ML20010B266

Second Set of Interrogatories to Governor Brown Re Emergency Response Plan.W/Certificate of Svc.Related Correspondence

ML20010B266
Person / Time
Site:	Diablo Canyon
Issue date:	08/07/1981
From:	Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO.
To:	CALIFORNIA, STATE OF
References
ISSUANCES-OL, NUDOCS 8108140291
Download: ML20010B266 (11)

Text

, 3UHATED CORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COf1 MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the flatter of )

) Docket Nos. 50-275 0.L.

PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 0.L.

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(Diablo Canyon Nuclear Power ) Low Power P g Plant, Unit Nos. 1 and 2) )

APPLIC/.NTPACIFICGASANDELECTRICCOqkNY lj J q TO OVERNO ED!UN9 G. BRO N, R.

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Pursuant to 10 C.F.R. SS2.740-2.741, and t card Ordqg f August 4, 1981, Apr , cant PACIFIC GAS AND ELECTRIC CO 9' y\

(" Applicant") hereby propounds the following Interrogato To Governor Edmund G. Brown, Jr.

INSTRUCTIONS

1. All information is to be divulged which is in the possession of the individual or corporate party, their attorneys, investi-ga to rs , agents, employees or other representatives of the named party and their attorneys.

2. Where an individual Interrogatory calls for an answer which involves more than one part, each part of the answer should be clearly set out so that it !s understandable.

3. In the event the space provided is not sufficient for your answer to any of the questions, please attach a separate sheet of paper with the additional information.

4. These Interrogatories are intendeu as continuing Interrogatories, requiring you to answer by supplemental answer, setting forth any information within the scope of the' Interrogatories as may be acquired by you, your agents, attorneys or representatives following your original answers up to the time of hearing, e  %

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1. State in detail each and-every fact whichcyou believe evidences that the Applicant's emergency response plan will not co:: P l y with 10 C.F.R. S50.33(g).by October 1, 1981~.

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2. State in detail each and every fact which you.believe evidences that the State of California's emergency response plan will.not.

comply with 10 C.F.R. S50.33(g) by October 1, 1981.

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3. State in detail each and every-factz which'you believe evidences-that the County of San Luis Obispo's emergency response plan will not comply with 10 C.P.R. S50.33(g) by October 1, 1981.

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4. Sta'te in detail each and every fact which you believe evidences ..

that the Applicant's emergency response plan will not comply.with 10 C.F.R. S50.47 by' October 1, 1981.

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l l S. State in detail each and every fact which you believe. evidences that the State of California's emergency response plan will not ,

comply with-10 C.F.R. S50.47 by October 1,-1981.

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6. State in datall each and every fact which you believe evidences that the County of San Luis Obispo's emergency response plan will not comply with 10 C.F.R. S50.47 by October 1, 1981.

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7. State in detail each and every fact which you believe evidences that the Applicant's emorgency response plan will not comply with-i 1G C.P.R. Part.50, Appendix E, by October 1, 1981.

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8. State in detail each and every. fact which you believe evidences that the State of California's emergency response plan.will not comply with 10 C.F.R. Part 50, Appendix E, by. October 1, 1981.

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. 9. State in detail each and every fac't which you'believe evidences that the County of San Luis Obispo's emergency response plan will not comply with 10 C.F.R. Part 50, Appendix.E, by October 1,-

, 1981.

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10. Identify each and every person supplying either answers to these interrogatories or information upon which answers were based.

4 Also identify the specific interrogatories to which each such person contributed.

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11. As to the person (s) identified in the preceding answer to

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interrogatory, please state the (a) name, (b) occupation, (c) address, and (d) telephone number for each such person.

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12. Identify each and_ every document upon which you base any answer to the preceding interrogatories and for each such document:

(a) State the name, author, and date of the document. '

(b) Identify the interrogatory answer to which the dccument relates.

(c) Identify the specific page(s) of the document which relates to the answer.

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13. As to each and every person you may call or subpoena as a witness to any-hearing which may be had on the emergency preparedness contention as admitted by the Licensing Board in its order of August 4, 1981, please state:

(a) The name, occupation, address and telephone number of each such person and whether_ that person may appear for you as a voluntary witness or as a subpoenaed witness.

(b) The field or science in which each such person is sufficiently schooled to_ enable-him to express opinion iidence in this matter, if any.

(c) Whether such witness will base his opinion:

(i) in whole or in part upon faats acquired personally by that person in the course of an investigation or examination as to the facts; or .

(ii) solely upon information provided that person by others.

(d) The qualifi.ations of each such person that would render that persc., if possible, as an expert witness.

(e) If any such witness has made a personal investigation or examination relating to any of the facts or bases. set forth in the answers to preceding interrogatories, state the date(s) and nature of each such investigation or examination.

(f) Each and every fact, and each and every document, photograph, report, item, or other tangible object supplied or made available to each such person.

(g) Whether each such person has rendered written reports, regarding facts, bases, or opinions as respects you answers to the preceding interrogatories. If so, state:

(i) the date(s) of each s,uch report; and (ii) the name and address of the custodian of each such-report.

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Respectfully submitttd,.

MALCOLM H. FURBUSH PHILIP A. CRANE, JR.

Pacific Gas and Electric Company '

77 Beale Street San Francisco,-California 94106

.(415)781-4211 ARTHUR C. GEllR Snell & Wilmer 3100 Valley Center ,

Phoenix, Arizona 85073 (602)257-7288 BRUCE NORTON~ ,

Norton, Burke, Berry-& Junck, P.C.

3216 N. Third Street Suite 300-Phoenix, Arizona 85012 (602)264-0033 4

Attorneys for Pacific Gas and Electric Company I'

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uu( .c Dw Bruce Norton DATED: August 7, 1981. .

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@M CMPJU: iPONDENCE

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENS7.G BOARD In the Matter of )

) Docket Nos. 50-275 0.L.

PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 0.L.

)

(Diablo Canyon Nuclear Power ) (Low Power License)

Plant, Units No. 1 and 2) )

CERTIFICATE OF SERVIcu I hereby certify that copies of " APPLICANT PACIFIC GAS AND ELECTRIC OMPAN1'S SECOND S'.T OF INTERROGATORIES TO GOVERNOR EDMUND G.

BROWN AND APPLICANT PACIFIC CAS AND ELECTRIC COMPANY'S SECOND SET OF INTERROGATORIES TO JOINT INTERVENORS", dated August 7, 1981, have..been ser ed on the following by deposit in the United States mail, postage prepaid, this 7tr day of August, 1981:

The Hon. John F. Wolf, Chairman Gordon Silver Atomic Safety and Licensing Board 1760 Alisal Street Mail Drop East West 450 San Luis Obispo, CA 93401 U. S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Sandra A. Silver 1760 Alisal Street The Hon. Glenn O. Bright San Luis Obispo, CA 93401 Atomic Safety and Licensing Board Mail Drop East West 450 Harry W. Willis,-Esq.

U. S. Nuclear Regulatory Comm'n W. Andrew Baldwin, Esq.

Washington, D.C. 20555 601 California Street Suite 2100 The Hon. Jerry R. Kline San Francisco, CA 94108 l Atomic Safety and Licensing Board ,

Mail Drop East West 450 U. S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Mrs. Elizabeth Apfelberg John R. Phillips, Esq.

c/o Nancy Culver Center for Law in the 182 Luneta Drive Public Interest San Luis Obispo, CA 93401 10203 Santa Monica Blvd.

Los Angeles, CA 90067 David F. Fleischaker, Esq- Mrs. Raye Fleming 1735 Eye Street N.W. 1920 Mattie Road Washington, D.C. 20006 Shell Beach, CA 93449 Mr. Frede. rick Eissler D Scenic Snoreline Preservation qu Conference, Inc. -

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4623 More Mesa Drive / \

Santa Barbara, CA 93105 --

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William J. Olmstead, Esq. Carl Neiburger Lucy Swartz, Esq. P. O. Box 112 Edward G. Ketchen, Esq. San Luis Obispo, CA 93402 Office of-Executive Legal Director BETH 042 '

U. S. Nuclear Regulatory Comm'n Washington, D.C. 20555 J. Anthony Kline, Esq.

Byron S. Georgiou, Esq.

Legal Affairs Secretary Atomic. Safety and Licensing Board to the Governor Panel State of California U. S. Nucleat Regulatory Comm'n State-Capitol Building Washington, D.C. 20555 Sacramento, CA 95814 Herbert H. Brown, Esq.

Docketing and Service Section Lawrenc.e Coe Lanpher, Esq.

Office of the Secretary Ilill, C*aristopher & Phillipa U. S. Nuclear Regulatory Comm'n 1900 M Street, N.W.

Washington, D.C. 20555 . Washington, D.C. 20036 Janice E. Kerr, Esq.

Lawrence Q. Garcia, Esq.

350 McAllister Street San Francisco, CA 94102

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