ML20010H786
| ML20010H786 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/22/1981 |
| From: | Lanpher L CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | PACIFIC GAS & ELECTRIC CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8109290293 | |
| Download: ML20010H786 (44) | |
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UNITED STATES OF AMERICA DOCXDED g' NUCLEAR REGULATORY COMMISSION g. UsNac -
- 3EP 2 5 1981 *
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
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Ochsg a senice Etanch y In the Matter of ) ._
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PACIFIC GAS AND ELECTRIC COMPANY ) Doctet Nos. 50 '
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(Diablo Canyon Nuclear Power ) g'%
Plant, Unit Nos. 1 and 2) )
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RESPONSE OF GOVERNOR EDMUND G. BROWN JR . 2,-
TO PG&E DOCUMENT PRODUCTION REQUEST %g(p,,q 4 h~/
DATED AUGUST 18, 1981 ,j(aN %
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\ i $t on August 18, 1981, Pacific Gas and Elcatric Company ("PG&E")
requested the Governor to produce documents for inspection and copying. Governor Brown hereby responds to this request and states:
- 1. The PG&E requests are so broad and burdensome that compliance is impossible within the time limits set forth in the NRC's regulations. At least an additional 6 months will be required for full response.
- 2. Compliance with PG&E's requests wguld require the State to expend more than $1,000,000.
- 3. PG&E should either:
(a) Agree in advance to reimburse the State for the expenses incurred by the State in response to PG&E's requests; or (b) Limit the requests in some reasonable manner, such as limiting the requests to documents related to Diablo Canyon.
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8109290293 810922 ~ '
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- 4. If PG&E will not undertake either 3(a) or 3(b), the Governor hereby objects to PG&E's requests, purfaant to 10 C.F.R. SS 2.740(c) and 2.741(d), and requests the Licensing Board to issue a protective order.
The bases for the Governor's positions are set forth below.
I. The PG&E Do,cument Production Requests PG&E's August 18 document production requests are exceedingly broad. Indeed, PG42 requests every_ emergency planning document
- in the possession of the entire State government now, and further-more, in the possession of any past State employee. In reality, J PG&E has asked the State to conduct a virtual world-wide search i to track down former employees and locate documents, regardless j whether the documents relate to Diablo Canyon
Request No. 1:
i All documents in possession, custody, or control of the State of California (including the possession, custody or control of ang agency or organiz' tion of the State or of any contractor, employee., con-sultant, or agent of the State, past or present) 4 which relate in any way to radiological emergency planning (at Diablo Canyon or any other nuclear facility) or earthquake response or emergency planning (at Diablo Canyon or any other critical facility (nuclear, medical or otherwise)).
Request No. 2:
All documents in the possession, custody or control of the State of California (including the possession, custody or control of ang agency or organization of i
the State, or of any contractor, employee, consult-ant or agent of the State, past or present) which i relate in any way to State, local, Federal, or utility emergency response plans within the State of California. (emphasis supplied).
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. r The PG&E request is particularly burdensome because the request is directed to every agency and organization of the State. Thus, PG&E states:
(T]his request for production is directed to Governor Brown as a representative of an interested state. As such, the request is directed at the State of California and all of its agencies, organization, and/or sub-divisions of any kind whatsoever, including, but not limited to, the California Conserva-tion Corps., Department of Corrections, Depart-ment of Fish and Game, Department of Forestry, Department of Youth Author.ity, State Fire Marshal, Military Department, California Highway Patrol, Department of General Services, Depart-ment of Justice, Department of Transportation, Air Resources Board, Department of Food and Agriculture, Department of Aging, Department of Motor Vehicles, Department of Parks and Recrea-tion, Department of Rehabilitation, Department of Veteran's Affairs, Department of Conservation, Department of Education, Department of Finance, Department of Industrial Relations, Department of Water Resources, Energy Resources Conservation and Development Commission, Public Utilities Commission, Office of Emergency Services, and the State Person-nel Board. All documents in the possession of the State of California are to be produced, whether they be located in headquarter offices, regional offices, or local offices or any subdivision thereof. (emphasis supplied).
II. The Governor's Efforts to Comply with PG&E's Production Requests The Governor, from the outset, has been concerned that PG&E's l
l request amounted to a blatent " fishing expedition," without any focus on those documents in the possession of the State which might in fact relate directly to Diablo Canyon or be helpful to PG&E in l this proceeding. The Governor's counsel expressed this view to the Board during a conference call on August 26, 1981. While PG&E's I
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requests clearly may have been objectionable from the outset, the Governor nevertheless has taken these requests at face value and has diligently attempted to comply.
Thus, on August 26, 1981, the Governor's Legal Affairs Secretary, Byron S. Georgiou, sent a Memorandum to all State agencies and organizations requesting that they identify documents falling within the scope of PG&E's requests. A copy of Mr.
Garogiou's Memorandum is attached hereto as Exhibit A. A list of the 52 agencies and organizations to whom the Memorandum was sent is attached as Exhibit B.
The Governor has still not received responses from all agencies. However, the responses that have been received thus far document for the record that compliance with the PG&E request will be exceedingly costly and time-consuming. The Governor attaches hereto as Exhibits C-R the agency responses received thus far.
Further responses will be submitted when they are received. The attached responces are self-explanatory in large part but we highlight certain points as follows:
The California Office of Emergency Services ( "OES ") is the primary emergency planning and preparedness agency for the State.
Mr. John J. Kearns, OES Deputy Director, estimates that compliance by OES alone with the PG&E requests would. require production of more than 1,000 cubic feet of records, requiring 18 person-years and a cost of $450,000 in salary, $60,000 in overhead, and $1s0,000 for copying. See Exhibit C hereto.
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- Other agency. responses also indicate the substantial costs and resources required to comply with PG&E's requests:
COST TIME California Conservation , 3 wks./100 Staff Corps. S 13,714.00 personnel Department of Aging 432.20 October 9, 1981 Department of Develop-mental Services 23,292.68 2 Months Department of Fish and Game 132,500.00 6 Months Department of Forestry 594.34 60 Hours Department of Health Services 550.00 10 person-days Disaster Medical Services 50,000.00 --
California Highway Patrol 62,852.83 --
Department of Parks and Recreation 2,500.00 20 person-days Based on the foregoing, and assuming that responses from other agencies roughly are the same as the responses received so far, it is clear that a full and complete response by the State to PG&E's requests will take many months (we estimate ec least 6) and cost $1 million or more. This does not include the time and expense incurred for counsel to review the documents to ensure that production is legally permitted. As the California Highway Patrol indicates with respect to the materials it has produced, "every document that has been provided thus far contains material that is protected from release by one or more state and/or federal
statutes." The time requirad for counsel to review all these materials will be substantia'1. Moreover, this Board would likely have to issue a Protective Order to protect such informa-tion'from disclosure and require that the parties (and perhaps the Board also) execute Affidavits to comply with such Protective Order. All this would have to be done in accordance with State law, and there are preliminary ' legal determinations which will have to be made by the State in order to facilitate the Board in assuring the protection of information shielded from disclosure by State and/or Federal laws.
III. Requested Relief The Governor submits that the PG&E requests are manifestly unreasonable. PG&E does not request only those documents related to Diablo Canyon, but rather every emergency planning document in the entire State and in the possession of all State employees, present and past. Such an unfocused request constitutes a clear abuse of the NRC's discovary regulations. While PG&E's motives might or might not have been conceptually constructive, -the effect of PG&E's requests clearly is unreasonable if not an act of harrassment.
If PG&E truly desires the requested documents, and1in good faith helieves that its unbridled ragesu will further the search for truth and the public interest in this proceeding, this Board should require PG&E to commit, in advance, to reimburse the State for the State's expenses, at least those expenses incurred to produce documents nct directly related to Diablo Canyon. If PG&E is unwilling to undertake such reimbursement, it should narrow its
requests to documents which in fact are necessary and useful for this proceeding.
In the event PG&E refuses to restructure its requests or commit to reimburse the State, the Governor requests the Licenring Board to issue a Protective Order barring PG&E's discovery. Only in this way can the State be protected from PG&E's unreasonable discovery requests.
Respectfully submitted, Byron S. Georgiou, Esq.
Legal Affairs Secretary Governor's Office State Capitol Sacramento, California 95814
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Herbert H. Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D.C. 20036 Attorneys for Governor Brown of the State of California September 22, 1981
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4 tote of Californie M mOrandUm To : All State Agencies, Departments, Boards k. : August 26, 1981 and Ccmnissions Subject : Pequest to Identify and
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Produce Dnergency Planning and Earthquake Data Byron . Georgiou, Affairs Secretary to the Governor From Governor's ONice Governor Brown is participating, as representative of California, in the proceeding before the United States Nuclear Pegulatory Ccmnission ("NRC")
to determine whether a full power cperating license should be granted to Pacific Gas and Electric Cxpany ("PG&E") for operation of the Diablo Canycn Nuclear Power Plant. Amcng other things, this proceeding addresses whether there is adequate emergency preparedness to deal with a radiological emergency at Diablo Canyon, including preparedness to take emergency actions where an earthquake e xplicates emergency response.
As part of the pre-trial procedures, PG&E has requested Governor Brown to produce the follcwing types of documents:
- 1. All documents in the possessian, custcdy or centrol of the State of california (including the possessian, custody or control of l ' any agency or organization of the State or of any contractor, enployee, consultant, or agent of the State, past or present) which relate in any way to radiological emergency planning (at Diablo Canyan or any other nuclear facility) or earthquake response or emergency planning (at Diablo Canyon or any other critical facility (nuclear, # 4m l or otherwise]).
- 2. All th =nts in the possession, custody or control of the State of california (including the possession, custody or control of any agency or organization of the State, or of any contractor, ernployee, ccmsultant or agent of the State, paa ; or present) which relate in any way to State, local, Federal, or utility au=u.sency response plans within the State of california.
The PG&E request states further that:
(a]11 documentt in the possession of the State of enlifornia are to be produced, whether they be located in headquarter offices, regicnal offices, or local offices or any subdivision thereof.
2 e PG&E request defines "d r w nts" very broadly:
As used herein, " documents" includes, but is not limited to, papers, photographs, recordings, memoranda, books, records, w itings, letters, teley - s, mailgrams,'correspcodence, notes and/or minutes of meetings cr conversations or of telephone calls, inter-office or intra-office memoranda or written ecmumications of any nature, recordings ef con-versaticms either in writing or una any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, u:ru.is, studies, opiniens, analyses, assessments, surveys, evaluations, projections, hypotheses, fon:ulas, designs, drawings, manuals, note-books, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and ccuputer printout sheets, ccxtputer data, teleccpier transmissions, directives, proposals, and all drafts, revisicos, and differing versions (whether formal or informal) of any of the foregoing, and also, all copies of any of the foregoing which differ in any way (including hard-written notations cr other written orprintedIratter of any nature) frc2n the original.
PG&E's foregoing request for documents is unusually broad. Re Governor is, of course, concerned that PG&E's request will prove to be an unreasenzble burden on State rescurces. Nevertheless, pre-trial procedures require that the State cocperate as fully as possible. Accordingly, please do the following:
- 1. As soon as possible, provide to me all rm aily-available documents which fall within PG&E's request 1 or 2 above.
- 2. No later than Septer:ber 16, 1981, provide to me:
(a) A descripticn of the steps that your agency is taking and will
- need to take in order to search for the requested d r w nts;
( (b) ne numberof personnel in your agency required to acccrplish the foregoing search; i
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(c) The estimated ti::e by which such search can be am714 abad and all d m = nts provided to me; (d) An estimate of the direct costs of copying all such d e - nts and an estimate of the malaries and administrative costs as-sociated with the performance of these tasks by the perscns assigned to perfonn them.
Please contact Phillip A. Greenberg, Energy and Envi. m t Assistant to the Governor (3-6237) if you have any questions regarding this matter. Thank you f5r your coor .raticn.
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EXHIBIT B AGENCIES AND ORGANIZA" IONS TO WHICH GEORGIOU MEMORANDUM OF AUGUST 26, 1981 WAS SENT Tha Honorable Alice Lytle, Secretary State & Consumer Services Agency 915 Capitol Mall, Ste. 200 Sccramento, CA 95814 Tha Honorable David Janssen Director of General Services 915 Capitol Mall, Ste. 590 Sccramento, CA 95814 Tho Honorable Manuel Val Dir0ctor of Veterans Affairs 1227 - 0 Street Sncramento, CA 95814 Tha Honorable Richard B. Spohn Dircctor of Consumer Affairs 1020 - N Street Sacramento, CA 95814 The Honorable Philip C. Favro
, Stato Fire Marshal 7171 Bowling Dr., Ste. 800 Sacramento, CA 95823 .
Tho Honorable Lynn Schenk, Secretary t Business, Transportation & Housing Agency 1120 - N Street Sacramento, CA 95814 The Honorable Adriana Gianturco Director of Transportation 1120 - N Street i Sacramento, CA 95814 i
The Honorable Doris Alexis l
Dircctor of Motor Vehicles 2415 - 1st Avenue Sacramento, CA 95818 Tha Honorable Melinda C. Luedtke DIpsrtment of Economic & Business Development 1120 - N Street Sacramento, CA 95814 Tho Honorable I. Donald Terner Dircctor of Housing & Community Development 921 - 10th Street Sacramento, CA 95814 Tho Honorable Glendon B. Craig Commissioner of the California Highway Patrol 2555 - 1st Avenue P. O. Box 898
- Sacramento, CA 95804 ,
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- Tho Honorable Mario G. Oblado, Secretary
-H;nith & Welfare Agency 1600 - 9th Street, Reor 443 Sacramento, CA 95814 Ths Honorable Henry Zaretsky, Director
'Statswide Health Planning & Development 1600 - 9th Street Sacramento, CA 95814 The Honorable Be.verlee A, Myers Director of Health Services 714 - P St'reet, Room 1253 Sacramento, CA 15814 Tha Honorable Marion Woods Director of Social Services 744 - P Street, Room 1743 Sacramento, CA 95814 Tha Honorable Al M. Loeb Director of Mental Health 1600 - 9th Street Sacramento, CA 95814 The Honorable Sarah Davis Director of Alcohol & Drug Abuse Programs 111 Capitol Mall, Room 450 Sacramento, CA 95814
, The Honorable David E. Loberg Dirtctor of Developmental Services 1600 - 9th Street Sacramento, CA 95814 Tho Honorable Edward V. Roberts Dircctor of Rehabilitation 830 - K Street Mall l Sacramento, CA 95814 l
' Tha Honorable Russ Bohart
- Dircctor of Health & Welfare Agency Data Center 112 - J Street Sacramento, CA 95814 l
l Th3 Honorable Janet J. Levy Director, Department of Aging 1020 - 19th Street Secramento, CA 95814 ThQ Honorable Douglas X. Patino
, DirGctor of Employment Development ,
800 Capitol Mall, Room 5000 Sacramento, CA 95814
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u Ths Honorable Huey D. Johnson Srcretary, Resources Agency 1416 - 9th Street, Room 1311 Sccramento, CA 95814 l
Tha Honorable Peter Dangermond, Jr.
Director of Parks & P.ac reation 1416 - 9th Street, '4th Floor Sacramento, CA 95f;4 l The Honorable Rcuald B. Robie Director of Water Resources 1416 - 9th Street Sacramento, CA 95814 Thn Honorable Jan Denton Director of Conservation 1416 - 9th Street, 13th Floor Sacramento, CA 95814 Tha Honorable Marty Mercado Director of Boating & Waterways 1416 - 9th Street, Room 1336 Sacramento, CA 95814 Tha Honorable E. Chas. Fullerton
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Director of Fish & Game 1416 - 9th Street, 12th Floor Sacramento, CA 95814 Tha Honorable B. T. Collins Director, California Conservation Corps 1530 Capitol Avenue
- Sacramento, CA 95814 I
The Honorable David Pesonen Director of Forestry
- 1416 - 9th Street, 15th Floor Sacramento, CA 95814 Tho Honorable Richard E. Rominger Director of Food & Agriculture 1220 - N Street, Rooms 100-112 Sccramento, CA 95814 Tho HonoraPle Donald Vial Director of Industrial Relations 525 Golden Gate Avenue San Francisco, CA 94101 Th3 Honorable Howard K. Way S cretary, Youth & Adult Correctional Agency 1027 - loth Street, Ste. 300 Sacramente, CA 95814 l
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Ths Honorable Pearl West Director of the Youth Authority 4241 Williamsbourgh Dr.
Sacramento, CA 95823 Tho Honorable Antonio Amador Chairman, Youthful Offenders Parole Board 4241 Williamsbourgh cr.
Sacramento, CA 95823 Tho Honorable Raymond C. Brown Choirman, Board of Prison Terms 545 Downtown Plaza, Ste. 200 Sacramento, CA 95814 Ths Honorable Mary Nichols Sccretary of Environmental Affairs 1102 - 0 Street Sacramento, CA 95814 The Honorable Carla M. Bard Chairwoman, State Water Resources Control Board 1416 - 9th Street, 10th Floor Sacramento, CA 95814 Ths Honorable Terry A. Trumbull Chairman, Solid Waste Management Board 1020 - 9th Street, Ste. 300 Sacramento, CA 95814 The Honorable Alexander Cunningham Director, Office of Emergency Services 2800 Meadowview Road j P. O. Box 9577 l Sacramento, CA 95823 Major General Frank Schober, Jr.
l Tha Commanding General l Military Departmant 2329 Watt Avenue P. O. Box 214405 SEcramento, CA 95821 Tha Honorable Douglas Cunningham l Ex;cutive Director l Office of Criminal Justice Planning l 9719 Lincoln Village Dr.
l Sacramento, CA 95827 I
! Tho Honorable Deni Greene l
Director, Office of Planning & Research I
1400 - 10th Street Stcramento, CA 95814
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Th2 Honorable Russell Schweickart Chairman, Energy Resources Conservation & Development Commission 1111 Howe Avenue Stcramento, CA 95825 Tha Honorable John Bryson, President Public Utilities Commission 350 McAllister Street San Francisco, CA 94102 Tho Honorable Carole Onorato Chairwoman, California Transportation Commission 1120 - N Street Sacramento, CA 95814
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The Honorable William F. Northrop Ex cutive Officer State Lands Commission 1807 - 13th Street Sacramento, CA 95814 The Honorable Lenard Grote Chairman, California Coastal Commission 631 Howard Street, 4th Floor San Francisco, CA 94105 Director, Office of Appropriate Technology 1600 - 9th Street Sacramento, CA 95814 State Architect 1500 - 5th Street Sacramento, CA 95814 Chairman Building Standards Commission 915 Capitol Mall, 2nd Floor Sacramento, CA 95814 Tha Honorable Ruth L. Rushen Director of Corrections 630 - K Street, Ste. 200 S cramento, CA 95814 l
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State of Californie EXHIBIT C Momorandum l
Ta Byron S. Georgiou Dd* September 18, 1991 Legal Affairs Secretary l Office of the Governor John J. Kearns 1 Deputy Director From : OFFICE OF EMERGENCY SERVICES
Subject:
Request to Identify and Produce Emergency Planning and Earthquake Data Because th. Office of Emergency Services is involved in emergency response planning for nuclear power plants, earthquakes and other disasters, the request for documents outlined in your August 26, 1981 memo is so broad it would include nearly every paper, document, film and tape in the possession of OES. Further, within a short time it is impossible to accurately determine the state rescurces and time frame required for providing all of these materials to you.
Our current annual estimate of cubic footage of Records Holdings totals 1,049. Using our best estimates, duplication of these documents would require 18 person-years and a cost of about $450,000 in salary, $60,000 overhead and $130,000 for duplication, at a total of $640,000.
The magnitude of this task is such that further guidance is needed from your office to decide how we are to begin and what resources are to be assigned. Given this clarification, we will provide the necessary information as expeditiously -
aq possible.
I J . S pu tor ,
Ctodo cf California The Resourc :, Agency
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Momorandum .
Te : Bryon Georgiou Date : 8E? 17198)
Legal Affairs Secretary Governor's Office File No.:
State Capitol Sacramento, CA Subivo : Request tc Identify and Produce Emergency '
Plar.ning and From : Department of WWar Resources Earthquake Delta Yaur memo of August 26, 1981, addressed to all State agencies, departments, boards, and commissions, requests that certain actions be taken to assist Governor Brown in responding to a document production request made by Pacific Gas and Electric Company (PGandE) in the Diablo Canyon proceeding before the United States Nuclear Regulatory Commission. The following information has been conveyed orally to Larry Lanfer, the Washington, D.C. , attorney representing California in the Diablo Canyon proceeding.
DWR has been involved since 1977 as an intervenor in Pacific Gas and Electric Company (Stanislaus Nuclear Pro iect, Unit No. 1) U.S.
Nuclear Regulatory Commission Docket No. P05(4A. At issue in this proceeding, brought before the Atomic Safety and Licensing Board, is whether granting a permit and license to PGandE for the proposed Stanislaus Nuclear Project will create or maintain a situation inconsistent with the antitrust laws.
The Stanislaus litigation has involved and continues to involve lengthy discovery proceedings and massive document production efforts by PGandE and DNR. In the course of the Stanislaus discovery proceedings, DNR has furnished to PGandE the DWR File -- -
Manual (an index listing the title of all files in DNR's central _
records). The File Manual is contained in a large three-ring binder and consists of at least 300 single-spaced pages. By , _ _ __
using this index and inspecting the DWR file stations l (accompanied by a DNR attorney), PGandE has been able to i
designate which of DNR's files it was interested in examining.
Pursuant to PGandE's document production request in the Stanislaus proceeding, DNR has already turned over to PGandE f-3' approximately 48,300 pages of documents with an additional 25,300 pages waiting to be turned over. Ultimately, DNR estimates l that PGandE will receive more than 210,000 pages of DNR documents. .
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j Bryod'Georgiou Lage 2 SEP 17 tej We feel that, because of its knowledge of DWR's filing system obtained in the course of the Stanislaus litigation and its possession of DWR's central records filing index, PGandE should be able to specify with precision those DNR files which it wants produced in the Diablo Canyon proceeding. Because of the detailed records which DNR keeps of al'. of its transactions, access to the -
materials in DWR's central res:ords should provide PGandE with a very substantial amount of ma:erial on emergency preparedness.
These materials should be scrae,ned for privilege before being turned over to PGandE. .
With regard to the documents other than those in DWR's central ,
records, there is no easy way of estimating the time, personnel, ' .
and costs associated with retrieval, duplication, and production.
This residual body of documents would include all the papers in each staff member's office. There is no basis for estimating the volume of these papers. For example, the sole function of the DNR Division of Safety of Dams is to supervise the design, constuction, maintenance, repair, alteration and operation of all dams and reservoirs in the State above a certain minimum size and capacity, for the safety of life and property. Literal compliance with PGandE's document production request would require copying and screening for privilege virtually every piece of paper within that J ,
entire division.
The same dilemma is largely true of DNR's Division of Operation and Maintenance. A substantial task of that division is to ensure the continued safe functioning of the State Water Project. Therefore arguably a graat deal of paper in that division would be producible under the PGandE request for documents relating to emergency planning. The same is true of the Division of Flood Management and other units within DWR. This could result in enormous expenditures and could consume large amounts of time. , ,
We hope that this information will be of help to you in responding to the PGandE document production request. If you require any additional information please contact Michael J. --
Strumwasser of the Attorney General's office, who is representing DNR in the Stanislaus proceeding (8-677-2102) or Susan Weber of l
the DNR legal staff (445-4857).
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Ronald B. Robie Director cc: Michael J.- Strumwasser 3580 Wilshire Blvd.
Los Angeles, CA 90010
5 tete of California THE RESOURCIS AGENCY OF CAUFORNIA M'o m 6 r a n d u m sxararr s T. , Byron S. Georgiou cate : September 11, 1981 Legal Affairs Secretary to the Governor subject: Pacific Gas and Electriq Governor's Office Request for Documents Relatinf State Capitol to the Earthquake Emergency Sacramento, CA 95814 Response Considerations at Diabic Canyon From : Department of Conservation-Office of the Director We have not considered any earthquate emergency response '
activities as part of our correspondence.
I therefore believe that none of the materials within our files relate to the documents requested as characterized on page 2 of your August 26 memorandum.
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J:In Denton irector
[M 6 [U e -e-e- mee e ,e e, e h e ge me pp 6% e W 9e emmW n-w +
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State of Californie THE RESOURCIS AGENCY !
Momorandum
- EXHIBIT F i
To : Byron S. Georgiou Date : September 16, 1981 Legal Affairs Secretary l to the Governor File No.:
subject: Request to Identify and i Produce Emergency Planning and Earthquaki: Data From : California Conservation Corps I agree with the Governor--PG&E's request to provide every note, memo and revision of the California Conservation Corps' emergency response documents is unreasonable.
- 1. Attached are the CCC's major emergency planning documents and an example of a recent earthquake memorandum.
- 2. Initial conversations with headquarters and field staff have been conducted to get an idea of the extent of the planning required for the retrieval of the necessary documents. A complete search of the files pertaining to earthquakes or emergency planning will require the following planning, personnel and costs.
A.1. Initially, an Associate Environmental Planner would develop the guidelines of what materials need to be gathered. Identification of the various individuals having contact with emergency planning documents would be conducted. -
- 2. Directives and guidelines would then be sent to the appropriate headquirters and field staff.
- 3. All ine viduals identified to collect emergency planning documents would gather the material and route the documents to the Planning Branch.
- 4. Compilation of all field and headquarters documents would take place in the Planning Branch. -
- 5. Copies of all materials gathered would be made.
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' B. The number of people involved in a search of all files and documents related to emergencies would be around 100 staff.
C. Approximately three weeks would be required to complete the entire search process. If started today the final document could be in your hands by October 1, 1981.
D. An estimate of the copying costs for headqua'rters and field centers is
$955. An estimate of the labor and administrative costs for the search are $12,219. Total costs are estimated to be $13,1,74.
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B. T. Collins .
Director -
l attachments
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State of Crlifornia ,
l Mbm6randum EXHIBIT G To Byron Georgiou Data September 15, 1981 Charles Brandes -
From Governor's Office OfHce of Planning and Research subiect: Response to Request for Radiological Emergency Planning Data Attached are copies of documents prepared by OPR staff which may be relevant to PGSE's request for information on nuclear power plant emergency planning.
Attachment A is a 1980 legislative proposal which would have required low density development around nuclear power plants. Although approved by the Governor's Office the legislation was put on hold while NRC developed their low population zones.
However, the philosophy of appropriately zoning areas near nuclear facilities persists in OPR's second set of attachments, lettered B through E. These memos are concerned with the 1981 Office of Emergency Services (OES) Nuclear Power Plaat Emergency Response Plan. As you can see from these memos, we consistently
. raised a set of issues with OES on the safety of nuclear plants that have yet to be resolved. Our primary concerns center on impacts to human health from malfunctioning power plants or reactor accidents. .
We also concur with the Energy Commission, (see attachment B), in questioning the wisdom of designating local government'; as responsible for detennining'if and when to evacuate an area. However, since this authority has beeh placed with local officials, we feel it is necessary to expand and clarify factual infonnation in the Plan. Since knowledge about hazards to health is basic to making sound decisions regarding emergency procedures, we considered the Radiation and Hazards Section particularly important.
In addition to the attached papers, OPR staff met with OES on one occasion, and ~-
with Phil Greenberg on another. Notes from these meetings are not readily available. The meeting with OES (May 1981) was mainly a discussion of philo ----
sophical differences regarding the Plan. A subsequent meeting with Phil Greenberg (July 1951) was convened to attempt resolution of these differences.
Attachment E, a memo to Phil Greenberg and Peter Gleick, contains suggested language changes to the Plan which were requested by the Governor's Office.
Handwritten notes taken at these meeting and some background material on the legislative proposal (Attachment A) do exist. Retrieval would take cooperation of 4 or 5 OPR staff and at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. -
State of Califors:ia The Resources Agency of C:llfornia MOmDrQndum EXHIBIT H Ta : Byron S. Georgiou Date : SEP 151981 Legal Affairs Secretary to the Governor Governor's Office subiat Response to Request to State Capitol, First Floor Identify and Produce Sacramento, California 95814 Emergency Planning and Earthquake Data From : Department of Boating and Waterways The Department of Boating and Waterways possesses no documents of any type relating to radiological emergency planning, earthquake response or emergency planning for Diablo Canyon Nuclear Power Plant or cny other facilities, nor does this Department possess any documents relating to State, local, Federal, or utility emergency response plans within the State of California.
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State of C:llfornb Momorandum "S" I Ta Mr. Byron S. Georgiou Do
- September 15, 1981 Legal Affairs Secretary to the Governor Place : Sacrdmento State Capitol ,
Sacramento, CA 95814 Phone: 5-7126 From : Department of Food end Agriculture
Subject:
Request to Identify und ' Produce '
Emergency Planning and Earthquake Data At this time the Department of Food and Agriculture has no documents as requested in your memo of August 26.
We have contracted with Envirosphere to formulate a nuclear response plan for the Department; work on that plan has not ,
yet begun. Envirosphere is developing response plans for other state agencies and ours will be coordinated with them.
Richard E. Rominger Director SURNAME SO.IOe
5 tete of Californie Health and Welfare Agony MdmOrGndUm EXHIBIT J ,
T8 ' Byron Georgiou "' ' September 14, 1981 ,
Legal Affairs Secretary to the Governor ~
Governor's Office Office of the Director From : California Department of Aging Mi"t* Request to Identify and Produce Emergency Phnning and Earthquake Data' In response to your request of August 26, 1981:
- a. We will be fonvarding copies of the following information identified in your request:
- 1. The Department's internal emergency preparedness plan.
- 2. The most recent draft of the Department's requirements for emergency planning by its sub-grantees.
- 3. The Department's directive to its sub-grantees requiring emergency ,
planning resource data.
- 4. Responses from sub-grantees to Item 3 above.
- 5. Data sheets reflecting first-phase cataloguing of sub-grantee ~ resources.
- 6. Sumary sheets by geographic area of sub-grantee resources.
- 7. All inter- and intra-departmental correspondence and reports involving --
emergency planning. --
- 8. ' Drafts of site-location maps by sub-grantee geographic jurisdiction. -----
- b. All emergency planning activity rests with the' single staff person desig-nated as Emergency Preparedness Coordinator (EPC). All documentation resh with the EPC, who maintains single-point files.
One person (the EPC) will be required for the search, which will be completed by approximately September 21, 1981.
- c. The documents will not be available until Friday, October 9,1981, because of scheduling priorities for duplicating services.
. s*
. . s Byron Georgiou September 14,1981
- d. Document copying will cost $432.20, distributed as follows:
- 1) 4000 pages 0 .005 per xerox impression = $ 20.00
- 2) 4000 pages 0 $?.50 per 500 sheet ream = $ 20.00
- 3) Staff time (hours) = $392.20 a) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Office A*ssistant II fT) = $261.36 -
Salary, benefi ts , etc. = $10.89/hr.
b) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> - Staff Services Manager II = $130.84 ,
Salary, benefits , etc. = $32.71/hr.
TOTAL ESTIMATED COSTS $432.20
)
JANET J. LEVY Director O
e e
'Stcte f C2lifIrnia Department of Devel:pnantal Servic:s
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Mdmdrandum EXHIBIT K l
)
D ' Byron S. Georgiou Date i September 16, 1981 Legal Affairs Secretary I to the Governor subject : Request to Identify Governor's Office and Produce Emergency State Capitol Planning and Earthquake Data Telephone: ATSS(8)473-3131' Fr m ' Office of The Director (916)323-3131 This is in response to your memorandum of August 26, 1981, to all State Agencies, Departments, Boards and Commissions, requesting identification and production of emergency planning and earthquake data for Pacific Gas and Electric Company (FG&E).
In order to begin a search for the requested documents, the Department must first contact, by telephone, each of the nine state hospitals to determine what .
materials they have which are readily available. The next step would be to follow up the telephone request with a memorandum to each State hospital giving more specific details as to what P6&E defines as " documents" which relate in any way to radiological emergency planning or earthquake response or emergency planning, and/or
" documents" which relate in any way to State, local, Federal, or utility emergency response plans within the State of California. The Department of Developmental Services, Health and Safety Unit, has begun the process by collecting copies of Emergency Preparedness Plans for each of the nine State hospitals from the headquarters Health and Safety Unit files. All materials that are readily available -
at this time are enclosed. As some hospitals are currently working on revision of their Emergency Preparedness Plans, it is hoped that they can Le finalized within the next two months. .
I The approximate number of personnel required to accomplish the data search is 21.
The personnel assigned to the data search is as follows:
1 - Staff Services Manager II .._ .. - __.
1 - Management Services Technician (B)
~~- ' ~
9 - Herpital Health and Safei;y Coordinators 10 - Office Assistants II (Typing) l 21 l
The estimated time by which a search can be' completed and all documents provided is l two (2) months (10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week for 8 weeks x 21 staff = 1680 total man hours). .
The estimated costs of copying all documents (3,500 pages x 1.3c per page) is $45.50.
i Byrtti S. Georgiou The following estimate of salaries and administrative costs is based on each staff member participating in the search for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per month:
Hourly Hrs Per Total Staff Admin -
Personnel Salary
- Month Salary Benefits Supcort Total, Staff Svs Mgr II $ 17.42 x 40 = $696.80 + $201.48 + $166.23 =$ 1,064.51 Mgmt Svs Tech (B) 8.52 x 40 = 340.80 + 98.44 22.64 = 461.88 Hosp Health &
Safety Coordinator 13.61 x 40 = 544.40 + 157.32 + 36.18 = 6,641.10 Office Asst II (T) 6.37 x 40 = 254.80 + 73.83 + 16.98 = 3,456.10
- Based en 173.33 hour3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> months as provided in State Personnel Board $11,623.5e Rule 93.
In the event that it would take two full months to accomplish the search for data, tne total estimated cost for copying, salaries and administrative support would be
$23,292.68.
All subsequent " documents" relating to emergency planning and earthquake data will be forwarded to your office at the earliest possible date. Should you have any questions coacerning tnis matter, please contact Douglas G. Arnold, Deputy Director, Administration Division, 1600 Ninth Street, Third Floor Southeast, Sacramento, phone 445-6168.
Y c + ----
David E. Loberg, Ph.D. - - - . -. . . . - _ _ - -
Director _ _ __
Enclosures cc: Albert C. Brown Chief Deputy Director Douglas G. Arnold Deputy Director Administration Division .
Bamford Frankland
- Deputy Director ,
i Hospital Operations Divison l
l James K. Kahue, Chief j Personnel Management Branch Jose Romero, Chief Manpower Training, Safety Section
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> 5 tate cf gli.fornia Ccpirtment cf Health Servirts M o m o'r a n d u m ' -
Exn1Brr n To : Beverlee A. Myers Date : September 16, 1981 Director 8/1253 Subied: Request from Governor's
,. Office to Produce Emergency Planning and Earthquake Data e
From : Richard H. Koppes O Chief Counsel Office of Legal Services 8/1216 2-2784' Attached is a memorandum from Byron S. Georgiou, Legal Affairs Secretary to the Governor. He has stated in this memo that Pacific Gas & Electric (PG&E) has requested Governor Brown to produce certain relevant documents prior to the proceeding before the United States Nuclear Regulatory Commission to determine whether a full operating license should be granted for operation ,
of the Diablo Canyon Nuclear Power Plant. To enable the Governor's Office to respond to PG&E's request, Mr. Georgiou requests that we provide hin with all readily available documents'that fall within PG&E,'s request. As to those documents that are not readily available, he has requested that the Department provide s
by September 16, 1981, both a descriptien of the search that will have to be undertaken to produce such documents and a description of the time, commitment of staff and the costs associated with responding to this request.
You have asked the Office of Legal Services to coordinate the Department's response to this request. The fact that the memo was received by you on September 10th and by this office at the close of bysiness on September 11, 1981, has made it difficult to coordinate a full response to Mr. Georgiou's request. In an j
attempt to r spond fully, we have. conducted a search of this office's files and have discussed the request with Ellen Powell of the Office of Legislative Liason, Dr. William Nesbitt of the Disaster Medical Services Section and Joe Ward of the Radiologic Health Section.
Ellen Powell provided us with the attached copies of the files on SB 1183, SB 1184 and SB 1185, which were adopted in 1979, mandating the development of emergency plans for the San Onofre, Rancho Seco, and Diablo Canyon Nuclear Power Plants. Ellen ,
stated that these files contained all of her office's files covered by the PG&E request. .
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- Beverlee A. Myers -
' September 16, 1981 Bob Kunstel frcm the Disaster Medical Services Section has pro-vided all of that section's readily available documents encem-passed within the request. He has stated that a response to the request as to all other documents would necessitate a search of four file cabinets and two bookcases. He stated that such a search would requirs as l'ong as a person month. He further in-dicated that with a staff of four people, such a commitment of staff time would be difficult.
Ken Fess from the Radiologic Health Section has provided us with the attached nemo (Attachment 1) and. documents. In that memo he has outlined the scope of the search that would be required for
, that section to respond to this request.
I The search in our office revealed no documents that would be covered by the request. Marian King of my staff discussed with Wade Rose of the Governor's Office the unreasonableness of PG&E's definition of " documents." Mr. Rose stated that the Governor's Office is only interested in receiving " standardized documents."
They are not interested in receiving calendars, : appointment books, '
diaries and the like.
Please let me know if I can be of any furtLar assistance in this mat,te r.
RHK:MAK:pfb' Attachment ec: Ellen Powell OLL Joe Ward Radiologic Health Shction Dr. William Nesbitt Disaster Medical Services Section e
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State of C&liforni:2 Department cf Health Servic s Momorandum To : Marian King Date : September 16, 1981 Office of Legal Services OB8/1216
Subject:
Request for Emergency Planning and Earthquake Data Documentation.
From : Radiologic Health Se: ion 520 Capitol Mall, Roua 800 ,
3-2772 The following information relative to your request is provided herein:
- 1. The first draft of the Radiologic Health Section Emergency Operating Procedures, produced by Envirosphere, and comments thereof, are being copied and should be available by Wednesday noon. Other appropriate leteers and documents immediately available are enclosed herewith, i, We estimate there is approximately 13 cubic feet of filed material which needs to be sorted, reviewed, and copies made. The main areas include, but are not limited to:
a) comments and working papers on the Nuclear Power Plant study done by Science Applications Inc.,
b) ingestion planning zone development procedures and guidance papers, c) remote radiation detector systc::.s notes, correspondence and directives (1979 - SB1184),
d) RHS - Envirosphere correspondence regarding work on contract on operating procedures, e) RHS consnents to the OES on Utility, State and County planning documents, f) comments and notes on conduct of Emergency exercises and drills (San Onofre and Diablo Canyon).
We estimate the review will take a minimum of ten (10) dedicated person-days and, if 20% of material is germane, the cost for copying such material should appraximate
$550.00, and with high priority take two (2) days.
Since additional staff has not been provided for this effort, it will be necessary to divert two or more persons from current projects. The immediate result will be:
a) we will be unable to participatb in the interagency support revhw meeting with the U.S. Department of Energy on September 22nd for needed aderal technical support of emergency actions, b) we will forgo reviewing preliminary dr fts of the four-county emergency plans for a Rancho Seco accident, and be unprepared for discussions on this matter on September 23rd,
~
. s s Marian King September 16, 1981 c) we will delay needed calibrations of our emergency kit instruments, i
d) the formulation of transportation studies on nuclear packaging, storage and i surveillance will be postponed again, e) if the work extendt into October, our replacement of dosimeters around nuclear power plants will iu later than specified by our contract with NRC.
3 We have verified with OES that they will respond to subject request by providing copies of State, County, Utility emergency response plans and correspondence with the Federal Emergency Management Agency (FEMA) regarding recent nuclear power plant drills and exercises. The Office of Emergency Services (OES) has also emergency planning documents involving the U.S. Navy and local municipalities such as San Diego and the four county region about Mare Island Naval Shipyard.
- 4. Verifying our agreement we will not furnish the Pacific Gas and Electric Company (PG&E) originate 2 documents such as Final Safety Reports, Emergency plans, Hosgri Seismic Evaluations, etc. These reports occupy about eleven (11) feet of shelf spaCS,
- 5. We also have on file safety and emergency planning reports from the Southern California Edison Company - San Onofre Nuclear Generating Station (SONGS) and from the Sacramento Municipal Utility District - Rancho Seco Nuclear Generating Station (RSNGS). This material is similar in scope with that of PG&E identified in paragraph 4 above. The amount of shelf space involved is thirteen (13) feet and seven (7) feet respectively. We suggest that should these documents are needed, they may be obtained from the Utility's document room or the U.S. Nuclear Regulatory Coamission (USNRC), and not by local reproda'*,; ion. If desired we will identify the appropriate ' volumes.
, 6. There are many Federal reports, directives, and guides concerning emergency l planning, the Three Mile Island (THI) coniequences, system and component upgrading, j and the Diablo Canyon Environment:1 statements all available as public documents.
l The Federal anergency Management Agency (FEMA) has published documents on emergency i planning and monitoring which are also in the public domain. I believe, we agreed l we do not need to provide these items.
l d4 f
nneth B. Fess Senior Health Physicist Enclosures l
, _ - .,.-__-_._-,..m_-.-_-.-_,_m,..-,, ,,._,_m. ,. ,__ ,...e m,,,.,f._. , _ , , _ , . , , , _ , , , , . _ . _ ~ . . , . _ _ _..-m-m,, , _ . , _ _ ,
( 4 State cf California Business, Transportation and Housing Agency MOmorandUm EXHIBIT M TO Byron S. Georgiou cate .
September 16, 1981 Legal Affairs Secretary to the Governor .
File No.
- 1.3909.A5002 Subject :
REQUEST TO IDENTIFY AND PRODUCE EMERGENCY PLANNING AND EARTHQUAKE DATA Fr::n : Department of California Highway Patrol Office of the Commissioner * ,
The packages that are accompanying this memorandum represent all readily available documents falling within the purview of the pacific Gas and Electric Company's request. They have been obtained from cach of our area offices throughout the state, each headquarter's unit and each subdivision of our organizatier. that is in any way involved with this type of planning.
The total number of pages provided is 12,648, which have been j.
reproduced at a cost of $157.50. The administrative cost to obtain' these documents is estimated to be $11,329.24.
In order to provide copies of the remaining documents as identified in your memorandum, we estimate that it would require 2,432 hours0.005 days <br />0.12 hours <br />7.142857e-4 weeks <br />1.64376e-4 months <br /> of staff time, including administrative and supervisory time, for a cost of $49,304.84. The estimated cost of reproducing the additional 164,904 documents requested would be approximately $2,061.25.
Please be advised that every document that has been provided thus far contains material that is protected from release by one or more state and/or federal statutes. In accordance with the direction --
received from Mr. phillip Greenberg, no attempt has been made to ~'~-~ -~
specifically identify the protected pages. ._
G. . CRA
- j. W Attachments .
4
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Sto*O.or california The Resources Ag:ncy Momorandum s m SIT n To Byren S. Georgiou case : September 17, 1981 Legal Affairs Secretary to the Governor From i Department of Fish and Game ,,
subject: Request to Identify and' Produce Documents on Emergency Planning and Earthquake Response Plans The information requested in your remorandun of August 26, 1981, is provided below. Because nf che unusually broad nature of PG&E's request, the personnel requirements and costs listed below are best estimates, and are subject to refinement as our search for the requested documents proceeds.
(a) A description of the steps that your agency is taking and will need to take in order to search for the requested documents.
The Department will have to utilize temporary help, '
as well as a large number of perranent emplovees to search our files, libraries, and the personal papers l
of employees in each office throughout the State. _ _ _ _ . _ _.
l A coordinator will be assigned the task # overseeinF _ . . . .
the statewide effort and assurinF the tirely completion I
of the document search and reproduction. -
l
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l (b) The number of personnel in your agency required to -
accomplish the foregoing search.
Over 400 Departme'nt employees will be invc1ved in j some manner during the acquisition and reproduction of the requested documents.
(c) The estimated time by v/ntch such search can be accomplished and all documents provided to me.
It will take about six months to accomplish the search, reproduce the documents, and provide then to you.
o "i' ~kyronS. Georgian .
-e - -
l (d) An esticate of the direct costs of copying all such documents and an estimate of the salaries and administrative costs associated with the cerformance of these tasks by the persons assigned to pe' rform them.
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Direct Copying Costs S 7,500 Personnel & Administrative Costs 125.000 Total Costs #132,500 .
Please contact us if you have any cuestions regarding these estimates.
1 .
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Director i ()i e
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. Stat % ef C nia The Resources Ag:ncy HAND DELIVERED M'o m o r a n d u m ExaIs1T o .
To i honorable Byron 5. Georgiou Date September 16, 1981 Legal Affairs Secretary to the Governor Governor's Office A1 State Capitol Sacramento, CA 95814 Telephone: ATSS ( ) ,
( 445)3976 s .
Fr:m : Departrnent of Forestry subject 71N COOPERATIVE FIRE PROTECTION '
T110 Lccal Government Protection Proiram J Diablo Canyon Nuclear Power Plant (PG&E)
Delivered with this memorandum are all of the documents within the scope of PG&E's request to identify and produce emergency planning and earthquake data in connection with the full power operating license proceedings on the Diablo Canyon Nuclear Power Plant before the NRC.
Attached to this r.emorandum is a report from this department's Region V office in Monterey, which includes the San Luis Obispo Ranger Unit.where the power plant is situated.
In addition to the document search and copying described in the Region V memorandum, we searched the only two files existing in Sacramento Headquarters, my personal file and the file of the Deputy Director for Fire Protection and Technical Service.s. The documents delivered with this memorandum include copies of all documents from those two files which were not duplicated in the papers transmitted from Region V.
I believe that we have made a' diligent search both here in"Headqua~rters ~ ~
and in the field and that this department possesses no other documents i
within the scope of PG&E's discovery request. .- , .
~
Finally, attached is a statement respecting costs incurred in comply-ing with this request at the Headquarters level, which supplements the statement of costs contained in the attached Region V memorandum of September lith.
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DAVID E. PESONEN -
Director l
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Attachments
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St:td gf calittrnis * "'" "Y i
M,o m o r a n d u m -
To : David E. Pesonen, Director Date :
Se tombe II, 1981 5AA fiu :.+d From : Department of Forestry . Region V '
gj4 stbiect i 7100 COOPERAT,y( riRE PROTECTJON ' ' ' ~ ' ' " '" 7 7110 Local Government Protection Program . -
Diablo Canyon Nuclear Power Plant (PG&E)
Reference is made to your memorandum of September 4, 1981, requesting that we provide copies of all documents related to emergency response planning as described in Legal Affairs Secretary to the Governor Byron S. Georgiou's memo dated August 26 to oli stata agencies, departments, boards and commissions.
'By special courier, we are delivering sll of the available documents related to emergency response planning which fall within PG&E's request in order to meet your deadline of September 14, 1981.
With reference to item 2 at the bottom of page 2 in Secretary Georgiou's memo, the following is intended to answer the spec; 5ir: questions asked.
(a) The Region directed the ranger units to make a search of their files and provide photocopies of all documents related to amergency planning described in items I and 2 on page I of Secretary Georgiou's memo of August 26. A copy of that memo was provided to each rangen unit in order that they would have ,
the benefit of the total request, including the definition of
" documents." Their photocopies were requested to be delivered to the Reglon Office by 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on September iI, in order - - ~~
that they could be combined and forwarded with the Region Office - ---
documents to meet the September 14 dead!Ine for delivery to the Director's office. Concurrently with the ranger units' efforts, - -- -- -
the Region headquarters files were also searched for emergency response planning documents. Only those that did not duplicate the documents supplied by the ranger units were photocopied to avoid dupilcation. All documents were then combined in a single package for delivery to the Director.
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.. d Mr. Pesonen September 11, 1981 (b,c & d) Tre follow'?g table provides the answers for items b, c and d as it rc s to the number of Region V personnel, esti-mated time required for the project and the estimated costs for salaries to do the job.
In addition to the above, the estimated direct cost for photocepy paper is: 3 reams a $2.65 = $7.95 Total
- Hourly -
No. Classification Hou rs Rate Total Cost i State For. Rgr.111 4 518.76 5 75.04" 4 Stara For. Rgr. !! 8 17.00 136.00 i State For. Rgr. I 2 15.45 30.90 i Fire Prev. Ofer. I i 15.45 15.45 i Secretary 1 7.92 7.92 4 Stenographer, Range B 36 6.98 251.28 i Office Asst. Il l 6.86 6.86
_ l, Dispatcher / Clerk _j[ 7.75 15.50 14 55 5538.95 JOHN H. HASTINGS
, Chief
/ / W By'c,hard RI H. Bawcom .
Assistant Chief l .. . .. ..... .
cc: w/ documents 1
o e
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.- . db lDENTIFICATION AND PRODUCTION OF EMERGENCY PLANNING AND EARTHQUAKE DATA lN RESPONSE TO REQUEST OF BYRON S. GEORGh0U, AUGUs? 24, 1981 Est* mate of the time to search and duplicate files of David E. Pesonen. Director, Decartment of Forestry:
.. Total Hourly No. Classification Hours Rate Total Cost 1 Administrative Assistant i 2 $10.79 $ 21.58 1 Office Asst, 11, Typing 3 6.37 19.11 2 5 40.69 In addition to the above, the estimated direct cost for photocopy paper is:
1-1/2 reams e $4.50 = $6.75 Region V Headauarters and Ranger Unit Offices, Department of Forestry:
1 State Forest Ranger Ill .
$18.76 $ 75.04 4 State Forest Ranger 11 8 17.00 136.00 i State Forest Ranger I 2 15.45 30 90 1 Fire Prevention Offle.er I 1 15.45 15.45 1 Secreta:y 1 7.92 7.92 4 Stenographer, Range B 36 6.38 251.28 1 Off'.ce Assistant it ! 6.26 6.86 l 1 Dispatcher / Clerk 2 7.75 - ?5.50 i 14 55 $33I.95 l
In addition to the above, the estimated direct cost for photocopy paper is':
3 reams G $2.65 = $7.95
eef emega eMm mm e em-m ew&
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" , State of Californio Health and Welfore Agency M o svi o r a si d u rii EXHIDIT P Ta Mr. Bryen S. Georgiou dan : Septembe.r 18, 1981 Legal Affairs Secretary to the Governor State Capitol, First Floor
Subject:
Your request to identify Sacramento, CA 95814 and ' produce emergency planning and earthquake ,
data (August 26, 1981) via Mario G. Obledo, Secretary' Health and Welfare Agency f _[/
Frrm : Department of Soshi Services In reference to the above requested mater' the only such material presently in our files and which is related directl, - the responsibilities of this Department, is a copy of ti,a San Luis Obispo County Social Services Department's Standard Operating Procedures for Nuclear Power Platt Emergency P.e*,ponse, datei March 1977, and a copy cf the San Luis Obispo County Social Services Depart-ment Standard Operating Procedures (Emergency Welfate Services Annex to the county's emergency response plan).
All other material relative to your inquiry, is naintained 5y the Office of Emergency Services, and is held by that agency.
The State Department of Social Services is presently workirc on an emergency l
response plan which is still under administrative review, and not in final form.
Such, however, will be forwarded at your request.
hb -
(rt, " r l
MARION J. UOODS l Director Enclosures ,
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EXHIBIT Q v
cfM* l fqgy,y EMERGENCY MEDICAL SERVICES AUTHORITY l
-M4 0 STATE OF CALIFORNIA l
'Y ,, 4p N _
[' ROGER S. TAYLOR, MD, MPA - DIRECTOR EDMUND G. BROWN JR. GOVERNOR MARIO G. OBLEDo, SECRETARY <
HEALTil AND WELFARE AGENCY TO: Byron S. Georgiou Date: September 15, 1981 Legal Affairs Secretary to the Governor VIA: Roger Taylor, M.D.
l h/y' ~
Emergency Medical Services Authority FROM: Calvin Freeman ;
Disaster Medical Services Section
SUBJECT:
Production of Emergency Planning & Earthquake Data This memorandum is in response to your request IOr procedcJe and cost information concerning the provision ci emergency planning and earthquake data. Enclosed please find material which is readily available. We bove cuecked with the Radiological Health Section of the Departme. 'f Health Services and they will provide you with a copy of the DUS Response Plan for Nuclear Power Plant Emergancies.
The Dicaster Medical Services Section possesses an enormous amount of ma.erial_,
provision of which would create a prohibitive workload for the four staff bi the Section. Specifically, the information requested is contair.ed in sixteen file drawers and on fifteen bookcase shelves. Our conservative estimate is that collecting, sorting, and refiling all the information requested would require about one person-month to complete. Duplication costs would be in the neighborhood of $50,000.
The Section's files are open, however, and staff would be available to assist anyone sith authorization to locate relevant information.
I' ;Ju hece any questions or require additional information please contact me at 2-2300.
CF/sl cc: Kathleer Acree, M.D.
William R. Nesbitt, M.D.
Enc.
1600 - 9TH iTREET. ROOM 443
- SACRAMENTO, CALIFORNIA 95814 * (916) 322-4336
Staee cf hiifornia Tha Resources Agency cf Cilif:rnia
' EXHIBIT R MOmorandUm Date : SEP 1 '? 1981 Ta : Byron S. Georgiou Legal Affairs Secretary to the Governor Governor's Office ,
State Capitol Sacramento, CA -
From : Department of Parks ano .hrescion
Subject:
Request to Identify and Produce , '
Emergency Planning and Earthquake Data Memorandum dated August 26, 1981 AJ per your request r1 search far, identify and produce in Sacramento all documents, charts, e' 2 dies, photographs, plans, etc., that address preparedness to take emergency actions where an earthquake complicates emergency response, we offer the following.
We will notify all park Regional Offices and park Area Offices to search for and provide the requested documents. As many as une hundred personnel will spend some work time searching, identifying and transporting documents to Sacramento. Totally this will amount to 20 persen/ days and the work should be completed within eeven working days. Our estimate of park emergency plans may equal five cubic feet and other phot g raphs, letters, memorandums, studies, etc., may equal one to two cubic feet, Cost $2,500.00.
We trust this will be helpful.
f f' t
/ I race David Jackson, Ph.D.
Chief Deputy Direntcr
O ' A' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power Plant, )
Units 1 and 2) )
)
CERTIFICATE OF SER'11CE I hereby certify that copies of " RESPONSE OF GOVERNOR EDMUND G. BROWN JR. TO PACIFIC GAS AND ELECTRIC COMPANY DOCUMENT PRODUCTION REQUEST DATED AUGUST 18, 1981" in the above-mentioned proceeding have been served to the following on September 22, 1981 by U.S. mail, first class.
Mr. Thomas Moore, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. W. Reed Johnson Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555
'Ur . John H. Buck Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman Atomic Safety and Licensing Appeal Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555
4 .. dk John F. Wolf, Esq., Chairman Atomic Safety and Licensing Bosrd U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr . Je rry R. Kline Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 William J. Olmstead, Esq.
Edward G. Ke tchen, Esq.
Lucinda Low Swartz, Esq.
Of fice of Executive Legal Director BETH 042 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 jyffENTION: Docke ting and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E. Kerr, Esq.
Public Utilities Commission 5246 State Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Beach, CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 Mr. Gordon Silver Mrs. Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401 4
g .m John Phillips, Esq.
Center for Law in the Public Interest 10203 Santa Monica Drive Los Angeles, CA 90067 Bruce Norton, Esq.
Norton, Burke, Berry & JuncF.
3216 North Third Street - Suite 300 Phoenix, Arizona 85012 Philip A. Crane, Jr., Esq.
Richard F. Locke , Esq.
F. Ronald Laupheimer, Esq.
Pacific Gas and Electric Company 1050 17th Street, N.W.
Suite 1180 Washington, D. C. 20036 David S. Fleischaker, Esq.
P.O. Box 1178 Oklahoma City, Oklahoma 73101 Arthur C. Gehr, Esq.
Snell & Wilmer 3100 Valley Bank Center Phoenix, Arizo ia 85073 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamiltot: Avenue - Suite K ,
San Jose, CA 95125 i Mr. Carl Neiberger Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Byron S. Georgiou, Esq.
Legal Affairs Secretary
. Governor's Of fice State Capitol Sacramento, CA 95814 ,,
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Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washington, D. C. 20036 September 22, 1981
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