ML20032C200
| ML20032C200 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/03/1981 |
| From: | Crane P PACIFIC GAS & ELECTRIC CO. |
| To: | CALIFORNIA, STATE OF |
| References | |
| NUDOCS 8111090439 | |
| Download: ML20032C200 (92) | |
Text
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d.N MATED CORRES?o:;pg:gc3 DOCKETED ost:ac 1
UNITED STATES OF AMERICA V -5 P2:i5 2
NUCLEAR REGULATORY COMMISSION l
3 0FFICE OF SECRETARY DOCKETtHG & SEP,VICE BRAllCH
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5 6
7 In the Matter of
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Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY
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Docket No. 50-123 g
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Diablo Canyon Nuclear Power Plant
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(Full P oceed5ngs) 10 Units Nos. 1 and 2
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.b 14 APPLICANT PACIFIC GAS AND ELECTRIC COMPANY ANSWERS TO GOVERNOR EDMUND G. BROWN JR's 15 SECOND SET OF INTERROGATORIES 16 17 INTERROGATORY NO. 1:
18 At page 36 of the PG&E Response, PG&E states that 19 it has an agreement with Rogers Helicopter Service to 20 provide a helicopter in the event of an emergency situation.
21 i
A.
What is the basis for the PG&E statement that 22 "this helicopter will be used to notify persons in 23 the Park if the County requested such assistance"?
24 Describe all tests, analyses, or other documents 25 which relate in any way to use of helicopters for 3503 26 this notification purpose.
5 8111090439 811103
/ /
PDR ADOCK 05000275 i r G
1 B.
Produce all documents constituting or relating to 2
the Rogers Agreement.
L 3
4 ANSWER TO INTERROGATORY NO. 1:
5 A.
PGandE has stated that a helicopter will be 6
used to notify persons in Montana de Oro State Park if 7
assistance is requested based on a contract executed 8
with Rogers Helicopter, Inc. dated 10/3/80.
9 On August 20, 1981, a test was conducted that 10 successfully demonstrated the ability to utilize a 11 helicopter both over the Diablo Canyon Plant site and 12 Montana de Cro State Park to notify public visitors of 13 an emergency.
The test was witnessed by NRC 14 representatives.
Transmission of emergency 15 notification information utilizing high power PA 16 systems was successfully demonstrated at altitudes of 17 500, 1,000, and 1,500 feet.
18 B.
Documents constitu+.jng or relating to the 19 Rogers Agreement have been submitted for discovery.
20 Ref. EPNG 0009416-0009420.
21 22 23 l
24 INTERROGATORY NO. 2:
25 At page 40 of the PG&E Response, PG&E states that 26 the onsite meteorological tower is capable of withstanding f
l I
winds of 110 miles per hour within normal working stresses t
2 and that such winds constitute the equivalent of a seismic 3
loading of 1.2g.
Provide all analyses, calculations, and 4
other documents which support or in any way relate to the 5
PG&E conclusion that winds of 100 miles per hour constitute 6
the equivalent of a seismic loading of 1.2g and/or that the 7
tower will, in fact, remain operable in such a situation.
8 9
ANSWFR TO INTERROGATORY NO. 2:
10 The meteorological tower is a latticed steel mast.,
11 guyed at intervals along its length to resist lateral loads.
12 Due to its relatively 'ight weight, its design is controlled 13 by wind loading rather than by earthquake.
In order to find 14 the safe wind loading on the towers, the ultimate capacity 15 of each principal element of the tower was first determined.
16 Then, for each element, the wind force necessary to stress 17 it to no more than two-thirds of its ultimate capacity was 18 determined.
Finally, the smallest such wit i force thus 19 determined was converted to the corresponding wind velocity; 20 in this case 110 miles per hour.
The equivalent seismic 21 coefficient was determined simply by dividing the wind 22 loading per unit. length of the mast by the weight per unit 23 lengths of the mast.
These computations and reference 24 material will be made available for discovery in San 25 Francisco.
26 f
e 1
INTERROGATORY NO. 3:
2 At page 75 of the PG&E Response, PG&E states its t
3 intention to construct a permanent EOF.
4 A.
When does PG&E intend to complete construction of 5
a permanent EOF?
6 B.
What is the current status of meeting the 7
foregoing construction completion objective?
8 C.
Describe all documents related to construction of 9
this permanent EOF.
10 D.
Will the permanent EOF be seismically qualified to 11 remain functional in all respects in the event of 12 an earthquake up to and including the SSE on the 13 Hosgri fault and a 7.0-7.5 magnitude earthquake on 14 the Rhinconada fault?
15 16 ANSWER TO INTERROGATORY NO. 3:
17 A.
Construction of the EOF, which will meet the 18 requirements of NUREG-0696, is currently scheduled to 19 be completed by October 1, 1982.
2C B.
To date, Central Coast Labs, at PGandE's 21 request, Ias performed a soil analysis of the area; and 22 PGandE has prepared a topographic map, presented a 23 letter of intent to the San Luis Obispo County Board of 24 Supervisors, and reviewed preliminary floor plans with 25 County officials.
PGandE is also assembling the 26 necessary information to file an application for a land
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1 use permit and to prepare the EOF design criteria L
2 memorandum.
PGandE has received County approval for 3
both the conceptual design and location of the EOF.
4 Equipment is being purchased which conforms to 5
NUREG-0696 requirements, and an estimate of the cost of the permanent EOF is being prepared.
6 Some documents have been generated to assist 7
C.
8 the design of the permanent EOF, and they are available 9
for discovery in San Francisco.
However, to date, no documents have been issued which will be used in the 10 11 construction of this facility.
12 D.
PGandE does not know if the permanent EOF will be " seismically qualified to remain functional in 13 14 all respects" because it does not know what the phrase 15 means.
The permanent EOF building will be designed 16 17 seismically in accordance with the principles of the 18 Uniform Building Code and the Lateral Force Requirements of the Structural Engineers Association of 19 20 California (the " Blue Book").
In part this states, i
21 structures designed in conformance with the forth herein should, in 22 provisions and principles set 23 general, be able to:
j 24 3.
Resist major earthquakes, of the intensity of 25 severity of the strongest experienced in 26 77f,
1 California, without collapse, but with some 2
structural as well as nonstructural damage.
3 In most structures, it is expected that structural 4
damage, even in a major earthquake, could be limited to 5
repairable damage.
6 7
I 8
9 INTERROGATORY NO. 4:
10 At page 81 of the PG&E Response, PG&E states that 11 in the event of OBE and SSE accelerations at the Diablo 12 Canyon site, UDAC and its related equipment will remain 13 functional.
14 A.
What accelerations does PG&E assume would occur in 15 the OBE and SSE at the UDAC site?
(If the l
16 l
accelerations are those set forth in Table I, t
17
- p. 84, so state.)
18 B.
What analyses support PG&Ei s statement that UDAC 19 and its associated equipment will remain 20 functional under such accelerations?
21 C.
Has PG&E performed any analyses to determine l
22 whether UDAC and its related equipment will still 23 remain functional in the event of a magnitude 24 7.0-7.5 earthquake on the Rhinconcada fault 25 located at its closest point to UDAC?
If so, 26 please describe such analyses and produce them. -
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1 If not, please describe the reason why such 2
analyses have not been performed.
E 3
4 ANSWER'TO INTERROGATORY NO. 4:
5 A.
Those set P in Table I, page 84, of the 6
PGandE Response.
7 B.
A
. mal analysis to support PGandE's 8
statement that UDAC and its associated equipment will 9
remain functional under postulated seismic-10 accelerations was not required.
UDAC primarily 11 contains tables and chairs to provide a work area for 12 technical personnel to perfore independent dose 13 assessment tasks.
This equipment ~ is not considered 14 essential to maintain the functional objectives of UDAC 15 since these dose assessment tasks can be performed 16 essentially at any location.
17 C.
No.
See answer to 4B, above.
18 19 20 21 INTERROGATORY NO. 5:
22 At pages 84-89 of the PG&E Response, PG&E presents 1
23 in tables its predicted acceleration. at various onsite and 24 offsite locations in the event of the SSE and the OBE.
In 25 these tables, PG&E uses the term " Distance from Hosgri 26 i
fault."
Define that term.,_
f 1
ANSWER TO INTERROGATORY NO. 5:
2 The term " distance from Hosgri fault" is defined 3
as the shortest distance between the site in question and 4
the surface trace of the Hosgri fault.
In applying this 5
~ distance to the estimation of peak definition of 6
acceleration at each site using Equation 1 of the TERA 7
report (pp.
3-7), two conservative assumptions were made:
8 (1) both the SSE and OBE were assumed to rupture to the 9
- surface, and (2) both the SSE and OBE were assumed to 10 rupture that part of the Hosgri fault closest to the site in 11 question.
12 13 14 15 INTERROGATORY NO. 6:
16 A.
With reference to the tables beginning at page 84 17 of the PG&E Response, what was the rationale for 18 using accelerations less than those postulated for i
19 the SSE in the Diablo Canyon seismic proceeding?
20 For example, the onsite meterological towers are 21 located at the Diab]
Canyon facility.
During the 22 seismic proceeding. a free field acceleration for 23 the SSE was postulated at 0.75g for that location.
24 Why was a lesser acceleration, namely 0.48g, 25 postulated in Table 1 and also in the Tera Report?
i 26 777 i
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B.
At page 66 of the PG&E Response, the following 2
statement is made:
(
3 The postulated magnitude 7.5 earth-quake on the Hosgri fault was 4
chosen because of its use as the seismic design basis for the Diablo 5
Canyon Power Plant and its dominant seismic hazard to the plant.
7 Explain why an acceleration of 0.75g was not also 8
assumed at the plant site for this magnitude 7.5 9
earthquake since:
(i) this was the free field 10 acceleration used in the seismic des. ten basis for 11 the Diablo Canyon plant; and (ii) a 0.75g SSE 12 scceleration is specifically set forth in the 13 Diablo Canyon Emergency Plan (Table 4.1-1, p. 15.)
14 15 ANShT.R TO INTERROGATORY NO. 6:
16 A.
The peak acceleration values provided in 17 response to Interrogatory 34 of the first set of 18 Governor Brown's interrogatories represent those 19
" expected" to occur during the SSE and OBE and were 20 computed as median estimates of acceleration using 21 Equation 1 of the TERA report.
By definition, the 22 median estimate is one for which 50 percent of the 23 values are larger and 50 percent of the values are 24 smaller.
The postulated 0.75g SSE for the Diablo 25 Canyon facility represents a design acceleration which 26 incorporates a margin of safety larger than a median or
_9_
I 1
" expected" value of acceleration.
In this context, the 2
value of peak acceleration expected for the SSE at the L 3
Diablo Canyon facility is 0.48g.
4 E.
As explained in Part A of this response, the 5
0.75g SSE used as the seismic design basis for the 6
Diablo Canyor facility represents an acceleration that 7
is larger than would be expected at the facility during 8
an M 7.5 earthquake on the Hoegri fault, and includes s
l 9
a margin of safety in addition to that incorporated in 10 the selection of the design basis earthquake.
Use of 11 an M 7.5 earthquake on the Hosgri fault for emergency s
12 planning purposes does not necessarily imply 0.75g as 13 the value of acceleration expected at the site during 14 such an earthquake.
In fact, as stated above, the 15 value of peak acceleration expected at the Diablo 16 Janyon facility for this earthquake is 0.48g.
For 17 planning purposes, expected values of peak acceleration-18 were used so that realistic damage scenarios would be 19 considered.
Scenarios incorporating greater and lesser 20 damage were also considered to account for uncertainty l
21 associated with this assessment of expected damages.
22 23 24 25 26
n 1
INTERROGATORY NO. 7:
2 With reference to the tables beginning at page 84 t
3 of the PG&E Response,-are the peak accelerations listed mean 4
peak accelerations or medians and what is the assumed 5
standard deviation?
6 7
ANSWER TO INTERROGATORY NO. 7:
a The acceleration parameter used to represent peak 9
acceleration in the response to Interrogatory 34 of the 10 first set of interrogatories is defined as the mean of the 11 two peak values scaled from the horizontal components of an 12 accelerogram.
The estimate of this parameter, as listed in 13 Tables I, II, and III, is the median value or that value 14 expected to occur at the site during the specified 15 earthquake.
The standard deviation associated with this 16 estimate is 0.405 for the natural logarithm of peak 17 acceleration, representing a multiplicative factor of 1.50 18 on the estimate of acceleration.
19 20 21 22 INTERROGATORY NO. 8:
23 At page 5 of the PG&E Response, lines 14-16, PG&E 24 states that "the dose reduction benefit of sheltering versus evacuationandbeingovbrtakenbythepassingplumewillbe 25 26 evaluated on a case-by-case basis."
What criteria will be
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l 1
utilized in thisL case-by-case determination?.What training 2
is being and/or has been provided to PG&E personnel on t
3 applicaticn of these criteria?
4 5
ANSWER TO INTERROGATORY NO. 8:
6 As required by NUREG-0654/ FEMA-REP-1, criteria for 7
plume exposure pathway protective action recommendations for 8
the general public are based on the " Manual of Protective 9
. Action Guides and Prctective Actions for Nuclear Incidents" 10 (EPA-520/1-75-001).
In order to determine the most 11 effective protective action, the dose reduction factor for 12 whole body dose and thyroid dose would be determined for 13 sheltering and evacuation.
The dose reduction factor 14 dep2nds upon composition of plume, magnitude of plume, plume 15 arrival time, duration of release (duration of plume 16 exposure), projected evacuation time, and plume transit 17 time.
The protective action which has the greatest dose 16 reduction factor would be the protective action recommended.
19 In cases where the dose reduction benefits are nearly equal, 20 sheltering would be initiate.d with evaluation of advantages 21 gained by subsequent evacuation.
With sheltering followed 22 by evacaation, advantages increase as degree of protection 23 by shelter decrease and plume exposure period increases.
24 PGandE personnel have been trained and will 25 continue to be trained on the applicable emergency 26 procedures.
In addition, PGandE personnel have attended i
_ rad ological accident assessment courses sponsored by the A
2 State of California and the NRC/ FEMA in which instruction 1
3 was provided by experts in the areas of protective action 4
application.
5 6
7 8
INTERR3GATORY NO. 9:
9 At page 7 of the PG&E Reponse, reference is made 10 to the media center at Cuesta College.
v.at is the seismic 11 qualification of that media center?
12 13 ANSWER TO INTERROGATORY NO. 9:
14 The seismic qualification of the media center at 15 Cuesta College is unknown.
16 17 18 19 INTERROGATORY NO. 10:
20 At pages 15-19 of the PG&E Response, PG&E hi; 21 described many elements of its public information program.
22 Has'this information been produced in response to Governor 23 Brown's prior document production requests?
If not, the 24 Governor requests that all documents described at pages 25 15-19 and drafts of documents not in complete form be 26 produced.
1 ANSWER TO INTERROGATORY NO. 10:
2 To the best of its knowIedge, all documents and 3
drafts of documents listed in pages 15-19 of the PGandE 4
Response have been made available for discovery.
5 6
7 8
INTERROGATORY NO. 11:
9 At page 27 of the PG&E Response, seven documents 19 are described related to emergency planning drills.
Have 11 these documents been produced in response to Governor 12 Brown's document production requests?
If not, produce 13 these documents.
14 15 ANSWER TO INTERROGATORY NO. 11:
16 The documents described on page 27 of the PGandE 17 Respcnse were not produced in response to Governor Brown's 18 Document Production request because of their irrelevancy.
19 However, with the exception of the Drill Logs, which were 2;
unsigned and dated August 13 and 17, 1981, respectively, all 21 other documents will be produced.
22 23 24 25 26 _ _ _ _ _
1 INTERROGATORY NO. 12:
2 At page 32 of the PG&E Response, PG&E describes t
3 various documents.
Documents Nos. 13 and 14, to our 4
knowledge, have not-yet been produced by PG&E in response to 5
the Governor's document production requests.
Produce these 6
documents.
7 8
ANSWER TO INTERROGATORY NO. 12:
9 The requested documents (Nos. 13 and 14) are 10 attached.
11 12 13 14 INTERROGATORY NO. 13:
15 In Interrogatory 9 of Governor Brown's first set 16 of Interrogatories to PG&E, the Governor asked PG&E, inter 17 alia, to identify and describe any tests or analyses which 18 have been performed either by PG&E or others on the 19 qualifications, characteristics, and response features of 20 the real-time monitors and the equipment at the 21 environmental monitoring stations.
PG&E omitted any.
22 response to this Interrogatory in its earlier answers.
23 Please provide a response at this time.
24 25 26 !
1 ANSWER TO INTERROGATORY NO. 13:
2 No analyses or tests have been performed by PGandE t
3 or others on the qualifications, characteris'.ics, and 4
re.sponse features of the real-time monitors and the 5
equipment at the environmental monitoring stations.
6 7
8 9
M ERROGATORY NO. 14:
10 At page 40 of the PG&E Response, PG&E referenced 11 that the Federal Signal Company has recently completed some 12 seismic work on the largest siren.
PG&E also stated that 13 this information was being forwarded to PG&E and will be 14 used to supplement PG&E's earlier response when available.
15 Has this informati' a yet been provided to PG&E?
When does 16 PG&E anticipate supplementing its earlier responses?
17 18 ANSWER TO INTERROGATOP.Y NO. 14:
19 PGandE received r_he information concerning the 20 seismic testing of the Model 1000 siren from the Federal 21 Signal Company in mid-September.
The actual testing was 1
22 performed by Wyle Laboratory for the Federal Signal Company.
23 The document is available for discovery in the PGandE office 24 in San Francisco.
25 26 1
INTERROGATORY NO. 15:
2 At page 42, lines 19-11, of the PG&E Response, t
3 reference is made to the compressor and the compressor 4
platforr. related to the siren system.
Have any seismic 5
analyses been performed regarding the compressor and/or the 6
associated platform?
If so, describe and provide these 7
&nalyses.
8 9
ANSWER TL
_ERROGATORY NO. 15:
10 No.
11 12 13 14 INTERROGATORY NO. 16:
15 At page 56 of the PG&E Response, it is stated that 16 the standard operating procedures for the Saa Luis Obispo 17 Cou..:y Emergency Plan would be described in PG&E's responses 18 to requests for production.
Our review of PG&E's production 19 responses discloses that these procedures were not so 20 dsecribed.
Accordingly, describe each of those operating 21 procedures or, in the alternative, produce them for 22 inspection and ccpying.
23 24 ANSWER TO IN2ERROGATORY NO. 16:
25 Standard Operating Procedures for the upgraded 26 County Emergency Plan are not yet finalized and approved by
~
of County R;qucsts for copics r ecmnty authoritics.
h cou.ty.
cogniza
.ast be directed to t e 2
de.
3 4
following 5
17:
the INTERROGATORY NO.of the PG&E Response, 6
66 At page 7
damage is made:
the statement variability of off-sitefrom result of 8
diversity to A large expected This challenges 9
would beearthquake.
comprehensivelyand requires them to be Hosgri of variety damage 10 The largely emergency plansflexible. consideredof both 11 extremelyscenarios e).pected ef fectsearthquakes Obispo that damage the 12 envelopes and larger Luis he main difference being tspecific San within smaller occur 13 might The of County.
likelihood 14 relative considered ny scenarios.
scenarios
- nd what way do the damage of both large 15 expected effects within San In A.
16 the occur envelope might that 17 earthquakes smaller which Luis Obispo County?
other documents 18 or analyses 19 all Describe above.
statement quote B.
20
/
support the 21 22
///
I 23 777
///
f 25 26 an e
1 ANSWER TO INTERROGATORY NO. 17:
2 A.
PGandE does not believe an enveloping of
(
3 expected earthquake effects is particularly useful for 4
emergency planning.
By evaluating a spectrum of 5
potential damage levels and the effects of these damage 6
levels on evacuation time estimates, the appropriate 7
emergency response can be determined for a wide range 8
of earthquakes, both large and small.
9 E.
Supporting analyses and documents are 10 provided in the TERA report on Earthquake Errergency 11 Planning at Diablo Canyon, copies of which have been 12 furnished to all parties.
13 14 15 16 INTERROGATORY NO. 18:
17 On page 72 of the PG&E Response, PG&E states that 18 it believes all applicable emergency plans will be in 19 compliance with all applicable regulations prior to 20 commercial operation of the Diablo Canyon facility.
21 A.
As of September 15, 1981, the date of the PG&E 22 Response, (or, if PG&E prefers, on the date PG&E 23 responds to these Interrogatories) what were (are) 24 the items of noncompliance with a p2icable 25 regulations for the PG&E, the County, and the 26 State emergency response plans?._.
1 B.
What schedule for resolution of these items of 2
noncompliance did PG&E assume when it made the L
3 foregoing statement on page 72?
4 5
ANSWER TC INTERROGATORY NO. 19:
6 A.
As stated preh um.ly, it is PGandE's position 7
that all applicable emergency plans will be in 8
compliance with ali applicable regulations prior to 9
commercial operation of the Diablo Canyon nuclear power 10 plant in order to assure that adequate protective 11 measures can and will be taken in the event of a 12 radiological eraergency.
13 This opinion is based on the individual and 14 collect;ve judgment of Applicant's staff who have been 15 intimately involved in emergency response planning for i
16 the past several years as well as the opinions of 17 various lederal, state and county emergency response 10 i
planners and evaluators.
In addition, Applicant has 19 retained consultants who have reviewed the various 20 plans and applicable regulations and have formed 21 similar opinions.
- Finally, the joint full field 22 exercise conducted on August 19, 1981 demonstrated a 23 capability to respond to a radiological emergency at 24 Diablo Canyon.
25 ff, 26 fff.
1 B.
These items will be resolved prior to 2
commercial operation.'
t 3
4 5
6 INTERROGATORY NO. 19:
7 Describe all human factors or other analyses which 8
have been performed or are to be performed n PG&E's 9
implementing procedures for the PG&E Emergency Response 10 Plan, Revision 3.
11 12 ANSWER TO INTERROGATORY NO. 19:
13 To date, no human factors or other related 14 analyses have been performed on the implementing procedures 15 associated with the PGandE Emergency Response Plan, 16 Revision 3.
At the present time, there are no requirements 17 for the performance of human factors analyses on n ' clear 18 power plant emergency response plans.
PGandE will consider 19 appropriate future actions or analyses when definitive 20 standards or criteria are established.
21 22 23 24 INTERROGATORY NO. 20:
25 At page 76 of the PG&E Response, PG&E objected as 26 irrelevant and outside of the scope of discovery to Governor 1
b e
1 Brown's request that PG&E describe human factors or other 2
analyses which have been performed on PG&E's emergency 3
operating procedures.
Emergency operating procedures are L
~4 relevant, however, since the Emergency Plan (e.g., pp. 6-8, 5
et.
seg.) specifically addresses assessment activities 6
covered by such procedures.
Further, in Joint Intervenors' 7
Statement of Clarified Contentions dated June 30, 1981, 8
emergency operating procedures were specifically included.
9 The Board restated Joint Intervenors' contention, but it 10 expressed no disagremeent [ sic] that emergency operating 11 procedures were part of that contention.
Accordingly, 12 Governor Brown requests PG&E to respond to the Governor's 13 original Interrogatory No. 30 which requests as follows:
14 Describe all human factors or other analyses which have been performed on or 15 are proposed to be performed on PG&E's Emergency Operating Procedures.
When 16 and by whom was each analysis performed?
17 ANSWER TO INTERROGATORY NO. 20:
18 Objected to as irrelevant and outside the scope of 19 discovery.
Emergency operating procedures are not the 20 subject of the contention before this Board, but rather 21 emergency planning under 10 C.F.R.
$$ 50.33(g), 50.47 and 22 Appendix E to Part 50.
23 24 25 26
m e
1 INTERROGATORY NO. 21:
2 At page 82 of the PG&E Response, PG&E identifies a g
3 Tera Corporation report entitled,
" Evaluation of Peak 4
Horizontal Ground Acceleration Associated with the Hosgri 5
Fault at the Diablo Canyon Nuclear Power Plant," dated 6
August 1980.
7 A.
Has this document been produced by PG&E?
8 B.
If not, produce this document.
9 10 ANSWER TO INTERROGATORY NO. 21:
11 Yes.
This document is Exhibit 1 to PGandE's 12 prefiled testimony for the ASLAB seismic hearings.
13 14 15 16 INTERROGATORY NO. 22:
17 At page 17 of the PG&E J. I. Response, PG&E states 18 that the Tera Report will be evaluated and appropriate 1
19 changes to the Emergency Plans and Procedures will be made i
20 as required.
21 A.
Has PG&E conducted analyses of the Tera Report to 22 identify any changes in plans and procedures which 23 will be required?
24 B.
If tha answer to the foregoing is yes, describe 25 all these analyses and changes and produce them.
26
///
3 >
1 C.
If such analsyes have'not been performed, when 2
will they be performed?
t 3
4 ANSWER TO INTERROGATORY NO. 22:
5 A.
PGandE is continuing its review of the TERA 6
report.
Currently, changes to the PGandE plan do not 7
appear warranted since Section 6 of that report 8
provides an augmented plan for earthquake effects.
9 B.
Not applicable.
10 C.
If changes to the Emerger.cy Plans are 11 warranted after review of the TERA report by federal, 12 state, and local planning officials is complete, PGandE 13 will include these in its annual review and update.
14 15 16 17 INTERROGATORY NO. 23:
18 At page 18 of PG&E's J.I.
Response
PG&E states 19 that it understands that the forthcoming Tera
.: port would 20 be applicable to earthquakes greater than the M 7.5 SSE.
21 Subsequent to PG&E's answers, PG&E has received the Tera 22 Report.
Does PG&E contend that this report is applicable to 23 earthquakes greater than the SSE?
If so, identify what 24 portions, in PG&E's opinion, address earthquakes greater 25 than the SSE.
26
///
1 ANSWER TO INTERROGATORY NO. 23:
2 Earthquakes greater than the M 7.5 SSE were not-t s
3 explicitly considered in the TERA report; rather, the 4
methodology for developing damage scenarios implicitly 5
considers larger earthquakes.
For instance, the scenario 6
thst considered damage greater than that expected from the 7
SSE also represents damage that is expected from an 8
earthquake of M greater than 7.5.
s 9
10 11 12 INTERROGATORY NO. 24:
13 At pages 41 and 42 of PG&E's J.I. Response, PG&E 14 identifies four land routes, in addition to the north and 15 south land routes, which might be utilized by vehicles or 16 foot traffic to leave Diablo Canyon.
The second route 17 (lines 18-22 on page 41) is identified as perhaps not being 18 available to ordinary vehicles.
Are routes 1, 3 and 4 19 available to ordinary vehicles?
If the answer is 20 affirmative, describe any analyses performed by or for PG&E 21 to document that ordinary vehicles can use these other three 22 routes.
23 24 ANSWER TO INTERROGATORY NO. 24:
25 Route No. I can be utilized by ordinary vehicles.
26 During_ previous public demonstrations at the Diablo Canyon 1
Power Plant, this route was utilized as an access road by 2
plant personnel.
Routes Nos. 3 and 4 can be utilized by t
3 high-chassis vehicles (e.g.,
pick-up trucks).
However, to 4
the best of our knowledge, passage over these routes by 5
ordinary vehicles has not been demonstrated.
6 7
8 9
INTERROGATORY NO. 25:
10 In document EPNG0005395, produced by PG&E in 11 response to Governor Brown's document production requests, 12 PG&E states that all " critical equipment" is securely braced 13 and anchored to prevent sliding, overturning, or striking 14 other equipment or the building.
How does PG&E define 15 critical equipment?
Does such critical equipment include 16 the onsite and offsite real-time monitors, environmental 17 monitoring equipment, and public notification system sirens?
18 19
-ANSWER TO INTERROGATORY NO. 25:
20 Document EPNG0005395 discussed the seismic 21 resistance of the Diablo Canyon Power Plant communication 22 system.
The term " critical equipment" was used in the 23 subject document to describe equipment specific to the 24 communications system (i.e.,
equipment and battery racks, 25 antennae and supports).
" Critical equipment" has no 26 relationship to the onsite and offsite real-time monitors, 1
environmental monitoring equipment, and public notification 2
system sirens.
L 3
4 5
6 INTERROGATORY NO. 26:
7 At pages EPNG0010795-96 of the documents produced 8
by PG&E in discovery (Tera proposal TR-81-1247), Tera states 9
that it proposes to analyze "other earthquake effects."
10 A.
Has Tera performed such an analysis?
If so, 11 provide such analysis.
12 B.
If Tera has not yet performed such analysis, is it 13 in the process of performing such analysis, and if.
14 so, when will it be performed?
Provide such 15 analysis when it has been performed.
16 17 ANSWER TO INTERROGATORY NO. 26:
18 This study was performed at the request of 19 counse.
and is a privileged communication not subject to 20 discovery.
21
///
22
///
23
///
i 24 25 26 I
1 INTERROGATORY NO. 27:
2 In the event of a major earthquake on the Hosgri t
3 fault up to and including the SSE, does PG&E expect that 4
there would be sufficient damage to homes and-residences in 5
San Luis Obispo County (or any part of it) such that 6
sheltering, at least in areas of greatest earthquake damage, 7
no longer will be a viable protective action alternative?
8!
A.
Describe the bases for your response.
9 B.
Identify any documents which relate in any way to lo this matter.
11 12 ANSWER TO INTERROGATORY NO. 27:
13 Based upon experience from other large 14 earthquakes, one might anticipate sone damage to homes and 15 residences in the area nearby the earthquake rupture While 16 instances of damage to specific buildings sufficient to 17 preclude sheltering in those buildings may occur, there 18 should be other structures without such major damage to 19 allow sheltering as a viable protective action.
20 21 22 23 INTERROGATORY NO. 28:
24 A page 8 of Tera Corporation's April 8, 1981 25
" Proposal for Earthquake Emergency Planning" (page 26 EPNG0017126 of documents produced by PG&E), personnel from - -
1 Tera Corporation who propose to work on the Tera t
2 Corporation's study are identified.
3 A.
Are these the persons from Tera Corporation who 4
- did, in fact, work on and prepare the Tera 5
Corporation report submitted in September 1981?
6 B.
Describe far each individual what his or her role 7
was in preparation of said report.
8 C.
Identify, with reference to specific sections of 9
the Tera Report and its appendices, the persons 10 primarily responsible for the
- analyses, 11 calculations, and technical portions of that 12 report.
13 14 ANSWER TO INTERROGATORY NO. 28:
15 A.
Yes, except for Mr. Joseph A. Fischer and Mr.
16 G.
Smith, who were not actively involved in the study.
17 B.
Mr. Robert L. Cudlin ac ed as Project Manager 18 and directed the emergency planning effort.
Dr.
R.
19 Winslow and Mr. Brian Davis assisted Mr. Cudlin in the i
20 evacuation studies.
Dr.
K.
Campbell directed the l
21 ground motion effort.
Dr.
C.
Mortgat directed the 22 assessment of damage to structures and roadways.
23 Messrs.
L.
Wright and D.
Davis were responsible for 24 corporate and division management.
25
///
26
/// i
n --
1 C.
Main Report 2
1.0 Introduction and Executive Mr. R.
Cudlin Summary Mr. D. Davis t
2.0 Study Areas Mr. R. Cudlin 4
3.0 Earthquake Effects 5
3.1 General Earthquake Effects Dr. K. Campbell 13. 2 Earthquake' Effects on 6
Transportati on Dr. C. Mortgat 7
4.0 Evacuation Time Estimates Mr. B.~ Davis 1
Dr. R.' Winslow 8
5.0 Communications Dr.
C. Mortgat 6.0 Diablo Canyon Earthquake Response M_.
R. Cudlin 10 Plan 11 Appendix:
Ground Failure 12 1.0 Overview of Critical. Routes Mr. M. Payne 34071 Pequito Dr.
13
~
Dana Point, CA 92629 14 2.0 Landslide Potential Dr. J. Chameau, 15 Professor School of 16 Engineering Grisson Hall 17 Purdue University West Lafayette, IN 18 47907 19 Appendix:
Bridges and Evacuation 20 1.0 Guideline for Evaluating the Mr. R. Nutt Probable Seismic Damage to 5311 Dredger Way 21 Highway Bridges in the San Luis Orangevale, CA Obispo Area 95662 2.0 Testing of Bridge Evaluation Mr. R. Nutt 23
.aidelines 24 3.0 Seismic Evaluation of Bridge Mr. R. Nutt Columns 25
///
26
/// >
D 1
4.0 Summary of Bridges Surveyed Mr. R. Nutt 2
5.0 Evacuation Network Dr. R. Winslow 1
3301 Ginger Tree Ct.
3 Fairfax, VA 22030 4
5 6
7 INTERROGATORY NO. 29:
8 In the document production responses of PG&E, a 9
number of documents constituting minutes of the PG&E 10 Emergency Planning Task Force were provided.
Have all 11 minutes up to the current time been provided?
If not, which 12 minutes have not been provided?
Provide all those not 13 previously provided.
In that regard, at page EPNP0047862 14 (minutes of February 4, 1981 Emergency Planning Task Force 15 Meeting, there is a statement that the Task Force will meet 16 bi-weekly until the field exercises are concluded.
We do 17 not have bi-weekly minutes up through August 19, 1981.
18 i
19 ANSWER TO INTERROGATORY NO. 29:
20 Records provided to date include all minutes for 21 the Emergency Planning Task Force.
The Emergency Planning 22 Task Force ceased to exist upon reorganization of the 23 Personnel and Environmental Safety Section in the month of 24 April, 1981.
25 26 i
4 1
INTERROGATORY NO. 30:
2 Three Tera Corporation references (pp. 7-1 and 3
' 7-2) are not publicly available.
These are:
.4 Applied Technology Council, 1981, " Guidelines for the Evaluation of Highway Bridges, 5
ATC-b, Final Draft Report,"
Applied Tecnnology
- Council, Berkeley, 6
7
- Campbell, K.
W.,
1980, " Attenuation of Peak Horizontal Acceleration within the 8
Near-Source Region of Moderate to Large Earthquakes,"
TERA Corporation, 9
Technical Report 80-1,
- Berkeley, Cali fornia.
10
- Campbell, K.
W.,
1981, "Near-Source Attenua-11 tion of Peak Horizontal Accleration,"
j Bulletin of the Seismological Society of 12 America, Vol. 71 (in press).
13 Produce these documents.
14 15 ANSWER-TO INTERROGATORY NO. 30:
16 The three documents listed in Interrogatory 30 of 17 the second set of interrogatories are available for 18 inspection at the PGandE office in San Francisco.
19 20 21 22 INTERROGATORY NO. 31:
23 At page 6-8 of the PG&E Emergency Plan, the I
24 following statement appears:
25 In the case of the LOCA with inadequate core cooling, the major release would 26 not be expected for at least two hours,
v
-e e
- + -
I and probably much longer, 'due to the time required to melt a large fraction 2
of the core and the expected time before t
any containment failure would be likely.
3 4
A.
What analyses have been performed to support the 5
foregoing statement?
6 B.
Describe all documents which relate in any way to 7
the foregoing statement.
8 9
ANSWER TO INTERROGATORY NO. 31:
10 A.
No analysis is required for the statement in 11 the context in which it was used in the paragraph.
12 This text provides a general background for a reader on 13 the significance of the postulated event.
14 B.
Not applicable.
15 16 17 18 INTERROGATORY NO. 32:
19 At page 6-17 of the PG&E Emergency Plan, it is 20 stated that "the real-time monitors would be automatically 21 interrogated throughout the course of the accident and any 22 environmental assessment."
23 A.
Does the capability exist at this time to 24 automatically interrogate from the pl:4nt all 25 onsite and offsite real-time monitors?
26
///. - _.. -.
r 1
B.
If the answer is affirmative, when s was this 2
capability. established and please describe i ts t
3 technical basis.
4 C.
If not, does PG&E intend to establish such 5
automatic interrogation capability and if so, 6
when?
7 8
ANSWER TO INTERROGATORY NO. 32-9 A.
Yes.
10 B.
This capability was established on a-11 conceptual basis in the Fall of 1979, and installation 12 of thic equipment occurred during the Spring and Summer 13 of this year.
14 The technical basis for the automatic 15 interrogation capability is the desire of radiological 16 assessment personnel to obtain as much radiation dose 17 rate informatio.. in the environs of Diablo Canyon Power 18 Plant as possible.
This information provided by the 19 real-time monitors is supplementary to radiological 20 information obtained from other sources such as field 21 teams.
The automatic interrogation capability provides 22 a radiological data source which would normally not 23 require the dispatch of personnel to each monitor 24 location to retrieve data.
25 C.
Not applicable.
26. a
1 INTERROGATORY NO. 33:
2 In the event the EOF and UDAC are not functional,
.t 3
what communication and assessment-capabilities are available 4
Lat the County's EOC?
5 6
ANSWER TO INTERROGATORY NO. 33:
7 1.
Communication Capabilities 8
In the event the UDAC and EOF are not functional, 4
9 the County EOC presently has or is in the process of 10 obtaining the following commuaications capabilities:
11 1.
Ten Pacific Telephone business lines.
12 2.
A Private-Line Selective Signaling Circuit 4
13 connecting the EOC to the OES headquarters, EOF, 14 NRC office in the EOC, Diablo Canyon Power Plant 15 Control Rooms Unit 1 and Unit 2 and Technical 16 Support Center.
17 3.
An HRC ENS Hot-Line to the NRC Bethesda, Maryland, 18 Headquarters.
19 4.
An NRC Health Physics Region V network hot-line.
20 5.
A Public Information Private-Line Selective 21 Signaling Circuit connecting the EOC-P10 to the 22 EOF-P10, PGandE Media Center at Questa College, 23 and the PGandE San Luis Obispo Office P10.
24
///
25
///
26
/// '
1 6.
A Hot-Line telephone circuit connecting the 2
EOC-Sheriff's dispatch center to Diablo Canyon 3
Power Plant Control Room and Technical Support 4
Center.
-5 7.
A UHF Radic Link connecting the EOC-Eneriff's 6
dispatch center to Diablo Canyon Power Plant 7
Control Room and Technical Support Center.
I 8
S.
Eleven Pacific Telephone Co.
business lines 9
serving the following offices in the EOC:
10 2 liaes - FEMA Office 11 2 lines - DOE / EPA Office 12 3 lines - NRC Office 13 3 lines - State of California Office 14 1 line - PGandE Office 15 9.
A private intercom link connecting the County P10, 16 UDAC, and EOF.
17 10.
(Under Investigation.)
A Private-Line Selective 18 Signaling Circuit' connecting the EOC to the 19 following nearby cities:
20 (a)
Morro Bay 21 (b)
Paso Robles 22 (c)
Atascadero 23 (d)
San Luis Obispo 24 (e)
South Bay 25 (f)
Pismo Beach 26 (g)
Arroyo Grande ;
r 1
(h)
Grover City L
2 (i)
CAL POLY University 3
2.
Assessment Capabilities 4
Dose Assessment capabilities will not be 5
significantly affected if the EOF and UDAC are not 6
functional since dose assessment taskt, can be performed 7
manually at virtually any location.
8 9
10 11 INTERROGATORY NO. 34:
12 At page 7-25 of the PG&E Emergency Plan, PG&E 13 states that the County Emergency Plan will provide for 14 special notification arrangements in the wilderness area 15 near the plant, particularly the State Park.
16 A.
What are these special notification arrangements?
17 B.
Have these arrangements ever been practiced?
If 18 so, describe the practice sessions.
I 19 20 ANSWER TO INTERROGATORY NO. 34:
21 A.
All o' the land around the Diablo Canyon 22 facility is either a part of the Montana de Oro State 23 Park or privately owned.
There is no additional 24
" wilderness" area.
See PGandE's response to 25 Interrogatory 8 of the Governor's First Set of 26 Interrogatories..
1 B.
The only notification process tested to date 2
has been the October 20, 1981, demonstration utilizing t
3 the Roger's Helicopter Service as described in 4
Interrogatory No. 1.
5 6
7 8
INTERROGATORY NO. 35:
9 At page 7-25 'of the PG&E Emergency Plan, PG&E 10 explains that the early warning notification sirens are 11 activated by a microwave signal from the Sheriff's office to 12 three transmitter staticns at Cuesta Feak, Rocky Butte, and 13 Davis Peak.
i 14 A.
What are the seismic qualifications of the 15 Sheriff's microwave equipment and the three j
16 transmitter stations noted above?
Describe all 17 documents which relate to the seismic 16 qualification of this equipment.
19 B.
In the event the Sheriff's microwave equipment t
20 fails, three backup encoders, located at County 21 fire stations, can be used to activate the early 22 warning notification sirens.
3 23 (1)
What procedures exist for use of these 24 alternate activation systems?
25 (2
What are the seismic qualifications of these 26 backup encoders? d we-,, -,,
--v
--mmm
_.m-,
~_-__,..c.,,.
-,-,,.,,.. -,._,.m
_ _ - -. -,. ~. -.., -... -
t 1
(3)
At which County fire stations are these 2
encoders located?
3 4
ANSWER TO INTERROGATORY NO. 35:
5 A.
The transmitter equipment that is being 6
purchased for this application is not seismically 7
quallfled.
All other structures and equipment are not 8
owned or maint.ained by PGandE and information relating 9
to their seismic design is unknown.
10 B.
(1)
The County Emergency Plan SOP for the San 11 Luis County Sheriff's Department includes the 12 procedure for activation of the early warning 13 system and the method for contacting the 14 backup locatione.
Final operating 15 procedures, based en the instruction sheet 16 for encoder operation, will be written for 17 each location when the backup system is 18 completed.
19 (2)
The backup encoders have not been seismically 20 tested.
These encoders are desk-top models, 21 about the size of a telephone.
22
///
I 23
///
1, 24
///
25 i
26 - - -,
1 (3)
The equipment for backup activation has not 2
been installed.
The original fire department t
3 locations did not have 24-hour dispatch 4
capabilities and the activation sites have 5
therefore been moved to the local sheriff's 6
departments.
7 8
9 10 INTERROGATORY NO. 36:
11 At page 7-35 of th PG&E Emergency Plan, PG&E 12 states that "the central computer sub-system is the heart of 13 the emelgency dose assessment and response system."
14' A.
Has the central computer system referred to above 15 been classified as safety-grade equipment?
16 B.
I f the answer is no, explain the rationale for 17 this decision.
18 C.
If the answer is yes, describe all analyses which 19 document that the computer meets safety-grade 20 requirements.
21 22
. ANSWER TO INTERROGATORY NO. 36:
23 A.
No.
24 B.
Regulatory requirements state the need for 25 the ability of the licensee to promptly determine the 26 extent of any potential or actual accidental release of 1
radioactive materials from the plant, assess the 2
potential or actual consequences that may result from t
3 the accidental release of radioactive materials on the
~
4 public health and safety, and to distribute such 5
information and assessments to the various emergency 6
response centers.
The central computer in the EARS 7
system is only one of several means to determine, a
assess, and distributa radiological information.
Ct,r 9
means in the form of personnel actions (manual sample 10 collection, calculation, etc.) and backup computers, 11 data and voice communications links prov'de the 12 capability to determine, assess and distribute 13 radiological information in emergency situations.
On 14 this basis, and on the fact that the central EARS 15 computer is not involved with nuclear safety related 16 activities, the central EARS computer is not considered 17 to be safety related.
18 C.
Not applicable.
19 20 21 22 INTERROGATORY NO. 37:
23 (a)
Describe the power source configuration for 24 the Diablo Canyon pressurizer heaters.
(b)
What other 25 power source configurations were evaluated by PG&E to supply 26 power to the pressurizer heaters?
(c)
What is PG&E's. _ -
I rationale for its choice of configuration?
(d)
If the 2
heaters were classified as safety-grade, what configuration 3
would be utilized?
4 5
ANSWER TO INTERROGATORY NO. 37:
6 (a)
The power source configuration for the 7
pressurizer heaters at Diablo Canyon Power Plant has a
been described in PGandE's submittel to the NRC dated 9
January 26, 1981, responding to the requirements of 10 Item II.E.3.1 of NUREG-0737, copies of which were 11 served on all parties.
In addition, the power source 12 configuration was discussed in detail, including a 13 point by point evaluation of the pressurizer heater 14 power supply design with the requirements of 15 NUREG-0737, in PGandE's answer to Joint Intervenors' 16 interrogatories (pp.
45-67) relating to Joint 17 Intervenors' Contention 11 for low power test 18 proceedings.
This information was served on all 19 parties March 16, 1981.
20 (b)
None.
21 (c)
PGandE chose the power source configuration 22 for the pressurizer heaters to comply w.th the 23 requirements of Item II.E.3.1 of NUREG-0737.
24
///
25
/7/
26
///
~
1 (d)
If the pressurizer heaters were classified as 2
safety-grade, the power source configuration would be t
3 the same as the present design'.
4 5
6 7
INTERROGATORY NO. 38:
8 What is the reliability of the power sources for 9
.the Diablo Canyon pressurizer heaters?
Describe all 10 documents which relate in any way to the reliability of 11 these power sources.
12 13 ANSWER TO INTERROGATORY NO. 38:
14 PGandE objects to this interrogatory as being 15 beyond the scope of Joint Intervenors' Contention 10.
There 16 are no safety grade requirements that define an acceptable 17 level of reliability of " components important to safety."
18 In addition, the interrogatory lacks specificity 19 in that reliability is not defined, the power sources of 20 interest are not identified, the conditions related to l
21 reliability aspects are not identified, etc.
22 23 24 25 26 6 a
1 INTERROGATORY NO. 39:
2 What is the worst case loading on the busses-t 3
supplying power to the pressurizer heaters at Diablo Canyon?
4 Include in your answer a description of the types of loads, 5
whether they are starting or transient loads, and the time 6
they are likely to occur.
7 8
ANSWER TO INTERROGATORY NO. 39:
9 PGandE objects to this interrogatory as being 10 beyond the scope of Joint Intervenors' Contention 10.
The 11 loading on the busses to the pressurizer heaters, whether 12 being the worst case or the nominal case, is not related to 13 how the components are classified with respect to 14 "importance to safety."
15 16 17 18 MTERROGATORY NO. 40:
19 For what seismic and environmental conditions have 20 the Diablo Canyon pressurizer heaters and related 21 structures, instruments, controls and power sources been 22 qualified?
Include in your answer a description of all 23 analyses and other documents which relate in any way to 24 qualification of these heaters.
25 26._
1 ANSWER TO INTERROGATORY NO. 40:
2 The pressurizer heaters and associated controls t
3 are not required by NRC regulations to be classified as 4
"important to safety" and therefore are not required to meet 5
all safety grade design criteria.
Therefore, the 6
pressurizer heaters have not been gaalified for any specific 7
seismic event.
However, their design does ensure that the 8
pressure boundary of the pressurizer is not jeopardized by 9
penetrations in the pressurizer vessel fcr the external 10 electrical connections to the heaters.
11 To comply with item II.E.3.1 of NUREG-0737, 12 certain controls and power sources for the pressurizer 13 heaters have been designed to withstand the postulated 14 Hosgri seismic event.
These include:
15 1.
The emergency diesel generator 16 2.
4}'V vital switchgear 17 3.
480V vital circuit breaker 18 4.
480V vital load center / motor control center 19 which are required to provide protection to the emergency 20 bus supplying power to the pressurizer heaters.
21 None of the instruments or controls aoJociated 22 with the pressurizer heaters are subjected to a harsh 23 environment and therefore they have not been qualified to 24 specific environmental conditions.
25 The pressurizer heaters were manufactured to 26 Westinghouse Equipment Specification 676440, Rev. 4 and >
1 Addendum 677231, Rev. O.
The following tests as required by 2
the Westinghouse specification were per med by the 1
r 3
supplier of the pressurizer heaters:
4 1.
Continuity test 5
2.
High potential test 6
3.
Radiography - full length examination in two 7l planes 90 degrees apart i
8; 4.
Megger resistance test i
9' 10 11' 12 INTERROGATORY NO. 41:
13 What accident or off-normal conditions at Diablo 14 Canyon would require the pressurizer heaters to operate?
15 16 ANSWER TO INTERROGATORY NO. 41:
17 Although alternative methods of reactor coolant 18 system (RCS) pressure control are available, procedures for 19 the Diablo Canyon Power Plant indicate the pressurizer 20 heaters could be used:
21 1.
After a postulated loss of offsite power; 22 2.
Following design basis accidents in which the 23 safety injection system is manually or 24(l automatically initiated; and 25
///
26
///
1 3.
Following anticipated events in which reactor trip 2
is manually or automatically initiated.
L 3
4' 5
6 I
7i INTERROGATORY NO. 42:
n 1
8 (a)
Are the pressurl:er heaters anticipated to be 7
ut:11:ed at Diablo Canyon when natural circulation needs to 10 be establisned?
(b)
If so, which emergency operating i
lli procedure (s) would-be involved?
(c)
What action or actions 12 would be planned in the event that natural circulation needs 13 to be achieved at Diablo Canyon and the pressurizer heaters 14 and/or the power sources taereto are not operative?
15' 16 ANSWER TO INTERROGATORY NO. 42:
17 (a)
Yes.
18 (b)
EP OP-0, REACTOR TRIP WITH SAFETY INJECTION 19 EP OP-1, LOSS OF COOLANT ACCIDENT 20 EP OP-2, LOSS OF SECONDARY COOLANT 21 EP OP-3A, STEAM GENERATOR TUBE RUPTURE 22 EP OP-4, LOSS OF ELECTRICAL POWER 23 EP OP-8, CONTROL ROOM INACCESSIBILITY 24 EP OP-13, MALFUNCTION OF REACTOR PRESSURE CONTROL SYSTEM 25 EP OP-23, NATURAL CIRCULATION OF REACTOR COOLANT 26 EP OP-44, GASEOUS VOIDS IN THE RCS.
1 (c)
If the pressurizer heaters are not available, t
2 the operator can use either the normal charging and 3
letdown system or the high head safety injection system 4!
to maintain or restore RCS pressure at the nominal 5,f value.
Adoption of one of the two pressure control 6
modes in conjunction with maintaining an effective heat 7l sink in the secondary of the steam generator via the 1
8;'
auxillary feedwater system will ensure that the system i
9j can be stabilized following a postulated accident.
I loi If there is a loss of offsite power, the 11; pressurizer heaters would obtain power from the onsite 12 e.T.ergency power supplies.
13l 14 15 16 INTERROGATORY NO. 43:
17 What rationale is utilized by PG&E to justify 18 classification of the pressurizer heaters and related 19 instruments,
- controls, structures and power sources as 20 non-safety grade?
Provide all documents, analyses, or other 21 materials which relate in any way to this rationale.
22 23 ANSWER TO INTERROGATORY NO. 43:
24 It is PGandE's position that thu pressurizer 25 heaters and associated controls are not required to be 26 classified as safety grade components and therefore are not.
1 required to meet all safety grade design criteria.
- However, i
2 the pressurizer heater design associated with the capability 3
of obtaining power from the onsite emergency power supply 4
meets GDC 10, 14. 15, 17 and 20 of Appendix A to 10 CFR 50.
5.
Therefore, PGandE believes the method that has been used to 6
connect the pressurizer heaters to the onsite emergency 7
power supply is fully adequate.
8 PGandE's position is based on the fact that the 9
design of the pressurizer heaters meets the NRC regulatory 10 requirements including those arising from post TMI lessons 11 learned, specifically NUREG-0737.
12 The plant design, including operational practice 13 (training, procedures, etc.) provides alternative and 14 reliable methods of maintaining pressure control, and 15 therefore maintaining natural circulation, which use systems 16 and components designed to safety grade requirements.
17 Therefore, the pressurizer heaters and associated controls 18 are not classified as safety grade.
Further, there are no 19 NRC re gulations or requirements that require the pressurizer 20 heaters and their associated controls to be classified 21 safety grade.
The NRC Staff, on page A-2, NUREG-0578, 22 states there is a need to consider the upgrading of 23 those pressurizer heaters and associated controls to a 24 safety grade classification.
The NRC Staff further 25 states, on page 12 of NUREG-0878, "in the short term, 26 designs should be upgraded to provide the operator with the L
1 capi.bility to maintain natural circulation at hot standby 2
through the use of pressurizer' heaters when offsite power is 3
not available."
This last statement has become a require-4 ment as identified in item II.E.3.1 of NUREG-0737.
S' Fressurizer heaters and associated controls meet E
both the requirements of item II.E.3.1 and GDC 17 in terms 7
cf emergency on-site power supplies for the pressurizer 8
heaters.
Item II.E.3.1 does not require the pressurizer 9
heaters or associated controls to be designed to safety 10 grade requirements.
In fact item II.E.3.1 states, "Being 11' non-Class IE loads, the pressurizer heaters must be 12 automatically shed from the emergency power sources.
13 The NRC Staff's characterization of the 14 pressurizer heaters as non-Class IE.Ioads, by definition, 15 precludes them from being classed as safety grade 16 components.
17 16 1
19 20 INTERROGATORY NO. 44:
21 What is the status of the EPRI tests on block and 22 power operac.ed relief valves of the kinds utilized at Diablo 23 Canyon?
24 25 26. _.
1 ANSWER TO INTERROGATORY NO. 44:
2 PGandE objects to. this interrogatory on the basis i
3 of relevancy.
The EPRI valve performance testing program is 4
clearly outside the scope of Joint Intervenors' Contention 5
12, which concerns only classification of relief valves, I
6 block valves and associated circuity, and compliance with 7
design criterla.
8:
s I
i 10 11 INTERROGATORY NO. 45:
12 Have the structures, instruments, control systems, 13 and power sources supporting and/or relating to the block 14 and relief valves at Diablo Canyon been analyzed and 25 quali fied for all potential operating and accident 15 conditions?
17 A.
If so, describe these analyses and all other 18 documents relating thereto.
19 B.
If not, why have these analyses not been carried 20 out?
21 22 ANSWER TO INTERROGATORY NO. 45:
23 The instruments, control systems and backup power 24 sources supporting and/or relating to the safety-related 25 block and relief valves at Diablo Canyon have been analyzed 26 and qualified for the conditions to which they may be -
1 subjected, whether during normal operation or an accident.
2 Analyses and qualification of structures for these velves k
3 are outside the scope of Joint Intervenors' Contention 12 4
and this portion of the interrogatory is objected to on that 5
basis.
6' A.
The conditions to which these instruments, control 7 1 systems, and backup power sources may be subjected i
8 have been described in the FSAR.
The analysis and 9
qualification of such instruments, control 10
- systems, and backup posar sources to those 111 potential conditions have been accepted by the 12 Staff, as indicated in SER Supplement 15.
13 B.
Not applicable.
14 15 16 17 INTERROGATORY NO. 46:
16 Does the EPRI test program for relief and block 19 valves cover structures, instruments, control systems, and 20 power sources of the type (s) utilized at Diablo. Canyon?
21 Provide the bases for your response.
22 23 ANSWEP TO INTERROGATORY NO. 46:
24 PGandE objects to thi interrogatory on the basis 25 of relevancy.
See the answer to interrogatory 44.
26 -
1 INTERROGATORY NO. 47:
2 Has PG&E seismically and environmentally qualified 1 3
the instrumentation, controls, structures and power sources 4
for its block and relief valves?
5-l 6'
ANSWER TO INTERROGATORY NO. 47:
1 7
PGandE objects to this interrogatory.
Environ-si mental qualification of equipment is the subject of another 9
contention, which is being considered separately by the 10 Board.
Furthermore, the seismic issue has already been 11' litigated and ruled upon by both the Licensing Board and the 12 Atomic Safety and Licensing Appeal Board.
13 14 15 10 INTERROGATORY NO. 48:
17 The power operated relief valves and block valves 18 at Diablo Canyon are not classified as safety grade.
What 19 is the rationale for failing to classify these items as 1
20 safety grade and what analyses, if any, have been conducted 21 to support such classifiction as non-safety grade?
Describe 22 all such analyses and all other documents relating to the 23 question of the classification of block and relief valves.
24 25 26 1
ANSWER TO INTERROGATORY NO. 48:
4 2
The assertion made in the interrogatory is 4
3 erroneous.
4 All of the block valves have been classified as 5
components important to safety and meet all safety-grade 6l design criteria.
Two of the three relief valves at Diablo i
7' Canyon have been classified as sa'fety grade components and meet all applicable safety-grade design criteria.
The 9
remaining valve, which does not meet safety-grade design 10
- criteria, was installed to provide 100 percent load 11 rejection without tripping the reactor.
It provides no 12 s afety-related function.
The following materials have been 13 Identified as relating to the classification of block and 14 relief valves:
15 FSAR Sections:
16 3.1 Conformance with AEC General Design Criterai 17 3.2 Classification of Structures, components and Systems 18 3.6 Criteria for Protection Against Dynamic Effects 19 Associated with a Postulated Rupture of Piping 20 3.9 Mechanical Systems and Compo"ents 21 5.2 Integrity of the Reactor Coolant System Boundary 22 15.1 Condition I-Normal Operation and Operational Transients 23 24 25 26.--._
r-1 INTERROGATORY NO. 49:
L 2
Does PG&E intend tu rely on block and/or relief 3
valves during an emergency situation such as a
4 loss-of-coolant accident?
Provide the bases for your 5
- response, including identification of all emergency 6'
operating procedures related thereto.
7 8
ANSWER TO INTERROGATORY NO. 49:
9 PGandE is prepared to utilize block and/or relief 10 valves dLring an emergency situation such as a
11 loss-of-coolant accident.
Postulated transients have been 12 analyzed which would result in conditions that necessitate 13 the operation of relief or block valves.
The following DCPP 14 Emergency Operating Procedures specify the use of relief or 15 block valves:
16 EP OP-0, REACTOR TRIP WITH SAFETY INJECTION 17 EP OP-1, LOSS OF COOLANT ACCIDENT 18 EP OP-2, LOSS OF SECONDARY COOLANT 19 EP OP-3A, STEAM GENERATOR TUBE RUPTURE 20 EP OP-4, LOSS OF ELECTRICAL POWER 21 EP OP-5, REACTOR TRIP WITHOUT SAFETY INJECTION 22
///
23
///
24
///
25 26 I L.-
4
'\\,
1 EP OP-13, MALFUNCTION OF REACTOR PRESSURE CONTROL 2
SYSTEM 3
EP OP-22, EMERGENCY SHUTDOWN 4
EP OF-38, ANTICIPATED TRANSIENT WITHOUT TRIP 5
6 7
8; Respectfully submitted, i
9; MALCOLM H. FURBUSH 10 PHILIP A. CRANE, JR.
RICHARD F. LOCKE 11 Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94120 12 (415) 781-4211
~
13 ARTHUR C. GEHR Snell & Wilmer 14 3100 Valley Center Phoenix, Arizona 85073 15 (602) 257-7288 16 BRUCE NORTON 17 Norton, Burke, Berry & French, P.C.
3216 N. Third Street Suite 300 18 Phoenix, Arizona 85012-2699 (602) 264-0033 19 20 Attorneys for Pa Gas and Electr Compan' =2'
21 e
22 B;
[
Ph'<'ip A.
ane, Jr.
23 24 DATED:
November 3, 1981.
25 26 -
5/El
-a;e, ci.
PACIFIC GAS AND ELECTRIC COMPANY DEPAR~NENT OF NUCLEAR PLANT OPERATIONS DIABLO CANYON POWER PLANT UNIT N05. 1 and 2 TI LE:
RcCIOL3GICAL E.MERGENCY PLAN AND R-PROCEDURES EXAP 1.
In the event of a Radiological Emergency, which of the followinc t
will initially assume the position of emergency coordinator:
a.
Security Supervisor b.
Shift Foreman c.
Security Shif t Suoervisor d.
CAS Ocerator.
2.
The Site 0:ergency Signal:
a.
Chir:s 0.
Is a steady siren c.
Has a cna racteris tic sound which is a rapid rise in citen followec oy a slower drop.
c.
Is a beil.
3.
I# you are escorting someone in the plant protectec area wnen the emergency signal souncs, where do you take them?
a.
The Adninistration Building o.
Raciation Access Control c.
Security Building c.
Control Room A.
I# you are in the containment when the containment evacuation signel sounds, you would immeciately leave anc gc to:
a.
The Control Room b.
Radiation Access Control c.
CAS 0.
Auxiliary operator's office 85' elevation 5.
Tne # ire signal:
a.
Chir;s b.
Is a monotone siren followed by a two-digit bell code call c.
Is a warbler siran followed by a two-digit bell coce call c.
Is a bell.
I 6.
When the rotating amoer light is on in areas equioped with the l
Cardox fire suppression system, this indicates the system has s s i
been turned off:
a.
True l
b.
False l
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a.
Imetiately call tne mif: fore-ar. if :nere is a pnene in the :c:.
3 Irr,eciately leave arc ; oceec to raciation a::ess control an: eocr:
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r Raticio;' cal Ere"gency Plan and R Procedures Exam 14 Whien agency is notified by the plant first in the event of an emergency s1:uation:
a.
NRC b.
FEMA 1
c.
State of California d.
San Luis Obispo County 1[.
If a site evacuation is ordered, where do personnel go:
a.
Home o.
San Luis Obispo ?G&E Service Center Designa ec off-site assemoly area for monitoring prior to release c.
c.
Sai. Luis Obispo County Sheriff's Office.
16.
If called in for response to an emergency situation where de you report:
a.
Visitors Center Acministrat cn Builcing 4
b.c. Tecnnical Supoort Center Operational Support Center (Security Building luncn room).
c.
17.
Foilowing sounding of the site emergency signal you are tne rarser in charge of your assembly area.
Where will instructions come f rom-a.
Security Shift Supervisor b.
Site Emergency Coordinator c.
Plant Manager c.
From b through a.
18.
At 10:00pm one of two mechanical maintenance personnel worxing on a radwaste concentrator is severely injured by falling due to a succen leak on the concentrate pumo. His companion helps him to Access Contrcl where you are the RPM on shif t.
You shoulc:
a.
Assist in care of the injury b.
Notify the Control Room to request an ambulance Detennine the extent of contamination involved with the injury c.
d.
All of the above.
You are entering the radwaste storage area on the east side of the plant 19.
alone to label waste containers, and notice a box of dry waste is smoking.
You should:
Discharge a fire extinguisher in the box and then continue your a.
labeling.
Exit the area, go to a phone dial 779-21 and remain on the phone b.
Get your labeling done and report the smoke to your supervisor c.
af terwards.
.Rac4cle;ical Er.er;ency clan and R D-occdure Exem
- 20. While on the graveyard shif t the Shift Foreman calls and reauests a raciation survey arourd the waste drumming station due to an area alarm inoication.
Upon entering the area, you report 150 mr/kracove the normal amoient radiation. The Shift Foreman declares an Alert Energency condition anc notifies the following:
(
San Luis Obispo County, State office of Emergency Sersites, NRC a.
b.
Plant Manager, Plant Superintendent, Plant Engineer, Supervisor of Cher.istry and Radiation Prctection.
c.
Manager of Nuclear Plant Operations d.
All of tne aoove.
LECTURE NOTES EPD 350 MAINTENANCE AND REPAIR UNDER RADIOLOGICAL Emergency Conditier I.
Introduction 1.
Purpose of Course 2.
Review of Basic Actions in the Event of an Emergency Onsite I:.
Site Energency Plan 1.
Purpose 2.
NRC Re;uirements Summaci:ed 3.
Summary and Organization 4
Emergency Procedure 5.
51te Emergency Organization 5.
Cor: orate E.P. Interfaces 7.
Emergency Facilities III.
Emergency Action Levels IV.
Acministration Under Emergency Conditions 1.
Site Assembly and Accountability 2.
Use of the Operational Support Center 3.
Communication With The. Technical Support Center J
Pace i of E l
MAINTENANCE AND Rect:R (*.,
RADIOLOGICAL EMERGENCY CONC:T:.
1.
Introduction l.
Purpose of Course This course is intendec to provide a broad overview of the Diabic Canyon Emergency Plan and those implementinc crotecures cealing with topics sucn as organization, communications, emergency facilities anc resconsibilities in an emergency situation.
- is intentec for those who may have tne resconsibility to perferr their ncrmai activities (maintenance and repair) uncer acnormal conc't cr.s wnen the Site Emergency Organization is in effect.
2.
Review of Basic Actions in the Event of an Emergency Onsite.
Refer to the lecture notes for EPD-600.
II.
Site Emer;ency Plan 1.
Purcose - A) Cemonstrate compliance witn NRC recuirements for Emergenc;.
F i a nr.i ng.
B) Provide an overview of the crganization, facilities, ecuipment and pencedures usec in an emergency anc in maintaining emergency prepa.caness.
2.
NRC Recuirements Summarizec:
10CFR50.33 Contents of Applications Must submit state and local Raciological Erergency Plans for ar.
Operating License.
10CF050.47 Emercency Plans Must have finding for an operating license that the state of onsite anc offsite emergency prepareoness provides reasonable assurance inat protection measures can and will be taken in the event of a radiologica'.
emergency.
Federal Emergency Management Agency (FEMA) to review state and local emergency plans.
FEMA finding of adequacy is a rebuttable presumption in NRC proceeding.
Sixteen standards for Emergency Plans defined.
Emergency Planning Zones set:
Plume Exposure Pathway = 10 miles Ingestion Pathway = 50 miles
_ _ ----- _- _ -_- _ _ ----------____ _ _ J
Lec ure Notes E ;-350 3.
Summary and Organization A.
Organization and Contents 1)
Definitions - Brief definitions of unusual terms.
L 2)
Scope and Applicability - Establishes purpose of document.
3)
Swatary - brief summary of following sections.
a)
Emergency Conditions - Contains information on the incertifi-cation anc classification of an emergency situation.
This information is basically the same as that in Procecure GA-1.
Stancard NRC emergency action levels are used to facilitate identification and non-tecnnical assessment of energency concitions.
These come from NUREG-0654, Accenciv Tne use of emergency action levels assist various affectec parties in understanding the potential severity anc initiatin; a precianned response during the early stages of an emer;ency situation.
Examples of Diabic Canynn conditiens for eacn emer;-
ency action level are also included in Section 4.
5)
Organizational Control of Emergencies - The normal piant operating and energency organizations are icentifiec in this section.
The Section also summarizes tne relationship between the plant staff and participating offsite emergency autnorities and responsibilities of individuals and organizations involvec in response organizations. - This section is the only place wnere sucn a surrary ex15:s without reviewing eacn of the incivi-cual plans.
6, Emergency Measures - Specific emergency response measures are outlined in this section.
The activiation and actions of the emergency organization, onsite evacuation, anc personnel injury are also accressed.
This information is summarizec from tne various emergency procedures.
7)
Emergency Facilities and Eouipment - Emergency control centers.
communication systems, anc assessment, prctective anc medical facilities are described in this section.
This is 61sc the only place where such a convenient summary exists.
8)
Maintaining Emergency Preparedness describes training, drills and exercises to be used to maintain emergency preparecness and the progrhm for emergency plan reviews and equipment maintenance.
9)
Recovery - describes general plans for restoring the plant to a safe status.
- 10) Appendices - Contains interfacing emergency plans and miscellantous information, such as a listing of emergency procedure and letters of agreement on emergency response.
Lccture Notes ECD-350 Interfacing Plans include:
a)
Corperate Emergency Plan b)
San Luis Obispo County Nuclear Power Plant Emergency Plan c)
State of California Nuclear Power Plant Emergency Plan t
d)
French Hospital Emergency Plan e) USD0E Radiological Assistance Plan f) Westingneust Emergency Responst Flen Letters of A;-eemen: Include:
a)
U.S. Guard - The Coast Guard crovices warning to craf:
off-snore in tne ever.: of a plart emergency.
b)
California Department of Forestry - CDF provices off-site suopor: in the case of a fire on-site.
c}
San Luis Ambulance Service - Provices ambulance service on-site in case of injurec, centamination victims.
4 Emergency Procecure Emergency procacures are located in volume 3 of tne plan: manual (Rec Book)
Volume 3 of the plant manual is in the control room, eacn supervisor's office anc a copy is available for inspection in the plant library.
The procecures are organized in the following catagories:
OP - Equipmen: Operation R - Radiological M - Miscellaneous GA - General Appendices A future addition to Volume 3 (3B) will contain the fcilowing series of procedures:
OR - Organization EF - Emergency Facility RB - Radiological (post accident) 5.
3ite Emergency Organization A.
Shift Organization The emergency plan and procedures permit broad discretion on the part of the Shift Foreman regarding assignments under emergency conditions.
Refer to Figure 1 for typical assignments.
The on-shift fire brigade contains a minimum of 5 persons.
These are designated as 1)
Senior Control Operator (Fire Captain)
- 2) Auxiliary Operator
Pace a of 5
.' Lecture Notes EDD-35C
- 3) Auxiliary Operator
- 4) Security Shift Superviser
- 5) Shift RPM L
In addition two fire crews are established from plant personnel nomally on-site during normal working hours.
B.
Long Tem Organization The icng tem orgae.ization is also flexible at the discretion c#
tne Site Emergency Coordinator.
The general structure is shown on figure 2.
As indicated a minimum number of these positions must be fillec at the Alert (in highed emergency leve:
c.
Corporate EF Interface The corporate emergency response organization i:; headec by a Corporate Emergency Coordinator (nomally tne Vice Presicent Nuclear Power Generation) while technical direction and contrcl is uncer a Recovery Manager (nomally the Manager-Nuclear Plant Operations).
Figure 3 shcws the organization structure.
Assistar.e
.o the site organization is suppling material or manpower for re:11rs would be provided under the control of the Corporate Tecnnical and Logistical Coordinator (normally the Manager, Nuclear Projects' with the organizations shown in figure 4 and 5.
Interface with the Corporate response organization for maintenance and repairs assistance is through the Emergency Maintenance Coordinator.
Besices PG&E assistance, further aid may be obtained through Westing-house, agreements with other utilities or other vendors or consultants.
7.
Emergency Facilities she primary emergency facilities are the control room and the H.P. and i
l Chemistry labs.
The experience at TMI-2 with control room overcrowding l
anc hign raciation in the plant has lead to the establishmer.t of facil-ities away from the control room to accommodate emergency response.
A.
Technical Support Center (TSC)
The TSC has been established to move emergency response and re;.overy l
management at the plant out of the control room but still provide a radiologically hardened facility.
l l
The TSC is located on the Unit 2 buttresses.
It consists of seven l
rooms, one of which is dedicated to HVAC equipment.
The structure is seismic class 1, shielded and the ventilation is connected to the control room pressurization system.
This facility has the RMS Health Physics and Harris computer facilities and has comunicat-l ions equipment installed (telephone and radio).
A closed circuit TV monitor system and video camerat in the control room provide plant status monitoring.
Office space is provided fcr plant person-nel and NRC.
A health physics counting laboratory is also being installed in the south end of this facility.
Le::ure Totes EDC-25C B.
Operational Support Center The secur ity building lunch room has been designated as the ocera-tional support center in the event of an emergency.
Its function is to provide space for personnel awaiting emergency response assignment, where they are readily available, but away from the
{
control room, laboratories or the TSC.
Direct communication with the TSC is available from this facility.
C.
Off-site Facilities Visitors' Center The visitors' center off highway 101 has communications inclucing ar.
NRC, red onone, blue pnone, plant phor.c, racio anc emergency kit.
It has the potential for being used as a site evacuation asser.oly area, an of'-site monitoring coordination area anc is, at less:
temporarily, the backup EOF.
Emergency Operations Facility (EOF)
The EOF is located at the SLO county Sheriff's office off Highway I between San Luis Ooispo anc Morro Bay.
It is a trailer office equipoed with emergency power, emergency communications and computer display equipment.
It is immediately acjacent to the county emergen:y operations center (EOC) whicn is the inservice training facility at the county jail.
Overall response management will be concucted here.
Real Time Radiation Monitors A network of 9 radiation monitors will be located off-site to provice general area readings from Morro Bay to south of Oceano.
Data from these monitors will be processed by the EARS system.
This informa-tion will assist in off-site monitoring and will be available to off-site authorities as well as the other parameters monitored by EARS.
Early Warning System This is a network of civil defense sirens to provice a capability to alert the public to an emergency condition in a short period of time.
An emergency broadcast system (EBS) will follow the alerting siren signal to provide people instructions and information on what protec-t1ve actions may be recommended by the autho.ities.
This system is required by NRC to extend to the 10-mile EPZ.
Our present intention is to cover heavily populated areas from Cayucos to Oceano.
This system is under the cont ol of San Luis Obispo County.
D.
Portable Emergency Equipment Radiological monitoring and respiratory eouipr 'nt is available in sufficient quantities on site. In addition em; gency supplies for monitoring and setting up controlled access areas are stored in the security building and off-site at the Visitors Center, Sheriff's office and Morro Bay Power Plant.
Page 6 of S Tecture Notes EDD-350 III.
Emergency Action Levels The NRC has defined four classes of Emergency Action Levels. These are:
L Notification of Unusual Event Alert Site Area Emergency General Emergency 1: is the responsibility of the plant to determine which class a giver situation fits.
The classification can be revised as the situation cnanges or more information is available, but the initial classification is very important as it determines:
a.
Tne extent of response by off-site agencies inclucing company, feceral, state, county ano city.
b.
The extent of immediate public alerting anc protective actions.
c.
The number of plant personnel called to responc.
The promptness of notifying off-site authorities.
NRC guid:.nes c.
class for notification within about 15 minutes for an unusual event anc sooner (consistent with the need for other energency actions) for otner classes.
Determination of the classification for an event is the responsibility initially of the Shift Foreman. This is assumed by the Site Emergency Coorcinator, when available.
Procecure guidance is provided to allow cetermining a classification basec either on tne type of s ant, or the actual (or potential) radiolog-ical effects. (examples of each classification)
tec;g? NCIEE Cf-aG IV.
Acministraticr, uncer Emergency Concitions A.
Site Assembly anc Accountability (see procedure GA-3 for a oescription of the accoantability process).
B.
Use of the Operational Support Center 1
The Operational Support Center is intended as an initial staging area for persnnnel reporting on-site in an emergency or for persons retained on-si ce awaiting assignment in an emergency situation.
It is expected that personnel with specific assignments will be movec to a location where the work is to be perfomec or in the case of complex joes, to a staging area for that activity (ie tne sno:s or labs).
Personnel er.tering or leaving the site snoulc check in anc out of the OSC to paintain a current status of on-site per'sonnel.
C.
Co:=unication witn the Technical Support Center 1.
Telephone The plant has three telephone capabilities:
a.
Computerized Branch Exchange - (Rolm CEX), handles outgoing (FT C calls and connect to the Company private automatic branch ex-change (PABX).
Most pnones in the TSC are on the CSX.
b.
PABX - Handles only calls within the PGandE private telephone system.
Most phones in the piant are on this system.
c.
Decicated chones - Go between the T5C and the following:
1)
Control Roor 2)
OSC 3)
EOF 4)
County Sheriff's Office 5)
State DES The CBX is progra:med to give the TSC, and other emergency extensiens priority access to available lines and sole acce:s to certain emerg-ency service lines.
In orcer to maintain this priority service, normal plant onones (and other in the PG&E system) cannot call direct to the TSC.
They can be called from the TSC phones.
Calls to TSC extensions from plant phones will be divertec to a pnore control console in the TSC where they can be forwardec to the desire:
extension.
Outside calls to the plant nomal number will be diverted to the TSC if the administration building phone console is off anc the TSC phones are manned.
Priority will be given to answering a special plant phone number designated for emergency use only.
Phone calls on both numbers divert to the control room if both the administration building and TSC phone console are off.
^
. ra; e ?.c:es Le. _.
c.a 2.
Radio The TSC has access to 6 plant radio-frecuencies, 3 of which are for local use-only. These are:
(
Operations Security Health Physics i
j
'Portacle radies will be available for in plant use on these local J
fre::uencies to cormanicate with the TSC.
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1
'YPICA!. ON-SHIFT EMERGENCY ORGANI7ATICN AND ASSIGNMENTS t
Site 1
Emergency Ceredinatew i
f 1
t imergency Eme rge.7.cy Emergency l
Liaisen 1 0: era:1cns 1 Evaluations &
Coorcina:r-Coordi a r-Re eva-v c--
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i Shift Foreman (Sr. Control fnterim Site Emergency Coordinator Operator if not availa~le) o l
Shift Control Technician or
~
Znterim E.mergency Liaison Coordinator Auxiliary Operator
,s InteriE Emergency Operations Coordinat:r' Sr. Control Operat:r er Contrei l
Operator j
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SECOND SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GA5 AND ELECTRIC C0ti ANY I have assisted in preparing the answers to Interrogatories 16, 29, 31 Said answers are true and correct to the f.est c* my knowledge and belief.
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. L. Potter Subscribed and sworn to before me tr.is 2nd day of November,1981 FM MA SEAL Theodora Notary Public in ano for
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SECOND SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 3
Said answers are true and correct to the best of my knowledge and belief.
1 E. P. Wollak Subscribed and sworn to before me this 2nd day of November, 1981
' SEAL eodora Cooke, Notary Public in and for the City and County of San Francisco, State of California My Commission expires January 28, 1985
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.L GOVERNOR EDMUhD G. BROWN, JR.
SECOND SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC C0"PANY I have assisted in preparing the answers to Interrogatories 11 Said answers are true and correct to the best of my knowledge and belief.
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' Ann Hartwell-Spann Subscribed and sworn to before me this 2nd day I
of November, 1981 1
SEAL Theodora Cooke, Notary Public in and for the City and County of San Francisco, State of California i
My Commission expires January 28, 1985
GOVERNCR EDMUND G. BROWfi, JR.
t SECOND SET OF INTERR0GATORIES
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APO THIRD REQUEST FOR PRODUCT 10N OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMFANY I have assisted in preparing the answers to Interrogatories 3
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62 tat P. D. Newell i
i Subscribed and sworn to before me this 2nd day of Nover.ber, 1981 SEAL TKeodora Cooke. Notary Public in and fcr the City and County of San Francisco, State of California My Cox.ission expires January 28, 1985
1 GOVERNOR EDMUND G. BROWN, JR.
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SECOND SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC C0!'PANY I have assisted in preparing the answers to Interrogatories 10 Said ansv;ers are true and correct to the best of my knowledge and belief.
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.T0 PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 1, 3, 4B,C, 9, 12, 24, 34 Said answers are true and correct to the best of my knowledge and belief.
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. ficDevitt Subscribed and sworn to before me this 2nd day of November, 1981 SEAL TheodoraCooke,NotaryPublic in and for the City and County of San Francisco, State of California My Cc;nmission expires January 28, 1985
GOVERNOR EDMUND G. BROWN, JR.
1 SECOND SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS
__ TO PACIFIC GAS AND ELECTRIC CCMFANY I have assisted in preparing the answers to Interrogatories 2
Said ansviers are true and correct to the best of ry knon' ledge and belief.
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Subscribed and sworn to before me this 2nd day of November, 1981 SEAL heodora Cooke, Notary Public in and for the City and County of San Francisco, State of California 1
My Commission expires January 28, 1985
GOVERNOR EDMUND G. BROWN, JR.
SECOND SET OF INTERROGATORIES
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AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PA:!FIC GAS AND ELECTRIC COMPANY I have assisted in preparing '.he answers to Interrogatories 33, 35A Said answers are true and correct to the best of my knonledge and belief.
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Subscribed and sworn to before me this 2nd day i
of November,1981 Egb SEAL j
Theodora Cooke, Notary Public in and for the City and County of San Francisco, State of California My Co-mission expires January 28, 1985
L GOVERNOR EDMUND G. BR0h'N, JR.
SECOND SET OF INTERROGATORIES
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I have assisted in preparing the-answers i
to Interrogatories 14, 15, 34A, 35B
. Said answers are true and e ret D the best of my knowledge and belief.
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K. fl. Godfrey
/ 8 Subscribed and sworn to before me this 2nd day of November,1981 SEAL Theodora Cooke, Notary Public
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GOVERNOR EDMUND G. BROWN, JR.
SECOND SET OF INTERROGATORIES
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AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 8
Said answers are true and correct to the best of my knowledge anc belief.
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T. A. Mack Subscribed and sworn to before me this 2nd day of November,1981 SEAL Theodora Cooke, Notary Public in and for the City and County of San Francisco, State of California My Commission expires January 28, 1985
GOVERNOR EDMUND G. BROWN, JR.
SECOND SET OF INTERROGATORIES
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TO PACIFIC GAS AND ELECTRIC C0fGANY t
I have assisted in preparing the answers to Interrogatories 2 0,41, 42, 49 Said answers are true and correct to the best of my knowledge and belief.
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W.H.FpMOTO Subscribed and sworn to before me this 2nd day of November, 1981 SEAL Theodora Cooke, Notary Public in and for the City and County of San Francisco, State of California My Comission expires January 28, 1985
GOVERNOR EDMUND G. BROWN, JR.
SECOND SET OF INTERRDGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY J
I have assisted in preparing the answers to Interrogatories 37, 38, 39, 40, 43 Said answers are true and correct to the best of my knowledge and belief.
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Subscribed and sworn to before me this 2nd day i
of November, 1981 l
E SEAL Theodora Cooke, Notary Publi~c in and for the City and County of Scn Francisco, State of California i
My Commission expires January 28, 1985 t
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GOVERNOR EDMUND G. BROWN, JR.
SECOND SET OF INTERROGATORIES AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY t
I have assisted in preparing the answers to Interrogatories 37, 40, 45 Said answers are true and ccrrect to the best of my knowledge and belief.
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Subscribed and sworn to before me this 2nd day of November, 1981 SEAL heodora Cc3ke, Notary Public in and for the City and County of San Francisco, State of j
California My Connission expires January 28, 1985 i
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t I have assisted in' preparing the answers to Interrogatories 4, 5, 6, 7,
17, 21, 23, 26, 27, 28 and 30.
Said answers are true and correct to the best of my knowledge and belief.
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My Commission Expires May 4, 1984
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GOVERNOR EDMUND G. BROWN, JR.
SECOND SET OF INTERROGATORIES 0
AND THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY I have assisted in preparing the answers to Interrogatories 44, 46, 47, 48 Said answers f
are true and correct to the best of my knowledge and belief.
G. C. WU Subscribed and sworn to before me this 2nd day of November, 1981 A SEAL lheodora Cooke, Notary Public in and for the City and County of San Francisco, State of California My Comission expires January 28, 1985
- 6
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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1 PACIFIC GA3 AND ELECTRIC COMPANY
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Docket No. 50-275
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Docket No. 50-323 Dinblo Canyon Nuclear Power Plant,
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Units 1 and 2
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(Full Power Proceedinci
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CERTIFICATE OF SERVICE The foregoing document 0Si of Pacific Gas and Electric Company hos (1:ard been served today on the follcwing by deposit in the United States mail, properly stamped and addressed:
Judge John F. Wolf Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety and Licensing Board San Luis Obispo, California 93401 U. S. Nuclear Regulatory Commission W3ehington, D.
C. 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo, California 93401 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission John Phillips, Esq.
Wachington, D.
C. 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest Judge Jerry R.
Kline 10203 Santa Monica Drive Atomic Safety and Licensing Board Los Angeles, California 90067 U. S. Nuclear Regulatory Commission W2chington, D. C. 20555 David F. Fleischaker, Esq.
P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City C/o Nancy Culver Oklahoma 73101 192 Luneta Drive S2n Luis Obispo, California 93401 Arthur C. Gehr, Esq.
Snell & Wilmer l
Janice E. Kerr, Esq.
3100 Valley Bank Center Public Utilities Commission Phoenix, Arizona 85073 of the State of California 5246 State Building Bruce Norton, Esq.
350 McAllister Street Norton, Purke, Berry & French, P.C.
SSn Francisco, California 94102 3216 N. Inird Street Suite 300 Mrc. Raye Fleming Phoenix, Arizona 85012-2699 1920 Mattie Road Shall Beach, California 93449 Chairman Atomic Safety and Licensing Mr. Frederich Eissler Board Panel Sesnic Shoreline Preservation U. S. Nuclear Regulatory Commission Conference, Inc.
Washington, D. C. 20555 4623 More Mesa Drive S2nta Barbara, California 93105
'e Chnirman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing 1
U. S. Nuclear Regulatory Coccission Appeal Board Waehington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 S2cretary U. S. Nuclear Regulatory Commission Judge W. Reed Johnson W3gh pgton, D.
C. 20555 Atomic Safety and Licensing Appeal Board Attn.:
Docketing and Service Section U. S. Naclear Regulatory Commission W shington, D. C. 20555 a
isilliam J. Olmstead, Esq.
l.adley W.
Jones, Esq.
Judge John H. Buck Office of Executive Legal Director Atomic Safety and Licensing DETH 042 Appeal Board U. S. Nuclear Begulatory Commission U. S. Nuclear Regulatory Commission W3chington, D. C. 20555 Washington, D. C. 20555 Mr. Al7har6 B. Hubbard MHB Technical Associates 17'.2 "e'nilton Avenue, suite K Sn:' Je;e, California 95125 Mr. Carl Neiberger Talacram Tribune P. O. Box 112 San Luis Ooispo, California 93402 H2rbert H. Brown, Esq.
LawrGnce Coe Lanpher, Esq.
Chriotopher B. Hanback, Esq.
Hill, Christopher & Phillips 1900 M Street, N.W.
W3chington, D.
C.
20036 l
Byron S. Georgiou, Esq.
l Lagal Affairs Secretary l Governor's Office l Stato Capitol Sacramento, California 95814 N
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~ Phil 'p"AttorneCranh, Jr.
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Pacific s and Elec ric Company Date:
November 3, 1981 l
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