ML20030D270
| ML20030D270 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/26/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20030D267 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8109010094 | |
| Download: ML20030D270 (17) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOt8 i
o BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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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)
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)
l GOVERNOR EDMUND G. BROWN JR. FIRST SET OF INTERROGATORIES AND SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF Pursuant to 10 C.F.R.
Sb 2.720(h), 2.744, and the Licensing Board Order of August 4, 1981, Governor Brown hereby propounds the following Interrogatories and Document Production Requests to the NRC Staff.
INSTRUCTIONS 1.
As used herein, " documents" include, but are not limited to, emergency plans and procedures, construction plans and speci-fications, papers, photographs, motion pictures, criteria, standards of. review, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-c'orporate memoranda or written communications of any nature, intra-agency memoranda or eritten communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, l
I appraisals, work papers, reports, studies, opinions, analyses, assessments, surveys, evaluations, projections, hypotheses, form-ulas, designs, drawings, manuals, notebooks, worksheets, contracts, 8109010094 810826 PDR ADOCK 05000275 G
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i agreements, letter agreements, diaries, desk calendars, charts, I
schedules, appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, f
proposals, and all drafts, revisions, and differing versions l
(whether formal or informal) of any of the foregoing, and also i
j all copies of any of the foregoing which differ in any way (including handwritten notations or other written or printed a
matter of any nature) from the original.
j E.
These Interrogatories and Document Production Requests are intended as continuing Interrogatories and Production Requests, requiring the NRC Staff'to answer by supplemental answer, setting' forth any information within the scope of these discovery requests as may be acquired by the NRC Staff, its agents, attorneys or representatives following the Staff's original answers up to the j
time of hearing.
3.
When asked to identify or describe a-document, set forth l
the author's name, date of preparation, title, the subject matter 4
I of the document, to whom such document was sent, and the where-l l
abouts of all copies.
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l 4.
When an Interrogatory cr Production Request seeks a i
l document or information of or in the possession of the NRC Staff, that Interrogatory or Request includes all documents or informa-i tion in the possession, custody or control of the Staff, including i
any of its past or present contractors, employees, consultants, or agents.
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m INTERROGATORY l For what regulatory purpose did the NRC Staff request PG&E to consider the complicating effects of an earthquake on emergency preparedness and response at Diablo Canyon?
INTERROGATORY 2 (a)
Identify the Staff personnel who have met or spoken with PG&E personnel concerning the potential complicating effects of an earthquake on emergency preparedness at Diablo Canyon.
(b)
Identify the PG&E personnel with whom such Staff personnel have met.
(c)
State the dates of such meetings and describe the matters discussed.
(d)
Identify and describe each and every document, memorandum, and personal notes related to all such meetings and/or telephone conversations.
INTERROGATORY 3 Describe the Staff position on each of the following matters.
Include in the answer a description of all analyses, reports, memoranda, or other documents in the possession, custody, or control of the NRC Staff which analyze or relate in any Way to any orallofthesemftters:
(a)
The time necessary to take onsite and/or offsite protective actions, including evacuation, in the event of a radio-logical emergency at Diablo Canyon; (b)
The feasibility of notifying persons in the backcountry of Montana de Oro State Park of a radiological emergency at Diablo Canyon;
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e (c)
The correctness of the location of PG&E's real-time monitoring instruments; (d)
The adequacy of tne alternate evacuation route from the PG&E facility to the north through the Field Ranch; (e)
The complications to emergency response resulting from an earthquake initiating and/or in conjunction with an accident at Diablo Canyon; and (f)
The complications to emergency preparedness resulting from an earthquake prior to, and independent of, a radiological emergency at Diablo Canyon.
INTERROGATORY 4 What is the Staff position regarding whether the offsite emergency response plans and preparedness (both local and State) 1 must satisfy 10 C.F.R.
S 50.47 prior to full' power operation?
Describe all documents that relate in any way to this position.
INTERROGATORY 5 What is the Staff position with regard to whether PG&E should consider the complicating effects on emergency preparedness and response of an earthquake greate_' than the SSE?
Describe all documents that relate in any way to this position.
INTERROGATORY 6 What is the Staff position on the adequacy of the criteria guiding PG&E employees regarding when to recommend evacuation (onsite and/or offsite) versus when to recommend sheltering?
Describe all reports, analyses, assessments or other documents that relate in any way to these criteria or to the Staff's position.
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INTERROGATORY 7 What is the Staff position on the adequacy of the public information program proposed by PG&E to support full power operati0n of the Diablo Canyon facility?
Describe all documents which in any way relate to this public information program and/or the Staff position thereon.
INTERROGATORY 8 (a)
What is the Staff position on the adequacy of the drills or exercises (including the August 19, 1981 exercise) which have been conducted to test all or any part of PG&E's onsite and/or offsite emergency preparedness and response capabilities?
(b)
Identify and describe any and all documents or criticues related to these drills or exercises.
INTERROGATORY 9 (a)
What is the Staff position on the adequacy of the train-ing provided to onsite and offsite emergency response personnel?
(b)
Identify and describe any and all critiques or other documents related to this training.
INTERROGATORY 10 (a)
What is the Staff position on the adequacy of equipment available to San Luis Obispo County personnel (including monitor-ing, communications, and notification equipment) ?
(b)
Identify and describe all analyses, reports, assessments or other documents which relate to such County equipment.
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o INTERROGATORY 11 (a)
What is the Staff position on the adequacy of medical facilities, personnel and equipment (both onsite and offsite) to deal with exposures and/or injuries related to a radiological emergency at Diablo Canyon?
(b)
Identify and describe all reports, analyses, assessments, or other documents which relate to such medical facilities, personnel or equipment.
INTERROGATORY 12 (a)
What is the Staff position on the adequacy of plans for notification of transient persons within 10 miles of the Diablo Canyon facility in the event of a radiological emergency?
Please address each of the following transients: (1) agricultural workers; (2) visitors to Montana de Oro State Park; and (3) persons who may be temporarily visiting the San Luis Obispo area.
(b)
Identify and describe all analyses, reports, assessments or other documents which relate in any way to such notification.
INTERROGATORY 13 (a)
What is the Staff position on the adequacy of the seismic qualification of: (1) the real-time monitors and associated structures proposed for use at Diablo Canyon, both onsite.and off-site; (2) the sirens and associated structures proposed for use as part of the Diablo Canyon public notification system; (3) the on-site meteorological tower and associated structures; and (4) the equipment and associated structures at each of the offsite environ-mental monitoring ~ locations.
(b)
Identify and describe all documents which relate in any way to the seismic qualification of the foregoing equipment, including any tests or analyses which have been performed by the m-see aw snwwm m, mm
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o INTERROGATORY 14 (a)
What is the Staff's position on the adequacy of both (1) onsite and (2) offsit preparedness to deal with the compli-cating effects of an earthquake on emergency preparedness and re-sponse to a radiological emergency at Diablo Canyon?
(b)
Identify each and every place in the PG&E, State and County emergency response plans reviewed by the Staff where the complicating effects of an earthquake on emergency preparedness and/
or response are considered or addressed.
(c)
Identify and describe all analyses, reports, assessments or other documents which in any way relate to these matters.
INTERROGATORY 15 (a)
Has the Staff met or spoken with officials of the California State government concerning the complicating effects of an earth-quake on emergency preparedness and/or response at Diablo Canyon?
(b)
If YES, please state the date (s) of all such meetings or conversations, the name (s) of the persons (and their organiza-tions) attending such meetings or participating in the conversa-tions, and the specific subjects discussed.
(c)
Describe all documents relating to these conversations or meetings.
INTERROGATORY 16 Attached to Revision 2 of the Diablo Canyon Emergency Response Plan are several agreements.
For example, there are agreements with French Hospital and with San Luis Obispo Ambulance Service.
(a)
What is the Staff pcsition on the adequacy of these agreements?
(b)
Describe any reviews, investigations, or analyses (including field investigations) performed by the Staff to deter-h ref 9h3s eEreements.
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INTERROGATORY 17 (a)
Does the Staff anticipate that prior to full power operation, the onsite and offsite emergency preparedness at Diablo Canyon will cor.. ply fully with all the ' Planning Standards of Section 50.47(b)?
(b)
If the answer is YES, describe the basis"for this posi-tion, including a standard-by-standard analysis of how each is satisfied and a description of each document related thereto.
(c)
If the answer is NO, describe each deficiency and ex-plain whether the Staff will support full power licensing of l
Diablo Canyon despite ee.ch such deficiency.
Describe the basis for the Staff's position on each such deficiency and describe each document related thereto.
INTERROGATORY 18 (a)
What is the Staff position on the adequacy of the San Luis Obispo County Emergency Plan (i.e.,
the draft version dated May 1981) ?
l (b)
Identify and describe any reports, analyses, assess-1 ments, or other documents which relate in any way to that May 1981 plan.
INTERROGATORY 19 (a)
What is th.e Staff's position on the adequacy of PG&E's systems for communicating from the Diablo Canyon site to offsite governmental authorities, including specifically the governmental authorities of San Luis Obispo County, the City of San Luis Obispo, the State of California, the Nuclear Regulatory Commission, FEMA, and the Cities of Atascadero, Arroyo Grande, Grover City, Morro Bay, Paso Robles, and Pismo Beach?
(b)
Identify and describe all analyses or other documents whink v.1=*a in anu umu en whic nneieinn
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o INTERROGATORY 20 What is the Staff position on the adequacy of offsite com-munications equipment.
Describe all documents which in any way relate to such communications equipment and/or the Staff position.
INTERROGATORY 21 Does the Staff contend that the PGEE and offsite communications equipment will remain fully functional in the event of the OBE?
The SSE?
An earthquake greater than the SSE?
(a)
If the answer (s) is (are) YES, please give the basis for the Staff position, including a des'ription of all documents relating c
thereto.
(b)
If the answer (s) is (are) NO, please give the basis for the Staff position, including (1) a description of all documents relating thereto and (2) a description of any compensatino measures proposed by the Staff in the event communications systems do not remain fully functional.
INTERROGATORY 22 Describe all analyses, critiques, memoranda or other documents which relate in any way to the August 19 emergency exercise, including:
(a)
Any documents concerning selection of the scenario used on August 19; (b)
Any documents analyzing the PG&E onsite response; and (c)
Any documents which analyze the offsite response.
INTERROGATORY 23 (a) List each and every person the Staff may call or subpoena as a witness to any hearing which may be held on the emergency preparedness contention admitted by the Licensing Board in its Order of August 4, 1981.
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_- 7 (b)
As to each such witness, please state:
(1)
The name, occupation, address and telephone number of each such person and whether that person may appear for I
the Staff as a. voluntary witnes's or a subpoenaed witness.
(2)
The field or science in which such person is schooled and,'or experienced to enable him or her to express opinion evidence in this matter, if any.
(3)
Whether such witness will base his or her opinion in whole or 'n part upon facts acquired personally by that person in the course of an investigation or examination as to the facts, or upon information provided that person by~otners.
(4)
The qualifications of each such witness.
(5)
If any such witness had made a personal investigation or examination relating to any of the facts or bases set forth in the answers to any interrogatories in the Governor's instant document, state the dates and nature of each such investigation or examination.
( 6)
Each and every fact aNd each and every document, photo-l graph or report or item, or other tangible object supplied or made available to each such person.
i (7)
Whether each such person has rendered written reports regarding facts, bases, cr opinions as respects your answers to these interrogatories.
If so, state the date of each such report and the name and address of the custodian of each such report.
(8)
A summary of each witness' proposed testimony.
(9)
Identify any other NRC proceedings in which each such witness has previously testified.
Provide copies of sucN testimony.
INTERROGATORY 24 Identify and describe all reports, studies, analyses, assessments or other docuements being prepared by or for the Staff that deal with any or all of the following:
(1)
The complicating effects of an earthquake on emergency preparedness for response to a radiological emergency; (2)
Evacuation time estimates for the evacuation of the Diablo Canyon facility and the emergency planning zones surrounding the facility; (3)
The Diablo Canyon public information program; (4)
The consequences of a radiological emergency at Diablo Canyon on the capability of offsite entities to provide assistance to PG&E; and (5)
The adequacy of onsite and offsite communications systems.
For each item described, specify who is preparing the item, when it is scheduled to be completed, and what the purpose (s) of the item is (are) intended to be.
INTERROGATORY 25 (a)
What is the Staff's position on the adequacy of the Diablo Canyon TSC, OSC, and the interim EOF to meet the reliability requirements of NUREG-0696.
See NUREG-0696, p.
5.
(b)
Identify and describe all analyses or other documents which relate in any way to the emergency response facilities'-
compliance or noncompliance with these requirements.
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k (c)
What is the Staff's position on whether the EOF and UDAC and related equipment will remain fully functional in the event of the OBE, the SSE, and an earthquake greater than the SSE?
Describe all documents related to this position.
INTERROGATORY 26 (a)
What is the Staff's position on whether the interim EOF meets the requirement that it be "well engineered for the design life of plant?"
NUREG-0696, p.
18.
(b)
Identify and describe all anclyses or other documents which relate in any way to the EOF's compliance or noncompliance with this requirement.
INTERROGATORY 27 (a)
What is the Staff's position on the adequacy of t'he emergency operating procedures for the Diablo Canyon facility?
(b)
Identify and describe all analyses or other documents which relate in any way to this position.
INTERROGATORY 28 (a) What specifically would the NRC Staff do if PG&E notified the NRC of a radiological emergency at Diablo Canyon?
(b)
In such case:
(1) who at the NRC would notify the State of California; and (2) would the Governor be called and, if so, by whom?
(c)
What specifically would the Staff do if an earthquake occurred in conjunction with a radiological emergency at Diablo Canyon?
(d)
Who at the NRC would be in charge if such an earthquake and radiological emergency occurred and what would be the lines of authority from the Commissioners to affected staff.
(Please include names of individuals, titles, and organization charts.)
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(e)
What would FEMA's role bo in the case of an earthquake and radiological emergency?
(f)
Please describe all Staff and Commission-level documents which relate in any way to lines of authority both (1) within the NRC and (2) between the NRC and FEMA during a radiological emergency at Diablo Canyon (in case of a radiological emergency both in con-junction with and separate from an earthquake), and all FEMA docu-ments related to the same.
INTERROGATORY 29 (a)
Identify and describe any and all reviews, studies, analyses, assessments, or other documents that the Staff has performed of a radiological emergency at Diablo Canyon that is caused by the threat designated in 10 C.F.R. S 73.1 or malevolent actions that Part 73 is intended to protect,against.
(b)
Did the Staff perform any integrated analyses or reviews of the PG&E Security Plan and Emergency Plan?
If so, identify and describe the methodology and the documents.
DOCUMENT PRODUCTION REQUEST (a)
Produce all documents described or identified in response to Interrogatories 1-29...
(b)
Produce all memoranda or other documents that relats in any way to the letter or to the substance of the letter sent by R. Tedesco to PG&E, dated December 16, 1980, and the similar letter to FEMA, dated November 1980, both related to the effects of an earthquake on emergency response.
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(c)
Produce all memoranda, assessments, reports, analyses, findings or other documents of FEMA which relate in any way to:
(1) The preparedness of offsite emergency response enti-ties to respond to an emergency at Diablo Canyon; and (2)
The complications to emergency preparedness that would or might result from an earthquake causing or in conjunction with a radiological emergency at Diablo Canyon.
These documents are to be produced at the offices of the undersigned counsel, 1900 M Street, N. W.,
Nashington, D. C.
- 20036, within 30 days of service of this request.
Respectfully submitted, Byron S. Georgiou Legal Affairs Secretary Governor's Office State of California Sacramento, California 95814
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i Herbert H.
Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P. C.
1900 M Street, N. W.
I Washington, D.
C.
20036 Attorneys for Governor Brown of the State of California August 26, 1981
(
4 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 Canyon Nuclear Power Plant,
')
Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " GOVERNOR EDMUND G. BROWN JR.
FIRST SET OF INTERROGATORIES AND SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY" and " GOVERNOR EDMUND G.
BROWN JR. FIRST SET OF INTERROGATORIES AND SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF" in the above-captioned proceeding have been served to the following on August 26, 1981 by U.S.
mail, first class.
Mr. Thomas S. Moore, Chairman Atomic Safety and Licensing Appeal Board U.
S.
Nuclear Regulatory Commission Washington, D. C.
20555 Dr.
W.
Reed Johnson Atomic Safety and Licensing Appeal Board U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Chairman Atomic Safety and Licensing Appeal Panel U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 John F. Wolf, Esq., Chairman Atomic Safety and Licensing Board U.
S. Nuclear Regblatory Commission Washington, D.
C.
20555 Mr. Glenn O.
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
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William J.
Olmstead, Esq.
Edward G.
Ketchen, Esq.
Lucinda Low Swartz, Esq.
Office of Executive Legal Director BETH 042 3
U.
S.
Nuclear Regulatory Commission i
Washington, D.
C.
20555 Secretary i
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 McA1.'ister Street San Francisco, California 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Beach, California 93449 Mr. Frederick Eissler i
Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, California 93105 Mr. Gordon Silver Mrs. Sandra A.
Silver 1760 Alisal Street San Luis Obispo, California 934.11 John Phillips, Esq.
i Center for Law in the Public Interest l
10203 Santa Monica Drive Los Angeles, California 90067 Bruce Norton, Esq.-
Norton, Burke, Berry & Junck 3216 North Third Street - Suite 300 Phoenix, Arizona 85012 Philip A.
Crane, Jr.,
Esq.
i Richard F.
Locke, Esq.
Pacific Gas and Electric Company 1050 17th Street, N.
W.
- Suite 1180 Washington, D.
C.
20036
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David S.
Fleischaker, Esq.
1735 Eye Street, N. W.
- Suite 709 Washington, D.
C.
20006 Arthur C. Gehr, Esq.
i 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 i
P.
O.
Box 112 San Luis Obispo, California 93402 i
l Byron S. Georgiou, Esq.
Legal Affairs Secretary i
Governor's Office - State Capitol l
Sacramento, California 95814
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Herbert H.
Brown - Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P. C.
I 1900 M Street, N. W.
Washington, D. C.
20036 August 26, 1981 l
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