ML13155A062
| ML13155A062 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/15/2013 |
| From: | Iwane C - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch, NRC/Chairman, NRC/OCM |
| References | |
| 78FR22576 00557, NRC-2013-0070 | |
| Download: ML13155A062 (5) | |
Text
Joosten, Sandy From:
Sent:
To:
cathy iwane [cathyiwane@yahoo.com]
Wednesday, May 15, 2013 3:31 PM CHAIRMAN Resource; CMRMAGWOOD Resource; CMRAPOS KIS CMRSVINICKI Resource; CMROSTENDORFF Resource T
San Diego OES response letter to me about NRC
,,.)
Rescwe; 110
Subject:
CD rn C/D
Dear Mrs. Iwane,
.-7 Thank you for your email dated April 2, 2013.
Mate hearing your personal perspective as a mother of young children who experienced the Fukushima Daiichi nuclear disaster first hand.
Much of your information talks to actions and decisions taken or not taken by the Japanese government and by the Tokyo Electric Power Company. I am not in a position to comment on those actions and decisions. What I can do is assure you that we in the San Diego County Office of Emergency Services (OES) understand our responsibility in planning for an emergency at the San Onofre Nuclear Generating Station (SONGS). It is a responsibility we take quite seriously.
Our planning effort is based on federal regulations (10 CFR Part 50) established by the Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency (FEMA). We at the local level are required to conform to those regulations. Accordingly, we have a ten mile Emergency Planning Zone (EPZ), a 20 mile Public Education Zone and a 50 mile Ingestion Pathway Zone.
Federal regulations require that offsite jurisdictions are able to take protective actions to safeguard the people living and/or working within the 10 mile EPZ. Those protective actions can be to shelter in place or evacuate. The recommended action depends on many variables, such as the duration of the release, wind direction, etc. The objective in any protective action is to prevent, or if that were not possible, to limit radiation exposure to residents. Our goal is always zero exposure.
I would like to provide a brief explanation of the process we use in determining which protective action to implement. First, Southern California Edison (SCE) is required to make a Protective Action Recommendation (PAR) based on the level of radiation detected. While that is occurring, San Diego County, Orange County and Marine Corps Base Camp Pendleton send radiation monitoring teams into areas around the plant to locate the plume and take soil and air samples to determine the extent of the release off plant grounds. That data, along with the data from the plant is provided to the Offsite Dose Assessment Center (ODAC). ODAC consists of the senior health physicists from both San Diego and Orange Counties, an Oceanside Fire Department Battalion Chief to run the field monitoring teams and a representative from SONGS. The data from the field and the data from the plant are analyzed by the health physicists and they either concur with the plant's recommendation or they provide one of their own. A decision is reached once all jurisdictions come together on a conference call to evaluate the Protective Action Recommendation from the plant as well as the recommendation from ODAC. We have never simply accepted the Protective Action Recommendation provided by the plant. Independent analysis and verification is built into our response planning and procedures.
SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= B. Benney (bjb) 1
In'additi6n to the planning we do specifically for SONGS, San Diego County has a multi-hazard regional Emergency Operations Plan. This covers the entire County and describes how we will evacuate populations at risk, shelter evacuees, provide emergency information to the public, conduct fire and law enforcement operations, among many other emergency management functions. This plan was used in the 2007 wildfires when we successfully evacuated over a half million people, including a large hospital and several skilled nursing facilities.
Another concern you addressed is that our plan has not been updated to include lessons learned from Fukushima. Many of the lessons learned will require regulatory changes on the part of NRC and FEMA. When federal regulations are changed, OES will be quick to implement the changes.,
Our SONGS Emergency Plan (the plan that provides the framework for our response) is updated every four years. In addition to our basic plan we have Inter-jurisdictional Policies (IPs) and local Standard Operating Procedures (SOP) that detail how we perform core functions, such as deployment of field monitoring teams, public information, coordination of offsite response activities, etc. These IPs and SOPs are updated whenever necessary. We just approved a new IP regarding equipment at our last Inter-jurisdictional Planning Committee meeting.
In regards to terrorism, it is true that our SONGS plan does not directly address it. It is addressed in our regional Emergency Operations Plan. You will find that very few, if any, local plans discuss terrorism response in any detail. This is to prevent potential terrorists from learning about our vulnerabilities and how we would respond to their actions. If they had knowledge of our response procedures they could devise ways to circumvent them.
Your next concern is the sheltering of children in their schools. In San Diego County there are no schools within the 10 mile EPZ. The one exception to this is a school on Camp Pendleton.
This school will follow the protective actions implemented by the base, in consultation with the school district. Schools within the 10 mile EPZ would be expected to be able to shelter in place.
Schools within the 20 mile Public Education Zone may also be requested to do so, depending on the circumstances of the emergency. There is no expectation of a need for sheltering outside of the 20 mile Public Education Zone. However, if circumstances arise and the Offsite Dose Assessment Center recommendation is to provide shelter outside the established planning zone, our sheltering plans are flexible and expandable. As far as schools' ability to act as a shelter, we use schools as shelters as a matter of course during emergencies because they are well equipped for such use.
At~the end of your email you asked that we consider the call for an adjudicated license amendment hearing.
The decision on that matter belongs, appropriately, to the regulatory agency, in this case the NRC.
I want to reiterate to you that the Office of Emergency Services takes its responsibilities very seriously. We are aware of the potential risks and consequences of a catastrophic event at SONGS and do not treat them lightly. Our focus is to ensure the San Diego region is always able to protect life, property and the environment during disasters.
Best regards, Tom Amabile, Sr. Emergency Services Coordinator Office of Emergency Services (858) 715-2203 (Voicemail) 2
(858) 565-3499 FAX 0
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x
Dear Commissioners,
Please find Mr. Amabile's response to my worried letter (sent to you just now) about the LACK of preparedness or lessons learned from Fukushima. He says he is waiting for YOU, the NRC and FEMA to make changes, before he can implement changes to San Diego's manual for Emergency Response in case of nuclear accident at SONGS. See his comments about this in yellow, below.
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This should be criminal and I will hold you all criminally responsible for negligence, should you restart SONGS and ANY harm comes to my children. We have ripped our lives and family from Japan, evacuating the nuclear meltdowns there, only to witness this nightmare unfolding 35 miles away from our present residence.
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