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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 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference ML20059D2071993-08-24024 August 1993 Intervenor Exhibit I-MFP-193,consisting of Review of LER 1-90-015-00,re Docket 50-275,dtd 910118 ML20059D2241993-08-24024 August 1993 Intervenor Exhibit I-MFP-220,consisting of Protest of Util ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 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 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 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 IR 05000275/19910061993-08-24024 August 1993 Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411 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 1999-09-20
[Table view] |
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UNITED STATES OF AMERICA 9H J U M ;~ r "'3 3 > 42
T!
NUCLEAR REGULATORY COMMISSION A')'
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) ) (Reopened Hearing --
) Design Quality
-) Assurance)
JOINT INTERVENORS' RESPONSE TO PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES Joint Intervenors hereby respond to Pacific Gas and Electric Company's (" Applicant") June 10, 1983 First Set of Interrogatories to Joint Intervenors, as follows:
Response to Interrogatory No. 1:
Joint Intervenors object to this interrogatory on the ground that it is overly broad, burdensome and oppressive, and not reasonably calculated to lead to the discovery of relevant or admissible evidence. In addition, the information requested is fully available to the Applicant at any time since the subject employees are employed by the Applicant or its contractors. Thus, the requested information can be obtained simply by asking the employees themselves.
8307050242 830617 DR ADOCK 0500027 L
Response to Interrogatory No. 2:
At this time, Joint Intervenors have not decided what persons, if any, they may call or subpoena as _ witnesses at the reopened hearing on the issue of design quality assurance. >
Response to Interrogatory No. 3:
To the extent that this interrogatory is directed at'the individual Joint Intervenors, the response is that no such examinations have been conducted other than the review of IDVP and/or DCP reports already in the public record and in PGandE's possession. To the extent that this interrogatory is directed t
at counsel for the Joint Intervenors, Joint Intervenors object to this interrogatory as calling for information protected by the attorney-work product privilege.
Response to Interrogatory No. 4:
"Important to Safety" -- see 10 C.F.R. Part 50, Appendix A, Introduction.
" Safety-related" -- see 10 C.F.R. Part 100, Appendix A, l
III(c).
I See also Memorandum, Denton to NRR Personnel, " Standard Definitions for Commonly-Used Safety Classification Terms" (November 20, 1981) ("Denton Memorandum").
Response to Interrogatory No. 5:
To the extent-that this interrogatory requests identification of each individual structure that is "important u.
to safety" but not Class I, Joint Intervenors object to this interrogatory as overly broad, burdensome and oppressive, and not reasonably calculated to lead to the discovery of relevant or admissible evidence. Without waiving such objections, Joint Intervenors state that they are unable to provide the information requested because the Applicant's FSAR.for Diablo
~
Canyon fails to distinguish between structures that are "important to safety" and structures that are " safety-related."
Those terms are apparently used interchangeably by the Applicant.
e Response to Interrogarory No. 6:
To the extent that this interrogatory requests identification of each individual system that is "important to safety" but not Class I, Joint Intervenors object to this interrogatory as overly broad, burdensome and oppressive, and
- not reasonably calculated to lead to the discovery of relevant or admissible evidence. Without waiving such objections, Joint Intervenors state that they are unable to provide the information requested because the Applicant's FSAR for Diablo Canyon fails to distinguish between systems that are "important to safety" and systems that are " safety grade." Those terms are apparently used interchangeably by the Applicant.
Response to Interrogatory No. 7:
To the extent that this interrogatory requests identification of each individual component that is "important
I to safety" but not Class I, Joint Intervenors object to this interrogatory as overly broad, burdensome and oppressive, and not reasonably calculated to lead to the discovery of relevant or admissible evidence. Without waiving such objections, Joint Intervenors state that that they are unable to provide the information requested because the Applicant's FSAR.for Diablo Canyon fails to distinguish between components that are "important to safety" and components that are " safety-grade."
Those terms are apparently used interchangeably by the Applicant.
Response to Interrogatory No. 8:
See (1) 10 C.F.R. Part 50, Appendix A; (2) 10 C.F.R. Part 100, Appendix A; (3) Denton Memorandum; (4) Supplemental Affidavit of Richard B. Hubbard Concerning Breakdowns In the Diablo Canyon Quality Assurance Program, at 28-33 (March 26, 1983). For Mr. Hubbard's background and qualifications, see Affidavit of Richard B. Hubbard Concerning Breakdowns In the Diablo Canyon Quality Assurance Program (May 24, 1982).
Responses to Interrogatory No. 9:
None.
Response to Interrogatory No. 10:
None.
Response to Interrogatory No. 11:
None.
~
_4._
l
Response to Interrogatory No. 12:
None.
Response to Interrogatory No. 13:
Joint Intervenors object to this interrogatory on the ground that Mr. Hubbard is not employed by the Joint Intervenors, and thus the request should be directed either to Mr. Hubbard or to the Governor of California. To the extent that this interrogatory calls for the Joint Intervenors' definition of terms used by Mr. Hubbard, Joint Intervenors object that such information is irrelevant and not reasonably calculated to lead to the discovery of relevant or admissible evidence. Without waiving such objections, Joint Intervenors supply the following responses:
(a), (b). The following definitions are based on standard English usage as expressed in Webster's New Collegiate Dictionary:
(1) " safety-significance": that which is materially relevant to safety; (2) " errors": acts or beliefs which involve a departure from accuracy; mistakes; discrepancies; deficiencies; (3) " deficiencies": acts or states of being which are inadequate in scope or extent to comply with a specified program i
l or to accomplish a specified objective; (4) " safety implications": that which has import or relevance with respect to a condition of safety; (5) " design QA": see 10 C.F.R. Part 50, Appendix B, Introduction, as applied to the design process; (6) " safety hazard": a condition or state of being which imposes or threatens to impose a danger of harm.
(7) " quality control": see 10 C.F.R. Part 50, Appendix B, Introduction; (8) " root cause": an occurrence or state of being which accurately could be characterized as having been the precursor to a specific result or condition; (9) " basic cause": an occurrence or state of being which accurately could be characterized as having been the necessary precursor to a specific result or condition; (10) "QA breakdown": the failure of a program, action or ,
series of actions designed or intended to provide adequate confidence that a structure, system, or component will perform satisfactorily in service; (11) " extreme likelihood": a condition of being which strongly militates towards a specified result.
(12) " major errors": mistakes of material significance which are extreme in character.
(13) " rigorous and thorough design verification program":
l a program as described in Response to Interrogatory No. 21 infra; l
! (14) " design product": the ability of a program of quality assurance to attain certain levels of performance and safety.
L (15) " minor QA breakdown": a potentially damaging but l-i relatively less significant failure to comply with a program as described in subparagraph (10) above; (16) "QA finding": an error, deficiency, discrepancy, or
. other failure to comply with a prescribed QA program; (17) "QA observation": the gathering of data or conclusion of fact as a result of inquiry mandated by a program or system designed to monitor and assure certain levels of performance.
(c) The term " safety-significance" differs from the term "important to safety" and " safety-related" insofar as the latter have specfic meanings as outlined in Response to Interrogatory No. 4, supra.
(d) See answers 13 (a) (2) and 13 (a) (12) above.
(e) See answers 13 (a) (2) and 13 (a) (3) above.
(f) The term " major QA breakdown" refers to the occurrence of a more serious failure to comply with prescribed QA requirements or procedures than does the term "QA breakdown."
(g) See answers 13 (a) (10) and 13 (a) (16) .
(h) See answers 13 (a) (10) and 13 (a) (17) .
Response to Interrogatory No. 14:
I Joint Intervenors object to this interrogatory as vague and ambiguous, overly broad, burdensome, oppressive, and not reasonably calculated to lead to the discovery of relevant or i admissible evidence. Without waiving such objections, Joint 1
Intervenors state that given the significant number of ITRs, the cryptic manner in which they are written, the complexity of the subjects being reviewed, and the fact that Joint Intervenors' l _7-i
l
. I review of the ITRs is continuing and not yet complete, they are unable to respond to this interrogatory at this time.
Response to Interrogatory No. 15:
Joint Intervenors object to this interrogatory as vague and ambiguous, overly broad, burdensome, oppressive, and not reasonably calculated to lead to the discovery of relevant or admissible evidence. Without waiving such objections, Joint Intervenors state that given the size of the Final Report, the
! complexity of the subjects reviewed, and the fact that Joint Intervenors' review of the Phase I Final Report is continuing and not yet complete, they are unable to respond to this i
interrogatory at this time.
Response to Interrogatory No. 16:
Joint Intervenors have direct knowledge only of items viewed during site tours of the Diablo Canyon Nuclear Power Plant.
Response to Interrogatory No. 17:
(a) Because Mr. Hubbard is not employed by the Joint Intervenors but by Governor Deukmejian, this interrogatory is not properly directed to the Joint Intervenors.
(b) See Response to Interrogatory No. 17 (a) .
(c) To the extent that this interrogatory _ calls for documents upon which Mr. Hubbard relied when preparing his affidavits, such documents are attached to said affidavits. To
the extent that it calls for documents upon which Joint Intervenors relied, see the Hubbard affidavits and attachments, as well as the Commission's November 19, 1981 Order Suspending License.
Response to Interrogatory No. 18:
See Response to Interrogatory No. 17(a).
Response to Interrogatory No. 19:
Letter, Lawroski (ACRS) to Hendrie (NRC), " Report on Diablo Canyon Nuclear Power Station Units 1 and 2 (July 14, 1978)."
Response to Interrogatory No. 20:
No. Conservatism is required by NRC regulations notwithstanding a superior QA/QC program. The record in this case has established that no such QA/QC program existed at Diablo Canyon.
Response to Interrogatory No. 21:
See Response to Interrogatory No. 17 (a) . To the extent that the interrogatory requests Joint Intervenors' understanding of the phrase in the context of this proceeding, such a basis can be achieved only through a complete, statistically valid design verification and physical inspection of all Diablo Canyon SS&C's and other important safety features as outlined in the Ilubbard Supplemental Affidavit, the completion and verification of all modifications to such SS&C's, and the reverification and
_ . . . - . - . - - _. - _ _ _ . . _ . = . _ _
I l
retesting of all pre-op tests of SS&C's affected by the reverification, redesign, and reconstruction effort.
i Response to Interrogatory No. 22:
Such errors and discrepancies, as well as their significance and probable causes, are identified in Mr. Hubbard's affidavits and the attachments thereto, as well as in Joint Intervenors' June 7, 1982 and May 10, 1983 motions.
Response to Interrogatory No. 23:
The documents relied upon include, but are not necessarily limited to, those documents referred to in or attached as exhibits to Joint Intervenors' June 7, 1982 Motion; Joint Intervenors' May 10, 1982 Motion; Joint Intervenors' May 31, 1983 Response to Motion of Governor Deukmejian to Reopen the Record on Construction Quality Assurance; and the various affidavits of Richard B. Hubbard, each of which has been filed in this proceeding. As Joint Intervenors' review of the documents issued by the IDVP, DCP, and NRC progresses, the foregoing list will obviously increase.
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Response to Interrogatory No. 24:
These responses were prepared by Joint Intervenors with the assistance of councel.
DATED: June 17, 1983 Respectfully submitted, JOEL R. REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
ERIC HAVIAN, ESQ.
KENNETH GOLDENBERG, ESQ.
Center for Law in the Public Interest l 10951 W. Pico Boulevard '
Los Angeles, CA 90064 (213)470-3000 D".VID S. FLEISCHAKER, ESQ.
P. O. Box 1178
, Oklahoma City, OK 73101 4
- By _.
EL R. ICE?N#LDS Attorneys for Joint Inter-venors 1
SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION
' CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. PORSTER
\
k I .
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) )
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 27th day of June, 1983, I have served copies of the foregoing JOINT INTERVENORS' RESPONSE TO PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES, mailing them through the U.S. mails, first class, postage prepaid.
Thomas S. Moore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Commission Conference, Inc.
Washington, D.C. 20555. 4623 More Mesa Drive Santa Barbara, CA 93105 Dr. W. Reed Johnson Atomic Safety'& Licensing Malcolm H. Furbush, Esq.
Appeal Board Vice Presid1nt & General U.S. Nuclear Regulatory Counsel Commission Philip A. Crane, Esq.
- Washington, D.C. 20555 . Pacific Gas & Electric Company Post Office Box 7442 i Dr. John H. Buck San Francisco, CA 94106 Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
-y- r- , , - 1
T Docket & Service Branch David S. Fleischaker Office of the Secretary Post Office Box 1178 U.S. Nuclear Regulatory Oklahoma City, OK 73101 Commission Washington, D.C. 20555 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95725 Lawrence Chandler, Esq.
Office of the Executive Legal Arthur C. Gehr, Esq.
Director - BETH 042 Snell & Wilmer U.S. Nuclear Regulatory 3100 Valley Center Commission Phoenix, AZ 85073 Washington, D.C. 20555 Virginia and Gordon Bruno Herbert Brown, Esq. Pecho Ranch Lawrence Coe Lanpher, Esq. Post Office Box 6289 Alan Dynner, Esq. Los Osos, CA 93402 Kirkpatrick, Lockhart, Hill, Christopher, et al. Sandra and Gordon Silver 1900 M Street, N.W. 1760 Alisal Street Washington, D.C. 20036 San Luis Obispo, CA 93401 Nancy Culver Jance E. Kerr, Esq. 192 Luneta Lawrence Q. Garcia, Esq. San Luis Obispo, CA 93401 J. Calvin Simpson, Esq.
California public Utilities Carl Neiburger Commission Telegram Tribune 5246 McAllister Street Post Office Box 112 San Francisco, CA 94102 San Luis Obispo, CA 93402 John Van de Kamp, Attorney Bruce Norton, Esq.
General Norton, Burke, Berry Andrea Sheridan Ordin, Chief & French, P.C.
Attorney General 2002 E. Osborn Michael J. Strumwasser, Special Phoenix, AZ 85016 Counsel to the Attorney General State of California 3580 Wilshire Boulevard Suite 800 Los Angeles, CA 90010
'btCo^^ C- 60Mk AMANDA VARONA i