ML20031F290
| ML20031F290 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/14/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-OL, NUDOCS 8110190492 | |
| Download: ML20031F290 (14) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CO'MMISSION 00CgETED p
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '
11 OCT 15 PI59
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In the Matter of
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CFF!M OF SECRETtJ:?
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket bos'."50-275 O.L.
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50-323 (Diablo Canyon Nuclear Pc.rer
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Plant, Units 1 and 2)
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OCTJ g IO81h.
GOVERNOR EDMUND G. BROWN JR. SECOND SET OF
[_L INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION { 8.s.Cd.#d$ car DOCUMENTS TO THE NRC STAFF
,s h3 rn Pursuant to 10 C.F.R.
SS 2.720(h), 2.744, Governor
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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-corporate memoranda or written communications of any nature, intra-agency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical reccrding devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, analyses, assessments, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agree-h 0
8110190492 811014 4 0\\
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ments, 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 any substantive way (including handwritten nota-tions or other written or printed matter of any substantive nature) from the original.
2.
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 time of hearing.
3.
When asked to identify or describe a document, set forth the author's name, date of preparation, title, the subject matter of the document, to whom such document was sent, and the where-abouts of all copies.
4.
When an Interrogatory or Production Request seeks a document or infromation of or in the possession of the NRC Staff, that Interrogatory or Request includes all documents or informa-tion in the possession, custody or control of the Staff, including any of its contractors, employees, consultants, or agents.
5.
The " Staff Response" when used herein refers to the "NRC Response to Governor Edmund G. Brown, Jr.,'s First Set of Interrogatories and Second Request for Production of Documents,"
dated September 14, 1981.
1
e 6.
The " Joint Intervenors' Response" when used herein re-fers to the "NRC Response to Joint Intervenors' First Set of Interrogatories to the Nuclear Regulatory Commission Staff,"
'ated September 2, 1991.
d INTERROGATORY 1:
In the Staff Response, it is stated that the purpose of the Stafs December 16, 1980 letter to PG&E was to ensure that the Applicant's emergency plan had adequately taken into consideration the complications from an earthquake which are discussed in that letter.
A.
Is it the Staff position that Revision 3 of the PG&E Emergency Response Plan adequately takes into consider-ation the items discussed in the December 16, 1980 letter?
B.
What criteria has the Staff used to determine whether the Applicant's Emergency Response Plan or any other documents or materials of Applicant adequately take into consideration the items discussed in the December 16 letter?
C.
If it is the Staff position that Revision 3 to PG&E's Emergency Response Plan constitutes an adequate response to the NRC Staff's letter of December 16, 1980, provide the bases for that position, including citations to those portions of the plan which the Staff relies upon as providing adequately for the complicating effects of an earthquake.
Describe all documents which form a basis for or relate in any way to your answer to this Interrogatory 1.
D.
At page 12 of the Staff Response, the Staff states that it "is satisfied that PG&E has adequately addressed the complicating effects that an earthquake may pose in the event the Emergency Plan has to be implemented in response to a radiological emergency."
(1)
What is the basis for the foregoing statement?
(2)
What analyses has the Staff performed or is the Staff performing to reach the foregoing conclusion?
(3)
What criteria is the Staff utilizing to reach its conclusion?
INTERROGATORY 2:
At pages 2 and 3 of the Staff Response, it is indicated that Mr. John Sears spoke with PGGE and Tera Corporation employees on May 19, 1981 and September 11, 1981.
For each discussion, what was discussed and who initiated these conversations?
Did Mr. Sears make any notes of or in any way keep any record of these discussions?
If so, describe these notes or other documents.
INTERROGATORY 3:
Describe all analyses, reviews and other documents of the NRC Staff which relate in any way to the Tera Corporation analyses submitted by PG&E in early September 1981.
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INTERROGATORY 4:
In the Tera Report prepared for PG&E, the contractor assumes a maximum accele::ation at the plant of slightly under 0.5g.
This is significantly less than the 0.75g peak free field acceleration assumed for the SSE in the Diablo Canyon seismic proceeding.
A.
Does the Staff believe that accelerations up to the 0.75g postulated for the M 7.5 SSE should be assumed by PG&E in analyzing the complicating effects of an earthquake?
Provide the basis for your response.
B.
Does the Staff agree with the Tera selection of under 0.5g as the maximum acceleration to be postulated for the " severe" earthquake mentioned in the Staff's December 16, 1980 letter to PG&E7 Provide the basis for your response.
INTERROGATORY 5:
At page 4 of the Staff Response, the NRC Staff states that PG&E's Evacuation Time Assessment for Diablo Canyon Nuclear Power Plant is " satisfactory."
A.
What Staff analyses have been performed by or for the Staff regarding this evacuation time assessment and what is the basis for the Staff's position that this Applicant response is satisfactory?
B.
Describe all documents which relate in any way to the PG&E assessment.
INTERROGATORY 6:
i At page 4 of the Staff Response, the Staff states its position that the system for notifying persons in Montana de Oro State Park is satisfactory.
A.
What analyses have been performed of this system for notifying persons in that State Park?
B.
What is the basis for the Staff's position?
If the sole basis for the Staff's position is Section 7.2-2 of the PG&E Emergency Plan, please so state.
INTERROGATORY 7:
At page 5 of the Staff Response, the Staff states that it believes-that the location of PG&E's real time monitors is satisfactory.
A.
What is the basis for this Staff position and what analyses have been performed by or for the Staff?
Describe all documents which relate in any way to the location of the real time monitors.
B.
Has the Staff considered requiring more real time monitors outside of the plant boundaries, but inside the 6-mile low population zone?
Explain 'the rationale for your response.
INTERROGATORY _8:
At page 5 of the Staff Response, the Staff states that it believes the alternate evacuation route to the North through the Field Ranch is satisfactory.
A.
What is the basis for this position?
B.
What analyses have been performed by or for the Staff to reach this position?
C.
What criteria were applied by the Staff in deter-4 mining whether the alternative evacuation route is satisfactory?
l l
D.
Does the Staff contend that the northern evacuation route will be available for use in wet or rainy weather?
E.
Describe all documents which relate in any way to the northern evacuation route.
F.
Identify all Staff personnel who have traversed the entire northern evacuation route.
INTERROGATORY 9:
At page 5 of the Staff Response, the Staff states its posi-tion that "the provisions for communications and transport are satisfactory."
A.
What is the basis for this position?
B.
What analyses have been performed by or for the Staff to reach this position?
I_NTERROGATORY 10:
At page 7 of the Staff Response, the Staff takes the position that the PG&E criteria for guiding PG&E employees regarding when to recommend evacuation versus sheltering are satisfactory.
A.
What is the basis for this Staff position?
3.
What analyses have been performed by or for the Stsff regarding this position?
C.
In the event of a M 7.5 earthquake on the Hosgri fault, does the Staff believe that sheltering will continue to
be a viable protective action throughout San Luis Obispo County?
Explain the basis for your position.
INTERROGATORY ll:
At page 7 of the Staff Response, the Staf f makes the following statement:
The NRC Staff position is that the public information program is satisfactory, the Staff will review, with FEMA, a draft of the public information material and that distribution of the material will be made prior to issuance o'-
a full power license.
6 A.
What is the basis for the Staff position that the public information program is satisfactory?
B.
What Staff review was made of the public information program prior to providing the above quotation in the Staff Response?
C.
What documents were reviewed or available to the Staff prior to making the above quoted statement in the Staff Response?
INTERROGATORY 12:
Attached to the Staff Response was a May 18, 1981 Memorandum from Mr. William J. Dircks to J. C. Mark, Chairman of the Advisory Committee on Reactor Safeguards.
At page 2 of that Memorandum, the following statement is made:
We have concluded that additional requirements, such as tue design of additional facilities, structures, and systems to specifically withstand earthquckes are not necessary.
In particular, no special seismic design of public notification systems, environmental monitoring capabilities or communicationc equipment is contemplated.
A seismic event coincident with a significant accident at the plant is a very low likelihood.
In addition, moderate seismic events would likely create a scan-ario in which events slowly develop prior to the occurrence of a radioactive release.
Sufficient time would be available for existing backup or alternate means of notification and monitoring to be effective.
(emphasis supplied).
A.
Provido all analyses and documents which provide the basis for or support the foregoing statement, including, in particular, those portions which are emphasized.
B.
Identify all Staff members who worked on, contributed to, or otherwise participated in the foregoing state-ment.
i C.
Provide any analyses or other documents which relate
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the foregoing statement to the site-specific conditions and projected events at Diablo Canyon.
D.
Has the Staff calculated the likelihood, i.e.,
probability, of a significant accident at Diablo 1
Canyon (or any other plant) coincident with a seismic I
event?
If so, describe and produce such calculations.
INTERROGATORY 13:
In the Dircks Memorandum quoted in the preceding Interrogatory, reference is made to a March 16, 1981 ACRS Memorandum.
A.
Provide a copy of the March 16, 1981 ACRS Memorandum.
B.
Provide copies of all other correspondence and other I
documents by or between the ACRS and the Staff concern-l ing emergency planning at nuclear facilities during and L
after natural events.
INTERROGATORY 14:
-At page 8 of the Staff Response,.it is stated that the draft NRC inspection report (presumably that for the August 19, 1981 l
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exercise) was in the process of being finalized.
4 A.
Describe that inspection report and its conclusions.
B.
Produce that document for inspection and copying.
INTERROGATORY 15:
At page 17 cf the Staff Response, the Staff states that the UHF and VHF radio systems at Diablo Canyon "would be expected to be operational for the OBE and SSE."
A.
What is the basis for the foregoing Staff statement?
B.
What analyses have been prepared by or for the Staff to support this statenent?
INTERROGATORY 16:
At page 24 of the Staff Response, the Staff states that the TSC, OSC, and interim EOF meet the " intent" of the guidance of NUREG-0696.
A.
By the foregoing response, does this mean that the Staff does not take the position that the foregoing facilities meet the reliability requirements of NUREG-06967 B.
What is meant by " intent"?
INTERROGAT RY 17:
At page 24 of the Staff Response, the Staff states that the EOF and UDAC may not remain fully functional during an earthquake.
The Staff goes on to note, however, that the assessment and com-munications functions will be performed at the TSC or the control
- room.
_11_
A.
How would assessment and communications functions by and with the County be accomplished in the event that the EOF and UDAC were not available?
9.
Describe the analyses and other documents which docu-ment that assessment and communications functions would still be accomplished in the event that these facilities were not available?
INTERROGATORY 18:
.'.t page 24 of the Staff Response, the Staff takes the position that the interim EOF does not need to be meet the criteria of NUREG-0696 of being "well engineered for the design life of the plant."
A.
What is the basis for this Staff position?
B.
What analyses have been performed to ensure that the interim EOF is in fact adequate?
INTERROGATORY 19:
At page 25 of the Staff Response, the Staff states that it is its position that the emergency procedures for Diablo Canyon are adequate to respond to an emergency.
4 A.
Describe all analyses which have been per' formed by or for the NRC Staff on the PG&E emergency procedures.
B.
What is the basis for the Staff's position?
INTERROGATORY 20:
At page 5 of the Joint Intervenors' Response, the Staff indicates that the Staff's final conclusions on Diablo Canyon
emergency preparedness would be set forth in SER Supp. 15.
They were not.
A.
Which SER Supplement will contain the Staff's final conclusions?
B.
When does the Staff intend to publish this Supplement?
INTERROGATORY 21:
At page 7 of the Joint Intervenors' Response, the Staff states that it does comply with Section 50.47 of the NRC Regula-tions.
A.
What is the basis for this Staff position?
B.
What analyses or other documents provide the basis for l
this Staff position?
INTERROGATORY 22:
l l
At pages 12 and 13 of the Joint Intervenors' Response, the Staff sets forth generally its position on how emergency plans should compensate for the potentially complicating effects of an l
As pointed out by the Staff, it is possible that an earthquake might occur which does not cause or occur simultaneously with an accident and radiological release at Diablo Canyon, but rather does interfere with elements of emergency planning and preparedness, for example, communications systems and/or evacuation routes.
A.
In the evena an earthquake occurs which disrupts communications and/or evacuation and transportation facilities, does the Staff believe that the plant should be shut down until there is restoration of communication and transportation facilitics?
B.
Please explain the basis for your position and describe any documents relating thereto.
INTERROGATORY 23:
At page 12 of the Joint Intervenors' Response, the Staff states that an Applicant should assume "that the plant will experience earthquake effects of the type normally experienced in the geographical region where the plant is situated."
A.
Does the Staff believe that faults other than the Hosgri fault (for example, the Rinconada fault) should be examined since it is in the same geographical re-gion where the plant is located?
B.
Provide the basis for the Staff's position.
C.
If the Staff does believe other faults should be analyzed, which are they and what accelerations does the Staff predict from such other faults?
INTERROGATORY 24:
At page 23 of the Joint Intervenors' Response, the Staff states that a decision to order evacuation or sheltering will be made "before any release of radioactivity occurs.
A.
What is the basis for the foregoing statement?
B.
Describe all analyses or other documents which address this matter.
INTERROGATORY 25:
Does the Staff agree that the Diablo Canyon pressurizer heaters and related structures, instruments, systems and power sources are properly classified as non-safety grade?
Provide the
o
_14-basis for your position and describe all documents which relate in any way to the classification question.
INTERROGATORY 26:
Does the Staff believe that the pressurizer heaters and related structures, instruments, systems and power sources should be seismically and environmentally qualified?
Provide the basis for your response and a description of all documents relating to the qualification question.
INTERROGATORY 27:
The power operated relief valves and block valves at Diablo Canyon are not classified as safety grade.
Does the Staff agree that these items (as well as related structures, controls, instru-ments and power sources) need not be classified as safety grade?
What analyses, if any, have been conducted to support such classi-fication as non-safety grade?
Describe all such analyses and all other documents relating to the question of the classification of block and relief valves.
DOCUMENT PRODUCTION REQUEST Produce all documents requested, identified or described in response to the foregoing Interrogatories.
Byron S. Georgiou Legal Affairs Secretary Governor's Office Sacramento, California 95814 7
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Herbert H. Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 i
Attorneys for Governor Brown of the October 14, 1981 State of California