ML20010G772

Answers to CA Governor Brown First Set of Interrogatories Re Emergency Preparedness.Affidavits & Certificate of Svc Encl.Related Correspondence

ML20010G772
Person / Time
Site:	Diablo Canyon
Issue date:	09/15/1981
From:	Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO.
To:	CALIFORNIA, STATE OF
References
NUDOCS 8109220511
Download: ML20010G772 (105)

Text

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BE70RE THE ATOMIC SAFETY AND LICENSING BOARD 5

6 7

I In the Matter of )

8 ) Docket No. 50-~275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 9 )

Diablo Canyon Nuclear Power Plant ) (Full Power P ocee. dings) 10 Units Nos. 1 and 2 ) j N, s 13 g @ ,

14 APPLICANT PACIFIC GAS AND ELECTRIC COMP o !S s' -

ANSWERS TO GOVERNOR EDMUND G. BROWN JR's 15 FIRST SET OF INTERROGATORIES Il@si 16 .

17 INTERROGATORY NO. 1:

18 (a) Describe and identify each study, evaluation, i9 assessment or other document in the possession, custody or 20 control of PG&E dealing with or relating in any way to the 21 time (s) necessary for and/or the feasibility of protective 22 actions in the event of a radiological emergency. By way of 23 example only, " protective actions" include an evacuation of 24 the Diablo Canyon site and adjoining areas, includin 7 the 25 basic emergency planning zone, the extended planning zone, 26 and the ingestion pathway zone. DS fft hD50ENOE$8;fy, '

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k. . . . - . _ _ _

1 1 (b) Describe which of such documents are 2 completed and which are underway. For those underway, 3 state: (1) what has been completed; (2) what remains to be 4 completed; and (3) the schedule for completion of the 5 remaining work.

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7 RESPONSE TO INTERROGATORY NO. 1.

8 (a) 1. " Manual of Protective Action Guides and Protective 9 Actions for Nuclear Incidents," U.S. Environmental 10 Protection Agency (EPA-520/1-75-001), September 11 1975 (revised June 1980).

12 2. " Reactor Safety Study," WASH-1400, October 1975.

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13 3. " Accidental Radioactive Contamination of Human 14 Food and Animal Feeds," U.S. DHEW (DHHS)/FDA, 15 Federal Register, December 15, 1978 (43 FR 58790).

16 4. "Public Protection Strategies ~for Potential -

17 Nuclear Reactor Accidents - Sheltering Concepts 18 .

with Existing Public and Private Structures,"

19 Sandia Laboratory (SAND 77-1725).

20 5. " Examination of Offsite Radiological Emergency l

i 21 Measures for Nuclear Reactor Accidents Involving 22 Core Melt," Sandia Laboratory (SAND 78-0454).

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1 6. " Protective Action Evaluation Part II, Evacuation 2 and Sheltering as Protective Actions Against 3 Nuclear Accidents Involving Gaseous Releases,"

4 U.S. Environmental Protection Agency (EPA 5 520/1-78-001 B).

6 7. " Evacuation Times Assessment for the Diablo Canyon 7 Nuclear Power Plant," Alan M. Voorhees &

8 Associates, September 1980.

9 8. " Emergency Ptanning Zones for Serious Nuclear 10 Power Plant Accidents," State of California Office 11 of Emergency Services, November 1980.

12 9. Draft " State of California Nuclear Power Plant 13 Response Plan," January 1981 (revised March 1981).

u 14 10. Draft " State of California Department of Health 15 Services Implementing Procedures - Volume 'II , "

16 March 1981.

17 11. Draft " San Luis Obispo County Nuclear Power Plant 18 Emergency Response Plan," May 1981.

19 12. -GandE Diablo Canyon Power Plant Units 1 & 2 20 Emergency Plan, August 1981.

21 13. PGandE Diablo Canyon Power Plant Units 1 & 2 22 Emergency Procedure RB-10, " Protective Action 23 Guidelines," September 1, 1981.

24 14. TERA Report, '" Earthquake Emergency Planning at 25 Diablo Canyon," September 2, 1981.

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1 (b) All of the above documents are complete 2 except numbers 9, 10, and 11, the completion dates of 3 which are unknown.

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6 7

8 INTERROGATORY NO. 2:

9 (a) Identify and describe the criteria that PG&E 10 employees are trained to apply in determining whether to 11 recommend evacuation (cnsite and/or offsite) versus 12 sheltering.

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13 (b) Identify and describe all analyses or other 14 documents which support or in any way relate to these 15 criteria.

16 (c) Identify and describe all training manuals, -

17 operating procedures, or other instructive or educational 18 materials.that relate in any way to these criteria.

l 19 (d) Describe all equipment available to PG&E l 20 and/or offsite response personnel to assess and predict the 21 likely consequences of an accidental radioactive releace 22 from Diablo Canyon. Include in your response a description l

23 of tb onsite meterological tower and computer used to 24 determine real-time atmospheric dilution factors.

l 25 fff 26 fff l

1 . . . . -. _ . . - - . , , . . _ . - - - . ,- .- . .- - _.

1 RESPONSE TO INTERROGATORY NO. 2:

2 (a) Criteria for plume exposure pathway 3 protective action recommendations for the general 4 public are based on the " Manual of Protective Action 5

Guides and Protective Actions for Nuclear Incidents 6

(EPA-520/1-75-001). For the plume exposure pathway, 7 the principal protective actions . recommended for the 8 public would be sheltering and/or evacuation.

9 The effectiveness of evacuation in limiting a 10 radiation dose is a function of the time required to 11 evacuate. In cases where there is no time to evacuate 12 prior to arrival of the plume, or where the projected 13 evacuation time and time before plume arrival are 14 nearly equal, the dose reduction benefit of sheltering 15 vs. evacuation and being overtaken by the passing plume 16 _would be evaluated on a' case-by-case basis.

17 On-site protective action criteria are based 18 on minimizing exposures for non-essential site 19 personnel. Evacuation is the principal protective 20 action and is considered at the Alert emergency action -

21 level when such action can prevent significant 22 exposure. Evacuation of non-essential personnel is 23 generally conducted at the Site Emergency level and is 24 automatic at the General Emergency level. Shelt< ring 25 would be used as a protective action for non-essential 26 personnel in the event the dose expected during l

i 1 evacuation is higher than that which would be received 2 in a shielded or protected area.

3 (b) See response to interrogatory 1(a).

4 (c) See response to interrogatory 1(a).

5 (d) See Section 7.3 of the Diablo C nyon Power 6 Plant Emergency Plan and Section 2.3 of the FSAR.

7 8

9 10 11 INTERROGATORY NO. 3:

12 Identify and describe the public information

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13 program for emergency planning and preparedness proposed by 14 PG&E to support PG&E's application for a full power 15 operating license for the Diablo Canyon facility. Identify 16 and describe all documents which in any way relate to this -

17 public information program including, without limitation, 18 any brochures, statements to be published in news media or 19 broadcast on radio or TV, materials to be sent to PG&E's 20 customers (enclosed in bills or otherwise), or public 21 notices (in draft or final form), which constitute any part 22 of or relate in any way to the public information program.

l 23 24 RESPONSE TO INTERROGATORY NO. 3:

25 Pacific Gas and Electric Company has initiated a 26 variety of programs designed to effectively notify the l

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1 public about appropriate protective actions in the event of 2 a plant emergency.

3 These efforts can be categorized as notification 4 during an emergency and an ongoing community 5 education / awareness project.

6 NOTIFICATION DURING AN EMERGENCY 7 There are two levels of notifications --

8 non-general emergency and general emergency, 9 Non-General Emergency 10 If an unusual event reaches an alert stage and the 11 San Luis Obispo County Emergency Operations Center and the 12 Media Center at Cuesta College are activated, the County 13 Public Information officer will be issuing periodic news 14 releases on the status of the emergency, the plant, and 15 protective measures necessary, if any.

16 These releases and the press conferences will be a l

17 timely and effective way of notifying the public, especially 18 since the local media -- including the radio and television 19 stations --

will be able to disseminate the information 20 quickly. During the recent compressed time field exercise 21 conducted by NRC and FEMA to judge the on-site and off-site 22 emergency response plans, news conferences were held and

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23 news statements released at least every hour.

24 Before the Media Center is activated, Pacific Gas 25 and Electric Company is prepared to alert the public, 26 through major local area and regional broadcast and other l

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1 media, of any actions the public might prepare for -- such 2 as sheltering or evacuation.

3 The public can be referred to the Nuclear 4 Emergency Response Plan Booklet, which will be 5 hand-delivered to every residence, place of husiness, public

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6 institution and commercial establishment in the Emergency 7 Planning Zone, with other distribution throughout the 8 county.

9 Residents and others can also be referred to Page 10 A-4 of the San Luis Obispo County telephone book Survival 11 Guide (to be published in October 1981). (Please see the 12 following Ongoing Community Education Awareness section for 13 more information.)

14 Both the booklet and the telephone page contain 15 basic information on radiation, the Diablo Canyon plant, 16 nuc?aar power, sheltering and evacuation. Once the county 17 approves its Nuclear Emergency Response Plan, more- specific 18 information on evacuation routes, reception and care 19 centers, and other county elements of the emergency plan 20 also will be available.

21 General Emergency 22 If a general emergency (off-site radiological 23 release) is declared, the Early Warning System (EWS) will

24 be activated. The sounding . of the sirens (and other 25 measures to reach remote and/or transient populations) will 26 alert the populace to tune their radios or televisions to

1 the Emergency Broadcasting System (EBS) station for further 2 direction. The public will know to do this because of the 3 ongoing community education program PGandE has begun and 4 throdgh county educational efforts.

5 The message on the EBS will be wri ten and 6 released by the county. Other area radio and television 7 stations will have the capanility to relay messages soon 8 after the EBS broadcast. The messages will be repeated or 9 changed as necessary at the direction of the county.

10 In addition to the EBS information, the media 11 center will still be operating and the public will be 12 receiving messages and information based on the statements 13 released and news conferences held there.

14 ONGOING COMMUNITY EDUCATION / AWARENESS 15 PGandE has developed a comprehensive community 16 education and information plan to help ensure residents of 17 the emergency planning zone are informed.

j 18 At this point in their development, none of these 19 materials specifically refers to information that will be 20 contained in the county's Nuclear Emergency Response Plan 21 for its residents. Once the county adopts a final version 22 of this plan, the materials will be updated to reflect the 2,3 information in the county plan.

l 24 In general, updates or revisions are planned i

25 annually, with the exception of the "Diablo Canyon 26 Newsletter" -- a quarterly publication.

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1 The program elements are: 1 2 Emergency Response Information: Booklet on Diablo Caryon 3 Nuclear Power Plant and how it works, with 4 information on radiation, what the raublic 5 should do in an emergency, locations of 6 emergency care centers and evacuation routes 7 (once county plan is approved), and a phone 8 number to call for further information.

9 Distribution: Door-to-door to all households, businesses, 10 hotels, motels, and public institutions in 11 the Emergency Planning Zone (EPZ). To 12 appropriate public officials. By mail to 13 residents in extended planning zone. Spanish 14 language version to be available, with notice 15 in Sp.3nish and English in English version 16 that a Spanish language booklet is available,

• 17 with instructions on how to obtain it.

18 Booklets will be furnished to all new 19 customers. Booklets will also be available 20 at all PGandE, state, county, and local 21 government offices in the county.

22 Frequency: Annually. Distribution will be the same as 23 in the first year except that mail delivery 24 will be used instead of door-to-door.

25 Support- Advance radio, TV, print advertising, 26 publicity, news releases, and local PGandE

1 bill inserts will call attention to the 2 distribution and offer copies. Display in 3 local PGandE offices will also be used, with 4 follow-up ads and publicity.

5 Emergency pages in telephone book, will give instructions to 6 the public on how to respond in an emergency 7 and the place to call or write for further 8 information. It will appear as page A-4 of 9 the 1982 directory (October 1981).

10 Distribution: All telephone subscribers in San Luis Obispo 11 County.

12 Frequency: Annually in each new book beginning October 13 1981, 14 Support: News releases, features in a new Diablo 15 Canyon newsletter to the community (see 16 below), notir:es posted in hotels, motels, and 17 public recr'aational areas. All will call l 18 attention to the phone book as a source of l

[ 19 information on emergency planning.

! 20 Public Service nnouncements (PSAs) will be on local radio 21 and television. These PSA's will call atten-22 tion to the telephone book information, on 23 the need to know what to do in the event of l

24 an emergency and on other aspects of the l

i 25 emergency response plan. Stations will be 26 I

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1 provided with pre-recorded tapes and scripts, 2 or both.

3 Distribution: All radio and TV outlets, including cable, in 4 San Luis Obispo County.

5 Frequency: As appropriate. New PSAs will be furnished 6 at least annually.

7 Posted signs: Wil' be located in public places such as 8 parks, beaches and recreation. areas. These 9 will also be suitable for use in schools, 10 hospitals, public entertainment centers, 11 hotels, and motels.

12 Distribution: At sites located within the EPZ, to be 13 selected by the county.

14 Frequency: Updated as needed.

15 Emergency directior. sheet will be provided for restaurants, 16 hospitals and other institutions. These will 17 not be posted for public viewing but for the 18 information of institutional managers in 19 advising guests or occupants what to do in an 20 emergency.

21 Diablo Canyon Newsletter: This will be a periodic mailing i

22 to all homes and businesses in the EPZ, 23 giving educational information on nuclear f

24 power, Diablo Canyon, radiation and health, 25 emergency planning, shelters, etc. It will 26 also contain news items about progress and

1 new developments at Diablo Canyor.. Its 2

purpose will be to keep the community updated 3

on new developments in emergency planning, 4 sustain awareness of the plan, _

build 5

confidence in the safety of the plant by 6

increasing the community's familiarity with 7 it and to lessen fears about radiation by 8 providing regular information on the subject.

9 It will give a place to call or write for 10 additional information.

4 11 Distribution: By mail, to all residents and businesses 12 within the EPZ.

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13 Frequency: Quarterly, possibly more frequently.

14 Media backgrounders: These will be conducted at the place 15 of business of the SLO County media. They 16 .

will be formal programs, beyond the normal 17 regular contacts, and will cover emergency 18 plans, information concerning radiation and 19 other nuclear subjects and how information 20 will be handled during a plant emergency.

j 21 Distribution: To all interested radio, television, and 22 print media throughout the PGandE service 23 area, and to . media in Los Angeles. Seminars

- 24 may prove more suitable for out-of-county 25 media.

i 26 Frequency: At least annually.

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1 Speakers: Technical speakers from the plant's staff 2 will be utilized as speakers within the 3 surrounding communities.

4 Nuclear exhibits: Nuclear information displays, including 5 the current Nuclear exhibit, will be set up 6 in Los Padres district offices, covering, 7 among other subjects, radiation.

8 Mobile Environmental Monitoring Lab _: (MEML) Suitable for 9 inspection by small groups.

10 Special audiences: Using speakers, slide shows and 11 exhibits, outside experts, special printed i 12 material, audio- visual presentations, etc.,

13 regular educational contacts will be 14 maintained, with the community, government 15 officials, public schools, clergy, service 16 clubs, health agencies and societies, 17 employees and other special agencies as 18 required or requested.

19 i 20 21 22 23 INTERROGATORY NO. 4:

24 Has PG&E commenced its full power public informa-25 tion program. .I so, describe each and every step taken 26 thus far and the schedule for remaining steps. If not, 1 describe PG&E's schedule for commencement and full 2 implementation of that program.

3 4 RESPONSE TO INTERROGATORY NO. 4:

5 Yes. As seen by the attached schedule (as of 6 mid-August), many elements of the program outlined in the 7 answer to interrogatory No. 3 are completed and in use.. In 8 addition, see answers to previous interrogatories propounded 9 by Joint Intervenors.

10 EMERGENCY RESPONSE INFORMATION 11 Proj ect 12 Project Due  % Done Status 13 1. Booklet on DCPP & Emergency 15 Dec 75 Text being revised.

I 14 Response Plan -- writing, New layout made.

printing

2. Above in Spanish 14 Aug 10 Awaiting English version 16 -

Translators ready.

17 3. Distribute booklet 19 Aug 5 In holding pattern, door-to-door 18

4. Phone book emergency page 1 July 100 Complete To Printer.

5. (a) Radio, TV, PSAs on 20 July 100 Complete.

20 booklet 21 6. News release on booklet 1 Oct 70 In holding pattern.

22 7. Advertising on booklet 1 Aug 50 (A) copy and layout developed.

23 In approval.

0 (b) Production.

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8. Bill insert on booklet 1 Aug 51 (A) Developed.

25 In approval.

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0 (B) Production.

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1 Project

! Project Due  % Done Status 2'

9. News release on phone page 1 Oct 50 PTT to do

10. (a) Emergency Plan signs (a) 1 Nov 10 Awaiting County 4 approval of plan.

Mo6tana de Oro sign i 5 in clearance to NPO I (b) Arrange posting (b) 15 Dec 0 6

11. PSAs on Plan 30 July 50 Awaiting County 7

approval of plan.

8 12. (a) Develop and 1 Nov --

(b) distribute posted 15 Dec 25 Awaiting County 9 instructions for motels, approval of plan.

10 13a. Write notification to LPZ 15 July 100 Completed.

residents of Emergency 11 procedures.

12 13b. Distribute notification. 15 Aug 50 New due date to

. verify identifi-13 cation of LPZ residents 14 14a. Slide show on response plan 15 July 100 Ccmpleted.

14b. Mini version 1 Ang 100 Completed-being shown ,

14c. Speakers support nuclear 15 Sept 20 New program-17 power approved.

18 15. Speeches on plan, radiation 15 July 100 Complete week.

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16. Videotape on 30 July 100 Complete-Showing 20 A. Plan B. Radiation 100 Complete-Showing 21

17. Overall video tape on DCNPP 15 Sept 1 Writing script.

22 18a. Develop and 1 Nov 10 Awaiting county 23 18b. Distribute direction 19 Oct 20 approval.of plan for instructions 24 25 ///

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1 GENERAL EMERGENCY RESPONSE INFORMATION 2 Proj ect Proj ect Due  % Done Status 3

1. Quarterly Newsletter 20 July 100 Completed.

2. Media backgrounders 1 Aug 75 LA-to be done.

3. Press tc for 6 (a) backgrounders, _26 July 100 Complete (b) drill 10 Aug 75 In progress 7 (c) emergency 15 Aug 70 Holding 8 4. Plant tours 14 Aug 100 Complete 4a. Overlook Tours 100 Complete 9

5. Train speakers on 15 July 100 Complete 10 D.C./ nuclear 11 6. Community seminars on 14 Aug Ongoing-% deleted nuclear and radiation

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7. Mobile environmental 17 Apr 100 Showings complete.

13 monitoring lab (MEML) 14 8. Publicity on MEML 6 May 100 Complete.

15 9. Displays in area local offices 1 Aug 100 Completed 16 10. General Informatic , --- ---

Ongoing special audiences 17 a. Doctors 1 Aug 100 Complete

b. Schools 1 Aug 100 All contacts 18 complete l c. Government Officials 14 Aug Ongoing-% deleted 19 d. Clergy 1 Aug 100 Complete

e. Employees Ongoing 20 f. Community leaders Ongoing-% deleted 21 11. Slide show and t. ilk on 1 Apr 100 Complete general nuclear 22

12. Advertising on nuclear 76 Ongoing 23

13. Staff backgrounding 22 June 100 Sessions complete.

14. Selected Staff to PWR School 1 Aug 100 Completed 25 26 ///  ;

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1 GENERAL EMERGENCY RESPONSE INFORMATION 2 Project Project Due  % Done Status 3

1. Develop plan as per 4 Feb 100 Completed and approved 4 NUREG-0654 5 2. Select media center and 1 July 100 Co pleted get approval 6

3a. Secure media center 15 Aug 100 Completed 7 3b. Rehabilitate annex 15 Aug 100 Completed 9c. Secure alt. media center 15 July 100 Completed 8

4. Staff up 15 Apr 100 Completed 9

5. Phones and other communications 1 Aug 68 Installation underway.

10 Sa. Hard copy communications 7 July 100 Completed Training continuing 11

6. Employee information plan 30 July 100 Completed 12

. 7. Plan info delivery to 15 June 100 Recommendation made 13 PG&E Offices to NPE and management 14 8. Clerical services 20 July 100 Completed 15 9. A-V, photo services 14 Aug 100 Completed 16 10. Rumor control center, SLO 14 Aug 100 Completed -

(Public Infor Center) 17

11. Training staff on ERP 14 Aug 85 Ongoing 18

12. Communications Equip. 1 Aug 80 Progress-waiting 19 on PTT 20 13. Visuals 20 July 87 Proceeding 21 14. Develop with SLO County EBS 1 Aug 100 Turned over~to radio-TV messages and get SLO Co. 7/28.

22 commitments.

23 15. Develop timely exchange of 1 Aug 80 Third meeting info between spokespersons set for 8/8/81 24 25 ///

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1 Project Project Due  % Done Status 2

16. Prepare public info program 1 Aug 40 Being developed 3 for site review team and EWS task force approval, including 4 mailers for billings, telephone book inserts, briefings, etc. -

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17. Implement PI plan for County 1 Aug 35 First reusse )

6 EWS. Prepare and ivplement mailed 7/7/81 media programs 7

18. Provide area phone number on 1 Aug 100 Complete 8 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis 9 I 10 l

11 12 13 INTERROGATORY NO. 5:

14 (a) Identify and describe each and every drill or 15 exercise which has occurred relating to or testing all or 2

16 any part of the PG&E and/or offsit.e emergency preparedness 17 to implement or carry out duties under the onsite and 18 offsite emergency respon.e' plans.

I 19 (b) Identify all participants in and observers of 20 each drill or exercise.

21 (c) Identify and describe all written critiques 22 and other documents (including photographs and motion

, 23 pictures) which relate in any way to these drills or 24 exercises.

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1 RESPONSE TO INTERROGATORY NO. 5:

2 Drills or exercises have been conducted at 3 three levels: (i) corporate emergency response; 4 (ii) onsite, and (iii) integrated.

5 6 (a)(i) Practi:al application of concepts introduced 7 in formal emergency response classroom training 8 was achieved through Table-Top walkthrough 9 sessions, actual simulations or drills and the 10 full FEMA exercise. These activities were 11 structured to first test sma'l portions of the 12 emergency response organization, then integrate 13 these responses in larger scale walkthroughs, 14 drills, etc.

15 Walkthrough sessions involved "round table" 16 group discussions utilizing postulated accident -

17 scenarios to identify and review appropriate 18 . emergency response actions. Simulations, drills, 19 and the FEMA exercise utilized postulated accident 20 scenarios that were applied to test emergency 21 responses in an actual fie environment.

22 A detailed schedule .dentifying participation 23 of the Corporate Emergency Response Organization 24 (CERO) in walkthrough sessions, simulations, 25 drills and the FEMA exercise is provided in 26 Attachment I.

1 (b)(i) Participants in walkthrough- sessions, 2 simulations, drills, and the FEMA exercise were 3 shown as needed from CERO personnel lists 4 established in respective Corporate Emergency 5 Response Plan (CERP) implementing piocedures.

6 Attachment II provides a current overall listing 7 of CERO personnel. It is impossible to 8 individually identify all participants in each 9 drill or exercise since such comprehensive data 10 was not collected at the time. The vast majority 11 of the persons identified have participated in the 12 drills.

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13 EDS Nuclear Inc. provided personnel to 14 observe walkthrough sessions and simulations 15 involving the CERO. These individuals are listed 16 . in Attachment-III.

17 (c)(i) EDS Nuclear Inc. provided critiques of the 18 CERO walkthrough sessions and simulations. These 19 critiques as well as scenarios generated to 20 support these activities are listed in Attachment 21 IV and are available as discovery documents.

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l 1 ATTACHMENT I SCHEDULE OF CERO PARTICIPATION 2

., Date i 3 Drill Participating Departments Conducted 4 Walkthrough 3A Entire Emergency Response 3-20-81

. Organization -

Walkthrough 3B Security, Personnel Relations 3-23-81 Walkthrough 3C Communications 3-25-81~

Walkthrough 3D Materials 3-27-81 8 General Construction Eng. & Tech. Support 9 Div. Support Quality Assurance 0

Walkthrough 3E Radiological Analysis and 3-30 11 Protection 12 Walkthrough 3F Gov. Relations 4-1-81

• Public Relations 13 Law Insurance 14 Safety, Health and Clain.s 15 Utility Corporate PGandE 4-2-81 Training Utate OES 16 FEMA -

SLO County 17 Stone & Webster Voo'rhees 18 Make-Up Individuals from: 6-2-81 19 Nuclear Projects i

Public Information 20 Quality Assurance 21 Simulation 4A, Security Personnel 5-2-81 4B, 4C Relations, Communications Simulation 4D Materials, General Construction, 5-5-81 23 Engr. & Tech Support, Division Support l, 24 Quality Assurance 25 Simulation 4E Radiological Analysis and 5-8-81 Protection 26

4 1 ATTACHMENT II 2 CERO PERSONNEL 3

CWAllen JRHerrera GSPruett 4 RRAlvea JBHoch WTRapp MRAmerio GNHorne CERalston 5 GHAster RCHowe WARaymond RSBain KHHuston HWReynolds 6 RWBarbey AJinkerson RWRichardson WRBarnes WBKaefer CLRichmond 7 DJBaxter RLKelmenson SPRobison LCBeanland DLKennedy JVRocca 8 ALBechtold WJKeyworth BERoddick RPBenton EBLangley, Jr. GMRueger 9 RVBettinger BSLew GCRussell GABlanc CALewis PFlutkowski 10 JVBoots HLiu BFSadler HEBrennan RFLocke BTSaenz 11 SGBrown RWLorenz CGSarkiaian PCBurgess DGLubbock COSchrial 12 LBCarter LGLunsford JOSchuyler

. BJCasey ANLyon GNScourkes 13 LACole JMacCormick DPSerpa DCorona GAManeatis JASexton 14 PACrane CKMaxfield BWShackleford GWCryer BMcCloskey DRShaffer 15 RPDavin RJMcDevitt HCShaw OHDavis JSMcKarns JDShiffer 16 HEDeady RJMcKell CGShih BADettman AWMedcalf AWSimila 17 TGdeUriate EJMeyers ALSimmons FJDodd FWMielke, Jr. SMSkidmore 18 DLDuke RHMiller ACSmith RDunleary MLMooney BMSpeckman i 19 RJEider. TFMorris AGStrassburger GAEnglish RDMullikin WMStubblefield 20 RDEtzler JCNeel GSwallow l

RDFagg AJNavolo RMSwanson l 21 SMFandel RFNichols PASzalinski l TRFerry WPNoone RDTesta 22 EHFletcher RROchsner RCThornberry l

EFortner DAOglesby RHThuillier 23 JHFraser ROhlbach RGTodero

JLFrazier DOkabayashi JDTownsend l

24 WHFujimoto RPatterson MRTresler i WFunabiki HNPeelor RTTwiddy 25 WSGarrett RJPeters JAVance CDGilson CHPeterson JRVanSchaick 26 EAGiudici GAPierce JCVocke l l

1 Attachment II CERO Personnel (continued) 2 3 REGleason HSPitner RMWetherall KMGodfrey CTPolidoroff VFWittman 4 DDGubara DWPooler LFWomack DRHanes JLPotter RAWong 5 RAYoung 6

7 8

9 10 11 12 ATTACHMENT III

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13 EDS NUCLEAR INC. OBSERVERS 14 Robert B. Wester Klenne L. Herman 15 Mark Goldstein Ronald M. Polivka 16 Mark G. Smith

• 17 Edward T. Quinn RcLert Ridge 18 David L. Powell Terrance W. Pellisero Vlada Kuceravy 19 Laura S. Listug Dennis H. Paley 20 Mark D. Schumann 21 22 fff 23 ///

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1 ATTACHMENT IV 2 DRILL SCENARIOS AND CRITIrdES a 3

4 5 Drill Scenarios 6 PGandE Corporate Emergency Preparedness Drill Scenario Walkthroughs 3A-3F 7 March 1981 8 PGandE Corporate Emergency Preparedness Drill Scenario Communications Test 9 April 1981 10 PGandE Corporate Emergency Preparedness Drill Scenario Simulations 4A-4F 11 May 1981 12 PGandE Corporate Emergency Preparedness Drill Scenario

. Walkthrough 3 13 June 1981 14 Diablo Canyon Power Plant Emergency Preparedness Exercise Scenario

. 15 Field Exercise Dress Rehearsal August 1981 17 Drill Critiques 18 Critique of Corporate Emergency Preparedness Walkthroughs 3A-3F Critique of Corporate Emergency Preparedness. Communications Test.

Critique of Corporate Emergency Preparedness Simulation 4ABC 21 Critique of Corporate Emergency Preparedness Simulation 4D Critique of Corporate Emergency Preparedness Simulation 4F Critique of Corporate Emergency Preparedness Walkthrough 3E Critique of Corporate Emergency Preparedness Simulation 4 24 25 ///

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1 (a)(ii) The following drills have been conducted by 2 the Diablo Canyon plant staff:

3 May 2, 1979 Emergency Exercise August 20, 1980 Radiological Personnel Injury Drill 4 June 9, 1981 Radiological Personnel Injury Drill July 3, 1981 Site Emergency Signal Drill-5 July 22, 1981 Plant Staff Notification Drill August 13,1981 Emergency Plan Exercise -

6 Preparation Drill August 17, 1981 Emergency Plan Exercise -

7 Preparation Drill-a (b)(ii) The following participated or observed the 9 drills identified above:

10 May 2, 1979 Participants - Diablo Canyon Site Personnel, San luis Obispo Ccunty, French 11 Hospital, California Dept. of Forestry 12 Observers - NRC

, August 20, 1980 Participants - Diablo Canyon Site Personnel, 13 French Hospital Observers - PGandE General Office Personnel 14 June 9, 1981 Participants - Diablo Canyon Plant Staff, French Hospital 15 Observers - Helgeson Nuclear Services, Inc. Persennel 16 July 3, 1981 Participants - Diablo Canyon Plant Staff -

Diablo Canyon Construction 17 Personnel Observers - Diablo Canyon Plant Staff 18 PCandE General Office Personnel

. July 22, 1981 Participants - Diablo Canyon Plant Staff l

19 Observers - None l August 13, 1981 Participants - Diablo Canyon Plant Staff

20 Observers - Stone and Webster Personnel August 17, 1981 Participants - Diablo Canyon Plant Staff 21 PGandi General Office ~ Personnel San Luis Obispo Cc.inty 22 Hea^.th Dept.

California Office of 23 Emergency Services Observers - Stone and Webster Personnel 24 fff 25 fff 26 ///

1 (c)(ii) The following documents relate to the drills 2 identified above:

3 1. Memo to File, " Discussion of Emergency Exercise of May 2, 1979" by J. .D. Shiffer, 4 undated.

5 2. Memorandum to File,

Subject:

' Emergency Drill, Personnel Injury (Radiological),

6 August 20, 1980, by J. V. Boots, 8/26/80.

7 3. Memorandum to File,

Subject:

Personnel Injury (Radiological), June 9, 1981, by 8 H. W. C. Fong, 6/15/81.

9 4. Memorandum to File,

Subject:

Emergency Plan Drill Report (July 3, 1981), by W. J.

10 Keyworth, 7/13/81.

11 5. Memorandum to File,

Subject:

Emergency Plan Drill Report (July 22, 1981), by W. J.

12 Keyworth, 7/23/81.

13 6. Drill Log -

August 13, 1981, undated, unsigned.

7. Drill Log -

August 17, 1981, undated, 15 unsigned.

16 (a)(iii) June 8 - 9 Medical Drill 17 June 16 - 17 Briefings (2) l Week of June 22 Preliminary Assessment Training 19 July 8 Tabletop (key county people).

July 9 Monitoring / EOF Drill 21

, Week of July 13 Accident Assessment Course / Drill 22 July 14 Reception / Care Facility Drill 23 JuAy 21 - 22 Alert / Warning Evaluation July 28 Evacuation / Control Drill 25

. August 5 Full-Scale c.OC Drill 26

1 August 17 TSC/EDF/EDAC/CIRL Drill 2 August 19 Full Field Exercise 3 August 21 Exercise Critique 4

5 (b)(iii) French Hospital 6 San Luis Obispo 7 San Luis Obispo/ San Jose 8 San Luis Obispo/ San Jose 9 C.S.T.I.

10 Sheriff's/ Field 11 C.S.T.I.

12 Paso Robles Fairgrounds 13 San Luis Obispo 14 Sheriff's Office 15 Sheriff's Office

16 Sheriff's Office -

17 San Luis Obispo 18 19 (c)(iii) For each of the exercises listed ab' o ve in 20 Sa(iii) sign up sheets were utilized. These 21 documents are available under responses to 22 requests for production.

23 24 25 26

1 INTERROGATORY NO. 6:

2 (a) Describe all training provided to onsite and 3 offsite emergency response personnel to prepare them to 4 respond to a radiological emergency at Diablo Canyon.

5 (b) Identify and describe all documents, 6 including critiques, photographs and motion pictures, which 7 pertain in any way to this training, including the complete 8 PG&E training program designed to ensure that PG&E personnel 9 and employees are prepared to respond adequately to a 10 radiological emergency at Diablo Canyon.

11 12 RESPONSE TO INTERROGATORY NO. 6:

13 (a) The onsite and offsite training for emergency 14 response personnel was conducted by PGandE and the 15 State of California Office of Emergency Services. This 16 . combined training program for PGandE, county, state, 17 and federal personnel was conducted on the following 18 schedule:

19 20 SCHEDULE OF CERO TRAINING 21 Date Session Participating Departments Conducted 22 1 Executive Officers and Corporate 2/20/81 23 Emergency Response Organization Recovery Managers and Primary 24 Coordinators 25 2A Security and Personnel Relations 2/23/81 26 ///

't 1 Date Session Participating Departments Conducted 2B Materials 2/25/81 2C Corporate Emergency Response Plan 3/6/81 4 Site Personnel 5 2D Division Support 3/5/81 6 2E Quality Assurance 3/2/81 7 2F Communications 3/9/81 i

8 2G General Construction, Engineering 3/11/81 and Technical Support, and 9 Computer Systems and Services 10 2H Radiological Analysis and 3/13/81 Protection 11 2I Law, Insurance, and Safety, 3/16/81 12 Health and Claims 13 2J Governmental Relations and 3/18/81 Public Relations 14 15 16 .

DIABLO CANYON TRAINING 17 Lead 18 Activity Participants Date Location Agency 19 Briefings (2) All Officials June 17-18 SLO OES 20 Preliminary County. Health, June 22 SLO OES Assessment Dept Ag, Air 21 Training Pollution Control 22 Accident County Health, July 13-16 CSTI OES Assessment Dept Ag, Air 23 Course Pollution Control, PG&E, OES, DHS Alert / Warning /Public 25 Information Evaluation July 21-23 SLO FEMA /0ES 26 ///

1 Lead Activity Participants Date Location Agency 2

PIO Orientation County & July 23 SLO PG&E 3 Utility PIO's 4 .unbulance San Francisco July 27 SF PG&E Attendant Training Ambulance, Air -

5 Ambulance 6 Additional Accident State & Week of ,

Assessment Training Local Personnel July 27 CSTI 7

PIO Planning Meeting County, State, July 28 SLO OES/ County 8 Utility, FEMA PIO's 9

Reception / Care County, State, July 29 Camp Roberts OES 10 Facility Training Red Cross 11 PIO Planning Mtg. County, State, Aug 12 SLO OES/ County Utility, FEMA 12 UDAC Planning Mtg. County, State, Aug 13 SLO OES/ County /

13 Utility PG&E 14 Press Briefing Aug 18 SLO County /0ES 15 Congregate Care Mtg. County, Red Cross Aug 18 Camp Roberts County 16 Exercise Critique County, State, Aug 21 SLO County / FEMA Utility, FEMA, 17 hTC 18 Medical Personnel St. Francis Aug 24-28 Oak Ridge Oak Ridge Training Hospital Farm Assoc. Univ.

19 20 21 (b) The following list of training documents 22 depicts the onsite and offsite PGandE, county, state, 23 and federal training program:

24 (1) Nuclear Plant Administrative Procedure No. B-2, General Requirements for Training of On-site 25 Personnel, Revision 2, dated 10/22/79.

26 ///

l l

1 (2) Diablo Canyon Power Plant Unit Nos. 1 and 2 Administrative Procedure B-50, Safety and 2 Emergency Planning Training Courses, Revision 1, dated 5/31/79.

(3) Handwritten revision (incomplete) to Diablo Canyon 4 Power Plant Units Nos. 1 and 2, Administrative Procedure B-50, " Emergency Plan Traini)1g Courses,"

5 undated, prepared by W. J. Keyworth.

6 (4) Memorandum, ' R. C. Thornberry to J. D. Shiffer, subject: Emergency Plan Training, dated July 7, 7 1981.

8 (5) Memorandum, R. C. Thornberry to J. D. Shiffer, subject: Emergency Plan Training, dated 5/6/81.

(6) EPD-600 Basic Actions in the Event of an Emergency 10 On-Site" originals of overhead slides, undated, prepared by W. J. Keyworth, date unknown.

(7) Lecture Notes, EPD-600, Basic Perronnel Actions in

'12 the E mnt of an Emergency, by J . D . Shiffer,

. Rev. O, dated 1/22/79.

13 (8) Lecture Notes, EPD-600, Rev. 1, 12/1/80, by W. J.

14 Keyworth.

15 (9) Lecture Notes, EPD-600, Rev. 2, 8/27/81, Basic Actions in the Event of an Emergency On-Site, by 16 W. J. Keyworth.

17 (10) Lecture Notes, EPD-500, Rev. ) 1/2/81, Overview of I Diablo Canyon Emergency Plan and Procedures, by 18 W. J. Keyworth.

19 (11) Lecture Notes, EPD-500, Rev. O, 1/2/81, Overview l of Diablo Canyon Emergency Plan and Procedures, t

20 annotated Rev. 1, 6/1/81, annotated as updated a 7/6/81.

21 l (12) Radiological Emergency Plan Overview Exam, dated 22 5/81 by W. J. Keyworth.

I 23 (13) Radiological Emergency Plan and R-procedures. Exam,-

i dated 6/81, by W. J. Keyworth.

I 24 (14) Lecture Notes, EPD-350, Maintenance and Repair 25 under Radiological Emergency Condition, undated by W. J. Keyworth, date unknown.

26

a 1 (15) Nuclear Data Communications System (NDCS)

Training, Class Outline, undated by Dr. T. C. Chu, l 2 date unknown.

3 (16) Diablo Canyon Power Plant Emergency Plan, Rev. 3, 6/15/81, section 8 Maintaining Emergency 4 Preparedness annotated by W. J. Keyworth, date unknown. -

~

5 (17) Emergency Procedures, Volume 3 of the Diablo 6 Canyon Power Plant Units 1 and 2 Plant Manual.

7 (18) The following draft emergency procedures:

8 R-2 (Rev. 3) Release of Airborne Radioactive Mat'1, 8/11/81 9 G-1 Accident Classification and Emergency Plan Activation, 9/1/81 G-2 Establishment of the On-site Emergency OrganOcation, 7/25/81 10 G-3 Notification of Off-site Emergency Organizations, 7/27/81 11 G-4 Personnel Assembly and Accountability, 7/27/81 12 G-5 Evacuation of Nonessential Site Personnel, 7/8/81

. OR-2 Release of Information to the Public, 7/24/81 13 EF-1 Activation of the Technical Support Center, 7/24/81 14 EF-2 Activation of the Operational Support Center, 7/24/81 15 EF-3 Activation of the Emergency Operations Facility, 7/10/81 EF-4 Activation of the Mobile Radiological Monitoring Van, 7/8/81

~

EF-5 Emergency Equipment, Instrument & Supplies, 5/26/81 17 EF-6 Activation of the Emergency Assessment and Response System, 7/24/81 18 EF-7 Activation of the Nuclear Data Communications System, 8/7/81 RB-2 Emergency Exposure Guides, 7/9/81 19 RB-3 Stable Iodine Thyroid Blocking, 6/23/81 20 RB-4 Controlled Area Establisha.ent, 7/21/81 21 RB-5 Personnel Decontamination, 7/21/81 RB-6 Area & Equipment Decontamination, 8/11/81 22 RB-7 Emergency On-Site Radiological Environmental Monitoring, 7/24/81 23 RB-8 Emergency Off-Site Radiological Environmental Monitoring, 7/24/81 24 RB-9 Determination of Release Rates, 8/11/81 RB-10 Protective Action Guidelines, 6/23/81 25 RB-11 Emergency Off-Site Dose Calculations, 7/24/81 ,

26 (19) Corporate Emergency Response Plan Lesson Plans A,

1 INTERROGATORY NO. 7:

2 Describe all equipment available to San Luis 3 Obispo County personnel (including personnel of any c nac 4 Cities responding pursuant to the County Plan) to r,espond to ,

5 a Diablo Canyon radiological emergency.

6 7 RESPONSE TO INTERROGATORY NO. 7:

8 Applicant objects to this question on the ba' sis it 9 is (a, impossible to answer, (b) overly broad and vague, (:)

10 not within the knowledge of the answering party, and (d) not 11 designed to lead to admissible evidence. The interrogatory 12 asks for a listing of all equipment available to the County 13 to respond to a radiological emergency. Such a question 14 could generate answers from the number of pencils and 15 erasers available to the number of Hewlett Packard 1010's 16 for measuring radiological conditions. Clearly the number 17 and kind of radiological monitoring equipment is material to 18 the issue at bar. The number of pencils is not. Unfortn-19 nately the interrogatory makes no such distinction.

20 21 22 23 INTERROGATORY NO. 8:

24 (a) Describe all plans for notification of 25 transient persor.s within 10 miles of the Diablo Canyon 26 facility in the event of a radiological energency.

I

1 Transient persons include agricultural workers, visitors to 2 Montana de Oro State Park, and other persons who may be 3 temporarily visiting the San Luis Obispo area.

4 (b) Describe all documents which relate in any 5 way to such notification, including, without limitation, any 6 analyses of the time (s) necessary for and feasibility of 7 notifying persons in the backcountry of Montana de Oro State 8 Park.

9 10 RESPONSE TO INTERROGATORY NO. 8:

11 (a) The detailed procedures for notification of 12 transient populations can be found in the San Luis 13 Obispo County Nuclear Power Plant Emergency Response 14 Plan and Standard Operating Procedures.

15 There are two groups of transient populations 16 which would be notified directly by PGandE at the

• 17 request of the County Sheriff's Office as described 18 below:

19 (1) Migrant farm workers along the DCPP 20 South access road. In addition to installing two 21 non-electronically activated warning devices ~ on 22 existing structures, PGandE will dispatch from 23 the plant a vehicle equipped with a megaphone or 24 other loudspeaker devices which would proceed 25 along the South access road to the pea farm 26 located approximately 4.2 miles from the plant.

1 This vehicle would be used to notify all persons j

2 working in the area. See Diablo Canyon Power 3 Plant Emergency Procedures, EP G-5, Rev. O.,

4 entitled " Evacuation of Non-essential Site 5 Personnel."

6 (2) Hikers in remote areas of Montana de Oro 7 State Park. The San Luis Obispo County Nuclear 8 Power Plant Emergency Response Plan Standard 9 Operating Procedure III.12 entitled " State 10 Department of Parks and Recreation" outlines a 11 procedure for notification and evacuation of 12 persons in the Park.- PGandE currently has an 13 agreement with Rogers Helicopter Service to 14 provide a helicopter in the event of an emergency 15 situation. This helicopter could be used to 16 -

notify persons in the park if the County requested 17 such assistance. Helicopters are available which 18 could be used as a back-up or primary vehicle for 19 notification of transient populations.

20 21 (b) (1) DCPP Emergency Procedures - EP G-5 22 (2) DCPP Emergency Plan - Letters of Agreement 23 (3) SLO Emergency P3an and Standard Operating 24 Procedure 25 (4) Evacuation Times Assessment for DCNPP, 26 Voorhees 1980

1 (5) NUREG-0654, Appendix 3 2 (6) TERA report " Earthquake Emergency 3 Planning at Diablo Canyon" 4

5 6

7 8

9 INTERROGATORY NO. 9:

10 (a) Describe the seismic qualification, including 11 a description of the earthquake forces (acceleration, 12 velocity and displacement) that the equipment is designed to 13 withstand and still be completely functional, of: (1) the 14 real-time monitors, both onsite and offsite (PG&E Plan, Fig.

15 7.3-4); (2) the equipment at each of the offsite 16 environmental monitoring stations (Figure 7.3-3); (3) Se -

17 sirens utilized in the early warning system (Figure 7.2-8);

18 and (4) the onsite meteorological tower.

19 (b) Identify and describe the manufacturer and 20 the model numbers of all such equipment.

21 (c) Describe the structures to which all- stich 22 equipment is attached and the seismic qualification of such 23 structures.

24 (d) Identify and describe any tests or analyses.

25 which have been performed either by PG&E or others on the 26 qualification, characteristics, and response features of the

1 foregoing equipment and structures proposed for use at 5 2 Diablo Canyon, onsite and offsite.

3 4 RESPONSE TO INTERROGATORY NO. 9:

5 (a) The real-time monitors, offsite environmental 6 monitoring systems, sirens and the onsite 7 meteorological tower have not been seismically 8 qualified.

9 10 (b) The real-time monitors and the environmental 11, monitoring station-equipment are described in section 12 7.3 of the Diablo Canyon Site Escrgency Plan.

13 The manufacturer of sirens is Federal Signal 14 Corporation Signal Division. Model Numbers of the 15 sirens are:

16 .(1) Models 1000A & 1000B with RCMIA & RCMIB control 17 cabinets and ARCH-S1 receivers and timers. Model 18 '

.000 sirens are rated 125 dB.

19 (2) Models STH10A & STH10B with RC5WA &RC5WB control 20 cabinets and ARCH-S1 receivers and timers. 'odel 21 STH10 sirens are rated 115 dB.

22 (3) Models 5A & SB with RC5WA & RC5WB control cabinets 23 and ARCH-S1 receivers and timers. Model 5 sirens 24 are rated 107 dB.

25 (4) Model 2 with RC5W control cabinet and ARCH-S1 re-2C ceiver and timer. Model 2 sirens are rated 102 dB.

1 (5) Model LCS-1 lo.*al coverage siren. Model LCS-1 2 sirens are rated 85 dB.

3 4 Meteorological instrumentation is comprised 5 of:

6 (1) wind measurenant by a Teledyne-Geotech Series 50 7 system using three-cup anemometers and " quick one" 8 vanes.

9 (2) temperature and temperature gradient measurements 10 by a Teledyne Geotech Model 40.35 microprocessor 11 system in conjunction with platinum resistance 12 thermometers in Teledyne Geotech Model 327 aspi-13 rated radiation shields.

14 (3) precipitation measurement by a Belfort Model 15 tipping bucket raingage with rainfall increments 16 digitally accumulated by a Teledyne Geotech Model 17 40.52 processor.

18 (4) . dew point measurement by an EG&E Model 110-M 19 chilled minor dew point system with signal pro-20 cessing by a Teledyne Geotech Model 40.71 signal 21 processing module.

22 (5) data acquisition of primary and backup tower data 23 by Teledyne Gectech "Outomet V" digital data 24 acquisition systems.

25 (6) mechanical backup for automated tower data by use 26 of a Meteorology Research Incorporati!,n Model 1071 portable mechanical weather station.

l

1 (d All real-time monitors and on-and offsite 2 monitoring stations are free standing structures 3 located outside of any structure (except for the 4 station at Morro Bay Power Plant). ,

5 The primary meteorological instrumentation is 6 deployed on a 2 foot square 67 meter tall guyed tower 7 of angle iron construction via retractible steel tube 8 booms. Backup meteorological instrumentation is 9 deployed on a 50 meter tall guyed tubular steel tower 10 of triangular cross section; 18 inches on a side, via 11 lowerable aluminum booms. The site of the backup tower 12- is separated by 1.2 kilometers from the site of the 13 primary tower. Acquisition and recording equipment are 14 sheltered in small concrete block structures with 15 corrugated steel roofs.

16 .

17 (d) The onsite meteorological tower is a light-18 weight structure which is not highly susceptible to 19 earthquake forces. Instead, it is designed for wind.

20 It has been determined capable of withstanding a 110 21 mph wind within normal allowable working stresses.

22 This is equivalent to a seismic loading of 1.2g.

23 The Federal Signal Company, the siren manu-24 facturer, has recently completed some seismic work on 25 the largest siren, model 1000. This material is being 26 forwarded to PGandE and will, when available, be used l -

to supplement these answers.

1 INTERROGATORY NO. 10:

2 What is the status of implementation, testing and 3 activation of the public notification system sirens (see 4 PGG':., Plan, Rev. 2, Figure 7.2-8)? In your response, do the 5 .tollowing:

6 (a) Describe how each siren is mounted; 7 (b) Identify the final seleted [ sic] location of 8 each siren; 9 (c) The criteria for choosing each siren 10 location; 11 (d) The population covered by each siren; 12 (e) The estimated population (both permanent and 13 transient) within the early warning boundary system (see 14 Figure 7.2-8) which is not covered by the siren system; 15 (f) The means, if any, by which the population 16 not covered by the siren system will be notified of a Diablo 17 Canyon emergency; 18 .(g) Describe all tests of the siren system, 19 including g1) tests designed to test the coverage of 20 individual sirens and (2) tests designed to determine the 21 seismic qualification of the siren system; and 22 (h) Identify and describe all documents which 23 relate in any way to (a) - (g) above.

24 ///

25 ///

26 ///

1 RESPONSE TO INTERROGATORY NO. 10:

2 General Status 3 Seventy-three of the eighty-tnree sirens that 4 currently comprise the system have been installed in the SLO 5 County Basic Emergency Planning Zone. Five of t'.he remaining 6 sites have been cleared for construction, and four are 7 awaiting additional approvals. Presently, the siren radio 8 receivers are being retrofitted for a new frequency and also 9 for subaudible tone activation in order to increase the 10 security of the system. All of the parts and equipment 11 necessary to retrofit the receivers are in order. It is 12 anticipated that the existing system will be operational in 13 November of 1981.

14 The activiating enccder is installed in the County 15 Sheriff's dispatch room and is operational.

16 Specific Parts 17 (a) Siren Mounting 18 (1) Models 1000A & B 19 Compressor platform is bolted to pole with 20 2-3/4" through-bolts. Platform stabilizers are logged -

21 to pole and bolted to the platform.

22 Control and receiver caninets are bolted to 23 the platform and supported with cross-arm braces. The 24 schedule to rigid steel air pipe from the compressor to 25 the chopper assembly is attached to the pole with 26 galvanized - steel brackets at 5 ft. intervals. The

l 1 siren unit which includes the chopper assembly is 2 attached to the steel pipe at the top of the pole.

3 (2) Models STH10A & B, 5A & B, 2 4 These sirens are bolted to a tri-mount 5 bracket which in turn is bolted to the top'of the pole.

6 The control cabinets, ARCH-S1 receivers and 7 disconnect switch are bolted to a 6 ft. length of 6" 8 channel which is "through-bolted" to the pole with 3/4" 9 bolts.

10 (3) Model LCS-1 11 This self-contained siren is "through-bolted" 12 to the pole with 1/2" bolts.

13 14 (b) Location of each siren as shown on the map in 15 the Emergency Plan.

16 SIREN NO. LOCATION 17 1 North Morro Bay - near the intersection of Sequoia and Birch.

18 1A Cayucos on Standard Oil property near 19 Highway 1.

20 IB Near the Cayucos Cemetary on Highway 1.

21 1C Cayucos near the intersection of 4t'h &

Park.

22 (2) On PG&E property at the Morro Bay Power 23 Plant.

24 (3) In Morro Bay, on Morro Avenue north of Olive.

25 3A In Morro Bay, near the intersection of 26 Ridgeway street and Fairview Avenue.

1 SIREN NO. LOCATION 2 6A In Baywood Park near the intersection of El Morro Avenue and 6th Street.

3 7 In Los Osos on Pecho Valley Road several 4 blocks west of Pine Avenue.

5 8A Montana de Oro Park near the Ranger Station.

6 8B Montana de Oro Park near the Ranger's 7 residence.

8 8C On the Field's property south of the gate.

8D On the Field's property near the Field's 10 , residence.

11 9 Near Highway 1 on PG&E's Baywood substation yard.

. 10 Near Highway 1 west of San Luisito Creek 13 Road.

14 12 On Highway 1 just north of Cuesta College.

13 On Highway 1 northwest of animal 16 . shelter.

17 14 On Highway 1 about 1/2 mile west of the California Division of Forestry.

15 In San Luis Obispo across the street 19 from City Fire Station on No. Chorro Street.

20 16 In San Luis Obispo near Grand Avenue and 21 Slack Street.

22 17 In San Luis Obispo in parking lot next to the fire station on Graden Street.

2,3 18 On Clark Valley Road - near the PG&E 500 24 kV right of way.

25 19 Los Osos - near the end of Valley View

- Place.

26

l l

1 SIREN NO. LOCATION l 2 19C Los Oson - near the end of Valley View Place.

3 19D In Los Osos - on N1pomo Avenue East of 4 South Bay Boulevard. .

5 19E In Los Osos

• near the fire station on Cs11e Cardonay.

6 20 On Los Osos Valley Road near the 500 kV 7 right of way.

8 21 On Los Osos Valley Road east of Turri Road.

9 22 On Los Osos Valley Road about 1.5 miles 10 east of No. 21.

11 23 Near the intersection of O'Connor Way and Foothill Road.

12 23A On O'Connor Way about 2 miles west of 13 23.

14 24 On Perf'tmo Canyon' Road.

15 24A About 2000 ft. south of Perfumo Canyon Road.

16 .

24B Near the end of Sycanore Canyon Road.

17 25 At the top of Perfumo Canyon Road.

25A On Coon Creek Road about 1 s/4 miles 19 west of See Canyon Road.

20 26A On Coon Creek Road about 1/2 miles west of See Canyon Road.

I 21 l

27A On See Canyon Road about 1 mile east of 22 27B.

t l

23 27B On See Canyon Road about 3500' west of 26A.

24 l 27C On See Canyon Road about 2500 east of l 25 Davis Canyon Road.

26 27 On See Canyon Road about 2500 east of l Davis Canyon Road.

l A y e -w - ~ ..-,---4 --- p - - e e,e-,-ww -+w-->

l 1 SIREN NO. LOCATION 2 29 On Los Osos Valley Road about 2000' south of Madonna Road.

3 29A '

Off Los Osos Valley Road in Laguna Lake 4 area.

5 30 In San Luis Obispo on Meisner Road.

6 31 In PG&E's Service Center yard on So.

Higuera.

31A Near the end of Davenport Road.

31B On Highway 101 Frontage Road south of 9 So. Higuera off ramp.

10 31C On Highway 101 Frontage Road about 2000 ft. north of 500 kV right of way.

32 On Squire Canyon Road e'ast of Highway 12 101.

13 33 Across street from Belleview - Santa Fe School on See Canyon Road.

34 In Avila Beach near DCPP security. gate.

35 In downtown Avila Beach near San Antonio 16 .

Street. -

17 36 On Highway 101 near Palisades Drive.

18 37A At Shell Beach fire station.

19 38 On Mattie Road near McLintock's i restaurant.

! 20 38A On Shell Beach Road north of Ocean Way.

21 39 In San Luis Obispo on Santa Fe Road 22 south of Tank Farm Road.

23 40 On private property south of San Luis Airport.

41 North of the Town of Edna.

25 42 On Price ~ Canyon Road on Grace Oil 26 property.

1 SIREN NO. LOCATION ,

2 43 On Price Canyon Road about 1 mile north of Pismo Beach.

3 44 In Pismo Beach on a watertank in sub-4 division above Pismo Beach.

5 45 In Pismo Beach on Bello Road near Veteran's Hall.

6 46 On Highway 1 South Pismo Beach.

7 47 In Grover City - 4th and Manhattan.

8 48 In Oceano on Railroad Avenue. ~

9 49 In Grover City at Water Tower.

50 On Halcyon Road near Oceano city limits.

11 51 In Arroyo Grande near new fire station.

12

- 51A At PGandE substation on Valley Road 13 south of Arroyo Grande.

14 52 On Arroyo Grande Road east of Arroyo Grande.

15 52A On Printz Road north of Arroyo Grande.

16 -

52B On Noyes Road north of Printz Road.

17 49B On Central Boulevard north of Arroyo 18 Grande.

19 49C On Central Boulevard about 4000 ft.

north of 49B.

I 20 53 On Valley Road about 7C00 ft. south of i 21 51A.

22 56 Near intersection of El Campo &

i Clarkway.

23 57 On Valley Road about 7000 ft. South of 24 53.

25 58 On Stanton Road South of Los Berros Road.

26 ///

1 SIREN NO. LOCATION 2 59 Near intersection of Los Berros and Keokee.

3 60 On Pomeroy Road.

61 On Willow Road at Black Lake County 5 clad, 6

7 (c) Criteria 8 The two major criteria used in determining 9 siren coverage were:

10 (1) The NRC requirements for notification of the 11 population as outlined in Appendix 3 of NUREG-0654 12 and, 13 (2) The recommended 10 dB sound level above average 14 daytime ambient backgrcund noise as a target level 15 for the design of an adequate system (NUREG-0654, 16 -

FEMA " Outdoor Warning Systems Guide").

17 In addition to sound propagation and notifi-18 cation of the population, several other criteria were 19 thoroughly investigated before final siren site 20 locations were selected.

21 (3) Environmental Impact. PGandE's " Environmental 22 Impact Analysis of Construction and Testing of the 23 Early Warning System" evaluates the potential 24 impact of the EWS on all known important wildlife 25 and rare plant species. Several sites were

~

26 ///

1 relocated in order to avoid sensitive nosting 2 areas and kangaroo rat habitats.

3 (4) Cultural Resources. A study entitled "DCPP Early 4 Warning System Cultural Resources Literature 5 Search and Report on the Field Invest 5igations of i

6 Selected Pole Sitings" was performed by a 7 consultant firm to avoid siting poles in 8 archeologically active sites.

9 (5) Coastal Zone. In order to avoid potentially 10 negative impacts on the aesthetic coastal 11 environment, considerable effort was made to site 12 sirens in this area on existing poles.

~

13 14 (d) The population covered by each siren:

15 The siren system was designed so that the 16 total population within the Basic Emergency Planning

• 17 Zone would be alerted in the event of an emergency 18 situation at DCPP. The system was not designed from 19 the standpoint of each siren covering a specific sector 20 of the population.

21 22 (e) The resident population within the 10-mile 23 radius of the plant and the Basic Emergency Planning 24 Zone presently not covered by the siren system is less 4

25 than a fraction of 1 percent. The transient population 26 within the siren system boundary would consist of we y+ e , , - - - - r w-. y y--y go. ,i-u= -

I 1

visitors in Montana de Oro State Park and farm workers 2 along the DCPP southerly access road. The camIground, 5 3 all beach areas and all parking areas at Montana de Oro 4

State Park are within the siren system cov,erage area.

5 6 Refer to interrogatory 8 response.

(f) 7 8 (g) Testing of the Siren System.

9 Each siren is tested upon installation to en-10 sure that all component parts are operational. A full 11 siren test will not occur until November 1981. A test-12 ing program is being prepared which will qualitatively 13 and quantitatively assess the capability of the siren 14 system to meet design criteria during the full siren 15 test.

16 Maintenance system testing will be performed 17 according to the manufacturer's requirements.

18 Individual siren coverage tests will not be 19 performed.

20 No seismic testing is anticipated beyond what 21 has been discussed in interrogatory 9.

22 23 (h) 1. NUREG-0654, FEMA-REP-1, Rev. 1.

24 2. FEMA Document GPG-1-17, FEMA Outdoor Warning Systems Guide.

3. "Public Notification System Service Manual,"

26 'ngineering Systems, Federal Signal Corporation.

1 4. " Radio-Controlled Siren Alerting System for the Diablo Canyon Nuclear Plant," prepared by 2 Engineering Systems, Federal Signal Corporation.

3 5. " Evacuation Times Assessment for the Diablo Canyon Nuclear Power Plant, September 1980, PRC Voorhees 4 and Associates.

5 6. "Diablo Canyon Power Plant Early War ing System Cultural Resources Literature Search and Report on 6 Field Investigations of Selected Pole Sitings,"

Vance Bente, Mary Hilderman-Smith, Legion 7 Archaeological Research.

8 7. " Environmental Impact Analysis of Construction and Testing of the Diablo Canyon Early Warning 9 System," Report 411-80.396, PG&E Department of Engineering Research, January 1981.

8. " Rare Plant Survey and Wildlife Siting Information 11 for 18 Relocated Pole Sites," July 17, 1981, letter from John Icanberry to C. J. Smith.

12

. 9. Isopleth map delineating current siren coverage. -

13

10. Engineering Drawings.

14 I 15 16 -

17 18 INTERROGATORY NO. 11:

19 Attached to Revision 2 of the Diablo Canyon 20 Emergency Response Plan are a number of agreements. For 21 example, there are agreements with French Hospital and with 22 San Luis Obispo Ambulance Service.

23 (a) Identify and describe: (1) all updated 24 versions of these agreements; and (2) any other agreements 25 which PG&E believes support in any way the preparedness of 26 ///

,,y , , -, , - - -

, . .n, , - - , -v v - - - - --- - ,-, 7 ,ma,w ..--se - --n ,---r --- -m- --=

1 PG&E and/or offsite entities to respond to a radiological 2 emergency at Diablo Canyon.

3 Describe any plans of PG&E to enter into any (b) 4 further agreements related to emergency planning and

~

5 preparedness that are in addition to those included in 6 Revision 2 of PG&E's Emergency Response Plan.

7 8 RESPONSE TO INTERROGATORY NO. 11:

9 Letters of Agreement have been obtained from 23 10 public and private entities. Requests have been made to 11 several additional agencies for letters of agreement which 12 are still pending.

13 COMPLETED LETTERS OF AGREEMENT 14 1. State of Californi ', Office of Emergency Services Effective May 27, 1981

2. French Hospital, San Luis Obispo, California 16 . Effective June 8, 1981 17 3. Condor Helicopters and Aviation, Inc.

Ventura, California 18 Effective July 31, 1981 19 4. Rogers Helicopters, Clovis, California Effective July 1, 1981 1 5. Rotor-Aids, Inc., Ventura, California 21 Effective July 9, 1981 22 6. San Luis Ambulance Service, Inc.

San Luis Obispo, California 23 Effective May 13, 1981 l

l 24 7. State of California, Department of CALTRANS l Effective May 11, 1981 l- 25 L

8. State of California, Department of Rehabilitation 26 Effective July 27, 1981

1 9. State of California, Department of Military Effective April 14, 1981

10. State of California, Department of Youth Authority 3 Effective April 30, 1981 4 11. State of California, Department of General Services Effective April 22, 1981

12. State of California, Department of Forestry 6 Effective April 20, 1981 7 13. State of California, Department of Corrections Effective April 27, 1981

14. American Red Cross 9 Effective April 17, 1981 10 15. State of California, Department of Health Services Effective July 14, 1981

16. Air Ambulance Inc., San Carlos, California 12 Effective July 8, 1981 13 17. State of California, Department of the California Highway Patrol 14 Effective April 13, 1981 15 18. Camp San Luis Obispo, San Luis Obispo, California Effective July 2, 1981 16 -

19. Cuesta College, San Luis Obispo, California 17 Effective May 26, 1981 18 20. State of California, Department of Fish and Game Effective June 12, 1981 19

21. San Luis Obispo Ranger Unit / County Fire Department 20 Effective August 5, 1981 21 22. Southern California Edison Company,

Sacramente Municipal Utility District, 22 Pacific Gas and Electric Company, 4 " Radiological Emergency Mutual Assistance Agreement" 23 Effective June 1, 1981 24 23. San Francisco Ambulance Service San Francisco, California 25 Effective June 25, 1981 26 ///

-cv , - -- --,un,- .

e -

-~y, - - ,. - - .- . - - .

i i

1 24. Radiological Emergency Mutual Assistance Agreement I between Southern California Edison, Pacific Gas and 2 Electric Company and Sacramento Municipal Utility District, dated June 1, 1981.

3 J

25. Institute of Nuclear Power Operations, Letter, 8/27/80 4

26. Institute of Nuclear Power Operations, Voluntary 5 Assistance Agreement, 1/15/81 6

7 8 OTHER PENDING LETTERS OF AGREEMENT 9 1. U.S. Coast Guard 10 2. U.S. Air Force, Vandenberg AFB 11 3. U.S. Army National Guard, Camp Roberts 12 4. California Department of Parks and Recreation 13 5. California Department of Food and Agriculture 14 6. San Luis Obispo County Sheriff's Department 15 7. A backup ambulance service 16 8. An alternate media center 17 9. St. Francis Memorial Hospital 18 10. Western Regional Nuclear Plant Energy Preparedness Assn.

19 20 ///

21 ///

22 ///

23 24 25

~

26

-54 .

1 INTERROGATORY NO. 12:

2 (a) Is it PG&E's position that prior to full 3 power operation, the oneite and offsite emergency 4 preparedness at Diablo Canyon will comply fully with each 5 and every one of the Planning Standards in Section 50.47(b)'>

l 6 (b) If the answer is YES, describe in detail the 7 basis for and specifically demonstrate the means by which 8 each Planning Standard will be satisfied.

9 (c) If the answer is NO, describe each deficiency 10 . that PG&E anticipates and state whether PG&E, in that event, 11 will rely on Section 50.47(c)(1) to support licensing of 12 Diablo Canyon despite such deficiency.

13 (d) For each such deficiency, provide the 14 technical basis for use of Section 50.47(c)(1).

15 16 RESPONSE TO INTERROGATORY NO. 12:

• 17 (a) Yes.

18 (b) See Emergency Plans for applicant, county and 19 state, and all implementing procedures.

20 (c) N/A.

21 (d) N/A.

22 ///

23 ///

24 ///

25 26

4 1 INTERROGATORY NO. 13:

2 Describe each and every standard operating 3 procedure for the San Luis Obispo County Emergency Plan 4 (i.e., the draft version dated May 1981) which is in PG&E's 5 possession, custody, or control, including the possession, 6 custody, or control of PG&E's agents, consultants, or 7 OU12cractors.

8 9 RESPONSE TO INTERROGATORY NO. 13:

10 These procedures will be described in pending 11 respcnc ?s: to requests for production.

12 13 14 15 16 INTERROGATORY NG. 14:

17 (a) Describe each and every system or means that 18 PG&E plans to have available for communicating from the 19 Diablo Canyon site to offsite governmental authorities.

20 Include in your answer a description of:- (1) the seismic 21 qualification of each such communication system and related 22 equipment and structures; and (2) all analyses, tests, and 23 other documents which relate in any way to these systems and 24 structures.

25 (b) Which of these systems does PG&E inf.end to 26 use for communicating with each of the following

1 governmental authorities: San Luis Obispo County, the City 2 of San Luis Obispo, the State of California (specifically, 3 the Governor's Office, the Office of Emergency Services, and 4 the IIighway Patrol), the Nuclear Regulatory Commission 5 (specifically, th.: regional office and headquarters), FEMA 6 (specifically, the regional office and headquarters), and 7 the Cities of Atascadero, Arroyo Grande, Grover City, Morro 8 Bay, Paso Robles, and Pismo Beach.

9 (c) With respect to each of such cities, whom 10 does PG&E intend to contact in the event of a radiological 11 emergency at Diablo Canyon?

12 13 RESPONSE TO INTERROGATORY NO. 14:

14 (a) The following means are available for com-15 municating from Diablo Canyon to offsite governmental 16 authorities:

17 1. The NRC's eme2.gency notification phone system to 18 .the NRC Operations Center.

19 2. The NRC's health physics phone network to NRC 20 Region V, Region V power plants, and NRC 21 Operations Center.

22 3. PGandE's Diablo Canyon phone exchange with access 23 to Pacific Telephone Company's network.

24 4. Diablo Canyon phone exchange interconnection via 25 microwave systems to PGandE's corporate 26 headquarters in San Francisco. This

1 interconnection allows access to the Pacific 2 Telephone Company's network from San Francisco.

3 5. Unlisted Pacific Telephone Company private phones 4 at Diablo Canyon.

5 6. Dedicated automatic tie line phone to the San Luis 6 Obispo Sheriff's Office.

7 7. Dedicated automatic tie line phone to the 8 California Office of Emergency Services (CES) in 9 Sacramento, California.

10 8. A radio sysoem between Diablo Canyon and the San 11 Luis Obispo Sheriff's Office.

12 Major communications equipment has been 13 strengthened and braced for seismic considerations.

14 Seismic capability of the communications system is  ;

15 discussed in the aforementioned TERA Report, Chapter 5.

16 17 (b) PGandE intends to use the following systems 18 for communications with:

19 1. San Luis Obispo County: radio system, dedicated 20 automatic tie line, and the Pacific Telephone 21 network.

22 2. City of San Luis Obispo: Pacific Telephone 23 network.

24 3. State of California, et al.: dedicated automatic 25 Lie line to OES and the Pacific Telephone n twork.

26 ///

1 4. Nuclear Regulatory Commission: NRC emergency 2 notification phone system, NRC health physics 3 phone network, and the Pacific Telephone network.

4 -. FEMA: Pacific Telephone network.

5 6. Cities of Atascadero, Arroyo Grande, rover City, 6 Morro Bay, Paso Robles, and Pismo Beach: ' Pacific 7 Telephone network.

8 9 (c) PGandE is required to notify the San Luis 10 Obispo County Sheriff dispatcher in the event of a 11 radiological emergency at Diablo Canyon. Notification 12 of cities is the responsibility of the San Luis Obispo 13 County Emergency Organization.

14 15 16 -

17 18 INTERROGATORY NO. 15:

19 (a) List each and every person PG&E may call or 20 subpoena as a witness to any hearing which may be held on 21 the emergency preparedness contention admitted by thi:

22 Liceming Board in its Order of August 4, 1981:

23 (b) As to each witness, please state:

I 24 (1) The name, occupation, address and tele-25 phone number of each such person and l 26 whether that person may appear for PG&E ,

l l

l l

1 as a voluntary witness or a subpoenaed 2 witness.

3 (2) The field or science in which such 4 person is sufficiently schooled and/or 5 experienced to enable him 'or her to 6 express opinion evidence.

7 (3) The qualifications of each such witness.

8 (4) Whether such witness will base his or 9 her opinion in whole or in part upon 10 facts acquired personally by that person 11 in the course of an investigation or 12 examination as to the facts, or solely 13 upon information provided that person by 14 others. If on the basis of investiga-15 tion or examination, please describe 16 such and state the nature and dates of 17 such. If on the basis of information 18 provided by others, please identify such 19 others and state their qualifications.

20 (5) Each and every fact and each and every 21 document, photograph or report or item, 22 or other tangible object supplied or 23 made available to each such person.

24 (6) Whether each such witness rendered 25 written reports regarding facts, bases, 26 or opinions as respects your answers to

1 these interrogatories. If so, state the 2 date of each such report and the name 3 and address of the cust 3dian of each 4 such report.

5 (7) A summary of each such witness' proposed 6 testimony.

7 (8) Identify any other NRC proceedings in 8 which such witness has previously 9

• testified and provide copies of such 10 testimony.

11 12 RESPONSE TO INTERROGATORY NO. 15:

13 (a) and 14 (b) (1) (3) (8) 15 The following list identifies . individuals that 16 PGandE may call as a witness to any hearing which may be -

17 held on the emergency preparedness contention admitted by 18 the Licensing Board in its order of August 4, 1981.

19 Individuals listed under numbers 2, 3, and 4 may well have 20 to be subpoenaed as well as Messrs. Waddell, Whiting, and l 21 Hubbard.

22 ///

23 ///

24 ///

25 26 l l __ . -_ - _ - . . - _ . . _ _ _ _ ___ _

)

i 1 1 1 R. C. Thornberry S. G. Brown R. Patterson G. N. Horne 2 W. B. Kaefer D. P. Serpa W. J. Keyworth R. W. Lorenz 3 J. M. Gisclon K. M. Godfrey J. V. Boots T. A. Mack 4 B. A. Dettman J. L. Potter A. J. Nevolo W. H. Fujimoto -

5 J. V. Rocca M. Mooney R. S. Bain R. Thuillier 6 G. A. Blanc T. Martin J. D. Shiffer F. Rockmaker 7 J. D. Townsend J. R. Torrena S. M. Skidmore *R. V. Bettinger 8 R. J. McDevitt R. N. Swanson J. B. Hoch 9 D. J. Baxter C. O. Coffer 10 11 2 4 S. MacElvaine J. Kearns J. Eldridge D. Stillwell A. Flcok K F. Nauman 12 T. Ness O. Orr V. Paule

. T. Mazzacano 13 R. Jensen 14 15 S S K. W. Campbell C. M. Payne 16 R .. L . Cudlin J. Penzien Smith B. J. Davis S. 'V .

17 D. K. Davis R. H. Winslow C. P. Mortgat 19 R. T Wester R. Rogers EDS Nuclear Inc. Rogers Helicopters 20 220 Montgemery Street P.O. Box 4 San Francisco, CA 94104 Clovis, CA 9361a 21 (415) 544-8000 (209) 299-4903 22 T. Waddell W. K. Brunot P.O. Box 151 595 John Muir Drive #508 23 San Luis Obispo, CA 93406 San Francisco, CA 94132 (415) 543-4244 (415) 334-0586 24 25 lll 26 lll 62-

-wa- - -- w w w g ..m y,es -m wy - 9-9 --+-----e-wr e+S+- ve7*-- e et e -+r -

• 1 R. Hubbard Sheriff G. Whiting MHB Technical Associates 2 Sheriff's Operations Facility 1723 Hamilton Avenue - Suite K San Luis Obispo, CA 93408 San Jose, CA 95125 3

(805) 543-2850 (408) 266-2716 4 I Pacific Gas and Electric Company 2 County Administration Office 77 Beale Street Courthouse Annex Room A205 5 San Francisco, CA 94106 San Luis Obispo, CA 93408 (415) 781-4211 (805) 549-5011 3 4 Office of the Governor Federal Emergency Management Agency 7 Office of Emergency Services 211 Main Street Nuclear Power Plant San Francisco, CA 94105 8 Planning Section (415) 556-9412 P.O. Box 9577 9 Sacramento, CA 95823 (916) 427-4341 5

,,I* TERA Corporation A

2150 Shattuck Avenue Berkeley, CA 94704 12 (415) 845-5200

^

13 14 (b)(2) Resumss have previously been submitted on all 15 witnesses listed in response to Joint Intervenors' 16 interrogatories of August 4, 1981.

• 17 18 (b)(4) Applicant cannot answer this interrogatory as 19 respects witnesses it may have to subpoena. As to 20 witnesses it will call, testimony has not yet been 21 written and therefore no " opinions" from which to 22 answer this question are available. However, for 23 the most part, it is anticipated that opinion 24 testimony will be based largely upon facts 25 acquired personally by the witness in conjunction 26 with information supplied by others.

1 (b) Identify all analyses, reportr., or other doc-2 uments which relate in any way to the complicating effects 3 of an earthquake, including complications to the northern 4 i and southern evacuation routes from the Diablo Canyon site.

5 6 llESPONSE TO INTERROGATORY NO. 16:

7 (a) Emergency planning for the Diablo Canyon site 8 has included consideration of the complicating effects 9 of earthquakes. Analyses of possible. specific effects 10 related to the three referenced earthquakes are not 11 particularly useful to planning as the exact

~ 12 consequences are not amenable to a purely deterministic 13 prediction. The objective of emergency planning for 14 Diablo Canyon was to establish a flexible response 15 capability able to respond to a spectrum of events and 16 . specific effects that could materialize.

17 The Diablo Canyon studies focused on two 18 areas where the most significant earthquake 19 interactions would be manifested: transportation and 20 communications. The study also establishes a 21 conceptual framework for an " earthquake response plan" 22 which addresses both the response to the complicating 23 effects of damage as well as advanced planning concepts i

l 24 to deal with the duality of radiological and earthquake 25 emergency. ">a specific evaluations assumed a 7.5 26 magnitude surface wave located on the Hosgri fault.

s

I l

i 1 Th3 consideration of a single, specified 2 large earthquake is appropriate for two reasons: (1) 3 the specific earthquake that was considered is the most 4 2ogical one to be involved in a combined radiologi-5 cal / earthquake emergency and (2) the planning concepts 6 determined to be appropriate are not particularly 7 sensitive to the choice of earthquake size or location.

8 The postulated magnitude 7.5 earthquake on 9 the Hosgri fault was chosen because of its use as the 10 seismic design basis for the Diablo Canyon Power Plant 11 and its dominant seismic hazard to the plant.

12 Furthermore, the use of this large earthquake was 13 responsive to the requests of FEMA and the NP.C.

14 A large variability of off-site damage would 15 be expected to result from the Hosgri earthquake. This 16 diversity in damage comprehensively challenges

• 17 emergency plans and requires them to be extremely 18 flexible. The variety of damage scenarios considered 19 largely envelops the expected effects of both smaller 20 and larger earthquakes that might occur within San Luis 21 Obispo County, the main difference being the relative 22 likelihood of specific scenarios. The specific 23 earthquake effects for three defined earthquake damage 24 levels are provided in the report referenced in part 25 (b) of this response.

26 ///

1 The emergency responses to these earthquake l 2 effects will be highly dependent on the actual 3 situation that develops. This has been considered in 4 the development of an Earthquake Response Plan for 5 Diablo Canyon that provides for feedback df off-site 6 conditions to the responsible emergency organica!-ions 7 so that recommendations for protective actions related I 8 to radiological hazards can be appropriately adjusted.

9 Postulates of lesser or greater off-site effects will 10 not affect the type of response, but only the degree to 11 which additional outside resources would need to be 12 called on to supplement the local response.

13 14 (b) Earthquake Emergency Planning At Diablo 15 Canyon, TERA Corporation, September 2, 1981.

16 ,

17 18 19 i

l 20 INTERROGATORY NO. 17:

21 Describe all reports, assessments, studies, l

22 analyses, or other documents (written, filmed, or recorded) 23 being prepared by or for PG&E that deal with any of the

i. 24 following:

25 (a) The effects of an earthquake on emergency 26 response to a radiological emergency; I _. . , . . - _ . . . . . . . , _ . _ . . .

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

I l

l 1

(b) Evacuation tirae estimates for the evacuation 2 of the Diablo Canyon facility and the 3 emergency p.ianning zones surrounding the 4 facility; 1 (c) The Diablo Canyon public information program; 6 and

-7 (d) The consequences of a radiological emergency 8 at Diablo Canyon on the capability of offsite 9 entities to provide assistance to PG&E.

10 For er.h sur. _ tem described, specify who is 11 preparing the item, when it is scheduled to- be completed, 12 and what the purpose (s) of the item is (are) intended to be.

13 14 RESPONSE TO INTERROGATORY NO. 17:

15 (a) (b) and (d) 16 PGandE has ongoing efforts to assist local, -

17 state and federal authorities in their radiological 18 emergency planning. However, no reports, assessments, 19 studies, analyses dr other documents are now in 20 preparation by or for PGandE.

21 22 (c) In addition to the response above, the 23 responses to interrogatories 3 and 4 provide this 24 infc mation.

2s fff e

26 ///

i

1 INTERROGATORY NO. 18:

2 State in detail each and every fact which FG&E 3 believes evidences that PG&E's Emergency Response Plan will 4 comply with 10 C.F.R. S 50.33(g) by October 1, 1981.

5 6 RESPONSE TO INTERROGATORY NO. 18,:

7 See interrogatory 26.

8 9 INTERROGATORY NO. 19:

10 State in detail each and every fact which PG&E 11 believes evidences tnat the State of California's Emergency 12 Response Plan will comply with 10 C.F.R. S 50 33(g) by 13 October 1, 1981.

14 15 RESPONSE TO INTERROGATORY NO. 19:

16 See interros ory 26.

17 18 INTERROGATORY NO. 20:

19 State in detail each and every fact which PG&E 20 believes evidences that the County of San Luis Obispo's 21 Emergency Response Plan will comply with 10 C.F.R. 22 5 50.33(g) by October 1, 1981.

23 24 RESPONSE TO INTERROGATORY NO. Tf,:

25 See interrogatory 26.

~

26 ///

1 INTERROGATORY NO. 21:

2 State in detail each and every fact which PG&E 3 believes evidences that PG&E's Emergency Response Plan will 4 comply with LO C.F.R. S 50.47 by October 1, 1981.

5 6

RESPONSE TO INTERROGATORY NO. 21:

7 See interrogatory 2(,.

8 9 INTERROGATORY NO. 22:

10 State in detail each and every fact which PG&E 11 believes evidences that the State of California's Emergency 12 Response Plan will comply - with 10 C.F.R. S 50.47 by 13 October 1, 1981.

14 15 RESPONSE TO INTFRROGATORY NO. 22:

16 See interrogatory 26.

~

17 18 INTERROGATORY NO. 21:

19 State in detail each and every fact which PG&E

') believes evidences that the County of San Luis Obispo's 21 Emergency Response Plan will comply with 10 C.F.R. S 50.47 22 by_ October 1, 1981.

23 24 RESPONSE TO INTERROGATORY NO. 23:

25 See interrogatory 26.

26 ///

-. - . . - . ~ - . - . - - - - - - - - - - . -

1 INTERROGATORY NO. 24:

2 State in detail each and every fact which PG&E 3 belie,es evidences that the PG&E Emergency Response Plan 4 will comply with 10 C.F.R. Part 50, Appendix E, by 5 October 1, 1981.

6 7 RESPONSE TO INTERROGATORY NO. 24:

8 See interrogatory 26.

9 10 INTERROGATORY NO. 25:

11 State in detail each and every f' ct which PG&E 12 believes evidences that the State of Cahfornia's Emergency 13 Response Plan will comply with 10 C.F.R. Part 50, 14 Appendix E, by October 1, 1981.

15 16 RESPONSE TO INTERROGATORY NO. 25:

17 See interrogatory 26.

18 19 ///

20 ///

21 ///

22 23 24 25 26

1 INTERROGATORY NO. 26:

2 State in detail each and every fact whith PG&E 3 believes evidences that the County of San Luis Obispo's 4 Emergency Response Plan will comply with 10 C.F.R. Part 50, 5 Appendix E, by October 1, 1981.

6 7 RESPONSE TO INTERROGATORY NO. 26:

8 In response to interrogatories 18 through 26, it 9 in the Applicant's position that all applicable emergency 10 plans will be in compliance with all applicable regulations 11 prior to commercial operation of the Diablo^ Canyon nuclear 12 power plant in order to assure that adequate protective 13 measures can and will be taken in the event of a 14 radiological emergency.

15 This opinion is based on the individual and 16 collective judgment of Applicant's staff who have been 17 intimately involved in emergency response planning for the 18 past several years as well as the opinions of various 19 fe'deral, state and county emergency response planners and 20 evaluators. In addition, Applicant has retained consultants 21 who have reviewed the various plans and applicable 22 regulations and have formed similar opinions. Finally, the 23 joint full field exercise conducted on August 19, 1981 24 ds~monstrated a capability to respond to a radiological 25 emergency at Diablo Canyon.

26

1 INTERROGATORY NO. 27:

2 (a) Is it PG&E's position that the Diablo Canyon 3 TSC, OSC, and EOF meet the reliability requirements of 4 NUREG-0696? See NUREG-0696, p. 5.

5 (b) If the answer is YES, state in etail each 6 and every fact that supports such position.

7 (c) If NO, please explain in detail.

8 (d) Identify and describe all documents which 9 relate in any way to the emergency response facilities' 10 compliance or noncompliance with these NUREG requirements.

11 12 RESPONSE TO INTERROGATORY NO. 27:

13 (a) Yes.

14 15 (b) NUREG-0737 further defints criteria for 16 . emergency operating facilities originally required by 17 NUREG-0696. The Applicant plans to comply with these 18 dated. requirements.

l 19

20 (c) Not applicable.

l 21 l t

22 (d) NUREG-0696, SER Supp. 14, D. G. Eisenhut's

, 23 letter of February 18, 1981, NUREG-0737. l

! 24 l

25 26 l

l I l

1 INTERROGATORY NO. 28:

2 (a) Is it PG&E's position that the Diablo Canyon 3 interim EOF meets the requirement that it be "well 4 engineered for the design life of plant?" NUREG-0696, 5 p. 18.

6 (b) If YES, identify and describe all analyses or 7 other documents which relate in any way to the EOF's a compliance or noncompliance with this requirement.

9 (c) If NO, please explain in detail, including a 10 description of all documents which relate thereto.

11 (d) Describe the seismic qualification of PG&E's 12 interim EOF, including a description of the facility and all 13 analyses or other documents which relate -in any way to the 14 likelihood that that facility and all equipment tnerein 15 would remain functional in the OBE, the SSE, and in the 16 event of an earthquake greater than the SSE.

17 18 RESPONSE TO INTERROGATORY NO. 28:

19 (a) Lo.

l 20 21 (b) N/A.

! 22 23 ///

i 24 ///

25 /// l 26 i

1 (c) The interim E.O.F. is a temporary facility 2 and therefore is not designed for the life of the 3 plant. It is PGandE's intention to construct a 4 permanent E.O.F. designed for the life of the plant.

5 6 (d) Refer to TERA Report Earthquake Emergency 7 Planning at Diablo Canyon," September 2, 1981.

8 9

10 11 12 INTERROGATORY NO. 29:

13 Identify and describe: (a) all measures taken by 14 PG&E to integrate its security plan with its emergency plan; 15 (b) all training provided to security personnel concerning 16 the onsite emergency plan; (c) all drills or exercises of 17 the emergency plan that involve the threat designated by 10 18 C.F.R. 5 73.1; and (d) all meetings held by PG&E with State 19 and/or County officials concerning situations that would l 20 involve both the onsite and offsite emergency plan and the 21 security plan.

l 22 2.3 RESPONSE '"5 IN"ERROGATORY NO. 29:

l 24 Objected to by Applicant as tocily irrelevant to 25 the instant proceedings. The security plan and the details 26 thereof are restricted and have been the subject of l

-7s-

T 1 litigation heretofore between the parties. The security 2 plan is not a part of these proceedings nor can it be.

3 4

5 6

7 INTERROGATORY NO. 30:

8 Describe all human factors or other analyses which 9 have been performed on or are proposed to be performed on 10 PG&E's emergency operating procedures. When and by whom was 11 each analysis performed?

12 13 RESPONSE TO INTERROGATORY NO. 30:

14 Objected to as irrelevant and outside the scope of 15 discovery. Emergency operating procedures are not the

~

16 subject of the contention before this Board, but rather 17 emergency planning under 10 C.F.R. 55 50.33(g), 50 47 and 18 Appendix E to Part 50.

19 20 21 22 23 INTERROGATORY NO. 31:

24 Describe all equipment which has not been 25 seismically and environmentally qualified but which PG&E may 26 use or rely upon in any way during a radiological emergency 1

1 at Diablo Canyon. Include in your response a description of ,

2 the use(s) of each identified item of equipment. ,

i

, 3 4 RESPONSE TO INTERROGATORY NO. 31: . .

5 As with interrogatory 7, this question is 6 impossible to answer in that it asks for a list of all f

7 equipment which PGandE may use or rely on in any way during 8 a radiological emergency. However, other than class' one 9 structures and systems at Diablo Canyon, little equipment 10 which might be relied upon in any way would be seismically 11 or environmentally " qualified" as no such requirement exists 12 nor could reasonably be expected to exist.

13 14 15 16 17 INTERROGATORY NO. 32:

18 On Thursday, August 20, 1981, representatives of 19 PG&E, San Luis Obispo County, and others met at the 20 Sheriff's office to discuss, inter alia, the emergency 21 exercise wich was conducted on August 19, 1981.

22 (a) Who was present at the August 20, 1981 23 meeting on behalf of PG&E?

l l 24 (b) Describe all statements of PG&E made at that l 25 meeting, including, without limitation, any statements i

26 concerning problems identified in the August 19 exercise.

l i I

I L

l l

l 1

(c) Identify and describe all documents which 2 relate in any way to the August 20, 1981 meeting, including:

3 (1) any notes taken by any person identified in (a) above; 4 (2) any documents taken to the meeting by any such person; ,

5 and (3) any memoranda or other documents prepared after the 6 meeting which relate in any way to the meeting or to the 7 August 19 exercise.

8 9 RESPONSE TO INTERROGATORY NO. 32:

10 (a) The following PGandE personnel were present 11 at the meeting held August 20, 1981 at the San Luis 12 Obispo County Sheriff's Office:

13 W. B. Kaefer R. J. McDevitt D. J. Baxter W. J. Xeyworth D. P. Serpa J. L. Potter 14 J. D. Shiffer D. L. Duke S. M. Fandel S. M. Skidmore R. W. Lorenz J. S. McKarns 15 16 (b) Three Company representatives made statements

• 17 at the meeting. Their statements are summarized below:

18 (1) .J. D. Shiffer -- Because he was stationed in EOF 19 during the exercise, he did not directly observe 20 EOC. However, things seemed to go well from his

! 21 vantage point. He reminded people in EOC tha't if

! 22 they needed assistance from PGandE, they should ,

23 call Mr. Shiffer, who is the Company Recovery l 24 Manager.

25 (2) W. B. Kaefer --

He was impressed with county 2E decision makers, and he agreed with the).r l  :

l 1 decisions. He agreed that they should have 2 provided more feedback to Mr. Shiffer.

~

3 (3) D. J. Baxter -- He was impressed with the number 4 of news releases and the information they 5 contained. The problems he observed'were minor.

i 6 He suggested more coordination between the company  !

7 and the county. He noted that the first press 8 conference was held without a Company technical 9 advisor being present.

10 11 (c) No notes were taken by persons in (a) above 12 at the August 20, 1981 meeting. Critiques _ of the 13 August 19, 1981 drill and notes regarding that drill 14 were developed by PGandE and will be produced pursuant 15 to pending requests for production.

16 -

17

! 18 l

l 19 20 INTERROGATORY NO. 33:

21 Describe the Uniform Dose Assessment Center 22 ("UDAC") and its functions. Does PG&E contend that UDAC and 23 relate'd equipment will remain fully functional in the event 24 of the'OBE?, the SSE?, an earthquake greater than the SSE?

25 Describe all analyses or ^t h documents which relate in any way to UDAC and/or its seismic qualification.

~

26

-79 .

i

)

I l

l 1 RESPONSE TO INTERROGATORY NO. 33: l l

2 The Unified Dose Assessment Center (UDAC) is 3 co-located with the County Emergency Operations Center (EOC) 4 and the Emergency Operations Facility (EOF) . I,ts function 5 is to coordinate radiological data from field monitoring 6 teams, the PGandE Emergency Assessment and Response System 7 (EARS) dose projection system, dose projections by other 8 means such as overlays and hand calculations within UDAC and 9 other sources and to prepare integrated recommendations to 10 the County Health Officer throughout the emergency 11 situation.

12 The UDAC is under the direction of the SLO County 13 Director of Environmental Health and represents the combined 14 technical expertise (in radiological assessment) of the 15 County, PGandE, State of California, and federal agencies.

~

16 Therefore, the UDAC is utilized as the primary source of 17 recommendations for instituting protective measures for the 18 public which are presented to the County decision makers.

19 The responsibilities of the UDAC include but are not limited 20 to the following areas: (1) assessment of the radiological 21 significance of the radioactive plume; (2) assessment of the 22 aignificance of the radioactive plume on food and water 23 supplies; (3) recomaendation of protective actions which are 24 presented to decision makers on plume and ingestion 25 pathways; (4) review of data from the field and the making 26 of recommendations to control exposure to emergency workers

1 or aur.horization of exposures in excess of exposure limits 2 for emergency workers engaged in lifesaving operations; (5) 3 assessment of the need to screen evacuees for radioactive 4 contamination and recommending conduct of screening and 5 decontamination actions if required; and (6) evaluation of 6 contamination levels in areas evacuated in order to 7 recommend actions to be taken during the recovery and 8 reentry phase.

9 The Applicant assumes for purposes of answering 10 questions regarding OBE and SSE that these earthquakes occur 11 directly opposite the site on the Hocgri resulting in OBE 12 and SSE ground motion at the site. In such event, UDAC and 13 its related equipnient will remain functional. As for "an 14 earthquake greater than the SSE," Applicant simply cannot 15 answer. How much greater? As for documents, see answer to 16 interrogatory 34.

17 18 19 20 21 INTERROGATORY NO. 34:

22 For the OBE and the SSE, provide the peak 2.3 horizontal ground accelerations, velocity, and displacement 24 which PG&E predicts will occur at each of the following 25 locations:

~

26 ///

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

l l

l 1

1 (a) The onsite meterological [ sic] tower.

2 (b) The mountain-top radio repeater. l 3 (c) Morro Bay.

4 (d) The PG&E Information Center. ,

5 (e) The Avila Beach guard station. l t

6 (f) The EOF.

7 (g) Each siren location.

8 (h) Each offsite environmental monitoring station.

9 (i) Each real-time monitoring station.

10 .

(j) The Montana de Oro Campground.

11 (k) San Luis Ambulance Service.

12 (1) Prench Hospital.

13 (m) Shell beach.

14 15 RESPONSE TO INTERROGATORY NO. 34:

16 The basis for estimating peak ground-motion values 17 used in the earthquake emergency planning study is a TERA 18 Corporation report entitled " Evaluation of Peak Horizontal 19 Ground Acceleration Associated with the Hosgri Fault at 20 Diablo Canyon Nuclear Power Plant," submitted to Pacific Gas 21 and Electric Company in August, 1980. Equation 3-3 in 'this 22 report has been used to estimate the horizontal peak ground 23 acceleration at all locations as requesCed. These values 24 may be found in the attached Tables I-IV.

25 For the purposes of estimating peak acceleration, 26 the SSE was taken to be a surface magnitude 7.5 earthquake

1 located offshore on the Hosgri fault. The OBE has been 2 specified only in terms of a peak acceleration of 0.2 g.

3 Placing the OBE on the Hosgri fault, Equation 3-3 was used 4 as a basis for estimating a local Richter magnitude of 5.7 ~

5 for this earthquake. This magnitude was then used to 6 estimate peak acceleration for the OBE at all specified 7 locations. Velocity and displacement values have not been a calculated.

9 ///

10' ///

11 ///

12 13 14 15 16 17 18 19 20 21 22 23 }

24 25 26

~

TABI". 4 ESTIMATED PEA > ACCELERATION AT ELEVEN MISCELLANEOUS SITES DISTANCE FROM HOSGRI FAULT PEAK ACCELERAT LJ (g)

(km) SSE OBE LOCATION

- On-Site Meterological Tower 5.8 .48 - .20 Mountain-Top Radio Repeater 13.3 .32 .l1 ,

14.1 .31 .10 Morro Bay 17.4 .27 .08 PGandE Information Center 12.5 .33' .)1 Avila Beach Guard Statica 21.ti .23 .07 Emergency Off-Site Facility Montana de Oro Campgr_cand 7.0 .44 .18 25.9 .21 .06 San.Luis Ambulance Service 26.6 .20 .06 French Hospital Shell Beach 17.2 .2i .08 18.1 .27 .08 Pismo Beach s

4

TABLE II' ESTIMATED pears ACCELERATION At SIREN '.0 CATIONS o OlSTANCE FROM H05GRI FAULT PEAKACCELERATION(g)

SIREN REFERENCE (km) SSE OBE NUMBER

• 1 13.4 .32 . 10

. 2 14.0 .31 -

.10 14.0 .31 .10.

3 14.6 .30 .10 4

13.7 .32 .10 5

13.3 .32 .10 6

14.8 .30 .10 7

16.8 .28. .09 8

) .26 .08 9 19.1 l .07 10 21 .6- .23 .

23.5 .22 .06 11 25.6- .21 .06 12 25.8 .21 .06 13 27.4 .20 .Di 14 25.4 .21 .06

! 15 26.6 .20 .06 16

[ 24.2 .22 .06 i 17 22.0 .23 . 07

18 24.7 .21- .06-19 22.5 .23 .06 20 24.5 . 2'. .06

! 21 1

26.0 .21 .06 22 22.7 . 23 - .06 ,

23 19.7 .25 .07 i 24 18.6 .26 .08 25 19.5 .25 .07~

. 26 18.1 .27 .08 27-16.5 .28 .09 28 16.5 .28 .09 29

• See PGandE Bmergency, Plan. Figure 7.'2-3-for locations.

f

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

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

TABLE 11 (continued)

DISTANCE FROM SIREN REFERENCE HOSGRI FAULT PEAK ACCELERATION (g)

NUMBER (km) SSE OBE 30 16.9 .28 .08 31 17.2 .27 . .08 32= 18.1 .27 .08 33 19.3 .25 .08 34 18.6 .26 .08 35 19.9 .25 .07 36 22.9 .23 .06 37 20.4 .24 .07 38 18.0 .27 .08 39 17.2 .?? .08 40 16. fi .28 .09 41 18.1 .27 .08

~

42 19.6 .25 .07 43 19.6 .25 .07 44 17.7 .27 .08 4a 19.9 .25 .07 46 16.1 .29 .09 .

47 18.5 .26 .08 48 19.9 .25 .07 49 ,

17.8 .27 .08 50 13.4 .32 .10 51 14.0 .31 .10 52 11.0 .36 .12 53 13.6 .32 .10 54 15.4 .29 .09 55 14.2 .31' .10 56 14.5 .31' .10-57 17.8 .27 .08 58 19.6 .25- .07 59 21.6 .24 .07 60 22.0 .23. .07 61 21.7 .23 .07

______.______.._.___m_m_____._.. _ _ _ _ _ _ . _ _ . _ _ _ . _ . _ . . _ _ _ . _ _ _ _ . __ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . . . _ _ _ . _ _ _ . _ _ _ _ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _

TABLE II (continued)

~

DIST/l!CE FROM SIREN REFERENCE HOSGRI FAULT PEAKACCELERATION(g)

NUMBER (km) SSE' OBE 62 22.0 .23 .07 63 18.9 .26 . .08 64 15.6 .29 .09 65 15.6 .29 .09 66 15;7 .29 .09 67 16.8 .28 .CP 68 16.8 .28 .09 69 16.8 .28 .09 14 3 70 . 31 .10 71 12.1 . 34. .11 .

72 5.9 . 47 .20 73 5.2- . 49 .22 74 6.6 . 45 .18 75 7.6 . 43 .17-76 18.9 . 26 .08 Y

s e

i

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O TABLE III ESTIMATED PEAK ACCELERATION AT OFF-SITE ENVIRONMENTAL MONITORING STATIONS ENVIRONMENTAL MONITORING DISTANCE FROM STATION REFERENCE HOSGRI FAULT PEAK ACCELERATION (g)

NUMBER * (km) SSE OBE 1 14.1 .31 - .10 2 13.4 .32 .10 3 11.0 .36 .12 4 13.8 .31 .10-5 7.6 .43 .17 6 5.2 .49 .22 7 5.6 . 4 8_ .21 8 3.6 .40 .15 1

9 11.4 .35 .12 10 14.4 .3i .10 11 13.4- .32 .10 12 17.0 .28 .08 13 27.0 .20 .05 14 26.2 .20 .06 15 25.4 .21 .06 16 14.0 .31 .10 .

17 13.6 .32 .10 18 17.4 .27 .08 19 19.6 .25 . 07

~20 16.1 .29 .09 21 16.8 .28. .09

• See PGandE' Emergency. Plan Figure 7.3-3 for locations.

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

TABLE IV ESTIMATED PEAK ACCELERATION AT OFF SITE REAL TIME RADI ATION MONITORS DISTANCE FROM MONITOR HOSGRI FAULT PEAK ACCELERATION (g).

(km) SSE OBE-REFERENCE NUMBER

• 1 14.1 .31 . .10 2 12.3 .34 .11 3 21.6 .23 .07 4 25.9 .21 .06 5 25.5 .21 .06 6 17.4 .27 .08 7 12.5 .33 .11 8 18.. .27 .0S 9 19.9 .25 .07 t

E

. *See PGandE Emergency Plan Figure 7.3-4 for locations.

1 2 Respectfully submitted, 3 MALCOLM H. FURBUSH PHILIP A. CRANE, JR.

4 RICHARD F. LOCKE Pacific Gas and Electric Company 5 P.O. Box 7442 San Francisco, California 94120 6 (415) 781-4231 7 ARTHUR C. GEHR Snell & Wilmer 8 3100 Valley Center Phoenix, Arizona 85073 9 (602) 257-7288 10 ERUCE NORTON Ncrton, Eurke, Berry & F.~ench, P.C.

11 3216 N. Third Street Suite 300 12 Phoenix, Arizona 85012-2699 (602) 264-0033 13 Attorneys for 14 Paci 'c Gas and Electri Company 15 '

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16 B V '

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ce Nortpn 17 \

18 DATED: September 15, 1981.

19 20 g 21 22 23 24 25 26

_ . . _ _ _ - _ _ _ - ~. _ _ . . . . . . . _ _ . _ _ _ . _ _ _ _ _ _ _ . . _ . _ _ _ _ , __. _ . - . - _ .

I inve assisted in preparing the answers to.

Interrogatories 32 . Said answers are true and correct to the best of rqy knowledge and belief.

/

J.hSHIFFER k8 Subscribed and sworn to

. before me this 15th day of September,1981.

SEAL Theodora Cooke, Notary Public in. ond for the City and County of ' San Francisco, State of Cciifornia My Comission expires January 28, 1985 l

I have assisted in preparing the answers to.

Interrogatories 5. 6. 17 and 28 Said answers are true and correct to the best of my knowledge and belief.

W S. M. SKIDMORE l

Subsgribed and sworn to before me this 15th day of Septer.ber,1981.

\

SEAL Theodora Cooke, Notary Public in hrd for the City and County .

cf San Francisco. State of

. California My Commission expires Janusry 28, 1985

/

l-.

I have assisted in preparing the answers tc-Interrogatories .

11 . Said answers are true and correct to the best of ray knowledge and belief, A4 4 L *L s ,

((R.TORRENS Subscribed and sworn to before me this 15th day c6 September, 1981.

eodbra Cooke, Notary Public in-ar.d for the City and County of San Francisco, State of California My Conunission expires Januery 28, 1985

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I have assisted in preparing the answers to.

, Interrogatories 28 and 33 . Said answers are true and correct to the best of nty knowledge and belief.

F. M. GERMANO Subscribed and sworn to before me this 15th day of Sentember, 1981.

/

U SEAL Theodcra Cooke, Notary Public in and for the City and County -

of San Francisco, State of California My Comission expires January 28, 1985 l

l I have assisted in preparing the answers to, Interrogatories 11 . Said answers are true and correct to the best of my knowledge and belief.

~

[ J. L. Potter Subscribed and sworn to before me this 15th day of September,1981.

__ L SEAL'

.eodora Cooke, Notary Public in and for the City and County cf San Francisco, State of California My Comission expires January 28, 1985 i'

\

I have assisted in preparing the answers to.

Interrogatories 3, 4, 5 and 17 . Said answers are true and correct to the best of rqy knowledge and belief.

l l

l Jabt,9. Sexa d k F,.ROCKMhKER Subscribr ri and sworn to i

. before me this 15th day of September,1981.

eo 6ra Cooke, Notary Public .g in ar.it for the City and County -

of San Francisco, State of California My Comis'.h n expires January 28, 1983

I have assisted in preparing the answers to.

Interrogatories 8, 9 and 10 . Said answers are true and correct to the best of ray knowledge and belief.

g

{lll Met /m K.M.GODFREY/ [/

Subscribed and sworn to

. before me this 15th day of S?ptember, 1981.

Z/

eodcra Cooke, Notary Public SEAL in.arej for the City and County of San Francisco, State of Cclifornia My Commission expires January 26, 1985 9

D a

- m--- - .,ye----e. --+ e- w --g of -- , +- g + - - - - ,, -wc-- - + ,---y - *g r+--- ---W- **v ?

• y I have assisted in preparing the answers to.

Interrogatories 5, 6, 12, 14, 15, 32 . Said answers are crue and correct to the best of my knowledge and belief.

R.VJ. McDEVITT Subscribed and sworn to

. before me this 15th day I

of September,1981.

SEAL Theode.ra Cooke, Notary Public ir a;;d for the City and County .

of San Francisco, State of l California My Commission expires January 28, 1985

/

A _ _ _ - _ _

I have assisted in preparing the answers to.

Interrogatories 14 and 27 . Said answers are true and correct to the best of my knowledge and belief.

/ .~ s

' / /'f, 8, & ~

. W. H. FUJIMOTO Subscribed ar.d sworn to

. before me this 15th day of September,1981.

heodora Cooke, Notary PubTic SEAL in and for the City and County of San Francisco, State of Chiifornia Hy Comission expires January 28, 1985 t

I l

l

.-,4.- . . - . , - . - . - - , . - - - _ . - _ . . _ . , ,

I have assisted in preparing the answers to.

Interrogatories 2, 9 . Said answers are true and correct to the best of ray knowledge and belief.

/ v D. P. SE A Subscribed and sworn to before me this 15th day of September,1981.

4 SEAL Theocora Cooke, Notary Public in'and for the City and County -

6f San Francisco, State of

- C'ali forni a My Comission expires January 28, 1985

l l

I have assisted in preparing the answers to.

Interrogatories 27 . Said answers are true and correct to the best of my knowledge and belief.

l Afo w G. WALLACE Subscribed and sworn to

. Before me this 15th day cf September,1981.

SEAL Theodcra Cooke Notary P'u ic in coi:d for the City and County of San Francisco, State of Cciifornia My Comission expires January 28, 1985 A

1 l

I have assisted in preparing the answers to.

Interrogatories 1 and 2 . Said answers are true and correct to the best of nty knowledge and belief.

@d. M T. A. MACK Subscribed and sworn to

. before me this 15th day of September,1981.

3 <? SEAL Theodt'ra Cooke Notary Public in e.n; for the City and County .

of San Fr weisco, State'of C.tliforni a My Conrnission expires Jarur y 28, 1985 t

- -- - , # ----,,.%<, -,w--. , ,, .-- -. _ - -,-- - - - . . - c..,, -w,,y -r-.. . - .,. , m.- ,c,,c-- u , - +_ , , --_

I have assisted in preparing the answers to.

Interroget: ries 16, 17 ind 34 . Said answers are true and correct to the best of te knowledge and belief.

A

= =1-D. K. DAVIS Subscribed and sworn to

. before me this 15th day of September,1981.

g SEAL Theodcra Cooke, Notary Public in.ana for the City and County of San Francisco, State of Cc~liforni a My Commission expires January 28, 1985 t

D 7, UNITED STATES OF AMERICA d S' NUCLEAR REGULATORY COMMISSION C3  : ' '

,- :o 13 GM.

In the Matter of T-) F #

PACIFIC GAS AND ELECTRIC COMPANY Diablo Canyon Nuclear Power Plant,

)

)

Docket No. 50-275 Docket No. 50-323 Q:;~l 4

Units 1 and 2 ) (Full Power Proceeding)

~

_ )

CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (have) been served today on the following by deposit in the United States mail, properly stamped and addressed:

Judge John F. Wolf Mrs. Sandra A. jilver Chairman 1760 Alisal Street Atomic Safety and Licensing Board San Luis Obispo, California 93401 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Fr. Gordon Silver 1760 Alisal Streat Judge Glenn O. Bright San Luis Obispo, California 93401 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission John Phillips, Esq.

Washington, D. C. 20555 Joel Reyneids, Esq. ,

Center fo; Law in the Public Interest Judge Jerry R. Kline 10203 Santa Monica Drive Atomic Safety and Licensing Board Los Angeles, California 90067 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 David F. Fleischaker, Esq.

• P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City C/o Nancy Culver Oklahoma 73101 192 Luneta Drive Stn Luis Obispo, California 93401 Arthur C. Gehr, Esq.

Snell & Wilmer Janice E. Kerr, Esq. 3100 Valley Bank Center Public Utilities Commission Phoenix, Arizona 85073 of the State of California 5246 State Building Bruce Norton, Esq.

350 McAllister Street Norton, Burke, Berry & French, P.C.

San Francisco, California 94102 3216 N. Third Street Suite 300 Mrs. Raye Fleming Phoenix, Arizona 85012-2699 1920 Mattie Road Shell Beach, California 93449 Chairman Atomic Safety and Licensing Mr. Frederick Eissler Board Panel l Scenic Shoreline Preservation U. S. Nuclear Regulatory Commission conference, Inc. Washington, D. C. 20555 4623 More Mesa Drive i Srnta Barbara, California 93105 l l

1 1

Chairman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Appeal Board W2shington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Sacretary U. S. Nuclear Regulatory Commission Judge W. Reed Johnson Washington, D. C. 20555 Atomic Safety and Licensing Appeal Board Attn.: Docketing and Servico Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555 William J. Olmstead, Esq.

Bradley W. Jones, Esq. Judge John H. Buck Office of Executive Legal 0irector Atomic Safety and Licensing B ETH 0 42 Appeal Box.rd U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Mr. Richard B. Hubbard MHB Tedhnical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 Mr. Carl Neiberger Taleeram Tribune P. O. Box 112 S2n Luis Obispo, California 93402 H2rbert H. Brown, Esq.

Lawrence Coe Lanpher, Esq.

Christopher B. Hanback, Esq.

Hill, Christopher & Phillips 1900 M Street, N.W.

W2chington, D. C. 20036 i Byron ~S. Georgiou, Esq.

D;puty Legal Affairs Secretary Governor's Office State Capitol, Sacramento, California 95814 I

l

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'FhT 1 bp A. f ,

Cran ,

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Attorney Pacific as and Elect ic Company Date: September 15, 1981

.. .. . , _ _ -