts or allegations that l cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning C your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 3. With respect to conten tion 1(b), do you deny that the scope of the IDVP review of both the seismic and rjon-seis,mic aspects of the designs of safety-related systems, structures 1
5.
l .
l l
l l and components was too narrow in that in the design activities i
the IDVP did review, it did not verify samples from each of the design groups in the design chain performing the design activity?
- 4. If your answer to the preceding interrogatory is a denial of the contention stated therein:
l (a) Please state each and every fact on which you rely in support of your denial.
, (b) Please identify each and every document on which l
you rely in support of your denial.
(c) Please iden tify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
l (d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 5. With respect to contention 1(c), do you deny that the scope of the ,IDVP review of both the seismic and non-seismic
! aspects of the designs of safety-related systems, struc tures and components was too narrow in that the IDVP did not have statistically valid samples from which to draw conclusions?
- 6. If your answer to the preceding interrogatory is a denial of the contention stated therein:
6.
_.. _, *j_,_ .. c ..
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that l cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please identify each and e rery person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 7. With respect to conten tion 1(d), do you deny that the scope of the IDVP review of both the seismic and non-seismic l aspects of the designs of safety-related systems, struc tures and components was too narrow in that the IDVP failed to verify independently the analyses but merely dhecked data of inputs to l
models sed by PGEE?
l l
- 8. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
7.
(c) Please identify ead and every document known to you or believed by you to contain facts or allegations that contradict, are inconsistent with, or tend .to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 9. With respect to conten tion 1(e), do you deny that the scope of the IDVP review of both the seismic and non-seismic aspects of the designs of safety-related systems, structures 4
and components was too narrow in that the IDVP failed to verify the design of Unit 2?
- 10. If your answer to. the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please iden tify each and every documen t on which you rely in support of your denial.
(c) Please iden tify each and every documen t known to you or believed by you to contain f acts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validit.y of your denial or upon those f acts on I
whid you base your denial.
8.
. . . . . - - . . . . . . . . _ . . , . . . . . . . . . . . . . . . . . . , . . . )
(d) Please identify each and every person you intend l to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contention.
- 11. With respect to contention 2(a), do you deny that the scope of the ITP review of both the seismic and non-seismic aspects of the decigns of the safety-related systems, i structures and components was too narrow in that the ITP did not verify samples from each design activity (seismic and i
l no n-seismi c) ?
I
- 12. If your answer to the preceding interrogatory is a
,i denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
(c) Please iden tify each and every document known to you or believed by you to contain f acts or allegations that l contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d) Please identify each and every person you intend bo call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
l
- 13. With respect to contention 2(b), do you deny that the scope of the ITP review of both the seismic and non-seismic 9.
aspects of the designs of the safety-related systems, structures and components was too narrow in that in the design activities the ITP did review, it did n3t verify samples f rom each of the design group 2 in the design chain performing the design activity?
- 14. If your answer to the preceding interrogatory is a denial of the contention stated therein:
l (a) Please state each and every fact on which you rely in support of your denial.
(b) Please iden tify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d) Please iden tify each and every person you intend bo call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 15. With respect to conteition 2(c), do you deny that the scope of the ITP review of both the seismic and non-seismic aspects of the designs of the safety-related systems, structures and components was too narrow in that the ITP did not have statistically valid smples f rom which to draw
(
co nclusions?
10.
- * ^
- 16. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please identify each and every document on which you reJy in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 17. With respect to conten tion 2 (d), do you deny that the scope of the ITP review of both the seismic and non-seisadc l
aspects of the designs of the safety-related systems, structures and components was too nuerow in that the ITP has failed systematically to verify the ad quacy of the design of Unit 27 ,
- 18. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please iden tify each and every documen t on which you rely in support of your denial.
11.
._.L ,
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contestion or the facts on which you rely in suppport of the denial of this contention.
l
- 19. With respect to contea tion 3 (a), do you deny that the ITP used improper engineering standards to determine whether l
design activities met license criteria in that it accepted the
! mean measured performance of structures and materials in lieu of code-specified minima and that the IDVP either used or l approved the use of such an improper standard or did not verify it at all?
- 20. If your answer to the preceding interrogatory is a i
denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b), Please identify each and every document on which you rely in support of your denial.
(c) Please iden tif y each and every documen t known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
I 12.
l l . . - .
r- .
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contes tion.
- 21. With respect to contention 3 (b), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it failed to verify that the stress and load factor s for steel used in the containment building were within code values and that the IDVP 1
either used or approved the use of such an improper standa rd or did not verify it at all?
- 22. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please iden tify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to f you or believed by you to cont in f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the, validity of your denial or upon those f acts on which you base your denial.
(d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 23. With respect to conten tion 3 (c), do you deny that the 13.
ITP used improper engineering standards to determine whether design activities met license criteria in that it failed to specify all damping values used in various seismic modes in the containmen t and auxiliary buildings and that the IDVP either
' used or approved the use of such an improper standard or did not verify it at all?
- 24. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are incons~isten t with, oc tend to cast doubt upon the validity of y.our denial or upon those f acts on which you base your denial.
(d) Please identify each and every person you intend I to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 25. With respect to conten tion 3 (d), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it f ailed to verify that PG&E's use of the double algebraic sum method of calculation (rather than the sum of the squares method) was acceptable as a substitution and that the IDVP either used or 14.
approved the use of such an improper standard or did not verify it at all?
- 26. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please iden tify each and every documea t on whida f
you rely in support of your denial.
(c) Please iden tify each and every documen t known to l
you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 27. With respect to conten tion 3 (e), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that it used time-history, modeling techniques for some accelerations, displacemen ts and shell forces in the containmen t struc ture and Blume response spectra for other accelerations, displacements and shell forces in the same structure and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
l 28. If your answer to the preceding interrogatory is 15.
1
. - __ _ _ _. _ Ji. _ ! ____ .1 Z2 :L ,1 J_ . , _ _.__ ._ . . _ __._._. _ _ ., _ . _ _ _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _
a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you bo contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 29. With respect to conten tion 3 (f), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria with respect to its modeling of the soil properties for the containment and auxiliary buildings and that the IDVP either used or approved the use of such an improper standard or did not verify it at all? ,
- 30. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please iden tif y each and every documen t on which you rely in support of your denial.
16.
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on
~
which you base your denial. -
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 31. With respect to contention 3(g), do you deny that the ITP used improper engineering standards to determine whether-design activities met license criteria with respect to its
- modeling of the crane in the turbine building and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
32 . If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
l (c) Please identify each and every document known to l
you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial. -
17.
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contention.
- 33. With. respect to contention 3 (h),do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria by virtue of its modeling of the tor sion factor s for dif feren t buildings by dif fering techniques and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 34. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please iden tify each and every document on which you rely in support of your denial.
(c) Please iden tify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt i
l upon the, validity of your denial or upon those f acts on i which you base your denial.
l (d) Please iden tify each and every person you intend l
to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you e rely in suppport of the denial of this contention.
- 35. With respect to conten tion 3(i), do you deny that the
! 18.
1 I
_ _ . , _ , . . _ f_ _ _ , . _ _ . _ _ . , _ _ _ _ . . _ _ . _ .
ITP used improper engineering standards to determine whether design activities met license criteria with respect to its modeling of hydr odynande forces for the intake structure and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 36. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please iden tify each and every document on which you rely in support of your denial.
(c) Please iden tif y each and every documen t known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on which you base your denial.
(d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning l your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 37. With respect to conten tion 3 (j), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that for its modeling of the intake structure it used different models for horizontal and vertical seismic loadings and combined the results of these dif ferent models for vertical and horizontal responses and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
19.
l l
~- "*6* ~- - - - - . - . . _
b
- 38. If your answer to the preceding interrogatory is a denial of the 'conten tion stated therein:
, (a) Please state each and every f act on which you rely in support of your denial.
(b) Please identify each and every document on which t
you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt l upon the validity of your denial or upon those facts on i
which you base your denial.
, (d) Please identify each and every person you intend bo call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you l
rely in suppport of th'e denial of this contention.
- 39. With respect to conten tion 3 (k), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria in that for its modeling of the intake structure it used improper ductility f actors for steel and concrete and that the IDVP either used or appr oved the use of such an improper standard or did not verify it at l all? -
- 40. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you l
rely in support of your denial.
(b) Please identify each and every documen t on whida you rely in support of your denial.
20.
L
__.---___,,-,,--..~: :*- _ _. , ..._~...,,--. - _ -..,.,, ,-,-,-- _ , , , - ~ . , . - . , . - . . - - . . , , , - . . - - _ . . _ .
I (c) Please identify each and every document known to you or believed by you to contain facts or allegations thct contradict, are inoonsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please iden tify each and every person you intend to call as-a witnesa whom you expect to testify concerning your denial of this contastion or the facts on which you rely in suppport of the denial of this contention.
- 41. With respect to conten tion 3 (1), do you deny that the ITP used improper engineering standards to determine whether design activities met license criteria with respect to its computations of modes in the containment building having frequencies between 20 and 33 HZ and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 42. If your answer to the preceding intercogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
l (b) ,
Please iden tify each and every document on which you rely in support of your denial.
(c) Please iden tif y each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt 4 upon the validity of your denial or upon those f acts on which you base your denial.
1 21.
. - . _ _ _ . . . 2 . :. .. : * ": ^ * . ::: ~:. - - _ - -. - ._- .
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this contention.
- 43. With respect to contention 3 (m), do you deny that the ITP used > improper engineering standa rds to determine whether design activities met license criteria in that in modeling the containmen t building it f ailed to use two hor izontal componen ts for the DE and DDE and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 44. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please iden tif y each and every documen t on which you rely in support of your denial.
(c) Please iden tif y each and every document known to f
you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the, validity of your denial or upon those f acts on which you base your den ial.
(d) Please iden tify each and every person you intend to call as a witness whom you expect to testify concerning your denial of thic conten tion or the facts on which you rely in suppport of the denial of this contention.
- 45. With respect to contention 3(n), do you deny that the 22.
ITP used improper engineering standards to determine whether design activities. net license criteria by virtue of the stress values it used for concrete in shear walls in modeling the f
auxiliary building and that the IDVP either used or approved the use of such an improper standard or did not verify it at all?
- 46. If your answer to the preceding interrogatory is a denial of the contention statad therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please iden tify each and every document on whidh you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on 4
which you base your denial.
(d) Please iden tify each and every person you intend
- to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you l
- rely in ,suppport of the denial of this contention.
- 47. With respect to conten tion 4, do you deny tha t the j
IDVP has accepted deviations from the licensing criteria
. without providing adequate engineering justification?
i 48. If your answer to the preceding interrogatory is a denial of the conten tion stated therein: -
23.
,.c.-,--, ,, -e-----% , , - . - , . - , - . ,._-.-.# ,.
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that co nt radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please iden tify each and every person you intend to call as a witness whon you expect to testify concerning your denial of this contention or the facts on which you rely in suppport of the denial of this contention.
- 49. With respect to contention 5, do you deny that the verification program has not verified that Diablo Canyon Units 1 and 2 "as built" conform to the design drawings and analyses?
l
- 50. If your answer to the preceding interrogatory is a l denial of the conten tion stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b), Please identify each and every document on which you rely in support of your denial.
(c) Please identify e ach and every document known to you or believed by you to contain facts or allegations that co nt radic t, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
24.
. ~ - . - _ __
1_.____.___..__._ . _
(d) . Please identify e ach and every person you intend to call as a witness whom you expect to testify concerning your denial of this contention or the f acts on which you rely in suppport of the denial of this conten tion.
- 51. With respect to contention 6, do you deny that the verification program failed to verify that the design of safety i related equipment supplied to PGEE by Westinghouse met licensing criteria?
- 52. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every fact on which you rely in support of your denial.
(b) Please iden tify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain f acts or allegations that contradict, are inconsisten t with, or tend to cast doubt upon the validity of your denial or upon those f acts on i
which you base your denial.
(d) Please iden tify each and every person you intend b3 call ,as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you rely in suppport of the denial of this contention.
- 53. With respect to conten tion 7, do you deny that the verification program failed to identify the root causes for the failures in the PG&E design quality assurance program and
' failed to determine if such failures raise generic concerns?
25.
l
\_. . _ _____. . _ _ , _ _ ._, _. . _ _ _
- 54. If your answer to the preceding interrogatory is a denial of the conten tion stated therein:
(a) Please state each and every f act on which you rely in support of your denial.
(b) Please identify each and every document on which you rely in support of your denial.
I (c) Please identify each and every document known to you or believed by you to contain facts or allegations that cont radict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on ,
which you base your denial.
(d) Please identify each and every person you intend to call as a witness whom you expect to testify concerning your denial of this conten tion or the facts on which you l rely in suppport of th'e denial of this contention.
- 55. With respect to contention 8, do you deny that the ITP f ailed to develop and implement in a timely manner a design quality assurance program in accordance with 10 C.F.R. Part 50, Appendix B to assure the quality of the recent design l
modifications to the Diablo Canyon facility and that the IDVP failed to ensure that the corrective and preventative action programs implemented by the ITP are sufficient to assure that the Diablo Canyon f acilities will meet licensing criteria?
- 56. If your answer to the preceding interrogatory is a denial of the contention stated therein:
(a) Please state each and every f act on which you
(
' rely in support of your denial.
26.
(b) Please identify each and every document on which you rely in support of your denial.
(c) Please identify each and every document known to you or believed by you to contain facts or allegations that i contradict, are inconsistent with, or tend to cast doubt upon the validity of your denial or upon those facts on which you base your denial.
(d) Please identify each and every person you intend 60 call as a witness whom you expect to testify concerning your denial of this contea tion or the facts on which you rely in suppport of the denial of this contention.
- 57. For each and every person identified in your answers to the preceding interrogatories as a prospective witness in these proceedings, please state:
(a) Whether he or she will be offered as an expert wi tness.
(b) If the witness will be offered as an expert, the specific subject matter about which the witness will be expected to testify.
(c) If the witness will be offered as an expert, the specific qualifications of the witness that you contend would qualif y the witness to give opinion testimony on each specific subject matter about which the witness will testify.
(d) Each and every professional article, book, or the like, if any, the witness has authored or co-authored concerning each specific subject matter set forth in your answer to subpart (b), above.
27.
(e) The identity of each and every document the witness will rely on to reach any opinion testimony and specifically correlate each such document (by page and paragraph number) to each specific subject matter on whidi the witness will render an opinion.
(f) As to each specific subject matter identified in your answer to subpart (b), above, the identity by docket number and case name of each case (court or administrative ag ency) where the witness has previously given expert testimony concerning each specific subject matter.
(g) As to e ach such case, (i) the da te (s) the expert testimony was given; (ii) whether you have a copy of the testimony given; (iii) whether you have a copy of the transcript covering any or all of the witness's examination cr cross-exami nation for each such pr oceeding; (iv) whether you have a copy of any notas whi,ch the witness made in preparation for, or utilized during, the witness's examination or cr oss-exami nation in e ach such pr oceeding.
- 58. Please iden tif y each and every documen t--excluding the IDVP and DCP Final Reports, the Interim Technical Reports, and Supplemen t 18 to the Safety Evaluation Repor t--tha t:
28.
(a) Describes how the DCP, the IDVP, or the s taf f drew inferences from sample observations of design activities and products concerning the quality of design of Diablo Canyon.
(b) Discusses the validity of the methods used to draw inferences about the quality of design of Diablo Canyon from sample observations.
(c) Discusses the validity of the inferences about the quality of design of Diablo Canyon drawn from sample observations.
(d) Discusses the method by which any one cr more sample was drawn for the purpose of assessing the quality of design of Diablo Canyon.
(e) Discusses the validity of the sampling methods used.
DOCUMENT PRODUCTION REQUEST
- 1. Pursuant to 10 C.F.R. section 2.241, you are requested to produce each documen t iden tified in the answers to the interrogatories above.
The, documen ts shall be produc ed on October 4,198 3, at 3580 Wilshire Blvd. , Suite 800, Los Angeles, California 90010, 29.
l at 10:00 a.m., unless other arrangements are made with counsel.
1 DATED: September 2,198 3 JOIM K. VAN DE KAMP, Attor ney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J . STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General
? n ,
{
By '[b.I t e .i SUSAN L. DURBIN Attorneys for Governor j
George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2105 i
0 30.
_ .___ _.._________._ _ _ _ _ _ _ _