ML19323A923
| ML19323A923 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/02/1980 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| REF-10CFR9.7 NUDOCS 8005070095 | |
| Download: ML19323A923 (1) | |
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NUCLEAR REGULATORY ~ COMMISSION Smith g,p, g Re O g g d f p gm W ASHINGTON. D.C. 20555 8
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January 2, 1980 Haller j
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MEMORANDUM FOR:
Lee V. Gos-ick, Executive Director for Operations j
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Samuel J. Chilk, Secretar;s h h FROM:
SECY-79-656 - RESPONSE T0sGkJ RECOMMENDATIONS ON
SUBJECT:
RANCHO SECO EMERGENCY PREPAREDNESS (COMMISSIONER ACTION ITEM)
This is to advise you that the Commission (with all Commissioners concurring) has approved the proposed letter to Congress and response to the GA0 recomendations subject to the following modifications:
Commissioner Kennedy's comments:
1.
The letter should indicate that a proposed rule has been published for comment and a copy of the FRN should be included as an enclosure; 2.
The response to recommendation 1 should indicate that~the proposed rule now out for comment would require a joint
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Federal, State and local exercise at each plant on a periodic basis (e.g. every 3 or 5 years);
Commissioner Bradford's comments:
3.
Add to the second paragraph of the response to question / comment
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4.
The last sentence in the closing paragraph of the enclo:ure should be deleted.
The Staff is requested to prepare the revised letter and response for the Chairman's signature.
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oormat rs.1'esmhing astivity, is alee. respees,1es to the SAS receamondation,m hs Mi sente4ned in es4r Norsh 30,,1W9 reportitbet an emergency planning. aene.
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l NRC RESPONSES TO GAO REPORT
" EMERGENCY PREPAREDNESS AROUND THE RANCHO SECO NUCLEAR POWER PLANT:
l A CASE STUDY" The four recommendations directed to the Chairman, Nuclear Regulatory Comission and our responses follow.
1.
GA0 Recommendation
--Establish criteria for exercising emergency-response plans which realistically test their effectiveness. This might include requiring longer exercises with involvement from all emergency-response agencies and stipulating that periodic exercises be held at night and on weekends.
In developing this criteria, the Chairman should also consider the most appropriate method to defray increased costs incurred by State and local governments.
NRC Response NRC guidance for States and local governments indicates that annual exercises are required to maintain concurrence. This exercise must include mobilization of State and local personnel and resources adequate to verify the capability to respond to a given accident scenario. We are oeveloping scenarios which can be used for this purpose.
In addition, the proposed rule on emergency preparedness published for coment on December 19, 1979, would require a joint Federal, State, local and licensee exercise at each facility on a periodic basis (e.g., every 3 or 5 years).
Current exe cises are critiqued by a Regional Advisory Comittee composed of six federal agencies and cochaired by FEMA and the NRC. Standard forms have been developed for observers of these exercises. We, never-theless, agree that more specific criteria are desirable and have initiated efforts to develop these. Contractor assistance has been obtained and a preliminary work scope written. The effort will include specifying the characteristics of en appropriate scenario and exercise evaluation criteria. The final criteria to be used for evaluating emergency response plans will be developed with FEMA in accordcnce with the President's decision to have FEMA responsible for all offsite emergency planning.
With respect to funding, the NRC staff has recently published a report "Beyond Defense-in-Depth" (NUREG-0553) (copy encloses) which addresses the subject of funding State and local government radiological emergency response plans. The report was published for public comment on November 9,1979 and following this comment period, which expires December 31, 1979, we will be considering the recomendations made in it.
. 2.
GA0 Recommendation
--Require T.ht at least one member of the utility emergency-response team be assigned the sole responsibility of communicating with State and local emergency officials.
NRC Response The NRC staff has recently published for interim use and comment
" Action Level Guidelines", NUREG-0610. Four classes of action levels are defined. The two most serious classes specify that the licensee provide a dedicated individual for plant status updates to offsite authori ties. Other actions include requirements for establishment of a near-site Emergency Operations Center at which State and local officials would have designated representatives.
3.
GAO Recommendation
--Require the installation of the Atmospheric Release Advisory Capability conputer modeling system at Rancho Seco to enhance emergency planning and preparedness around that power plant and test the system for possible use nationwide.
l NRC Response The NRC staff has been evaluating the ARAC system for some time s ad has recently had discussions with the Departn.ent of Energy (D0E) for installing it as a pilot project at a comercial nuclear power facility. Gar Office of State Programs has proposed a phased, pilot installation of ARAC which would include equipment in two or three State emergency operations centers, replicate equipment at a reactor site and local government emergency operations centers in those States, and an installation at the NRC Operations Center.
This action would allow a greater ur. der-standing and evaluation of the technology and methodology associated with ARAC and would highlight any institutional or technological problems involved in the use of such a system. The staff intends that the first installation should be in New York State (Indian Point) followed closely by installations in Illinois (Zion) and California (Rancho Seco). We have requested funds in the FY-80 Supplement budget for this purpose.
4.
GA0 Recomendation
--Determine the feasibility and desirability of requiring installation of atmospheric release conputer modeling systems at nuclear power plants nationwide.
, NRC Response The pilot studies described in the response to item 3 above would be done for the purpose of determining the feasibility and desirability of the ARAC system.
Some atmospheric release computer modeling capa-bility now exists at certain facilities, although not as complex as the ARAC system. Whether ARAC or some singler system is ultimately chosen is, at this point, open but a requirement for some such system is likely. We favor moving ahead with a pilot study on ARAC because it is readily available from a National Laboratory.
In closing, we note that the GA0 found that, in the case of Rancho Seco
" emergency officials from each county appear well informed concerning their responsibilities during an accident, despite the absence of a formal plan in some Cases."
Federal Register / Vol. 44. No. Zoo / Tueadry. October 23. 1979 / Notices 81123 priate and prudent for emergsney NUREG-0396. EPA 520/1-78-018. dated a
December 1978. Single copies of the p
' guidance to take into report can be obtained by writing to the consideration the principal Director. Division of Technical characteristics (such as nuclides Information and Docr sent Control.
released and distances likely to be Nuclear Regulatory '.nmission.
Involved) of a spectrum of design basis Washington. DC 2a55. & task force and core melt accidents. While the report was published for public Commi==ian recognizes that the comment in the Federal Register on guidance may have significant response December 15.1978 and the comment impacts for many local lurisdictions, it penod was extended to May 15.1979 to beneves that implementation of the allow additional comments resulting guidance is nevetheless needed to from the accident at nree Mile Island.
Improve emergency response planninqr A synopsia of the comments received
- and preparedness around nuclear power and the task force consideration of these reactors.
comments is available from the N Commission is direction its staff Assistant Disector for Emergency to incorporate the planning basis Preparedness. Omca of State Programs, guidance into existing d~m==ats used U.S. Nuclear Regulatory Co===== nan, in the evalaation of stata anlocal Washington. DC 20555.
emergency response plans to the extant practicable.N NRC has recently Pt.nmne Basis published and. Advance Notice of The mefor recommendation of the Proposed R"1=== Mag concerning report is that two Emergency Planning additional regulations on emergency Zones (EPZs) should be established
. plans. 44 FR 41484. Tuesday. July 17 around light water nuclear power plants. 1979. Additional guidance will be The EPZ for airborne exposure has a provided following this rulemaking. This radius of about to miles: the EPZ for additional guidance can be expected to contaminated food has a radius of about consider how local conditions such as 50 miles. Predstermined protective demography land use, and meteorology action plans are needed for the EPZs.
can influence the size an shape of the b exact size and shape of each EPZ EPZs and to address other issues, such '
will be decided by emergency planning as evacuation planning.
ofhala after they consider the specific Specific implementation dates for full conditions at each sita. hse distances implementation of the taskforce are considered large enough to provide a recommendations and any others that response base which would support are developed will be established as activity outside the planmng zone part of the ongomg rulamaking effort.
Planning Basis for Emergency Responses to Nuclear Power Reactor should this ever be needed..
The Commission also expects the staff
.I Accidents.
He report also provides planning to assist state and local governments in basis guidance in the form of a range of improving their emergency responte Acancy: Nuclear Regulatory time values in which emergency capabilities at existing sites in the
. l Chsh response omchts should be prepared to immediata future.
l AcTiose NRC Policy Statement.
Implement protective action. b report Detad at Wasinagena. DA this teth day of indicatas that, depending on soch Purpose factom as the specific sequence of For the Nuclear @W-W This is a statement of policy with events dunng an accident which results regard to an Environmental Protection in the release of radioactivity to the 8"""' par.
Agency (EPA) and Nuclear Regulatory atmoshpere and the prevailing Secasaryo@ co-h Commission (NRC) task force report on meteorological conditions, protective-In o massa ru.s maan nes amt guidance for use in state and local action may be required from perhaps same cosa moms radiological emergency response plans one-half hour to one day after the l
st nuclear power plants.
latiation of the accident. Development and periodic testing of procedures for Backsmund
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The NRC remived a mquest from the response omczals is encouraged. sine
- Conference of Radiation Control the time available for action is strongly Program Directors, an organization of affected by the time consumed in State omcials, to "make a determination notification.
of the most servere accident besis for h chemical and physical which radiological emergency respanse characteristics of those radionuclides plans should be developed by offatta which contribute most significantly to agencies " to msponse. an EPA and NRC human exposure are presented.
task force.sas established which prepared a report entitled " Planning NRC Policy Basis for the Development of State and NRC concurs in and endorses for use local Government Radiologicut the guidance contained in the task forcer Emergency Response Plans in Support of report. In endorseg this guidan-the 1.ight Water Nuclear Ptriser Plants.
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i REPORT 3Y THE Comptroller General OF THE UNITED STATES Emergency Preparedness Around The Rancho Seco Nuclear Powerplant:
A Case Study At the request of Representative Robert T.
Matsui, GAO evaluated emergency prepared-ness around the Rancho Seco nuclear power-plant, located in California about halfway be-tween Sacramento and Stockton, and found that:
--State and county emergency plans have been developed based on Nuclear Regu-1 latory Commission criteria; however, these plans have only been tested on a 1
limited basis.
--Local authorities would need State and Federal assistance to handle a major nuclear emergency.
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--Local residents have not been period-ically informed of emergency evacua-tion procedures.
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--Given the worst possible accident, not all of the potentially affected counties would have adequate emergency plans.
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EMD-79-103 4cCOUNp O OBER 2,1979
8 COMPTROLLER GENERAL. Ofr THE UNITED STATES WASHIPMBTON. D.C.
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flatsui House of Representatives Lear Mr. Hatsui:
Your letter of April 24, 1979, asked us to review the emergency preparedness of localities surrounding the Rancho Seco nuclear powerplant near Sacramento, California.
To address your questions we reviewed nuclear emergency pre-paredness actions of the California Office of Emergency Services, Sacramento and San Joaquin counties, and the oper-atina utility--Sacramento Municipal Utility District.
We alsc discussed nuclear emergency preparedness with the emer-gency coordinator of Amador and Calaveras Counties.
- Finally, we reviewed Nuclear Regulatory Commission emergency prepared-ness requirements and evaluated Federal agency capabilities and preparedness to assist in the event of a nuclear accident at Rancho Seco.
Our evaluation of the issues you raised shows that:
--State and county emergency-response plans have been developed for Rancho Seco based on Nuclear Beaulatory Commiss n criteria; however, these plans have only been te=ted on a limited basis.
--State and local authorities appear to have adeauate coordination with respect to handling nuclear emer-gencies.
While local authorities are aware of their emergency response roles, they would need State and Federal assistance to handle a major nuclear emergency.
--Local residents have not been routinely inforned of evacuation procedures in the event of an emergency.
Several public meetings to discuss emergency plans were held following the Three Mile Island incident.
--Given the worst possible accident under the worst meteorological conditions, all potentially affected l
areas would not have adequate plans.
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B-164105 area for tnis accident woula incluae 44 counties in Calitornia ana several in Nevaca, with an affected population of over 8 million people.
These issues are discussec in more detail in appendix I.
In a recent report 1/ we recommenced tnat tne Nuclear Regulatory Commission revise its emergency preparedness regulations to (1) require full Feaeral, State, ano local government participation in annual emergency preparecness drills; (2) extend emergency planning zones around nuclear powerplants from 5 miles to 10 miles; and (3) require cnat people living near nuclear powerplants be inrormea or poten-tial hazaros and plannea emergency actions.
Tne Commission is now considering tnese recommenaations in tne context or a ma]or review of nuclear emergency planning and preparea-ness prompted by tne Three Mile Island accident.
The Cou-mission's implementation of our prior report recommendations, the recommendations in tnis report, anc otner cnanges tne Commission is now considering, should measuraoly traprove emergency preparedness around Rancho beco anc otner nuclear powerplants.
The California Office of Emergency Services, the Sacra-mento Municipal Utility District, and ban Joaquin County proviaed written comments on this report.
Tnese comments are incluced as appendixes II, III, anc IV.
We also ob-tained verbal comments from Sacramento County, the emergency coordinator of Amador and Calaveras Counties, the Nuclear Regulatory Commission, anc the Department or Energy.
wnere we considered it appropriate, we made changes to the text of tne report to rerlect tne written and vernal comments we rece ived.
Generally, all comments agreed with our conclu-sions and recommencations.
Some commentators said the report unculy emphasizes the worst possible accident at Rancho Seco and tnat accident's implications for emergency preparedness.
Some commentators also expressed concern about tne capabili-ties of State and local governments to finance expanced nuclear emergency prepareaness activities.
A more detaileo discussion of the comments we received appears at tne end l
of appendix I beginning on page 15.
l
-1/" Areas around Nuclear Facilities Shoula Be Better Preperea For Radiological Emergencies," EMD-7 8-110, Mar. 30, 1979.
2
B-164105 As arranged with your office, unless you publicly an-nounce its contents earlier, we plan no fitrther distribution of this report until October 15, 1979.
At that time, we will send copies to interested parties and make copies available to others upon request.
Sincerely yours, I
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Ccmptroller General of the United States 4
3
Contents Page APPENDIX I
EVALUATION OF DiERGENCY PREPAREDNESS AROUND THE RANCHO SECO NUCLEAR POWERPLANT
1 Background
1 What sort of evacuation plans have been prepared at State and local levels?
1 Has there been any consultation between State and local authorities on han-dling nuclear emergencies?
6 Have local residents been intormed of evacuation procedures in the event of an emergency?
8 Assuming the worst possible accident, would all the affected areas have adequate emergency plans?
9 Use of modeling can improve emergency preparedness 10 Conclusions 11
/
Recommendations to the Chairman, Nuclear Regulatory Commission 14 Recommendations to the Secretary, Department of Energy 14 Agency comments and our evaluation 15 II Letter from the Sacramento Municipal Utility District, dated September 10, 1979 18 III Letter from the Office of Emergency Services, State of California, dated September 6, 1979 22 IV Letter from San Joaquin County, California, dated '.ptember 5, 1979 24 V
Letter dated April 24, 1979, from Representative Robert T.
Matsui requesting a review of emergency preparedness around i
the Rancho Seco nuclear powerplant 25 i
APPENDIX I APPENDIX I EVALUATION OF EMERGENCY PREPAREDNESS AROUND THE RANCHO SECO NUCLEAR POWERPLANT BACKGROUND The Rancho Seco nuclear powerplant, operated by the Sacramento Municipal Utility Dihtrict, is located of f High-way 99 approximately halfway between the cities of Sacra-mento and Stockton.
The plant produces about 900 megawatts 1/ of electricity, over 60 percent of the District's peak demand.
State and local governments, the District, and several other organizations have developed responso plans for Rancho Seco, and the State plan has received Nuclear Regulatory Con-mission concurrence. 2/
Additionally, the Federal Government's Interagency Radiological Assistance Plan--the vehicle through which State and local governments can request Federal assistance--can be activated if a serious emergency occurs at the plant.
WHAT SORT OF EVACUATION' PLANS HAVE BEEN PREPARED AT STATE nnD LOCAL LEVELS?
In California local governments are responsible for planning and implementing evacuation, sheltering, and other protective actions.
The State's Office of Emergency Services approves local plans, coordinates response efforts between various jurisdictions, and oversees planning and implementation of response capability at the State level.
If local governments lack adeguate resources to handle a particular emergency, they can request assistance from other jurisdictions, including the State.
Similarly, if the State needs additional resources, it can obtain Federal assistance.
Regardless of which governmental level is involved, local authorities are responsible for decisionmaking related to the health and safety of populated areas outside the plant's perimeter.
1/A megawatt is 1,000 kilowatts.
r 2/While States are not required to have nuclear rowerplant emergency plans, the Commission encourages the development of such plans.
When the Commission is satisfied with a State plan, it issues a formal letter of concurrence.
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1
APPENDIX I APPENDIX I Local evacuation plans In licensing the Rancho Seco powerplant to operate in 1974, the Commission established a 5-mile radius for ener-gency planning purposes. This was the area which the Commission believed might need protective action in the event of a nuclear accident involving an offsite radiolog-ical release.
According to the 1970 census, 352 people live l
within this area.
Using this criterion, only Sacranento and San Joaquin Counties needed to develop emergency response plans.
Sacramento County, which contains most of the area within the 5-mile radius, has prepared an emergency-response plan which identifies emergency organizations, specifies eva-cuation critoria, and establishes tasks for various county departments.
Additionally, each affected department has developed procedures to be followed in case of an emergency.
Also, the county has identified, trained and eouipped radio-logical monitors who will be responsible for obtaining and communicating radiation levels to the county emergency oper-ations center.
Under the Sacramento County plan, the County Executive is responsible for making evacuation and other emergency response decisions.
In cases where this individual cannot be reached or radiation levels at the plant boundary indi-cate that immediate evacuation is necessary, county " alert of ficers" are authorized to make evacuation decisions.
These alert officers, and radiological monitors, are tied into a 24-hour countywide paging system.
No similar plan exists for San Joaquin County.
While the county does have a war-related nuclear emergency plan, it does not address specific problems associated with Rancho Seco, such as evacuation routes, radiological monitoring and contamination checkpodnts.
Sacramento County officials said their response planning is adequate to handle the small area and limited number of San Joaquin County residents located within the 5-mile radius.
In 1976 the Commission and the Environnental Protec-tion Agency established a task force to review the planning basis for offsite preparedness around nuclear powerplants.
In a November 1978 report, 1/ the task force recommended
-1/" Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," NUREG-0396, Nov. 1970.
2
APPENDIX I APPENDIX I establishing a protective zone of about 10 miles in radius for initiating immediate emergency actions, such as eva-cuation.
The task force believes this distance should be I
large enough to assure that the lower values of the Agency's q
limits to radiation exposure, called Protective Action s
Guidelines, are not exceeded outside the planning area as a result of certain types of postulated accidents.
It also believes this is the most likely area in which protective action might have to be taken for releases larger than the most serious postulated accident the Commission uses in li-censing nuclear powerplants. Such an accident, called the design-basis accident, night result in limited releases of radioactive materials outside the boundaries of a nuclear powerplant.
The task force recommended against establish-ing protective zones based on the postulated worst-case accident.
The task force based its conclusion on an analysis of the early fatalities and injuries which would be expected to occur at various distances for a spectrum of postulated acci-dents.
Their analysis showed that most early fatalities and injuries would occur within about.0 miles of a nuclear powerplant, and that rapid and ef ficient implementation of either evacuation or sheltering for areas within this dis-tance is required.
The task force determined that most postulated reactor core-melt accidents would not require these emergency actions beyond 10 miles.
The task force also determined that beyond 10 miles, early fatalities and injuries are greatly diminished.
Finally, the task force determined that although protective actions may be recuired for individuals located
.t distances beyond 10 miles, the effectiveness of various evacuation or sheltering measures used beyond this distance will not strongly influence the number of early health ef fects.
,,,j(
The Commission hac not yet acted on the task force p A. JL.
7 L,J recommendation.
j None of the local governments we contacted have devel-oped response plans for evacuating the population out to a j
radius of 10 miles from the plant.
According to the 1970 census, 6,061 people live within this area.
Although Sacra-mento County officials believe, given their experience, that they can evacuate out to the 10-mile radius with little trouble c'.
under the current plan, other counties within the 10-mile
).$s" planning zone have no formal plans and will probably have i
difficulty evacuating out to 10 miles.
Officials from all j
local governments contacted told us that additional planning
.+
l will be required for an evacuation planning zone out to 10
[,.,,..,
l miles or beyond.
'" Y"1 l
'9 l
3
'c
/
APPENDIX I APPENDIX I Y
g v.
a/
Additionally, the California Legislature is considering if f a bill which.would require a site specific study, including analysis of a major accident. If enacted, such a law nay g, g y3 extend the planning zone around Rancho Seco even further
<J '>. ~
s than the. task force-recommended 10-mile area.
State emetgency~ response plan The California Office of Emergency Services acts as
)
overall coordinator for nuclear powerplant response plans, insures that State resources are available in case of an accident at Rancho Seco, an'd coordinates activities in emer-gencies involving more than one county.
The California plan assigns tasks to various State agencies and establishes the State's emergency organization and communication methods.
Most State agencies have prepared attachments to the plan identifying resources available and establishing procedures j
to be followed in an emergency.
The State's basic plan appears to be comprehensive.
In some cases, however, standard operating procedures re-quired of State agencies are either missing or incomplete.
For example, while the Department of Health's Radiologic Health Section has numerous responsibilities, including as-sisting the counties in detecting food pathway contamination, they have no plan or standard operating procedures for accom-plishing these tasks.
Similarly, California Department of f
Transportation procedures'have been returned for completion by the State Office of Emergency Services.
Because the Department and its radiological monitors would play cri im-portant role in an accident at Rancho Seco, it is important that the Department promptly detail its emergency procedures.
Have plan's been' tested?
The Commission requires all licensees to exercise their emergency plans at least once a year with offsite emergency agencies.
Each exercise must test, as a minimum, the commu-nications links and notification procedures with these off-site agencies.
Rancho Seco has conducted annual exercises with sacramento County and California's Of fice of Emergency Services, but none has involved San Joaquin County.
- Also, i
no other counties have participated in these exercises, and Federal emergency response agencies have not been involved l
in any exercises since 1975.
Although the exercises were conducted in accordance with Commission requirements, we question their ef fective-4
APPENDIX I APPENDIX I ness.
First, all exercises since 1975 among the utility and State and local governments were held between 8:00 and 11:00 in the morning on regular workdays.
This does not insure that plant personnel working during off-shifts parti-cipate in emergency response exercises with State and local organizations, nor does it allow State and local jurisdictions to test their abilities to contact and assemble their staf fs on a 24-hour basis.
Because nuclear powerplant accidents can occur at any time, it is important to assure that all personnel periodically participate in exercises and that State and local jurisdictions can respond on a 24-hour basis.
Secondly, exercises have been too short to allow State and local agencies to completely test their emergency re-sponse capability or test all emergency components involved.
Although Sacramento County has considerable experience in emergency evacuation, comprehensive testing of its power-plant plan is still needed to insure all responsibilities are covered and communication networks work effectively.
Although Commission criteria do not require such comprehen-sive testing, such a requirement can improve emergency preparedness.
Similarly, although Federal agencies would probably be involved in the event of a serious accident, they have not participated in tests since 1975.
Finally, recent exercises indicate that communications problems exist between the plant operator and offsite of fi-cials.
The Rancho Seco emergency-response plan designates the plant emergency coordinator as the person responsible for maintaining communications with State and local of ficials.
1 This individual is also responsible for all emergency opera-tions at the plant.
According to State and local officials, plant emergency operations take precedence over communica-tion with offsite officials.
For example, in a 1978 exer-cise, the County was forced to contact the plant several times to obtain current data on the progress of the simul-ated accident.
Local officials told us that communications during the most recent exercise were even worse.
We believe the Commission can eliminate this problem by requiring util-ities operating nuclear powerplants to have one individual on the emergency response team responsible only for communi-cating with of f site emergency of ficials.
Curing our review, State and local officials were con-cerned about how to fund increases in the length of exercises and exercises held during non-duty hours.
The Commission is 5
APPENDIX I APPENDIX I currently studying funding issues related to participation by State and local governments in emergency-response activi-ties around nuclear powerplants.
In establishing more ef-fective test criteria, we believe the Commission also needs to determine the most appropriate mechanism for funding in-creased participation by State and local governments.
HAS~ THERE' BEEN' ANT CONSULTATION BETWEEN STATE AND LOCAL AUTHORITIES ON HANDLING NUCLEAR EMERGENCIES?
Considerable coordination and consultation exist among the State, Sacramento and San Joacuin Counties, and two near-4/,
by counties which could be af fected by an accident at Rancho Seco.
Moreover, emergency officials from each county appear b',1 well informed concerning their responsibilities during an f
- accident, despite the absence of a formal plan in some cases.
,J Local j urisdictions, with or without a plan, will need State, and probably Federal, assistance to effectively re-V spond to a nuclear 'powerplant accident with offsite releases.
The more significant the of fsite release, the more assist-
.i ance will be needed.
This is particularly true if radioac-tive releases require evacuation or other protective neas-
V ures beyond the current 5-mile emergency plannina zone.
' State' assistance' capabilities
~ (??
(? '
The most immediate, and probably long term, assistance will come from State agencies.
State officials recognize
~
this fact and have developed plans, alerting procedures, and communication systems to insure that activities in all af-fected counties will be coorJinated.
Also, the State has participated,' on a limited basis, with the District and Sac-ramento County in emergency exercises.
A complete test of
.he State's capabilities has not, however, been undertaken.
Areas where local jurisdictions will most likely need assistance include
--n.onitoring food pathway contamination,
--performing some radiological monitoring and interpre-tation functions, l
--monitoring contamination to fish and wildlife, i
l l
--providing additional traffic control, and i
--coordinating with Federal agencies.
l t
b I
APPENDIX I APPENDIY I With the exception of monitoring food pathway contamination, the State will probably be able to provide these services.
Commission guidelines for State nuclear emergency plans re-quire States to include methods for removing contaminated foodstuffs from the food chain, including identifying mar-keting channels in advance.
State officials are apparently unaware of this provision and, consequently, no State plans have been prepared which cover this area.
In fact, even though Federal and private sector assistance will be needed g
to insure that no contaminated food products are introduced.L. 7 into the market system, we found no plans or procedures at r,u i any level to insure effective implementation of this
,4 " P' requirement.
Fede' al assistance' capabilit'ies r
The State and local covernments can reauest Federal i
assistance in a nuclear emergency through the Interagency Radiological Assistance Plan.
Under this plan, the resources of 13 Federal agencies capable of varying degrees of radio-logical assistance can be used.
The Assistance Plan designates the Department of Energy as the agency responsible for directing the administration, implementation, and application of the Plan's provisions.
The Department's San Francisco Operations Of fice is respon-sible for coordinating the regional assistance plan.
In any major accident, however, Department headquarters would as-sume control and coordinate the Federal response.
No specific plans relating to Rancho Seco have been prepared by participating Federal agencies.
Similarly, no drills to test the capabilities of Federal agencies have been performed recently, making it difficult to evaluate the adequacy of Federal emergency response capabilities.
Although Federal officials believe they can effectively respond when called on, they agree that participating in drills can identify communications problems, test readiness capabilities, and help familiarize officials with each other's capabilities and roles in a pcssible accident.
We find it rather ironic that Federal agencies do not participate in drills while the utility, State, and local agencies are required, or a t least encouraged, to prepare detailed plans and participate in drills.
We believe Fed-j eral agencies need to develop site-specific procedures for responding to nuclear powerplant emergencies and periodically participate in drills and exercises with other of fsite emer-gency organizations.
7 i
APPENDIX I APPENDIX I In our March 30, 1979, report, we pointed out that the Federal Emergency Management Agency was to be established by April 1, 1979, to consolidate diff use Federal emergency-related organizations and serve as a focal point for all Federal emergency planning and preparedness activities.
We also pointed out that the new agency would not automatically assume Federal nuclear emergency-response planning, policymaking and coordination functions unless it rescinded the prior delegation of these f unctions to the Nuclear Reg-ulatory Commission.
In July 1979 the new agency became organizationally complete and also became a participant in the Interagency Radiological Assistance Plan.
According to Department of Energy of ficials, participants in the Assistance Plan
--including the new agency--will be reviewing and updating the Assistance Plan in the near future.
One important item on the agenda, these officials said, is to decide whether the lead agency role should be transferred from the Depart-ment of Energy to the Federal Emergency Management Acency.
HAVE LOCAL' RESIDENTS BEEN' INFORMED OF EVACUATION PROCEDURES IN'THE EVENT OF AN~ EMERGENCY?
As a result of the incident at Three Mile Island, the Sacramento Municipal Utility District sponsored several public meetings for residents living around the Rancho Seco nuclear powerplant.
Prior to that incident, neither the utility nor State and local governments had held such public meetings or distributed emergency-relatea information, nor do they have any plans to periodically do so in the future.
Also, the Commission has not required utilities to distri-bute emergency-related information to the public.
We believe that a serious weakness >in assuring the overall preparedness of nuclear eneraency-response planning results from the absence of some recuirement for periodi-cally providing the public information about the (1) poten-tial hazards present at nuclear facilities such as Rancho Seco, (2) emergency responses required to cope with a nu-clear emergency, and (3) protective measures that can be taken to minimize or avoid radiation exposure.
This infor-mation could be provided in utility bills or through public meetings conducted by utilities and local emergency organizations.
The success of emergency preparedness at Rancho Seco depends to a large extent on public reaction to the infor-l l
8 1
APPENDIX I APPENDIY I mation and directions provided if a radiological release threatens public health and safety.
Without sone prior
~
g.
knowledge of what to expect and what to do in case of a 41- ~
hancho Seco accident, the public may not react quickly or as cooperatively as the situation demands.
ASSUMING THE WORST POSSIBLE ACCIDENT, WOULD ALL'THE AFFECTED AREAS HAVE ADEQUATE EMERGENCY PLANS?
We examined the implications of two serious accident scenarios for Rancho Seco.
The first scenario describes r_
the impact of a worst possible accident and the second describes the impact of the worst accident the Commission uses in licensing nuclear powerplants.
Our worst case accident scenario for Rancho Seco is tha t of a hypothetical melt-down of the reactor core, fol-lowed by the rupture of the reactor vessel and containment building, which releases substantial amounts of radioactive material to the environment.
The amounts of radioactive material released to the environment for our scenario were based on considerations of the estimated amounts of radioac-tive materials present in the reactor core at Rancho Seco.
!!any variables such as weather conditions, wind directior, and speed, and topography of the area can affect the dispersion of radioactive material released to the envi-ronment from a nuclear accident.
Worst meteorological con-ditions, based on data collected at the Rancho Seco site, were assumed to be present at the :ime of the hypothetical release.
Based on this scenario, the Commission calculated, a t our request, the geographical boundaries of the areas which would require protective actions, if possible, under the Environmental Protection Agency's Protective Action Guides.
This calculation shows that persons within a wedge-shaped area of about 1,350 square miles will receive expo-sures in excess of the Protective Action Guides.
This area is estimated to extend out to a distance of about 150 miles.
All areas within a 150-mile radius of the plant should be used to estimate the affected area since wind direction can-not be predicted.
Although the model used cannot provide accurate results for distances greater than about 50 miles, the 150-mile figure can be used as an upper limit since very conservative assumptions were used to make the calculations.
l 9
APPENCIX I APPENDIX I We also asked the Commission to calculate the area that would be af fected by the worst accident--the design-basis accident--considered by the Commission in licensing nuclear powerplants.
Based on this scenario and similar adverse meteorological conditions, the Commission showed that the areas requiring mandatory evacuation.under the
" Protective Action Guides would be within a radial distance
~
of about 5 miles from Rancho Seco.
State and local governments do not have emergency plans covering all of the areas which would be affected in the worst possible accident.
Such an ef for t would require plan-ning and coordinating efforts of 44 counties in California and several in Nevada, with an af fected population of over 8 million people.
Obviously, such a planning effort would involve significant administrative, financial, and technical difficulties.
While existing plans do cover the 5-mile radial area calculated in the second of our two accident scenarios, they do not cover the 10-mile radial protective zone reconmended by the Commission / Environmental Protection Agency task fo,rce as a basis for emergency-response planning.
c.j g ir r *
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USC'OF MODELING CAN IMPROVE q# [
2 e.
j The Atmospheric Release Advisory Capability is a -' " I J k.2 Department of Energy system developed at Lawrence Livermore Laboratory which can assess the effects of atmospheric radi-ological releases on surrounding locations.
Sophisticated computer modeling of release data can be performed to pre-dict the effects of radioactive releases.
This system was originally developed to provide the Department of Energy with a better means of dealing with potential..ccidents at its own facilities.
A growing interest, however, is being expressed in the role such a system can play in predicting radiological contamination from accidents at commercial nu-clear facilities.
i This system is a valuable tool for assessing the l
impacts of a radiological accident.
It can process a tre-mendous aucunt of data and provide a real time perspective of contamination pathways.
Maps and other data produced by the system can aid decisionmakers in efficiently deploy-ing resources.
For example, it can aid in determinina (1) 1 where to deploy radiological monitors, (2) evacuation routes, s
10 l
t
APPENDIX I APPENDIY I and (3) probable areas where food contamination will be a problem.
Additionally, such a system could improve emer-gency response planning and training efforts.
According to Commission of ficials, the Laboratory's system is the most sophisticated such system now in existence.
State, county, and utility of ficials are enthusiastic about the system and believe it should be installed at Rancho Seco as soon as possible.
At the Commission's request, the Lawrence Livermore Laboratory recently completed a detailed assessment of the feasibility of installing the system at Rancho Seco.
According to Commission officials, Rancho Seco was selected because of its proximity to the Laboratory and the limited funds available for the assess-ment.
The assessment shows that for an initial cost of S125,000 and an annual operating cost of about S10,000 the Livermore system can be made operational at Pancho Seco.
't In view of the benefits identified in the Laboratory's A*
study, and the small cost relative to the approximately $1 c
billion cost of building a nuclear powerplant, we believe c,
the Commission should move rapidly to reauire the installa-f.
e tion of the Laboratory's computer modeling system at Rancho i.
Seco.
In addition to improving emergency preparedness at Rancho Seco, this would provide the Commission with valuable cost and benefit data on the feasibility of installing such a system in nuclear powerplants nationwide.
CONCLUSIONS
%hile the probability of a significant radiological release from Rancho Seco may be remote, it nevertheless re-mains a possibility.
There may be no advance warning of such an accident, and time for action could be short.
For this reason, a high degree of planning and preparedness must exist among all the organizations charged with emergency responsibilities.
State and local officials believe their emergency-response plans are adequate to protect the population within 5 miles of the plant boundary--the current planning zone.
If protective actions were necessary out to 10 miles, the jurisdictions involved may have considerably more difficulty insuring public safety.
Neither local, State, nor Federal agencies have plans for protecting residents out to the 150-mile limit established in our worst accident scenario.
Such an effort would require planning and coordination among 44 counties in California and several in Nevada, with an af-fected population of over 8 million people.
11
APPENDIX I APPENDIX I Although emergency planning for the worst possible ac-cident is theoretically possible, the administrative, finan-cial and technical dif ficulties involved would be signifi-cant.
Furthermore, we believe the joint task force report recommending a 10-mile protective zone established a tech-nically valid basis for of fsite nuclear energency response planning.
Consequently, we continue to believe that the Commission should rapidly establish an emergency response planning zone of about 10 miles around all nuclear powerplants.
Only limited testing has been done for emergency response plans at Rancho Seco.
While the Commission re-quires plant operators to conduct tests with offsite orga-nizations at least once a year, this requirement does not stipulate how comprehensive the tests should be or who should participate.
We believe comprehensive exercises need to be conducted periodically and the results carefully eval-uated by the Commission to determine weaknesses in the emer-gency response effort.
Similarly, recent exercises indicate that communica-tions problems exist between the plant operator and of fsite officials.
According to State and local officials, plant emergency operations take precedence over communication with offsite officials.
We believe the Commission could eliminate this problem by requiring utilities operating nuclear power-plants to have one individual on the emergency-response team responsible only for communicating with offsite emergency officials.
Residents living near the Rancho Seco plant have not been routinely informed of the potential hazards or the appropriate response in case of an offsite radioloaical release.
Because successful emergency response may depend on public reactions to the emergency situation, we believe residents around Rancho Seco should periodically be given such information.
No plans dealing specifically with Rancho Seco have been prepared by Federal agencies participating in the In-teragency Radiological Assistance Plan.
Furthermore, these agencies have not participated in drills to test their response capability.
We believe Federal agencies need to develop comprehensive nuclear powerplant emergency plans and periodically participate in drills and exercises to test the effectiveness of these plans.
12
APPENDIX I APPENDIX I Finally, we believe the Commission should move rapidly to require the installation of the Lawrence Livermore Labo-ratory's computer modeling system at Rancho Seco for two reasons.
First, use of such a systen can enhance emergency response actions, serve to improve emergency planning ef-forts, and provide for more realistic exercises.
- Second, the Commission can use the cost and benefit data obtained from experience at Rancho Seco in determining if this or similar systems should be installed at nuclear powerplants nationwide.
In our previous report on nuclear emergency preparedness we reached some of the above conclusions based on reviews of emergency preparedness around other selected nuclear power-plants and emergency planning and preparedness information provided to us by State governments.
In that report, we rec-ommended that the Chairman, Nuclear Regulatory Commission:
--Allow nuclear powerplants to begin operation only where State and local emergency-response plans meet all of the Commission's essential planning elements.
--Require license applicants to make agreements with Federal, State, and local agencies assuring their full participation in annual emergency drills over the life of the f acility.
--Establish an emergency-planning zone of about 10 miles around all nuclear powerplants as recommended by the Environmental Protection Agency / Nuclear Regu-latory Commission task force, and require licensees to modify their emergency plans accordingly.
--RegCire that the people living near nuclear power-plants be provided with information about the poten-tial hazard, the emergency actions planned, and what to do in the event of an accidental radiological release.
As a result of our recommendations and the Three Mile Island incident, the Commission is (1) reviewing its emer-gency planning and preparedness requirements and (2) consid-ering adopting a wide range of additional emergency planning regulations.
Full Commission implementation of the above recommendations, the recommendations in this report, and other changes the Commission is now considering, should measurably improve emergency preparedness around Rancho Seco and other nuclear powerplants.
13
t APPENDIX I APPENDIY I RECOMMENDATIONS TO'THE' CHAIRMAN, NUCLEAR REGULATORY COMMISSION In addition to implemcnting the recommendations in our March 30, 1979, report on nuclear emergency preparedness, we recommend tha t the Chairman, Nuclear Regulatory Commision:
--Establish criteria for exercising emergency-response plans which realistically test their effectiveness.
This might include requiring longer exercises with involvement from all emergency-response agencies and stipulating that periodic exercises be held at night and on weekends.
In developing this criteria, the Chairman should also consider the most appropriate method to defray increased costs incurred by State and local governments.
--Require that at least one member of the utility emergency-response team be assigned the sole respon-sibility of communicating with State and local emer-gency officials.
--Require the installation of the Atmospheric Release Advisory Capability computer modeling systen at Rancho Seco to enhance emergency planning and pre-paredness around that powerplant and test the system for possible use nationwide.
--Determine the feasibility and desirability of recuir-ing installation of a tmospheric release computer modeling systems at nuclear powerplants nationwide.
RECOMf!ENDATIONS TO THE SECRETARY, DEPARTMENT OF ENERGY The Federal agencies participating in the Interagency Radiological Assistance Plan will soon be revising and up-dating the plan.
One item on their agenda is to decide whether or not lead agency responsibility should be trans-ferred to the new Federal Emergency Management Agency.
At the moment however, the Secretary, Department of Energy, is the lead Federal agency official under the Assistance Plan.
Therefore, we recommend that the Secretary of Energy, in conjunction with other participating Federal agencies, l
l 14
s APPENDIX I APPENDIY I
--prepare site-specific procedures for responding to emergencies at nuclear powerplants, and
--periodically participate with other of fsite agencies in emergency exercises around nuclear powerplants.
AGENCY' COMMENTS'AND OUR EVALUATION We obtained comments on this report from the Nuclear Regulatory Commission, the Department of Energy, the Eacramento Municipal Utility District, the California Office of Emergency Services, Sacramento County, San Joacuin County, and the emergency coordinator of Amador and Calaverac Counties--counties which border on Sacramento and San Joaquin County.. Written comments provided by the Utility District, the California Office of Emergency Services, and San Joaquin County are included as appendixes II, III, and
)
IV, respectively.
The other parties provided verbal com-1 ments which are discussed below.
Nuclear Regulatory Cbmmission comments and our evaluation With one exception, Commission officials generally agreed with our conclusions and recommendations.
These of ficials pointed out that the Commission has becun prepar-ing new emergency preparedness regulations which should respond to the recommendations in both this report and our March 30, 1979, report.
Commission officials said the Con-mission currently (1) plans to complete the new regulations by January 1980 and (2) is considering a thorough review of nuclear emergency preparedness which should be completed by 1984.
Commission of ficials said that because of the number of nuclear powerplants operating and under construction and the costs associated with emergency-response exercises, Federal agencies should participate in nuclear powerplant emergency exercises once every 5 years.
Commission officials do not believe that Rancho Seco represents the best nuclear powerplant to test an emergency-response related computer modeling system, such as the sys-tem developed by the Lawrence Livermore Laboratory.
They said they would prefer to select a powerplant with a higher surrounding population density--where the system would be of maximum benefit in the event of a real emergency--and a more 15 l
l l
APPENDIX I APPEFDIX I complex surrounding terrain--which would maximize the useful-ness of test information.
These officials acknowledaed that selection of a powerplant other than Rancho Seco would add at least 6 months to the time required to install and Lenin testing the Laboratory's computer modeling system.
i While we recognize the benefits Commission officials hope to attain by selecting another powerplant, we believe early installation and testing of an emergency-response related computer modeling system is important so the Con-mission can rapidly determine whether or not to reouire such systems nationwide.
Therefore, we continue to believe the Commission should require the installation of the Atmos-pheric Release Advisory Capability system at Rancho Seco.
Lepartment of Energy comments Department of Energy officials commented only on the Federal assistance and atmospheric release computer modelina aspects of the report.
These officials agreed that the Fed-eral agencies participating in the Interagency Radiological Assistance Plan should participate to some degree--perhaps every 5 years as suggested by the Nuclear Regulatory Commission--in nuclear powerplant energency exercises.
They pointed out, however, that the Secretary, Department of Energy, cannot compel such participation from other parti-cipating agencies.
Department officials agreed that the Atmospheric Release Advisory Capability system could be tested and used at nuclear powerplants; but pointed out that many details
--such as whether or not the Department's Lawrence Livernore Laboratory should have a role--need to be worked out.
Sacramento Municipal Utility Listrict comments The Utility District's comments pertained only to the clarity and accuracy of statements in our draf t report.
The Utility District said that responsibility for of fsite communications is one of the first matters delegated by the plant emergency coordinator.
We noted, however, that there is na guarantee that the individual delegated this offsite communications responsibility will be trained in the proper commur.ications f unctions and procedures.
";he Utility District also expressed concern over our discr.ssion of the worst case accident, and stated that it cannot comment on the validity of the calculated af fected 16 l
T
APPENDIX I APPENDIX I areas without reviewing the assumptions used in the cal-culations.
California Office of Emeraency Services The California Office of Emergency Services generally agreed with our conclusions and recommendations.
The Office did, however, disagree with our statement that a comp
- e*a test of the State's capabilities has not been undertakea, pointing out that parameters for a " complete test" have i
not been established.
We continue to believe a complete test has not been undertaken, and have recommended in t!iis report that the Commission establish more comprehensivre i
test criteria.
The Office also said that the report enduly
)
emphasizes the worst possible accident at Rancho Seco and tha t accident's implications for emergency preparedness.
Other comments 1
San Joaquin County did not comment on our conclusions and recommendations, but pointed _out it would need addi-tional funding from non-county sources to finance nuclear emergency preparedness improvements.
The emergency coordinator of Amador an.i Calaveras Counties agreed with our conclusions and r>ecommendations.
1 l
l 17 I
APPENDIX II APPENDIX II esuun SACRAMENTO MUNICIPAL UTILITY oisTRICT C 6201 s street. Box 15830. Sacramento, Califomia 95413; (916) 452 3211 September 10, 1979 Mr. Louis G. Roberts U. S. General Accountino Office 1275 Market Street, Suite 900 San Francisco, CA 94103 Dear Mr. Roberts.
On August 30, 1979, you requested the staff of the Sacramento Municipal Utility District to review a draft report on emergency prepared-ness around the Rancho Seco nuclear power plant (EMD-79-103). Based L' that request we are providing the following coments:
Pace No.
Corrnents 3
The sentence "Such an accident, celled a Design Base Accident, l
might result in limited releases of radioactive materials outside the boundaries of a nuclear power plant." should be deleted.
It, in conjunction with the preceeding discussion of releases larger than a DBA, causes confusion on the part of the reader and does not contribute to the overall discussion.
4 The sentence "Furthermore, no other local jurisdictions nor Federal Government have participated in these exercises." fails to reflect the fact that:
l 1.
The State Office of Emergency Services has participated
- either directly or indirectly in each of the annual exercises involving the Sacramento County Office of l
Emergency Operations.
2.
The Department of Energy's radiological assistance t
l team physically participated in a Rancho Seco orill in 1974.
3.
The NRC Region V office is notified during major drills and participates via telephone comunications back and forth throughout the duration of the simulated incident.
4.
Annually, the local hospital (Sutter General Hospital) carries out, in conjunction with Rancho Seco, a full fledged medical contamination and over exposure drills at their facility.
GAO note:
Page numbers in this letter have been changed to correspond to page numbers in the final report.
18
APPENDIX II APPENDIX II 5
The sentence "First, all the exercises were held between 8 and 11 in the morning on regular workdays." does not reflect the following:
1.
The DOE radiological assistance team drill in 1974 was conducted starting at 5 a.m. and was completed at approximately 1 p.m.
2.
Quarterly Rancho Seco onsite drills have been conducted in off hours when minimum shift capability exists.
3.
On more than one occasion, the Sacramento County Emergency Operations Office has exercised its internal emergency notification procedures during back shifts.
Experience gained from these exercises has helped them understand the degree of delay in arrival of off duty personnel and what shortages in manpower and resources can be expected during such periods.
5 The sentence "This does not insure that plant personnel working during off shifts receive adequate emergency response experience nor does it allow State and local jurisdictions to test their ability to contact and assemble their shifts on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis."
misrepresents what actually occurs. Beside the coments listed above, which directly address the subject, I would state that at Rancho Seco each shift of a minimum of 7 people is rotated to other shifts weekly. Records have been maintained on which shifts have been involved in emergency drills and efforts are made to assure that all shifts receive equal opportunity to face emergency drill situations. It should be noted that whether a drill itself is conducted during the day or on off shif ts the procedures require the same basic type of response. While no changes in the procedures are necessary between daytime and off shift periods, it is recognized that there is a reduction in j
manpower and resources.
5 The sentences "The Rancho Seco Emergency Response plan designates the plant emergency coordinator as the person responsible for maintaining comunications with State and local officials. This individual is also responsible for all emergency operations at l
the plant." misleads the reader by suggesting that the Emergency Coordinator has so many things under his responsibility, that a good job of offsite comunications is not likely. Although the Rancho Seco Emergency plan itself is somewhat vague, in every drill conducted to date, the responsibility for coninunications is one of the first things delegated by the Emergency Coordinator to a plant operator. This individual is responsible for recom-mending which agencies should be contacted and filling out the information sheet and finally obtaining Emergency Coordinator 19
~
APPENDIX II APPENDIX II approval on both prior to initiating comunications (see
" Instructions" on page E-27 of the Plan).
5 The sentence "According to State and local officials, plant emergency operations take precedent over comunications with offsite officials." is based on experiences that have occurred during drills. What has happened in most cases is that by the time the onsite emergency is gearing down and people are being reassigned for routine operational tasks, the Office of Emergency Services and the Emergency Operations Office are gearing up and are developing needs for additional information to carry out their portion of the scenario. This confusion has often resulted in a lack of continuity of information flow. In a real emergency, comunications wuuld be established and maintained and the flow of infonnation would be more reliable and of higher quality than that encountered in past short duration drills.
8 The sentence "To date, no evacuation information has been dis-tributed to residents living ir the area around Rancho Seco."
is not accurate. Within a short time frarre after the Three Mile Island incident, members of the SMUD staff were conducting publicized meetings. The subject content of these meetings included:
1.
A description of the Three Mile Island Accident scenario.
2.
Rancho Seco design as it relates to Three Mile Island.
3.
Public health aspects of the Three Mile Island Accident.
4.
Emergency plans at Rancho Seco in the event of a major radiological accident including protective action (such as evacuation) in the 5 mile radius.
5.
Worst case (class 9) accidents, the consequences and latest proposed government emergency plan guidance (NUREG0396).
The specific dates and locations of where some of these meetings were held follows:
TMI and Emergency plan Related Meetings Date*
Location Estimated Attendance April 9 Herald 150 April 10 Galt 50 April 17 Wilton 200 April 18 Elk Grove 150 April 19 Sloughouse 150 May 1 Folsom 100 l
l 20
APPENDIX II APPENDIX II
- These specific meetings involved a SMUD nuclear engineer and health physicist. In addition, SMUD has a Speakers Eeau which conducted over 50 talks to citizens groups in the Sacramento and Rancho Seco area during the period April - June 1979. Members of the Speakers Bureau had a l
working knowledge of the Rancho Seco and Offsite Response Agency Emergency Plans.
9 The entire discussion of the NRC conducting a Rancho Seco site specific class 9 accident analysis concerns us deeply. Without SMUD review of the assumptions and modeling used in generating such numbers, we cannot accept or support their use or reliability.
This can also serve to confuse the public in light of guidance given in NUREG 0396.
10 The Rancho Seco Unit No. I Final Safety Analysis Report and related NRC Environmental Impact Statement does not support these latest calculations for a Rancho Seco desion base accident.
Again, without further explanation or SMUD review we cannot support the use or reliability of such numbers. Furthermore, the discussion suggests that existing emergency plans fail to meet even the Design Basis Accident for which they were written.
This is of course not true.
We hope the above consnents have been constructive and meaningful and that they will aid you in your final report.
Sincerely yours, A' !MW
/
D. G. Raasch, Manager Generation Engineering Department 21
APPENDIX III APPENDIX III STAft OF CAtsfotNtA EOMUNO G. 8ROWN JR Co verg, OFFICE OF EMERGENCY SERVICES POST OFFICE 6CI 9377 SACRAmtNTO. CAuf0tNIA 99473 (916) 421-4990 September 6, 1979 Mr. H. J.
D'Ambrogia Assistant Regional Manager U.S. General Accounting Office Regional Office 1725 Market Street, Suite 900 San Francisco, CA 94103
Dear Mr. D'Ambrogia:
Thank you for the opportunity to review and comment on the draft of your proposed report to Congressman Matsui on emergency preparedness around the Rancho Seco nuclear power plant.
Detailed comments are attached, but I should like to point out that the present plans around Rancho Seco and all nuclear power plants in California have been developed consistent with the existina Nuclear Regulatory Commission criteria. We acknowledge that some changes are necessary as a result of the Three Mile Island incident. This is expressed in recommendations forwarded to Governor Brown on May 20, 1979 by the NL: lear Power Plan Emergency Review Panel of which I was a member (a copy of our recommenda-tions is attached). However, to suddenly judge all existing plans and procedures on the basis of criteria which have not yet been accepted or even acknowledged by the Nuclear Regulatory Commission is unrealistic.
Furthermore, on several occasions in the Report you cite the worst-case accident at Rancho Seco and its impact on 44 counties in California and possibly affecting 8 million people. No actual scenario is defined and as far as we are concerned, the example has no relevance as a planning basis. Recognizing that it is included in the report because Mr. Matsui asked a specific question, we feel irs implied importance to emergency planning is overstated by repetition.
If you feel it should be included in the i
t 22 l
APPENDIX III APPENDIX III Report then it should be put in perspective by describing the accident parameters, their associated probabilities and the implications for emergency planning.
Generally we are in accord with your findings and we commend you for your efforts.
I trust our comments will be of assistance.
Sincerely, f
-d'i m !
W ALEX R. CUNNINGHAM Director attachment
/
GAO note:
The detailed comments attached to this letter are not included in this report, but were addressed in final preparation of the report.
23
APPENDIX IV APPENDIX IV f[gQ W 8 Ar
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$70cMTON. CALWORNI A 9s2o2 y,p Tatsamosos e 309 e 944.81t1 September 5, 1979 Mr. Louis G. Roberts, Team Leader
REFERENCE:
U. S. General Accounting Office 301542 Regional Office Suite 900,1275 Market Street San Francisco, California 94103
Dear Mr. Roberts:
Thank you for the opportunity to review your draft of the report to the !!onorable Robert T. Matsui re Rancho Seco emergency pre-paredness plans.
My comments follow:
1.
San Joaquin County is still waiting for an official detemination of the evacuation radius around Rancho Seco before developing a comprehensive response plan.
A radius change from 5 miles totally changes our planning approach.
2.
Being primarily an agricultural area, we are also quite concerned that no plans have been developed for monitoring food pathway contamination. We need criteria and guidelines so we can plan to assist with this service.
3 Your report brought the problems into focus and it appears that once again Federal and State agencies have dumped the workload on the locals.
To achieve the high degree of planning and preparedness needed, we require additional funding from some source other than our County budget.
I would be interested in a copy of your final report when available.
It was a pleasure to work with you.
Sincerely,
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Mrs.C)eoJaniw, Coordinator Emergency Services CJ/hid 24
e' APPENDIX V APPENDIX V
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Mouse of Representatiben Wasbhiston,B.C. 20515 April 24, 1979 The Honorable Elmer B.
Staats Comptroller General of the United States General Accounting Office Washington, D.C.
20548
Dear Mr. Staats:
As you may know, the Rancho Seco nuclear power plant in Sacramento is of Babcock & Wilcox design, similar to the Three Mile Island reactor which underwent a core melt-down last month.
Because of the gravity of the situation at Three Mile Island, and the potential for a similar accident at Rancho Seco --which also has a history of cooling system difficul-ties-- I am hereby asking the General Accounting Office to conduct a study of the emergency preparedness of the locali-ties surrounding that plant.
Specifically, I would like the report to address the following areas of concern:
--What sort of evacuation plans have been prepared on state and local levels? Have any of them been tested?
--Has there been any consultation between state and local authorities on handling nuclear emergencies? Are local authorities aware of the role they would be asked to play in an emergency? Could local authorities handle an emer-gency on their own, or would they need to rely on state or federal assistance?
--Have local residents been informed of evacuation pro-cedures in the event of an emergency?
--Assuming the worst possible accident under the worst meteorlogical conditions, would all the affected areas have adequate emergency plans?
l 25
APPENDIX V APPENDIX V Finally, I would like the GAO to recommend any changes or improvements they see as necessary for a comprehensive and feasable plan.
A possible generic defect in Babcock & Wilcox designed plants, NRC doubts about their safety, the history of cooling system difficulties at Rancho Seco, and the conges-ted areas surrounding the plant call for a prompt investi-gation of the emergency preparedness of nearby localities.
I would appreciate your giving priority to this matter.
Also, I wish this report for my use only, with a hold put on the public release of the report for thirty days after I receive it.
Thank you for your assistance.
Sincerely, ROBERT T. MATSUI Member of Congress RTM:r (301542) 26
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