ML20032A081
| ML20032A081 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/22/1981 |
| From: | Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8110280267 | |
| Download: ML20032A081 (11) | |
Text
m h RC UNITED ' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYANDLICENSINGBf..._.O RD' 0FFICE OF SECRETARY C0CXETmG & SERVICE ERANCH
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 O.L.
)
50-323 O.L..
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
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O/A y THIRD SET OF INTERROGATORIES k%,h%,
JOINT INTERVENORS' AND REQUEST FOR PRODUCTION OF DOCUMENTS ~)s
_g TO PACIFIC GAS AND ELECTRIC COMPANY D
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I.
Interrogatories Please use the same instructions as those given in Joint Intervenors' first set of interrogatories to Pacific Gas and
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Electric Company ("PGandE" or " Applicant").
69.
For each of the components, systems, or facilities listed below, state whether you contend that it has been seismically qualified to withstand and continue to function in the event of a 7.5 magnitude earthquake on the Hosgri Fault, and state i
each and every fact upon which your response is based.
Include in your response a description of all qualification tests performed, the date of such tests, the persons or entities conducting the tests, and any modifications to the 95d J 8110280267 811022 PDR ADOCK 05000275
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component, system, or facility tested which were mad.? as a
. result of such testing.
(a)_ Early Warning System sirens (and related compressors and compressor platforms) located within the Diablo Canyon plume exposure pathway EPZ; (b)
PGandE telecommunications equipment racks, battery racks, antennae, and supports; (c) mountai.ntap PGandE Private Microwave System repeaters; (d) mountaintop UHF and VHF Radio System repeaters located at Davis Peak, Tepusquet Peak, and Tassajera-Peak; (e)
Emergency Broadcast System radio transmission towers; (f)
Early Warning System transmitters (located at Davis Peak, Rocky Butte, Cuesta Peak, Morro Bay, San Luis Obispo, and Pismo Beach) and encoders (located at the San Luis Sheriff's Office and the California Department of Forestry);
(g) offsite Emergency Operations Facility and associated cables, wiring, and equipment; (h)
San Luis Obispo County Emergency Operations Center and i
associated cables, tiring, and equipment; (i) onsite Technical ' 2pport Center and associated cables, wiring and equipment; (j) radiological monitoring stations (k)
PGandE onsite neteorological tower and associated cables, wiring, and equipment.
(1)
UDAC and assoc.iated cables, wiring, and equipment. __.
70.
With respect to each of the components, systems, or facilities listed in Interrogatory No. 69, s' tate whethor you contend that such component, system, or facility need not be seismically qualified to withstand and continue to function in the event of a 7.5 magnitud? earthquake on the Hosgri Fault,'and state each and every fact upon which your response is based.
71.
List each and every agreerent and/or contract between PGandE and any third party for the provision by such third party of services, assistance, workers, equipment, and/or vehicles for the repair of damage resulting from an earthquake on the Hosgri Fault which acompanies a radiological emergency at Diablo Canyon, and specify precisely:
(a) whether the agreement and/or contract is formal or informal; (b) the party or entity committing to provide such services, assistance, workers, equipment, or vehicles; (c) the substance of such agreement and/or contract; (d) the type and number of services, assistance, workers, equipment, or vehicles agreed to be provided; (d) whether such agreement and/or contract specifically provides for the provision of such services, assistance, workers, equipment, or vehicles when there is a risk of radiation exposure to such workers, equipment, or vehicles; (f) the address of the party or entity committing to provide services, assistance, workers, equipment, or vehicles,
and the location of such equipment or vehicles.
72.
At section 6 of the TERA Corporation Report entitled
" Earthquake Emergency Planning at Diablo Canyon," a number of "special tasks that might have to be performed following a major earthquake and radiological emergency" are identified.
Included among these tasks are (a) damage reconnaissance; (b) emergency repair and/or restoration of. key transportation routes; (c) clearing debris from key transpartation routes; (d) coordination with_ law enforcement agencies for barricading of certain areas; (d) procurement and allocation of transportation resources; (f) traffic control; and (g) evaluation and determination of protective actions to be taken by nonessential PGandE employees and by the public.
As to each of these individual tasks in the event of a 7.5 magnitude earthquake on the Hosgri Fault, state precisely (1) how many persons.would be needed to perform the specified task; (2) how many PGandE employees would be available to perform the specified task; (3) how many County or State personnel would be available to perform the specified task; i
(4) how many other persons would be available to perform the specified task; <-
e (5) a list of any <nd all agreements and/or contracts in which specific comitments have been made to supply personnel; (6)- every fact upon which your responses to subparts
_(1) through (5) of this interrogr. tory are aased,-
73.
State whether-you contend that'the TERA Corporation Report cited supra satisfies the NRC Staff's December 16, 1980 request that PGandE provide analyses of.the complicating effects of earthquakes on the Diablo Canyon emergency pl6ns, and state each fact upon which your response is based.
74.
Describe in detail the specific changes which will be made in PGandE's onsite emergency plan based on the information, findings, and recommendatios contained in the TERA Corporation Report cited supra.
75.
Do you contend that sheltering will, under certain circumstances, be a preferable protective action alternative to evacuation?
If so, state what those circumstances are and 2ach and every tact upon which your response is based.
List each and every study, report, and/or analysis which supports your conclucion.
76.
State where, if at all, in the evacuation times assessment prepared for Diablo Canyon and submitted by PGandE the estimates are adjusted for delays likely to result from "rr,ataneous evacuation" by persons other than those within a specified evacuation area.
77.
On pp. 26-27 of PGandE's Response to Joint Intervenors' first set af interrogatories ("PGandE Response"), PGandE's proposed -.. _ _ -
l public education program is outlined,.but no projectd
-implementation dates are specified.
For each element of the program,. state the current status of development and the-projected date for implementation.
78.
On p. 27 of the PGandE Response, you asse'rt that "all known residents within the 10-mile radius will be alerted and L
notified tiithin 15 minutes."
What is the basis for that' statement, and Lescribe in detail any and all tests of the Early Warning Siren System conducted to date which relate'to the statement quoted.
79.
On pp. 7-15 of the PGandE Response, you list numerous j
existing deficiencies of the applicant, State, and~ local emergency plans in compliance with the Commission's regulaticr.o.
In response to a question regarding what d.eficiencies will not be eliminated prior to full power.
j operation, you respond, at p. 16, "none."
What actions, if' f
any, are you taking now to ensure that those deficiencies will be eliminated prior to full power operation?
80.
On p. 32 of the PGandE Response, you note " meteorological condit ions as one of the factors to be considered when evalua -ing the protective action alternatives."
Assuming that the onsite meteorological tower is' totally disabled for any reason (including a major earthquake) during a radiological emergency, describe each and every alternative means for obtaining the necessary meteoroloogical information 81.
State (a) whether accelerations less than those postulated for the-Diablo Canyon SSE are utilized in the TERA Report for
]
the Diablo Canyon site.and (b) if so,fwhat is,the factual-basis'for the difference.
~
II.
Request for Production-of Documents Please.use the'same-instructions as those given-in Joint Intevenocs' second request for production of: documents!to PGandE, except that the date for. production :shall-be on or -before tiovember 20, 1^91, unless another time is agreed upon by the parties or'specified'by the-board.-
1.
All documents-identified in, relied upon, or relevant to the responses to Interrogatory Nos. 69-81 supra.
2.
All written communications between TERA Corporation and.
PGandE which relate to the TERA Report cited supra, s
Dated:. October 22, 1981 Respectfully submitted,.
JOEL R. REYNOLDS, ESO.
JOHN R. PHILLIPS, ESQ.
Center for Law in the Public Interest-10951 West Pico Blvd.
Los Angeles, CA 90064 (213) 470-3000 DAVID S. FLEISCHAKER, LSQ.
P. O. Box 1178 Oklahoma City,. Oklahoma 7 3101 By
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(JDEL R. EtYROLDS
)
Attorneys for. Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE -.
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1 3CENIC SHORELINE PRESERVATION 1-
-CONFERENCE, INC.
ECOLOGY ACTION CLUB i
SANDRA SILVER
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ELIZABETH APFELBERG JOHN J. FORSTER 4f' t.
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UNITED STATES OF M4 ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-27 5 O.L.
)
50-323 0.L.-
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)-
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 22th day of October,'1981, I have served copies of the foregoing JOINT INTERVENj J' THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY, mailing them through the G. S. mails, first class, postage prepaid.
Nunzio Pallodino, Peter A. Bradford, Chairman Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Victor Gilinsky, John F. Ahearne, Commissioner Commissioner U.S.. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W.
1717 ~ 3treet, N.W.
Washington, D.C.
20555 Washir 7n, D.C.
20555 Thomas Roberts, Commissioner i
U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
- Washington, D.C.
2055.5 L
Thomas S. Moore, William Olmstead, Esq.
Chairman Marc R. Staenberg, Esq.
Atomic Safety & Licensing Edward G. Ketchen, Esq.
Appeal Board Office of the Executive' Legal U.S. Nuclear Regulatory Director - BETH 042 Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Dr. W.
Reed Johnson Atomic Safety & Licensing Nancy Culver Appeal Board 192 Luneta U.S. Nuclear Regulatory San Luis Obispo, CA 93401 Commission Washington, D.C.
20555 Mr. Fredrick Eissler Scenic Shoreline Preservation
~
Dr. John H. Buck Conference, Inc.
Atomic Safety & Licensing 4623-Mere Mesa Drive Appeal Board Santa Barbara, CA 93105 U.S. Nuclear Regulatory Commission Sandra A.
Silver Washington, D.C.
20555 1760 Alisal Street San Luis Obispo, CA 93401 Admin. Judge John F. Wolf, Chairman Gordon Silver Atomic Safety & Licensing 1760 Alisal Street Board San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission David S.
Fleischaker,.Esq.
Washington, D.C.
20555 P. O. Box 1178 oklahoma' City, Oklahoma 73101 Glenn O. Bright Atomic Safety & Licensing Bruce Norton, Esq.
Board 3216 N.
Third Street U.S. Nuclear Regulatory Suite 202 Commission Phoenix, Arizona 85012 Washington, D.C.
20555 Mr. Yale I.
Jones, Esq.
Dr. Jerry R.
Kline 100 Van Ness Avenue Atomic Safety & Licensing 19th Floor Board San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Andrew Baldwin, Esq.
Washington, D.C.
20555 Friends of the Earth 124 Spear Street Docket & Service Branch San Francisco, CA 94105 i
Office of the Secretary U.S. Nuclear Regulatory Harry M. Willis, Esq.
Commission Seymour and Willis Washington, D.C.
20555 601 California Street Suite 2100 San Francisco, CA 941'08
' i
l rs. Raye Fleming Janice E. Kerr, Esq.
1920 Mattle Road Lawrence Q. Garcia, Esq.
Shell Beach, CA 93449 J. Calvin Simpson, Esq.
California Public Utilities MHB '2echnical Associates 1 23 Hamilton. Avenue 52 tat uilding 3ie 350 McAllister Street San Jose, CA 95125 San Francisco, CA 94102
- Carl Neiburger Malcolm H. Furbush, Esq.
"9' Vice President and General O
x an s OMspo, CA 93402 Ph p
Crane, Esq.
Pacific Gas & Electric Company Byron Georgiou, Esq.
San h'r ci CA 941
- fh e
r State Capitol Building Arthur C. Gehr, Esq.
Sa ram nto, CA 95814 Snell & Wilmer 3100 Valley Center Lawrence Coe Lanpher, Esq.
Phoenix, Arizona 85073 Hill, Christopher & Phillips.
1900 M Street, N.W.
Washington, D.C.
20036 A
YpOLDS, ESQ.
OEL R.
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