ML20010A883

First Request for Production of Documents Directed to Util

ML20010A883
Person / Time
Site:	Diablo Canyon
Issue date:	08/05/1981
From:	Lanpher L CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS
To:	PACIFIC GAS & ELECTRIC CO.
References
ISSUANCES-OL, NUDOCS 8108130064
Download: ML20010A883 (7)

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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 8

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RELATED CORRESPONDENCB f9-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD; U610 fggy , 2 L OIlO k*itti.3 Cf e s the scgre:a EM d

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In the Matter of )

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PACIFIC. GAS AND ELECTRIC COMPANY ) 50- L.

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Plant, Unit Nos. I and 2) ) P

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GOVERNOR EDMUND G. BROWN JR.

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• Cl FIRST REQUEST FOR PRODUCTION OF DOCUMEN u.a. gam 711 TO PACIFIC GAS AND ELECTRIC CCMPANY cu 4' Pursuant to 10 C.F.R. S 2.741 and the Licensing Bo August 4, 1981, Memorandum and Order, Governor Brown requests Pacific Gas and Electric Company to produce for inspection and 1/

copying the documents described below. PG&E is requested to produce these documents at the offices of the undersigned counsel, 1900 M Street, N.W., Washington, D.C. 20036, on or before September 8, 1981, unless another time or location is agreed upon among the parties.

As used herein, " documents" includes, but is not limited to, emergency plans and procedures, construction plans and specifica-tions, papers, photographs, criteria, standards of review, record-ings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-corporate 1

l Governor Brown intends to file additional discovery requests

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l be litigated.

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memoranda or written communications of any nature, intraagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions; analyses, assessments, surveys, evaluations, projections, hypotheses, form-ulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer deta, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and.also all copies of any of the foregoing which differ in any way (including handwritten notations or other written or printed matter of any nature) from the original.

Request 1. All documents in the possession, custocy or control of PG&E (including the possession, custody, or control of any contractor, employee, consultant, or agent of PG&E) which l relate in any way to the NRC Staff request of December 16, 1980, 1

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that PG&E " evaluate the potential complicating factors which might be caused by earthquakes which either initiate or follow the initiation of accidents." A copy of the Staff's December 16 request is attached hereto. Without limi.tation of the scope of l this request, documents within the scope of Request 1 include:

l (a) The contractor report referenced by Staff witness Mr. John Sears at page 7 of his prepared testimony

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in the Diablo Canyon fuel load and low power test proceeding; (b) All analyses, memoranda, and work papers related to such contractor report; (c) PG&E's written agreement or contract with such contractor for preparation of such contractor's report, including any documents related to the performance schedule and scope of work to be performed by such contractor under the agreement or contract; (e) Any correspondence between PG&E and the NRC Staff related to earthquake analyses requested in the NRC Staff's December 16, 1980, 'le tter ; and (f) Any correspondence, memoranda, or other documents between PG&E and the Federal Emergency Management Agency covering potential effects of an earthquake in emergency plans or preparedness at Diablo Canyon and the surrounding Emergency Planning Zones.

Recuest 2. All documents in the possession, custody or control of PG&E (including the possession, custody or control of any contractor, employee, consultant, or agent of PG&E) which analyse or relate to any analysis or evaluation of the ability of onsite and/or offsite emergency preparedness (both persons and systems) at Diablo Canyon and in the Emergency Planning Zones to

• function in the event of an earthquake which is greater than the SSE. Without limitation of the scope of this request, all documents

which address emergency response actions to be taken in the event of an earthquake greater than the SSE are within the scope of this Request 2.

Request 3. Any revisions (in draft or final form) to the PG&E Emargency Response Plan or to PG&E Emergency Procedures which set forth, in whole or in part, actions to be taken to respond to the potential complicating effects of an earthquake.

Request 4. All documents in the possession, custody or control of PG&E (including the possession, custody or control of any contractor, employee, consultant, or agent of PG&E) which analyse or relate to the effect of an earthquake, including an earthquake greater than the SSE, on onsite and/or offsite preparedness to:

,(a) Communicate among or between PG&E and County, State, and/or federal government officials; (b) Alert persons anywhere within the plume exposure EPZ to evacuate or to take other protective actions;-

(c) Conduct evacuation of (1) the Diablo Canyon site and (2) the surrounding plume exposure EPZ; (d) Provide medical assistance to persons within the plume exposure EPZ; and/or (e) Conduct r;.diological monitoring within the plume ex-posure and injestion exposure EPZ's.

Request 5.. All documents in the possession, custody or control of PG&E (including the possession, custody or control of

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any contractor, employee, consultant, or agent of PG&E) which analyse or relate to whether (a) the onsite operations support center and/or (b) the offsite emergency operations facility (both the present interim facility and the proposed permanent facility) will be available to function without interruption in the event of an earthquake, including an earthquake exceeding the SSE.

Dequest 6. Revision 3 of the PG&E Emergency Plan or, if

, not yet available, any draft (s) thereof.

Request 7. The PG&E Emergency Procedures described at the Diablo Canyon fuel load and low power test hearing (e.g., Tr.

10,827) and any revisions -thereto.

Respectfully submitted, Byron S. Georgiou Legal Affairs Secretary Governor'e Office State Capicol

. Sccramento, California 95814

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Herbert H.

Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.

1900 M Street, N.W.

Washington, D.C. 20036 i

Attorneys for Governor Brown of the '

State of California l

August 5, 1981

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/. 34 UMTED STATES y , y, 7 g NUCLEAR REGULATORY COMMISSION 1.' ].. - E vvASHINGTON. D. C. 2C555

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...s DEC 161980 Docket Nos.: 50-275/323 -

Mr. Malcolm H. Furbush ,

Vice PPsident - General Counsel Pacific Gas & Electric Company -

P.O. Box 7442 San Francisco, Califernia 94106 -

SUBJECT:

EFFECTS OF EARTHQUAKES ON DIABLO CANYON, UNITS 1 A 2 EMERGENCY PLANS' ,

We are requesting that you evaluate the potential complicating factors which might be caused by earthquakes which either initiate or follow the initiation ,

of accidents. Two general cases' chould be considered. First, a severe '

earthquake at the site which could disrupt normal power and auxiliary services and thereby cause the. plant to be in a degraded mode should be concidered.

An Alert or higher energency class, depending on specific plant damage wocid ,

be declared in, such a case in accordance with .Sopendix l of NUREG-0654, Re'v.1.

g, The facility emargency plans should be capable of functioning under such conditions. Of principal importance under such conditions would be augmentation of the facility staff and wpporting resources to assure that a more severe accident did not develop. Factors to be considered for your. facility pl:ns should include the impacts due to potential disruption of comunicatiens networks and transportation routes. Your concern should be the availability of resource's and personnel to augment onsite staff, transit to and among-emergency re:ponse facilities and communications with offsite organi:ations. Arrangements.should be made such that equipment to be used in such circumstances (such as helicopters,

! offroad vehicles, etc.) will be dedicated for use by the plant even under '

l prt.ssing and competing needs such as offsite rescue missions. These aspects must be satisfactorily addressed prior to full power operation.

The second case which should be considered is an earthquake offsite which _

disrupts co munications networks and transportation routes in particular locales. In California, such occurrences appear to be frequent enough~to warrant consideration in your emergency plans. The procedures ,to be utsd to determine the protective actions recommended to offsite authorities should be revised to incorporate. consideration of earthquake effects offsite.

Evacuation time estimates sh6uid incorporate consideration of local s. '

! transportation route disruption. ,

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We are requesting FEMA to review the adequacy of State and local capabilitics with respect to response duririg earthquakes. A copy of our memo to FEMA is enclosed.

Sincerely, hb Robert L. Tedesco, Assistant Director-for Licensing Division of Licensing

Enclosure:

Memo to FEMA dtd.

11/03/80 cc: See next page.

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MEMORANDUM FOR: John McConnell, Assistant Associate Director for Population Preparedness, FEMA FROM: Brian X. Grimes, Program Direct 6r, Emergency Preparedness Program Office, NRR

SUBJECT:

REQUEST FOR FFA ASSISTANCE TO REVIEW EFFECTS OF EARTHQUAKE AND VOLCANIC ERUPTION ON STATE / LOCAL EMERGENCY PLANS As we have discussed, in the course of our review of licensed utility emergency plans, volcanic eruptions and catastrophic earthquakes have emerged as two issues of high public interest. To insure that these issues are being adequately addressed, we request that FEMA review the State and local planning efforts for the areas around California nuclear power plant sites and the Trojan site with respect to the complications which might arise in the event of extreme n tural c phenomena and how these can best be addressed in the planning process.

In conjunctich'with the Trojan plant evaluation for compliance with the new'NRC emergsncy planning regulations, the Comission has directed that s the problems of effective protective, measures and evacuation.during or soon after volcanic eruption (giving due consideration to the possible effects 'of severe ashfall, mudflows, floods, and landslides) be closely examined. In this regard, we are requesting the licensed utility to revise its emergency plan to explicitly address the possible problems associated with an eruption. This will include considerations of site access during an emergency, assured comunications and appropriate revision of the evacuation time estimates used in protective action deteminations. The Oregon State Department of Energy, has already addressed the feasibilit,"

of implementing effective protective measures during an eruption (enclosure 1).

The earthqutke issue has particular relevance to nuclear plants in California (i.e., Diablo Canyon, Humboldt Bay, Rancho Seco and San Onofre).

We un.derstand from the FEMA news release of September 29, 1980 that FEMA will lead a team consisting of personnel from Federal, State and local j-agencies to accelerate efforts towards improving the state of readiness to cope with potential major earthquakes in California. 'In this regard we request that FEMA include in its evaluation of offsite eme'rgency plans, a qualitative evaluation of complicating factors which might be caused by earthquakes for California nuclear power reactor sites. Specifically, .

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John McConnell .

~l c s such evaluation should include the impacts.on State / local emergency plans due to potential disruption of communications networks and evacuation routes.

In this regard, we are requesting the affected licensees to revise their emergency plans to explicitly address the possible problems associated with an earthquake to ir-lude the type of potential complications discussed above for the Trojan facility.

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Thank you for your assistance in these matters.

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W Brian K. Grimes, Program Director Emergency Preparedness Program Office Office of Nuclear Reactor Regulation

Enclosure:

Oregon DOE Study Report Measures N .

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EUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

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) )

)

CERTIFICATE OF SERVICE.

I hereby certify that copies of " GOVERNOR EDMUND G. BROWN JR. FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PACIFIC GAS AND ELECTRIC COMPANY" have been served to the following on August 5I, 1981 by U.S. mail, first class, except as otherwise no ted .

Richard S. Salzman, Esq., Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission .

Washington, D.C. 20555 Dr. W. Reed Johnson Atomic Safaty 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 l Atomic Safety and Licensing Board Panel l U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 Chairman Atomic Safety and Licensing Appeal Panel ,

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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_ Mr. Glenr. v.. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -

Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 William J. Olmstead, Esq.

Edward G. Ketchen, Esq.

Lucinda Low Swartz, Esq.

Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Docketing and Service Section Mrs.-Elizabeth Apfelberg c/o Nancy Culver 192 Luneta Drive San Luis Obispo, California 93401 Janice E. Kerr, Esq.

Public Utilities Commission ,

5246 State Building 350 McAllister Street San Francisco, California 94102 Mrs. Raye Fleming ,

1920 Mattie Road Shell Beach, California 93449

) Mr. Frederick Eissler l Scenic Shoreline Preservation Conference, Inc.

4623 More Mesa Drive Santa Barbara, California 93105 l

! Mr. Gordon Silver Mrs. Sandra A. Silver i 1760 Alisal Street l San Luis Obispo, California 93401 f John Phillips, Esq.

Center for Law in the Public Interest 10203 Santa Monica Drive Los Angeles, California 90067

- Bruce Norton, Esq. (*)

Norton, Burke, Berry & Junck 3216 North Third Street, Suite 300 i

Phoenix, Arizona 85012

Philip A. Crane, Jr., Esq.

Richard F. Locko, Esq.

Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94106 -

David S. Fleischaker, Esq.

1735 Eye Street, N.W., Suite 709 Washington, D.C. 20006 Arthur C. Gehr, Esq. ~

Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizona 85073 Mr. Richard B. Hubbard MHB 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 .

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. s ActvJ- $ N Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.

1900 M Street, N.W.

Washington, D.C. 20036 August i$ 1981

(*) By Federal Express on August _-6 1981

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