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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20045D8561993-06-21021 June 1993 San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related Correspondence ML20045D8291993-06-18018 June 1993 Response to Third Set of Suppl Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6751993-06-0404 June 1993 Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence ML20045A6401993-05-26026 May 1993 PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence ML20044F7701993-05-21021 May 1993 Intervenor San Luis Obispo Mothers for Peace Second Set of Supplemental Interrogatories & Requests for Production of Documents to Pge Cable Failures at Diablo Canyon Nuclear Power Plant.* W/Certificate of Svc.Related Correspondence ML20056C1891993-03-10010 March 1993 Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence ML20128P2251993-02-16016 February 1993 Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories & Requests for Production of Documents to Pg&E.* PG&E Should Answer Interrogatories within 14 Days.W/Certificate of Svc.Related Correspondence ML20213E5791986-11-0606 November 1986 Response to Util Second Set of Interrogatories Re Reracking of Spent Fuel Pools.Equations of Motion Appear in Encl Computer Program.W/Proof of Svc ML20213E6091986-11-0606 November 1986 Response to NRC Second Set of Inerrogatories Re Proposed Reracking of Spent Fuel Pools.Not Possible to Either Identify or Supply All Ref Documentation Supporting Contentions.W/Proof of Svc.Related Correspondence ML20213E6201986-11-0606 November 1986 Response to NRC Second Set of Interrogatories.Contentions Re Proposed Reracking & Alternatives Based on Understanding of Existing Industry Practice & Currently Available Technology. W/Proof of Svc.Related Correspondence ML20213F5851986-11-0505 November 1986 Suppl to 861003 Response to Intervenors 860916 First Set of Interrogatories Re Metals Used in Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20213F5011986-11-0505 November 1986 Response to 861017 Second Set of Interrogatories Re Seismic Analysis of High Density Fuel Racks for PG&E for Diablo Canyon Nuclear Power Station & Request for Production of Documents.W/Certificate of Svc.Related Correspondence ML20211E2121986-10-20020 October 1986 Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence ML20215H6691986-10-20020 October 1986 Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence ML20211E1721986-10-20020 October 1986 Second Set of Interrogatories Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses on Spent Fuel Pool.Related Correspondence ML20211E1871986-10-20020 October 1986 Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence ML20210S8921986-10-0606 October 1986 Response to Util Interrogatories Re Preparation for Upcoming Safety Hearings on Reracking of Spent Fuel Pools.Safety Issues Should Be Considered Before Amend Accepted.W/ Certificate of Svc.Related Correspondence ML20210S9651986-10-0606 October 1986 Answers to Sierra Club 860915 First Set of Interrogatories Re Reracking of Spent Fuel Pools.W/Certificate of Svc. Related Correspondence ML20210T2611986-10-0606 October 1986 Response to NRC Interrogatories on Contention 1 Re Util Responsibility to Demonstrate Safety of High Density Reracking.Intervenors Not Responsible for Solving Waste Storage Problem.W/Certificate of Svc.Related Correspondence ML20210S9711986-10-0303 October 1986 Response to Util & NRC First Set of Interrogatories & Request for Production of Documents.Interrogatories Opposed for Reasons Indicated.Certificate of Svc Encl.Related Correspondence ML20210T0731986-10-0303 October 1986 Response to Interrogatories & Request for Production of Documents Re Alternatives to High Density Reracking of Spent Fuel Pool at Facilities.Certificate of Svc Encl.Related Correspondence ML20210T0221986-10-0303 October 1986 Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence ML20210S9241986-10-0303 October 1986 Response to San Luis Obispo Mothers for Peace First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20206U7481986-10-0303 October 1986 Response to 860916 Interrogatories & Request for Production of Documents Re Licensing Proceedings.Certificate of Svc Encl.Related Correspondence ML20210S9931986-10-0303 October 1986 Response to Consumers Organized for Defense of Environ Safety First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20210T0541986-10-0303 October 1986 Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20210B7341986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc ML20214P8291986-09-16016 September 1986 Requests Response to Listed Interrogatories Re Design & Const of Fuel Ponds.Certificate of Svc Encl.Related Correspondence ML20214Q3521986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210B6321986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds ML20214Q3781986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions I & II Concerning Reracking of Spent Fuel Pools.Notice of Change of B Norton Address & Certificate of Svc Encl.Related Correspondence ML20210B6701986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools ML20214Q2981986-09-16016 September 1986 First Round of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20214Q3621986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210E1781986-09-15015 September 1986 Interrogatories & Request for Production of Documents Re Theoretical Work Concerning Displacement of High Density Spent Fuel Racks Due to Hypothetical Seismic Excitation. W/Certificate of Svc.Related Correspondence ML20214R1401986-09-15015 September 1986 Interrogatories Requesting All Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools, Dry Cask Onsite Storage & Cost/Benefit Assessment on Reracking.Certificate of Svc Encl.Related Correspondence ML20214R2341986-09-15015 September 1986 Interrogatories Requesting Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools & Dry Cask Onsite Storage as Alternative to High Density Reracking.Certificate of Svc Encl.Related Correspondence ML20081D7851983-10-26026 October 1983 Request for Production of Documents by NRC at 831107 Hearing in Avila Beach,Ca.Certificate of Svc Encl ML20080S2831983-10-14014 October 1983 Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20080Q3741983-10-0707 October 1983 Second Supplemental Answers to First Set of Interrogatories. Certification of Counsel & Prof Qualifications Encl ML20080Q3851983-10-0707 October 1983 First Supplemental Answers to Second Set of Interrogatories. Certification of Counsel Encl ML20080Q3951983-10-0707 October 1983 First Supplemental Answers to Fourth Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl ML20085J5951983-10-0707 October 1983 Fifth Supplemental Response to First Set of Interrogatories. Portions of RB Hubbard & Fj Samaniego 821221 Direct Testimony & Certificate of Svc Encl ML20080Q4441983-10-0505 October 1983 Response of Idvp to Interrogatory 57 in Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20078E1861983-10-0303 October 1983 Fourth Supplemental Response to First Set of Interrogatories.Certificate of Svc Encl ML20078D5091983-09-29029 September 1983 Supplemental Response to Second Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl.Related Correspondence ML20080M8521983-09-28028 September 1983 First Supplemental Answers to Third Set of Interrogatories. Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20078E1331983-09-28028 September 1983 First Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20080L5721983-09-26026 September 1983 Response to Fourth Set of Interrogatories.Certification of Counsel & Certificate of Svc Encl ML20078B8021983-09-23023 September 1983 Idvp Answers to First Set of Interrogatories.Certificate of Svc Encl 1993-06-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference ML20059D2071993-08-24024 August 1993 Intervenor Exhibit I-MFP-193,consisting of Review of LER 1-90-015-00,re Docket 50-275,dtd 910118 ML20059D2241993-08-24024 August 1993 Intervenor Exhibit I-MFP-220,consisting of Protest of Util ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 IR 05000275/19910061993-08-24024 August 1993 Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 1999-09-20
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 8
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RELATED CORRESPONDENCB f9-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD; U610 fggy , 2 L OIlO k*itti.3 Cf e s the scgre:a EM d
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In the Matter of )
) Docket Nos. 50-275 0.L.
PACIFIC. GAS AND ELECTRIC COMPANY ) 50- L.
.eff(,9 (Diablo Canyon Nuclear Power l 3 '
Plant, Unit Nos. I and 2) ) P
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GOVERNOR EDMUND G. BROWN JR.
12 08I
- Cl FIRST REQUEST FOR PRODUCTION OF DOCUMEN u.a. gam 711 TO PACIFIC GAS AND ELECTRIC CCMPANY cu 4' Pursuant to 10 C.F.R. S 2.741 and the Licensing Bo August 4, 1981, Memorandum and Order, Governor Brown requests Pacific Gas and Electric Company to produce for inspection and 1/
copying the documents described below. PG&E is requested to produce these documents at the offices of the undersigned counsel, 1900 M Street, N.W., Washington, D.C. 20036, on or before September 8, 1981, unless another time or location is agreed upon among the parties.
As used herein, " documents" includes, but is not limited to, emergency plans and procedures, construction plans and specifica-tions, papers, photographs, criteria, standards of review, record-ings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-corporate 1
l Governor Brown intends to file additional discovery requests
-1/ in the near fut'ure covering other aspects of the issues to i
l be litigated.
8108130064 a1080'5 #Y
$DRADOCK05000 m 8 5g
memoranda or written communications of any nature, intraagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions; analyses, assessments, surveys, evaluations, projections, hypotheses, form-ulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer deta, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and.also all copies of any of the foregoing which differ in any way (including handwritten notations or other written or printed matter of any nature) from the original.
Request 1. All documents in the possession, custocy or control of PG&E (including the possession, custody, or control of any contractor, employee, consultant, or agent of PG&E) which l relate in any way to the NRC Staff request of December 16, 1980, 1
l l
that PG&E " evaluate the potential complicating factors which might be caused by earthquakes which either initiate or follow the initiation of accidents." A copy of the Staff's December 16 request is attached hereto. Without limi.tation of the scope of l this request, documents within the scope of Request 1 include:
l (a) The contractor report referenced by Staff witness Mr. John Sears at page 7 of his prepared testimony
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in the Diablo Canyon fuel load and low power test proceeding; (b) All analyses, memoranda, and work papers related to such contractor report; (c) PG&E's written agreement or contract with such contractor for preparation of such contractor's report, including any documents related to the performance schedule and scope of work to be performed by such contractor under the agreement or contract; (e) Any correspondence between PG&E and the NRC Staff related to earthquake analyses requested in the NRC Staff's December 16, 1980, 'le tter ; and (f) Any correspondence, memoranda, or other documents between PG&E and the Federal Emergency Management Agency covering potential effects of an earthquake in emergency plans or preparedness at Diablo Canyon and the surrounding Emergency Planning Zones.
Recuest 2. All documents in the possession, custody or control of PG&E (including the possession, custody or control of any contractor, employee, consultant, or agent of PG&E) which analyse or relate to any analysis or evaluation of the ability of onsite and/or offsite emergency preparedness (both persons and systems) at Diablo Canyon and in the Emergency Planning Zones to
- function in the event of an earthquake which is greater than the SSE. Without limitation of the scope of this request, all documents
which address emergency response actions to be taken in the event of an earthquake greater than the SSE are within the scope of this Request 2.
Request 3. Any revisions (in draft or final form) to the PG&E Emargency Response Plan or to PG&E Emergency Procedures which set forth, in whole or in part, actions to be taken to respond to the potential complicating effects of an earthquake.
Request 4. All documents in the possession, custody or control of PG&E (including the possession, custody or control of any contractor, employee, consultant, or agent of PG&E) which analyse or relate to the effect of an earthquake, including an earthquake greater than the SSE, on onsite and/or offsite preparedness to:
,(a) Communicate among or between PG&E and County, State, and/or federal government officials; (b) Alert persons anywhere within the plume exposure EPZ to evacuate or to take other protective actions;-
(c) Conduct evacuation of (1) the Diablo Canyon site and (2) the surrounding plume exposure EPZ; (d) Provide medical assistance to persons within the plume exposure EPZ; and/or (e) Conduct r;.diological monitoring within the plume ex-posure and injestion exposure EPZ's.
Request 5.. All documents in the possession, custody or control of PG&E (including the possession, custody or control of
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any contractor, employee, consultant, or agent of PG&E) which analyse or relate to whether (a) the onsite operations support center and/or (b) the offsite emergency operations facility (both the present interim facility and the proposed permanent facility) will be available to function without interruption in the event of an earthquake, including an earthquake exceeding the SSE.
Dequest 6. Revision 3 of the PG&E Emergency Plan or, if
, not yet available, any draft (s) thereof.
Request 7. The PG&E Emergency Procedures described at the Diablo Canyon fuel load and low power test hearing (e.g., Tr.
10,827) and any revisions -thereto.
Respectfully submitted, Byron S. Georgiou Legal Affairs Secretary Governor'e Office State Capicol
. Sccramento, California 95814
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/ %AtwJ/Brown WAwu/ <
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Herbert H.
Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C. 20036 i
Attorneys for Governor Brown of the '
State of California l
August 5, 1981
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/. 34 UMTED STATES y , y, 7 g NUCLEAR REGULATORY COMMISSION 1.' ].. - E vvASHINGTON. D. C. 2C555
) 4
...s DEC 161980 Docket Nos.: 50-275/323 -
Mr. Malcolm H. Furbush ,
Vice PPsident - General Counsel Pacific Gas & Electric Company -
P.O. Box 7442 San Francisco, Califernia 94106 -
Dear Mr. Furbush:
SUBJECT:
EFFECTS OF EARTHQUAKES ON DIABLO CANYON, UNITS 1 A 2 EMERGENCY PLANS' ,
We are requesting that you evaluate the potential complicating factors which might be caused by earthquakes which either initiate or follow the initiation ,
of accidents. Two general cases' chould be considered. First, a severe '
earthquake at the site which could disrupt normal power and auxiliary services and thereby cause the. plant to be in a degraded mode should be concidered.
An Alert or higher energency class, depending on specific plant damage wocid ,
be declared in, such a case in accordance with .Sopendix l of NUREG-0654, Re'v.1.
g, The facility emargency plans should be capable of functioning under such conditions. Of principal importance under such conditions would be augmentation of the facility staff and wpporting resources to assure that a more severe accident did not develop. Factors to be considered for your. facility pl:ns should include the impacts due to potential disruption of comunicatiens networks and transportation routes. Your concern should be the availability of resource's and personnel to augment onsite staff, transit to and among-emergency re:ponse facilities and communications with offsite organi:ations. Arrangements.should be made such that equipment to be used in such circumstances (such as helicopters,
! offroad vehicles, etc.) will be dedicated for use by the plant even under '
l prt.ssing and competing needs such as offsite rescue missions. These aspects must be satisfactorily addressed prior to full power operation.
The second case which should be considered is an earthquake offsite which _
disrupts co munications networks and transportation routes in particular locales. In California, such occurrences appear to be frequent enough~to warrant consideration in your emergency plans. The procedures ,to be utsd to determine the protective actions recommended to offsite authorities should be revised to incorporate. consideration of earthquake effects offsite.
Evacuation time estimates sh6uid incorporate consideration of local s. '
! transportation route disruption. ,
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, .+
,.. > 3 DEC - l 6 1980 7
1 .
We are requesting FEMA to review the adequacy of State and local capabilitics with respect to response duririg earthquakes. A copy of our memo to FEMA is enclosed.
Sincerely, hb Robert L. Tedesco, Assistant Director-for Licensing Division of Licensing
Enclosure:
Memo to FEMA dtd.
11/03/80 cc: See next page.
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- g NUCi. EAR REGULATORY COMMISSION
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MEMORANDUM FOR: John McConnell, Assistant Associate Director for Population Preparedness, FEMA FROM: Brian X. Grimes, Program Direct 6r, Emergency Preparedness Program Office, NRR
SUBJECT:
REQUEST FOR FFA ASSISTANCE TO REVIEW EFFECTS OF EARTHQUAKE AND VOLCANIC ERUPTION ON STATE / LOCAL EMERGENCY PLANS As we have discussed, in the course of our review of licensed utility emergency plans, volcanic eruptions and catastrophic earthquakes have emerged as two issues of high public interest. To insure that these issues are being adequately addressed, we request that FEMA review the State and local planning efforts for the areas around California nuclear power plant sites and the Trojan site with respect to the complications which might arise in the event of extreme n tural c phenomena and how these can best be addressed in the planning process.
In conjunctich'with the Trojan plant evaluation for compliance with the new'NRC emergsncy planning regulations, the Comission has directed that s the problems of effective protective, measures and evacuation.during or soon after volcanic eruption (giving due consideration to the possible effects 'of severe ashfall, mudflows, floods, and landslides) be closely examined. In this regard, we are requesting the licensed utility to revise its emergency plan to explicitly address the possible problems associated with an eruption. This will include considerations of site access during an emergency, assured comunications and appropriate revision of the evacuation time estimates used in protective action deteminations. The Oregon State Department of Energy, has already addressed the feasibilit,"
of implementing effective protective measures during an eruption (enclosure 1).
The earthqutke issue has particular relevance to nuclear plants in California (i.e., Diablo Canyon, Humboldt Bay, Rancho Seco and San Onofre).
We un.derstand from the FEMA news release of September 29, 1980 that FEMA will lead a team consisting of personnel from Federal, State and local j-agencies to accelerate efforts towards improving the state of readiness to cope with potential major earthquakes in California. 'In this regard we request that FEMA include in its evaluation of offsite eme'rgency plans, a qualitative evaluation of complicating factors which might be caused by earthquakes for California nuclear power reactor sites. Specifically, .
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John McConnell .
~l c s such evaluation should include the impacts.on State / local emergency plans due to potential disruption of communications networks and evacuation routes.
In this regard, we are requesting the affected licensees to revise their emergency plans to explicitly address the possible problems associated with an earthquake to ir-lude the type of potential complications discussed above for the Trojan facility.
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Thank you for your assistance in these matters.
An
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W Brian K. Grimes, Program Director Emergency Preparedness Program Office Office of Nuclear Reactor Regulation
Enclosure:
Oregon DOE Study Report Measures N .
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EUCLEAR 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. 1 and 2) )
)
CERTIFICATE OF SERVICE.
I hereby certify that copies of " GOVERNOR EDMUND G. BROWN JR. FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY" have been served to the following on August 5I, 1981 by U.S. mail, first class, except as otherwise no ted .
Richard S. Salzman, Esq., Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission .
Washington, D.C. 20555 Dr. W. Reed Johnson Atomic Safaty and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman l Atomic Safety and Licensing Board Panel l U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 Chairman Atomic Safety and Licensing Appeal Panel ,
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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_ Mr. Glenr. v.. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -
Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 William J. Olmstead, Esq.
Edward G. Ketchen, Esq.
Lucinda Low Swartz, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Docketing and Service Section Mrs.-Elizabeth Apfelberg c/o Nancy Culver 192 Luneta Drive San Luis Obispo, California 93401 Janice E. Kerr, Esq.
Public Utilities Commission ,
5246 State Building 350 McAllister Street San Francisco, California 94102 Mrs. Raye Fleming ,
1920 Mattie Road Shell Beach, California 93449
) Mr. Frederick Eissler l Scenic Shoreline Preservation Conference, Inc.
- 4623 More Mesa Drive Santa Barbara, California 93105 l
! Mr. Gordon Silver Mrs. Sandra A. Silver i 1760 Alisal Street l San Luis Obispo, California 93401 f John Phillips, Esq.
Center for Law in the Public Interest 10203 Santa Monica Drive Los Angeles, California 90067
- Bruce Norton, Esq. (*)
Norton, Burke, Berry & Junck 3216 North Third Street, Suite 300 i
Phoenix, Arizona 85012
Philip A. Crane, Jr., Esq.
Richard F. Locko, Esq.
Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94106 -
David S. Fleischaker, Esq.
1735 Eye Street, N.W., Suite 709 Washington, D.C. 20006 Arthur C. Gehr, Esq. ~
Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 ,
Mr. Carl Neiberger Telegram Tribune P.O. Box 112 San Luis Obispo, California 93402 Byron S. Georgiou, Esq.
Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814 .
s Y f l /Y
. s ActvJ- $ N Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C. 20036 August i$ 1981
(*) By Federal Express on August _-6 1981
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