ML20031B347
| ML20031B347 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/25/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | Federal Emergency Management Agency |
| Shared Package | |
| ML20031B345 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8110010257 | |
| Download: ML20031B347 (7) | |
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMFANY
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Docket Nos. 50- 275 0.L.
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50-323 0.L.
(Diablo Canyon Nuclear Power
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Plant, Unit Nos. 1 and 2)
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GOVERNOR EDMUND G. BROWN JR. REQUEST
'S FOR PRODUCTION OF DOCUMENTS TO THE FEDERAL EMERG.il?CY MANAGEMENT AGENCY Governor Brown hereby requests the Federal Emergency Manage-ment Agency (" FEMA") to produce for inspection and copying the documents described below.
The documents shall be produced with-in 30 days of service of this request at the offices of Governor Brown's undersigned counsel, 1900 M Street, N.W.,
8th Floor, Washington, D.C. 20036, unless another time or location is mutually agreed upon.
Definitions 1.
" FEMA" when used herein includes, but is not necessarily limited to, FEMA headquarters in Washingtor.,
D.C., all FEMA regional offices, including FEMA Region IX, the Regional Assistance Committees, and all employees, contractors, consultants or agents of FEMA.
2.
"PG&E" whr.n used herein refers to Pacific Gas and Electric Company and all employees, contractors, consultants or agents of PG&E.
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"NRC" or "NRC Staff" or " Staff" when ased herein refers i
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to the United States Nuclear Regelatory Commission, including b'
all regional offices and all staff, employees, contractors, con-a, sultants or agents thereof.
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"Diablo Canyon" when used herein refers to the Diablo 5
Canyon Nuclear Power Plant located in San Luis Obispo County, California.
.t 5.
" San Luis Obispo County" or " County" when used herein i
.i refers to San Luis Obispo County, including all offices, depart-y i
ments, and agencies thereof and all employees, contractors, con-
"i sultants or agents thereof.
4 6.
" County Plan" when used herein refers to the San Luis I
Obispo County Nuclear Power Plant Emergency Response Plan (Draft, 5
May 1981), together with all procedures thereto and all revisions
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thereof.
2 7.
" California" or " State" when used herein refers to the State of California and all offices, depat. tents and organizations thereof, incle. ding without limitation the California Office of Emergency Services, OES"), and all employees, contractors, con-sultants or agents thereof.
8.
" State plan" when used herein refers to the State of California Nuclear Power Plant Emergency Response Plan (Revised March 1981), together with all procedures thereto and revisions thereof.
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" Documents" when used herein include, but are not limited to emergency plans and procedures, critiques or evalua-tions of emergency exercises or drills, construction plans 3
and specifications, papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writings, letters, telegrams, ailgrams, correspondence, notes and minutes of meet -
ings or of conversations or of phone calls, inter-office, intra-a corporate memoranda or written communications of any nature, intra-agency memoranda or written communications of any nature, a
recordings of conversations either in writing or upon any i
mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, analyses, assessments, surveys, evaluations, projections, hypo-a theses, formulas, designs, drawings, manuals, notebooks, work-sheets, contzacts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer 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 in..sy substantive way (including handwritten notations or other sub-stantive written or printed matter of any nature) from the original.
Request 1:
All documents in the possession, custody or control of FEMA which relate in any way to the NRC Staff request of November 3,
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1 1980, that FEMA evaluate the complicating factors for emergency response at California nuclear reactors, including Diablo Canyon, which might be caused by an, earthquake.
A copy of the Staff request is included as Exhibit A hereto.
Without limitation of the secoe of this request, documents within the scope of Request 1 include:
(a)
All correspondence between FEMA and PG&E, the Staff the County and/or the State related to the compli-cating effects of an earthquake on emergency pre-paredness at Diablo Canyon.
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(b)
All analyses, memoranda or other documents which predict or assess the damage or complications which t
might result in the County from an earthquake on either (i) the Hosgri Fault or (ii) on any other fault in or near the County.
Please supply separately stated answers for (i) and (ii).
With respect to faults other than the Hosgri, please identify each such fault considered by FEMA.
l (c)
All analyses of how or whether the County Plan and/or the State Plan deal with or compensate for the com-plicating effects of an earthquake.
(d)
All analyses or other documents which relate in any way to the report of Tera Corpe;ation entitled,
" Earthquake Emergency Planning at Diablo Canyon,"
submitted to PG&E by Tera on September 2, 1981.
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Request 2:
All documents in the possession, custody or control of FEMA which analyse, assess, or in any way relate to whether the County
- i Pla's and County preparedness pursuant to the County Plan satisfy
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each or any Planning Standard of 10 C.F.R.
S 50.47(b).
1 Request 3:
All documents in the possession, custody or control of FEMA which analyse, assess, or in any way relate to whether the State Plan and State preparedness pursuant to the State Plan satisfy I
each or any Planning Standard of 10 C.F.R. S 50.47(b).
Request 4:
All documents in the possession, custody or control of FEMA which relate in any way to the emergency preparedness exercise held on August 19, 1981 in San Lula Obispo County.
Without limitation of the scope of this request, documents within the scope of Request 4 includer (a)
All evaluations, assessments, memoranda, notes, critiques or other documents which assess the August 19 exercise.
(b)
All notes, photographs, memoranda or other documents which record or in any way relate to actions or events which occurred during the August 19 exercise.
(c)
All documents which assess or in any way relate to whether the scenario for the August 19 exercise was complete and adequate to test the emergency response capabilities of PG&E, the County, and the State.
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Request 5:
All documents related in any way to correspondence and/or conversations of FEMA personnel with NRC personnel concerning Diablo Canyon.
Request 6:
All documents in the possension, custody or control of FEMA which assess or relate in any way to energency preparedness trainirs, drills or exercises for Diablo Canyon other than the August 19 exercise.
Request 7:
All documents in the possession, custody or control of FEMA which relate in any way to the " findings and determinations" of FEMA for Diablo Canyon which are called for under 10 C.F.R. S 50.47 (a) (2), including drafts thereof.
Request 8:
All documents in tite possession, custody or co1 trol of FEMA i
which relate in any way to FEMA's methodology for making the
" findings and determinations" called for under 10 C.F.R. S 50.47 (a) (2).
Without limitation of the scope of this request, documents within the scope of Request 8 include:
(a)
Manuals which guide FEMA reviewers.
(b)
Checklists for assessing exercises and drills.
(c)
Analyses of the Planning Standards of 10 C.F.R.
S 50.47(b),
(d)
Criteria for determining when the Section 50.47(b)
Standards are satisfied.
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s Request 9:
All documents not produced in response to Requests 1-8 which relate in any way to emergancy planning and preparedness I"
at Diablo Canyon.
Respectfully submitted, Byron S. Georgiou, Esq.
Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814
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Herbert H.
Brown 1
Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 4
Attorneys for Governor Brown of the 7
State of California September 25, 1981 k-s l
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I-UNITED STATES.
EXIIIBIT A 8
NUCi. EAR REGULATORY COMMISSION WA$mNGTON D.C.20$55
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MEMORANDUM FOR: John McConnell, Assistant Associtte Director for I
Population Preparedness FEMA FROM:
Brian K. Grimes, Program Director, Emergency Preparedness Program Office, NRR I
SUBJECT:
REQUEST FOR FEMA ASSISTANCE TO REVIEW EFFECTS OF EARTHQUAKE AND YOLCANIC ERUPTION ON STATE / LOCAL EMERGENCY PLANS As we have discussed, in the course of our review of licensed utility emergency I
plans, volcanic eruptions and catastrophic earthquakes have emerged as two I
issues of high public interest. To insure that these issues are being i
adequately addressed, we request that FEMA review the State and local planning efforts for the areas around California nuclear power plant sites and the Trojan site with respect to the complications which might arise in the event of extreme natural phenomena and how these u n best be addressed in the planning process.
In conjunction with the Trojan plant evaluation for compliance with the new'Np: emergency planning regulations, the Comission has directed that the,..oblems of effective protective, measures and evacuation. during or i
4 soon after volcanic eruption (giving due consideration to the possible effects of severe ashfall, mudflows, floods, and landslides) be closely i
examined..
In this regard, we are requesting the licensed utility to revise its emergency p1*.n to explicitly address the possible problems associated with an eruption. This will include considerations of site access during an emergency, assured comunications and appropriate revision of the evacuation time e.;timates used in protective action determinations. The Oregon State Department of Energy, has already addressed the fusibility of implementing effective protective measures during an eruption (enclosure 1).
The earthquake issue has particular relevance to nuclear plants in California (i.e., Diablo Canyon. Humboldt Bay, Rancho Seco and San Oncfre).
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We understand from the FEMA news release of September 29, 1980 that FEMA will lead a team consisting of personnel from Federal, State and local 3-agencies to accelerate efforts towards improving the state of readiness to cope with potential major earthquakes in California. "In this regard we request that FEMA include in its evaluation of offsite emergency plans.-
a qualitative evaluation of complicating factors which might be caused by earthquakes for California nuclear power reactor :;ites. Specifically, 1
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2-John McConnell such evaluation should include the impacts on State / local emergency plans due to potential disruption of communications networks and evacuation routes.
In this regard, we are requesting the affected licensees to revise their emergency plans to explicitly address the possible problems associated with an earthquake to include the type of potantial complicatiens discussed above for the Trojan facility.
Thank you for your assistance in these ratters.
N Brian K. Grimes; Program Director Emergency Preparchess Program Offict Office of Huclear Reactor Regulation
Enclosure:
Oregon DOE Study Report Measures e
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
)
l In the Matter of
)
j
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
)
50-323 o.L.
(Diablo Canyon Nuclear Power
)
Plant, Unit Nos. 1 and 2)
)
)
SUBPOENA DUCES TECUM 4
To:
San Luis Obispo County DQ:3zy Courthouse Annex 4
usyg,'
4 San Luis Obispo, California 93408 L-SEP23gOll6 T.
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L.'.\\'[ 9,' %nic, Attention:
Donald D. Stillwell 1
ounty Administrator a
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\\c) d You are b.__sby directed to produce for inspection >and copying the documents specified in the filing attached hereto entitled,
" Governor Edmund G. Brown Jr. Request for Production of Documents to San Luis Obispo County."
These documents shall be produced within 30 days of service of this subpoena.
If you oppose chis subpoena, you may move to quash or modify in accordance with 10 C.F.R. S 2.720(f).
l l
JOHN F. WOLF Presiding Officer l
September 1981 8
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