ML20010B298
| ML20010B298 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/12/1981 |
| From: | Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CALIFORNIA, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8108140334 | |
| Download: ML20010B298 (8) | |
Text
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fpv UtilTED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD co**'55 "
In the Matter of
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PACIFIC GAS AND ELECTRIC C0!1PANY Oocket Nos. 50-275 0.L.
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50-323 0.L.
(Diablo Canyon Huclear Power Plant )
Unit Nos. 1 and 2)
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STAFF INTERR0GATORIES TO GOVERNOR EDMUND G. BROUN, JR.
Pursuant to 10 C.F.R. 9 2.740(b), the NRC Staff serves the following interrogatories on Governor Edmund G. Brown, Jr.
INSTRUCTIONS AND DEFINITIONS
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1.
Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of the Governor.
2.
As used herein, " documents" includes, but is not limited to papers, photographs, criteria, standards af review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence. notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-agency or interagency menoranda or written comunications 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, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer 8108140334 810812 7
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data, 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 4
in any way (including handwritten notations or other 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:
a.
Answer the direct ques; ion asked or provide the information 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 the Governor as to the answer given in the interrogatory.
Include a statement of professional qualifications for any identified individual.
e.
Give the name and address of any individual, corporation, 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 Governor on the issue addressed in each interrogatory.
3_
INTERROGATURY 1 - Set forth with specificity each vsficiency which the Governor alleges is present in the Diablo Canyon Nuclear Power Plant onsite emergency plan.
INTERROGATORY 2 - Set forth with specificity each deficiency which i
the Governor alleges is present in the emergency plans of San Leis Obispo County, or any other local government's emergency plans, relative to a radiological emergence at Diablo Canyon :luclear Facility.
INTERROGATORY 3 - Sat forth with specificity each deficiency which the Governor believes is present in the State of California's Emergency Plans relative to a radiological emergency at Diablo Canyon Nuclear Facility.
INTERRUGATORY 4 - For ea:h deficiency identified in Interrogatories 1 through 3 above, iGantify the specific rule (s), regulation (s), or other statutory provision (s) which the Governor alleges are not met as a result of the identified deficiency.
INTERROGATORY 5 - Identify the NRC regulation (s) or other statutory provision (s) which the Governor believes require PG&E to conduct a site-specific analysis of acute and 16tv 2 'ealth effects as a function i
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.
INTERROGATORY 6 - State specifically cach and every way the Governor believes the California Emergency Response Plan, dated 1975 and revised in 1978, does not comply with 10 C.F.R. 9 50.4/.
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- c INTERROGATORY 7 - State specifically each and every way the Governor believes the San Luis Obispo County evacuation plans dated 1976 do not comply with 10 C.F.R. s 50.47.
INTERROGATORY 8 - State specificallv each and every way the Governor believe the San Luis Obispo County emergency plan, dated 1976, have not been adequately implemented.
INTERROGATORY 9 - State specifically each and every way the Governor believes 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 the Govarnor believes require further training and coordination of offsite personnel, who would be asked to respond to the effects of a Diablo Canyon radiological emergency.
INTERR0GATORY 11 - Give the name and title of ecch individual that the Governor believes has been inadequately trained to respond to the effects of a Diablo Canyon radiologlcal emergency.
INTERR0GATORY 12 - State specifically each piece of equipment which the Governor believes San Luis Obispo County lacks, which is necessary for the County to respond to a radiological emergenqy at Diablo Canyon.
INTERROGATURY 13 - For each piece of equipment identified in Interrogatory 13 above, state in what way the Governor believes that particular piece of equipment is necessary for response to a Diablo Canyon raUlogical emergency.
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INTERROGATORY 14 - State specifically what NRC regulati(n(s) or other statutory provision (s) the Governor believes require the equipment identified in Interrogatory 12 above.
INTERROGATORY 15 - State specifically what NRC regulation (s) or other statutory provision (s) the Governor believes requires the Diablo Canyon onsite, County, or state plans, to address the complications arising from attempting emergency ~ response during an earthquake situation.
INTERROGATORY 16 - State specifically each and every way the Governor believes there is inadequate preparedness to evacuate or take other protective actions on behalf of persons in Montana ds Oro State Park.
IliTERROGATORY 17 - State what NRC regulation (s) or other statutory provision (s) the Governor believes require additional measures to protect or evacuate persons in the Montana de Oro State Park.
INTERROGATORY 18 - State specifically each a,1d every way the Governor believes the proposed information program of PG&E does not provide detailed information necessary to protect W public health and safety.
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INTERROGATORY 19 - State specifically what NRC regulation (s) or other statutory provision (s) the Governor believes require PG&E to
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provide more detailed information than that already provided in PG&E's l
l proposed public information program.
INTERR0GATORY 20 - State specifically each and every way the Governor believes the emergency operating procedures at Diablo Canyon are not adequate for full power.
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'l1 TERR 0GATORY 21 - State what liRC regulation (s) or other. statutory provision (s) the Governor believes are not met due to the inadequacies identifie i in Interrogatory 20 above.
Documer.t Hequests 1.
Provide all documents identified in Governor Brown's 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 Governor Brown whie.h 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, n
Ab
'h Bradley W. Jones 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.
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(Diablo Canyon Nuclear Power Plant Unit Nos. 1 and 2 CERTIFICATE OF SERVICE I hereby certify that copies of STAFF.INTERR0GATORIES TO GOVERNOR EDMUND G.
BROWN, JR. in the above-captioned proceeding have becn 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 Licens*
Board i Wayne A. Soroyan, News Reporter U.S. Nuclear Regulatory Co..aossion 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 Commission San Luis Obispo, California 93401 Washington, D.C.
20555
- Arthur C. Gehr, Esq.
l Elizabeth Apfelberg Snell & Wilmer l
1415 Cozadero 3100 Valley Center San Luis Obispo, California 93401 Phoenix, Arizona 95073 l
Philip A. Crane, Jr., Esq.
Paul C.' Valentine, Esq.
i Pacific Gas 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 Ncrth 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
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John R. Phillips Esq'.
Atomic Safety and Licensing Appeal Simon Klevensky, 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 Panal.
10203 Santa Monica Boulevard U.S. Nuclear Regulatory Commission Los Angeles, California 90067 Washington, D.C.
20555
- Byron S. Gecrgiou Docketing and Service Section Legal Affairs Secretary U.S. Nuclear Regulatory Comission Governor:s Office Wa dington, 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 141B 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.
20G36 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
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# W Nuclear Projects Engineer Counfe or Staff Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94105
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