ML17083A859

Affidavit Re Facility Emergency Response Plans.Refresher Training Not Included as Part of Annual Facility Tour by Dept of Forestry.Forestry Personnel Receive Inadequate Training

ML17083A859
Person / Time
Site:	Diablo Canyon
Issue date:	04/17/1981
From:	Paulus R CALIFORNIA, STATE OF
To:
Shared Package
ML16340B670	List: ML16340B669 ML16340B671 ML16340B672 ML16340B674 ML16340B675 ML16340B676 ML16340B677 ML16340B678 ML16340B679 ML16340B680 ML17083A858 ML17083A859 ML17083A860 ML17083A861 ML17083A862 ML17083A863 ML20003G997
References
ISSUANCES-OL, NUDOCS 8105040484
Download: ML17083A859 (22)

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UNITED STATES OF Ah&RICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

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

) 50-323 O.L.

(Diablo Canyon Nuclear Power Plant, )

Units 1 and 2) )

)

Affidavit of Robert E. Paulus I, Robert E. Paulus, being duly sworn, state under oath the .following:

(1) I am Deputy Director of the California Department of Forestry (CDF) for Fire Protection and Technical Servi'ces.

I am responsible to the Director of the Department with respect to all matters bearing upon fire control opera-tions, training, manpower and supply for CDF's statewide fire control operations and all other emergency response operations. I have been employed by CDF in fire control and fire training positions for 27 years. I reside at 4528 Onyx Way, Carmichael, California.

(2) The Department of Forestry is a statewide wildland and rural fire protection organization which also engages, pursuant to contracts with local governments, in fire protection of structures, industrial facilities, and airports at various locations throughout the state. CDF maintains its own forces and supervises a large number of volunteer fire companies. CDF's own forces consist of approximately 3,000 permanent employees, nearly 2,000 seasonal fire fighters, 354 fire engines (augmented by 371 engines owned by local governments and operated by CDF), 55 bulldozers, approximately 600 other miscellaneous vehicles, and 17 air tankers.

(3) On April 16, 1981 I toured PG&E's Diablo Canyon nuclear facility in the company of the plant manager and certain of his staff, the Director of the Department of Forestry, the Chief of the San Luis Obispo City Fire Department, CDF's Regional .Chief for the South Coast Region, the Director of the California Office of Emergency Services and his Chief Deputy, along with certain other staff persons of the Department of Forestry. The tour included F f OSQQgi-F W 7 pP~

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C an extensive meeting with the plant manager concerning the degree o f planning, training and equipping o f CDF personnel who may be called to respond at the plant, pursuant to the letter of understanding, referred to in paragraph 4 below. The visit to the CDF administeredtourfire was preceded by a stations't the San Luis Obispo Airport and the Nipomo Forest Fire Station; including interviews with the personnel stationed at these facilities.

(4) I have reviewed the Emergency Plan (revision 2) dated February 1980 for the Diablo Canyon nuclear power plant standingg units 1 and 2 prepared by Pacific Gas and Electric Company; I am also familiar with the letter of under-dated February 13, 19 79 from T. J. Waddel1, CDF Ranger-in-Charge of the San Luis Obispo Ranger Unit, addressed to the late Nr. R. D. Ramsay, Plant Superin-tendent, which letter is appended to the aforementioned emergency plan. A true copy of the letter of under-standing is attached hereto as Exhibit "A."

I am familiar with the facilities, manpower and equipment at various CDF stations throughout'San Luis Obispo County that may be called upon to respond to emergencies at the Diablo Canyon nuclear power plant pursuant to the afore-mentioned emergency plan and letter of understanding.

(6) can state of my own knowledge that (contrary to the assertion in paragraph 8. 1. 2. 2 (d) of the aforementioned emergency plan) that "refresher training and radiation protection practices and procedures is..." not included as part of an annual tour of the Diablo Canyon facility and its fire suppression equipment by Department of Forestry personnel. I can further state of my own knowledge that the pattern of twice-yearly fire drills and annual walk-through tours for CDF personnel, pro-vided for in said plan, has not occurred in any regular way but has been sporadic and has failed to include significant numbers of CDF personnel who may be called upon to respond to in-plant emergencies.

(7) CDF personnel in San Luis Obispo County have received no detailed training on necessary techniques in or equipment for responding to an in-plant fire or emer-gency medical incident at Diablo Canyon, nor have they received training concerning fire fighting in an emergency which potentially includes radiation hazards.

Because of this lack of training, the Department, con-trary to the letter, agreement, could not utilize the most effective fire suppression methods which might otherwise be available.

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(8) The stations administered by the Department of Fore'stry which are. most likely to be called upon to respond to emergencies at the Diablo Canyon nuclear power plant pursuant to the aforementioned letter of agreement are located at the San Luis Obispo County Airport and at the Nipomo Forest Fire Station in the town of Nipomo. Zn major emergencies certain other facilities throughout the county may also be called upon to respond. Xn addi-tion, certain volunteer companies who are under the command of the Department of Forestry may be called upon to respond to emergencies at the plant. The three most likely facilities and the equipment available to them, along .with response times are as follows:

(a) Avila Beach Station at a distance of 12 miles with a 15-minute response time; 'this is an entirely volunteer fire company equip'ped to respond with a 500 gallon per minute pumper.

(b) Nipomo Station at, a distance of 26 miles from the plant with a 40-minute response time. There is one full-time CDF Captain on duty at all times, aug-mented by a volunteer fire company equipped to respond with a 750 gallon per minute pumper.

(c) Edna Valley/Airport Station 18 miles from the plant with a 30-minute response time. There is one full-time CDF Captain on duty at all times, augmented by a volunteer fire company equipped to respond with a 750 gallon per minute pumper.

(9) While the fire fighters in CDF's system responsible for operating the aforementioned stations are aware that they may be called upon to respond to emergencies at, the plant:,

all of those with whom the matter was discussed on April 16 agreed that they had not received any significant training- to prepare them for fire suppression responsibil-ities in the event of simultaneous radiation exposure or risk thereof at the plant.

(10) On April 14, 1981 Ranger-in-Charge T. J. Waddell solicited attendance by other chiefs of fire departments within,San Luis Obispo County to attend a meeting scheduled for Hay 14, 1981 to B.scuss possible approaches to a training and equipment plan connected with any response to emer-gencies at the Diablo Canyon nuclear power plant. I am not able at this time to estimate how much time must elapse before CDF personnel are adequately trained and equipped to respond to in-plant emergencies.

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(11) As a result of the tour on April 16th and the information developed at that time, Ranger Waddell has notified PC&E that the letter of understanding dated February 13, 1979 been abrogated and is no longer in effe'ct. A true 'as copy of the letter transmitting such notice is attached hereto as Appendix "B."

(12) Ranger Waddell ' notice also informed PG&E ' plant manager CDF's wish to proceed as expeditiously as circumstances

'f will permit to develop and carry out planning and training which will permit CDF personnel to safely respond to in-plant emergencies.

ober E. Paulus Subscribed and sworn to before me this ~day oe i

1981.

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~ ADEl AfDE V GRU88S Ny commission expires: NOTARY PUBLIC SRCRAYBIf0 "OUIIB CALIF0o'IIA My Commissiorr Expires Oecember 22. I983

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~rlRA RESOURCES AGENCY EXHIBIT A EOMUNO G. BROWN JR., Gorere~

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>CD OF FORESTRY c.O. Box 151, Hwy 1, H.

<.~an Luis Obispo, CA. 93406 805-543-4244 February 13, 1979 7100'OOPERATIVE r IR" PROTECTION 7150 mutual Aid Diablo Canyon Power Plant (PGGZ)

Pacific Gas & Electric Company Diablo Canyon Power Plant P.O. Box 56 Avila Beach, California 93424

.Attention: ~1r. R.D. Ramsay, Plant Superintended 4r Dear Mr. Ramsay=

This letter of understand"ng superc des our letter of February 1, 1978.

As discussed with your representative, this Department approves of and

.agrees to the following procedures.

1. To provide fire suppression support for, grassland fires and/or in plant f'res and e.-;.e -g. ncy medical inciden+s at Diablo Canyon.

To participate 'in a fire 'drill on a se~i.'i-annual bas:s.

3. To make designated members of the Deo'art.;.ent available for bas'c training in radiat'on protect'o". to be presented by P.G. E.

personn l. G

4. That Depa=t; ent personn 1, when called to assist in fire sup-pression, have the authority and responsibility to determ'ne and utilize the most effective fire suppression methods, providing, that th se methods do not adversely affec nuclea'r safety or he possible health and saf ty of the public.

5. That PG~~E will, when asking for assistance, .advise the Department if the potential for radiation exposure and/or contamination exists.

6. That, when tho potential for rad'a+ion exposure and/or contaminat-ion exists, PGG will provide dosimeters for Department personnel and w'l provide a tra'ed monitor to accompany Departm=nt person-nel to advise and 'nsure that Forestry personnel are not unnece"-

sarily exposed.

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7. That PGSE wi 1, at the conclusion of any monitor Department personae> and equ'pment for contamination and fire suppression activi ty, perform any c.econtamination work required.

8. That PG&E will replace any equipment tpat cannot be satisfactorily decont urinated.

SincE e>

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1 RESUME OF ROBERT E. PAULUS DATE 1/80 to Present DEPUTY DIRECTOR FOR FIRE PROTECTION AND TECHNICAL SERVICES Responsible to the Director for all aspects of Department of Forestry's Fire Protection Program.

5/75 to 1/80 STATE FOREST RANGER IV Ranger-in-Charge of the Butte Ranger Unit. Responsible for the total administration and direction of the unit, which consists of all Department of Forestry activities, including contractual fire protection. Via a contractual arrangement, served as the Chief of the Butte County Fire Department.

7/71 to 5/75 STATE FOREST RANGER III Ranger-in-Charge of the California Department of Forestry Fire Academy. Responsible for total administration and direction of the Academy training program accomplished through the directing and coordinating of an administrative staff consisting of a State Forest Ranger II and seven State Forest Rangers I.

Effective February 1, 1973, assigned additional program responsi-bilities as the Department of Forestry In-Service Training Officer.

Responsible for the development, coordination, and evaluation of all Department in-service training programs.

11/68 to 7/71 STATE FOREST RANGER II Under the direction of a State Forest Ranger III assigned as the Director of Training at the Department of Forestry Fire Academy.

Primary duties included the direct supervision of four State Forest Rangers I assigned to the Academy as instructors. Evaluation and adjusting the training program to ensure an accurate and meaningful training program. Evaluated student progress, counseled students, and coordinated with ranger unit supervisors relative to personnel matters with probationary employees. Other duties as assigned.

7/64 to ll/68 STATE FOREST RANGER I Under the direction of a State Forest Ranger II administered a Ranger District comprised of three forest fire stations, one county fire station, and one forest fire lookout, in a geographical sub-unit which covered 319,000 acres of State responsibility lands and 80,000 acres of local government responsibility area.

7/54 to 7/64 Promoted;=through various levels of the Department's fire supres-sion program, including Fire Fighter, Fire Apparatus Engineer, and Fire Captain.

4/22/81

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 O.L.

) 50-323 O.L.

(Diablo Canyon Nuclear Power Plant, )

Units 1 and 2) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of the "GOVERNOR EDMUND G.

BROWN JR. SUBMISSION OF PREPARED TESTIMONY" in the above-captioned proceeding have been served on the following on May 8, 1981, as follows:

Richard S. Salzman, Esq., Chairman **

Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. W. Reed Johnson **

Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. John H. Buck **

Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman **

Atomic Safety and Licensing Board Panel 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 John F. Wolf, Esq., Chairman

• Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555-

2 ~

Mr. Glenn O. Bright

• Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Jerry R. Kline

• Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 William J. Olmstead, Esq. **

Edward G. Ketchen, Esq. **

Lucinda Low Swartz, Esq.

• Office of Executive Legal Director BETH 042 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Secretary **

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Docketing and Service Section Mrs. Elizabeth Apfelberg **

c/o Nancy Culver 192 Luneta Drive San Luis Obispo, 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, Ines 4623 More Mesa Drive Santa Barbara, CA 93105 Mr. Gordon Silver **

Mrs. Sandra A. Silver **

1760 Alisal Street San Luis Obispo, CA 93401 P

John Phillips, Esq. **

Center for Law in the Public Interest 10203 Santa Monica Drive Los Angeles, CA 90067 Bruce Norton, Esq. **~

Norton, Burke, Berry & Junck 3216 North Third Street Suite 300 Phoenix, Arizona 85012

I f(

Philip A. Crane, Jr., Esq. **

Pacific Gas and Electric Company P. O. Box 7442 San Francisco, CA 94106 David S. Fleischaker, Esq. **

1735 Eye Street, N. W. Suite 709 Washington, D. C. 20006 Arthur C. Gehr, Esp. **

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

MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95'125 Mr. Carl Neiberger **

Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Byron S. Georgiou, Esq. **

Legal Affairs Secretary Governor's Office State Capitol Sacramento, CA 95814 Herbert. H. Brown HILL CHRISTOPHER g AND PHILLIPS g P ~ C ~

1900 M Street, N. W.

Washington, D. C. 20036 May 8, 1981

• By messenger 4+> Bq express ~it first-class By U.S. mail,

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