San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related CorrespondenceML20045D856 |
Person / Time |
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Site: |
Diablo Canyon ![Pacific Gas & Electric icon.png](/w/images/f/ff/Pacific_Gas_%26_Electric_icon.png) |
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Issue date: |
06/21/1993 |
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From: |
Culver N SAN LUIS OBISPO MOTHERS FOR PEACE |
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To: |
PACIFIC GAS & ELECTRIC CO. |
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References |
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CON-#293-14066 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9306300139 |
Download: ML20045D856 (9) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20045D8561993-06-21021 June 1993 San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related Correspondence ML20045D8291993-06-18018 June 1993 Response to Third Set of Suppl Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6751993-06-0404 June 1993 Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence ML20045A6401993-05-26026 May 1993 PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence ML20044F7701993-05-21021 May 1993 Intervenor San Luis Obispo Mothers for Peace Second Set of Supplemental Interrogatories & Requests for Production of Documents to Pge Cable Failures at Diablo Canyon Nuclear Power Plant.* W/Certificate of Svc.Related Correspondence ML20056C1891993-03-10010 March 1993 Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence ML20128P2251993-02-16016 February 1993 Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories & Requests for Production of Documents to Pg&E.* PG&E Should Answer Interrogatories within 14 Days.W/Certificate of Svc.Related Correspondence ML20213E5791986-11-0606 November 1986 Response to Util Second Set of Interrogatories Re Reracking of Spent Fuel Pools.Equations of Motion Appear in Encl Computer Program.W/Proof of Svc ML20213E6091986-11-0606 November 1986 Response to NRC Second Set of Inerrogatories Re Proposed Reracking of Spent Fuel Pools.Not Possible to Either Identify or Supply All Ref Documentation Supporting Contentions.W/Proof of Svc.Related Correspondence ML20213E6201986-11-0606 November 1986 Response to NRC Second Set of Interrogatories.Contentions Re Proposed Reracking & Alternatives Based on Understanding of Existing Industry Practice & Currently Available Technology. W/Proof of Svc.Related Correspondence ML20213F5851986-11-0505 November 1986 Suppl to 861003 Response to Intervenors 860916 First Set of Interrogatories Re Metals Used in Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20213F5011986-11-0505 November 1986 Response to 861017 Second Set of Interrogatories Re Seismic Analysis of High Density Fuel Racks for PG&E for Diablo Canyon Nuclear Power Station & Request for Production of Documents.W/Certificate of Svc.Related Correspondence ML20211E2121986-10-20020 October 1986 Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence ML20215H6691986-10-20020 October 1986 Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence ML20211E1721986-10-20020 October 1986 Second Set of Interrogatories Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses on Spent Fuel Pool.Related Correspondence ML20211E1871986-10-20020 October 1986 Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence ML20210S8921986-10-0606 October 1986 Response to Util Interrogatories Re Preparation for Upcoming Safety Hearings on Reracking of Spent Fuel Pools.Safety Issues Should Be Considered Before Amend Accepted.W/ Certificate of Svc.Related Correspondence ML20210S9651986-10-0606 October 1986 Answers to Sierra Club 860915 First Set of Interrogatories Re Reracking of Spent Fuel Pools.W/Certificate of Svc. Related Correspondence ML20210T2611986-10-0606 October 1986 Response to NRC Interrogatories on Contention 1 Re Util Responsibility to Demonstrate Safety of High Density Reracking.Intervenors Not Responsible for Solving Waste Storage Problem.W/Certificate of Svc.Related Correspondence ML20210S9711986-10-0303 October 1986 Response to Util & NRC First Set of Interrogatories & Request for Production of Documents.Interrogatories Opposed for Reasons Indicated.Certificate of Svc Encl.Related Correspondence ML20210T0731986-10-0303 October 1986 Response to Interrogatories & Request for Production of Documents Re Alternatives to High Density Reracking of Spent Fuel Pool at Facilities.Certificate of Svc Encl.Related Correspondence ML20210T0221986-10-0303 October 1986 Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence ML20210S9241986-10-0303 October 1986 Response to San Luis Obispo Mothers for Peace First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20206U7481986-10-0303 October 1986 Response to 860916 Interrogatories & Request for Production of Documents Re Licensing Proceedings.Certificate of Svc Encl.Related Correspondence ML20210S9931986-10-0303 October 1986 Response to Consumers Organized for Defense of Environ Safety First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20210T0541986-10-0303 October 1986 Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20210B7341986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc ML20214P8291986-09-16016 September 1986 Requests Response to Listed Interrogatories Re Design & Const of Fuel Ponds.Certificate of Svc Encl.Related Correspondence ML20214Q3521986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210B6321986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds ML20214Q3781986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions I & II Concerning Reracking of Spent Fuel Pools.Notice of Change of B Norton Address & Certificate of Svc Encl.Related Correspondence ML20210B6701986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools ML20214Q2981986-09-16016 September 1986 First Round of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20214Q3621986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210E1781986-09-15015 September 1986 Interrogatories & Request for Production of Documents Re Theoretical Work Concerning Displacement of High Density Spent Fuel Racks Due to Hypothetical Seismic Excitation. W/Certificate of Svc.Related Correspondence ML20214R1401986-09-15015 September 1986 Interrogatories Requesting All Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools, Dry Cask Onsite Storage & Cost/Benefit Assessment on Reracking.Certificate of Svc Encl.Related Correspondence ML20214R2341986-09-15015 September 1986 Interrogatories Requesting Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools & Dry Cask Onsite Storage as Alternative to High Density Reracking.Certificate of Svc Encl.Related Correspondence ML20081D7851983-10-26026 October 1983 Request for Production of Documents by NRC at 831107 Hearing in Avila Beach,Ca.Certificate of Svc Encl ML20080S2831983-10-14014 October 1983 Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20080Q3741983-10-0707 October 1983 Second Supplemental Answers to First Set of Interrogatories. Certification of Counsel & Prof Qualifications Encl ML20080Q3851983-10-0707 October 1983 First Supplemental Answers to Second Set of Interrogatories. Certification of Counsel Encl ML20080Q3951983-10-0707 October 1983 First Supplemental Answers to Fourth Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl ML20085J5951983-10-0707 October 1983 Fifth Supplemental Response to First Set of Interrogatories. Portions of RB Hubbard & Fj Samaniego 821221 Direct Testimony & Certificate of Svc Encl ML20080Q4441983-10-0505 October 1983 Response of Idvp to Interrogatory 57 in Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20078E1861983-10-0303 October 1983 Fourth Supplemental Response to First Set of Interrogatories.Certificate of Svc Encl ML20078D5091983-09-29029 September 1983 Supplemental Response to Second Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl.Related Correspondence ML20080M8521983-09-28028 September 1983 First Supplemental Answers to Third Set of Interrogatories. Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20078E1331983-09-28028 September 1983 First Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20080L5721983-09-26026 September 1983 Response to Fourth Set of Interrogatories.Certification of Counsel & Certificate of Svc Encl ML20078B8021983-09-23023 September 1983 Idvp Answers to First Set of Interrogatories.Certificate of Svc Encl 1993-06-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059C7361993-08-24024 August 1993 Intervenor Exhibit I-MFP-88,consisting of NRC Insp of Diablo Canyon Units 1 & 2 IR 05000275/19920161993-08-24024 August 1993 Intervenor Exhibit I-MFP-137,consisting of Insp Rept Re Dockets 50-275/92-16 & 50-323/92-16,dtd 920707 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059M5041993-08-24024 August 1993 Staff Exhibit S-2,consisting of Re Notice of Violation ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 1999-09-20
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/hM TFf ATED CODRCSPONDENCE
- CLnEiED U5NRC UNITED STATES OF AMERICA '93 JJ!124 P4 :07 NUCLEAR REGULATORY COMMISSION a wv ATOMIC SAFETY AND LICENSING. BOARD $[I .;.- .I N o
Before Administrative Judges:
Charles Bechhoefer, Chairman Jerry R. Kline Frederick J. Shan In the Matter of Pacific Gas and Electric Company Docket Nos. 50-275-OLA-2 Diablo Congon Nuclear Power Plant 50-323-OLA-2 Units 1 and 2 ASLBP No. 92-669-03-OLA-2 Focility Operating Licenses No. DPR-80 and DPR-82 June 21, 1993
! San Luis Obispo Mothers for Peace Supplemental Response to First and Second Sets of
! Interrogatories and Requests for Production of Documents Filed by Pacific Gas and Electric Company Son Luis Obispo Mothers for Peace C"SLOMFP"3 herein supplements its l
responses to Pocific Gas and Electric Company's ("PGSE"3 first and second sets of interrogatories and requests for production of documents filed Februarg 19, 1993. ;
First Set:
l l Interrogatory A-1: Identify the name, profession, employer, and creo of professionci expertise of each person whom MFP expects to call as a witness, including any expert witness, at the hearing on this matter.
Answer: As of this date, SLOMFP hos no commitment from any person to appear os on expert witness at the hearing. If/when SLOMFP secures a commitment from on expert witness to testify at the hearing, SLOMFP will l
promptly contact the interested parties. j I
Interrogatory A-2: Identify the contentions relating to which and specific !
to the subject matter on which each witness'is expected to testify at the hearing.
l Answer: Refer to answer to interrogatory A-1.
9306300139 930621 25 PDR- ADOCK 05000272 g PDR 39 3
Interrogatory A-3: Identify all documents, and all pertinent pages or parts thereof, that each witness has been shown to date and any other documents the witness will rely upon or will otherwise use for his/her testimony at the hearing.
Answer: SLOMFP hos agreed to identify all documents that it will rely upon These documents are listed in Attachment A and B. The in its cose.
majority of these documents are readily available to PGSE and, in fact, were provided to SLOMFP by PG&E. Three documents are being provided in Attachment C: "The Aging of Nuclear Power Plants: A Citizen's Guide to Causes and Effects," Nuclear Information and Resource Service by James Riccio and Stephanie Murphy, 1988; SLOMFP Reply to NRC and PGSE Responses to Petitioner's Supplement to Petition to Intervene, December 10, 1992 Cprepored for the first preheoring conference but not accepted]; Diablo Canyon Independent Sofety Committee Recommendations, Follow Up and Review of Safety Issues CJonuary 25, 1993].
Interrogatory A-4: Provide copies of all documents identified in response to A-3 above that are not documents provided to MFP by PG&E ond that are not otherwise available to PGSE.
Answer: These documents are found in Attachment C.
Interrogatory A-5: Identify the educatianol and professional experience of each witness identified in A-1 above.
Answer: Refer to answer to interrogatory A-1.
Second Set:
Answers to Interrogatories for Contention I Interrogatory B-1: In its Prehearing Conference Order, the Licensing Board did not strictly limit MFP "to the specific incidents relied upon to admit its contention." Prehearing Conference Order, at 25.
" Incidents such as those that MFP cttempted to read into the record at the preheoring conference may be acceptable, as long as they are material to the implementation of maintenance and surveillance programs." Ida
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B-1.1 Does NFP intend to identify additional " incidents" other than l
those set forth in its " Supplement to Petition to Intervene"
[ Supplemental Petition"3? j B-1.2 If so, identify all of the incidents, other than those set l forth in the Supplemental Petition, on which NFP intends to rely in !
support of Contention I. Explain why they support Contention I. I B-1.3 Provide any and all documentation relevant to the incidents !
identified in response to B-1.2. Include any documentation originally '
prepared for, and intended to be submitted at, the Preheoring 1 Conference.
B-1.9 PG&E emphasized the continuing nature of B-1 and directs NFP !
to review instruction L obove.
Answer: SLOMFP has categorized the incidents into " trends." The categories are self-explanatory. The identification of documentation for I
incidents relating to maintenance and surveillance programs at DCNPP are ]
Those documents that are not readily available to I located in Attachment A. 1 l
i PG&E have been provided in Attachment C. The document originally prepared l l for the first preheoring conference is included.
Interrogatory B-2: Describe the qualifications and experience of MFP members and their consultants in this proceeding, pertinent to the !
nature, scope, purpose of, ond/or porticipation in:
B-2.1 maintenance and surveillance practices and activities at DCPP or other commercial nuclear power plants; B-2.2 predictive, preven,tive, and corrective maintenance practices employed generally throughout the nuclear industry as well as at DCPP.
Answer: Refer to answer to interrogatory A-1, i Interrogatory B-4: Identify and provide copies of all reports of which MFP or its consultant is cwore, and on which it intends to rely in this proceeding, relevant to the implementation of maintenance and surveillance programs at commercial nuclear power plants located in the United States.
B-9.1 Provide copies of any and all documents relevant to the information identified in response to B-9.
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l Answer. SLOMFP intends to use NRC NUREGs, generic letters, information i
notices and events from other nuclear power plants that are relevant to the maintenance and surveillance programs at DCNPP. These documents have been 1 identified in Attachment A. The booklet entitled "The Aging of Nuclear Power Plants: A Citizen's Guide to Causes and Effects" has been provided in Attachment C.
Interrogatory B-8: Identify any and all information, of which MFP or its consultant is aware, regarding:
B-8.1 the maintenance rule and its implementation at DCPP; B-8.2 molntenance and surveillance activities at DCPP; ond/or B-8.3 oging, aging management, ond/or the effectiveness of programs to manage oge-related degradotion at DCPP.
B-8.4 Does MFP intend to use any of the information identified in response to B-8.1 .3 in support of Contention I? If so, explain the intended use of any such information.
B-8.S Provide copies of any documentation identified in response to B-8.1 .3 which is not already available to PGSE.
Answer: Because the maintentonce rule does not become effective until July of 1995, SLOMFP will not be relying on any information relating to its implementation to support Contention I. The documents that SLDMFP will use in support of Contention I have been identified in Attachment A. Documents have been provided in Attochment C. SLOMFP intends to use this information to show two things:
- 1. Despite the existing maintenance and surveillance programs at DCNPP and the corrective actions token when problems are identified, serious problems continue. Personnel continue to make and repeat significant errors. They frequently fail to follow the existing procedures due to inottention or lock of understanding. Procedures or instructions for maintenance and testing activities are often inadequate. Corrective actions that include additianol training, procedural revisions and memos repeatedly fail to
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prevent recurrence of on event. Equipment continues to corrode and degrade l l
despite surveillance. Design, maintenance, installation and manufacturing I
deficiencies continue to plague the safe operation of the plant.
- 2. In some cases, the technology for detecting aging effects simply does not exist.
1 Interrogatory B-11: MFP contends that "the NRC has repeatedly cited PGSE l for its slow response to correct maintenance problems." Supplemental l Petition, at 7. Identify and provide supporting documentation for all l such incidents, other than those listed in the Supplemental Petition l in support of Contention I.
Answer: Refer to the documents identified in Attachment A in the category entitled " untimely response."
Answers to Interrogatories for Contention V Interrogatory B-17: In support of the admissible portion of Contention V pertinent to the implementation of interim compensatory fire-l protection measures at DCPP, MFP cites five incidents based on two NRC inspection reports and three LERs. Prehearing Conference Order, at 35.
B-17.1 What, if any, other incidents does MFP or its consultant intend to rely upon in support of Contention V, os admitted by the Licensing Board, which regards implementation of Thermo-Log compensatory measures at DCPP7
! B-17.2 Provide any cnd all documentation relevant to the incidents identified in response to B-17.1.
B-17.3 PG&E reiterates the continuing nature of this request and i
directs MFP and its consultant to review instruction L obove.
Answer: SLOMFP will be relying on those incidents that are identified in Attachment B.
Interrogatory B-20: Identify all instances, known to MFP, in which fire l watches have been missed at DCPP since implementation of the interim l compensatory measures at issue.
Answer: In its supplemental response to the third set of interrogatories filed by SLOMFP CMorch 8, 1993], PG&E claims that there have been no missed
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i or late fire watches. However, SLOMFP has noted several instances in which
- roving and/or continuous fire watches were not established when fire protection equipment was inoperable or when degraded barriers existed.
These incidents are identified in Attachment B.
l Interrogatory B-21: Identify all studies, reports, and information, within t the knowledge or possession of MFP or its consultants, pertaining to the implementation of interim compensatory measures at DCPP and/or ong 3
commercici nuclear power plant.
B-21.1 Is any of the information identified in response to B-21 comparative in nature; e.g., does it compare the implementation of interim compensatory measures at various commercial nuclear power plants?
B-21.2 Upon which of the items identified in response to B-21 does MFP and its consultant intend to rely in support of Contention V?
Explain how.
B-21.3 If MFP and its consultant do not intend to rely upon certain of the items identified in response to item B-21, explain why for each study, report, or source of information.
B-21.9 Provide any and all documentation relevant to the items identified in response to B-21.
Answer: SLOMFP has no such documents.
Interrogatory B-22: Identify all documents and all sources of information available to MFP or its consultants pertaining to missed fire watches within the commercial nuclear power industry and/or at DCPP.
B-22.1 Does MFP intend to rely upon any of this information to support Contention V? If so, in each cose explain how.
B-22.2 If NFP does not intend to rely upon certain of the information identified in response to B-22, explain why for each document, report, or source of information.
B-22.3 Provido any and all documentation relevant to the infarmation j provided in response B-22.
Answer: SLOMFP hos no such documents nor other sources of information.
Interrogatory B-23s NFP aseerte that " human observere are not completely reliable. They make mistakes." Supplemental Petition, at 29.
. 1 B-23.1 Explain the factors, events, and conditions which lead to the asserted "unreliability" of human observers. 4 l
B-23.2 Uhot kinds of "mistokes" do human observers make? Explain the factors, events, and conditions which lead to these " mistakes?"
B-23.3 Identify and provide copies of any and all reports, documents, and sources of information which indicate that " mistakes" of this type ,
have in fact occurred at DCPP. Explain why they support Contention V. !
Answer: " Personnel error" is the common " root cause" of missed fire 1 l
watches and the failure to establish fire watches when needed due to l l
inoperable fire protection equipment or degraded barriers. Often these personnel errors are o result of inadequate instructions, misunderstanding of duties, misinterpretation of fire protection requirements or failure to idontify the need for fire protection measures. These incidents degrade the fire protection program at DCNPP and support SLOMFP's Contention V, Incidents of this type are identified in Attachment B.
Respectfully Submitted, 1
Noney Culver, President San Luis Obispo Hothers for Peace P.O. Box 169 i Pismo Beach, CA 93998 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of Pacific Gas and Electric Company Docket Ncs. S0-27S-OLA-2 Diablo Canyon Nuclear Power Plant S0-323-OLA-2 Units 1 and 2 ASLBP No. 92-669-03-OLA-2 Focility Operating Licenses No. DPR-80 and DPR-82 June 21, 1993 AFFIDAVIT I, Jill K. ZomEk, the Treasurer on the Board for Son Luis Obispo Mothers for Peace, have-provided the information for the " Son Luis Obisco Mothers for Peace Response to Supplemental Response to First and Second Sets of Interrogatories and Pequests for Production of Documents filed by Pacific Gas and Electric Company."
The information contained in the referenced interragotory answers and responses to requests for documents is true and correct to the best of my knowledge and belief.
__ _ _ __<J e Ji 1K. Zom k Scte of California County of Son Luis Obispo _
St Sworn and subscribed to before me this _2_/___dog of June, 1993 e s Notary Public ,
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My comm ssion expires
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'93 JW 24 P4 :07 Certificate of Service I hereby certify that copies of the foregoing Son Luis Obispo Mothers for '
Peace Supplemental Response to First and Second"Setsjof Interrogatories and Requests for the Production of Documents Filed by Pacific Gas and Electric Company have been served upon the following persons by U.S. mail, first class and by FAX cs indicated C*].
Office of Commission Appellote Administrative Judge Adjudication Charles Eechhoefer, Chairman U.S. Nuclear Regulatory Ctmmission Atomic Sofety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Sofety and Licensing Board Frederick J. Shon U.S. Nuclear Regulatory Commission Atomic Sofety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Edward O'Neill Ann P. Hodgdon, Esq. Peter Arth, Jr.
Office of the General Counsel Trumon Burns U.S. Nuclear Regulatory Commission Robert Kinosion (
Washington, DC 20555 Peter G. Fairchild, Esq. I Californio Public Utilities Commission Joseph B. Knotts, Jr., Esq.* 505 Uon Ness Avenue l Winston & Strown San Francisco, CA 99102 l 1900 L Street, N.W. l Washington, DC 20005 Adjudicatory File Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Branch Washington, DC 20555 U.S. Nuclear Regulatory Ccmmission Washington, DC 20555 Robert R. Wellington, Esq.
Diablo Canyon Independent Sofety Committee 857 Coss Street, Suite D Monterey, CA 93990 Christopher Warner, Esq.*
Richard Locke, Esq.
Pacific Gas and Electric Co.
77 Beale Street
. San Francisco, CA 59106 l
Jill ZomEk Dated June 21, 1993, Son Luis Obispo County, CA
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