ML20010E654
| ML20010E654 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/02/1981 |
| From: | Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8109080104 | |
| Download: ML20010E654 (39) | |
Text
09/02/81 i
Vill'20 STATES OF Af4 ERICA flVCLEAR REGULATORY C0tuilSSION BEFORE THE AT0l4IC SAFETY AliD LICEtiSING BOARD i
In the Matter of
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50-275 0.L.
PACIFIC GAS AtlD ELECTRIC C0i4PANY Docket flos.
50-323 0.l;QM:- f/'$
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ey (Diablo Canyon riuclear Power Plant, Unit Nos. I and 2)
/
g ilRC RESP 0llSE TO J0lflT INTERVENORS' l-SEp u,,, yRlfraugg d FIRST SET OF INTERR0GATORIES 1
TO THE HUCLEAR REGULATORY C0i414ISSI0rl STAFF C;
c NA I.
Interrogatories Vf; f
N ('l Contention 1 (as restated by the Board in August 4, 1981 14emorandum and Urder.
PG&E and the combined onsite, state and local emergency response plans and preparedness do not comply with 10 CFR 50.33(g); 50.47 and revised Appendix E to Part 50.
The interrogatories presented to the Staff by Joint Intervenors requested that each intert gatory be answered in 4 parts. The Staff has labeled the responses A 1 irough D, corresponding to Joint Intervenors' request.
The Staff objects to Part D(2) of the interrogatories. Any summary of the witnesses testimony would be privileged as trial preparatory material.
See Kansas 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 lioore's Federal Practice, 1 33.20 (3). Therefore, throughout this document Part (2) of Subpart D will not be answered, The Staff further notes that Joint Intervenors will have a complete copy of all Staff testimony prior to any hearing.
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Interrogatory 1 I
Explain the present Staff position on Joint Intervenors' contention 1, reggding emergency response planning.
Response
A.
The present Staff position is that the Applicant's emergency plan provides an adequate planning basis for an acceptable state of emergency preparedness.
State and local plans are under review by FEMA.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3. Safety Evaluation Geport related to the operation of Diablo Canyon Nuclear Power Station, Units 1 and 2. Supplement Nos.10,12 and 14.
C.
Tue Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered ir. the interrogatory other than the normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory.
Copies of their professional qualifications iire in attachments A and B respectively.
(2) See paragraph prior to Interrogatory 1.
(3) John R. Sears has testified:
(a) on emergency planning and security in Pacific Gas and Electric Company (Diablo Canyon Nucicar Power Plant, Units 1 and 2),
Docket Nos. 50-275,50-023; l
(b) on emergency planning and security in Southern
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California Edison Company (San Onofre, Units 2 and 3), Docket Nos.
50-361, 50-360 OL; (c) on emergency planning in a proceeding culminating in il Commonwealth Edison Company (Zion Station, Units 1 and 2), LBP-80-7, 11 URC 245 (1980);
(d) on emergency planning in Boston Edison Company (Pilgrim Nuclear Generating Station, Unit 2), Docket No. 50-47);
(e) on emergency planning in Long Island Lighting Company (Jamesport Nuclear Power Station, Units 1 and 2), Docket Nos. 50-516, 50-517; and (f) on implementation of plant operations in Yankee Atomic Electric Company (Yankee Nuclear Power Station), Docket No.50-029.
Dean Kunihiro has testified:
(a) on security matters in Commonwealth Edison Company (Zion Station, Units 1 and 2), Docket No. 50-295, 50-304.
Interrogatory 2 Does the current position differ from the position of the Staff in any prior proceedings? If so, identify the proceeding (s), explain the prior position, and explain the bas.3 ' r the change in position, f
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Response
A.
In the low power test proceeding, John Sears, the Staff's witness concluded that the Diablo Canyon emergency plan, when revised in l
l accordance with the commitments made, provides an adequate planning basis I
for an acceptable state of emergency preparedness. Commitments had been
made in upgrading the meteorological program, in an alert and notification system and in a public information system. These programs and sys ems are now being implemented.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
Safety Evaluation Report related to the operation of Diablo Canyon Nuclear Power Station Units 1 and 2, Supplement Nos. 10, 12 and 14.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal Staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 3 Identify any officers or employees of, or consultants to, the Staff who dissent from the present Staff position on Joint Intervenors' l
contention 1.
Explain the reasons for which any such person dissents.
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Response
A.
There are no identified dissenting staff members.
B.
None.
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7 C.
The Staff and/or inaependent contractor are not presently engaged in or intend to engage in further research or work which may bear on the,fssues covered in the interrogatory other than normal stdff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachnents A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 4 Identify the specific sections and page numbers of the FSAR for Diablo Canyon and the 14RC Staff's SER and SER Supplements for Diablo l
Canyon, which are relied upon in formulating the Staff position oa Joint Intervenors' contention 1.
Response
A.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3, in its entirety; Sections III. A.1.1.1, III. A.1.2, III.A.1.2(a), III.A.1.2(b), III.A.3, III.A.3.3, III.B and III.B.1 on pages III.A-1 through page III.B-3 of SER Supplement No. 10; sections III. A.1.1, III. A.1.2, III. A.1.2(b) and III.A.2 on pages 111-1 through page III-3 of SER Supplement No. 12; and sections III.A.1.2 and III.A.2 on pages 3-23 and 3-24 of SER Supplement No.14 were relied upon in The formulating the Staff position on Joint Intervenors' contention 1.
final conclusions of the NRC will be published in SER Supplement No. 15.
.o-B.
See response to Interrogatory 4.A.
C.
The Staff and/or independent contractor are not presently engaged:in or intend to engage in further research or work which may bear 1
on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 5 Identify all sections and page numbers of the FSAR, SER, and SER Supplements which contain subject matter pertaining to Joint Intervenors' contention 1.
l
Response
The Staff notes that this interrogatory is objectionable in that it asks the Staff to ccmpile data which is as readily available to Joint Intervenors as to Steff. The Joint Intervenors can read the FSAR, SER and SER Supplements ard find for themselves any portions relevant to their contention. See 4A Moore's Federal Practice, 133.20(3).
Interrogatory 6 Does the Staff contend that the Applicant, state, and local-emergency response plans for Diablo Canyon as they are presently 1
l
constituted comply with the Comuission's revised emergency planning regulations, effective november 3, 1980 (" Final Regulations on Ertrgensj Planning," 45 Fed. Reg. 55402 (August 19, 1980))?
1
Response
A.
The Staff does contend that the Applicant's emergency response plans for Diablo Canyon as they are presently constituted compt with the Commission's revised emergency planning regulations, effective Hovember 3,1980 (" Final Regulations on Energency Planning," 45 Fed. Reg. 554C2 (August 19,1980)). State and local plans are still under review by FEl4A.
B.
The draf t Emergency Plan for the Diablo Canynn Power Plant, Revision 3.
Safety Evaluation Report related to the operation of Diablo I
Canyon Huclear Power Station Units 1 and 2, Supplement Hos.10,12 and 14.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or' work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in l
dttachments A and B respectively.
l (2) See response to Interrogatory 1.0 (2).
(3) See answer to Interrogatory 1.D(3).
l
Interrogatory 7 If the answer to interrogatory 6 is yes, specify each and every fact supporting that answer.
f Responsh A.
The facts are described in SER Supplement Nos.10,12 and 14.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
Safety Evaluation Report related to the operation of Diablo Canyon Huclear Power Station, Units 1 and 2, Supplement Nos. 10, 12 and 14.
C.
The Staff and/or independent contractor are not presently engaged in or intend t'o engage in further research or work which may bear on the issues covered in the interrogatory other than normal Staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D (2).
(3) See answer to Interrogatory 1.D (3).
Interrogatory 8 If the answer to interrogatory 6 is no, does the Staff contend that the Commission's revised emergency planning regulations need not be complied with prior to issuance of a full power license at Diablo Canyon?
Specify each and every fact supporting the answer to this interrogatory.
Response
A.-D.
Not applicable.
9-Interrogatory 9 If the answer to interrogatory 6 is no, using a section by section analysis:: explain how and in what sections the Applicant, state, and local emergency plans do not couply with the Coamission's revised emergency planning regulations.
Response
A.-D.
Not applicable.
Interrogatory 10 Specify any and all revisions or changes which the Staff contends uust be made in the applicable emergency plans referred to in Joint Intervenors' contention 1, and any and all actions which must be taken, to eliminate prior to full operation at Diablo Canyon any deficiencies in those plans as they relate to the Commission's revised emergency planning regulations.
Response
A.
The Staff contends that prior to full operation there are no revisions, changes, actions which must be taken regarding the Applicant's i
Diablo Canyon emergency plans. With regard to the offsite plans, they are still under review and, therefore, no such determination has been l
f made.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
Safety Evaluation Report related to the operation of Diablo Canyon Nuclear Power Station Units 1 and 2 Supplement Nos.10,12 and 14.
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l C.
Tne Staf f and/or independent contractor are not presently engaged in or intend to engage in further research or work which raay bear on the ; issues covered in the interrogatory other than norraal staff h
review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in dttachiaents A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 11 Specify what, if any, deficiencies in the Applicant, state, and local ciaergency plans as they relate to the Commission's revised eiaergency planning regulations which the Staff contends need not be elirainated prior to full power operation at Diablo Canyon.
Response
A.
The Staff contends there are no deficiencies in the Applicant's l
emergency plans as they relate to the Commission's revised einergency planning regulations. With regard to the offsite plans, they are still under review and, therefore, no such determination has been made.
B.
The draf t Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
Safety Evaluation Report related to the operation of Diablo Canyon lluclear Power Station Units 1 and 2, Supplement hus.10,12 and 14.
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C.
The Staff and/or independent contractor are not presently engaged in or 'ntend to engage in further research or work which may bear on the i,ssues covered in the interrogatory other than normal staf f i
review.i D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Stoff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in dttachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 12 With respect to any of the deficiencies specified in answer to interrogatory 11, explain why they are not significant for Diablo Canyon and what interim actions have been or will be taken to compensate for the deficiencies.
Response
A..>0.
110t applicable.
Interrogatory 13 Specify precisely how, if at all, the Applicant, state, and local emergency plans for Diablo Canyon consider, allow for, or describe the possible effects on the implementation of those emergency plans of a major earthquake which occurs simultaneously with, or initiates, a radiological emergency at Utablo Canyon.
Response
A.
Tne offsite plans do not specifically address the effect of a major e4rthquake which occurs siuultaneously with a radiological i
emer',2nby at Diablo Canyon. The NRC Staff position is that consideration should be given by the Applicant to the complicating factors which might be caused by earthquakes in the development of emergency plans for a nuclear power plant. As a planning basis, the assumption is made that the plant site experiences earthquake effects of the type normally experienced in the geographical region where the plant is situated.
(In 1
any event no more severe than the Safe Shutdown Earthquake.) This assumption is consistent with the consideration of other natural phenomena such as blizzards, torr.adoes and hurricanes in other geographical regions of the country.
(NUREG-0654 Rev. 1, pp. 4-6).
The assumption need not be made that a reactor accident occurs simultaneously with the earthquake event, but the planning basis should consider that the plant might have been adveresely affected by the [arthquake (e.g.
through failure or degradations in non-seismically qualified systems and components) and may, therefore, be nor; prone to the potential for an incident that might result in offsite releases of radioactive material.
Fcctors to be considered should include the impacts due to potential disruption of communications networks and transportation routes, and should include the availability of resources and personnel to augment onsite staff, transit to and among emergency response facilities and communications with offsite authorities.
i In Section 7 of the Emergency Plar., the Applicant has described his communications system which includes an extensive telephone system
among corporate headquarters, the reactor plant, offsite ::acrgency facilities, and the 14RC and local and state authorities. The plant also naintains two UliF radio systems to establish and uaintain communications il between the plant control room, the Morro Bay Switching Center, the PG&E Infonaation Center, the Port San Luis guardhouse, the San Luis Obispo County Sheriff's Operation Center, Technical Support Center, the Offsite Recovery Center, Security Department and several mobile portable radio sets.
This equipment is considered to be adequate for communica.tions folloding an earthquake. The Applicant has contracts for helicip*,er service to furnish transportation to and from the plant following an earthquake if all other means of transportation are inoperative.
B.
Tne draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 includes in Appendix E a May 13, 1987 letter of agreement with Rogers Helicopters.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or$ork which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 14 If the answer to interrogatory 13 is no, will the Staff require that such coijsideration and information be included in the relevant plans 9
prior to full power operation at Diablo Canyon?
Response
A.
The Applicant has complied with our requirements as stated in the response to Interrogatory 13.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifica'tions are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 15 If the answer to interrogatory 13 is yes, specify how such plans consider, allow for, or describe the effects on the implementation of such plans of an earthquake yeater than the shutdown earthquake ("SSE")
which occurs simultaneously with, or initiates, a radiological emergency at Diablo Canyon.
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., Response A.
Earthquakes greater than the SSE are not reasonably anticipated natural! phenomena expected to occur during the operating life of the '
9 facility. The flRC Staff position is stated in response to Interrogatory 13.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 16 Specify now and where, if at all, the Applicant, state, and local plans (1) consider the complicating effects of an earthquake on emergency evacuation and (2) describe precisely the extent of the increases in evacuation times which could result if such an event were to cccur simultaneously with a radiological emergency at Diablo Canyon.
Response
A.
(1) The flRC Staff position, as stated in response to Interrogatory 13, is that the assumption need not be made that a reactor i
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accident occurs simultaneously with the earthquake event.
(2) The Staff objects to this part of Interrogatory 16.
No study exists at present within the NRC which specifically deals with increases in evacuation times which could result from an earthquake occuring simultaneously with a radiological emergency at Diablo Canyon.
Since no such study presently exists, requiring the Staff to conduct such a study is objectionable.
See 4A Hoore's Federal Practice, 1 33.20(3).
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
The Staff and/or independcht contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are tae experts whom the Staff intends to have testify on the subject matter : overed in the interrogatory. Copies of their professional qualific. tions are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 17 Describe in detail what, if any, cfforts the Staff has made or intends to make to require PG and E prior to full power operation to
17 -
update and revise (in accord with flVREG-0654) the letters of agreement set forth in Appendix 7 to its on site cuergency plan.
Response
i A.i Draft Revision 3 of the Emergency Plan incluaes uposted letters of agreement.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
Tne Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the 1:iterrogatory other than normal staff
- review, D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 18 Describe how the public will be notified and informed about
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appropriate protective actions which should be taken in the event of an emergency.
Specify when any proposed notification system will be fully operational and how long it will take to notify all persons within 10 l
I miles of the reactor.
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Response
A.
Prinary responsibility for prompt notification of the public lieswiphtheCounty.
Notification of the public involves both warning i
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that ag eiaergency condition exists and the issuance of instruction to the public so that protective actions may be implemented.
The sounding of an area-wide siren system designated as the Early Warning System (EWS) within the State Basic Euergency planning zone will alert members of the general public to tune radios to the Emergency Broadcast stations for the receipt of emergency instructions. The initial sounding of the siren system will not necessarily be to recommend evacuation; the initial instructions might include directives to stay inside, close windows and doors, shut off ventilation systems, and listen to radio and television for further information.
Population in parks and on beaches will be notified by mobile vehicle public address and hand-held public address units in the inore accessible areas. These notifications will be carried out by State Parks Department, County Sheriff, and incorporated ci*y police personnel, generally depending on the jurisdiction.
Isolated rural population and transients outside of siren range will be notified by sedans and off-road veh,les, carrying mobile public address systems assisted by helicopter surveillance and warning.
Ships at sea will be notified by marine radio and by direct interceptions by the U.S. Coast Guard:
l The EWS will be operational prior to full power operation.
i The public will be alerted by the siren alerting system. A prior public information program will instruct the public, upon hearing the sirens, to take shelter and listen to the local radir station for further l
l
instructions, the notification system will be fully operational by October 1981. The objective in the public alerting and notification
.is for the public within the 10-uile zone shall be notified within systeal i
15 minutes of the time that the initial notification is cade offsite by the operator.
B.
San Luis Obispo County Nuclear Power Plant Emergency Response Plan.
Section 7.2.2 of the draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
Tne Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
1 D.
(1) John R. Sears and Dean Kunihiro are the experts whom the.
Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.0(2).
(3) See answer to Interrogatory 1.D(3).
J Interrogatory 19 90 the Applicant, state, and local emergency plans for Diablo Canyon contain the actual wording of emergency messages or the standard format for detailed initial and follow-up communications? If not, why not?
1
Response
i A.
The Applicant's emergency implementir.g procedures for Diablo Canyon c,ontain the actual wording of emergency raessages or the standard 1
foru,, ifor detailed initial and follow-up communicacions.
flo such message examples are included in the present plans of the offiste agencies. However, they are planned to iie included in the standard operation procedures which comprise Part III of the San Luis Obispo County liuclear Power "iant Emergency Response Plan.
B.
The Applicant's implementing procedures and the San Luis Obispo County lluclear Power Plant Emergency Response Plan.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear
.i on the issues covered in the interrogatory other than normal staff review.
i D.
(1) John R. < ears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter cdvered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 20 Describe in detail tne public information program or measures which will be implemented to comply with 10 C.F.R. 950.47(b)(7). When will that program or those measures be implemented?
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Response
A.
The PG&E public information program includes the following:
1.
A sign has been drafted and sent to state and local
.i officials for approval, to be installed at the ranger's station in liontana de Oro State Park.
2.
A page in tne October 1981 county telephone book will describe cuergenqy response instructions.
3.
A newsletter has been mailed to San Luis Obispo County residents giving basic emergency response information.
4.
A booklet will be mailed to all residents in San Luis Obispo County with more complete information than the newsletter by October 1, 1981. The aspects of public information dissimination during an accident are outlined in Section II.6 of the proposed San Luis Obispo County Nuclear Power Plant Emergency Response Plan.
B.
San Luis Obispo County Nuclear Power Plant Emergency Response Plan.
The draft Emergency Plan for the Diablo Canyon' Power Plant, Revision 3.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal st < '
review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 21 Describe in detdil how, if at all, the caergency response facilities for Diab 1o Canyon will not comply with the criteria set forth in 7f liUREG-Op96, entitled " Functional Criteria for Emergency Response Facilities, Final Report," prior to full power operation at Diablo Canyon.
Response
A.
The Applicant's emergency response facilities comply with the intent and guidance in NUREG-0696, with the exception that the interim Emergency Operations Facility is located in two trailers at the San Luis Obispo County Sheriff's Operations Facility.
The Staff has been informed that the Applicant has under design a permanent Emergency Operations Facility which is scheduled for completion before October 1, 1982.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the l
Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
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(3) See answer to Interrogatory 1.D(3).
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M.rogatory 22 Explain how the decision will be made whether to order sheltering or evacuatipn during an atmospheric release of radioactivity. What factors 1
will be considered in making the decision? What criteria will be applied to decide when to evacuate as opposed to when to shelter?
Response
A.
Tne decision to order shelter or evacuation following an accident will be made by a county official based on a recormendation by PG&E to local authorities before any release of radioactivity occurs on the basis of observable acasurable indications at the reactor plant.
6 These plant conditions are listed in Section 4 of the Emergency Plan and follow the guidance of Appendix 1 to NUREG-0654.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or%ork which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) Jonn R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of tneir professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
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Interrogatory 23 Who will order the appropriate protective action for the public and on the 5 asis of what information and criteria?
'i Retsonse A.
The San Luis Obispo County Emergency Plan has the provision that if the Emergency Coordinator at the plant recommends in.rdiate precautionary evacuation, in the event the Emergency Operation Facility and the Emergency Operation Center are not in operation, the Sheriff's Department has the authority to order the evacuation. The Chairman of the Board of Supervisors also has the authority to order an evacuation.
B.
Tne draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3, and the San Luis Obispo County Emergency Plan.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the l
Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachnents A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
t j
Interrogatory 24 In endorsing the concept of E?Z planning guidance, the Commission stated "it is appropriate and prudent for emergency planning guidance to t
take into consideration the principal characteristics... of a spectrum of design basis and core melt accidents." 44 Fed. Reg. 61123 (October 23,1979;).
Explain how the relevant Diablo Canyon emergency response 1
plans ih effect at the time of full power operation will consider the
- rincipal characteristics and effects of a spectrum of core melt accidents.
Response
A.
The rationale for the 10-mile Emergency Planning zone for the plume exposure pathway is described in HUREG-0396, Planning Basis for the Developnent of State and Local Government Radiological Emergency Response Plans in Support of Light Water fluclear Power Plants. The document states that the authors of the report judged that the consequences of a spectrum of accidents should be the principal rationale behind the planning basis. The emergency response plans for Diablo Canyon fluclear Power Plant extend beyond 10 miles and that basis is taken into account.
6.
tiUREG-0396, Planning Basis for the Developmep't of State and Local Government Radiological Emergency Response Plans in Support of Light Water fluclear Power Plants.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
. 4 (2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
Interrogatory 25 Specify in detail what efforts, if any, have been made to achieve coordination of PG and E's emergency response organization with all officials responsible for emergency preparedness and response in (a)
Avila Beach, (b) Los Osos, (c) Montana de Oro State Park, (d) Cayucos, (e) Pismo Beach, (f) Oceano, (g) Atascadero, (h) Arroyo Grande, (i) Morro Bay, (j) riipomo, (k) Cambria, (1) Santa Maria, (m) Paso Robles, (n) San Luis Obispo, and (o) local beaches and parks, including Pismo, Cayucos, Morro Strand, and Atascadero.
Response
A.
Comunities within the 10-mile Emergency Planning Zone are located in San Luis Obispo County.
San Luis Obispo County has prepared an Emergency Response Plan and an Emergency Evacuation Plan.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
Tne Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the i
interrogatory. Copies of their professional qualifications are in 4
attachments A and B respectively.
l
)
(2) See response to Interrogatory 1.0(2).
(3) See answer to Interrogatory 1.0(3).
1 1
Interroijatory 26 Specify what efforts, if any, have been made to date to educate and inforu the public within a 50 mile radius of Diablo Canyon regarding what nedical facilities to contact in the event of radiation-related injury, what actions to take in the event of a radiological emergency, what the risks of operation of the reactor are, and what the evacuation routes are in the event of a radiological emergency.
Response
A.
The public information program which has been described in response to Interrogatory 20 will extend thrm;gnout the basic emergency planning zone of San Luis Obispo County.
In addition, the numerous meetings, sponsored by the county in the development of its emergency response plan, are held for the purpose of informing,the public and allowing them input into the development of the county emergency plan.
B.
San Luis Obispo County Nuclear Power Plant Emergency Response Plan. The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3.
C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work wnich may bear on the issues covered in the interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the
interrogatory. Copies of their professional qualifications are in dttdchnents A and B respectively.
i; (2) See response to Interrogatory 1.D(2).
i (3) See answer to Interrogatory 1.D(3).
Interrogatory 27 Describe all emergency preparedness drills and/or exercises which have been conducted by the Applicant and/or local and state officials in which the northern evacuation route from the site has been utilized.
Response
A.
There has been none.
B.
None.
4 C.
The Staff and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in d:
interrogatory other than normal staff review.
D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory. Copies of their professional qualifications are in attachments A and B respectively.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.0(3).
o.
.. Interrogatory 28_
Describe in detail all available evacuation routes frou Ciablo Canyon ip the event both the main entrance to the plant from Avila Beach I
and theinorthern evacuation route through the Field Ranch are blocked.
Response
A.
In such a case, evacuation could be accomplished via helicopter.
B.
The draft Emergency Plan for the Diablo Canyon Power Plant, Revision 3 includes in Appendix d a ilay 13, 1981 letter of agreement with Rogers Helicopters.
C.
The Staff and/or independent contractor are not presently l
engaged in or intend to engage in further research or work which may bear on the issues covered in the in errogatory other than normal staff review.
D.
(1) John R. Sears is the expert whom the Staff intends to have testify on the subject matter covered in the interrogatory. A copy of his professional qualifications is in attachment A.
(2) See response to Interrogatory 1.D(2).
(3) See answer to Interrogatory 1.D(3).
II.
Request for Production of Documents Pursuant to 10 C.F.R. 9 2.741(d), the Staff will respond to Joint Intervenors' request for production of documents within 3D days after the service of the request.
Attorney for objections:
+ /4
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f Bradley 4< ones Counsel Tor 14RC aff Dated at Bethesda, Maryland this 2nd day of September, 1981.
r
UFIITED STATES OF AtlERICA HUCLEAR REGULATORY C0!411SSION BEFORE THE AT0i11C SAFETY AND LICENSING BOARD
~
i Inthellalterof PACIFIC GAS Afl0 ELECTRIC C011PANY
)
Docket Hos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Unit Nos. I and 2)
)
AFFIDAVIT OF BARTH0L0t1EW C. BUCKLEY I, Bartholomew C. Buckley, being duly sworn, state as follows:
1.
I an employed by the U.S. Nuclear Regulatory Commission a3 Project ilanager in the Division of Licensing, Office of Nuclear Reactor Regulation.
2.
I am Project 14anager assigned to the Diablo Canyon Power Plant.
3.
I am duly authorized to review the answers to Interrogatory Nos. I through 28 and I hereby certify that the answers given are true and correct to the best of r.y knowledge.
OdAbo C.
H Bartholomew C. Buckley Subscribed and sworn to before me this S/or day of August,1981
$l,1.t's '1/1 Q0.s>
Notary Publib ity Coranission Expires:
dj'<952.
UtilTED STATES OF A!! ERICA IluCLEAR REGULATORY COMlilSS10N BEFORE THE ATOMIC SAFETY AND LICEflSiflG BOARD _
i In the !%tter of
)
(
)
Pt.CIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. f0-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant 1 Unit Hos. I and 2)
)
AFFIDAVIT OF JOHN R. SEARS 1, 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 Interrogatories 1-28 and I hereby certify that the answers given are true to the best of ray knowledge.
wlSJ
,I
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s w
John R. Sears L/
Subscribed and sworn to before me this d/s t day of August, 1981.
LYUn b 'm CL(1?u Notary Publicd fly Commission expires: O,, 0m i_ 1983 J
6
UNITED STATES Of AMERICA NUCLEAR REGULATORY C0tcISSION B_EF,0.RE,,THE ATOMIC SAFETY AND_L_ICENSING BOARD
.,.if 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)
)
AFFIDAVIT OF DEAN,_M.,,KU,NI,HIRO I. Dean M. Kunihiro being duly sworn, depose and state as follows:
1.
I am employed by the U. S. Nuc1 car Regulatory Conniission as Regional State Liaison Officer. Office of Inspection and Enforcement.
2.
I am duly authorized to answer Interrogatories 1 through 27 and I hereby certify that the answer given is true to the best,0f my knowledge.
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,k" ;ys.
' Qi **
l Dean M. Kunihiro Subscrihed and sworn to before me I
this.'/ M day of August 1981.
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My Commission expires:
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Attachmentt A U';1TE] STATES OF A" ERICA NUCLEAR REGULAT0TY C0441SSIO:{
BEF0RETHEAT0511CSAFETYAR3__LICERSILBOARD_
In the Matter of PACIFIC AS AND ELECTRIC C0ilPAiY
)
Docket Nos. 50-275 0.L.
50-323 0.L.
(Diaolo Canyon Nuclear Poser Plant 1 Unit Nos. I and 2)
)-
J0iil R. SEARS PROFESS!0.AL QUALIFICATIONS 1
EMERGENCY PREPAREDNESS P_ROGRAM OFFICE Prior to 1952, I was employed in fielo jobs in various aspects of mechanical engineering.
In 1952. I joined Brookhaven National Laboratory While as a Reactor Shift Supervisor on the Brookhaven Graphite Reactor.
at Brookhaven, I completed a series of courses given by the Nuclear Engineering Department in nuclear engineering. These courses were patterned on the ORSORT programs.
In 1956. I was appointed Project I,was a member of Engineer on the Brookhaven Medical Research Reactor.
the design group, participated in critical design experiments, wrote specifications, coauthored the hazards report, was responsible for field inspection and contracter liaison, trained operators and loaded and About three months after start-up, in 1959, started up the reactor.
following the successful co:npletion of proof tests and de:aonstration 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 Coinpliance.
I was responsible for the inspection, for safety and
2-conpliance witn license requirements, of the licensed reactors and the fuel fabrication and fuel processing plants, which use more than critical l
amounts of special nuclear naterial, in tne Eastern United States.
In Septenber 1963 I transferred to the Operational Safety Branch, i
Directorate of Licensing.
My responsibility included developnent of appropriate guides for evaluation of operations 1 aspect of license applications and staff assistance in revied of power reactor applicants Personnel submittals in the areas of Organization and !!anagement.
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 emphasis and attention upon areas of physical security and energency planning.
In 1976, I transferred to the Division of Operating Reactors as the l
sole reviewer responsible for review of emergency planning for all tne operating reactors in the United States.
New York 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 Plann
~
Instructor at DCPA, 1976, 1977 - Course in Emergency Planning f
. ~, -,,,. --
- -, -... ~. - -
~
Director, 1952 - Reactor Progra1, Atons for Peace Exhibit Bangkok, Thailand Direptor, 1956 - Atons for Peace Exhibit, Utrecht, Eslland fi e
.# ~
, Attachment B UllITED STATES OF AMERICA I4UCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD inthelYatterof
)
PACIFIC GAS AllD ELECTRIC COMPANY Docket Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power Plant )
Unit lios. I and 2)
)
DEAll M. KUNIHIRO PROFESSIONAL QUALIFICATIONS I joined the Nuclear Regulatory Commission Staff in 1976 as a Program Analyst in the Office of Nuclear Material Safety and Safeguards. Following that assignment I was assigned as a Reactor Safeguards Analyst in the Office of Nuclear Reactor Regulation.
In that position 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 technica), evaluation of emergency plans for 8 nuclear power facilities. Among these facilities was the Diablo Canyon Nuclear Power Plant.
I am presently assigned as the Regional State Liaison Officer, U.S.
NRC Pegion V.
As part of my duties I serve as a member of the Regional Assistance Committees in Federal Regions IX and X.
These committees l
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. Arnly in a variety of assignments to include combat infantry duty in c
Viet fiam, and radiobiology research with the Defense Nuclear Agency.
i l
l
I have a Bachelor of Scierce degree frora the United States Military Acaderay and a Master of Science degree in Physics from the Naval Post-grafduateSchool.
i 4
4 9
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
1 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)l PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
h) 50-323 0.L.
y (Diablo Canyon Nuclear Power Plant Unit Nos. 1 and 2
)
CERTIFICATE OF SERVICE I hereby certify that copies of NRC RESPONSE TO JOINT INTERVEN0RS' FIRST SET OF INTERR0GATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF in the above-captioned proceeding have been served on the following by deposit in the i
United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 2nd 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
- Mr. Gordon Silver Dr. Jerry Kline Administrative Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Strett 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 Gas and Electric Company 321 Lytton Avenue 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..
Phoenix, Arizona 85012' 4623 More Mesa Drive Santa Barbara, California 9310F 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. t;uclear Regulatory Commission Marion P. Johnston, Esq.
Washington, D.C.
20555
- Joel Reynolds, Esq.
Centerfor(awinthePublic Atomic Safety and Licensing Board Interest i 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 Aff airs 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.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 I
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
W Mr. James 0. Schuyler Br i l
o Nuclear ?rojects Engineer Coun or Stat' Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106
_ _ ___________ _______