ML20005B920
| ML20005B920 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/14/1981 |
| From: | Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CALIFORNIA, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8109160120 | |
| Download: ML20005B920 (38) | |
Text
_
s 09/14/81
(
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
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50-323 0.L 5
co (Diablo Canyon Nuclear Power Plant )
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g# 1 NRC RESPONSE TO GOVERNOR EDMUND G. BROWN, JR.'S E g ', g
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p FIRST SET OF INTERROGATORIES AND SECOND F
ll REQUEST FOR PRODUCTION OF DOCUMENTS sf iN/ l g\\
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INTERROGATORIES Contention 1 (as restated by the Board in the August 4,1981 Memorandum and Order).
PG&E and the combined onsite, state and local emergency response plans and preparedness do not comply with 10 C.F.R. 50.33(g); 50.47 and the revised Appendix E to Part 50.
The Staff notes that to the extent these interrogatories ask for infor-faation related to FEMA's positions the Staff cannot respond. The NRC does not represent the FEMA Staff.
Any questions on FEMA's positions would be appropriately addressed to FEMA.
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, o interrogatory 1 For what regulatory. purpose did the NRC Staff request PG&E to consider the complicating effects of an earthquake on emergency preparedness and I
response at Diablo Canyon?
4
Response
The regulatory purpose was to insure that the Applicant's emergency plan had adequately taken into consideration the items discussed in the December 16, 1980 letter from the NRC to PG&E.
Interrogatory 2 (a)
Identify the Staff personnel who have met or spoken witn PG&E personnel concerning the potential complicating effects of an earthquake on emergency preparedness at Diablo Canyon.
(b)
Identify the PG&E personnel with whom such Staff personnel have
- met, f
(c)
State the dates of such meetings and describe the matters discussed.
(d)
Identify and describe each and every docunent, memorandum, and personal notes related to all such meetings and/or telephone conv3rsations.
Respon e a)
John R. Sears has spoken with PG&E personnel concerning the pote9 j
tial complicating effects of an earthquake on emergency prepared-ness at Diablo Canyon.
i l
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O i
-3a b)
John Sears spoke with Steve Skidmore, who is an employee of PG&E, and Don Davis,.who is an employee of TERA Corporation.
c)
John Sears' discussions took place on May 19, 1981 and September 11, 1981. The matter discus;ed was eartnquake emergency preparedness at Diablo Canyon.
d)
The documents which relate to the matter are the May 14, 1981 draft document ermitled " Technical Status of Earthquake Effects on Evacuation? by TERA and the September 2,1981 document entitled
" Earthquake Emergency Planning at Diablo Canyon, Vols. I, II and III" by TERA.
i Interrogatory 3 Describe the Staff position on each of the following matters.
Include in the answer a description of all analyses, reports, memoranda, or other documents in the possession, custody, or control of the NRC Staff which analyze or relate in any way to any or all of these matters:
(a) The time necessary to take onsite and/or offsite protective actions, including evacuation, in the event of a radiological emergency at Of ablo Canyon; I
(b) The feasibility of notifying persons in the backcountry of Montana de Oro State Park of a radiological emergency at Diablo Canyon.
(c) The correctness of the location of PG&E's real-time monitoring instruments; (d) The adequacy of the alternate evacuation route from the PG&E facility 1
to the north through tha Field Ranct.;
l l
(e) The complications to emergency response resulting from an earth-1 quake initiating and/or in conjunction with an accident at Diablo Canyon; and (f) The complications to emergency preparedness resulting from an earthquake prior to, and independent of, a radiological emergency at Diablo Ctnyon.
Response
a)
The NRC Staff position is that the Applicant's response of November 25, 1980 is satisfactory. The document is entitled
" Evacuation Time Assessment for the Diablo Canyon Nuclear Power Plant" and dated September,1980.
The time necessary to take onsite and/or offsite protective actions is dependent on the event.
A more detailed discussion of the Commission's position is set forth in paragraph VI of the Supplemen-tary Information to the final rule changes to the Commission's emergency planning requirements (Fed. Reg. 55402, August 19,1980).
b)
The NRC Staff position is that the system for notifying persons in Montana de Oro State Park is satisfactory. The Early Werning System is described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 7.2.2 and in the San l
i Luis Obispo Nuclear Power Plant Emergercy Response Plan (Draft) of May, 1981.
1 i
c)
The NRC Staff position is that the location of PG&E's real-time monitors is satisfactory. The system is described in Section 7.3.2.4 of the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
d)
The NRC Staff position is that the alternate evacuation route to the north thru the Field Ranch is satisfactory. The route is described in Section 6.3.1.3 of the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
e)
The NP.C Staff position is that the provisions for communications and transpertation are satisfactory. These provisions are discussed in the draft Omergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 7.2 Appendix E and the " Earthquake Emergency Planning at Diablo Canyon" dated September 2,1981 by the TERA Corporation, f)
See answer to Interrogatory 3(e).
Interrogatory 4 What is the Staff position regarding whether the offsite emergency response plans and preparedness (both local and State) must satisfy 10 C.F.R. 650.47 prior to full power operation? Describe all documents that relate in any way to this position.
Response
The NRC Staff position is that the onsite and offsite emergency response plans must satisfy 10 C.F.R. 550.47 prior to full power operation. The
pertinent regulatory document is the final tule on Emergency Planning (Fed.
Reg. 55402, August 19,1980) NUREG-0654, Revision 1 is a document related to this issue.
Interrogatory 5 What is the Staff position with regard to wt. ether PG&E should consider the complicating effects on emergency preparedness and response of an earth-quaka greater than the SSE? Describe all documents that relate in any way to this position.
Response
The NRC Staff position is that in considering the complicating factors that might be caused by earthquake, the Applicant should assume that the plant site experiences earthquake effects reasonably likely to occur but in any event no more severe than the Safe Shutdown Earthquake.
I_nserrogatory 6 What is the Staff position on the adequacy of the criteria guiding PG&E employees regarding when to recommend evacuation (onsite and/or offsite) versus when to recommend sheltering? Describe al; reports, analyses, assess-ments or other documents that relate in any way to these criteria or to the Staff's position.
Response
The Nri Staff position is that the PG&E criteria are satisfactory. The criteria are described in PG&E's Emergency Procedure EP GA-1 and conform to NUREG-0654, Appendix 1.
The EPA Protective Action Guide Manual is a document which relates to the criteria.
Interrogatory 7 What is the Staff position on the adequacy of the public information program proposed by PG&E to support full power operation of the Diablo Canyon facility? Describe all ducuments which in any way relate to this public information p;ogram and/or the Staff position thereon.
Response
The NRC St3ff position is that the public information program is satis-factory, the Staff will review, with FEMA, a draft of the public information l
material and tilat distribution of the material will be made prior to issuance of a full power license. The program is described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 8.1.2.3.
Interrogatory 8 (a) What is the Staff position on the adequacy of the drills or exer-l l
cises (including the August 19, 1981 exercise) which have been conducted to i
test all or any part of PG&E's onsite and/or offsite energency preparadness and response capabilities?
l
(b)
Identify and describe any and all documents or critiques related to these drills or exercises.
Response
a)
The NRC Staff position is that the August 19, 1981 exercise satis-factorily demonstrated PG&E's state of onsite and offsite emergency prepared-ness to cope with a radiological incident.
b)
The FEMA critique is entitled " Evaluation Findings Diablo Canyon Nuclear Power Pla.nt Offsite Er argency Response Plans Exercise" (August 19, 1981) and was transmitted from Robert Jaske, FEMA to Brian Grimes, NRC by letter dated September 10, 1981.
The draft NRC Inspection Report:
50-275 81-21/50-323 81-15 1s in the process of being finalized. The final NRC inspection report will be withheld from public disclosure for a certain amount of time while the utility decides if the document should be regarded as proprietary information.
If the report is not considered proprietary, it will be available in the public doucment room.
Interrogatory 9 (a) What is the Staff position on the adequacy of the training pro-vided to onsite and offsite emergency response personnel?
(b)
Identify and describe any and all critiques or other documents related to this training.
~.,
Response
a)
The NRC Staff position is that the trcining provided to onsite emergency response psrsonnel is adequate. The August 19, 1981 exercise demonstrated this adequacy. After the NRC receives the FEMA finding, the Staff will determine the adequacy of the training provided to offsite emergency response personnel.
b)
The draft Emergency Plan for tha Diablo Canyon Power Plant, Revision 3 is a document related to this iraining.
Interrogatory 10 (a) What is the Staff position on the adequacy of equipment svailable to San Luis Obispo County personnel (including monitoring, communications, and notificatica equipment)?
(b)
Identify and describe all analyses, reports, assessments or other documents which relate to such County equipment.
Response
a)
After the NRC receivec the FEMA finding, the Staff will determine the adequacy of equipment available to San Luis Obispo County personnel, b)
The Applicant's resources are described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
Interrogatory 11 (a) What is the Staff position on the adequacy of medical facilities, personnel and equipment (both onsite and offsite) to deal with exposures t
i
. 4 and/or injuries related to a radiological emergency at Diablo Canyon?
(b)
Identify and describe all reports, analyses, assessments, or other documents which relate to such medical facilities, personnel or equipment.
Response
a)
The NRC Staff position is that both onsite and offsite medical provisions are adequate subject to complet'on of the Staff review after receiving the FEMA fit: ding.
b)
The medical provisions are described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 7.5 and Appendix H.
Interrogatory 12 (a) What is the Staff position on the adequacy of plans for notifi-cation cf transient persons within 10 miles of the Diablo Canyon facility in the event of a radiological emergency? Please address each of the following transients:
(1) agricultural workers; (2) visitors to Montana de Oro State j
Park; and (3) persons who may be temporarily visiting the San 1.uis Obispo area.
(b)
Identify and describe all analyses, reports, assessments or other l
documents which relate in any way to such notification.
l
Response
a)
After the NRC receives the FEMA finuing with respect to offsite emergency preparedness, the Staff will datermine the adequacy of plans for
notification of transient persons within 10 miles of the Diablo Canyon facility in the event of a radiological emergency.
b)
The San 1.uis Obispo County plan discusses such notification.
Section 8.1.2.3 of the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 discusses prior public education.
Interrogatory 13 (a) What is the Staff position on the adequacy of t% seismic quali-fication of:
(1) the real-time monitors and associated structures proposed for use 7.t Diablo Canyon, both onsite and offsite; (2) the sirens and associated structures proposed for use as part of the Diablo Canyon public notification system; (3) the onsite meteorological tower and associated structures; and (4) the equipment and associated structures at each of the offsite environmental monitoring locations.
(b)
Identify and describe all documents which relate in any way to tha seismic qualification of th: foregoing equipment, including any tests or analyses which have been performed by the Staff or anyone else.
Response
a)
The NRC Staff position is that such equipment need not be seis-mically qualified.
b)
The NRC Staff position is described in a letter from Dircks to Mark (ACRS) dated May 18, 1981.
Interrogatory 14 (a) What is the Staff's position on the adequacy of both (1) ensite and (2) offsite preparedness to deal with the complicating effects of an carthquake on emergency preparedness ar.d response to a radiolvgical emergency at Diablo Ca' yon?
(b)
Identify each and every place in the PG&E, State and County emer-gency response plans reviewed by the Staff where the complicating effects of an earthquake on emergency preparedness and/or response are considered or addressed.
(c)
Identify and describe all analyses, reports, assessments or other documents which in any way relate to these matters.
Response
a)
The NRC Staff is satisfied that PG&E has adequately addressed the complicating effects that an earthquake may pose in the event the emergency plan had to be implemented in response to a radiological emergency, b)
The Staff notes that this interrogatory is objectionable in that it asks the Staff to compile data which is as readily available to Governor Brown as to the Staff.
Governor Brown can read the PG&E, State and County emergency response plans, the " Earthquake Emergency Planning at Diablo Canyon" by the TERA Corporation, and the references in Interrogatory 3(e) and find for themselves any portions relevant to the effects of an earthauake on emergeray preparedness.
See 4A Moore's Federal Practice, 1 33.20(3).
c)
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 and the " Earthquake Emergency Planning at Diablo Canyon" dated September 2,1981 by the TERA Corporation relate to these matters.
Interrogatory 15 (a) Has the Staff met or spoken with officials of the California State government concerning the complicating effects of an earthquake on emergency preparedness and/or response at Diablo Canyon?
(b)
If YES, please state the date(s) of all sLch meetings or conversa-tions, the name(s) of the persons (and their organizations) attending such meetings or participating in the conversations, and the specific subjects discussed.
(c) Describe all documents relating to these conversations or meetings.
Response
a)
The Staff has not met or spoken with officials of the California State government concerning the complicating effects of an earthquake on emergency preparedness. Brian Grimes, NRC, had a conversatt;n with John Kearns, OES, in December 1981, in which he stated that earthquake effects on emergency preparedness would be considered at California nuclear power l
facilities, b)
Not applicable.
c)
Not applicable.
Interrogatory 16 Attached to Revision 2 of the Diablo Canyon Emergency Response Plan are i
several agreements.
For example, there are agreements with French Hospital l
and with San Luis Obispo Ambulance Service.
(a) What is the Staff position on the adequacy of these agreements?
.b)
Describe any reviews, investigaticns, or analyses (including field inve3*igations) performed by the Staff to determine the adequacy of these agreements.
Response
a)
The NRC Staff position is that those agreements are adequate subject to completion of the Staff review after receiving the FEMA finding.
b)
The agreements are documented in Appendix E and H of the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 and were reviewed by the Staff.
Interrogatory 17 (a) Does the Staff anticipate that prior to full power operation, the onsite and offsite emergency preparedness at Diablo Canyon will comply fully with all the Planning Standards of Section 50.47(b)?
(b)
If the answer is YES, describe the basis for this position, includ-ing a standard-by-standard analysis of how each is satisfied and a description of each document related thereto.
(c)
If the answer is N0, describe each deficiency and explain whether the Staff will support full power licensing of Diablo Canyon despite each such deficiency. Desc-ibe the basis for the Staff's position on each such deficiency and describe each document related thereto.
Response
a)
The Staff does. anticipate that prior to full power operation, the onsite and offsite emergency preparedness at Diablo Canyon will comply fully with all the Planning Standards of Section 50.47(b).
b)
The standard-by-standard analysis of the onsite plan is included in Appendix B to Supplement 14 to NUREG-0675, the Safety Evaluation Report of April, 1981.
As it pertains to offsite preparedness, it is based on the expectation that the planning standards will be satisfied, not on any standard-by-standard analysis which has been performed at this time, c)
Not applicable.
Interrogatory 18 (a) What is the Staff position on the adequacy of the San Luis Obispo County Emergency Plan (i.e., the draft version dated May 1981)?
(b)
Identify and describe any reports, analyses, assessments, or cther documents which relate in any way to that May 1981 plan.
Response
a)
The Staff has no position pending receipt of the FEMA findings except to the extent that the planning effort to date contributed to a favorable FEMA critique of the August 19, 1981 exercise.
b)
Not applicable.
Interrogatory 19 (a) What is the Staff's position on the. aoaquacy of PG&E's systems for communicating from the Diablo Canyon site to offsite governmental authorities, including specifically the governmental authorities of San Luis Obispo County, the City of San Luis Obispo, the State of California, the Nuclear Regulatory Commission, FEMA, and the Cities of Atascadero, Arroyo Grande, Grover City, Morro Bay, Paso Robles, and Pismo Beach?
(b)
Identify and describe all analyses or other documents which relate in any way to this position.
Response
a)
After the NRC receives the FEMA finding, the Staff will determine the adequacy of PG&E's communication systems, b)
The systems are described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 7.2.
In addition, see answer to Interrogatory 8(b).
Interrogatory 20 What is the Staff position on the adequacy of offsite communications equipment. Describe all documents which in any way relate to sucii communi-cations equipment and/or the Staff position.
l I
Response
After the NRC receives the FEMA finding, the Staff will determine the adequacy of the offsite communications equipment. The equipment is described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 7.2.
The Safety Evaluation Report,.NUREG-0575, Supplement No.14, of April 1981 relates to the communications equipment.
l
Interrogatory 21 Does the Staff contend that the PG&E and offsite communications equip-ment will remain fully functional in the event of the OBE? The SSE? An earthquake greater than the SSE?
(a)
If the answer (s) is(are) YES, please give the basis for the Staff position, including a description of all documents relating thereto.
(b)
If the answer (s) is(are) H0, please give the basis for the Staff position, including (1) a description of all documents relating thereto and (2) a description of any compensating measures proposed by the Staff in the event communications systems do not remain fully functional.
Response
a & b) The UHF and VHF radio systems described in the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 at Section 7.2.1.10 would be expected to be operational for the OBE and SSE.
However, the Staff has r0 basis to assume whether or not all offsite communication's equipment will remain fully functional.
See also the answer to Interrogatory 3(e).
Earthquakes greater than the SSE are not reasonably anticipated natural phenomena expected to occur during the operating life of the facility.
Interrogatory 22 Describe all analyses, critiques, memoranda or other documents which relate in any way to the August 13 em.argency exercise, including:
(a) Any documents concerning selection of the scenario used on August 19;
(b) Any documents analyring the PG&E onsite response; and (c) Any documents which analyze the offsite response.
Response
c)
The exercise scenario was prepared by a PG&E contractor.
b & c) See answer to Interrogatory 8(b).
Interrogatory 23 (a) List each and every person the Staff may call or subpoena as a witness to any hearing which may be held on the emergency preparedness con-tention admitted by the Licensing Board in its Order of August 4,1981.
(b) As to each such witness, please state:
(1) The name, occupation, address and telephone number of each such person and whether that person may appear for the Staff as a voluntary witness or a subpoenaed witness.
(2) The field or science in which such person is schooled and/or experienc(d to enable him or her to express opinion evidence in this matter, if any.
(3) Whether such witness will base his or her opinion in whole or in part upon facts acquired personnaly by that person in the course of I
an investigation or examination as to the facts, or upon information provided that person by others.
(4) The qualifications of each such witness.
(5)
If any such witness had made a personal investigation or examination relating to any of the facts or bases set forth in the L
answers to any interrogatories in the Governor's instant document, state the dates and nature of each such investigation or examination.
(6) Each and every fact and each and every document, photograph or report or item, or other tang 1ble object supplied or made available to each such person.
(7) Whether each such person has rendered written reports regard-ing facts, bases, or opinions as respects your answers to these inter-rogatories.
so, state the date of each such report and the name and address of the custodian of each such report.
(8) A summary of each witness' proposed testimony.
(9)
Identify any other NRC proceedings in which each such witness has previously testified.
Provide copies of such testimony.
Response
(a) The Staff is replying to this interrogatory by providing the names of all witnesses it presently expects will testify at the Diablo Canyon fc11 power hearing.
Any additional witnesses which the Staff determines will j
testify will be identified, as soon as that determination is made.
The l
Staff may call John R. Sears and Dean Kunihiro as witnesses to any hearing which may be held on the emergency preparedness contention admitted by the Licensing Board in the Order of August 4, 1981.
(b)(1)
John R. Sears is a Senior Reactor Safety Engineer at the U.S.
l Nuclear Regulatory Commission, Washington, D.C. 20555.
His telephone number l
is(301)492-7000.
Dean Kunihiro is a Regional State Liaison Officer at the U.S. Nuclear Regulatory Commission, Region V,1990 N. California Boulevard, l
. Walnut Creek, California 94596. His telephone number is (415) 943-3700.
John R. Sears and Dean M. Kunihiro will appear as voluntary witnesses.
(o)(2)
See the professional qualifications which are in Attachments A and B.
(b)(3)
JoM R. Sears and Dean M. Kunihiro have based their opinion in whole and in part upon facts acquired personally by them in the course of an investigation or examination as to facts, or upon information provided by other persons.
(b)(4)
The qualifications of each witness are in Attachments A and B.
(b)(5)
The witnesses have made a personal investigation or examina-tion relating to the facts or bases set forth in the answers to the inter-rogatories in the Governor's instant document.
John Sears and Dean Kunihiro i
have made onsite and offsite visits, reviewed documents and were observers during the exercise on August 19, 1981.
(b)(6)
The Staff objects to this interrogatory section. Under2.740(b),
discovery must be relevant to the subject matter involved in the procteding, i
The request in this interrogatory is so broad and undefined as to not appear reasonably relevant to the subject matter involved in t'le proceeding. The l
request asks for all documents made available to the witness.
It does not limit itself to documents related to the NRC, Diablo Canyon or even limit it to documents involving nuclear power plants.
The Staff, therefore, will not i
answer this interrogatory section.
(b)(7)
This request is not clear.
It appears to refer to written reports involving the preparation of answers to these interrogatories. To
.~
~
the extent the request asks for these materials, it asks for trial prepara-tory materials without making the requisite showing under 10 C.F.R. 92.740(b)(2).
The Staff, therefore, objects to this section of the interrog-atory.
(b)(8)
The Staff objects to the request for a summary of each witness' proposed testimony.
Any summary of the witnesses' testimony would be privileged as trial preparatory material.
See Kanses Gas and Electric CO.
(Wolf Creek Nuclear Generating Station, Unit 1), ALAB-327, 3 NRC 408 (1976).
Further, since at present no such summaries exist, requiring the Staff to compile data and create such a summary is objectionable.
See 4A Moore's Federal Practice, 1 33.20 (3). The Staff further cotes that Governor Brown will have a complete copy of all Staff testimony pritr to any hearing.
(b)(9)
John R. Sears has testified in other NiC proceedings:
(a) on emergency planning and security in Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, ISits 1 and 2), Docket Nos.
50-275,59-323; (b) on emergency planning and security in Southern California Edison Company (San Onofre, Units 2 and S), Docket Nos. 50-360, 50-361 j
OL; (c) on emergency planning in a proceeding culminating in pommonwealth Edison Company (Zion Station, Units 1 and 2), LBP-80-7,11 NRC 245 i
(1980);
(d) on emergency planning in Boston Edison Company (Pilgrim Nuclear Generating Station, Unit 2). Docket No. 50-741; (e) on er;ergency planning in Long Island Lighting Company (Jamesport Nuclear Power Station, Units 1 and 2), Docket Nos. 50-516, 50-517; and I
(f) on implementation of plant operatiens in Yan3ee Atomic Electric Company (Yankee Nuclear Power Station), Docket No.50-029.
(b)(9)
Dean M. Kunihiro has testified in the following NRC proceedings:
(a) on security natters in Commonwealth Edison Company (Zion Station, Units 1 and 2), Docket No. 50-295, 50-304.
Copies of John R. Sears' and Dean M. Kunihiro's testimony are available in the NRC Public Document Room.
Interrogatory 24 Identify and describe all reports, studies, analyses, assessments or other documents being prepared by or for the Staff that deal with any or all 1
of the following:
(1) The complicating effects of an earthquake on emergency prepared-ness for response to a radiological emergency; (2)
Evacuation time estimates for the evacuation of the Diablo Canyon facility and the emergency planning zones surrounding the facility; I
(3) The Diablo Canyon public information program; (4) The consequences of a radiological emergency at Diablo Canyon on the capability of offsite entities to provide assistance to PG&E; and (5) Tne adequacy of onsite and offsite communications systems.
For each item described, specify who is preparing the item, when it is scheduled to be completed, and what the purpose (s) of the item is(are) intended to be.
Response
(1) The December, 1980 Tedesco letter to PG&E instructing the Licensee to consider the potential effect!, of earthquakes.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
(2)(a) The September,1980 " Evacuation Times Assessment for the Diablo Canyon Nuclear Power Plant" by Alan H. Voorhees and Associates.
(2)(b) The May 14, 1981 draft document entitled " Technical Status of Earthquake Effects on Evacuation" by TERA.
(3) The draft Emergency Plan for the Diablo Canyan Power Plant, Revi-sion 3.
(4) The draft Emergency Plan for the Diablo Canycn Power Plant, Revision 3.
(5) The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
Interrogatory 25 (a) What is the Staff's position on the adequacy of the Diablo Canyon TSC, OSC, and the interim E0F to meet the reliability requirements of NUREG-0696.
l See NUREG-0696, p.5.
t (b)
Identify and describe all analyses or other documents which relate in any way to the emergency response facilities' compliance or noncompliance with these requirements.
1 I
(c) What is the Staff's position on whether the EOF and UDAC and related equipment wi?1 remain fuity functional in the event of the OBE, the SSE, and an earthquake greater than the SSE? Describe all documents related to this position.
l
Response
a)
The TSC, OSC, and interim EOF meet the intent of the guidance of tiUREG-0696, although it should be noted that the full implementation of all matters in t10 REG-0696 are not required prior to October 1,1982.
b)
See answer to Interrogatory 8(b).
In addition, the draft Emergency Plan for tne Diablo Canyon Power Plant, Revision 3 relates to the emergency response facilities.
c)
It is the f4RC Staff position that these facilities may not remain fully functional during earthquakes.
In such a case, the assessment and communication functions would be performed at the TSC or the control room.
It should be noted t,1at, earthquakes greater than the SSE are not renonably anticipated natural phenomana expected to occur during the operating life of the facility.
Interrogatory 25 (a) What is the Staff's position on whether the interim Ev.- meets the requirement that it be "well engineered for the design life of plant?"
lil> REG-0696, p.18.
(b)
Identify and describe all analyses or other documents which relate in any way to the EOF's compliance or no:. compliance with this requirement.
Response
a)
The f4RC Staff position is that the interim EOF need not meet the criteria of "well, engineered for the design life of the plant."
b)
The fiRC criteria for interim Engineering Support Facilities are stated in fiUREG-0694.
Interrogatory 27 (a) What is the Staff's position on the adequ.1cy of the emergency operating procedures for the Diablo Canyon facility?
(b)
Identify and describe all analyses or other documents which relate in any way to this position.
Response
a)
The NRC Staff position is that the emergency operating procedures are adequate to respond to an emergency. As a technical matter it is noted that the emergency operating procedures are a different set of documeats than the implementing procedures.
Since the admitted contention.in this proceeding relates to emergency preparedness, it is assumed that Interrog-atory 27 intendeo to refer to emergency procedures.
b)
The Applicant's implementing procedures.
Interrogatory 28 (a) What specifically would the NRC Staff do if PG&E notified the NRC of a radiological emergency at Diablo Canyon?
(b)
In such case:
(1) who at the NRC would notify the State of California; and (2) would the Governor be called and, if so, by whom?
(c) What specifically would the Staff do if an earthquake occurred in conjunction with a radiological emergency at Diablo Canyon?
(d) Who at the NRC would be in charge if such an earthquake and radio-logical emergency occurred and what would be the lines of authority from the Commissioners to affected staff.
(Please include names of individuals, titles, and organization charts.)
(e) What would FEMA's role be in the case of an earthquake and radio-logical emergency?
(f) Please describe all Staff and Commis',lon-level documents which relate in any way to lines of authority both (1) within the NRC and (2) betweer. the NRC and FEMA during a radiological emergency at Diablo Canyon (in case of a radiological emergency both in conjunction with and separate from an earthquake), and all FEMA documents related to the same.
Response
a)
The detailed response to the interrogatory is contained in NUREG-0728, "The NRC Incident Response Plan."
b)(1) The primary notification of an accident would come directly from PG&E.
The NRC Region V office would notify the State of California.
b)(2) P e Governor would ha contacted by members of the State government staff.
For accidents for which the NRC headquarters response center is activated, the Director of the NRC Executive Team (usually the Chairman of the NRC) would consult with key offsite officials periodically and make recommendations with respect to the NRC evaluation of the licensee's recom-mendations for offsite protective measures.
c)
See answer to Interrogatory 28(a).
i
(
d)
See answer to Interrogatory 28(a),
e)
FEMA's role is described in the Memorandum of Understanding between FEMA and NRC for Incident Response dated October 22, 1980 and in the National Radiological Emergency Preparedness / Response Plan for Commercial Nuclear Power Plant Accidents (45 fed. Reg. 84910, December 23,1980).
f)
See answer to Interroghtory 28(a) and 28(e).
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Interrogatory 29 (a)
Identify and describe any and all reviews, studies, analyses, assessments, or other documents that the Staff has performed of a radio-logical emergency at Diablo Canyon that is caused by the threat designated in 10 C.F.R. 573.1 or malevolent actions that Part 73 is intended to protect against.
(b)
Did the Staff perform any integrated analyses or reviews of the PG&E Security Plan and Emergency Plan? If so, identify and describe the methodology and the documents.
Response
a)
The response to this interrogatory must be withheld from public disclosure because the matter is proprietary.
b)
The Staff did perform a review of the PG&E Security Plan and Emergency Plan, however, any further answer must be withheld from public disclosure because the matter is proprietary.
II. GOVERN 0R BROWN'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS (a)
Produce all documents described or identified in response to Inter-rogatories 1-29.
(b)
Produce a'l memoranda or other documents that relate in any way to the letter cr to the substance of the letter sent by R. Tedesco to PG&E, dated December 16, 1980, and the similar letter to FEMA, dated November 1980, both related to the effects of an earthquake on emergency resr7nse.
The NRC Staff is enclosing the documents responsive to Govenor Brown's Second Set of Document Requests which have not previously been made avail-able to the Governor. The Staff is not forwarding NUREG-0696 ertitled
" Functional Criteria for Emergency Response Facilities," NUREG-0728 entitled "The NRC Incident Response Plan," NUREG-0396 entitled " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," and the June,1980 EPA Protective Action Guide Manual.
These four documents are available for inspection and copying in the Public Document Room at 1717 H Street, Washington, D.C.
Attorney for objections:
M Bradley W A.nes [
Counsel f5r NRC Staff Dated at Bethesda, Maryland this 14th day of September,1981
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 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 Unit Nos. I and 2 CERTIFICATE OF SERY.CE I hereby certify that copies of "NRC RESPONSE TO GOVERNOR EDMUND G. BROWN, JR.'S FIRST SET OF INTERROGATORIES AND SECOND REQUEST FOR PRODUCTION OF DOCUMENT the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 14th day of September, 1981:
John F. Wolf, Esq., Chairman Richard E. Blankenburg Administrative Judge Co-publisher Atomic Safety and Licensing Board Wayne A. Soroyan, News Reporter U.S. Nuclear Regulatory Commission South County Publishing Company Washington, D.C.
20555
- P.O. Box 460 Arroyo Grande, California 93420 Glenn 0. Bright, Esq.
Administrative Judge Marjorie Nordlinger Atomic Safety and Licensing Board Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Washington, D.C.
20555
- Dr. Jerry Kline Mr. Gordon Silver Administrative Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Commissicn San Luis Obispo, California 93401 Washington, D.C.
20555
- Arthur C. Gehr, Esq.
Elizabeth Apfelberg Snell & Wilmer 1415 Cozadero 3100 Valley Center San Luis Obispo, California 93401 Phoenix, Arizona 95073 Philip A. Crane, Jr., Esq.
Paul C.' Valentine, Esq.
Pacific Gas and Electric Company 321 Lytton /.s ?nue P.O. Box 7442 Palo Alto, California 94302 San Francisco, California 94120 Bruce Norton, Esq.
Mr. Frederick Eissler 3216 North 3rd Street Scenic Shoreline Preservation Suite 202 Conference, Inc. t Phoenix, Arizona 85012 4623 More Mesa Drive Santa Barbara, Califorata 93105 Andrew Baldwin, Esq.
124 Spear Street Mrs. Raye Fleming San Francisco, California 94105 1920 Mattie Road Shell Beach, California 93449
John R. Phillips, Esq.
Atomic Safety and Licensing Appeal Panel Simon Klevansky, Esq.
Margaret Blodgett, Esq.
U.S. Nuclear Regulatory Commissian Marion P. Johnston, Esq.
Washington. 0.C.
20555
- Joel Reynolds, Esq.
Center for Law in the Public Atomic Safety and Licensing Board Interest Panel.
10203 Santa Monica Boulevard U.S. Nuclear Regulatory Commission Los Angeles, California 90067 Washington, D.C.
20555
- Byron S. Georgiou Docketing and Service Section Legal Affairs Secretary U.S. Nuclear Regu~.atory Commission Governor's Office Washington, D.C.
20555
- State Capitol Sacramento, California 95814 Mark Gottlieb California Energy Coninission David S. Fleischaker, Esq.
MS-18 P.O. Box 1178 1111 Howe Avenue Oklahoma City, Oklahoma 73101 Sacramento, California 95825 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 John Marrs, Managing Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 Herbert H. Brown Hill, Christopher & Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Harry M. Willis Seymour & Willis 601 California St., Suite 2100 San Francisco, California 94108 Janice E. Kerr, Esq.
Lawrence Q. Carcia, Esq.
350 McAllister Street San Fraarisco, California 94102 Mr. James 0. Schuyler
'BrN1 o
Nuclear Projects Engineer Cou or Staff Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 l
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m UNITED STATES OF AMERICA
!!0 CLEAR REGULATORY COMMISSION BEFORE THE-ATCMIC SAFETY AND LICEt4 SING SCARD In the Matter of PACIFIC GAS Ar4D ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
(DiabloCanyonfluclearPowerPlant1 50-323 0.L.
Unit Hos. I and 2)
)
AFFIDAVIT OF GARTH 0LOMEW C. BUCKLEY I, Bartholomew C. B;ckley, being duly sworn, state as follows:
1.
I an employed by the U.S. Nuclear Regulatory Commission as Project Manager in the Division of Licensing, Office of Huclear Reactor Regulation.
2.
I am a Project Manager assigned to the Diablo Canyon Power Plant.
3.
I am duly authorized to review the answers to Interrogatory tios. I through 29 and I hereby certify that the answers given are true and correct to the bett of my knowledge.
(Y&sMLAA)
Bartholomew C. Buckley Subscribed a d sworn to before me this / 4 day of September, 1981
% alu A Dla u nothry Put/lic /
My Commission Expires
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the flatter of
)
PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
)
50-323 0.L.
(ijiablo Canyon Nuclear Power Plant )
Unit Nos. 1 and 2)
)
AFFIDAVIT OF JOHN R. SEARS I, John R. Sears, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Senior Reactor Safety Engineer, Emergency Preparedness, Office of Inspection and Enforcement.
2.
I am duly authorized to answer Interrogatory Nos. I through 29 and I hereby certify that the answers given are true and correct to the best of my knowledge.
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Subscribed and sworn to before me this /0 M day of September, 1981 Ma A i &
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Nota'ry Putilig f/
My Commission Expire j /, /7 h A f/
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UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 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 )
Unit hos. I and 2)
)
AFFIDAVIT OF DEAN M. KUNIHIRO I, Dean M. Kunihiro being duly sworn, depose and state as follows:
1.
I am employed by the U. 5. Nuclear Regulatory Commission as Regional State Liaison Officer, Office of Inspection and Enforcement.
2.
I am duly authorized to answer Interrogatories 1 through 29 and I hereby certify that the answer siven is true to the best of.my knowledge.
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_ :_ 6h!,.. IN-Dean M. Kunihiro
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-fff Subscribed and sworn to before me l
this 9&/ day of August,1981.
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Attach 6citt A UtilTED STATES OF A'iERICA NUCLEAR REGULM01Y C0+11SSION BEFORE THE AT0';11 SAFETY AND LICENSING BOARD In the Matter of
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PACIFIC GAS aid ELECTRIC C011PAiY Docket Nos. 50-275 0.L.
(DiaoloCanyonNuclearPowerPlant1 50-323 0.L.
Unit Nos. 1 and 2)
)-
JOHN R. SEARS PROFESSIONAL QUALIFICATIONS EtjERGENCY PREPARED liESS PR0 GRAM OFFICE Prior to 1952 I was employed in field jobs in various aspects of mechanical engineering.
In 1952 I joined Brookhaven National Laboratory as a Reactor Shift Supervisor on the Brookhaven Graphite Reactor. W5ile at Brookheven, I completed a series of courses given by the Nuclear Engineering Departnent in nuclear engineering. These courses were patterned on the ORSORT programs.
In 1956. I wss appointed Project Engineer on the Brookhaven Medical Research Reactor.
I was a nember of the design group, participated in critical design experiments, wrote Specifications, coauthored the hezae', report, was responsible for field I
inspection and contractor liaison, trained operators and loaded and started up the reactor. About three months after start-up, in 1959, following the successful completion of proof tests and demonstration of the reactor in its design operating mode for boron capture therapy of brain cancer. I accepted a position as reactor inspector with the Division of Inspection, U. S. Atomic Energy Commission.
In 1960, I transferred, as a reactor inspector, to the newly-formed Division of Compliance.
I was responsible for the inspection, for safety and l
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conpliance with license requirements, of the licensed reactors and the fuel fabrication aad fuel processing plants, whir,h use more than critical amounts of special nuclear naterial, in the Eastern United States.
In (eptember 1968. I transferred to the Operational Safety Branch, Directorate of Licensing. My responsibit'ty included developaent of appropriate guides for evaluation of operations 1 aspect of license applications and staff assistance in review of power reactor applicants Per sonnel submittals in the areas of Organization and Managenent.
Qualifications, Training Programs Procedures and Administrative Control.
Review and Audit, Start-up Testing Programs Industrial Security and Energency Planning.
The Branch was reorganized as the Industrial Security and Energency Planning Branch in April 1974 to place increased enphasis and attention upon areas of physical security and energency planning.
In 1976, I transferred to the Division of Operating Reactors as the sole reviewer responsible for review of emergency planning for all tne operating reactors in the United States.
New Ycrk City College,1950 - Mechanical Engineering Argonne International School of Reactor Technology,1961 - Reactor Control Course GE BWR Systen Design Course, 1972 Popo-U.S. Army, 1974 - Course in Industrial Defense and Disaster Pl Instructor at DCPA, 1976. 1977 - Course in Emergency Planning l
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3-Director, 1952 - Reactor Progran, Ato n for Peace Exhibit, Bcngkok, Thailand Dire,gtor,1956 - Atons for Peace Exhibit Utrecht, Holland
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Attachment B UNITED STATES OF AMERICA HUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the IJatter of
)
1 PACIFIC GAS AND ELECTRIC COMPANY h
Dociet Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant h>
Unit Hos. 1 and 2)
J DEAN'M. KUNIHIRO PROFESSIONAL QUALIFICATIONS _
I joined the Nuclear Regulatory Comission Staff in 1976 as.I Program Analyst in the Office of Nuclear Material Safety and i
Safeguards.
Following that assignment I was assigneo as a Reactor In that Safeguards Analyst in the Office of Nuclear Reactor Regulaticn.
uasition I was charged with the technical evaluation of the physical security plans submitted pursuant to 10 C.F.R. 73.55 for 13 nuclear power facilities.
In addition I was selected to serve on the Emergency Planning Task Force and was tasked with the technical. evaluation of emergency plans for c, aclear power facilities. Among these facilities l
was the Diablo Canyon Nuclear Power Plant.
I am presently assigned as the Regional State Liaison Officer, U.S.
NRC Region V.
As part of g duties I serve as a member of the Regional Assistance Comittees in Federal Regions IX and X.
These committees were established to assist in development and evaluation of the offsite emergency preparedness around nuclear power facilities.
Prior to joining the Nuclear Regulatory Commission, I served in the U.S. Arg in a variety of assignments to include combat infantry duty in Viet Nam, and radiobiology research with the Defense Nuclear Agency.
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I have a Bachelor of Science degree from the United States Military i
Acadeny and a Master of Science degree in Physics from the Naval
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