ML20045G956

Intervenor San Luis Obispo Mothers for Peace Motion to Compel PG&E to Respond to Third Set of Supplemental Interrogatories & Requests for Document Production,Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc

ML20045G956
Person / Time
Site:	Diablo Canyon
Issue date:	07/01/1993
From:	Culver N SAN LUIS OBISPO MOTHERS FOR PEACE
To:	Atomic Safety and Licensing Board Panel
References
CON-#393-14087 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9307160187
Download: ML20045G956 (3)

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UNITED STATES OF AMERICA 9 NUCLEAR REGULATORY COMMISSION '3 ""'t U r-Jssu ATOMIC SAFETY AND LICENSING BOARD In the Matter of Pacific Gas and Electric Company Docket Nos. 50-275-OLA-2 Diablo Conycn Nuclear Power Plant 50-323-OLA-2 Units 1 and 2 ASLBP No. 92-SS9-03-OLA-2 Facility Operating Licenses i

No. DPR-90 and DPR-82 July 1, 1993 l l

Intervenor Son Luis Obispo Mothers for Peace Motion to Compel Pacific Gas and Electric Company  !

to Respond to the Third Set of Supplemental Interrogatories and Requests for the Production of Documents i Filed by San Luis Obispo Mothers for Peace i

On June 9, 1993, the Son Luis Obisco Mothers for Peace ("SLOMFP") 3 1

filed its Third Set of Supplemental Interrogatories and Requests for the Production of Documents to Pacific Gas and Electric Company ("PG&E"). PGSE l 1

responded to SLOMFP supplemental interrogatories in PG&E's Response to Third Set of Supplemental Interrogatories and Requests for the Production i of Documents Coging] Filed by SLOMFP CJune 18, 1993].

For reasons provided below, some of PG&E's answers to SLOMFP inquiries ,

and requests for production of documents are inadequate and incomplete. j Pursuant to 10 CFR 2.790Cf] and 2.740Ce]C3], SLOMFP moves that the Atomic i Sofety and Licensing Board enter on Order compelling PG&E to answer certain of SLOMFP interrogatories.

Interrogatory lb: In this request, SLOMFP asks PG&E to provide the equipment qualification ("EO"] files for the components listed (check volves, Limitorque volve operators, cables with bonded Hypolon jockets and cables listed in Attachment 1 to IN 93-33). PG&E objects to this interrogatory because it relates to the environmental qualification of equipment, not to the maintenance of olready qualified equipment. SLCMFP disagrees; SLOMFP is not questioning if the equipment is qualified to EO specifications. SLOMFP is questioning uhether or not the equicment has 9

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been molntoined withir This the boundorles of its environmental is o molntenance qualifications.

ssue, cnd the only way to look at the specifications to make this determination is octual conditions to hich the equipment in the EQ files and compare them to the Interrogatory 2

is being subjected.

A pertion of of this interrogatory requested temperature measurements in the contai Ci3the results nment and comparison betueen Ci13the results of any these temperoture measurements and enviro nmental quellfication specificottons for important not -to sofety equipment. PGSE did respond to those requests.

should state that. If PGSE does not have that Information, it Interrogatory 6:

In this interrogatory, SLONFP requests information regarding PG&E's methods for measuring radi safety equipment ction exposure to important-to-in contolnment.

SLOMFP further asks for these measurements and Ci]the results of Ci13the results of any comporison betwe measurements and EQ specificottons en these is simply that PG&E's response to this interrogatory

" qualification margins are sufficient to asuure that all ED radiction quellfication doses exceed any possible plant operations by o large margin." does during normal This response is inadequate.

not measure radiction exposure to import If PG&E does ant-to sofety equipment in s

containment, PG&E should say so, Respectfully Submitted, f\* CA Noncy Cu er, President Son Luis P.O. Obispo Mothers for Peace Box 169 Pismo Beach, CA B3398

Certificate of Service 93 JUL o. i3r 4.1 I hereby certify that copies cf the foregoing Intervenor Son Luis Obispo Mothers for Peace Nation to Compel Pacific Gas ond Electric Company to Respond to the Third Set of Supplemental Interrogatories and Requests for the Production of Documents Filed by Son Luis Obispo Nothers for Peace and '

Intervenor Son Luis Obispo Mothers for Peace Response to Prehearing l Conference Order Re: INPO Documents have been served upon the following cersons by U.S. mail, first class.

Office of Commission Appellote Administrative Judge Adjudication Charles Bechhoefer, Chairman U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board

'ashington, DC 20555

. U.S. Nuclear Regulatory Commission Washington, DC 2055S Administrative Judge Jerry Kline Administrative Judge Atomic Sofety and Licensing Board Frederick J. Shan U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Joshington, 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 Truman Burns U.S. Nuclear Regulatory Commission Robert Kinosion Uoshington, DC 20555 Peter G. Fairchild, Esq.

California Public Utilities Commission Joseph B. Knotts, Jr., Esq. 505 von Ness Avenue Winston & Strown Son Francisco, CA 99102 1900 L Street, N.W.

Washington, DC 20005 Adjudicatory File Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Branch Ucshington, DC 20555 U.S. Nuclear Regulatory Commission

2 copies) Washington, DC 2055S C2 copies and origino1]

Robert R. Wellington, Esq.

Diablo Canyon Independent Safety Committee 857 Cass Street, Suite D Honterey, CA 93990 Christopher Ucener, Esq. ,

Richard Locke, Esq. '

Pacific Gas and Electric Co.

77 Secle Street son Francisco, CA 99106 Dated July 1, 1993, San Luis Obispo County, CA

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