ML20032E068
| ML20032E068 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/13/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20032E064 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8111190588 | |
| Download: ML20032E068 (21) | |
Text
?
U 7
a UNITED-STATES OF AMERICA
,BILATED COERES?0KDENCE -
,f
. NUCLEAR REGULATORY COMMISSION I
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-DOCKETED USNRC
)
In the Matter of
)
- 81 NOV 16 P3:19
)
PACIFIC GAS AND ELECTRIC COMPANY
)
_ Docket Nos.. 5 0_- 225,,0. L.
)
50~32397fL.
~
(Diablo Canyon' Nuclear Power
)
,' "~'
Plant, Units 1 and 2)
) ~
)
GOVERNOR BROWN RESPONSE TO NRC STAFF REQUESTS FOR ADMISSIONS AND NRC STAFF THIRD SET OF INTERROGATORIES On October 21, 1981, the NRC Staff served Requests for t-Admission and a Third Set of Interrogatories on Governor Brown.
Each Interrogatory relates to the requested Admissions, asking in each instance to explain any reason (s) for not providing the-Admission as requested and to cross reference as appropriate-to applicable regulatory requirements.
Accordingly, since the-Ad-missions and Interrogatories are inter-related, they are answered in the single submission set forth below.
Admission 1.
The August 19, 1981 emergency planning exer-cise conducted in the vicinity of Diablo Canyon Nuclear Power Plant (DCNPP)-complied with 10 CFR S50. 4 7 (b), Appendix E to Part 50,-and applicable planning standards and evaluation criteria in NUREG-0654.
RESPONSE
The Governor cannot admit or deny Admission 1, be-cause the Admission request itself is ambiguous.
What is meant by an exercise "ccmplying" with Section 50. 4 7 (b), Appendix E to Part 50, and/or the planning standards and evaluation criteria of NUREG-0654?
81111905B8 8110@75 PDR ADOCK 050002 Q
le Governor, however,' believes that the thrust of this Acmission request concerns whether the Governor is satisfied with the scope-and/or-results of the August 19 emergency planning exercise and, if not, what areas of dissatisfaction may have been identified and how they relate to-regulatory requirements.
Based on the foregoing assumption, the Governor does have concerns con-cerning that exercise.
First, it is noted that in Appendix E to Part 50, a full-scale exercise should test as much of the licensee, State, and local emergency plans as is reasonably achievable without mandatory public participation.
The August 19 exercise, while valuable as a training tool, did not test as much of the emergency plans as reasonably achievable.
There was no realistic variation in weather conditions which frequently affect the San Luis Obispo area, there was no use of the northern evacuation route, notwithstanding the fact that ingress and egress to the Diablo Canyon site may be crucially dependent upon.that route under certain conditions, there were no simulated breakdowns of crucial systems or equipment or blockage or unavailability of any evacuation routes, there was no simulation of evacuation of remote I
regions of the LPZ, all affected cities were not involved in the exercise, and the scenario completely ignored the possible com-plicating effects of an earthquake on the Hosgri Fault or on any of the other faults in or near San Luis Obispo County.-*/ Further,
- /
E.g., PG&E Oct. 26 Response to Joint Intervenors' Inter-rogatories, pp. 52-53.
[...
the exercise related to.the May 1981-draft County Plan..Wefare informed, however,'that the'May. draft has'now been superseded by (an' October _1981 draft.
We have not yet received the new draf t but if revisions are substantial, it. clearly-could affect one's-appraisal of the usefulness of the August 19 exercise.
At this time, it is quite difficult to comment.in much greater detail regarding the emergency planning-exercise of August 19.
FEMA has not issued findings on the adequacy of. emergency prepared-
. ness at Diablo Canyon and until those findings are issued,-the proper conclusions to draw from the August 19 exercise simply
- /
cannot be made.
Notwithstanding the foregoing, however, the FEMA document entitled " Evaluation Findings -- Diablo Canyon.
Nuclear Power Plant Offsite Emergency Response Plans Exercise" suggests that the exercise, while successful in many respects, also identified specific problems that need to be corrected before-there can be confidence in preparedness at-Diablo Canyon.
We note below some of those problems:
(a)
Although a site area emergency was declared at 8:12 a.m.
and a general emergency was declared at 10:48 a.m., alerting and pro-tective actions, including evacuation and sheltering, were not-ordered for the general public until shortly after noon.
This is a savere delay which could have' obvious ramifications for the safety of persons requiring protective-actions.
10 C.F.R'.
S 50.47(b) (2), (4), (5), (75, (10), (14), (15).--**/
_/
We note in this regr.rd that the NRC Staff has repeatedly declined to present its position on offsite preparedness at Diablo Canyon pending those FEMA findings.
- /. See also related NUREG-0654 criteria for all C.F.R.
citations.
L.
.=.
-y ~
~(b)
The FEMA evaluation points out repeated problems with communications.. For instance, the radio link designed to be used for emergency action level verification did not-work due'to operator error. ' Further, the EOF failed to communicate properly with UDAC and, instead repeatedly funneled information directly to'the EOC.
10 C.F.R.
S 50.4 7 (b) (4), ( 5), (6), (8),
(9), (14), (15).
(c)
There is an indication that field monitoring units of San Luis Obispo County were not fully familiar with-certain of the procedures applicable to them.
10 C.F.R. ~ S 50.47(b) (6), (8),
(9), (11), (14), (15).
(d)
There is an indication that communications with tne cities (such as Morro Bay) which will be involved in emergency planning and preparedness were not adequate.to keep two cities in-formed in a neck exercise. These cc:T.unications will clearly he inadequate in a real life. situation where many more cities will be involved.
10 C.F.R.
S 50.47(b) (1), (3), (4), (5), (6), (14), (15).
(e)
See exercise critique in memorandum of Larry Garrett to Jim Watkins, August 31, 1981; exercise comments of State OES, all produced by the State in discovery.
In view of the identification of the foregoing problems, we cannot conclude that the exercise " complied" with the regula-tory and guidanc,e provisions cited by the Staff in Admission 1.
While the exercise certainly provided training, it also pointed
^
out shortcomings and weaknesses and the need to revise the 9
-,y w
-~~4
,y w,
v e-
,%y,
,----,c--g
,,,w--
,,r,-
-,,-m
.*we
,--e
emergency plans,-0/to continue and upgrade training, and1possibly the need for a further full field exercise, under realistic con-ditions, prior ~to any final conclusions on the adequacy of emergency planning and preparedness at Diablo Canyon.
See also San Luis Obispo County corrective action plan, dated October 30, 1981,_which identifies numerous problems arising from the exercise which need correction, attached as Exhibit A hereto; and recommendations in. Exhibits B-D hereto.
Admission 2.
Applicant's public information program for emergency planning and preparedness as described in Sec. 8.1.2.3 of the Emergency Plan (EP) Rev.
3, August 1981, for the DCNPP, and in its interrogatory responses in
" Applicant Pacific Gas and Electric Company's Answers to Governor Edmund G.
- Brown, Tr.'s First Set of Interrogatories" and ".\\pp icant Pacific Gas and Electric Company's Joint Intervenors' First Set of-Interrogatories" (SIC), ( Applicant's Responses) when imple-mented, will comply with 10 C.F.R. S 50.47 (b) (7), Appendix E to Part 50, and appli-cable NUREG-0654 planning standards and evaluation criteria.
RESPONSE
The PG&E public education program as described in Section 8.1.2.3 of the Diablo Canyon Emergency Plan is not complete.
That description is summary in nature and lacks many essential details.
However, in responses to Joint Intervenors' and Governor Brown's Interrogatories, PG&E has substantially expanded the inadequate descriptions set forth in the Plan and described in greater detail the various steps I
it intends to take and in certain cases is already taking to inglerent a public infornation program.
- /
A meeting for such purpose was held on October 15, 1981.
See PG&E October 26 Response to Joint Intervenors' Interrogatories, pp. 54-55.
w With several caveats, Governor Brown generally agrees that
'the steps outlined by PG&E represent a satisfactory method to provide the public with proper advance information of actions to be taken in the event of an emergency at Diablo Canyon.-*/
However, there is no evidence that these steps have been system-atically analyzed to ensure that they provide the best means to communicate these important data to the-public.
For instance, are inserts in telephone directories effective measures?
The same question could be raised about almost every step which PG&E proposes.
In its totality, PG&E appears to have covered most possible avenues of communication.
However, if there has been a failure to analyze which methods are best, its efforts may end up resulting in a public education program which is not as good as it might be.
Thus, until PG&E demonstrates that it has carefully designed its public information program using all available analytical tools, there can be no confidence that the program, if and implemented, will in fact be adequate.
A further concern must also be stated.
In response to the Governor's discovery requests, no public information documents were provided.
Additional documents have now been produced by
- /
-~
PG&E and presumably such documents will be provided.
Until that time, we cannot conclude that the actual pamphlets and other materials referenced by PG&E will in fact be adequate.
--*/
The Governor cannot admit that PG&E will properly and effect-ively implement its public information program.
Such imple-mentation relates to future actions, a matter which is properly addressed by testimony at the hearing.
- /
PG&E has indicated that it believes such documents were pro-vided in the first PG&E production.
At any rate, we have not yet had an opportunity to review any such documents.
Finally, certain specific deficiencies appear to be present:
(a)
There is a lack of specific attention to the special needs of the handicapped (NUREG-0654, p. 49);
(b)
There is a lack of attention to the needs of the transient population, especially persons in remote areas (Id. p.
- 50) ; and (c)
There is no evidence of systematic County activities to fulfill its public information responsibilities (Id. pp. 49-51).
Admission 3.
Applicant and local plans described in Applicant's EP, Section 6.3.4, Applicant's Responses, and San Luis Obispo County Nuclear Power Plant Emergency Response Plan (County Plan),Section I.6.E, II.5(1) Standard Year-ly Procedures, pertaining and applicable to notification of the public, comply with 10 CFR S50.47(b), Appendix E to Part 50, and applicable planning standards and evaluation criteria of NUREG-0654.
RESPONSE
Denied.
As clearly indicated at the August 19 emergency exercise, there was confusion and disagreement over when to take action to notify the public of a potential emergency at Diablo Canyon and when, after notification, to institute precautionary or mandatory protective actions.
Thus, notification of the public was delayed by many hours, instead of being given as soon as a site emergency was declared.~*/This confusion appears to relate, at least in part, from the overly generalized directives provided in the PG&E plan and draft County plan at this time re-lating to public notification.
--*/
The emergency exercise scenario produced by the Staff in discovery indicated that sheltering of persons within 5 miles of the plant should have been considered at 8:20 a.m.
See p.
III-5.
N
- It is our understanding that the County Plan and, perhaps also the PG&E Plan, are undergoing modification in these regards pursuant to the FEMA critique.
The Governor believes that public notification,at least to alert the public to stand by for further instructions, should commence at the earliest possible time and tnus alert the public. to the potential necessity of protective actions.
This was not the case on August 19 and it is not manda-tory in either plan at this time.
10 C.F.R.
S 50.47 (b) (2), (5),
(6), (7), (9), (14), (15) and related NUREG-0654 criteria and Appendix E, Parts IV(B)-(D), (F).
Admission 4.
Applicant, and offsite' plans to provide emergency notification and information to transient persons in Montana de Oro State Park and elsewhere in the plume exposure pathway EPZ for Diablo Canyon Nuclear Power
~
Plant designated in Applicant's draft Emergency Plan for Diablo Canyon Nuclear Power Plant, Revision 3 comply with 10 CFR 50.47(b); Appendix E to Part 50; and the applicable Planning Standards and Evalua-tions Criteria in NUREG-0654.
RESPONSE
Denied.
The Governor continues to have substantial concern concerning methods to notify transient persons in Montana de Oro State Park and elsewhere within the LPZ.
Where those persons are within easy access of a road, notification should not be difficult, and it is our understanding that siren systems should cover all such accessible areas.
However, the LPZ contains areas outside the reach of the proposed siren system.
These regions are utilized frequently by backpackers and hikers.
At this time, the County Plan merely provides that persons outside of the siren range "will be notified by sedans and off-road vehicles, carrying mobile vocal public address systems assisted
~
by helicopter surveillance and warning."
(See page 2.5(2).)
This is an entirely unsatisfactory planning statement.
Rather than such a statement, there needs to be actual efforts to devise and demonstrate a means of providing.a prompt alert to persons in the park backcountry.-*/
In this regard, the Governor was disappointed that the August 19 exercise did not include as part of its scenario the alerting of such persons.
10 C.F.R.
S 50.47 (b) (5), (14),- (15) ;
Appendix E, IV(D), (F); NUREG-0654~
pp._49-51..
Admission S.
Each agency represented in the San Luis Obispo County Emergency Operations Center -(EOC) established during the August 19, 1981 emergency planning exercises conducted in the vicinity of the Diablo Canyon Nuclear Power-Plant (DCNPP) demonstrated the capability of controlling access on traffic routes and performing a coordinated evacuation procedure, including the closure'and evacuation of the two State parks within the 10 mile EPZ.
RESPONSE
The Governor admits that FEMA in its evaluation of the August 19 exercise stated that the agencies in the EOC showed that they could provide access control on traffic routes and perform a coordinate'd evacuation procedure in accordance with the exercise.
FEMA also found that the state parks and beaches personnel fully staffed a complete closure and evacuation of two state parks in accordance with their plans.
The Governor does not dispute that the foregoing actions took place during the August 19 exercise, although the State Park closures and evacu-l ations only covered accessible regions.
There was no demon-
-*/
PG&E has stated recently that it has arranged for Rogers Heli-copter, Inc. to notify persons In the Park and that this capa-l bility has been demonstrated. See PG&E November 3 Response to Governor Brown, p.
2.
We cannot admit or deny the assertion, i
but note that there is no evidence that the County Plan incor-l porates Rogers for such purpose and there is no evidence that Rogers has received requisite training and can be on location in the necessary time frame.
i
,e,-
)
10-stration of-any ability to coordinate an evacuation of remote areas.- Further, the Governor also cannot agree -fully with the implications. of this Admission request.
First, there was no actual evacuation during the' exercise, except that involving some persons at a predesignated point in Montana de Oro State Park.
Thus,.the exercise ' demons trates very little about.the actual ability of response personnel' to perform-this function in an emergency sit'1ation.
At a minimum, a demon-stration of an unprearranged evacuation is necessary before any.
actual capability.could be said to be demonstrated.
Further, as noted earlier in these responses, the-scenario had s'erious short-comings in terms of lack of weather and earthquake complications and the lack of any unexpected breakdowns.
It is.thus speculative to conclude the EOC' personnel and agencies could' perform properly under those conditions, - since there has never been any _ testing or training for those conditions.
' Finally, to the extent this Admission request asks for actual facts relating to the ability to evacuate, etc., the Governor is not now in a position to respond.
We have not yet received the FEMA documents and thus lack necessary-underlying data.
10 C.F.R.
S 50.47 (b) (1), (2), (5), (14 ), - (15).
i l
Admission 6.
As a result of the emergency response plans drafted by Applicant,.the State of' California, and San Luis Obispo County, a coordinated standard emergency classification and action level scheme is, or will soon be, in use by the Applicant, State and County in accordance with 10 CFR S50.47(b) (4).
d f
M-"4 4
.A
=
m-4A a
e
RESPONSE
Assuming that San Luis Obispo County does in fact
~
adopt an emergency plan with classifications systems the same as those set forth in the May, 1981, draft plan, then each plan will contain basically the came coordinated emergency classification and action level scheme in accordance with Section 50.47 (b) (4).
Admission 7.
The latest draft (August 1981) of Applicant and County plans and procedures for providing prompt notification of the public in the event of a radiological emergency at DCNPP comply, or will comply when implemented, with 10 CFR S50.47(b), _ Appendix E to Part 50,'and applicable planning standards and evaluation criteria of NUREG-0654.
RESPONSE
Governor Brown cannot admit or deny this Admission request.
Governor Brown does not know what the Staff is referring j
to in its reference to the " latest draft ( August 19 81) of Applicant and County plans and procedures for providing prompt notification of the public.
The latest draft of the County Plan 1
(in our possession) dates-from May, 1981.
We note that FEMA, in l
1 its July 1, 1981 " Preliminary Review" of the County Plan, noted significant deficiencies and unaccomplished tasks respecting the i
May draft.
(This document was produced in discovery.)
gee alen i
responses to Admissions 1 and 3.
Admission 8.
The Staba of California Emergency Plan (" State Plan") for the Diablo Canyon Nuclear Power, Plant, as currently revised, meets the require-ments of 10 C.F.R.
S 50.47,'and Appendix E to j
Part 50.
i
RESPONSE
Denied.
The State of California plan does not, l
l as currently revised, meet the requirements of 10 C.F.R. 5 50.47 i
I and Appendix E to Part 50.
The plan is incomplete at this time 1
I because many necessary procedures have not yet been completely i
drafted and approved.
It is expected that such procedures will i
(
I L _
w f,-
be revised and approved by early 1982, at which time it is expected that the State Plan will meet applicable regulatory requirements.
We note that PG&E has taken the position in response'to Joint Intervenors' Interrogatories that the State Plan currently does not comply with certain regulatory requirements.
See pages 7-11' i
of PG&E Responses, dated September 2, 1981.
Admission 9.
Any necessary revisions to the State Plan to k
include in procedures,provided for in 10 CFR 50.47, Appendix.E of Part 50, and NUREG-0654 Planning Standards and Evaluation Criteria, plans and procedures taking account of the complicating effects of an earthquake will be completed by January 1, 1982.
RESPONSE
Denied.
It is uncertain if or when the State plan will be revised to take account of.the complicating effects of an earthquake.
The State already has an earthquake response plan and thus may not revise its nuclear response plan.
In the event, however, that it does revise the nuclear response plan, it is unlikely that this will be completed by January 1, 1982.
l Admission 10.
The State Plan is presently, or by January 1 1982, will be, fully integrated into the onsite and local offsite emergency response plans for DCNPP.
I
RESPONSE
Denied.
The State Plan is not presently fully integrated into the onsite and offsite emergency response plans for Diablo Canyon.
Indeed, it.would be impossible to be so integrated, since the County has not yet adopted an emergency plan and is not scheduled to do so until December, 1981.
- Further, the State OES only last week received the October revision of the County ple.n.
Notwithstanding the foregoing, the State of California, particularly under the direction of the State Office of Emergency 1
Services, has been working diligently to integrate the State Full response with PG&E and local emergency response plans.
integration, however, cannot be expected until after the County plan is adopted, until after State procedures are drafted and adopted, and until the local and onsite plans are revised to reflect the complicating effects of an earthquake.
It is unlikely all these steps will be accomplished by Janrary 1, 1982.
Admission 11.
The draft procedures for San Luis Obispo County Nuclear Power Plant Emergency Response Plan identified in item 30 of Governor Edmund G.
Brown Jr. Response to NRC Staff Document Request, page 2 of " Documents Available for Inspection and Copying," when taken together with the draf t San Luis Obispo County Nuclear Power Plant Plan itself, comply with 10 CFR S50.47(b), Appendix E to Part 50, and the planning standards and evaluation criteria of NUREG-0654.
RESPONSE
The Governor objects to this Admission request as overly broad and unanswerable.
First, the procedures identi-fied in item 30 are only some of the procedures which the County plans to have in effect or possibly in eftect once the emergency plan itself is adopted.
The draft procedures are all under revision and thus it is impossible to conclude that they plus a draft Fran that also is being revised comply with regula-tory requirements.
Second, it is not procedures or even a draft plan which complies with Section 50.47 and the other regulatory requirercents cited by the Staff; rather, it is emergency prepared-ness pursuant to plans and procedures which complies or will not comply with regulatory requirements.
Until a final plan and it is not procedures are provided and FEMA findings are issued, possible to formulate any comprehensive response to this request.
Admission-12.
The pluma exposure pathway EPZ's and ingestion path-way EPZ's_ adopted in Applicant's EP (Section 7. 2. 2. 3, Figure 7.2-2'and County's_ERP, Section~I.5,-and Attachment 'I.5-3), ' comply with 10 - C.F.R.
S50.47 (c),_
S50. 33 (g), Appendix E to Part-50,'and applicable-planning standards and evaluation criteria of-NUREG-0654.
RESPONSE
The regulatory orovisions cited by the Staff in this admission request do not specify precise plume exposure and ingestion pathway EPZ's which must be adopted.
- Rather, such EPZ's are to be adopted on a case-by-case basis.
The Governor believes that the State of California Extended Emergency-Planning Zone,-together with the_ State of California Basic Emer-gency Planning Zone, both of which are depicted on PG&E Figure 7.2-2, constitute a rationale and acceptable plume exposure planning zone for operation of Diablo Canyon.
The Governor also believes that the Ingestion Pathway Zone depicted in Attachment 1.5-3 of the draf t County plan (May.1981). is acceptable.
Admission 13.
Applicant's Revision 3 of the Emergency Plan.for DCNPP, August 1981, incorporates provisions for.the complicating effects of earthquakes so as to comply.
with 10 CFR 550.47 (b), Appendix E to Part 50, and i
applicable planning standards-and-evaluation criteria in NUREG-0654.
l
RESPONSE
Denied.
Revision 3 reflects no more than the most cursory attention to the complicating effects of an earthquake.
i This is not surprising since the Tera analysis became available See in September 1981, by which time Revision 3 was complete.
i also Admission 16.
i v
w i
Admission 14.
Applicant's Revision 3 of the Emergency Plan for' DCNPP, August 1981, together with descriptions in-cluded in Applicant's responses to interrogatories 22 and 23 of Joint Intervenors' First Set of. Inter-rogatories provide criteria for choice among recom-mended prctective actions in compliance with.10'CFR S50.47(b), Appendix E to Part 50, and. applicable planning standards and evaluation criteria of NUREG-0654.
RESPONSE
The Governor agrees that the Applicant's emergency plan, Revision 3,.as well as its responses to Joint Intervenors' Interrogatories 22 and 23 (First Set), provide criteria for choice among recommended protective actions.
However, the Governor does not agree that these criteria are adequate, particularly in light i
of the confusion during the August 19 emergency planning exercise relating to when various protective actions (especially evacuation) and public notificarion were to be instituted.
See Response to earlier requests.
10 CFR 550.4 7 (b) (5), (9), (10), (14), (15).
Admission 15.
Applicant's " Evacuation Time Assessment for the Diablo Canyon Nuclear Power Plant" dated September-1980, complies witn applicable provisions of 10 CFR 550. 47 (b), and the planning standards and evaluation criteria of NUREG-0654.
RESPONSE
Denied.
The evacuation time assessment does not include any meaningful analysis of the complicating effects of an earthquake on evacuation and other emergency preparedness activities.
Further, the assessment does not include the entire State of Californic extended emergency planning zone.
- Indeed, it is noted that during the August 19 exercise, evacuation was required assfar out as Santa Maria, an area which is not covered m
u m m m.
m- -a.
--m.
m.
-a
l
.. in the voorhees analysis.
Admission 16.
The Diablo Canyon Earthquake Response Plan; prepared by Tera Corporation for the Applicant, 4
when integ rated with. the State of California Earthquake Response. Plan, the County Plan, and j
Applicants Emergency Plan, will adequately take into account the complicating effects of an earthquake which may be required to be considered in complying with 10 CFR'S50.47(b), and the planning standards and evaluation criteria of NU REG-0 6 54.
RESPONSE
Denied.
First, this admission request assumes that the Ter. Corporation analysis will be integrated into the State emergency response plan, the County emergency response i
plan, and the PG&E plan.
No basis is provided for that assumption and until such integration is in fact accomplished, no response can be provided.
Further, there are potentially certain shortcomings in the Tera analysis.
For instance, Tera assumed very low accelerations.
If accelerations consistent with the Diablo Canyon seismic analyses are assumed (i.e., 0.75g at the site), far greater damage and dis-ruption mdst be predicted.--*/Further, the assumptions regarding i
bridge failure and liquif ation, while in places correct, do not i
_/
PG&E has apparently agreed that use of'O.75g would result in planning with a greater margin of safety.
See PG&E Nov. 3
~
Response to Gov. Brown, pp. 9-10.
The Governor believes that such extra margins should be used for emergency planning purposes, just as they are used for seismic design purposes.
In addition, the Governor believes that accelerations ac excess of the SSE accelerations might also need to be considered, as has been ordered at San Onofre.
l i.
u=m- - -m-
-u--
~~
- _17_
' seem conservative in asusming that almostJno bridges will. fail:
. completely or that no roads will be1 seriously blocked.
- Finally,
~
the times regarding repair estimateszare based-not on analysis, i
but on assumptions.
Further shortcomings are also identified.
No convincing 4
reason is provided.for assuming only.an earthquake on the'Hosgri Fault.
Further, assumptions relating lto communications capability also appear to be suspect.
A site visit indicates'that the. EOF and UDAC are unre-enrorced trailers..Even in low accelerations, these critical communications, assessment and notification i
facilities may be entirely lost.
There is no demonstrated means,
for compensatory response 'if this.were tcf occur.
Finally,.the Tera analyses omit consideration.of an earthquake's effect'on radiological monitoring equipment.
If such equipment is unavail-able after an earthquake, then decisions for protective actions will be far more difficult to make.
See ACRS Memo to Mr. Dircks, attached to Staff's Nov. 2, 1981 Response to Gov. Brown.
Respectfully submitted, i
Byron S. Georgiou Legal Affairs Secretary Governor's Office State Capitcl Sacram, ento, California 95814 V
r l T
' ~ ~
' QAv s,.;
. ?,.yy s i,..
Herbert H.
Brown Lawrence Coe Langher KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER
& PHILLIPS 1900 M Street, N.N.
Washington, D.C.
20036 t
i
[
Attorneys for Governor Brown of the November 13, 1981 State of California 1
h0LKETED RELATED C0F3ES?C:P.,E!CE USNRC 1-UNITED STATES OF AMERICA 81 g)y 16 P3:20 NUCIMAR REGULATORY COMMISSION e.-:r5 SECRETARY
, unEliNG & SERVICE.
ERANCH
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power Plant,)
Unit Nos. 1 and 2)
)
)
PRAECIPE Please note that the name of the law firm representing Governor Brown in the above-captioned matter has been changed.
The new name is:
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS.
The address of the firm remains the same.
Respectfully submitted, KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS
/
9 f
v!w.~ n/
ecwm u.cv gy.
Lawrence Coe Lanpher 1900 M Street, N.W.
Washington, D.C.
20036 (202) 452-7000 Attorney for Governor Brown of the State of California Dated:
November 13, 1981 Washington, D.C.
a
j
'. u (
RELATD C0F?ISPONDCCE !
L 1
UNITED STATES OF AMERICA T8 NUCLEARREGULATORYCO.'01ISSIONh;Igc BEFORE THE ATOMIC SAFETY AND LICH)i@Ih'w pgAM g
!!2 :if SECRETARY.
)
- 4.aiiNG & SERVICE In tha Matter of
)
BRANCH
)
FTtCIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 0.L.
)
50-323 0.L.
-(Diablo Canyon Nuclear Power
)
Plant, Unit Nos.1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " GOVERNOR BROWN RESPONSE TO NRC STAFF REQUESTS FOR ADMISSIONS AND NRC STAFF THIRD SET OF INTERROGATORIES" and "PRAECIPE" have been served to the following on November 13, 1981 by U.S. Mail, first class.
Mr. Thomas Moore, Chairman Atomic Safety and Licensing Appeal Board
)
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. W. Reed Johnson Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Chairman Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John F. Wolf, Esq., Chairman Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20553
y
_2-ar Glenn O.
Bright Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Jerry R.
Kline Atcmic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 William J. Olmstead, Esq.
Edward G.
Ketchen, Esq.
Lucinda Low Swarts, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatcry Commission Washington, D.C.
20555 Secretary U.S.
Nuclear Regulatory Cc= mission Washington, D...
20555 ATTENTION:
Docketing and Service Section y
Mrs. Elizabeth Apfelberg 1415 Coradera San Luis Obispo, CA 93401 Janice E.
Kerr, Esq.
Public Utilities Corpission 5246 State Building 350 McAllister Street San Francisco, California 94101 nrs. Raye Fleming 1920 Mattie Road Shell Beach, California 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, California 93105 Mr. Gordon Silver Mrs. Sandra A.
Silver 1760 Alisal Street San Luis Obispo, California 93401 Joel R. Reynolds, Esq.
John R. Phillips, Esq.
Center for Law in the Public Interest 10951 West Pico Boulevard Third Floor Los Angeles, California 90064 Bruce Norton, Esq.
Norton, Burke, Serry & Junck 3216 North Third Street, Suite 300 Phoenix, Arizena 85012
i V
' Philip A. Crano, Jr.,
Esq..
F. Ronald Laupheimer, Esq.
Richard F. Locke, Esq.
Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94106 David S. Fleischak'er, Esq.
P.O. Box 1178 Oklahoma City, Oklahoma 73101 Arthur C. Gehr, Esq.
Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 Mr. Richard B. Hubbard MH3 Technical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 Mr. Carl Neiberger Telegram Tribune P.O.
Box 112 San Luis Obispo, California 93402 Byron S. Georgiou, Esq.
Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814 w
~n,__,,,.,
u n
Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 November 13, 1981
,.m, a
n
.,-