ML20024D219
| ML20024D219 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/27/1983 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | CALIFORNIA, STATE OF |
| References | |
| NUDOCS 8308030319 | |
| Download: ML20024D219 (32) | |
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1 UNITED STATES OF AMERICA F AUG i 1983 > d 2 NUCLEAR REGULATORY COMMISSION m ere=se. p g D g essur.
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5
6 , ,
7 In the Matter of )
8 ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 9 )
Diablo Canyon Nuclear Power Plant ) (Reopened Hearing --
10 Units Nos. 1 and 2 ) Design Quality
, ) Assurance) 11 12 13 14 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S SECOND SET OF INTERROGATORIES 15 TO GOVERNOR DEUKMEJIAN
- 16 17 18 Pursuant to 10 C.F.R. $ 2.740b, Licensee PACIFIC 19 GAS AND ELECTRIC COMPANY hereby propounds the following 20 Interrogatories to GOVERNOR DEUKMEJIAN.
21 INSTRUCTIONS 22 1. All information is to be divulged which is in 23 the possession of the individual, association, or corporate 24 Party, their attorneys, consultants, investigators, agents, 25 employees, witnesses or other representatives of the named 26 Party.
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4 1 2. Where you have incomplete information that 2 precludes your fully answering an interrogatory, give such 3 information as you have and state what information you do 4 not have. If you are unable to give the information in the 5 form sought but have the information aggregated differently, 6 give the information in the form in which you have it and , ,
7 explain the reason for the deviation.
8 3. When asked in the interrogatories below to 9 identify or to give the. identity of a person, please give 10 the following information about him or her:
11 (a) full name; 12 (b) present job title, employer, and 13 telephone number.
i 14 4. When asked in the interrogatories below to 15 identify or to give the identity of a document or writing,
-16 please give the following information about the document:
17 (a) its title, if any; 18 (b) its nature (e.g., letter, memorandum, 19 chart, computer printout, ledger);
20 (c) the date, if any, stated on the 21 document; 22 (d) the identity of each person who signed 23 it; 4
24 (e) the identity of each person to whom it 25 is addressed; 26 ///
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1 5. Where an individual Interrogatory calls for 2 an answer which involves more than one part, each part of 3 the answer should be clearly set out so that it is 4 understandable.
5 6. These Interrogatories are intended as 6 continuing Interrogatories, requiring you to answer by 7 supplemental answer, setting forth any information within 8 the scope of the Interrogatories as may be acquired by you, 9 your agents, attorneys or representatives following your 10 original answers up to the time of hearing.
11 7. " Documents" include printed material, writ-i 12 ings, handwritten notes, photographs, xerox repoductions, 13 and audio or video recordings. " Writings" and " recordings" 14 consist of letters, words, or numbers, or their equivalent, 15 set down by handwriting, typewriting, printing, i
l 16 photostating, photographing, magnetic impulse, mechanical or i
17 electronic recording, or other form of data compilation, as 18 defined in Rule 1001 of the Federal Rules of Evidence, 28 l
19 U.S.C.
20 INTERROGATORIES 21 1. State each dnd every fact upon which you base 22 your contention that the licensee has failed to timely 23 develop and implement a systematic quality assurance / quality 24 control program for the design of safety related structures, 25 systems and components for design work at Diablo Canyon 26 Units 1 and 2 since November 1, 1981.
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1 2. State each and every fact upon which you base 2 your contention that the licensee's major subcontractors at 3 Diablo Canyon Units 1 and 2 have failed to timely develop 4 and implement a systematic quality assurance / quality control 5 program for the design of safety related structures, systems 6 and components for design work at Diablo Canyon Units 1 and , ,
7 2 since November 1, 1981.
8 3. Please list each and every major subcontrac-9 tor for Diablo Canyon Units 1 and 2 who has been involved in 10 the design of safety related structures and/or systems 11 and/or components.
12 (a) For each such subcontractor state:
13 (i) the time period when the subcontractor did design 14 of safety related structures, systems and 15 components for Diablo Canyon Units 1 and 2.
16 (ii) the time period you allege when the subcontractor j 17 did not develop and implement a systematic quality 18 assurance / quality control program.
19 4. For each and every major subcontractor for 20 Diablo Canyon Units 1 and 2, state specifically each and 21 every fact you rely on as a basis for your allegation that 22 each such subcontractor's design quality assurance program 23 failed to comply with criterion 1 of Appendix B to 10 C.F.R. 24 'part 50 prior to November 1, 1981.
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u 1 5. For each and every major subcontractor for 2 Diablo Canyon Units 1 and 2, state specifically each and 3 every fact you rely on as a basis for your allegation that 4 each such subcontractor's' design quality assurance program 5 failed to comply with criterion 2 of Appendix B to 10 C.F.R. 6 part 50 prior to November 1, 1981.
7 6. For each and every major subcontractor for 8 Diablo Canyon Units 1 and 2, state specifically each and 9 every fact you rely on as a basis for your allegation that 10 each such subcontractor's design quality assurance program 11 failed to comply with criterion 3 of Appendix B to 10 C.F.R. 12 part 50 prior to November 1, 1981.
13 7. For each and every major subcontractor for 14 Diablo Canyon Units 1 and 2, state specifically each and I 15 every fact you rely on as a basis for your allegation that 16 each such subcontractor's design quality assurance program 17 failed to comply with criterion 4 of Appendix B to 10 C.F.R. 18 part 50 prior to November 1, 1981.
19 8. For each and every major subcontractor for 20 Diablo . Canyon Units 1 and 2, state specifically each and 21 every fact you rely on as 'a basis for your allegation that 22 each such subcontractor's design quality assurance program 23 failed to comply with criterion 5 of Appendix B to 10 C.F.R. 24 part 50 prior to November 1, 1981.
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1 9. For each and every major subcontractor for 2 Diablo Canyon Units 1 and 2, state specifically each and 3 every fact you rely on as a basis for your allegation that 4 each such subcontractor's design quality assurance program 5 failed to comply with criterion 6 of Appendix B to 10 C.F.R. 6 part 50 prior to November 1, 1981. .
7 10. For each and every major subcontractor for 8 Diablo Canyon Units 1 and 2, state specifically each and 9 every fact you rely on as a basis for your allegation that 10 each such subcontractor's design quality assurance program 11 failed to comply with criterion 7 of Appendix B to 10 C.F.R. 12 part 50 prior to November 1, 1981.
13 11. For each and every major subcentractor for 14 Diablo Canyon Units 1 and 2, state specifically each and 15 every fact you rely on as a basis -for your allegation that 16 each such subcontractor's design quality assurance program 17 failed to comply with criterion 10 of Appendix B to 10 18 C.F.R. part 50 prior to November 1, 1981.
19 12. For each and every major subcontractor for l
20 Diablo Canyon Units 1 and 2, state specifically each and 21 every fact you rely on as a basis for your allegation that 22 each such subcontractor's design quality assurance program 23 failed to comply with criterion 16 of Appendix B to 10 24 C.F.R. part 50 prior to November 1, 1981.
25 13. For each and every major subcontractor for 26 Diablo Canyon Units 1 and 2, state specifically each and
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1 every fact you rely on as a basis for your allegation that l 2 each such subcontractor's design quality assurance program 3 failed to comply with criterion 17 of Appendix B to 10 4 C.F.R. part 50 prior to November 1, 1981.
5 14. For each and every major subcontractor for i 6 Diablo Canyon Units 1 and 2, state specifically each and 7 every fact you rely on as a basis for your allegation that 8 each such subcontractor's design quality assurance program l
9 failed to comply with criterion 18 of Appendix B to 10 10 C.F.R. part 50 prior to November 1, 1981.
11 15. For each and every major subcontractor for 12 Diablo Canyon Units 1 and 2, state specifically each and 13 every fact you rely on as a basis for your allegation that 14 each such subcontractor's design quality assurance program 15 failed to comply with criterion 1 of Appendix B to 10 C.F.R. 16 part 50 since November 1, 1981.
17 16. For each and every major subcontractor for 18 Diablo Canyon Units 1 and 2, state specifically each and 19 every fact you rely on as a basis for your allegation that 20 each such subcontractor's design quality assurance program 21 failed to comply with critdrion 2 of Appendix B to 10 C.F.R. 22 part 50 since November 1, 1981.
23 17. For each and every major subcontractor for 24 Diablo Canyon Units 1 and 2, state specifically each and 25 every fact you rely on as a basis for your allegation that 26 each such subcontractor's design quality assurance program
1 failed to comply with criterion 3 of Appendix B to 10 C.F.R. 2 part 50 since November 1, 1981.
3 18 For each and every major subcontractor for 4 Diablo Canyon Units 1 and 2, state specifically each and 5 every fact you rely on as a basis for your allegation that 6 each such subcontractor's design quality assurance program 7 failed to comply with criterion 4 of Appendix B to 10 C.F.R. 8 part 50 since November 1, 1981.
9 19. For cach and every major subcontractor for 10 Diablo Canyon Units 1 and 2, state specifically each and 11 every fact you rely on as a basis for your allegation that 12 each such subcontractor's design quality assurance program 13 failed to comply with criterion 5 of Appendix B to 10 C.F.R. 14 Part 50 since November 1, 1981.
15 20. For each and every -major subcontractor for 16 Diablo Canyon Units 1 and 2, state specifically each and 17 every fact you rely on as a basis for your allegation that 18 each such subcontractor's design quality assurance program 19 failed to comply with criterion 6 of Appendix B to 10 C.F.R. 20 part 50 since November 1, 1981.
21 21. For each and every major subcontractor for 22 Diablo Canyon Units 1 and 2, state specifically each and 23 every fact you rely on as a basis for your allegation that 24 each such subcontractor's design quality assurance program 25 failed to comply with criterion 7 of Appendix B to 10 C.F.R. 26 part 50 since November 1, 1981.
1 22. For each and every major subcontractor for 2 Diablo Canyon Units 1 and 2, state specifically each and 3 every fact you rely on as a basis for your allegation that 4 each such subcontractor's design quality assurance program 5 failed to comply with criterion 10 of Appendix B to 10 6 C.F.R. part 50 since November 1, 1981.
7 23. For each and every major subcontractor for 8 Diablo Canyon Units 1 and 2, state specifically each and 9 every fact you rely on as a basis for your allegation that 10 each such subcontractor's design quality ass.urance program 11 failed to comply with criterion 16 of Appendix B to 10 12 C.F.R. part 50 since November 1, 1981.
13 24. For each and every major subcontractor for 14 Diablo Canyon Units 1 and 2, state specifically each and 15 every fact you rely on as a basis for your allegation that 16 each such subcontractor's design quality assurance program l 17 failed to comply with criterion 17 of Appendix B to 10 18 C.F.R. part 50 since November 1, 1981.
19 25. For each and every major subcontractor for 20 Diablo . Canyon Units 1 and 2, state specifically each and 21 every fact you rely on as 'a basis for your allegation that 22 each such subcontractor's design quality assurance' program 23 failed to comply with criterion 18 of Appendix B to 10 24 C.F.R. part 50 since November 1, 1981.
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4 1 26. State specifically each and every fact you 2 rely on as a basis for your allegation that the licensee's 3 design quality assurance program for Diablo Canyon Units 1 4
4 and 2 failed to comply with criterion 1 of Appendix B to 10 5 C.F.R. part 50 since November 1, 1981.
'6 27. State specifically each and every fact you 7 rely on as a basis for your allegation that the licensee's 8 design quality assurance program for Diablo Canyon Units 1 9 and 2 failed to comply with criterion 2 of Appendix B to 10 10 C.F.R. part 50 since November 1, 1981.
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11 28. State specifically each and every fact you 12 rely on as a basis for your allegation that the licensee's 13 design quality assurance program for Diablo Canyon Units 1 14 and 2 failed to comply with criterion 3 of Appendix B to 10 15 C.F.R. part 50 since November 1, 1981.
l 16 29. State specifically each and every fact you 17 rely on as a basis for your allegation that the licensee's 18 design quality assurance program for Diablo Canyon Units 1 19 and 2 failed to comply with criterion 4 of Appendix B to 10 20 C.F.R. part 50 since November 1, 1981.
21 30. State specifically each and every fact you 22 rely on as a basis for your allegation that the licensee's 23 design quality assurance program for Diablo Canyon Units 1 24 ~ and 2 failed to comply with criterion 5 of Appendix B to 10 25 C.F.R. part 50 since November 1, 1981.
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1 1 31. State specifically each and every fact you 2 rely on as a basis for your allegation that the licensee's 3 design quality assurance program for Diablo Canyon Units 1 4 and-2 failed to comply with criterion 6 of Appendix B to 10 5 C.F.R. part 50 since November 1, 1981.
6 32. State specifically each and every fact you t
7 rely on as a basis for your allegation that the licensee's 8 design quality assurance program for Diablo Canyon Units 1 9 and 2 failed to comply with criterion 7 of Appendix B to -10 10 C.F.R. part 50 since November 1, 1981.
11 33. State specifically each and every fact you 12 rely on as a basis for your allegation that the licensee's 13 design quality assurance program for Diablo Canyon Units 1 14 and 2 failed to comply with criterion 10 of Appendix B to 10 15 C.F.R. part 50 since November 1, 1981.
16 34. State specifically each and every fact you 17 rely on as a basis for your allegation that the licensee's 18 design quality assurance program for Diablo Canyon Units 1 19 and 2 failed to comply with criterion 16 of Appendix B to 10 20 C.F.R. part 50 since November 1, 1981.
21 35. State specifically each and every fact you 22 rely on as a basis for your allegation that the licensee's 23 design quality assurance program for Diablo Canyon Units 1 24 and 2 failed to comply with criterion 17 of Appendix B to 10 25 C.F.R. part 50 since November 1, 1981.
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l 1 36. State specifically each and every fact you 2 rely on as a basis for your allegation that the licensee's 3 design quality assurance program for Diablo Canyon Units 1 4 and 2 failed to comply with criterion 18 of Appendix B to 10 5 C.F.R. part 50 since November 1, 1981.
6 37. List. specifically each and every licensee , ,
7 commitment set forth in the Diablo Canyon FSAR which you 8 allege has not been achieved as a result of the licensee's 9 design quality assurance program since November 1, 1981.
10 38. State specifically each and every fact upon 11 which you base your allegation that the licensee's design 12 quality assurance program since November 1, 1981 has caused 13 commitments in the Diablo Canyon FSAR not to be achieved.
14 39. List specifically each and every license 15 commitment set forth in the Diablo Canyon FSAR which you 16 allege has not been achieved as a result of major 17 subcontractors' design quality assurance programs since 18 November 1, 1981.
19 40. List specifically each and every portion of 20 the licensee's design quality assurance program from 21 November 1, 1981 to the present which you believe is 22 deficient.
23 41. State each and every fact upon which you base 24 your judgment regarding deficiency as to each such portion 25 of licensee's design quality assurance program.
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1 42. List specifically each and every implementing 2 procedure of the licensee's design quality assurance program 3 from November 1, 1981 to the present which you believe to be 4 deficient.
5 43. State each and every fact upon which you base 6 your judgment regarding each such deficiency for each such 7 implementing procedure of the licensee's design quality 8 assurance program.
I 9 44. For each and every major subcontractor for 10 Diablo Canyon Units 1 and 2 since November 1, 1981, list 11 specifically each and every portion of each such 12 subcontractor's design quality assurance program which you 13 believe to be deficient.
14 45. State each and every fact upon which you base 15 your judgment regarding each such deficiency for each such 1
16 portion of each such subcontractor's design quality I
l l 17 assurance program.
18 46. For each and every major subcontractor for l 19 Diablo Canyon Units 1 and 2 since November 1, 1981, list 20 specifically each and every implementing procedure of each 21 such subcontractor's design quality assurance program which 22 you believe to be deficient.
l l 23 47. State each and every fact upon which you base l
l 24 your Judgment regarding each such deficiency for each such 25 implementing procedure of each such subcontractor's design 26 quality assurance program.
1 48. Do you believe there are any of the 18 2 criteria of Appendix B to 10 C.F.R. part 50 which the 3 licensee's design quality assurance program does not 4 address?
5 If so, please list each such criterion.
1 j 6 49. Do you believe there are any of the 18 - -
t 7 criteria of Appendix B to 10 C.F.R. part 50 which any of the 8 major subcontractor's design quality assurance programs do 9 not address?
10 If so, for each such subcontractor, list each 11 such criterion.
12 50. State each and every fact upon which you base 13 your allegation that the scope of the IDVP's review of the 14 seismic design of safety related SS&Cs is too narrow.
15 51. Please identify each and every document which 16 you claim supports each fact set forth in the preceding 17 response and correlate each such document as specifically as 18 possible (page and paragraph number) with each such fact.
'9 52. State each and every fact upon which you base 20 your allegation that the IDVP did not verify samples from l
21 each of the seismic design activities.
22 53. Please identify each and every document which 23 you claim supports each fact set forth in the preceding 24 ~ response and correlate each such document as specifically as 25 possible (page and paragraph number) with each such fact.
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1 54. State each and every fact upon which you base 2 your allegation 'that the IDVP did not verify samples from 3 each of the design groups in the design chain performing the 4 seismic design activities it did review.
5 5 5 .' Please identify each and every document which 6 you claim supports each fact set forth in the preceding 7 response and correlate each such document as specifically as 8 possible (page and paragraph number) with each such fact.
9 56. State each and every fact upon which you base l
i 10 your allegation that the IDVP did not verify samples from 11 each of the non-seismic design activities.
( - 12 57. Please identify each and every document which
' 13 you claim supports each fcct set forth in the preceding 14 response and correlate each such document as specifically as 15 Possible (page and paragraph number) with each such fact'.
16 58. State each and every fact upon which you base 17 your allegation that the IDVP did not verify samples from 18 each of the design groups in the design chain that performed 19 the non-seismic design activities it did review.
20 59. Please identify each and every document which 21 you claim supports each fact set forth in the preceding 22 response and correlate each such document as specifically as l 23 Possible (page and paragraph number) with each such fact.
24 60. State each and every fact upon which you base 25 your allegation that the number of samples obtained for the 26 non-seismic design activities the IDVP did verify are
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t 1 insufficient to provide mathematically verifiable 2 conclusions about even those activities.
- 3 61. Please identify each and every document which 4 you claim supports each fact set forth in the preceding 5 response and correlate each such document as specifically as 6 possible (page and paragraph number) with each such fact.
7 62. State each and every fact upon which you base 8 your allegation that the IDVP has accepted substitution of 9 mean measured performance of structures and materials in 10 lieu of code-specified minima.
11 63. Please identify each and every document which i
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12 you claim supports each fact set forth in the preceding 13 response and correlate each such document as specifically as 14 possible (page and paragraph number) with each such fact.
15 64. State each and every fact upon which you base 16 your allegation that the IDVP has-accepted deviations from 17 the equipment standards set forth in PG&E's license 18 commitments without providing an adequate engineering 19 justification for the change.
20 65. Please identify each and every document which 21 you claim supports each fact set forth in the preceding 22 response and correlate each such document as specifically as 23 possible (page and paragraph number) with each such fact.
24 66. State each and every fact upon which you base 25 your allegation that the IDVP has failed to ascertain the 26 root cause of the deviation from PG&E's license commitments
t 1 and the regulatory requirements that it was and is 2 discovering.
3 6 7 .- Please identify each and every document which 4 you claim supports each fact set forth in the preceding 5 response and correlate each such document as specifically as l
l 6 possible (page and paragraph number) with each such fact.
7 68. State each and every fact upon which you base 8 your allegation that the IDVP has failed to verify indepen-9 dently that all safety related structures, systems, and com-10 ponents at Diablo Canyon meet PG&E's licensing commitments.
11 69. Please identify each and every document which I
12 you claim supports each fact set forth in the preceding 13 response and correlate each such document as specifically as 14 possible (page and paragraph number) with each such fact.
15 70. State each and every fact upon which you base 16 your allegation that the IDVP has performed no independent 17 verifications, but has merely checked data inputs to models 18 used by PG&E.
19 71. Please identify each and every document which 20 you claim supports each fact set forth in the preceding -
21 response and correlate eacli such document as specifically as 22 possible (page and paragraph number) with each such fact.
23 72. State each and every fact upon which you base 24 your allegation that the IDVP has failed to verify that 25 modeling by PG&E of ' soils properties for the containment 26 building is justified and proper.
1 73. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and-correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
5 74. State each and every fact upon which you base 6 your allegation that the IDVP has failed to verify PG&E's 7 computations for modes in the containment building having 8 frequencies between 20 and 33 HZ.
9 75. Please identify each and every document which 10 you claim supports each fact set forth in the preceding 11 response and correlate each such document as specifically as 12 possible (page and paragraph number) with each such fact.
13 76. State each and every fact upon which you base 14 your allegation that the IDVP has failed to verify that use 15 of inconsistent seismic techniques of modeling of accelera-16 tions, displacements, and shell forces in the containment 17 building is justifiable and proper.
18 77. Please identify each and every document which 19 you claim supports each fact set forth in the preceding 20 response and correlate each such document as specifically as 21 possible (page and paragraph number) with each such fact.
22 78. State each and every fact upon which you base
.23 your allegation that the IDVP has failed to verify that 24 ' failure by PG&E to use two horizontal components in its 25 seismic modeling of the containment building for the DE and 26 DDE, as it did for the Hosgri, is justifiable and proper.
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1 79. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and. correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
5 80. State each and every fact upon which you base 6 your allegation that the IDVP failed to verify that use by 7 PG&E of inappropriate and potentially dangerous stress 8 factors and load factors for steel still used in the 9 containment building, is justifiable and proper.
10 81. Please identify each and every document which 11 you claim supports each fact set forth in the preceding 12 response and correlate each such document as specifically as 13 possible (page and paragraph number) with each such fact.
14 82. State each and every fact upon which you base 15 your allegation that the IDVP has failed to verify that 16 PG&E's failure to specify all damping values used in 17 modeling of each mode in the containment building, is 18 justifiable and proper.
19 83. Please identify each and every document which 20 you claim supports each fact set forth in the preceding 21 response and correlate eacif such document as specifically as 22 possible (page and paragraph number) with each such fact.
23 84. State each and every fact upon which you base 24 your allegation that the IDVP has failed to verify that the 25 values used by PG&E in modeling soils properties for the 26 auxiliary building are correct and properly used.
1 85. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
5 86. State each and every fact upon which you base
{ 6 your allegation that the IDVP has failed to verify that all 7 damping factors used by PG&E in modeling of the DE for 8 auxiliary buildings are conservative and proper.
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[ 9 87. Please identify each and every document which 10 you claim supports each fact set forth in the preceding 11 response and correlate each such document as specifically as
! 12 possible (page and paragraph number) with each such fact.
13 88. State each and every fact upon which you base 14 your allegation that the IDVP has failed to verify that all l
15 stress values for concrete in shear walls used by PG&E in l
16 modeling the auxiliary building are conservative and proper.
17 89. Please identify each and every document which 18 you claim supports each fact set forth in the preceding 19 response and correlate each such document as specifically as
! 20 possible (page and paragraph number) with each such fact.
21 90. State each and every fact upon which you base 22 your allegation that the IDVP has failed to verify that l 23 PG&E's modeling of the crane in the turbine building at full l
24 ~ load is complete, covers all cases, and is conservative and 25 proper.
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1 91. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and. correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
5 92. State each and every fact upon which you base 6 your allegation that the IDVP has failed to verify that 7 PG&E's use of the double algebraic sum method of 8 calculation, rather than the square root of the sum of the 9 squares method, is justifiable and properly done.
10 93. Please identify each and every document which 11 you claim supports each fact set forth in the preceding 12 response and correlate each such document as specifically as 13 possible (page and paragraph number) with each such fact.
14 94. State each and every fact upon which you base 15 your allegation that the IDVP has failed to verify that' i
16 PG&E's modeling of torsion factors by differing techniques l 17 for different buildings is conservative and properly done.
l 18 95. Please identify each and every document which 19 you claim supports each fact set forth in the preceding 20 response and correlate each such document as specifically as 21 possible (page and paragraph number) with each such fact.
22 96. State each and every fact upon which you base 23 your allegation that the IDVP has failed to verify how 24 hydrodynamic forces were computed by PG&E in its modeling of 25 the intake structure, and that such computation was properly 26 and correctly done.
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1 97. Please identify each and every document which 2 you claim supports each fact set forth in the preceding ,
3 response and. correlate each such document as specifically as 1
4 -possible (page and paragraph number) with each such fact.
5 98. State each and every fact upon which you base 6 your allegation that the IDVP has failed to verify that 7 PG&E's use .in modeling the intake structure of different 8 models for non-linear vertical dynamic amplification and for 9 horizontal seismic loading, and PG&E's method of combining 10 their responses, are justifiable and properly done.
11 99. Please identify each and every document which l 12 you claim supports each fact set forth in the preceding
'13 - response and correlate each such document as specifically as l 14 possible (page and paragraph number) with each such fact.
15 100. State each and every fact upon which you base 16 your allegation that the IDVP has failed to verify that PG&E's 17 use of ductility factors for steel and concrete in modeling 18 the intake structure is conservative and properly done.
19 101. Please identify each and every document which 20 you claim supports each fact set forth in the preceding 21 response and correlate each such document as specifically as 22 possible (page and paragraph number) with each such fact.
23 102. State each and every fact upon which you base 24 'your allegation that the standards which the IDVP utilized 25 to determine whether the non-seismic design activities it 26 reviewed met PG&E's license commitments were improper.
1 103. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and. correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
1 5 104. State each and every fact upon which you base 6 your allegation that the IDVP has accepted deviations from 7 the equipment standards set forth in PG&E's license 8 commitments without providing an adequate engineering 9 justification for the changes.
10 105. Please identify each and every document which 11 you claim supports each fact set forth in the preceding i
12 response and correlate each such document as specifically as 13 possible (page and paragraph number) with each such fact.
14 106. State each and every fact upon which you base l 15 your allegation that the IDVP has failed to ascertain the 16 root cause of the deviations from PG&E's license commitments
. 17 that it was and is discovering.
l 18 107. Please identify each and every document which
- l. 19 you claim supports each fact set forth in the preceding 20 response and correlate each such document as specifically as 21 possible (page and paragraph number) with each such fact.
22 108. State each and every fact upon which you base 23 your allegation that the IDVP has no systematic program for 24 verifying that the design of equipment supplied to PG&E from 25 its subcontractors met PG&E's license commitments for such 26 equipment.
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1 109. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
5 110. State each and every fact upon which you base 6 your allegation that the IDVP has failed to verify whether .
7 equipment and components supplied to PG&E by PG&E's 8 subcontractors met all seismic design requirements.
9 111. Please identify each and every document which 10 you claim supports each fact set forth in the preceding 11 response and correlate each such document as specifically as 12 possible (page and paragraph number) with each such fact.
13 112. State each and every fact upon which you base 14 your allegation that the IDVP has failed to verify whether 15 equipment supplied to PG&E by PG&E's subcontractors met all 16 non-seismic design requirements.
17 113. Please identify each and every document which 18 you claim supports each fact set forth in the preceding 19 response and correlate each such document as spac:ifically as 20 possible (page and paragraph number) with eaci och fact.
I 21 114. State each and every fact upon which you base 22 your allegation that the IDVP has failed to require PG&E to l
23 implement a corrective and preventative action program that l
24 'is sufficient to assure that the seismic design deficiencies 25 that have been uncovered do not exist in other unexamined 6 ///
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1 portions of the plant or will not be repeated in future f 2 design documents.
3 115.. Please identify each and every document which 4 you claim supports each fact set forth in the preceding 5 response and correlate each such document as specifically as
- 6 possible (page and paragraph number) with each such fact.
116.
~
7 State each and every fact upon which you base
- a your allegation that the IDVP has failed to look for the 9 root cause of the discrepancies it has found in the seismic 1
- 10 design.
l 11 117. Please identify each and every document which 1-'
12 you claim supports each fact set forth in the preceding 13 response-and correlate each such document as specifically as i 14 possible (page and paragraph number) with each such fact.
15 118. State each and every fact upon which you base 16 your allegation that the IDVP has failed to recognize the 17 generic nature of a number of the seismic design 18 discrepancies uncovered.
19 119. Please identify each and every document which 20 you claim supports each fact set forth in'the. preceding response and correlate each' such document as specifically as 21 l 22 possible (page and paragraph number) with each such fact.
23 120. State each and every fact upon which you base 24 your allegation that the IDVP has failed to require PG&E to 25 implement a corrective and preventative action program that i
26 is sufficient to assure that the non-seismic design 1
1 deficiencies that have been uncovered do not exist in other, 2 unexamined protions of the plant or will not be repeated in 3 future design documents.
4 121. Please identify each and every document which 5 you claim supports each fact set forth in the preceding 6 response and correlate each such document as specifically as ,
7 possible (page and paragraph number) with each such fact.
8 122. State each and every fact upon which you base 9 your allegation that the IDVP has failed to look for the 10 root cause of the discrepancies it has found in non-seismic 11 design.
12 123. Please identify each and every document which 13 you claim supports each fact set forth in the preceding 14 response and correlate each such document as specifically as 15 possible (page and paragraph number) with each such fact.
16 124. State each and every fact upon which you base 17 your allegation that the IDVP has failed to recognize the 18 generic nature of a number of the non-; seismic design l 19 deficiencies uncovered.
l 20 125. Please identify each and every document which l 21 you claim supports each fact set forth in the preceding 22 response and correlate each such document as specifically as 23 possible (page and paragraph number) with each such fact.
24 126. State each and every fact upon which you base 25 your allegation that the IDVP has failed to require PG&E to 26 implement a corrective and preventative action program that l
l
1 is sufficient to assure the deficiencies in the design 2 documents of its equipment subcontractors do not exist in 3 the design documents of contractors whose work was not 4 examined and will not occur in the design work of future 5 subcontractors.
6 127. Please identify each and every document which 7 you claim supports each fact set forth in the preceding 8 response and correlate each such document as specifically as 9 possible (page and paragraph number) with each such fact.
10 128. State each and every fact upon which you base 11 your allegation that the IDVP has no systematic program for 12 reviewing whether the seismic design modifications it has 13 requested that PG&E perform have occurred.
14 129. Please identify each and every document which 15 you claim supports each fact set forth in the preceding 16 response and correlate each such document as specifically as 17 Possible (page and paragraph number) with each such fact.
18 130. State each and every fact upon which you base 19 your allegation that the IDVP has no systematic program for 20 reviewing whether the non-seismic design modifications it 21 has requested that PG&E perform have occurred.
22 131. Please identify each and every document which 23 you claim supports each fact set forth in the preceding 24 response and correlate each such document as specifically as 25 Possible (page and paragraph number) with each such fact.
26 ///
' - - *------- - - - ye c ' *=w=-
- r-- r-'u-1 -" e-w=------ -+
o 1 132. State each and every fact upon which you base 2 your allegation that PG&E's Internal Technical Program ("ITP")
3 does not provide assurance, equivalent to Appendix B compli-4 ance, that PG&E has and will meet its license commitments for 4
5 the seismic design of SS&C's at Diablo Canyon.
6 133. Please identify each and every document which 7 you claim supports each fact set forth in the preceding 8 response and correlate each such document as specifically as 9 possible (page and paragraph number) with each such fact.
10 134. State each and every fact upon which you base 11 your allegation that PG&E and its major subcontractors
- 12 failed to develop and implement in a timely fashion a QA/QC 13 program for the design of important to safety but not safety 14 related SS&Cs at Diablo Canyon which met (and meet) the 15 requirements of GDC-1 of Appendix-A to 10 C.F.R. part 50 16 (" Appendix A").
17 135. Please identify each and every document which 18 you claim supports each fact set forth in the preceding 19 response and correlate each such document as specifically as 20 possible (page and paragraph number) with each such fact.
21 136. State each and every fact upon which you base 22 your allegation that the IDVP has not and will not provide 23 any assurance, equivalent to Appendix A compliance, that the L 24 ' design of important to safety but not safety related SS&Cs 25 at Diablo Canyon meets the regulatory requirements for the.
26 design of such equipment.
l
o 1 137. Please identify each and every document which 2 you claim supports each fact set forth in the preceding 3 response and. correlate each such document as specifically as 4 possible (page and paragraph number) with each such fact.
5 138. For each even numbered interrogatory from 6 number 50 through number 130, state specifically (section #,
7 page and line, etc.) where in the regulations, the 8 Commission order of November 19, 1981, the Denton letter of 9 November 19, 1981, or T.he IDVP's Phase I and II program 10 plans that the activity (or lack thereof) by the IDVP you 11 allege did (or did not) take place is required to take (or 12 not take) place.
13 139. Define " root cause" as used in your proposed 14 contention II A 1(c).
15 140. Define " equipment standards" as used in your 16 proposed contention II B 1(b).
17 141. Please list each and every " equipment 18 standard" set forth in PG&E's license commitments which you 19 believe the IDVP has accepted deviations from.
20 142. Define " torsion factors" as used in your 21 proposed contention II B 1("q).
22 143. Define " hydrodynamic forces" as used in your 23 proposed contention II B 1 (r).
24 144. Define " generic nature" as used in your 25 proposed contention II C 1(b).
26 ///
29-
- - - m,~ ay e <
, 1 142. Please list each regulation, or regulatory 2 guide, by specific section and/or subsection, which requires 3 the identification of a " root" cause when a deviation 4 occurs, or at any time, or which defines " root cause."
5 143. For each answer to these interrogatories, and 6 all subparts thereto, identify each person who participated 7 in the preparation of your answers pursuant to 10 C.F.R. 8 6 2.740b(b).
9 Respectfully submitted, 10 ROBERT OHLBACH 11 PHILIP A. CRANE, JR.
RICHARD F. LOCKE 12 Pacific Gas and Electric Company P.O. Box 7442 13 San Francisco, California 94120 (415).781-4211 14 ARTHUR C. GEHR 15 Snell & Wilmer 3100 Valley Center 16 Phoenix, Arizona 85073 (602) 257-7288 17 i BRUCE NORTON l 18 Norton, Burke, Berry & French, P.C.
P.O. Box 10569 19 Phoenix, Arizona 85064 (602) 955-2446 20 Attorneys for l 21 Pacific Gas and Electric Company l
l 22 23 % N l
By, XAALR )
i 24 Bruce Norton l
l 25 26 DATED: July 27, 1983.
. l UM., N,N UNITED STATES OF AMERICA -
5',\
NUCLEAR REGULATORY COMMISSION eq /{ .e g)
/ -
. Et In the Matter of ) i !', .T!
)
- c. , -
- A PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275 -
\ "'"
) Docket No. 50-323 .
65 Diablo Canyon Nuclear Power Plant, ) <. N ud 4
Units 1 and 2 )
)
N M.\ <
CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (have) been served today on the following by deposit in.the United States mail, properly stamped and addressed:
Judge John F. Wolf Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety and Licensing Board San Luis Obispo CA 93401 US Nuclear Regulatory Commission Washington DC 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission John Phillips, Esq.
Washington DC 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest Judge Jerry R. Kline 10951 W. Pice Blvd. - Suite 300 Atomic Safety and Licensing Board Los Angeles CA 90064 US N,uclear Regulatory Commission Washington DC 20555 David F. Fleischaker, Esq.
P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer l 1493 Southwood Arthur C. Gehr, Esq.
I San Luis Obispo CA 93401 Snell.& Wilmer 3100 Valley Bank Center Phoenix AZ 85073 l
Janice E. Kerr, Esq.
Public Utilities Commission l State of California Bruce Norton, Esq.
5246 State Building Norton, Burke ~, Berry & French, P.C.
350 McAllister Street P. O. Box 10569 San Francisco CA 94102 < Phoenix AZ 85064 i Mrs. Raye Fleming Chairman 1920 Mattie Road Atomic Safety and Licensing
-Shell Beach CA 93449 Board Panel
! US Nuclear Regulatory Commission 20555
-Mr. Frederick Eissler Washington DC i Scenic Shoreline Preservation Conference, Inc.
l 4623 More Mesa Drive -
Santa Barbara CA 93105
Chairman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Washington DC 20555 US Nuclear Regulatory Commission Washington DC 20555 Secretary US Nuclear Regulatory Commission Judge W. Reed Johnson Washington DC 20555 Atomic Safety and Licensing Appeal Board Attn: Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555 Lawrence J. Chandler, Esq. Judge John H. Buck Henry J. McGurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission Washington DC 20555 Washington DC 20555
-Mr. Richard B. Hubbard
- Michael J. Strumwasser, Esq.
MHB Technical Associates Susan L. Durbin, Esq.
1723 Hamilton Avenue Suite K Peter H. Kaufman, Esq.
San Jose CA 95125 3580 Wilshire Blvd. Suite 800 Los Angeles CA 90010 Mr. Carl Neiberger Telegram Tribune Maurice Axelrad, Esq.
P. O. Box 112 Lowenstein, Newman, Reis, and San Luis Obispo CA 93402 Axelrad, P.C.
1025 Connecticut Avenue NW Washington DC 20036 l
Dated: July 27, 1983 m Pacific Gas and' Ele ~ctric Company l
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- This copy sent via EXPRESS MAIL.
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