ML20031G552

Request for Admissions of Listed Statements.Certificate of Svc Encl

ML20031G552
Person / Time
Site:	Diablo Canyon
Issue date:	10/21/1981
From:	Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	CALIFORNIA, STATE OF
References
ISSUANCES-OL, NUDOCS 8110230223
Download: ML20031G552 (7)

Text

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10/21/81 cl [

UNITED STATES OF NiERICA

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In the Matter of

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Docket Nos. 50-275 0.L.

PACIFIC GAS AND ELECTRIC COMPANY 50-323 0.L.

(Diablo Canyon Nuclear Power Plant )

Unit Nos. I and 2)

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NRC STAFF'S REQUEST FOR ADMISSIONS BY GOVERNOR EDMUND G. BROWN, JR.

The NRC Staff hereby requests Governor Brown, pursuant to 10 C.F.R.

Q2.742 and in accordance with the Atomic Safety and Lbnsing Board's 1/ 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 G50.47(b), Appendix E to Part E0, and applicable planning standards and evaluation criteria in NUREG-0654.

1/

10 C.F.R. 92.742(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."

DESIGNATED ORIGINAL Of[0 D

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2.

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 il " Applicant Pacific Gas and Electric Company's Answers to Governor Edmund G. Brown, Jr.'s First Set of Interrogatories and " Applicant Pacific Gas ana 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 tLa public, comply with 10 CFR 950.47(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 Montana 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.

3-s 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) demonstrated 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 emergency 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 950.47(b)(4).

7.

The latest draft (August 1981) of Applicant and County plans and procedures for providing prompt notification of the public in the event of a radiological emergency at DCNPP comply, or will comply when implemented, with 10 CFR 950.47(b), Appendix E to Part 50, and applicable planning standards arm evaluation criteria of NUREG-0654.

8.

The State of California Emergency Plan (" State Plan") for the Diablo Canyon Nuclear Power Plant, as currently revised, meets 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 prouadures provided for in 10 CFR 50.47, Appendix E of Part 50, t

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. s and NUREG-0 sea 'lanning Standards and Evaluation Criteria, plans and procedures taking account of the complicating i ffects of an earthquake will be completed by January 1,1982.

10. The State Plan is presently, or by Jar.uary 1,1982, will be, fully integrated into the onsite and local offsite emergency response plans for DCNPP.

11. The draft procedures for San Luis Obispo County Nuclear power Plant Emergency 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 950.47(b), Appendix E to Part 50, and the planning standards and evaluation criteria of NUREG-0654.

12. The plune 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. 550.47(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 aoplicable planning standards and evaluation criteria in NUREG-0654.

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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, canplies with applicable provisions of 10 CFR 950.47(b), and the planning standards and evaluation criteria of NUREG-0654.

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 earthoce:e which may be required to be considered in complying with 10 CFR Q50.47(b),

and the planning standards and evaluation criteria of NUREG-0654.

Respectfully submitted, M

William J. O mstead Deputy Chief Hearing Counsel Dated at Bethesda, Maryland this 21st day of October, 1981.

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UNITED STATES OF A" ERICA NUCLE.^.P RE6ULATORY CO:GISSION 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 OMISSIONS.BY GOVERNOR EDMUND G. BROWN, JR. 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 Regulctory Commission's internal mail system, this 21st day of October, 1981.

John F. Wolf, Esq., Chair...an 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 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 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 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 San Francisco, California 94120__,

Palo Alto, California 94302 Bruce No-ton, Esq.

Mr. Frederick Eissler 3216 Nor-3rd Street Scenic Shoreline Preservation Suite 20c Conference, Inc..

Phoenix,,. zona 85012 4623 More 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

John R. Phillips, Esq.

Atomic Safety and Licensing Appeal Simon Klevansky, Esq.

Panel 4

Margaret Blodgett, Esq.

U.S. fluclear 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 Boulevard 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 9E814 Mark Gottlieb California Energy Commission David S. Fleischaker, Esq.

MS-18 P.O. Box 1178 1111 Howe Avenue Ok.lahoma_ City, Oklahoma 73101 Sacramento, California 95825 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jote, 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 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 y

i Mr. James 0. Schuyler William J. Olmstead Nuclear Projects Engineer s

Deputy Chief Hearing Counsel Pacific Gas and Electric Company 77 Beale Street l

San Francisco, California 94106 l

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