ML20081D771

Application for Subpoena to Compel Production of Evidence by Applicant at Hearing Commencing on 831031.List of Documents to Be Produced Encl

ML20081D771
Person / Time
Site:	Diablo Canyon
Issue date:	10/26/1983
From:	Durbin S CALIFORNIA, STATE OF
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20081D761	List: ML20081D755 ML20081D771 ML20081D776 ML20081D785
References
ISSUANCES-OL, NUDOCS 8311010330
Download: ML20081D771 (7)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

)

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

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

)

GOVERNOR'S APPLICATION FOR SUBPOENA '

DIRECTED TO APPLICANT Governor Deukmejian hereby respectfully applies to the Atomic Safety and Licensing Appeal Board, pursuant to 10 C.F.R.

section 2.720, for a subpoena to compel production of evidence by applicant Pacific Gas & Electric Company ("PG&E") at the hearing commencing on October 31, 1983.

The evidence documents sought to be produced is attached hereto. Each request is either for a document that is explicitly referred to or relied upon in the applicant's prefiled direct testimony, or is for the doc ~umentation that forms the basis for a portion of such testimony. Each requested document or document category is accompanied by a citation to the portion of~the applicant's direct testimony that refers to or is based upon the

! document.

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F311010330 831024 PDR ADOCK 05000275 o PM

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eo v'

The relevancy of the documents requested lies in PG&E's reliance upon them in its direct testimony.

DATED: OCTOBER 26, 1983 Respectfully submitted, JOHN K. VAN DE KAMP, Attorney 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 By $ [ML

• SUSAN L. DURBIN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 Telephone: (213) 736-2105 4

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1 UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD l

)

In the Matter of )

)

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

(Diablo Canyon Nuclear Power

) 50-323 0.L.

)

Plant, Units 1 and 2) )

)

)

SUBPOENA FOR PRODUCTION e OF EVIDENCE TO THE CUSTODIAN OF RECORDS, PACIFIC GAS & ELECTRIC COMPANY YOU ARE HEREBY COMMANDED to produce, on October 31, 1983, at 1:00 p.m., at the San Luis Bay Inn, Avila Beach, California, for inspection and copying by counsel for Governor Deukmejian, the documents listed or described on the attached Exhibit A.

DATED: , 1983 THOMAS S. MOORE, Chairman Atomic Safety & Licensing Appeal Board I

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,s EXHIBIT A DOCUMENTS TO BE PRODUCED BY PG&E DOCUMENT DESCRIPTION CITATION IN PG&E'S DIRECT PREFILED TESTIMONY PG&E Panel 1 PG&E Panel 1 Testimony

1. The in-depth Page 3, line 7 reviews and analyses to assure compliance with licensing criteria

2. The study or studies on Page 14, lines 16-18 which PG&E relies for its judgment that none of the findings of the ITP or'IDVP would have resulted in the failure of any structure or system to perform its intended safety function

3. Documentation setting forth Page 17 line 3 to the scope, procedures, and page 18, line 24 results of the ITP's functional design reviews of non-seismic safety-related design activities

4. The basic criteria Page 17; 11 to 12; page 18 for each ITP review of the -

lines 3 and 15 non-seismic systems described in the testimony

5. The documentation by the Page 29, lines 21-23 Unit 2 Project Engineer of the inapplicability of Unit 1 findings

6. The documentation of the Page 30, lines 5-7 differences and applicability of Unit 1 review to Unit 2

7. The log of each ITP and Page 30, lines 14-21 IDVP finding and all the associated completion sheets for Unit 2.

1.

8. The guidelines and Page 32, lines 22-35 tolerances issued by the PG&E ,

, engineering Department, including i the documentation requirements PG&E Panel 2 PG&E Panel 2 Testimony

1. Documentation of all Page 71,-line 23 to analyses performed concerning page 72, line 6

, separation or uplift of the i containment foundation mat.

PG&E Panel 3 PG&E Panel 3 Testimony

1. Decumentation of the daily Page 37, lines 18-26 mean, maximum and minimum ocean temperatures at the site for June 1, 1983 to the present date, including hourly reports for all time periods wherein

, the ocean temperature exceeded 64*F.

2. All analysis of component Same cooling water supply temperatures (and length of time at peak temperatures) with two heat exchangers in operation, assuming a 70*F intake temperature, a LOCA, no off-site power available, and a failure of an auxiliary saltwater pump, all occurring together.

3. Documentation provided to Same PG&E by pump cooler suppliers ,

regarding peak acceptable component cooling water supply temperatures.

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4. Documentation relied upon Same *

, to support the conclusion that if 64*F were used as the maximum ocean temperature for other accident analyses, the results of the analyses-would.

be bounded by analyses governed by a maximum. assumed ocean temperature of 70*F specified in the FSAR (page 5 of May 18, 1983 letter of Crane-to Eisenhut).

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2. -

.fo PG&E Panel 4 PG&E Panel 4 Testimony

1. Documentation of NRC's Page 3, -line 3 approval of Westinghouse's QA Program for all time ,

periods of Diablo Canyon design activities.

2. Documentation of the Page 13, lines 8-9 thirteen audits of Westinghouse design contract conducted by the NRC, and all responses thereto, by Westinghouse, including the description of all corrective action taken by Westinghouse.

! PG&E Panel 5 PG&E Panel 5 Testimony

1. Training aids used for Page 17, line 4 to the training personnel page 18, line 2 who perform quality-related activities, a well as the attendance records and reports resulting from such training.

2. The summary document Page 21, lines 5 to 7 listing the 100 findings and the corrective actions associated with each finding

3. The overall audit plan, Page 21, lines 19 to 21 including the definition of areas of activities to be audited annually, as separate and distinguished from areas to be covered by monitoring activities.

4. The summary document Page 23, lines 13 to 17 listing the 100 characteristics of governing procedures and over 400 pieces of evidence covered by the audits, and a description of the several findings _

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5. The discrepancy report Page 24, line 7 initiated regarding the use

, of Stress Intensification Factors.

6. The Project audit of the Page 24, lines 15 to 22 Unit 2 internal review of Unit 1 Verification Program results.

7. Documentation of the audits Page 25, lines 1 to 7 and quality monitoring activities regarding the process of reviewing as-built information and of determining conformance with the design analysis. ,

l PG&E Panel 6 PG&E Panel 6 Testimony

1. The lists of " design Page 45, line 16 to page elements" for the AFWS, the 46, line 11 K160-V AC system, and the CRVPS I

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