ML20032A092
| ML20032A092 | |
| 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: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-OL, NUDOCS 8110280283 | |
| Download: ML20032A092 (12) | |
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TNC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO ET 26 P1:15 BEFORE THE ATOMIC SAFETY AND LICENS G BOARD ~
OFFICE OF SECRETAi;Y 00CKETit4G ?. SEFNICC PRAllCli
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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'O.L.
(Diablo Canyon Nuclear Power
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3 JOINT INTERVENORS' THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS'.1
- c TO THE NUCLEAR REGULATORY COMMISSION STAFt'/ /g
& A
- 39 I.
Interrogatories Please use the same instructions as those given in Joint Intervenors' first set of interrogatories to the Nuclear Regulatory Commission Staff
(" Staff").
69.
For each of the components, systems, or facilitics listed below, state whether you co;itend that it has been seismically qualified to withstand and continue to function in the event
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of a 7.5 magnitude earthquake on the Hosgri Fault, and state 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 SOT D
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component, system, or facility tested which were made 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) mountaintop PGandE Private Microwave System repeaters; i
(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 associated cables, wiring, and equipment; (i) onsite Technical Support Center and associated cables, wiring and equipment; (j) radiological monitoring stations (k)
PGandE onsite meteorological tower and associated cables, wiring, and equipment.
(1)
UDAC and associated cables, wiring, and equipment. e
70.
With respect to each of the components, systems, or facilities listed in Interrogatory No. 69, state whether 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 magnitude earthquake on the Hosgri Fault, and state each and every fact upon which ycnr response is based.
71.
List each and every agreement and/or contract between PGandE or San Luis Obispo County 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 tne 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;
c.
(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 transportation routes; (d) coordic.ation~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 tavks 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 mani Jounty or State personnel would be available to perform the specified task; (4) how many other persons would be available to perform the specified task; (5) a list of any and 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 interrogatory are based.
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. plans, and state each fact upon which your response is based.
74.
Describe in detail the specific changes which will be made in the relevant applicant, State and local emergency plans based on the information, findings, and recommendations 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 each and every fact upon which your response is based.
List each and every study report, and/or analysis which supports your conclusion.
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
" spontaneous evacuation" by persons other than those within a specified evacuation area.
77.
On p. 4 of'the Staff's response to Joint Intervenors' first set 1of interrogatories
(" Staff Response"),'you state that an
. upgraded meteorological program, an alert system, and'a public information system "are,now.being-implemented."
. Describe in deta'.1 the. basis for that statement.
78.
On=p. 12 of the Staff. Response, you state-that the "offsite
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plans do not specifically address the effect of a major earthquake which occurs simultaneously with a radiological
.e.ergency at Diablo Canyon."'
(a)
State whether you contend that such offsite plans need not consider the complicating factors which might1be
-caused by earthquckes in the development of emergency plans'for a nuclear power plant, mand, if not, state each and every fact upon which your response is based.
(b)
With respect.to the San Luis Obispo County plans and the State of California plan, state how such complicating effects are addressed, if at all.
79.
On p. 13:of the Staff Response, you state that "this
[ communications] equipment is considered to be adequate for communications-following an earthquake."
Describe in detail the basis for that conclusion and cite each and every study, analysis or test prepared, conducted, or reviewed by you in.
reaching the-conclusion.
8. 'On p. 13 of the' Staff Response, you cite a contract with'.a 0
helicopter company "to furnish transportation to and from the.
p ant following an earthquake if all other means of l
transportation are inoperative."
State precisely:
(a) the f/ actual basis for your conc]usion.that such a-contract will provide an adequate means of transportation to and from the plant; (b) the-numbec of helicopters to be provided under the contract on an emergency basis; i
(c) the number of persons which the helicopter (s) in question can transport at one time; (d) a description of any and all drills or exercises of which you are aware which support the statement quoted.
81.
Do you contend tr.at the letters of agreement contained in Draft 3 of PGandE's onsite plan comply with all epplicable i
NUREG-0654 criteria and, if so, what is the basis for your conclusion that they satisfy criterion II.A.3?
Do you contend that.any other agreements are necesary?
82.
On p. 18 of the Staff Response, you cite various methods of j
public notification.
What is the basis for-your conclusion that any of the inethods cited can be implemented and, i f implemented, will be successful in notifying all members of the public?
Describe any and all studies upon which you rely in concluding that the area-wide siren system will successfully cover the plume exposure EPZ.
l 83.
On p. 21 of the Staff Response, you describe the PGandE public information program..
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(a)
Describe the proposed implementation schedule for the prograA.
(b)
What, if anything, has been or will be done to inform visitors to the beaches and parks (including Pismo, Cayucos, Morro Strand, and Atascadaero) as required by 10 C.F.R. S 50.47 (b) (7)?
84.
On p. 23 of the Staff Response, you refer to the plant conditions listed in Section 4 of the Diablo Canyn onsite plan and the guidance of Appendix 1 to NUREG-0654.
Describe any and all training received by PL.ndE personnel and County personnel in the application of that guidance to determine what protective actions to recommend or order.
85.
On p. 26 of the Staff Response, you note that San Luis Obispo County has prepared certain emergency plans.
What efforts have been made spect.fically to coordinate PGandE's emergency response organization with all officials responsible for local emergency preparedness and response in the jurisdictions cited in Joint Intervenors' Interrogatory No.
25?
86.
With respect to the TERA Corporation Report entitled
" Earthquake Emergency Planning at Diablo' Canyon," state whether you contend that the mnximum acceleration at the plant postulated for purposes of that report is properly calculated as less than the.759 acceleration postulated for the SSE in the Diablo Canyon seismic proceeding, and, if so, state each and every fect upon which you response is based. L
II.
Request for Production of Do_cuments Please use the sane instructions as those given in Joint Intd0enors' second request for production of documents to the NRC Staff, excent that the date for production shall be on or before November 20, 1981, 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. 69-86 supra.
Dated:
October 22, 1981 Respectfully submitted, JOEL R. REYNOLDS, ESQ.
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, ESQ.
P. O. Box 1178 Oklahoma City, Oklahoma 73101 By J
R. RETNDLDS Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER-ELIZABETH APPELBERG JOHN J. FORSTER )
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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)
)
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 22th day of October, 1981, I have served copies of the foregoing JOINT INTERVENORS' THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION STAFF, mailing them through the U. 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 H Street, N.W.
Washington, D.C.
'20555 Washington, D.C.
20555 Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555
s.
i Thomas S. Moore, William Olmstead, Esq.
Chairman Marc R. Staenberg, Esq.
Atomic Safety & Licensing Edward G. Ketchen, Esq.
Office of the Executive Legal Appeal Board 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 More Mesa Drive Appeal Board Santa Barbara, CA 93105 U.S. Nuclear Regulatory Concaission Sandra A.
Silver Washington, D.C.
20555 1760 Alisal Street i
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 Atomic Safety & Licensing Bruce Norton, Esq.
Board 3216 N. Third Street U.S. Nuclear Regulatory Suite 202 Commission Phoenix, Arizona 85012 i
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 Andrew Baldwin, Esq.
Commission Washington, D.C.
20555 Friends of the Earth 4
124 Spear Street Docket & Service Branch San Francisco, CA 94105 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
i _ _
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Mrs. Raye Fleming Janice E. Kerr, Esq.
1920 Mattle Road I
Lawrence Q. Garcia, Esq.
Shell Beach, CA 93449 i
J.
Calvin.Simpson, Esq.
California Public Utilities MHB Technical Associates I
52 6 tate Building gf3 Hamilton-Avenue l7
~ 350 McAllister Street San Jose, CA 95125 San Francisco, CA 94102 ar el urger I
Malcolm H. Furbush, Esq.
e e9 Vice President and General O
x Counsel San'Luis'Obispo, CA 93402 Philip A. Crane, Esq.
Pacific Gas & Electric Company
' Byron Georgiou, Esq.
Sbn Fr n is o CA 94106 fheGovernor State Capitol Building Arthur C. Gehr, Esq.
Sacramento, CA 95814 Snell & Wilmer 4
3100 Valley Center Lawrence Coe Lanpher, Esq.
Phoenix, Arizona 85073 Hill, Christopher & Phillips 1900 M Street,'N.W.
Washington, D.C.
20036 1
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