ML20031H034
| ML20031H034 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/28/1981 |
| From: | Wolf J Atomic Safety and Licensing Board Panel |
| To: | Stillwell D SAN LUIS OBISPO, CA |
| Shared Package | |
| ML20031H027 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8110270074 | |
| Download: ML20031H034 (2) | |
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.l-o Huitch 9tates af Ameria RELATED CORRESPONDENCE NUCLEAR REGULATORY COMMIS.ci.ON l
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0 In the matter of:
PACIFIC GAS AND ELECTRIC COMPANY
>- DOCKET NO. 50-2750:0'.L.
(Diablo Canyon Nuclear Power Plant, Unit Nos. 1 and 2) 50-323 0.L.
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N POCKETED SUBP0ENA DUCES TECUM 4
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San Luis Obispo County OCT I19 i98\\
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Attention: Donald D. Stillwell b
County Administrator cn You are hereby directed to produce for inspection and copying the document's specified in tb-filing attached hereto entitled, " Governor Edmund G. BrowneJr.
Recuest for Production of Documents to San Luis Obispo County." These documents shall be produced within 30 days of service of this subpoe 3.
By Order of the. Atomic Safety and Licensing Board
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By 8110270074 811016 h
PDR ADOCK 05000275 G
PDR September 28, 1981
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Attorney for " Governor Brown of the State of California" Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 (202)452-7011 10 C.F.R. 2.720 (f) prestsing officer or, if he is u sveiraste. the On onorion made promptly, and in any event Commt sfon may (1) quash or modify the sub-at or tefere the time specified in the ssshpcena pcena if it is nonreason:ble or requires erfdence for cornpliance by the person to whom the sub-not refer:nt to any rn.rtscr in issue, or (2) con-pot'se is t!irected. and on notice to the party at dition der.ial of the motiors on just snd recs 3nable u+.ose instener the subpoen2..as issued, the terans.
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. RETURN ON SERVICE Received this subpoena at......S.an..Luis...Ohisp.o...CA...........................on Oc.tober.. 6.,..1.9.81.....and onoc.tober.. 6.,.19.ad...... 2.:.15...p.,m.......'...........
served it on the within named.D.Q'NALD...S.TJLLELL.,....thK9. ugh..h13...4.ca.ig-d ace No aJ nat8cliverm,;;nt,copyTo h m. Hodend'enng tbyh.of Bo 5d er Sec me 1 e f8r one usy sf Supervisors oy a
i an i.m attendance and the mileage allowed by law.1 Dated.. October 6,......... 3 9.81'....
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DIANE GRIFFJN Service Fees Tra vel...................... S Services................ S
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Notary Subscribed and sworn to before me, a.?phl19........this....#.th..............
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(j ft 19 y ~5tUlu!.ituk NOTE - Affidasit required on!y if smice i a person ot er than a United States Marshal or his deputy.
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] Fees and miscage need not be tendered to the uitness ugon serace of a sutrorna issued in te!.atf of the Unl:ed States or en offcer or agency thereof.
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UNITED STATES OF AliERICA r;nRO NUCLEAR REGULATORY COMMISSION 6-3)
OCT. A 919M
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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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 FOR PRODUCTION OF DOCUMENTS TO SAN LUIS OBISPO COUNTY Governor Brown hereby requests San Luis Obispo County to produce for inspection and copying the documents described below.
The documents shall be produced at the County's adminis-trative offices within 30 days of service of this request, unless another time or location is mutually agreed upon.
Definitions 1.
" San Luis Obispo County" or " County" when used herein refers to San Luis Obispo County, including all offic6s, depart-ments, and agencies thereof and all employees, contractors [in-cluding, without limitation, PRC Voorhees], consultants or agents thereof.
2.
" County Plan" when used herein refers to the San Luis Obispo County Nuclear Power Plant Emergency Response Plan (Draft, May 1981), tcgether with all proce<1ures thereto and all revisions thereof.
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" FEMA" when used herein refers to the Federal Emergency Management Agency, including FEMA Region IX, the Regional Assistance Committees, and all employees, contractors, consultants
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or agents of FEMA.
4.
"PG&E" when used herein refers to Pacific Gas and Electric Company and all employees, contractors, consultants or agents of PG&E.
5.
"NRC" or "NRC Staff" or " Staff" when used herein refers to the United States Nuclear Regulatory Commission, including all regional offices and all staff, employees, contractors, con-sultants or agents thereof.
6.
"Diablo Canyon" when used herein refers to the Diablo Canyon Nuclear Power Plant located in tan Luis Obispo County, California.
7.
" California" or " State" when used herein refers to the State of California and all offices, departments and organizations thereof, including 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 s
i California Nuclear Power Plant Emergency Response Plan (Revised March 1981), together with all procedures thereto and revisions thereof.
i 9.
" Documents" when used herein include, but are not i
limited to emergency plans and procedures, critiques or evalua-tions of emergency exercises or drills, construction plans and specifications, papers, photographs, criterie, standards of review, e
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c.,.
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recordings, memoranda, books, records, writings, letters, tele-grams, mailgrams, correspondence, notes and minutes of meetings d
or of conversations or of phone calls, inter-office, intra-corportte memoranda or written communications of any aature, intra-agency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, neudies, opinions, analyses, assessments, eurveys, evaluations, projections, hypo-theses, formulas, designs, drawings, manuals, notebooks, work-sheets, contracts, 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 tha foregoing which differ in any substantive way (including handwritten notations or other sub-stantive written or printta matter of any nature) from the original.
t Please produce the following documents:
Request 1:
The County Plan and all drafts thereof and revisions thereto.
Request 2:
All documents in the possession, custody or control of the County which relate in any way to training of County personnel to respond to the effects of a radiological emergency at Diablo Canyon.
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4-Request 3:
All documents in the possession, custody or control of the County which relate in any way to the adoption of the County Plan by the Board of Suoervisors including, without limitation, any status reports or similar documents regarding the progress of action)s necessary to conplete and fully imple-ment the County Plan.
Request 4:
All documents in the possession, custody or control of the County which analyse or relate in any way to the complicating effects of an earthquake on County emergency preparedness.
Without limitation of the scope of this request, documents within the scope of Request 4 include:
(a)
All correspondence between the County and FEMA, PG&E, the Staff, and/or the State related to the complicating effects of an earthquake on emergency preparedn'ess at Diablo Canyon.
(b)
All analyses, memoranda or other documents which predict or assess the damage or complications which 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 ' o f aults other than the Hosgri, please t
identify each such fault considered by the County.
(c)
All analyses of how or whether the County Plan deals with or compensat,es for the complicating effects of an earthquake.
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(d)
All analyses or other documents which relate in any way co the. report of Tera Corporation entitled,
" Earthquake Emergency Planning at.Diablo Canyon,"
submitted to PG&E Ly Tera on September 2, 1981.
Request 5:
All documents in the possession, custody or control of the County voich relate in any way to the emergency preparedness exercise held on August 19, 1981 in San Luis Obispo County.
Without limitation of the scope of this request, documents with-in the scope of Request 5 include:
(a)
All evaluations, assessments, memoranda, notes, critiques or other documents which assess, or in any way relate to the August 19 exercise.
(b)
All notes, photographs, memoranda, or other documents which record or relate in any way to actions or events which occurred during the August 19 exercise.
(c)
All documents which assess or in nay 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/or the State.
Request 6:
All documents in the possession, custody or control of the County which assess or relate in any way to emergency prepared-ness drills or exercises for Diablo Canyon other than the August 19 exercise.
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I J., sp.r.,* s Request 7:
All documents in the' possession, custoly or control of the County which analyse, assess, or in any way relate to whether the County Plan and County preparedness pursuant to the County Plan satisfy each or any Planning Standard of 10 C.F.R.
S 50.47(b).
Request 8:
All contracts or other documents in the possession, custody o'r control of the County which relate in any way to devalopment and implementation of County preparedness for a Diablo Canyon emergency.
Request 9:
All documents not produced in response to Requests 1-8 which relate in any way to emergency planning and pr.eparedness at Diablo Canyon.
Respectfully submitted, Byrons S.
Georgiou, Esq.
Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814
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M Herbart H. Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND FHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Attorneys for Governor Brown of the State of California September 25, 1981 i
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