ML20010B147
| ML20010B147 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/12/1981 |
| From: | Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8108140133 | |
| Download: ML20010B147 (8) | |
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9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD U
s In the Matter of N
PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon liuclear Power Plant Unit Nos. I and 2)
)
STAFF INTERROGATORIES TO JOINT INTERVENOPS Pursuant to 10 C.F.R. 9 2.740(b), the NRC Staff serves the following interrogatories on Joint Intervenors.
INSTRUCTIONS AND DEFINITIONS 1.
Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Joint Intervenors.
2.
As used herein, "dccuments" includes, but is not limited to papers, photograpns, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of l
phone calls, interoffice, intra-agency or interagency 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, t
1 opinions, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notpbooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, l
appointment books, punchcards and computer printout sheets, computer 8108140133 8100127 PDR ADOCK 05000 pp 6r; bo7 4
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date-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 ciner written or printed natter of any nature) from the original.
3.
As used herein, " Emergency Plan (s)" unless otherwise stated includes, but is.not limited to, any State; County; local municipalities'; local municipal' departments; or PG&E plan which would apply to the Diablo Canyon Nuclear Facility site and the surrounding area in the event of a radiological emergency at the Diablo Canyon site.
4.
Each Interrogatory should be answered in five parts as follows:
Answer the direct question asked or provide the information a.
requested.
b.
State completely any documents used as the basis for the answer to the interrogatory.
c.
State completely any documents consulted, but not used as a basis for preparation of your response to the interrogatory.
d.
Give the name and professional qualifications of any individual who will testify on behalf of Joint Intervenors as to the answer given in tie interrogatory.
Include a statement of professional qualifications for any identified individual.
Give the name and address of any individual, corporation, e.
business, professional association, state or local official, or other organization which served, serves, or it is planned will serve as advisor, witness or consultant to the Joint Intervenors on the issue addressed in each interrogatory.
l l
I 1
I
INTERROGATORY 1 - Set forth with specificity each deficiency which Joint Intervenors allege is present in the Diablo Canyon Nuclear Power Pl',t onsite emergency plan.
INTERROGATORY 2 - Set forth with specificity each deficiency which Joint Intervenors allege is present in the emergency plans of San Luis Obispo County, or any other local government's emergercy plans, relative to a radiological emergency at Diablo Canyon Nuclear Facility.
INTERROGATORY 3 - Set forth with specificity each deficiency which Joint Intervenors believe is present in the State of California's Emergency Plans relative to a radiological emergency at Diablo Canyon Nuclear Facility.
INTERROGATORY 4 - For each deficiency identified in Interrogatories 1 through 3 above, identify the specific rule (s), regulation (s), or other statutory provision (s) which Joint Intervenors allege are not met as a result of the identified deficiency.
INTERROGATORY 5 - Identify the NRC regulation (s) or other statutory orovision(s) which Joint Intervenors believe require WG&E to conduct a site-specific analysis of acute and latent health effects as a function of meteorology, demography, topography, access routes, jurisdictional boundaries, release characteristics and time of year of release to determine the adequacy of the proposed size of the EPZ's.
INTERR0GATORY 6 - State specifically each and every way Joint Intervenors believe the California Emergency Response Plan, dated 1975 and revised in 1978, does not comply with 10 C.F.R. 9 50.47.
l I
INTERROGATORY 7 - State specifically each and every way Joint Intervenors believe the San Luis Obispo County evacuation plans dated 1976 do not comply with 10 C.F.R. 5 50.47.
INTERROGATORY 8 - State specifically each and every way the Joint Intervenors believe the San Luis Obispo County eraergency plan, dated 1976, have not been adequately implemented.
INTERROGATORY 9 - State specifically each and every way Joint Intervenors believe the training and coordination of offsite personnel, who would be asked to respond to the effects of a Diablo Canyon radiological emergency, is inadequate.
INTERROGATORY 10 - Give the NRC regulation (s) or other statutory provision (s) which Joint Intervenors believe require further training and coordination of offsite personnel, who would be asked to respond to the effects of a Diablo Canyon radiological emergency.
INTERROGATORY 11 - Give the name and title of each individual that Joint Intervenors believe has been inadequately trained to respond to the effects of a Diablo Canyon radiological emergency.
INTERROGATORY 12 - State specifically each piece of equipment which Joint Intervenors believe San Luis Obispo County lacks, which is necessary for the County to respond to a radiological eraergency at Diablo.
Canyon.
INTERROGATORY 13 - For each piece of equipment identified in Interrogatory 12 above, state in what way Joint Intervenors believe that particular piece of equipment is necessary for response to a Diablo Canyon radiological emergency.
INTERROGATORY 14 - State specifically what NRC regulation (s) or other statutory provision (s) Joint Intervenors believe require the equipment identified in Interrogatory 12 above.
INTERROGATORY 15 - State specifically what NRC regulation (s) or other statutory provision (s) Joint Intervenors believe requires the Diablo Canyon onsite, County, or state plans, to address the complications arising from attempting emergency response during an earthquake situation.
IitTERR0GATORY 16 - State specifically each and every way Joint Intervenors believe there is inadequate preparedness to evacuate or take other protective actions on behalf of persons in Montana de Oro State Park.
IHTERR0GATORY 17 - State what NRC regulation (s) or other statutory provision (s) Joint Intervenors believe require additional measures to protect or evacuate persons in the Montana de Oro State Park.
INTERROGATORY 18 - State specifically each and every way Joint Intervenors believe the proposed information program of PG&E does not provide detailed information necessary to protect the public health and safety.
INTERROGATeRY 19 - State specifically what NRC regulation (s) or other statutory provision (s) Joint Intervenors believe require PG&E to provide more detailed information than that already provided in PG&E's proposed public information program.
INTERR0GATORY 20 - State specifically each and every way Joint Intervenors believe the emergency operating procedures at Diablo Canyon are not adequate for full power.
9
-C-INTERROGATORY 21 - State what NRC regulation (s) or other statutory provision (s) Joint Intervenors believe are not met due to the inadequacies identified in Interrogatory 20 above.
Document Requests 1.
Provide all documents identified in Joint Intervenors' answers to interrogatories 1 through 21 above which are not already in the possession of the U.S. Nuclear Regulatory Comission.
2.
Provide all documents within the possession or control of Joint Intervenors which relate to emergency planning (State, local, or on-site plans) for the Diablo Canyon Nuclear Facility, which are not already in the possession of the U.S. Nuclear Regulatory Comission.
Respectfully submitted, W.
Bradley. Jon s Counsel for NRC Staff Dated at Bethesda, Maryland this 12th day of August, 1981.
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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 Canycr. Nuclear Power Plant Unit Nos. 1 and 2 CEGflFICATE OF SERVICE I hereby certify that copies of STAFE INTERR0GATORIES TC JOINT INTERVEN0RS in 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 12th day of August, 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 O. 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 Administritive Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Commission 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 C3s and Electric Company 321 Lytton Avenue P.O. Box 7442 Palo Alto, California 94302 San Francisco, California 94106 Bruce Norton, Esq.
Mr. Frederick Eissler 3216 North 3rd Street Scenic Shoreline Preservation Suite 202 Conference, Inc..
Phoenix, Arizona 85012 4623 More Mesa Drive Santa Barbara, California 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 Simon Klevansky, Esq.
Panel Margaret Blodgett, Esq.
U.S. Nuclear Regulatory Commission Marion P. Johnston, Esq.
Washington, D.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 *
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Byron S. Georgiou Docketing and Service Section Legal Affairs Secretary U.S. Nuclear Regulatory Commission Governor'.s Office Washington, D.C.
20555
- State Capitol Sacramento, California 95814 Mark Gottlieb California Energy Comission David S. Fleischaker, Esq.
MS-18 Suite 709 1111 Howe Avenue 1735 Eye Street, N.W.-
Sacramento, California 95825 Washington, D.C.
20006 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 9.. Box 112 San Ldis Obispo, California 93406 Herbert H. Brown l
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 Francisco, California 94102 Mr. James 0. Schuyler Bradi g W. Jon Nuclear Projects Engineer Counfel for C Staff Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106
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