ML20010E398

Response to Util 810807 First Set of Interrogatories Directed to Joint Intervenors.Certificate of Svc Encl. Related Correspondence

ML20010E398
Person / Time
Site:	Diablo Canyon
Issue date:	08/26/1981
From:	JOINT INTERVENORS - DIABLO CANYON
To:	PACIFIC GAS & ELECTRIC CO.
References
ISSUANCES-OL, NUDOCS 8109040067
Download: ML20010E398 (41)

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UNITED STATES OF AMERICA y Gi l i+f g NUCLEAR REGULATORY COMMISSION O BEFORE THE ATOMIC SAFETY AND LICENSING BOARQ bL 3 g g r .. p 0 -

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4 b PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

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':: cAlig3 ,I981y :Lq' JOINT INTERVENORS' RESPONSE TO E- ' ^ ~ '27 PACIFIC GAS AND ELECTRIC COMPANY' FIRST SET OF INTERROGATORIES 9 Eu.a TNj/[/

N VC Joint Intervenors hereby respond to Pacific Gas and Electric Company's (" Applicant") August 7, 1981 First Set of Interrogatories to Joint Intervenors, as follows:

Response to Interrogatory No. 1 It is the Applicant's burden to demonstrate compliance with all applicable provisions of the Commission's emergency planning requirements. Until such compliance has been demonstrated by the Applicant, Joint Intervenors do not concede that cry of the provisions of the Commission's emergency planning regulations has been met, either by the Applicant or by offeite agencies, and this applies to 10 C.F.R. S50.33(g).

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t Joint Intervenors are informed and believe and on the basis of such information and belief respond that at the present titae, all of the relevant emergency plans -- Applicant, State, and local -- are being substantially revised in an attempt to achieve compliance with the Commission's revised regulations, effective November 3, 1980. Therefore, neither the NRC nor FEMA has issued its findings regarding the adequacy of the various plans. Until each has been submitted, approved, and adopted by the responsible authorities, the requirements of 10 C.F.R. S 50. 3 3 (g) clearly cannot be met. Moreover, until Joint Intervenors have had an opportunity to examine the revised plans for sufficiency, no definitive determination can be made regarding compliance with that section.

Response to Interrogatory No. 2 See Response to Interrogatory No. 1.

Response to Interrogatory No. 3 See Response to Interrogatory No. 1.

Response to Interrogatory No. 4 It is the Applicant's burden to demonstrate compliance with all applicable provisions of the Commission's emergency l planning requirements. Until such compliance has been demonstrated by the Applicant, Joint Intervenors do not concede that any of the l

provisions of the Commission's emergency planning regulations has i

been met, either by the Applicant or by offsite agencies, and this applies to 10 C.F.R. S50.47.

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The Applicant has failed to demonstrate the existence of onsite or offsite preparedness either within the LPZ or to the full extent of the 10 mile EPZ and 50 mile ingestion pathway planning zone. During the low power test hearing, held May 19-22 in San Luis Obispo, California, the evidence demonstrated -- and the Apelicant conceded -- that the combined Applicant, State, and local plans for-Diablo Canyon fail to meet even one of the

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emergency planning standards set forth in 10 C.F.R. S 50. 47 (b) and addressed by specific criteria in NUREG-0654. In addition, all parties conceded that the relevant plans fail to consider and allow for the effects of a major earthquake occurring simultaneously with a radiological emergency at the site. In their Proposed Findings of Fact and Conclusions of Law, filed J'me 16,1981, Joint Intervenors submitted a detailed analysis (including citations) of the numerous deficiencies of the various l

plans in compliance with the regulations. That discussion -- set l forth at pp. 11-38 -- is hereby incorporated by reference in l

! partial response to this interrogatory. (See Appendix A hereto.)

Also at that hearing, the Applicant indicated through testimony that Revision 3 of its onsite emergency plan was being prepared and that it was expected to be completed by mid-June 1981. Similarly, the Staff stated through testimony that an analysis of the effects of earthquakes on emergency preparedness, l being prepared by PGandE pursuant to Staff directive, could be completed in mid-May 1980. Neither document has been completed

( or, if completed, neither has been served on Joint Intervenors.

l Thorough examination of each is critical to a determination of the adequacy of emergency preparedness at Diablo Canyon.

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t Joint Intervenors are infocmed that on August 19, 1981 a

" full scale exercise" was held to test the adequacy of the Diablo i.

Canyon emegency plans. Despite repeated attempts to gain access to that exercise as observors, Joint Intervenors and their counsel were excluded and, therefore, have no way of judging at the present time either the adequacy of the drill or the level of preparedness demonstrated by it. Further discovery is essential to obtain such information. Joint Intervenors are informed and believe, however, that' the exercise failed to provide a true test of response capability in that the scenario upon which it was based did not even remotely resemble circumstances likely to exist in the event of a real emergency, especially if initiateu or accompanied by a major seismic event.

Because Joint intervenors have only recently initiated discovery in this proceeding and no responses have yet been received, this response is submitted without prejudice to their right to raise legal or factual issues regarding any information subsequently discovered by them.

Response to Interrogatory No. 5

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See Response to Interrogatory 4.

l Response to Interrogatory No. 6 See Response to Interrogatory 4.

Response to Interrogatory No. 7 It is the Applicant's burden to demonstrate compliance with all applicable provisions of the Commission's emergency

4 planning requirements. Until such compliance has been demonstrated by the Applicant, Joint Intervenors do not concede that any of the provisions of the Commission's emergency planning regulations has been met, either by the Applicant or by offsite agencies, and this 1

applies to 10 C.F.R. Part 50, Appendix E.

The Applicant has yet even to address -- much less demonstrate compliance with -- Appendix E to 10 C.F.R. Part 50.

None of the relevant plans as they currently exist -- Applicant, State, or local -- contains the requisite information needed to' demonstrate compliance with the criteria for organization, assessment action, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emargency preparedness, and response.

Moreover, as stated in response to Interrogatory Nos. 4-6, the plar.s fail to meet the criteria set forth in 10 C.F.R. S50.47 (b) .

Because that is also a requirement of Appendix E, all of the deficiencies discussed in Joint Intervenors' Response to Interrogatory Nos. 4-6 (including the incorporated sections of the Proposed Findings) apply equally to.the Applicant's failure to ,

demonstrate compliance with Appendix E.

Appendix E explicitly requires a full-scale exercise "which tests as much of the licensee, State, and local emergency plan as is reasonably achievable . . . ." Although an " exercise" was apparently held in San Luis Obispo on August 19, 1981, Joint Intervenors are informed and believe that its limited scope was clearly insufficient to meet the cited requirement.

See also Response to Interrogatory Nos. 4-6.

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A Response to Interrogatory No. 8 See Response to Interrogatory No. 7.

Response to Interrogatory No. 9 See Response to Interrogatory No. 7.

Response to Interrogatory No. 10 These responses were prepared by Joint Intervenors with the assistance of counsel. Witlicut exception, they are based on documents of pub.ic record and testimony previously offered in this proceeding.

I Response to Interrogatory No. 11 The requisite information is a matter of record on this docket. See Response to Interrogatory No. 10.

l Response to Interrogatory No. 12

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l The documents relied upon include, but are not

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l necessarily limited to, those documents attached as exhibits to Joint Intervenors' April 27, 1981 Response in Opposition to NRC Staff and PGandE Motions for Summary Disposition (and those incorporated therein by reference); all documents marked for identification or offered into evidence by Joint Intervenors l

l during the low power test hearing; and all documents cited by Joint Intervenors in their June 16, 1981 Proposed Findings of Fact and Conclusions of Law, filed in the low power test proceeding.

This response is given without prejudice to Joint Intevenors' right to rc'.y upon any documents subsequently discovered by them.

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D.asponse to Interrogatory 13 g

At this time, Joint Intervenors have not decided what persons, if any, t ;y may call or subpoena as witnesses at the hearing to be held on the admitted emergency preparedness contention.

Dated August 26, 1981 4

4 Respectfully submitted, JOEL R. REYNOLDS, ESQ.

i JOHN R. PHILLIPS, ESQ.

Center for Law in the Public Interest 10203 Santa Monica Blvd.

Fifth Floor Los Angeles, CA 90067 DAVID S. FLEISCHAKER, ESO.

1735 Eye Street, N.W.

Washington, D.C. 20006 (202) 638-6070 By 6?W g)J DEL R.-REYNOLDS i

Attorneys for Joint Intervenors-SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY' ACTION CLUB SANDRA SILVER ELIZABETH APPELBERG s JOHN J. FORSTER l

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requirements, it has the ,burdea o~f proof to demonstrate

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i that the exemption'ciiteria set forth at707mIh-S50,A2.Lcj_

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have~been satisfied.

B. Adecuacy of Diablo Canyon Emergency Plans

15. The board finds that t.te existing applicant.

State, and local emergency response plans are inadequate to assure protection of the health and safety.of the public in the event of a radiological energency at Diablo Canyon duriLg ,

low power testing.

16. It is undisputed that existing applicant, State, and local emergency plans for Diablo Canyon do not meet the Ccmmission's revised regulatione or the NUREG-0654 criteria.

(Joint Intervenors' Exh. 111; Shiffer, Tr. 10614; Buckley, Tr. 1105e; Sears, Tr. 11062.) Indeed, in response to the promulgation of new regulations, significant revisian of the relevant Diablo Canyon plans has become necessary and is currently

! in prcgress. None of th;se revisions is expected to ha completed prior to fuel loading for low powur testing. (SER Supplement 12, at III-3; Shif f er, Tr. 10660; Jorgensen, at 3.)1A!

14/ By letter to the MRC Staff dated February 27, 1981, PGandu roguested " relief" from the Commission's revised emer-gency planning requirements However, for purposes of loading PGandC fuelauthority cited no and conducting low power tests.

for such relief in the regulations themselves; indeea, the Ccamission's emergency planning regulations contain no Accordingly, exemption for operation of a facility at less than full power.

( this board rejects any requests by PGandC for relief from the Ocmnission's emergency plaining regulations. See note 46 infra.

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17. Primary legal responsibility for evacuation and other of fsite cmergency response measures rests with the local jurisdiction, the County of San Luis Obispo. (Shif fer, Tr.

10746.) The principal testimony offered regarding local emergency planning was that of Jeffrey Jorgensen, a member of the San Luis Obispo County Board of Supervisors. With respect to the general-adequacy of the local plans, he testified that although they have never been formally rescinded, they are in essence nothing more'than paper plans; because they have not -

been ir.plemented, they would not provide substantial protection to the public in the event of a radiological emergency.

(Jorgensen, at 1-2; Tr. 10917.) Supervisor Jorgensen testified that prior to the TMI-2 accident, emergency olanning was not perceived to be a high ;evel priority for the county government; after the accident, however, it becam extremely clear that the ccunty's plans would have to be substantially changed. Conse-quently, the County in effect shelved the existing plans and embarked on a new planning effort to devise plans which comply with the Cctmission's revised regulations. (Tr. 10918.)

Since the TMI-2 accident, no action has been taken to implement the existing plans in any way. (Tr. 10917.) The draft revised plan is not scheduled for formal adoption by the Board of Supervisors until December 1981. (Tr. 10921.) In short, Supervisor Jorgensen testified that

[tlo date, no actual preparedness has been developed and will not be until the County's

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i i current planning effort is completed.

(Jorgensen, at 3.) 15/

18. More specifically, the board finds that the extent of noncompliance with 10 C.F.R. S50.47(b) is substantial.

Through interrogatory responses offered into evidence by Joint Intervenors and received by the board, PGandE admitted that the existing combined applicant, State, and local emergency plans fail to comply with any of the sixteen planning standards contained in that subsection. (Joint Intervenors' Exh. 111.)15! ,

This fact is not attributable to the inadequacy of any single plan; on the contrary, PGandE's onsite plan fails to comply with thirteen of the regulatory standards, the State plan with fifteen, and the local plans with fourteen. PGandE did not even attempt to demonstrate specifically the insignificance of any but a very few of the deficiencies. Neverthuless, as is evident from the discussion below of the individual standards, numerous deficiencies relate to critical aspects of the emergency 15/ This testimony of Supervisor Jorgensen was virtually uncontradicted by PGandC and the Staff. Although PGandE t offered testimony of County Sheriff George Whiting in rebuttal

' to Jorgensen's testimony, the board notes that the response plan produced by the Sheriff and roccived in evidence as Board Exh. 5 has not been revised since 1977, two years prior to the TML-2 accident. Rather than contradicting Supervisor Jorgensen ' !; testimony, this is consistent with his statement that no action has been taken to implement the existing county plans since March 1979.

16/ The Staff repeatedly stated its view that the cc=binUd Applicant, Stato and local emergency plans do not comply with the Commission's revised emergency planning regula-ti ens . (Buckley, Tr. 11056; Gears, Tr. 11062; Olmstead, Tr. 10697.)

The Staf f did not challenge or contradict PGandE's admissior.s in Joint Intervenors' Exl . 111.

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I response capability, regardless of whether the facility is operating at loi rather than full power.

19. Further deficiencies in compliance with 10 C.F.R.

S 50.47(b) wera revealed on cross-examination of the PGandE and Staff witnesses and through the direct testimony of Supervisor Jorgensen, County Health Director Howard Mi tchell, and California Depc.rtment.of Forestry official Robert Paulus.

Most significant of these deficiencies, together with those admitted by PGandE in Joint Intervenors' Exhibit 111 ("J. I. ,

Exh. 111"), are summarized briefly as follows:

(A) Assicnment of Responsibility (Orcanization Control)17/ -

(1) Interfaces between onsite and offsite emer-i gency response organizations are not sufficiently defined or diagrammed in applicant, State, or local plans. (J.I.

Exh. 111; Shiffer, Tr. 10667.)

(2) Letters of agreement with offsite emergency

! response organizations, set forth in Appendix 7 to PGandE's onsite plan, are out-of-date and insuf ficiently specific, contain no critaria for implementation, include unverified information (e.g., phone numbers), and do not comply with i

MUPEG-0654 criteria. They are not set forth in the State or local plans. (J.I. Exh. 111; Shiffer, 10668-73, i

17/ Titles for each of the standards are drawn from MU:IG-0654.

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(3) PGandE onsite plan doesn't require 24-hour manning of communication links (Shiffer, Tr. 10682),

and State plan contains no commitment to 24-hour per day response or manning of ccmmunication links with local officials and applicant. (J.I. Exh. 111.)

'(4) Title of persons to be contacted at the State and local' levels in the event of-an emergency is not specified in the onsite plan nor does plan contain phone numbers of persons to contact. (J.I. Exh. 111; Shiffer, Tr. 10630-82.)

(5) The relationship of FEMA to the emergency response effort is not specified. (J. I. Exh. 111.)

(B) Onsite Emergency Oroanization (1) Responsibilities and authority of Site Emergency Coordinator are not sufficiently defined, particularly with regard to delegation of duties and the critical ultimate decisionmaking authority in the control room during an emergency. (J. I. Exh. 111; Sniffer, Tr. 10662.)

(2) Staffing requirements set forth in NUREG-0654 are not sufficiently addressed in PGandE's onsite plan, including the fact that on weekends and off-hours a fire brigade of five members will be drawn from the minimum fourteen persons onsite. (J. I. Exh. 111; Patterson, Tr. 10802-03.)

(3) Interfaces between onsite and offsite emergency response organizations and personnel are not outlined as i, i requir**d by NUREG-0654. (J. I. Exh. 111; Shiffer, Tr. 10667.)

(4) PGandE's onsite plan fails to discuss adequate]y the long-term augmentation of the emergency organization.

(J. I. Exh. 111.)

(5) PGandE's onsite plan faiis to identify in sufficient detail the services to be provided by local and/or Stats agencies in the avent of a radiological emergency at the facility. Letters of agreement to provide such services fail to detail the authorities, responsibilities, an.1 limitations on actions of contractors, privnte organizations, and incal support groups. The casite plan provides inadequate assurance of necessary ambulance service, docs not provide for a means to transport injured persons to St. Francis Hospital in San Francisco, and fails to describe adequately the capacity, trained personnel, and facilities available at St. Francis Ilosp i t al . (J. I. Exh. 111; Shiffer, Tr. 10668-73, 10800, 10864-65.

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(C) Emeroency Response Support and Resources (1) The applicant, State, and local plans do not specify the federal resources expected in the event of an emergency, the time of arrival of resources, or the persons responsible for requesting federal assistance. (J. I. Exh. 111.)

(2) The applicant and State plans do not specify all available radiological laboratories which might be.

utilized in the event of an emergency. (J. I. Exh. 111.)

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,. i (3) Agrc0ments vhich exist are out-of-date and insufficiently specific regarding authority, responsibilities, and limitations of assisting organizations. (J. I. Exh. 111; Shiffer, Tr. 10668-73; Paulus, at 4.)

(4) There has been no adegaate coordination of County personnel who would be required to implement the plans.

(Jorgensen, at 2.)

(D) Emergency Classification System .

(1) The relevant applicant, State, and local plans do not contain a standardized emergency classification system to determine, implement, and coordinate response measures.18/

None of the plans complies with the classification scheme set forth in Appendix I of NUREG-0654. While PGandE's onsite plan may require additional quantification of parametric values, neither the State nor local classification scheme is consistent with NUREG-0654. (J. I. Exh. 111.)

( 2) Neither the State nor local plans contain procedures providing for emergency action which take into account local offsite conditions at the time of the emergency.

(J. I. Exh. 111.) None of the plans considers and allows for the occurrence of an earthquake simultaneously wit.h a radio-18/ The 1cmony Commission noted the absence of coordinated emergency plans and accident classification systems as a contributor to the inadequacy of emergency preparedness at T:1I . (J. I. Exh. Il4A, at 38.)

I 1 logical emergency.19/

- (Jorgensen, at 2; Sears, at 3; Sears, Tr. 11060.)

(E) Notification Methods and Procedures (1) The early warning system described in Appendix III of NUREG-0654 is not. projected for completion prior to fuel load. (Shif fer, Tr. 10696. )

(2) None of the relevant plans contain the actual wording of emergency measures or the standard format for detailed initial and follow-up communications. (J. I. Exh. 111; Shiffer, Tr. 10699.)20/-

(3) Although PGands and the Staff rN1y on the ability of the County Sheriff to notify all persons in the .

LPZ in the event of an accident at low power, the Sheriff has never attempted to notify all residents and visitors in that area nor is there any estimate based on actual experience of the time such notification would take. The Sheriff has not prupared a written state 3 ant to give to persons in the LPZ upon notification in explanation of what actions to taic, (

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l 19/ See discussion infra at 29-31 regarding the failure of f

existing plans to allow for a radiological emergency occurring

! si:nultaneously with an catthquake, i

i 20/ The Kemony Commission criticized the NRC Commissioners' i

l ole iri the TMI-2 accident response in part because theyI.were preoccupied with theThe drafting of Commission a press release. (J.

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' Exh. ll4A, at 40.) Kemeny recognized that during a radiological emergency such things as the wording of notifi-t cation nessages should not require significant attention.

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t B how much time is available, and what is actually occurring.

Adverse weather conditions could preclude the use of helicopters for notification purposes. The feasibility of notification by helx;onter in remote areas of Montana d<t Oro State Park has not been demonstrated. (Shiffer, Tr. 10866, 10871; Sears, Tr. 11068, 11252.)35/

(4) The State plan contains no information on procedures or systems for notification, alerting, or mobilizing emergency personnel and no detailed discussion of the time required.

to instruct the public. (J. I. Exh. 111.)

(5) Neither the State nor local plans incorporate an Early Warning System which satisfies Appendix III of NUREG-0654, (J, 1. Exh. 111.)

(F) Emercency Communications (1) Applicant, State, and local plans contain insufficient description of communication plans, including NUREG-0654 criteria. Neithcr the State nor local plans discuss communication capability with State, local, and federal emergency response organizations. (J. I. Exh. 111.)

(2) None of the relevant plans discusses a periodic .

communications testing program. (J. I. Exh. 111.)

(3) The Caunty does not have adequate communica-tions equipment to reach headquarters and other personnel.

In fact, during a drill in 1979, County llealth Department 21/ See discussion infra at 32-34.

personnel were forced to use a pay telephone to communicate the results of thei: findings. (Mitchell, at 1; Mitchell, Tr. 10916, 10959, 10960; Jorgensen, at 2,)

(G) Public Education and Information22/ -

(1) PGandE has not implemented a public information program. PGandE has taken no action to inform the LPZ resio dents what medical facilities to contact in the event of radiation-relathd injury, what actions to take in the -

event of a radiological emergency, what the risks of low power testing are, and, aside from publishing its emergency plan, what the evacuation routes are. (Sears, at 5; Sears, Tr. 11064; Shiffer, Tr. 10874-75.)

(2) The State and local plans contain no discussion of a public information program. (J. I. Exh. 111.)

(3) At the local level, there has been no system-atic public information program designed to educate the public on necessary actions, including evacuation and shelter, to be taken in the event of a radiological emergency.

(Jorgensen, at 2.)

(II) Emercency Facilities and Equipment (1) At the time of fuel loading for low power testing, the three principal emergency facilities will not comply with all criteria set forth in NUREG-0696, entitled 22/ See discussion infra at 32-34.

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" Functional Criteria for Emergency Response Facilities, Final Report." (Shiffer, Tr. 10674.)

(2) The interim offsite emergency operations facility is a trailer, and the permanent facility is not 1

projected for completion prior to fuel load. The interim facility is not a seismic Class I structure. (Shif fer, at 10; Shiffer, Tr. 10680, 10698.)23/ -

(3) Although the operational support centcr ("0SC")

is the staging area for emergency support personnel, PGandE does not intend to compy with the NUREG-0654 requirement that certain specified supplies be stored there, including respiratory protection, protective clothing, portable lighting, monitoring equipment, cameras, and communicctions equipment. (Shiffer, at 10; Shiffer, Tr. 10676.) The OSC is not a seismic Class I structure. (Shiffer, Tr. 11306.)

(4) The State plan contains no discussion of an emergency operations center, the timely activation of staffing for such a facility, or identification of emergency equip-ment. (J. I. Exh. 111.)

(5) None of the plans addresses the periods of inspection, replacement, and calibration of emergency l

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23/ The board notes the imoortance of the Emergency Operations Facility to the overall emergency response capability of the l

j combined organizations. The purpose of the facility is to j

provide overall direction of the offsite activities from PGandE's standpoint, and it is intended to serve as a conduit to(Shiffer, offsite l

agencies for information regarding activities onsite.

Tr. 10753.) The particular vulnerability of the interim facility to inclement weather conditions and to seismic activity is not an insignificant factor.

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equipment. The State plan provides no indication of the location of radiological monitoring equipment. PGandE's onsite plan contains an inadequately detailed discussion of meteorological instrumentation. (J. I. Exh. 111.)

(I) Accident Assessment (1) The County has inadequate monitoring equipment beyond the site boundaries. (Mitchell, at 1.)

(2) The onsite and state plans contain insufficiently detailed discussion of methods, equipment, and expertise for rapid asst sment of the actual or potential magnitude and locations of radiological hazards. (J. I. Exh. 111.)

(3) Monitoring instruments installed by PGandE are located away from where the problem is -- few, if any, are located in the area of concern for low power. (Mitchell, Tr.

10910; PGandE E::hs. 67, 69.)

(4) The County has an inadequate and overly dispersed staff to conduct monitoring. (Mitchell, Tr. 10910.)

(5) The maps included in the onsite plan do not constitute accurate and up-to-date descriptions of the number

'and location of monitoring instruments. (Shiffer, Tr.

10780.)

(6) None of the monitoring instruments can be interrogated by radio; therefore, the data must be obtained by vehicle and, for all but the few real time instruments, turther analysis must then be performed, either An the field or at the facility. (Shiffer, Tr. 10780.)

(J) Protective Response (1) The local plans have not been implemented, and they provide no substantial protection to the general public in the event of a radiological emergency. For the foreseeable future, the County will not be able to respond effectively to a radiological emergency at Diablo Canyon. (Jorgensen, at 1-3.)

(2) The onsite plan does not address the times necessary to warn the public and take protective actions.

(J. I. Exh. 111.)

(3) The County plans don't discuss the effects on emergency response of inclement weather, high traffic density, and specific radiological conditions, nor do such plans address the means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement. Maps attached to the State and local plans do not indicate relocation centers and shelter areas.

(J. I. Exh. 111; Mitchell, at 2.)

(4) The State and local plan fails to discuss projected traffic capacities of evacuation routes under energency conditions, identification of and means for dealing with potential impediments (i.e., seasonal impassibility of roads) to evacuation routes, and time estimates for evacuation of various areas based on a dynamic analysis.

(J. I. Exh. 111.)

(5) An ability to notify promptly all segments of the transient and resident population of the LPZ has not

been demonstrated, nor has the County Sheriff or PGandE attempted to do so. (Shiffer, Tr. 10867; Sears, Tr. 11068-69.)

(6) The onsite plan should be revised to include new maps, population distribution information, and the bases for choice of recommended protective actions. (J. I. Exh. 111.)

(7) The local plan does not provide for use, quantities, storage or distribution of radioprotective drugs.

(J. I. Exh. 111.)24/

(8) The letter of understanding betceen PGandS .

and the California Department of Forestry for fire fighting support onsite has been rescinded by CDF. (Paulus, at 4.)

(9) None of the relevant plans considers and allows for a Diablo Canyon eme';gency occurring in conjunction with a major ca.:thquake on the Hosgri Fault. (Jorgensen, at 2; Sears, at 3; Sears, at 11060; J. I. Exh. 117.)

(K) Radioloaical Exposure Control (1) PGandE's onsite plan contains an insufficiently specific discussion of (a) EPA Protective Action Guides (PAG's) l for actions specified in NUPEG-0654, (b) application of any l

existing radiation protection measures to emergency situations, (c) an onsite dosimetry program, (d) radiation control procedures, contamination control measures, and (e) decantamination capability f for onsite personnel. (J. I. Exh. 111.)

i 2*/ See discussion of radioprotective drugs by Keme y l Ccmmission in its Report, J. I. Exh. ll4A, at 41-42.

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9 (2) Stato and local plans contain no detailed discussion, if any, of means for decontamination of personnel and equipment .,nn for waste disposal.

(L) Medical and Public Health Support (1) The County has inadequate medical facilities to trannport and treat persons in the event of a radiological emergency. (Jorgensen, at 2; Mitchell, at 2.)

(2) The County Health Office is inadequately

- staffed to respond to a radiological emergency at Diablo Canyon. (Mitchell, at 1.)

(3) The County Division of Environmental Health's Standard Operating Procedures for Nuclear Power Plant Emergency Response can't be implemented. (Mitchell, at 2.)

(4) The County is inadequately informed about and has never attempted to evacuate persons requiring ambulances from the LPZ and immediately surrounding area. Limited ingress and egress presents difficulty in removing persons with special needs. (Mitchell, at 2.)

(5) Despite the absence from the letter of agrooment between PGandE and the San Luis Ambulance Service of any pledge to treat radiation-related injuries, PGandE's onsite plan improperly states, in reliance upon that letter, that the Ambulance Service has committed to handle personal injury cases involving radioactive contamination. (Shiffer, Tr. 10670-71.)

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(6) The State plan cites reliance upon local authorities for medical services. No further discussion is provided. (J. I. Exh. 111.)

(7) Tr.e discussion of medical provisions in the local plan is insufficiently specific. (J. I. Exh 111. )

(8) Regarding PGandE's'onsite medical preparedness, there is no doctor onsite; no assurance of getting an ambulance promptly; no estimate'of. ambulance time or previcus drill on the Field Ranch Road (main alternate route to and from the site);25/ no plan for transport of injured persons to St. Francis Hospital in San Francisco; no speci-ficaticn of the capacity of or numbers of doctors available at St. Francis Hospital; only one NuCon contaminated personnel carrier onsite; and no rccord of which ambulance personnel have actually been trained. (Shif fer, Tr. 10695, 10865, 10686, 10693, 10673, 10800, 10688, 10692.)

(9) Because the County is short on ambulances, PGandE and local officials cannot be certain at any particular moment that any of the ambulances will be available to respond to injuries other than, for example, autcmobile accidents and heart attackn. (Shiffer, Tr. 10865; Mitchell, Tr. 10912.)

25/ PGandC witness Shiffer stated on cross-examination that the Field Ranch Road is slippery and muddy in adverse weather conditions. (Tr. 10799.) He also admitted that a member of the Field f amily had recently informed him that the road is

" impassible in wet weather and during the winter for as much as two weeks at a time." (Tr. 10870.)

(M) Recovery and P.eentry 'lanninc and Post-Accident Operations (1) Applicant, State, and local plans are insufficiently specific. The State plan contains no description of plans or peocedures, and the local plan, while providing general guidance, contains no specific procedures on reentry ,

and recovery. (J. I. Exh. 111.)

(N) Exercises and Drills ,

(1) Beyond reference to an annual exercise, the State plan contains no discussion of drills. The plan does not describe how the exercise is to be carried out, whether observers are to be present, or whether it is consistent with MU REG- 0 6 5 4 . (J. T. Exh. 111.)

(2) The local plan contains no specific exercise roc,u iremen t . (J. I. Exh. 111.)

(3) The existing onsite plan does not provide for drills and exercises consistent with NUREG-0654. (J. I.

Exh. 111.)

(4) No general exorcise or drill has been held involving applicant, State, and local officials with the i

public participating. (Shiffer, Tr. 10700.)

l

'5) There have been no full scale exercises to demonstrate the effectiveness of the local plans. (Jorgensen, at 2.)

(6) The County Sheriff has never conducted a drill involving notification of all areas of the LPZ.

i

According to Dr. Mitchell, the Sheriff's personnel did not even gc to See Canyon during the 1977 drill. (Shiffer, Tr.

10866-67; Mitchell, Tr. 10916.)

(7) The 1977 and 1979 local drills did not demonstrate adec:ste preparedness. Moreover, neither simulated a real-life emergency in that persons involved were not dispersed throughout~the County as they would be in the even. sf an actual emergency. (Mitchell', Tr. 10916.)

(8) PGandE's onsite plan does not require communications drills. (Shiffer, Tr. 10701.)

(9) No full scale exercise is planned prior to fuel load. (Shif fer, at 32.)

(0) Radiolocical Emergency Response Training (1) California Department of Forestry employees have not received the radiation training which PGandE agreed to provide. (Paulus, at 203; Paulus, Tr. 10986.)

(2) FGandE's onsite plan contains an insufficiently detailed discussion to determine whether requisite training l

is protided. (J. I. Exh. 111.)

l (3) State and local plans contain no specific l

l training requirements. Exh. 111.)

(J. I.

(4) There is no adequate trainir..J or coordination of local personnel. (Jorgensen, at 2.)

t (5) Relatively few physicians in San Luis Obispo l

l County have the training or equipment necessary to handle 1

and treat radiation-related injuries. (Mitchell, Tr. 10911.)

l 1

l l .-, c, ., .- ,. ..- . , . . , _ . . , . . , _

(6) State and local plans do not provide for I

training specified in NUREG-0654, including training of coordinators of response organizations, accident assessment personnel, radiological monitoring personnel, police, security personnel, firefighters, maintenance personnel, first aid and rescue personnel, local support services personnel (i.e., Civ'il Defense), medical support personnel, license headquarters personnel, and cpmmunications personnel.

4 (J. I. Exh. 111.) .

(P) Responsibility for Planning Effort:

Develonment and Periodic Review and Distribution of Emergency Plans (1) The State plan contains no discussion of this standard. (J. I. Exh. 111.)

(2) The County plan is insufficiently specific and hasn't been revised since its issuance. Neither the State nor local plan is cross-referenced to NUREG-0654.

(J. I. Exh. 111.)

(3) The phone numbers in the applicant, State, and

. local plans have not been updated. (J. I. Exh. 111; Shiffer, Tr. 10669.)

(4) The applicant and State plane do not contain Standard Operating Procedures as required by NUREG-0654.

(J. I. Exh. 111.)

20. The board finds further that none of the relevant onsite or offaite emergency plans considers and allows for

1 .

the effects of a major carthquake on the Hosgri Fault occurring simultaneously with a radiological emergency at Diablo Canyon.26/ -

On December 16, 1980, the ::RC requested that PGandE evaluate "the potent _al complicating factors which might be caused by carthquakes which either initiate or follow the initiation of accidents." (J. I. Exh. 117, at 1.) Specifically, the evaluation must consider two general cases:

~First, a severe earthquake at the site which could disrupt normal and auxiliary services and thereby cause the plant to be in a degraded mode should be considered.

The facility plan should be capabic of functioning under such conditions. Of principal importance under such conditions would be augmentation of the facility staff and supporting resources to assure that a more severe accident did not develop. Factors to be considered for your facility plans should include the impacts due to potential disruption of communications networks and transportation routes. Your concern should be the availability of resources and personnel to augment onsite staff, transit to and among emergency response facilities and communica- * *

• tions with offs te organizations. i The second case which should be considered is an earthquake offsite which disrupts communi-cations networks and transportation routes in particular locales. In California, such occurrences aupcar to be frequent enough to warrant consideration in your emergency plans. The procedures to be used to determine the protective actions recommended to offsite authorities should be revised to incorporate consideration of earthquake effects offsite.

Evacuation time estimates should incorporate consideration of local transportation route disruption. (Id.)

{6/ See Jorgensen, at 2; Sears, at 7; Sears, Tr. 11060, 11283; Shiffer, Tr. 10878-79.

In addition, the NRC requested FEMA to review the adequacy of State and local capabilities with respect to response during carthquakes.27/ -

21. The carthquake analysis requirement is based on the Ccmmission's appreciation of the greater scismic risk associated with nuclear plants located.in California relative to facilities in other areas. (Scars, Tr. 11060.) The NRC has not received such an analysis from PGandE, nor has FEMA reviewed the adequacy of the State and local capabilities with respect to earthquake effects. Although both PGandE and the Staff urge that the seismic evaluations are not required prior tu low power operation, no logical justification for such a view was offered at the hearing, and there is no factual basis to conclude that tne effects of an earthquake on emergency response capability will be reduced at power levels below Diablo Canyon's full capacity. Particularly in light of the continued importance of seismic safety in this proceeding (Scars, Tr. 11060), the board considers the absence of any analysis of and preparation for earthquake effects on emergency planning on and offsite to be a critical deficiency in cmcr;cncy preparedness at Diablo Canyon.28/ -

27/ Memorandum from Grimes to McConnell, " Request for FEMA Assistance to Review Ef fects of Earthquake at.d Volcanic Eruption on State / Local Emergency Plans" (Nov. 3, 1980) (J. I. Exh. 117).

28/ Ths board notes the recent licensing board decision in In the~ Matter of Southern California Edison Co. (San Onofre Nuclear Generating Station, Memorandum and Order, at 2 (April 8, 1981),

where the board recognized that "(alpplicants, particularly appli-cants in a seismically active area like California, should be prepared to demonstrate that their emergency plans can function in a major carthquake situation."

l l

1

- - - - , , . - - - - , . - . - . , , . . --w- . .r -

[ .

22. Of the numerous emergency planning deficiencies cited above, PGandC and the Staff focussed specifically on the absence of an early warning system and a public information program. In an attempt to minimize the significance of this conceded noncompliance with the Commission's regulations, both parties cited (1) increased time to respond which might perr.it

" house-to-house" notification of LPZ residents by the County Sheriff and (2) PGandE's intenti6n to circulate a public infor-mation brochure just prior to fuel loading for low power testing.

(Shiffer, Tr. 10340, 10872, 10874; Sears, at 4-5; Sears, Tr.

11067, 11251.) This board disputes such testimony for aeveral reasons. First, the Sheriff's capability for prompt nott'~fcation

+

of all so, ents of the resident and transient population in the LPZ has never been demor,strated. Although some of his deputies may have been dispatched to See Canyon during a drill in 1977, there is no evidence as to what precisely occurred nor does that action provide any assurance that notification of all persons throughout the I PZ , including Montana de Oro State Park, can be promptly accomplished by the Sheriff. (Shif fer, Tr.

10866-7; but see Mitchell, Tr. 10916.) S!

29/ In addition, although plant operators may have more time during low power operations to prevent a routine transient from developing into a serious accident, there is no evidence or assurance that such additional time will also be available once it beccmes apparent that protective actions offsite will be necessary. It is indeed a possibility that, regardless of whether the plant is operating at low or full power, public notifi-cation of the need to evc.cuate would be delayed as long as pocnible in order to avoid needless public panic or evacuation.

The Kemeny Commission noted that one of the reasons emergency planning had a low priority with the MRC was the desire to avoid raising public concern about the safety of nuclear nower.

(J. I. C:< h . 114A, at 38.)

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23. Second, the public unders:anding -- at 1 cast within the LPZ -- of essential emergency response information is virtual.ly nonexistent. On cross-examination, James Shiffer, on behalf of PGandE, conceded that PGandE had taken no actions to inform the residents of the LPZ regarding (1) the risks to them of low power operations, (2) the available medical facilities equipped and staffed to treat radiation-related injuries resulting'from an accident at the plant, and (3) the most appro-priate actiona to take in the event of such an emergency.

(Shiffer, Tr. 10874-75.) Similarly, John Sears, on behalf of the Staff, testified in effect that apart from inclusion of the local plans in its onsite plan, PGandE has not demonstrated that the public knows what the evacuation routes are. (Sears, Tr. 11064.) Although PGandE has apparently been preparing a public information brochure, it is only in draft form. (Se ars ,

at 5.)

i

24. In light of such testimony, the board cannot agree with the view expressed by PGandE and the Staff that at the present time there is no real purpose for a public information program. (Shif fer, Tr. 10872; Sears, at 5.) We find that increased public understanding and awareness of the kinds of

information mentioned above would greatly facilitate implementation

[

of emergency protective actions when necessary and that dissemina-tion of such information at the earliest possible date would increase the likelihood that all segments of the resident i

1

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- -, . -, , , . , - - . - . , , , -. , - - . , . , , _ . . - - . , , . , , - , - - , ~ . ,-,.-,--,--.~,,,,.n.

and transient population of the LPZ will be adequately informed.30/ -

!!ad the Commission intended that a public information and education prsgram regr.rding emergency response need be instituted only weeks prior to actual operation of a nuclear facility, its regulations certainly would reflect such a view. In order to assure the best possible response by the public this board believes that PGandE should have instituted a public infor:.tation program long ago. The absence of a final determination as to method of notification is no excuse. -

26. To demonstrate the adequacy of the Diablo Canyon h offsite plans, the Staff, through the Sears testimony, ci tes an alleged FEMA " finding" documented in (1) a Memorandum for I

liarold R. Denton and John W. McConnell trom FEMA /NRC Steering Committee and (2) a FEMA /NRC Interim Agreement on Criteria for i

! 30/ The Kemeny Commission recognized the direct connection i

between an adequate public infor. nation p 7 gram and ef fectiva emergency preparednes;. In its Report, the Commission recommended the following:

l l

If emergency planning and response to a radiation-related emergency is to be effective, the public must be better informed about nuclear power. The Ccamission recommends a program to educate the i public on how nuclear power plants operate, on radiation and its hea..th i effects, and on protec-l tive actions against radiation. Those who would l

be affected by such emergency planning must have clear information on actions they would be required to take in an emergency.

J. I. Exh. 1143, at /7.

J i

Low Power Testing at New Commercial Facilities. (Scars , at 6. ) 31/ -

, on cross-examination of Sears, however, a number of significant

facts were revealed. First, regarding the 6xtent of Sears' personal knowledge of the basis for the e'.ocuments, (a) he was not a member of the FEMA /NRC Steering Committee at the time the documents were issued (Scars, Tr. 11016); (b) he was not present at the Steering Committee' meetings at which thej were discussed (Sears, Tr. 11069-70); (c) he did not personally know whether FEMA actually reviewed the specific Diablo Canyon offsite plans for adequacy prior to the issuance of those documents (id. ) ; and (d) he had no personal knowledge of the Denton-McConnell corres-pondence cited in the FEMA /NRC Interita Agreement nor could he recall whether r.uch correspondence contained any reference to an ,

evaluation by FEMA of the specific Diablo Canyon offsite plans.

1 (Sears, Tr. 11081, 11270.) In fact, such correspondence contains i

no reference to Diablo Canyon or its emergency plans. (Gov.

l Brown Exhs. 4 and 5.)

27. Second, regarding the content of such documents, (a) there is no indication that FEMA evaluated tLe Diablo Canyon site-specific offsite plans (Ecars, Tr. 11079); (b) the word

" finding" does not appear in either of the two documents (Sears, Tr. 11264); and (c) they form the basis not only for Sears' conclusion but also for the Staff's statement in SER Eupp. 12, 31/ In its Proposed Findings of Fact and Conclusions of Law, PGandE also relics on FERA/NRC docursnts in support of its claim

~

that the Diablo Canyon offsite plans are adequate. PGandE's Proposed Findings of Fact and Conclusions of Law, at 5-6, 34 (June 1, 1981).

1 i

at III-3, that FEnA had "previously specifically approved the emergency preparedness at Diablo Canyon for low power testing on an interim basis." (Sears, Tr. 11277.)32/ -

28. In light of this evidence, the board can only conclude that FEMA, which is the federal agency responsible for review of offsite plans prior to plant licensing by the NRC,33/ has neither 32/ The parties srlpulated that the FEMA /NRC Steering Committee documents relied upon by Sears were issued on March 12, 1980. (Tr. 11084.) Thus, any " finding" by FEMA approving emergency preparedness for low power operations at Diablo Canyon would have to have been made at least eight months prior to the effective date of the Commisr41on's revised emergency planning regulations and four months before PGandE even applied for a low power license. Sears was apparently unaware of thia, and, similarly, he did not know whether the proposed Diablo Canyon low power test program had ever been routed either to FEMA or the FEMA /NRC Steering Committee. (Sears , Tr. 11071, 11091.)

33/ See " Memorandum of Understanding Between NRC and FEMA to Acccmplish a Prompt Improvement in Radiological Emergency Plan 7ing and Preparedness" ("MOU") (January 11, 1980) (Gov. Brown Exh, 3) . This memorandum was entered into in response to the President's December 7, 1979 decision "that FEMA will take the lead in off-site planning and response. . . . MOU, at D-3.

Under section II of the agreement, FEMA's responsibilities include the following:

1. To take the lead in off-site emergency planning and review and assess State and local emergency plans for adequacy. *

3. To complete, as soon as possible, the review of State and local plans in those states affected by plants scheduled for operation in the near future.

! 4. To make findings and determinations as to whether State and local emergency plans are adequate and capable of implementation (c.a.,

adequacy and maintenance of procedures, training, resources, staffing levels, and qualifications and equipment adequacy).

• MOU, at D-4.

(- - _____________ _ __ __ _

reviewed the specific Diablo Canyon offsite plans nor found them adequate for lcw power testing. The FEMA /MRC Steering Committee documents relied upon by the Staff give no indication whatsoever of any substantive finding by FEMA with respect to either the State or local plans.34/ Moreover, the testimony by Sears at the hearing indicated clearly his lack of personal knowledge concerning the basis for the documents cited by him, thereby undercutting as well the cupport for his own conclusion that the Diablo Canyon offsite preparedness'is adequate. IIis lack of personal familiarity with the basis for the FEMA /NRC documents effectively prevented other parties from enquiring into that issue on cross-34,' The Interim Agreement notes that Diablo Canyon is located in a state with an emergency plan which has received an MRC concurrence. This clearly does not, however, relieve FEMA of its obligation to review the specific offsite plans prior to licensing by the NRC. As the Director of FEMA stated in the '

June 24, 1980 Motice of Proposed Rulemaking entitled " Review and Approval of State and Local Radiological Emergency Plans and Preparedness":

[T]he lead for review of the adequacy of offsite emergency plans and their capability of implemen-tation has been placed in FEMA and there is no longer an 'IRC voluntary concurrence program for State emergency plans. * *

• The provious MRC

" con _cu r re n ce s " do not satisfy all the recuirements tor FE:1A annroval of State and lccal plans under_

this requlation.

45 Fed. Reg. 42341, 43242 (emphasis added),

"oreover, t ir . Shiffer (PGandE) acknowledged oc cross-e:s am in a tion that the State plan is only a "back-up" plan, while the p ri:::a ry legal responsibility for offsite response rests with the local jurisdiction, the County of San Luis Obispo.

(Shi f f er, Tr. 10746-47.) For obvious reasons, therefore, reziew of the local plans is essential to a true understanding

< of the state of emergency preparedness at Diablo Canyon.

i 0

.. examination, an issue which the board considers critical in this proceeding.dE/ Accordingly, in the absence of any evidence of a substantive review by FEMA of the Diablo Canyon offsite plans, we cannot afford any substantive weight to the so-called FEMA " finding" referred to by the Staff in the Sears testimony and embodied in the FC:1A/NRC documents cited therein.

4. g+o f-Lew--Pewer- O cra t ien - -- -

29. In essence, both PGandE and the Staff contend

/

/

that any ceficiencies in the existing Diablo Canyon emergency

\

\

plans are insignificant in view of the reduced levo,1 of risk during low, in\xcomparison to full, poaer operatlob. While

's PGandC concedes that even at low power Offsite' preparedness is

\ ,

necessary to the outer edge of the low population zone (six

\ -

\ /

/

\

35/ This board cannot rely upon testimony of a witness unable ~to orsvide t h e b a's i s for his conclusions. In the Matter of Virninia Cloctric and hower Comnany (North Anna Power Station, Units 1 and 2), ALAB-555, CCII . Nuc l . Reg . Rep . 9 30,407, at 29,042 (1979). In Vircinia Electric, the Appeal Board stated this principle in unmistakable terms:

s

\

Manifestly, it will not do for an expert witness to state his hltimate conclusions on a crucial aspect of'\the issue being l tried and then to profens an inability

-- for whatever reason 1g to provide the foundation for them to theg docision-maker as well as the other litigants. Indeed, l

I a trier of fact would be der'elict in the dicenarce or its responsibilities were it to rest utonificant findinqs on expressions l c: o mo r t- obt.i.on not susceptibio or beirg te:ted on examination of the witness. A l 'llcensing board decision sutterings from such informity would be a fit candi'date for reversal. \

\

29,043 (emuhasis added).

_Id. a t. \

V

. . ~ . ~ . .

I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-27 5 0.L.

4 ) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) ) (Low Power Test

) Proceeding)

)

CERTIFICATE OF SERVICE I hereby certify that on this 26th day of August, 1981, I have served copies of the foregoing JOINT INTERVENORS' RESPONSE TO PACIFIC GAS AND ELECTRIC COMPANY'S FIra ? SET OF INTERROG.TTORIES, JOINT INTERVENORS NOTICE OF OBJECTIONS TO THE ATOMIC SAFETY AND

' LICENSING BOARD'S ORDER OF AUGUST 4, 1981, mailing them through the U. S. mails, first class, postage prepaid.

I Nunzio Pallodino, Peter A. Bradford, Chairman Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 1717 H Street, N.W. 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555-Victor Gilinsky, John F. Ahearne, Commissioner Commissionat i U.S. Nuclear Regulatory

• U.S. Nuclear Regulatory Commis.sion Commission 1717 H Street , N .W. 1717 H Street, N.W.

Washington, D.C. 20555 washington', D.C. 20555 Thomas Rober_ts, Commissioner U.S. Nuclear Regulatory Commission

! 1717 H Street, N.W.

Washington, D.C. 20555 i

, , - - - ~.,.--.x,, , , - - , - - , . , , . .,_,, -. - _ ,,, , ,,,,. , , ,,_ , - . . . ..-_.,,-m,,,, - , - , - . , _ _ - , - , . . . , . - . -,

I b

William Olmstead, Esq.

Richard S. Salzman, Chairman Marc R. Staenberg, Esq.

Atomic Safety & Licensing Edward G. Ketchen, Esq.

Appeal Board Office of the Executive Legal U.S. Nuclear Regulatory Director - BETH 042 Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. W. Reed Johnson Atomic Safety & Licensing Nancy Culver Appeal Board 192 Luneta U.S. Nuclear Regulatory San Luis Obispo, CA 93401 Commission Washington, D.C. 20555 Mr. Fredrick Eissler Scenic Shoreline Preservation Dr. John H. Buck Conference, Inc.

Atomic Safety & Licensing 4623 More Mesa Drive Appeal Board Santa Barbara, CA 93105 U.S. Nuclear Regulatory Commission Sandra A. Silver Washington, D.C. 20555 1760 Alisal Street San Luis Obispo, CA 93401 Admin. Judge John F. Wolf, Chairman Gordon Silver Atomic Safety & Licensing 1760 Alisal Street Board San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission David S. Fleischaker, Esq.

Washington, D.C. 20555 1735 Eye Street, N.W.

Washington, D.C. 20006 Glenn O. Bright Atomic Safety & Licensing Bruce Norton, Esq.

Board 3216 N. Third Street U.S. Nuclear Regulatory Suite 202 Commission Phoenix, Arizona 85012 Washington, D.C. 20555 Mr. Yale I. Jones, Esq.

Dr. Jerry R. Kline 100 Van Ness Avenue Atomic Safety & Licensing 19th Floor Board San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Andrew Baldwin, Esq.

Washington, D.C. 20555 Friends of the Earth 124 Spear Street Docket & Service Branch San Francisco, CA 94105 Office of the Secretary U.S. Nuclear Regulatory Harry M. Willis, Esq.

Commission Seymour and Willis Washington, D.C. 20555 601 California Street Suite 2100 San Francisco, CA 94308 Mrs. Raye Ileming aanice E. Kerr, Esq. 1920 Mattie Road Lawrence O. Garcia, Esq. Shell Beach, CA 93449 J. Calvin Cimpson, Esq.

California Public Utilities MHB Technical Associates Commission 1723 Hamilton Avenue 5246 State Building Suite K 350 McAllister Street San Jose, CA 95125 San Francisco, CA 94102 Carl Nieburger Malcolm H. Furbush, Esq. Telegram Tribune Vice President and General P. O. Box 112 Counsel San Luis Obispo, CA 93402 Philip A. Crane, Esq.

Pacific Gas & Electric Company Byron Georgiou, Esq.

P. O. Box 7442 Legal Affairs Secretary to San Francisco, CA 94120 the Governor State Capitol Building Arthur C. Gehr, Esq. Sacramento, CA 95814 Snell & Wilmer 3100 Valley Center Lawrence Coe Lanpher, Esq.

Phoenix, Arizona 85073 Hill, Christopher & Phillips 1900 M Street, N.W.

Washington, D.C. 20036 v'"s /' N T)c-

~

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%i OEL R. REYQOLDS, ESO.