ML20031G550
| ML20031G550 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/21/1981 |
| From: | Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| References | |
| NUDOCS 8110230214 | |
| Download: ML20031G550 (7) | |
Text
10/21/81 i
N' k 8[h [(h UNITED STATES OF AtiERICA
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I NUCLEAR REGULATORY COMMISSION lc']' uOCTeg 193;g
-u h-n BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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50-275 0..GQ k U f In t:ie fiatter of
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Docket Nos.
PACIFIC GAS AND ELECTRIC COMPANY
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50-323 0.L.
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(Diablo Canyon Nuclear Powe Plant )
Unit Nos. I and 2)
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NRC STAFF'S REQUEST FOR ADMISSIONS BY JOINT INTERVEN0RS The NRC Staff hereby requests Joint Intervenors, pursuant to 10 C.F.R.
62.742 and in accordance with the Atomic Safety and Licensing Board's M the truth of the Memorandum and Order of August 4, 1981, to admit following relevant matters of fact within 15 days after service of this request:
That each of the following numbered statements is true.
1.
The August 19, 1981 emergency planning exercise conducted in the vicinity of Diablo Canyon Nuclear Power Plant (DCNPP) complied with 10 CFR 550.47(b), Appendix E to Part 50, and applicable planning standards and evaluation criteria in NUREG-0654.
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10 C.F.R. %2.742(b) provides, in pertinent part, that "[e]ach requested admission shall be deemed made unless... the party to whom the request is directed serves on the requesting party... a sworn statement denying specifically the relevant matters of which an admission is requested or setting forth in detail the reasons why he can neither truthfully admit nor deny them."
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Applicant's public information program for emergency planning and preparedness as described in Sec. 8.1.2.3 of the Emergency Plan (EP) Rev. 3, August 1981, for the DCNPP, and in its interrogatory responses in " Applicant Pacific Gas and Electric Company's Answers to Governor Edmund G. Brown, Jr.'s First Set of Interrogatories and " Applicant Pacific Gas and Electric Company's Joint Intervenors' First Set of Interrogatories" (SIC), ( Applicant's Responses) when implemented, will comply with 10 CFR 950.47(b)(7), Appendix E to Part 50, and applicable NUREG-0654 planning standards and evaluation criteria.
3.
Applicant and local plans described in Applicant's EP, Section 6.3.4, Applicant's Responses, and San Luis Obispo County Nuclear Power Plant Emergency Response Plan (County Plan),
Section I.6.E,11.5.(1) Standard Yearly Procedures, pertaining and applicable to notification of the public, comply with 10 CFR 550.47(b), Appendix E to Part 50, and applicable planning standards and evaluation criteria of NUREG-0654.
4.
Applicant, and off-site plans to provide emergency notification and information to transient persons in Ibntana de Oro State Park and elsewhere in the plume exposure pathway EPZ for Diablo Canyon Nuclear Power Plant designated in Appli-cant's draft Emergency Plan for Diablo Canyon Nuclear Power Plant, Revision 3 comply with 10 CFR 50.47(b); Appendix E to Part 50; and the applicable Planning Standards and Evaluations Criteria in NUREG-0654.
. a 5.
Each agency represented in the San Luis Obispo County Emergency Operations Center (E0C) established during the August 19, 1981 emergency planning exercises conducted in the vicinity of the Diablo Canyon Nuclear Power Plant (DCNPP) denonstrated the capability of controlling access on traffic routes and performing a coordinated evacuation procedure, including the closure and evacuation of the two State parks within the 10 mile EPZ.
6.
As a result of the energency response plans drafted by Applicant, the State of California,.and San Luis Obispo County, a coordinated standard emergency classification and action level scheme is, or will soon be, in use by the Applicant, State and County in accordance with 10 CFR 650.47(b)(4).
7.
The latest draft (August 1981) of Applicant and County plans and procedures for providing proept notification of the public in the event of a radiological emergency at DCNPP comply, or will comply when implemented, with 10 CFR 550.47(b), Appendix E to Part 50, and applicable planning standards and evaluation criteria of NUREG-0654.
8.
The Statt of California Emergency Plan (" State Plan") for the Diablo Canyon Nuclear Power Plant, as currently revised, meet.
the requirements of 10 C.F.R. 950.47, and Appendix E to Part 50.
9.
Any necessary revisions to the State Plan to include in procedures provided for in 10 CFR 50.47, Appendix E of Part 50,
. i and NUREG-0654 Planning Standards and Evaluation Criteria, plans and procedures taking account of the complicating effects of an earthquake will be completed by January 1,1982.
- 10. The State Plan is presently, or by January 1,1982, will be, fully in+.egrated into the onsite and local offsite emergency response plans for DCNPP.
- 11. The draft procedures for San Luis Obispo County Nuclear Power Plant Emargency Response Plan identified in item 30 of Governor Edmund G. Brown, Jr.
Response to NRC Staff Document Request, page 2 of " Documents Available for Inspection and Copying," when taken together with the draft San Luis Obispo County Nuclear Power Plant Plan itself, comply with 10 CFR 550.47(b), Appendix E to Part 50, and the planning standards and evaluation criteria of NUREG-0654.
- 12. The plume exposure pathway EPZ's and ingestion pathway EPZ's adopted in Applicant's EP (Section 7.2.2.3, Figure 7.2-2 and County's ERP,Section I.5, and Attachment I.5-3), comply with 10 C.F.R. 950.47(c), 650.33(g), Appendix E to Part 50, and applicable planning standards and evaluation criteria of NUREG-0654.
- 13. Applicant's Revision 3 of the Emergency Plan for DCNPP, August 1981, incorporates provisions for the complicating effects of earthquakes so as to comply with 10 CFR 550.47(b), Appendix E to Part 50, and applicable planning standards and evaluation criteria in NUREG-0654.
5-14 Applicant's Revision 3 of the Emergency Plan for DCNPP, August 1981, together with descriptions included in Applicant's responses to interrogatories 22 and 23 of Joint Intervenors' First Set of Interrogatories provide criteria for choice among recommended protective actions in compliance with 10 CFR 550.47(b), Appendix E to Part 50, and applicable planning standards and evaluation criteria of NUREG-0654.
- 15. Applicant's " Evacuation Time Assessment for the Diablo Canyon Nuclear Power Plant" dated September 1980, complies with applicable provisions of 10 CFR 650.47(b), and the planning standards and evaluation criteria of NUREG-0554.
- 16. The Diablo Canyon Earthquake Response Plan prepared by Tera Corporation for the Applicant, where integrated with the State of California Earthquake Response Plan, the County Plan, and Applicants Emergency Plan, will adequately take into account the complicating effects of an earthquake which may be required to be considered in complying with 10 CFR 550.47(b),
and the planning standards and evaluation criteria of NUREG-0654.
Respectfully submitted, l
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William J. Olmstead Deputy Chief Hearing Counsel Dated at Bethesda, Maryland this 21st day of October, 1981.
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f UNITED STATES OF A". ERICA NUCLEAR REGULA10RY 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 Unit Nos. 1 and 2 CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF'S REQUEST FOR ADMISSIONS BY JOINT INTERVENORS in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 21st day of October, 1981.
John F. Wolf, Esq., Chairman Richard E. Blankenburg Administrative Judge Co-publisher Atomic Safety and Licensing Board Wayr.e 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 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C.
20555
- Dr. Jerry Kline Mr. Gordon Silver Administrative Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Commission San Luis Obispo, California 93401 Washington, D.C.
20555
- Arthur C. Gehr. Esq.
Elizabeth Apfelberg Snell & Wilmer 1415 Cozadero 3100 Valley Center San Luis Obispo, California 9340-Phoenix, Arizona 95073 Philip A. Crane, Jr., Esq.
Paul C.' Valentine, Esq.
Pacific Gas and Electric Company 321 Lytton Avenue P.O. Box 7442 San Francisco, California _94120~~
Palo Alto, California 94302 Bruce Norton, Esq.
Mr. Frederick Eissler 3216 North 3rd Street Scenic Shoreline Preservation Suite 202 Conference, Inc..
Phoenix, Arizona 85012 4623 Morg Mesa Drive Santa Barbara, California 93105 AndrewBald$in,Esq.
124 Spear Street Mrs. Raye Fleming San Francisco, California 94105 1920 Mattie Road Shell Beach, California 93449 1
John R. Phillips, Esq.
Atomic Safety and Licensing Appeal Simon Klevansky, Esq.
Panel l'argaret Blodgett, Esq.
U.S. Iluclear Regulatory Commission Marion P. Johnston, Esq.
Washington, D.C.
20555
- Joel Reynolds, Esq.
Center for Law in the Public Atomic Safety and Licensing Board Interest Panel 10203 Santa Monica Isoulevard U.S. Nuclear Regulatory Commission Los Angeles, California 90067 Washington, D.C.
20555 *
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Byron S. Georgiou Docketing and Service Section Legal Affairs Secretary U.S. Nuclear Regulatory Commission Governor's Office Washington, D.C.
20555
- State Capitol Sacramento, California -95814 Mark Gottlieb California Energy Conmission David S. Fleischaker, Esq.
MS-18 P.O. Box 1178.
1111 Howe Avenue Ok1ahoma_ City,.Ollahoma 73101 Sacramento, California 95825 i
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 l
Harry M. Willis Seymour & Willis 601 California St., Suite 2100 l
San Francisco, California 94108 Janice E. Kerr, Esq.
Lawrence Q. Carcia, Esq.
350 McAllister Street l
San Francisco, California 94102 8
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Q Mr. James 0. Schuyler WifilamJ.
1mstead Nuclear Projects Engineer Deputy Chief Hearing Counsel i
Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 l
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