ML20077H736
| ML20077H736 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/04/1983 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| Shared Package | |
| ML20077H729 | List: |
| References | |
| NUDOCS 8308110255 | |
| Download: ML20077H736 (27) | |
Text
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8 1993,
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UNITED STATES OF AMERICA nuo 2
NUCLEAR REGULATORY COMMISSION q'
3 4
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5
6 7
In the Matter of
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8
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Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY
)
50-323 9
)
Diablo Canyon Nuclear Power Plant
)
(Reopened Hearing --
10 Units No. 1 and 2
)
Design Quality
)
Assurance) 12 13 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S SECOND SET OF INTERROGATORIES 14 TO JOINT INTERVENORS AND REQUEST FOR PRODUCTION OF DOCUMENTS 15 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 JOINT INTERVENORS.
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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2.
Where you have incomplete information that 2
prec.7.udes 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.
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; 24 (e) the identity of each person to whom it 25 is addressed; 26
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4 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-12 ings, handwritten notes, photographs, xerox repoductions, 13 and audio or video recordings.
" Writings" and " recordings" l
14 consist of letters, words, or numbers, or their equivalent, 15 set down by handwriting, typewriting,
- printing, 16 photostating, photographing. magnetic impulse, mechanical or 17 electronic recording, or other form of data compilation, as 18 defined in Rule 1001 of the Federal Rules of Evidence, 28 19 U.S.C.
20 INTERROGATORIES 21 1.
State each and every fact upon which you base 22 your contention that the Licensee has failed to develop and 23 implement in a timely fashion a quality assurance / quality 9
24 control program for the design and redesign of structures, 25 systems and components important to safety at Diablo Canyon i
26 since November 1, 1981.
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1 2.
State each and every fact upon which you base i
2 your contention that the Licensee's major subcontractors 3
have failed to develop and implement in a timely fashion a 4
quality assurance / quality control program for the design and 5
redesign of structures, systems and components important to 6
safety at Diablo Canyon since November 1, 1981.
7 3.
Please list each and every major subcontrac-8 tor for Diablo Canyon Units 1 and 2 whom you consider to 9
have been involved in the design of structures and/or 10 systems and/or components important to safety.
11 (a)
For each such subcontractor state:
1 12 (i) the time period when the subcontractor did design i
13 of structures, systems and components important to 14 safety for Diablo Canyon Units 1 and 2.
15 (ii) the time period you allege when the subcontractor 16 did not develop and implement a qual.ity 17 assurance / quality control program.
18 4.
For each and every major subcontractor for 19 Diablo Canyon Units 1 and 2, state specifically each and 20 every fact you rely on as a basis for your allegation that 21 each such subcontractor's' design quality assurance program-22 failed to comply with criterion 1 of Appendix B to 10 C.F.R. 23 Part 50 prior to November 1, 1981.
24 5.
For each and every major subcontractor for 25 Diablo. Canyon Units 1 and 2,_ state specifically each and 26 every fact you rely on as a basis for your allegation-that
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each such subcontractor's design quality assurance program 2
failed to comply with criterion 2 of Appendix B to 10 C.F.R. 3 Part 50 prior to November 1, 1981.
4 6.
For each and every major subcontractor for 5
Diablo Canyon Units 1 and 2, state specifically each and 6
every fact you rely on as a' basis for your allegation that 7
each such subcontractor's design quality assurance program' 8
failed to comply with criterion 3 of Appendix B to' 10 C.F.R. 9 Part 50 prior to November 1, 1981.
10 7.
For each and every major subcontractor for 11 Diablo Canyon Units 1 and-2, state specifically each and 12 every fact you rely on as a basis for your allegation that 13 each such subcontractor's design quality assurance program 14 failed to comply with criterion 4 of Appendix B to 10 C.F.R. 15 Part 50 prior to November 1, 1981.
16 8.
For each and every major subcontractor for 17 Diablo Canyon Units 1 and 2, state specifically each and 18 every fact you rely on as a basis for your allegation that 19 each such subcontractor's design quality assurance program 20 failed to comply with criterion 5 of Appendix B to 10 C.F.R. 21 Part 50 prior to November 1, 1981.
22 9.
For each and every major subcontractor for 23 Diablo Canyon Units 1 and 2, state specifically each and 24 every fact you rely on as a basis for your allegation that 25 each such subcontractor's design quality assurance program 26 gf i
1 failed to comply with criterion 6 of Appendix B to 10 C.F.R. 2 Part 50 prior to November 1, 1981.
3 10.
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 -7 of Appendix B to 10 C.F.R. 8 Part 50 prior to November 1, 1981.
9 11.
For each 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 10 of Appendix B to 10 14 C.F.R. Part 50 prior to November 1, 1981.
15 12.
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 11 of Appendix B to 10 20 C.F.R. Part 50 prior to November.1, 1981.
21 13.
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 16 of Appendix B to 10 26 C.F.R. Part 50 prior to November 1, 1981. -
1 14.
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 17 of Appendix B to 10 6
C.F.R. Part 50 prior to November 1, 1981.
7 15.
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 18 of Appendix B to 10 12 C.F.R. Part 50 prior to November 1, 1981.
13 16.
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 17 failed to comply with criterion 1 of Appendix B to 10 C.F.R. 18 Part 50 since November 1, 1981; 19 17.
For each and every major subcontractor for 20 Diablo Canyon Units 1 and 2, state specifically each and l
21 every fact you rely on as a basis for your allegation that-l 22 each such subcontractor's design quality assurance program 23 failed to comply with criterion 2 of Appendix B to 10 C.F.R. 24 Part 50 since November 1, 1981.
25 18.
For each and every major subcontractor for l
26 Diablo Canyon Units 1 and 2, state specifically each and - -
1 every fact you rely on as a basis for your allegation that 2
each such subcontractor's design quality assurance program 3
failed to comply with criterion 3 of Appendix B to 10 C.F.R. 4 Part 50 since November 1, 1981.
5 19.
For each and every major subcontractor for 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 9
failed to comply with criterion 4 of Appendix B to 10 C.F.R. 10 Part 50 since November 1, 1981.
11 20.
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 i
15 failed to comply with criterion 5 of Appendix B to 10 C.F.R. 16 Part 50 since November 1, 1981.
17 21.
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 criterion 6 of Appendix B to 10 C.F.R. 22 Part 50 since November 1, 1981.
23 22.
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 i -.
1 failed to comply with criterion 7 of Appendix B to 10 C.F.R. 2 Part 50 since November 1, 1981.
I 3
23.
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 i
6 each such~ subcontractor's design quality assurance program 7
failed to comply with criterion '10 of Appendix B to 10 8
C.F.R. Part 50 since November 1,.1981.
i 9
24.
For each and.every major subcontractor for 10 Diablo Canyon Units 1 and 2, state specifically eqch 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 11 of Appendix B to 10 14 C.F.R. Part 50 since November-1, 1981.
15 25.
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 16 of Appendix B to 10 20 C.F.R. Part 50 since November 1, 1981.
21 26.
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 i
25 failed to comply with criterion 17 of Appendix B to 10 26 C.F.R. Part 50 since November 1, 1981. _,
l 4
1 27.
For each and every major subcontractor for i
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 18 of Appendix B to 10 6
C.F.R. Part 50 since November 1, 1981.
7 28.
State specifically each and every fact you 8
rely on as a basis for your allegation that the Licensee's 9
design quality assurance program for Diablo Canyon Units 1 10 and 2 failed to comply with criterion 1 of Appendix B to 10 11 C.F.R. Part 50 since November 1, 1981.
l 12 29.
State specifically each and every fact you 13 rely on as a basis for your allegation that the Licensee's 14 design quality assurance program for Diablo Canyon Units 1 l
15 and 2 failed to comply with criterion 2 of Appendix B to 10 16 C.F.R. Part 50 since November 1, 1981.
17 30.
State specifically each and every fact you 18 rely on as a basis for your allegation that the Licensee's 19 design quality assurance program for Diablo Canyon Units 1 20 and 2 failed to comply with criterion 3 of Appendix B to 10
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21 C.F.R. Part 50 since November 1, 1981.
22
- 31.. State specifically each ' and every fact you 23 rely on as a basis for your allegation that the Licensee's
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24 design quality assurance program for Diablo Canyon Units 1 25 and 2 failed to comply with criterion 4 of Appendix B to 10 l
. 26
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C.F.R. Part 50 since November 1, 1981..- -
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1 32.
State specifically each and every fact you 2
rely on as a basis for your allegation that the Licensee's j
3 design quality assurance program for Diablo Canyon Units 1 4
and 2 failed to comply with criterion 5 of Appendix B to 10 5
C.F.R. Part 50 since November 1, 1981.
6 33.
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 6 of Appendix B to 10 10 C.F.R. Part 50 since November 1, 1981.
11 34.
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 7 of Appendix B to 10 15 C.F.R. Part 50 since November 1, 1981.
16 35.
State specifically each and every fact you 17 rely on as a basis for your allegatina that the Licensee's 18 design quality assurance program for Diablo Canyon Units 1 19 and 2 failed to comply with criterion 10 of Appendix B to 10 20
~
C.F.R. Part 50 since November 1, 1981.
21 36.
State specifically each and every fact you 22 rely on as a basis for your allegation that the Licensee's i
23 design quality assurance program for Diablo Canyon Units 1 24 and 2 failed to comply with criterion 11 of Appendix B to 10 25 C.F.R. Part 50 since November 1, 1981.
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1 37.
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 16 of Appendix B to 10 5
C.F.R. Part 50 since November 1, 1981.
6 38.
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 17 of Appendix B to 10 10 C.F.R. Part 50 since November 1, 1981.
11 39.
State specifically each and every fact you
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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 18 of Appendix B to 10 15 C.F.R. Part 50 since November 1, 1981.
j 16 40.
Please identify each and every document which 17 you claim supports each fact set forth in your responses to 18 Interrogatories 1 through 39 above and correlate each such 19 document as specifically as possible (page and paragraph 20 number)'with each such fact.
21 41.
List specifically, including page and section 22 number, each and every license commitment set forth in the 23 Diablo Canyon FSAR which you allege has not been complied 24 with.
25 42.
For each license commitment. identified in the i
26 preceding response, state specifically each and every fact l.
5 1
upon which you base your allegation that the license 2
commitment has not been met.
3 43.
Please identify each and every document which 4'
you claim supports each fact set forth in the preceding j
5 response and correlate each such document (page and 6
paragraph number) with each such fact.
7 44.
List specifically each and every license 8
commitment set forth in the Diablo Canyon FSAR which you 9
allege has not been achieved as a result of the Licensee's 10 design quality assurance program since November 1, 1981.
11 45.
State specifically each and every fact upon 12 which you base your allegation that the Licensee's design 13 quality assurance program since November 1, 1981 has caused 14 commitments in the Diablo Canyon FSAR not to be achieved.
15 46.
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 (page and 18 paragraph number) with each such fact.
19 47.
List specifically each and every license 20 commitment set forth in the Diablo Canyon FSAR which you 21 allege has not been achieved as a result of major 22 subcontractors' design quality assurance programs since 23 November 1, 1981.
24 48.
State specifically each and every fact upon 25 which you base your allegation that major subcontractors' 26 design quality assurance programs since November 1, 1981. - - -
O 1
55.
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 (page and j
4 paragraph number) with each such fact.
5 56.
For each and every major subcontractor for 6
Diablo Canyon Units 1 and 2 since November 1, 1981, list 7
specifically each and every portion of each such 8
subcontractor's design quality assurance program which you 9
believe to be deficient.
10 57.
State each and every fact upon which you base 11 your judgment regarding each such deficiency for each such 12 portion of each such subcontractor's design quality 13 assurance program.
14 58.
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 (page and 17 paragraph number) with each such fact.
18 59.
For each and every major subcontractor for 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.
23 60.
State each and every fact upon which you base 24 your judgment regarding each such deficiency for each such 25 implementing procedure of each such subcontractor's design 26 quality assurance program..
1 61.
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 (page and 4
paragraph number) with each such fact.
5 62.
Do you believe there are any of the 18 6
criteria of Appendix B to 10 C.F.R. Part.50 which the 7
Licensee's design quality assurance program does not 3
address?
9 If so, please list each such criterion.
10 63.
State specifically each and every fact upon 11 which you base your allegation that the criteria specified 12 in the preceding response have not. been addressed by 13 Licensee's design quality assurance program.
14 64.
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 (page and 17 paragraph number) with each such fact.
18 65.
Do you believe there are any of the 18 19 criteria of Appendix B to 10 C.F.R. Part 50 which any of the 20 major subcontractor's design quality assurance programs do 2- -
not address?
22 If so, for each such subcontractor, list each 23 such criterion.
24 66.
State specifically each and every fact upon 25 which you base your allegation that the criteria specified 26
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1 in the preceding response have not been addressed by major 2
subcontractors' design quality assurance programs.
3 67.
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 (page and 6
paragraph number) with each such fact.
7 68.
List specifically each and every " applicable 8
regulatory standard" which you allege has not been complied 9
with as a result of the Licensee's design quality assurance 10 program.
11 69.
For each regulatory standard identified in 12 the preceding response, state specifically each and every 13 fact upon which you base your allegation that such standard 14 has not been met.
15 70.
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 (page and 18 paragraph number) with each such fact.
19 71.
For each applicable regulatory standard 20 identified in your answer to Interrogatory 68, state 211.
specifically each and every fact upon which you base your 22 allegation that neither the ITP nor the IDVP_has provided 23 reasonable assurance of compliance with such standard.
24 72.
Pleare identify each and every document which 25 you claim supports each fact set forth in the preceding 26 fff -
1 response and correlate each such document (page and 2
paragraph number) with each such fact.
3 73.
State each and every fact upon which you base 4
your allegation that the IDVP is inadequate.
5 74.
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 75.
State each and every fact upon which you base 10 your allegation that the scope of the IDVP's review is 11 inadequate.
12 76.
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 i
15 possible (page and paragraph number) with each such fact.
16 77.
State each and every fact upon which you base 17 your allegation that the IDVP did not address 18 nonsafety-grade SS&Cs important to safety.
19 78.
Please identify each and every document which l
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 79.
State each and every fact upon which you base l
4 24 your allegation that the IDVP utilized sampling rather than 25 100% reverification of nonseismic SS&Cs.
26
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1 80.
Please idenhify 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.
I 5
81.
State each and every fact upon which you base 6
your allegation that the IDVP did not adequately describe 7
the statistical basis for the criteria to be used in the 8
selection of a suitable number and type of samples under the 9
program and for the selection of items for additional 10 verification.
11 82.
Please identify each and every document which 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 83.
State each and every fact upon which you base 16 your allegation that the IDVP did not verify independently 17 the accuracy' or propriety of PGandE's recalculation of the 18 seismic design of the facility.
19 84.
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 l
22 possible (page and paragraph number) with each such fact.
l 23 85.
State each and every fact upon which you base 24 your allegation that the IDVP failed to assure that an 25 adequate QA/QC program for the corrective action program has l
26 been established and is being implemented.
1 1
86.
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 87.
Identify specifically each and every finding 6
and recommendation of the Brookhaven National Laboratory 7
("BNL") which you allege should be incorporated into the 8
Diablo Canyon design.
9 88.
Identify each_and every regulation which you 10 believe requires that each finding and recommendation of BNL 11 specified in the preceding response are required to be 12 incorporated into the Diablo Canyon design.
13 89.
Please identify each and every document which 14 you claim supports each fact set forth in the preceding 15 response and correlate each such document (page and 16 paragraph number) with each such fact.
17 90.
State each and every fact upon which you base i
18 your allegation that the IDVP failed to assure that the i
19 findings and recommendations of BNL have been fully 20 incorporated into the Diablo Canyon design.
21 91.
Please identify each and every document which 22 you claim supports each fact set forth in the preceding l
23 response and correlate each such document as specifically as 24 possible (page and paragraph number) with each such fact.
25 92.
State each and every fact upon which you base 26 your allegation that the IDVP failed.to verify that the.
1 redesign has actually been incorporated into the "as-built" 2
facility.
3 93.
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 94.
State each and every fact upon which you base 8
your allegation that the IDVP failed to identify and 9
eliminate the " root cause" of the seismic and nonseismic 10 design errors discovered at the plant.
11 95.
Please identify each and every document which 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 96.
State each and every fact upon which you base 16 your allegation that the Interim Technical Reports issued by 17 the IDVP fail to document adequately the basis for the IDVP 18 findings, recommendations and/or conclusions set forth in 19 such reports.
20 97.
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 98.
Specifically identify each and every test 25 referred to in your proposed contentions "previously 26 conducted with respect to any Diablo Canyon SS&C which have
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1 been affected by the redesign conducted since September 2
1981."
3 99.
Please identify each and every document which 1
4 you claim supports each fact set forth in the preceding 5
response and correlate each such document (page and 6
paragraph number) with each such fact.
7 100. For each.and every "previously conducted" 1
8 test referred to in your contentions, explain in detail why 9
the alleged inadequacies in the design quality assurance 10 programs would require verification of the validity of the 11 results of such tests.
12 101. 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 (page and 15 paragraph number) with each such fact.
16 102. State each and every fact upon which you base 17 your allegation that PGandE failed to systematically review l
18 and verify the validity of all results of tests previously 19 conducted with respect to any Diablo Canyon SS&C which have 20 been affected by the redesign since September 1981.
21 103. Please identify each and every document which 22 you claim supports each fact set forth in the preceding 23 response and correlate each such document as specifically as 24 possible (page and paragraph number) with each such fact.
25 104. Identify- 'and describe all
" additional 26 testing" referred to in your contentions which you allege is.
i
l 1
" required to demonstrate that as redesigned and modified all 2
Diablo Canyon SS&C's will perform satisfactorily in 3
service.
4 105. 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 (page and 7
paragraph number) with each such fact.
8 106. Identify each and every written test 9
procedure of PGandE or its subcontractors referred to in 10 your contentions which are prescribed by criterion 11 of 11 Appendix B to 10 C.F.R. Part 50.
12 107. 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 (page and 15 paragraph number) with each such fact.
16 108. State each and every fact upon which you base 17 your allegation that PGandE failed to identify and perform 18 the additional testing required to demonstrate that as 19 redesigned and modified all Diablo Canyon SS&Cs will' perform 20 satisfactorily in service.
21 109. Please identify each and every document which 22 you claim supports each fact set forth in the preceding 23 response and correlate each such document as specifically as 24 possible (page and paragraph number) with each such fact.
t 25 110.
For Interrogatories 71, 73, 75, 77, 79, 81, 26 83, 85, 87, 88, 90, 92, 94, and 96, state specifically !
1 (section #, page and line, etc.) where in the regulations, 2
the Commission order of November 19, 1981, the Denton letter 3
of November 19, 1981, or the IDVP's Phase I and II program 4
plans that the activity (or lack thereof) by the IDVP you 5
allege did (or did not) take place is required to take (or 6
not take) place.
7 111.
Define " root cause" as used in your proposed 8
contentions.
9 112.
Please list each regulation, or regulatory 10 guide, by specific section and/or subsection, which requires 11 the identification of. a " root" cause when a deviation 12 occurs, or at any time, or which defines " root cause."
13 113.
For each answer to these interrogatories, and 14 all subparts thereto, identify each person who participated 15
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17
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18 19 20 21 22 23 24 25 26 I
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1 in the preparation of your answers pursuant to 10 C.F.R. 2 5 2.740b(b).
3 Respectfully submitted, ROBERT OHLBACH 5
PHILIP A. CRANE, JR.
RICHARD F. LOCKE 6
Pacific Gas and Electric Company P.O. Box 7442 7
San Francisco, California 94120 (415) 781-4211 8
ARTHUR C. GEHR 9
Snell & Wilmer 3100 Valley Center 10 Phoenix, Arizona 85073 (602) 257-7288 BRUCE NORTON 12 Norton, Burke, Berry & French, P.C.
P.O. Box 10569 13 Phoenix, Arizona 85064 (602) 955-2446 Attorneys for 15 Pacific Gas and Electric Company 16 By xu2o 18
Bruce Norton 19 20 DATED:
August 4, 1983.
21 22 23 24 25 26
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UNITED STATES OF AMERICA e fI NUCLEAR REGULATORY COMMISSION 4
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In the Matter of
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t PACIFIC GAS AND ELECTRIC COMPANY
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Docket No. 50-275
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Docket No. 50-323
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i Diablo Canyon Nuclear Power Plant, )
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4 CERTIFICATE OF SERVICE 4
The foregoing documents of Pacific Gas and Electric Company have been served today:
1.
Licensee Pacific Gas and Electric Company's Third Set of Interrogatories to Governor Deukmejian and Second Request for Production of Documents 2.
Licensee Pacific Gas and Electric Company's Second Set 4
of Interrogatories to Joint Invervenors and Request for Production of Documents The above-mentioned documents 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 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Gordon Silver i
1760 Alisal Street Judge Glenn O.
Bright San Luis Obispo, CA 93401 Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission
- John Phillips, Esq.
Washington, D.C.
20555 Joel Reynolds, Esq.
Center for Law in the Public Interest Judge Jerry R.
Kline 10951 W.
Pico Blvd., Suite.300 Atomic Safety and Licensing Board Los Angeles, CA 90064 I
U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 David F.
Fleischaker, Esq.
t P. O.
Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City, OK 73101 c/o Betsy Umhoffer 1493 Southwood Arthur C.
Gehr, Esq.
San Luis Obispo, CA 93401 Snell & Wilmer 3100 Valley Bank Center i
Phoenix, AZ 85073 l
Janica E. Kerr, Etq.
Bruca Norton, Esq.
Public Utilitics Commincion Norton, Burke, Berry & French, P.C.
Stdte of California P. O. Box 10569 5246 State Building Phoenix, AZ 85064
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350 McAllister Street Scn Francisco, CA 94102 Chairman Atomic Safety and Licensing Mrs.. Raye Fleming Board Panel 1920 Mattie Road U.S. Nuclear Regulatory Commission Shall Beach, CA 93449 Washington, D.C.
20555 Chairman Judge Thomas S. Moore i
Atomic Safety and Licensing Chairman i
Appeal Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Secretary U.S. Nuclear Regulatory Commission Judge W. Reed Johnson Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Attn:
Docketing and Service U.S. Nuclear Regulatory Commission Section Washington, D.C.
20555 Lawrence J. Chandler, Esq.
Judge John H. Buck Henry J. McGurren Atomic Safety and Licensing U.S.
Euclear Regulatory Commission Appeal Board Office of Executive Legal Director-U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
- Mich'ael J.
Strumwasser, Esq.
Mr. Richard B.
Hubbard.
MHB Technical Associates Susan L.
Durbin, Esq.
4 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 Sen Luis Obispo, CA 93402
- Axelrad, P.C.
1025 Connecticut Avenue, N.W.
Mr. Frederick Eissler Washington, D.C.
20036 Scenic Shoreline Preservation Conference, Inc.
4623-More Mesa Drive Santa Barbara, CA 93105 l
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August 4, 1983 Pacific Gas and Electric Company
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